Text

IE Insp Repts 50-324/80-39 & 50-325/80-42 on 801020-24 & 27-31.Noncompliance Noted:Failure to Include Summary of Quantities of Radioactive Effluents Released in Rept & to Establish Measures to Followup Corrective Actions
	ML20003F300
Person / Time
Site:	Brunswick
Issue date:	01/07/1981
From:	Belisle G, Fredrickson P, Ruhlman W, Skolds J, Tattersall A, Upright C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20003F289	List: ML20003F288; ML20003F295; ML20003F300;
References
	50-324-80-39, 50-325-80-42, NUDOCS 8104200543
	Download: ML20003F300 (36)
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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARlETTA ST., N.W., SUITE 3100

ATLANTA, CEORGIA 30303

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Report Nos. 50-325/80-42 and 50-324/80-39

Licensee:

Carolina Power and Light Company

411 Fayetteville Street

Raleigh, NC 27602

Facility Name:

Brunswick

Docket Nos. 50-325 and 50-324

License Nos. DPR-62 and DPR-71

Inspection at Brunswick site near Southport, NC and at Company Offices in

Raleigh, NC

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Inspectors:

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Accompanying Personnel:

D. M. Montgome y (October 24, 1980 exit only)

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SUMMARY

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Inspection on October 20-24 & 27-31, 1980

Areas Inspected

This routine, announced inspection involved 213 inspector-hours on site and

at the company offices. The inspection was conducted in areas of licensee

action on previous inspection findings; QA program review; QA/CC admin-

istration; organization and administration; personnel qualifications;

design, design changes and modifications; test and experinents; procurement;

receipt, storage and handling; records; document control; off-site review

committee; audits; off-site support staff; training; requalification training;

housekeeping / cleanliness; licensee action on previously identified open

items; and independent inspection in 0A program areas.

810.42oo593

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Summary

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Resul ts:

Of the 19 areas inspected, no violations were identified in 10 areas; 12

violations were found in 9 areas (Failure to include releases in semi-annual

report, paragraph 22.b; Failure to establish measures to assure conditions

adverse to quality are identified and corrected, paragraph 22.d; Failure to

perform corrective action on items identified during surveillances, paragraph

22.c; Failure to audit action taken to correct deficiencies, paragraph 22.f;

Failure to provide adequate QA/QC personnel training, paragraphs 5.a and

22.e; Failure to review documents by QA prior to release, paragraph 3.c.(1);

failure to review training and qualifications of facility staff, paragraph

22.g.; Failure to correctly identify audit findings, paragraph 16.b; Failure

to follow procedures, paragraphs 9.b, 9.c 10,14.a and 19; Failure to

establish neasures for design analysis, paragraph 9.a; Failure of the

Corporate Nuclear Safety Unit to review safety evaluation, paragraph 9.d;

and Failure to provide conditional release control, paragraph 12.a.)

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DETAILS

1.

Persons Contacted

Licensee Employees

**D. Allen, QA Supervisor

- H. Banks, General Manager, Harris

J. Brown, Manager Operctions

- R. Coats, Manager Nuclear Operations Administration

J. Davis, Maintenance

- W. Dorman, Project QA Specialist 00A

- T. Elleman, V. P. Nuclear Safety and Research

- L. Eury, V. P. Power Supply

- B. Furr, V. P. Nuclear Operations Department

- J. Johnson, Manager 00A

- L, Jones, Principal QA Engineer E&C QA

J.

Kaham, Foreman RC&T

M. Kesmodel, Document Specialist

R. Morgan, Plant Operations Manager

- S. McManus, Manager CNS & QAA

G. Oliver, Manager E&RC

R. Pasteur, Supervisor E&C

**A. Padgett, Director Nuclear Safety & QA

- R. Pollock, Corporate Nuclear Safety & QAA

**R. Poulk, Jr., Regulatory Specialist

C. Rose, 0QA Specialist

B. Snipes, 0QA Specialist

**A. Tollison, General Manager Brunswick

W. Triplett, Administrative Supervisor

W. Tucker, Manager Technical & Administrative

Other licensee employees contacted included technicians, operatars and office

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persorinel .

NRC Resident Inspector

J. Ouzts,

Attended exit interview at site on October 24, 1980

- Attended exit interview at Company Offices in Raleigh, NC on October 31,

1980.

The following terms are defined and used throughout this report:

Accepted QA Program

FSAR Section 13.4

CNS & QAA

Corporate Nuclear Safety and Quality Assurance

Audit

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CNSU

Corporate Nuclear Safety Unit

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CQA

Corporate Quality Assurance

CRD

Control Rod Drive

FSAR

Final Safety Analysis Report

0QA

Operations Quality Assurance

PM

Plant Modification

PNSC

Plant Nuclear Safety Committee

PSR

Pemanent Storage Room

Periodic Test

Quality Assurance

Quality Control

Safety Analysis Report

2.

Exit Interview

The inspection scope and findings were summarized on October 24 and 31,

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1980 with those persons indicated in paragraph 1 above.

At the

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conf.iusion of the first week of inspection (October 24,1980), site

personnel were briefed on the inspection activities conducted through

that week. The October 31, 1980, meeting included a summarization of

both weeks activities and was held at the Raleigh offices of the

licensee. The licensee was infomed of violations as discussed in

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paragraphs 3.c(1), 5.e, 9.a-d, 10, 12.a. 14.a

16.b, 19 and 22 b-g; the

unresolved item as discussed in paragraph 22.1; open items as discussed

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in paragraphs 5.b-e, 7, 13.a. 13.b, 14.b, 15, 18.a and 18.b; and

inspectoi- followup items as discussed in paragraphs 9.e,12.b.,18.c,

18.d, 20, 21.a and 22.h.

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Based on Region II concerns, James P. O'Reilly, Regional Director, and

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P. J. Kellogg, Reactor Projects Section Chief, met with members of the

licensee's staff at Raleigh, NC on November 13, 1980, to discuss the

results of this inspection related to recent problems in the area of

environmental releases and contamination control.

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3.

Licensee Action on Previous Inspection Findings (92701, 92702)

Items of noncompliance and unresolved items from inspection reports

discussed in paragraphs 3.a, 3.b, and 3.c were reviewed for completion.

Items 325,324/79-02-04 and 79-02-09 which had not reached their

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commitment date as of the time of this inspection were not reviewed for

completion.

a.

Inspection Report 50-325,324/79-02.

Items of noncompliance from this inspection were reviewed with

respect to the following licensee letters: Serial GD-79-654,

dated March 14, 1979; Serial 0QA-79-73, dated April 20, 1979;

Serial 0QA-79-174, dated August 24, 1979 and Serial GD-79-2762,

dated October 31, 1979.

(1)

(0 pen) Infraction (325, 324/79-02-05):

Appendix A, item D,

failure to have the segregation of Q-list items as required

and failure to have a program for identification and control

of items with limited shelf life. The inspector verified

that the limited shelf life program had been implemented.

The item remains open pending the comitment date of December

31, 1980 for completion of the new warehousing facility, at

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which time, the review of Q-list segregation will be conducted.

(2)

(Closed) Deficiency (325,324/79-02-07):

Appendix A,

item J, failure to establish bases for safety evaluations.

The inspector reviewed Revision 6 to ENP-3 issued February 2,

1979. The revision required increased emphasis on safety

analysis detennination for plant modifications.

Revision 7

to ENP-3 issued August 21, 1979 provided additional clarifi-

cation of the discussion of the bases for the safety analysis.

The inspector reviewed 11 plant modifications issued since

August 21, 1979 to verify that adequate bases were included

in the safety analysis.

(3)

(Closed) Infraction (325, 324/79-02-08): Appendix A, item B,

failure to establish housekeeping, recordkeeping and document

control programs which meet the requirements of accepted QA

Program commitments to ANSI N45.2.3, N18.7, and N45.2.9.

This item of noncompliance was partially closed in inspect 1on

reports 325/79-28, 324/79-27. The records review study has

been completed and has been evaluated.

Records and document

control programs have been implemented which meet the

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licensee's commitments. In the area of housekeeping, the

inspector verified that a satisfactory housekeeping procedure

had been implemented.

(4)

(Closed)

Infraction (325, 324/79-02-10): Appendix A, item

E, failure to have or follow procedures for calibration of

safety-related laboratory instrumentation. This item was

partially closed in inspection reports 325/79-28, 324/79-27.

Based on inspection reports 325/80-41 and 324/80-38, a

program has been developed for review of laboratory

instrument calibrations needs. This item is closed. A

violation was generated in inspection reports 325/80-41 and

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324/80-38 concerning one laboratory instrument not included

in this program.

(5)

(0 pen)

Deficiency (325,324/79-02-11): Appendix A, item H,

failure to have indication of calibration status on all

safety-related instruments as required by the accepted OA

The licensee has now implemented a computer program

Program.

to monitor calibration status for safety-related instruments.

There is no procedure in affect, that describes this

compoterized status program, delineates responsibilities for

implementation or covers how the system will actually be

The inspector reviewed an unapproved Administration

used.

Instruction (AI), entitled " Periodic Test Scheduling (PTS)

System" which described the mechanics of the computer system

but not its actual use. The CNS & QAA Section also indepen-

dently identified the inadequacies of this Al in OAA memo

dated April 22, 1980. A related area is discussed in

paragraph 16.c.

Due to the December 31, 1980 commitment

date, implementation of complete calibration program (of

which the calibration status system is a part), item 79-02-11

will be kept open.

Inspection reports 50-325,324/79-22.

Items of noncompliance from

b.

this inspection were reviewed with respect to the following

licensee letters: Serial GD-79-1971, dated August 6, 1979 and

Serial GD-79-2218, dated September 6,1979.

(1)

(Closed) Deficiency (325, 324/79-E2-01): Failure to Follow

Procedure TI-200. The inspector reviewed the licensee's

actions with respect to the two resynses. All operators who

were present during the self-study lectures have taken the

topical examination Also, TI-200, Appendix A has been revised

to define classroom training as required by 10 CFR 55,

Appendix A.

(Closed) Unresolved Item (325, 324/79-22-02):

Inadequate

(2)

definition of non-licensed personnel training guidelines.

Maintenance personnel training programs were reviewed to

detemine that training objectives and completion require-

ments were defined. The inspector detemined that these

actions have been accomplished.

(3)

(0 pen) Unresolved Item (325,324/79-22-03): Lack of a

This item

specific training plan for electrical maintenance.

remains unresolved pending resolution of the open item

discussed in paragraph 18.a and the inspector followup item

discussed in paragraph 18.c.

(4)

(Closed) Unresolved Item (325, 324/79-22-04):

Incomplete

QA/0C Departmental Training. This item b,as been closed and

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upgraded to a violation (325/80-42-05, 324/80-39-05) as

discussed in paragraph 22.e.

c.

Inspection Reports 50-325/79-28, 50-324/79-27.

Items of

noncompliance from this inspection were reviewed with respect to

the following letter:

Serial GD-79-2169, dated October 1,1979.

(1)

(Closed) Deficiency (325/79-28-01,324/79-27-01):

Failure

to include QA personnel in the review and approval of QA

related procedures. Administrative Procedures, Revision 30

dated 10/79 revised the Operating Manual Revision Fom to

include a signoff for QA review. The inspector reviewed 29

procedures that had recent revisions that required QA review

prior to issuance.

Four procedures were identified (TI-300,

Revision 4 dated 3/80; FH-11, Revision 13 dated 3/80; TI-001,

Revison 2 dated 3/80; RMI-3 Revision 0 dated 10/80) that did

not have the required review. When infomed of the inspector's

findings, the licensee performed a more extensive review and

identified 16 additional procedures that did not receive OA

approul prior to issuance.

10 CFR 50, Appendix B, Criterion VI, requires that measures

be established to control issuance of documents which prescribe

all activities affecting quality. The accepted QA Program

(FSAR), Section 13.4.3.H.1 requires that measures shall be

established to review documents prior to release to assure

quality requirements are sufficiently, clearly, and accurately

stated. The twenty documents discussed in the previous

paragraphs were issued or revised without proper QA review.

This item is closed; however, failure to perform QA reviews

is a violation (325/80-42-06, 324/80-39-06) and another

citation is being issued with this report. Similar items were

brought to the licensee's attention in our enforcement

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correspondence dated February 21, 1979, (Appendix A, Item K)

and September 4, 1979 (Appendix A, Item A).

(2)

(Closed)

Deviation (325/79-28-02,324/79-27-02):

Commitment

in licensee correspondence dated March 14, 1979, Serial GO-

79-654, to revise modification procedure ENP-3 on February 9,

1979 to require bases for the determination that the modifi-

cation did not involve an unreviewed safety question on all

modification packages. The licensee issued Revision 6 to

ENP-3 on February 2, 1979. The revision required increased

emphasis on safety analysis determination for modifications.

Revision 7 to ENP-3 was issued on August 21, 1979. This

revision provided additional clarification of the discussion

of the basis for the safety analysis. The inspector reviewed

11 modifications issued since August 21, 1979 to verify that

adequate bases were included in the safety analyses. The

inspector also reviewed the basis for the safety analyses for

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modifications79-031 and 79-165 as discussed in IE Reports

325/80-28,324/80-27 paragraph 3.a. and determined that the

bases for the safety analyses were adequate. Modification

79-083 mentioned in the same report was cancelled prior to

any work being performed. No records for this modification

could be reviewed.

(3)

(Closed) Unresolved Item (325/79-28-03, 324/79-27-03):

Certification of receipt inspectors did not meet specific

items required by paragraph 2.2.4 of ANSI N45.2.6. The

inspector reviewed TI-501, Storekeeper Training Instruction,

Revision 1 dated 10/79 and verified that the requirements of

paragraph 2.2.4 of ANSI N45.2.6 had been included. The

records of 5 personnel were reviewed to verify that the

requirements of ANSI N45.2.6 were being adhered to.

5.

QA Program Review (35701)

References:

(a)

OAI-2, Training Requirements of BSEP OA Surveillance

Personnel, Revision 0 dated 9/75

(b)

OAP-2, On-Site QA Surveillance, Revison 10 dated 6/80

(c) QAP-10, Method for Documenting Removal of Equipment

Repairs, Revision 0 dated 11/79

(d)

QAP-13, Procedure for Assigning Hold Points to Weld Data

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Cards, Revision 0 dated 11/79

(e)

QAP-15, Review of Work Requests and Authorization Forms,

Initial and Final, Revision 1 dated 2/80

(f) QAP-18, Documentation of Inspection, Revision 10 dated

1/80

(g) QAP-22, Identification of Repeated Offenders of Plant QA

Program, Revision 0 dated 4/80

The licensee had not submitted any revisions to the accepted 0A Program

(FSAR Chapter 13.4.3) since the previous inspection. The above procedures,

in addition to those referenced elsewhere in this report, were reviewed

to determine that they continued to meet the requirements of the

accepted QA Program.

Interviews were also conducted with OA personnel

and others that are responsible for the implementation of these require-

ments of the accepted 0A Frogram.

Interviews were also conducted with

0A personnel and others that are responsible for the implementation of

these requirements to ascertain that the significance of any revisions

were understood. Within the scope of this inspection activity, examples

contributing to two violations were identified (paragraphs 5.a and 5.b)

as well as four open items (paragraphs 5.b through 5.e).

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a.

Failure to Provide Adequate QA/QC Personnel Training

As indicated above, QAI-2 had not been revised since it was

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originally issued; the requirement for a biennial review did not

become part of the licensee's accepted QA Program until late 1979.

As a result, the procedure referenced material that was no longer

in use.

Further, it failed to reference items which currently

implement the Program. The current Quality Assurance Procedures

(QAPs) were not included; the current Modification Control Procedure

was not included; and the industry QA standards, while included,

were mostly draft standards not the issued versions which are now

part of the accepted Program. The above examples are illustrative

of the inadequacy; they are not all inclusive. This is an example

of failure to provide adequate training for QA/QC personnel which

is combined with otter examples listed in paragraph 22.e of this

report to collectively constitute a violation (324/80-39-05;

325/80-42-05).

b.

Revise QAP-2 to Provide Controls for PQA Items

In review of this procedure, the inspector identified a number of

weaknesses:

the procedure does not specify the action to be taken

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when an inadequate response'is received; the procedue does not

specify the action to be taken when a memorandum (sent when a

response is not received in the required timeframe) is ignored;

nor does the procedure treat the approval of changes to commitments

the same for all QA items. The first two inadequacies are considered

as direct contributors to the violation cited in paragraph 22.d of

this report, and the licensee's actions on these inadequacies are

called for in response to the citation. The remaining item allows

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a single approving manager, without benefit of additional review,

to approve changes to previous commitments for corrective action.

The licensee stated that this section (7.1.4) of the procedure

would be revised by November 15, 1980 to assure that PQA items

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received review and control in this area equivalent to that

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provided for 00A and CQA items. This item (324/80-39-23;

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325/80-42-23) is open.

c.

Revise QAP-17 to Include Additional Guidance for Determining Hold

Points

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Based on a review of the procedure and discussions with QA

Specialists and QC Technicians, additional guidance is necessary

to assure unifom consideration of all hold points. The current

procedure does not give either explicit criteria or examples of

specific hold point areas (e.g. torquing, cleanliness, tolerance

checks). These criteria and examples are delineated in ANSI

N45.2.4Property "ANSI code" (as page type) with input value "ANSIN45.2.4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. and N45.2.8, both of which are required by the licensee's

accepted QA Program.

Some of the technicians and specialists

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could not recall all of the criteria or specific examples of hold

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points when questioned by the inspectors:

this lack of training

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has been included in the citation listed in paragraph 22.e of this

report.

Since no specific examples were identified where the lack

of definitive guidance in this procedue had produced a lower than

acceptable quality in items installed in the plant (nor could

those interviewed recall any instances), and since the licensee

stated that the required criteria would be developed and represen-

tative examples would be included in the procedure, no violation

for an inadequate procedure is issued at this time. The changes

are to be made by a target date of April 1,1981 after which the

procedure will be reviewed by the NRC. This item (325/80-42-21;

324/80-39-21) is open.

d.

Revise QAP-22 to Make Procedure Workable

The accepted QA Program's commitment to ANSI N18.7 - 1976 requires

that the licensee develop a program to identify, track and correct

adverse quality trends. This procedure was developed to accomplish

this activity in one area, but, as written, it can not be implemented

for the following reasons:

it does not identify an " offender" (an

individual, a work group, a supervisor, a manager, or a department);

it does not provide a system to accomplish the responsibilities

assigned (the QA/QC specialist is required to identify repeat

offenders, but no system is available to allow or require comparison

of offenders with previous data); and no method or system is

provided to set forth a data base from which comparisons can be

made. The procedure has not been put into effect, but adverse

trends are reviewed on a general and non-statistical basis by the

QA Supervisor according to the licensee. The licensee stated that

this procedure would either be revised and made workable or

deleted and replaced with another method to accomplish the required

review of trends by November 30, 1980. This item (325-80-42-22;

324/80-39-22) is open.

e.

Differing Professional Opinions

During discussions with the QA Specialists and QC Technicians

documented in paragraph 5.c above, the inspector asked whether or

not their lack of training in the criteria for application of hold

points had produced any nonuniformity. The individuals answered,

in response to the inspector's direct question, that their decisions

on hold points were occassionally changed by their QA Supervisor

as were their decisions on whether or not a Maintenance Instruction

was required (i.e., job was outside the " skill of the craftsman"

category which does not require a procedure). The 0A Supervisor

confirmed that, when disagreements arose between maintenance and

QA/QC personnel, he resolved the conflict. While the inspector

acknowledged both the right and the obligation of the QA Supervisor

in such instances, the inspector also was concerned that such

decisions were not subject to audit by outside personnel.

10 CFR 50, Appendix B, Criterion XVII requires that records contain, as a

minimum, the results of reviews.

Since the results of the QA/QC

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Technicians review was not documented in such cases, the inspector

questioned if requirements of the licensee's accepted QA Program

were being met.

However, since no specific cases were identified

for the inspector's review, no specific violation is appropriate

at this time. The licensee stated that procedural changes to meet

the requirements of the accepted QA Program for documentation of

reviews would be effected by April 15, 1981. This item (325/80-

42-24; 324/80-39-2a) is open.

The licensee expressed concerns at the exit management meeting

that the documentaion o7 " differing professional opinions" could

be extrapolated to a position where all disagreements among

nersonnel and their supervisors would require documentation. The

inspector stated that such disagrements were not required to to

documented by this item. The licensee's position with respect to

action was disclosed in a telephone conversation between Mr.

W. Ruhlman of this office and Mr. A. Tollison, Jr., General

Manager, Brunswick Facility on November 10, 1980.

6.

QA/QC Administration (35751)

References:

(a)

FSAR Chapter 13.4

(b)

Corporate Quality Assurance Program, Part 2, Operation

and Maintenance, Revision 16 dated 6/80

(c) QAAP-1, Process for Corporate and ASME 0A Audits,

Revision 10 dated 5/80

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(d) QAP-1, Preparation and Control of Quality Assurance

Instructions and Procedures, Revision 3 dated 2/79

The inspector verified that the licensee's OA Program documents clearly

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define / identify those structures, systems, components, documents and

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activities to which the QA program applies; that procedures and responsi-

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bilities have been established for making changes to QA documents; that

the licensee has established administrative controls for 0A/QC Department

procedures; and that the responsibilities / methods have been established

to assure overall review of the effectiveness of the QA Program.

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No violations were identified during this review.

7.

Organization and Administrative (36700)

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References:

(a)

Letter E. E. Utley to T. A. Ippolito dated

November 7,1979, file NG-3514(B)

(b)

Letter T. A. Ippolito to J. A. Jones dated June 11,

1980

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The inspector verified that the licensee's onsite organization is as

described in the Technical Specifications; that personnel qualification

levels are in confomance with the Technical Specifications; and that

change:. in the organizational structure have been reported to the NRC

as required.

As the results of this review, one open item was identified. Operations

Manual, Volume 1, Administrative Procedures, Figure 2-1 does not

reflect the facility organization as required by the Technical Specifi-

cations, Figure

6.2.2-1.

Until Administrative Procedures are changed

to reflect the Technical Specification requirements, this is designated

an open item (325/80-42-14, 324/80-39-14). The licensee gave a target

date of November 15, 1980 for revision of the Administrative Procedures.

8.

Personnel Qualifications (36701)

References:

(a) Technical Specifications, Section 6.0

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(b)

Operating Manual, Volume 1, Administrative Procedures,

Section 2.0, Organization and Responsibility,

Revision 39 dated 9/80

(c) QAP-9, Welder Qualification, Revision 0 dated 1/79

(d) QAP-4, Qualification and Certification of Non-

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Destructive Testing Personnel, Revision 0 dated 1/77

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(e) Nuclear Operations Department Procedure No.-3.21,

Position Description Preparation, dated 4/80

The inspector varified by review of established administrative controls

that minimum educational, experience and/or qualifications requirements

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have been esta'511shed for the following personnel positions:

plant

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manager, manager operations, manager maintenance, manager technical and

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administrative, director nuclear safety and quality assurance, training

manager, manager environmental and radiation control, engineering

supervisor, shift operating supervisors, maintenance supervisors,

quality assurance supervisors, superintendent startup and testing,

administrative supervisor, environmental and chemistry supervisor,

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shif t technical advisors, control operaters, auxiliary operators A&B,

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plant craftsman, non-destructive testing personnel; plant health

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physics personnel, warehouse personnel, onsite and offsite quality

assurance personnel, and corporate nuclear safety unit personnel.

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The inspector reviewed the qualifications of 98 licensee personnel in

the previously listed positions. Specific inadequacies of QA personnel

are identiff ed in paragraphs 5.a. 5.e, 22.h, and 22.e.

No violations were identified as a result of this review.

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9.

Design, Design Changes and Modifications (37700, 37702)

References:

(a) Corporate Quality Assurance Program, Part 2, Operation

and Maintenance, Section 3, Modification Control,

Revision 16 dated 6/80

(b)

ENP-3, Q List Modification Procedure, Revision 10 dated

11/79

(c) Operating Manual, Volume 1, Administrative Procedures,

Paragraph 11, Plant Safety Revision 39 dated 9/80

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(d) OG-8 Guidelines for Preparation of Mechanical Jumper and

Abnormal System Operation Procedure, Revision 1 dated

3/80

(e)

Internal Interface Department for Brunswick Steam

Electric Plant Work, dated 6/80

(f) BSP-2, Site Comunications, Revision 0 dated 8/80

(g) QAP-16, Plant Modification Review Procedure, Revision 0

dated 11/78

The inspector reviewed the licensee's procedures for conducting plant

modifications to determine the following have been accomplished:

procedures have been established for control of plant modifications;

procedures and responsibilities for plant modifications have been

established; methods, procedures and responsibilities for independent

design verifications are established; design interfaces are established

'

in writing; responsibility for fir.:1 approval of plant modifications is

delineated; review of changes to plant modifications is comensurate

.

with the original design review; administrative controls for plant

l

modifications have been established; administrative controls and

responsibilities have been established to assure that plant modifi-

cations are incorporated into plant procedures, operator training and

updated drawings; administrative controls require collection and

storage of design documents and records which provide evidence that the

design and review process was performed; controls require that implemen-

tation of plant modifications be in accordance with approved procedures;

post-modification acceptance testing be performed per approved test

procedures and the results evaluated; responsibility has been assigned

for identifying post-modification testing requirements and acceptance

criteria; responsibility and method are established for reporting plant

modifications to the NRC in accordance with 10 CFR 50.59 and admini-

strative controls of similar scope and content have been established

l

for temporary modifications (lifted leads and jumpers).

l

L

.

,

12

1

The following plant modifications were reviewed to verify implementation

of established controls:

80-4

CAC Valves Isolation Overide, declared operational 7/80

-

80-14

MSIV Limit Switch Upgrade, declared operational 7/80

-

79-272

Reactor Coolant Recirculation Test Connection Removal,

-

declared operational 11/79

79-271

Reactor Coolant Recirculation Pump Bearing Holder

-

Assembly Modification, declared operational 11/79

79-164

Reactor Vessel Level Transmitter Calibration, declared

-

operational 11/79

79-57 CRD Return Line Themal Sleeve Removal declared

-

operational, 7/79

As the results of this review, two violations (paragraphs 9.a and 9.d),

two items contributing to a violation (paragraphs 9.b and 9.c) and one

inspector followup item (paragraph 9.e) were identified,

a.

Failure to Establish Measures for Design Analysis

10 CFR 50, Appendix B, Criterion III requires measures to assure

that applicable regulatory requirements are translated into

procedures and instructions. The accepted 0A Program (FSAR)

Chapter 13.4.3.E.4 states thtt suitable design analysis, as

appropriate, will be perfomed where applicable. ANSI N45.2.11-

1974Property "ANSI code" (as page type) with input value "ANSI N45.2.11-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as endorsed by the accepted QA Program, Section 4.2 also

I

requires design analysis to be perfonned. The inspector verified

l

by direct questioning of plant personnel that guidelines have not

been established to require design analysis and no program exists

j

for in-plant design analysis.

Failure to establish measures for

j

design analysis is a violation (325/80-42-10, 324/80-39-10).

b.

Failure to Follow Procedure - Update Plant Procedure

Plant Modification 79-272, declared operational 11/79, removed

valves VI, 2, 7 and 8 from the reactor recirculation system.

Tracedure OP-2, Reactor Recirculation System, Revision 25 dated

7/80, has not been updated to reflect this modification change.

In a recently completed valve line-up, these valves were noted on

a sheet as "not installed" by personnel performing the valve

line-up. This irailure to update procedures as required by reference

(b), section 3.20 and reference (a), section 3.5.5.3 is collectively

combined with paragraphs 9.c,10,14 and 19 to constitute a

'

violation (325/80-42-09,324/80-42-09).

--

.

,

_

.

.-

. _ - .

.

-.

.

'

,

l

I

.

,

13

l

c.

Failure to Follow Procedure - Identify Drawings Undergoing Revision

As required by reference (b), Section 3.20, drawings FP-50554, FP-

9527-5757, FP-50530, FP-5992 and LL-90046 sheets I 5 & 6 were

l

required to be identified as undergoing revision due to modifi-

cations 80-14,79-271, 79-164, 79-57 and 80-4 respectively.

None

of these drawings were identified as required. This failure to

identify drawings undergoing revision due to modifications is

combined with paragraphs 9.b, 10, 14.a and 19 to collectively

constitute a violation (325/80-42-09, 324/80-39-09).

I

d.

Failure of CNSU to Review Safety Evaluation

Technical Specification 6.5.3.3.a requires review of written

safety evaluations of changes in the facility as described in the

SAR by the CNSU. Modification 79-57 required CRD return line

thermal sleeve removal.

An FSAR change was submitted with this

modification package. The CNSU did not review the safety analysis

as required by Technical Specification. This failure to review

the safety evaluation of changes in the facility as described in

the SAR constitues a violation (325/80-42-11) and is applicable to

Unit 1 only.

e.

Outdated References in Operating Manual

Reference (c), Sections 11.6 and 11.6.2.E.2, references Section 3

Volume XI for controls to be used for jumper and wire removals.

Section 3. Volume XI was deleted 3/77.

Until the appropriate

references are incorporated into these sections of reference (c),

this item is identified as an inspector followup item

(325/80-42-26,324/80-39-26).

10. Test and Experiments (37703)

Reference:

(a) Operating Manual, Volume 1, Administrative Procedures,

Revision 39 dated 9/80

The inspector verified that a fonnal method has been established to

handle requests or proposals for conducting special procedures; that

provisions have been made to assure special procedures will be performed

in accordance with approved written procedures; that responsibilities

have been assigned for reviewing and approving special procedures; that

a formal system exists to assure that special procedures will be

reviewed to detennine whether they are described in the FSAR; and that

responsiblities have been assigned to assure that a written safety

evaluation will be developed for each special procedure not described

in the SAR to assure that it does not involve an unreviewed safety

question or a change in the Technical Specifications.

The inspector reviewed the following special procedures for conformance

to the above requirements:

_.

. - _ _

_

.

,

14

'

,

SP-79-37

Safety-Related Drywell Equipment Electrical

-

Terminal Solution and Inspection

SP-79-33A-D

24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Diesel Generator Load Test

-

SP-80-9

Jet Pump Visual Inspection

SP-80-22

Scram Discharge Volume Scram Testing

-

SP-80-7

LPRM Replacement

-

l

SP-80-02

Local Leak Rate Testing of Containment Isolation -

-

l

Water Test

SP-79-38

Checkout of Uninterruptable Power Supply (UPS)

-

l

As the result of this review one item contributing to a violation was

l

identified. Technical Specification 6.8.1 require that procedures be

implemented.

Reference (a), Section 5.1 requires a period of time to

be specified for use of special procedures.

No period of time for use

was identified on Special Procedures SP-79-37, -33A-D, -38, -80-2, -9

and -22. This failure to follow procedure is combined with other

l

examples as discussed in paragraphs 9.b, 9.c,14.a and 19 to collectively

l

constitute a violation (325/80-42-09; 324/80-39-09)

i

11.

Procurement (38701)

i

References:

(a) ANSI N45.2.13-(Draft 2, Rev 4 April 1974)

(b) 0QA-3, Qualification of Suppliers of Q-List Items,

Revision 5 dated 8/80

(c)

Qualified Suppliers List, Revision 16 dated 10/80

(d) QAP-12, Procedure for the Review of Purchase

Requisitions and Q-List Purchase Orders, Revision 3

dated 3/80

(e) A0AS-6, Audit Administration, Revision 7 dated 10/80

(f)

AQAS-7, Quality Assurance Audits, Revision 5 dated 11/79

(g)

VQA-5, Preparation and Maintenance of Approved Suppliers

List, Revision 2 dated 6/80

The inspector reviewed the licensee's QA Program relating to control of

procurement activities to verify conformance with regulatory requirements,

commitments in the application, and industry guides and standards. The

inspector reviewed the following Purchase Orders:

- .-.

. -.

-.

.

15

P.O. A 64130

Globe Valves

P.O. 701692

Globe Valve

P.O. 712296

CRD Parts

P.O. 719922

Pressure Indicator

P.O. 725418

Dropping Resistor

P.O. 726052

Cable

P.O. 730478

Velan Valve Parts

P.O. 731596

Test Instruments

P.O. 731607

Diaphragm Spare Parts

P.O. 734804

Check Valve Spare Parts

P.O. 735772

Blanket Purchase Order

The inspector also verified the establishment and utilization of an

approved suppliers list.

In fact, there are two lists - one for

operation , and one for construction. The lists are maintained separate

but the Engineering and Construction QA Section performs the vendor

surveys for both lists. A problem existed with reference (g) in that

no correlation had been established between the expiration date on the

approved suppliers list and the annual evaluation in use to update the

list. A change was made to reference (g) prior to the end of the

inspection to correct this problem.

No violations were identified as the result of this review.

12. Receipt, Storage, and Handling (38702)

l

References:

(a) ANSI N45.2.2-1972

(b)

NRC Regulatory Guide 1.38-March 1973

(c)

Storekeeper Instruction: SK-1 Material Requisition and

Reorder Procedures and Responsiblities

(d)

Storekeeper Instructior

SK-2 Receiving

(e)

Storekeeper Instruction:

SK-3 Storage

(f)

Storekeeper Instruction:

SK-4 Issuing of Material and

tools

(g)

Storekeeper Instruction:

SK-5 Packaging of Q-list Items

l

"

.

16

(h)

Storekeeper Instruction:

SK-6 Handling

(i)

Storekeeper Instruction:

SK-7 Shipping

(j)

Storekeeper Instruction:

SK-8 Housekeeping

(k) Training Instruction: TI-501 Storekeeper Training

(1)

0AP-20, Receiving Inspection of 0-List Material and

Components, Revision 0 dated 12/79

t'

(m) Maintenance Procedure MP-6, Operation of Cranes and

Use/ Inspection of Slings, Revision 5 dated 6/80

The inspector reviewed the licensee's QA program for the receipt,

storage and handling of equipment and materials to verify that it is in

-

confomance with Regulatory requirements, comitments in the application,

industry guides and standards.

As the results of this review, one violation (paragraph 12.a) and one

inspector followup item (paragraph 12.b) were identified.

a.

Failure to Provide Conditional Release Control

10 CFR 50, Appendix B, Criterion XV, requires that measures shall

be established to control the materials and parts components which

do not confom to requirements in order to prevent their use. The

accepted QA Program (FSAR), Chapter 13.4.3.Q.1 requires that

measures and procedures shall be established to control identiff-

cation, documentation, segregation, review, disposition, and

notification of the affected organization of nonconfomances of

l

material, parts, components, or services to prevent inadvertent

l

use or operation. ANSI 45.2.2-1972, as endorsed by the accepted

QA Program, Section 5.3 requires a statement documenting authority

and technical justification for conditional release of an item for

installation.

Reference (e), Section 4.5, defines conditional release and states

that if a nonconformance can be corrected prior to or after

installation or if the equipment is urgently needed, the equipment

I

can be conditionally released. The QA Supervisor must also

approve the conditional release.

However, there are no requirements

in the program to provide the technical justification for a

conditional release. This failure to provide conditional release

l

control is a violation (325/80-42-12, 324/80-39-12).

b.

Include Handling of Defective Rigging Equipment In MP-6.

Section II.D and II.E of reference (m) states that if an inspection

of a sling or hoist reveals any deficiency, remove the equipment

from service or consult with the maintenance foreman. This

__

. . .

.

.-

.

,

17

.

procedura does not indicate what happens to a deficient piece of

_

equipment when it is " removed from service" or when the maintenance

foreman is notified.

Measures must be established to ensure

'

deficient equipment remains out of service until repaired or

replaced or the deficient equipment is in someway identified as

deficient. This will be identified as an inspector followup item

(325/80-42-27,324/80-39-27).

.

13.

Records (39701)

References:

(a)

RMI-1,' Capture and Indexing of Correspondence and Plant

'

Records, Revision 9 dated 10/80

(b) RMI-2, Records Receipt and Storage, Revision 0 dated

10/80

The inspector reviewed records management instructions to verify that

provisions had been made to maintain various types of quality records,

and that responsibilities had been assigned to carry out these records

storage requirements.

Records storage controls were also reviewed to

ensure that they described the storage facility, the filing system

used, and methods of receipt, handling and disposal of these records.

The inspector, utilizing the records storage procedure, verified the

[

implementation of these procedures. The following records were selected

!

by the inspector for verification of indexing, retrievability and

storage.

1)

PNSC Minutes79-192

i

2)

PNSC Minutes 78-40

3)

QC Inspection Report 706

4)

Purchase Order 647113

5)

PM 77-351

t.

6)

PM 78-53

7)

LER (R.O.) 2-79-104

8)

P.T. 1.1.7P, 8/10/78

9)

P.T. 3.1.12, 5/79

i

10) LER (R.0) 2-80-42

11)

Control Operators Daily Surveillance Requirements, 11/11/78-11/17/78

12)

Drawing, FSP 2214, Sheet 128, Rev 3

.

-

.

_

18

As a result of this review, two open items were identified as discussed

in paragraphs 13.a and 13.b.

a.

Construction Records Not Controlled by Written Procedures

t

The licensee has a set of initial construction microfilm records

which are being properly stored in the PSR with another copy in

I

the library. Although actual control is adequate, there is no

records procedure which references the existence or control and

.

handling of this microfilm data. The licensee has committed to a

l

completion date of November 15, 1980 for including the construction

records into the records management program. Until the licensee's

actions have been completed and reviewed, this item remains open

(325/80-42-19,324/80-39-19).

b.

Records Generated Prior to New Index System Do Not have Documented

Index

A new records indexing system was initiated on 3/31/80 and is

documented in Reference (a).

All records generated since 3/31/80

l

have been filed under the new system, but records generated prior

to this date are still filed under the old system, with no procedure

'

in effect to differentiate the two indexing systems or no action

program in effect to change the older records over to the new

system. The licensee has committed to a completion date of

November 15, 1980 for properly documenting the records which are

now indexed under the previous system.

Until the licensee's action have been completed and reviewed this

item will remain open (325/80-42-18, 324/80-39-18).

14. Document Control (39702)

References:

(a) RMI-3, Reproduction, Distribution and Accountability of

Plant Documents, Revision 0 dated 10/80

(b) RMI-4, Plant Library, Revision 0 dated 10/80

(c)

ENP-3, Q-List Modification Procedure, Revision 10 dated

l

11/79

1

The inspector reviewed various records management instructions to

verify that proper controls have been established for drawings, technical

manuals, technical specifications, FSAR's and procedures affecting

quality.

In particular the inspector selected several documents to

verify the proper handling per the applicable procedures, to verify the

accuracy of the master index for the various documents and to verify

the proper updating of controlled drawings and other documents. The

selected documents reviewed were from the following types:

4 procedures,

1 Unit Technical Specifications, 4 technical manuals and 10 drawings.

.

-

.

19

The inspector also selected several Drawing Revision Sheets for verifi-

cation of drawing updates.

As a result of this review, one example contributing to a violation and

one open item were identified as discussed in paragraphs 14.a and 14.b.

a.

Failure to Follow Procedure - Stamping of Drawings

Reference (a), paragraph 9.0 requires stamping of drawings affected

by PM's in order to identify those prints being revised. The

inspector reviewed 3 Drawing Revision Sheets, being maintained in

the PSR, covering 3 PM's:

PM 79-065, PM 79-094 and PM 79-126.

One drawing from each PM was chosen to verify that the stamping

requirements of Reference (a) were being conducted on controlled

copies.

Contrary to the above requirements, of the 3 selected, 2

drawings (LL9364-88, PM 79-065 and LL9252-30, PM 79-094) were not

stamped in the Drawing Control Center and 1 Drawing (LL9252-30)

was not stamped in the library. This failure to implement Reference

(a), collectively with paragraphs 9.b, 9.c,10 and 19, constitutes

a violation (325/80-42-09, 324/80-39-09).

b.

Master Drawing Index Does Not Include Engineering on Distribution

Certain United Engineering prints are now being received at

Brunswick as aperture cards, whereas their previous revisions were

in print fonn.

As these aperture cards are received, distribution

is being made to the Engineering Section, which was not on

distribution when the drawings were in print fonn. The inspector

noted that for two aperture card drawings (LL9113-2, 4, 6 and

LL92072), master index cards had not been changed to show distribution

to the Engineering Section. The licensee has committed to a

completion date of October 31, 1980 for updating the master index

for those aperture card drawings now being sent to engineering.

Until the licensee's actions have been completed and reviewed,

l

this item remains open (325/80-42-17, 324/80-39-17).

i

15.

OffSite Review Committee (40701)

References:

(1) Technical Specifications Section 6.0

(2)

CNSP-1 Procedure for Conducting the Independent Off Site

Nuclear Safety Review Board as Required by the Federal

Regulations, Revision 3 dated 5/80

(3)

CNSI-1 Organization and Training, Revision 3 dated 5/80

(4)

CNSI-2 Program Control, Revision 4 dated 5/80

(5)

CNSI-3 Subjects to be Reviewed, Revision 3 dated 8/80

d

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.

20

(6) CNSI-4 Review, Documentation and Communications,

Revision 6 dated 8/80

(7) CNSI-5 Handling and Storage of Confidential Material,

Revision 1 dated 5/20

(8) CNSI-6 Selected Review of PNSC Items, Revision 0 dated

8/80

(9) CNSI-7 Selection of Nuclear Safety Items for In-Depth

Evaluation Revision, Revision 2 dated 5/80

(10) CNSI-8 Collection, Storage and Maintenance of CNS OA

Records, Revision 1 dated 5/80

The inspector verified the following aspects of the CNSU activities:

the procedures governing the CN50 activities are in accorfance with

Technical Specifications; the membership and qualifications are as

required by the Technical Specifications; and persons performing

reviews had the necessary expertise in the areas being reviewed.

The inspectcr verified the following CNSU review of records:

IE

Inspection Reports - 50/325, 324/79-02, 50-325, 324/79-22; 50-325/

79-29; 50-324/79-28; QA Audits - 0AA/21-14, QAA/170-2, and QAA/21-15;

Bimontnly Report of Nuclear Safety Concerns and Recommendations, July

1979-April 1980; PNSC minutes 7'.1, 712, 720, 722, 724, 725, 729, 713,

716, 718, 683, for H. B. Robinson; PNSC minutes 80/55A, 70, 71, 73, 75,

78-86, 87-98, 99, 998, 100-104, 107, 112, 54, 558, 57-69, 72, 76 and 77

for Brunswick; plant modifications M-557, 520, 418, 529 and 550 for H.

B. Robinson; plant modification 77-268D,79-276, 80-93,78-164, 79-275,78-165, 78-260,77-225 and 77-256 for Brunswick; IE Circulars 80-04 and

8C-07; IE Bulletins 80-07 and 80-13; Special Procedure 80-22; LER's

1-80-21, 8, 16, 1-79-113, 76, 106, 60, 1-80-66, 52, 28, 31, 2-80-26,

29, 26 supplement, 12, 24,14, 2-79-26, 89 and 81; and 24 Hour Notifi-

cations 1-80-61, 2-80-46, 47, 31 and 33.

As the results of this review one open item was identified ir.volving

clarification between CNSU procedures and Technical Specifications.

CNSU procedure CNSI 3, Section 2.8.2 provides guidance for the Principal

Engineer-Nuclear Safety to select items from the PNSC minutes for

review and verification of PNSC effectiveness as described in CNSI 6.

CNSI 6, Section 2.1.1.1 states that the Principal Engineer - Nuclear

Safety screens PNSC minutes and selects items that appear to have

safety implications. He then assigns them to the unit engineers for

further investigation and the normal three-part review. The Technical Specifications, Section 6.5.3.3.f requires reports and meeting minutes

of the PNSC to be reviewed by the CNSU.

Section 6.5.3.2.d also requires

reviews by three qualified persons. The Technical Specifications do

not allow for review of only selected or screened items of safety

implications from the PNSC minutes.

No violation is issued for ia-

.

21

i

edequate procedure since no inadequate reviews (less than three qualified

persons) were identified; however, clarification is needed to prevent

the possibility of an inadequate review. The licensee has given a

target date of November 30, 1980, for clarification of these procedures.

Until these procedures are clarified to prevent the possibility of an

inadequate review, this is identified as an open item (50-325/80-42-20,

50-324/80-39-20).

16. Audits (40702,40704)

References:

(a) QAAP-1, Process for Corporate and ASME QA Audits,

Revision 10 dated 5/80

(b) QAAI-1, Instruction for Preparing, Distributing and

Maintaining the Corporate QA Audit Documents and the

Corporate QA Program, Revision 12 dated 10/80

(c) Technical Specification, Section 6

i

a.

Program Review

The inspector reviewed the audit program to verify that:

the

scope of the program had been defined and was consistent with

requirements and cormitments; responsibilities had been assigned

l

for the management of the program, determining qualification of

!

auditors, preparing the aucit schedule, issuing the audit reports,

and periodic review of the audit program; administrative channels

exist for taking corrective action; and the audited organization

is required to respond to audit findings.

No violations were identified as the results of this review.

b.

Program Implementation

!

Three audits of the 3runswick facility were selected for review:

l

Audit #

Dates of Audits

QAA 21-13

11/5-9/79

QAA 21-14

3/10-14/80

QAA 21-15

7/14-18/80

The inspector noted that auditors were qualified to perform these

audits and that problem areas were being identified with followup

i

action from the auditing activity.

l

As a result of this review, one violation was identified involving

l

failure to correctly identify audit findings.

Reference (a)

defines a finding (nonconfomance) as "A deficiency in charac-

j

_

_ __

_ _ _ _

. .

.

.- - ._ - --

.

._

_ - - - -

-

.

1

22

teristic,.dacumentation or procedure which renders the quality of

i

!

an item unacceptable or indeteminant." This procedure also

!

defines, in part, a concern as"...an isolated deviation which does

l

not violate specific quality requirements...". The CNS and QAA

Section perfoms its audit function utilizing reference (a),

'

i

Contrary to the above, during audits QAA/21-13 and QAA/21-14, two

nonconfomances were incorrectly identified as concerns.

In

QAA/21-13, Concern 5, the audit team identified that" a master

'

.

surveillance schedule has not been estan11shed as described in

!

Section 5.2.8 of ANSI N18.7-1976 and Section A.2 of NRC Regulatory

Guide 1.33-1972". Although this concern was followed up in a QAA

i

memo dated April 22, 1980, continued as a concern in QAA/21-14 and

a portion of the concern was upgraded to nonconfomance in QAA/21-15,

the initial item in QAA/21-13 was addressed as a concern when

j

reference (a) specifically identified it as a nonconfomance.

In

QAA/21-14, Concern 3, the audit team noted that"...a commitment

was made for the PNSC to review these (QAP) changes in the accepted

'

i

QA Program by March 1, 1980.

Contrary to this commitment to NRC,

audit of the PNSC Meeting Minutes indicate that the required

reviews have not been made."

In fact, an extension of this item

,

had been granted to June 1,1980 by the NRC but was not mentioned

in QAA/21-14. This item was noted as completed in QAA/21-15, but

i

the reviews had been completed after the June 1,1980 commitment

dates. The inspector did not obsern a trend toward downgrading

nonconfomances, nor the lack of followup on nonconfomances or

concerns. The above two examples of failure to follow procedure

constitute a violation (325/80-42-08, 324/80-39-08).

A similar

.

item was brought to the licensee's attention with respect to the

Shearon Harris facility in NRC enforcement correspondence dated

June 3, 1980.

17. Offsite Support Staff (40703)

,

References:

Corporate Quality Assurance Program, Part 2, Operations and

Maintenance, Revision 16 dated 6/80

'

The inspector reviewed the reference document to verify that the

licensee has identified positions and responsibilities in the company

offices to perfom the offsite function of Quality Assurance, Design,

Engineering, Procurement and Construction. The inspector interviewed

individuals in each functional area at the managerial level and two

levels below.

During the interview, the inspector verified that each

individual was qualified for his position and was aware of his responsi-

bilities and authority in relation to the company organization and the

Quality Assurance Program.

No violations were identified as the results of this review.

l

~ . - . - - , . - . - . ,

- -

. -

- . - . - . -

- . - . - - - -

-

- - - -

- .

.

-

.

23

18. Training (41700)

References:

(a) TI-001, Brunswick Steam Electric Plant Training,

Revision 2 dated 5/80

(b) TI-100, Retraining and Replacement Training for Non-

Licensed Operating Personnel, Revision 1 dated 3/77

(c) TI-101, On the Job Training for I&C Technicians,

Revision 2 dated 5/80

(d) TI-102, On the Job Training for Pechanics, Revision 2

dated 5/80

(e) TI-103, On the Job Training for Radiation Control and

Test Technicians, Revision 3 dated 6/80

(f) TI-104, Related Training and on the Job Training for

Auxiliary Operators, Revision 1 dated 6/80

(g) TI-105, Related Technical Training and on the Job

Training for Electricians, Revision 0 dated 5/80

(h) TI-300, General Employee Training, Revision 4 dated 5/80

(i) TI-201, Brunswick Plant Operator Replacement Training

Program, Revision 2 dated 10/77

(j) TI-202, Replacement Training for Senior Operator

Personnel, Revision 0 dated 3/77

'

The following portions of the Brunswick training program have been

revised since the last inspection and were reviewed to detemine

conformance to regulatory requirements and comitments: general

employee training and replacement and retraining programs for mechanics;

instrument and control technicians, auxiliary operators and electricians.

The following areas were reviewed with respect to implementation of the

respective training program: general employee training; general

employee retraining; temporary employee training and on-the-job training

for auxiliary operators, mechanics, instrument and control technicians

and radiation control and test technicians. Training records were

reviewed for two individuals in each of the above classif' cations to

verify that the training program was being conducted as described.

Additionally, fourteen employees were interviewed to ascertain that the

training as described in the training records was actually completed.

As a resuit of this review, two open items, discussed in paragraphs

18.a and 18.b, and two inspector followup items, discussed in

paragraphs 18.c and 18.d were identified.

24

Training Programs Do Not Include Necessary Subjects

a.

The current training programs for mechanics, instrument and

control technicians and electricians do not include training or

retraining in the area of administrative controls and procedures

and the accepted QA Program. The licensee has committ'ed to a

completion date of Jur.e 30, 1981 for the incorporation of these

requirements into the Program. Lail the licensee's action have

been completed and reviewed, this items remains open (325/80-42-15,

324/80-39-15).

b.

General Employee Training Does Not Provide Criteria for Satisfactory

Completion of Training

The general employee training program as described in reference

(h) does not include criteria for satisfactory completion of

training and subsequent badging. The licensee has committed to a

completion date of December 31, 1980 for incorporation of the

required criteria for successful training completion into the

training instruction. Until the licensee's actions have been

completed and reviewed, this item remains open (325/80-42-16,

324/80-39-16).

c.

Evaluate Upgraded Training Program

.

The present program for training and qualifying mechanics,

instrument and control technicians and electricians has not been

implemented sufficiently to allow evaluation of the retraining

This area will be reviewed after the program is more

program.

fully implemented and thus is identified as an inspector followup

item (325/80-42-28, 324/80-39-28).

i

d.

Evaluate General Employee Retraining

!

Due to previously identified weaknesses, the general employee

training program was revised.

At the present time retraining is

'

commencing for station personnel. The method and scheduling of

this program appear to be satisfactory but until the scheduled

retraining is completed, the program can not be evaluated. This

area will be reviewed after scheduled retraining has been more

fully conducted, and this is identified as an inspector followup

item (325/80-42-29, 324/80-39-29).

19. Requalification Training (41701)

Reference:

1)

TI-200, Brunswick Plant Operator Retraining Program,

Revision 4 dated 7/79

As the requalification program had been revised since the last

inspection, the present program was reviewed to determine confomance

to the regulations and commitments.

.

25

The training records of three senior reactor operators including one

non-shift operating engineer and one reactor operator were reviewed to

determine if the required training had been completed.

Additionally,

the training record of one senior operator who had been absent from

licensed duties for greater than four months was reviewed to detennine

that the required accelerated requalification program had been satis-

factorily cbapleted. One senior reactor operator ard one reactor

operator were interviewed to determine if the training records accurately

reflected the training completed.

Also during this inspection, the

'

inspector attended one of the series of requalification lectures being

conducted.

As a result of this review, one example contributing to a violation was

identified involving failure to follow procedure requiring notification

of training supervisor.10 CFR 50, Appendix B, Criterion V, requires

that activities affecting quality are to be accomplished in accordance

with prescribed procedures.

Procedure ENP-3, Q list Modification

Procedure, Revision 10 dated 11/79, paragraph 3.20 requires that the

Project Engineer distribute the " Drawing Notification Sheet" to the

Training Super /isor when a plant modification is made operable. During

interviews with training subunit personnel, the inspector determined

that the Training Supervisor was not being notified that plant modifi-

cations were being placed in an operable status. This failure to

follow procedure ENP-3 when combined with examples as discussed in

paragraphs 9.b, 9.c,10 and 14.a collectively constitute a violation

(325/80-42-09,324/80-39-09).

20.

Housekeeping / Cleanliness (54701)

References:

(a) ANSI N45.2.3-1973

(b) ANSI N18.7-1976

(c) Operating Manual, Volume 1, Paragraph 12, Housekeeping,

Revision 39 dated 9/80

The inspector reviewed the licensee's housekeeping / cleanliness program

to ascertain whether the licensee is implementing adequate housekeeping /

cleanitness controls to assure the quality of safety-related systems is

not degraded.

As the results of this review one inspector followup item was identified.

During a tour of the plant the inspector observed the following:

Radiation tape tied to a fire extinguisher in order to support a

-

radiation control sign. This made any required use of the fire

extinguisher difficult.

Diesel generator building door 007 secured open by tying the door

-

to a fire hose reel support. To do this, the fire hose had to be

taken down from the support and would be difficult to reel out

properly if needed.

.

_ _ -

-__.

..

. - . _ = - _ ~ _

_

.. -

- - . - .-. . ..-

_ _ . - -

_

.

1

26

Diesel generator lube oil was running down the supports under the

-

'

!

diesel generator room.

Not enough lube oil was present to generate

a fire hazard but, if lef t uncorrected, it could present a hazard

in the future.

,

!

The above three items are identified as an inspector followup

i

item (325/80-42-25, 324/80-39-25).

,

l

21. Licensee Action on Previously Identified Open Items (92701). All open

items from the following reports were reviewed for completion, except

item 79-02-20 which has not reached its commitment date.

a.

(Closed)

Item (325, 324/79-02-12):

Inclusion of consumable /

l

expendable item on the "Q"-List".

Plant Operations Manual, Volume

i

XI, Book 2, "Q-List", Revision 13 dated 10/80 now includes a

i

Supplement I which is the consumable / expendable "Q-List".

However,

all listed items are not yet required to be in full compliance

j

'

l

with the QA Controls; therefore, a new inspector follow item

!

(325/80-42-31,324/80-39-31) will be tracked and reinspected after

!

the target completion date of April 1,1981 which was given by the

licensee for full implementation.

l

b.

(Closed) Item (325, 324/79-02-18): Need for timely correceive

action and responses. This item was originally opened to follow

'

corrective actions which, while incomplete as of the inspection

(January 1979) had been started in response to a previous citation

i

(November 1978,325,324/78-30-01). When the area was reinspected

later that year (Report 50-325/79-28,50-324/79-27), some progress

'

had been made, but the then controls established at that time were

still evaluated as insufficient.

Since this inspection disclosed

that controls are still inadequate and the percentage of items

which are not being properly handled has increased, t.his item is

closed for record purposes with the opening of a violation

(325/80-42-02,324/80-39-02) which is further discussed in paragraph

.

22.d.

c.

(0 pen) Item (325, 324/79-02-24): Update of drawings. The inspection

i

on this item was conducted based on three licensee letters, first

dated March 14, 1979 (GD-79-654, file NG-351(B)), the second dated

August 1,1979 (GD-79-1967, file NG-3513(B)) and the third dated

May 1, 1980 (BSEP/80-771, file B09-13514). The inspector determined

that drawings, based on plant modifications, which require revision

'

are being revised as committed by the licensee. The inspector

also verified that safety-related system descriptions have been

revised. This itam remains open pending revision completion of

the remaining system description. The licensee's conriitment for

this item is April 30, 1981.

l

d.

(Closed) Open Item (325, 324/79-02-25):

Procedure review and

approval. The program, as reviewed, consists of indicating in the

Master Index of the Operating Manual which procedures require PNSC

!

l

. -

_ _ _ _ _ _ _ _ .___ _ _ ___ _, _ _ . _ ._ _

.

. .

- . - _ _ . _ , . _ _ . . _ . .

-

.

. - .

-

.

,

27

approval. The inspector spot checked a number of maintenance

procedures to ensure PNSC approval.

Findings were satisfactory.

e.

(Closed) Open Item.

(325,324/79-22-05): After reviewing OAP-1,

Revision 10 dated 6/80, the inspector determined that there

i

appeared to be a proper method available to ensure prompt corrective

action as well as a means to track problem areas.

)

f.

(Closed) Open Item (325, 324/79-22-06): Updating of TI-200. The

i

current approved revision of TI-200 was reviewed and the inspector

detennined that the method and criteria for evaluation of personnel

was adequate.

g.

(Closed) Open Item (325, 324/79-2?-07): Completion of grading

examinations. The results of the end of course examinations for

1978 were reviewed to detemine that all examinations had been

graded.

,

h.

(0 pen)

Open Item (325, 324/79-22-08): Dissemination of infomation.

This item originally addressed the disseminatica of information to

operators from 1.ERs, current experience reports, NSSS letters and

,

industry publications in that there was no formal program governing

'

selection of material. TI-902 Plant Modifications; Training Group

I

Implementation, was revised and revision 7 was implemented on

!

8/31/79. However this TI only addresses the training subunit's

l

responsibility and does not address responsibilities of other

personnel . The licensee is now preparing a program in response to

NUREG 660, Task Item I.C.5, Procedure for Feedback of Operating

i

'

Experience to Plant Staff. The licensee anticipates that completion

of this program will also satisfy the open item. Therefore, the

date for Item I.C.5 of January 1,1981 is also the new licensee

commitment date for this item.

l

1.

(Closed) Open Item (325, 324/79-22-09): Completion of training

and evalcation. The content and grading of examinations for the

i

training conducted in accordance with IE Bulletin 79-08 was

l

reviewed and no problems were found.

>

22.

Independent Inspection - OA Program Areas (92706)

The inspection program requires that a percentage of inspection time be

devoted to inspection of areas not specifically required by the documented

l

program. The inspectors selected and reviewed the following additional

areas to fulfill that requirement:

P0A surveillance program, 00A

surveillance programs; CQA audit program and interviews with QA Specialists

and QC Technicians.

.

l

.

28

a.

Review of 0QA Surveillances

The inspectors reviewed reports of the surveillances conducted by

the group. During that review the inspectors identified two

violations as discussed in paragraphs 22.b and 22.c.

b.

Failure to Include Releases in Semiannual Report

!

Surveillance 0QAS-80-6(B) was conducted April 21-24, 1980. This

report, forwarded to management on April 25, 1980, identified

'

eleven releases or possible releases from the auxiliary boilers.

1

An additional release from the auxiliary boiler on February 22,

1980 had resulted in a civil penalty (50-325/80-12, 50-324/80-11).

The licensee's Semiannual Environmental and Effluent Report for

the period January 1, 1980 through July 30, 1980 was then reviewed.

The report, forwarded to the NRC in the licensee's letter (BSEP/

80-1345) dated August 13, 1980, specifically stated that only one

release had been made and evaluated. The Environmental Technical

Specifications (ETS) (5.4.1.1.a) require that the report cover the

preceeding six months of operations and include a sumary of the

'

quantities of radioactive effluent released from the plant.

Contrary to the requirements, the sumary of releases did not

include releases from the auxiliary boiler as a result of tube

leaks on or about January 23, February 28, March 2, March 6 and

.

March 13, 1980. This failure to comply with the requirements of

!

E.T.S. 5.4.1.1.a constitutes a violation (325/80-42-01, 324/80-

l

39-01).

'

Failure to Perform Corrective Action On Items Identified During

c.

Surveillances

In reviewing the 00A Surveillance Reports, the inspectors identified

three reports which contained "coments" which should have been

" findings" and which should have received corrective act'oas as

required for findings. The licensee's procedure 0QA-2, Conduct of

Plant Surveillance Program, Revision 4 dated 12/79, paragraph 4.3

requires that items discovered during the surveillance which

require corrective action will be identified.

Contrary to the above, Surveillance 0QAS-80-13(B) was not ac-

complished in accordance with procedure OQA-2 in that 27 plant QA

items were identified as either lacking corrective action or

lacking a known status and Action Items were not written

identifying a need for corrective action.

Contrary to the above, 0QAS-80-14(B) identified as a coment that

several record books in use such as the jumper log, administrative

operating instructions, and the annunciator status logbook contained

obsolete portions of the Plant Operating Manual; an Action Item

was not written identifying a need for corrective action.

- -

_ _ .

-

.

29

Contrary to the above, 00AS-80-4(B) icentified as a coment

several problems identified with pts such as changes being made,

sign-offs being made without meeting acceptance criteria, equipment

being used without being recorded, PT forms not being properly

filled out, using pts of the wrong revision, and pts not being

locatable; an Action Item was not written identifying a need for

corrective action.

These three examples of failure to follow procedures constitute a

violation (325/B0-42-03, 324/80-39-03).

d.

Failure to Establish Measures to Assure Conditions Adverse to

Quality are Identified and Corrected

While reviewing previously identified item 325,324/79-02-18,the

inspector noted that identified items were not being corrected and

that the procedure which established controls for these items was

still inadequate. Specifically:

,

Thirteen items had exceeded established dates without completion

-

of defined corrective action; eight items had no established

corrective action that was satisfactory to resolve the

identified problem; and three items had not received any

response by the established response due date. The above

inadequacies represent 46 percent of the total number of open

items (52) still outstanding ss of this date.

The controlling QA Procedure QAP-2 On-site QA Surveillance,

-

Revision 10 dated S/80, does not establish required measures

because it does not specify the action to be taken when no

response is received and the required follow-up memorandum is

-

ignored; nor does it specify the action to be taken when

j

proposed corrective actions are inadequate.

l

10 CFR 50, Appendix B, Criterion XVI, requires measures to assure

that conditions adverse to quality, such as failures, deficiencies,

deviations, and nonconfonnances are promptly identified and

corrected. The accepted QA Program, FSAR Section 13.4.3.R.3

l

states that measures shall be established to follow up on corrective

actions to assure proper implementation and closecut. Measures had

i

not been established nor had conditions adverse to quality been

promptly corrected as of October 29, 1980. This is a violation

(325/80-42-02,324/80-39-02).

,

l

A similar item was brought to the licensee's attention in NRC

enforcement correspondence dated December 5,1978.

Problems

germane to this citation have been outstanding during the period

from January 16, 1979, until October 29, 1980, in the form of item

(325,324/79-02-18), which was reinspected and updated in report

50-325/79-28,50-324/79-27 dated September 4,1979.

l

--

,.

_ , .

-

-_- _ _ -

-

. . _ .

-

.-

-

__.

.

30

e.

Failure to Provide Adequate QA/QC Personnel Training

This item was originally identified as item 325-324/79-22-04 when

an inspection of this area was conducted in June of 1979.

No

citation was issued at that time because the licensee had identified

the same inadequacy (00AS-37) and corrective actions were to be

undertaken.

During the inspection conducted to close the previous

open item, the following items were identified:

The procedure QAI-2, Requirements for BSEP QA Surveillance

-

Personnel, had not been revised since September, 1975. As a

consequence, it referenced procedures for personnel training

that no longer exists and it did not cover over 25 standards

and proceduies which are part of the current GA controls.

This item is also discussed in paragraph 5.a.

Procedure QAI-2 was not followed with respect to Section 3.c

-

because personnel had not received the required oral checkout

by the QA Supervisor following completion of the required

training (reading assignments).

Documentation of training was not complete in that additional

-

training, which had been conducted according to the QA

Supervisor, had not been recorded.

Proficiency was not maintained by the program in that over 95

-

'

percer.t of the documented training had ended with completion

of initial employment training in the QA/QC area.

For the

five technicians / specialists involved, two were initially

trained in 1977 and three in 1978/1979.

The formal training for test witnessing and process witnessing

'

-

had not been completed in that all persons interviewed

indicated that no fonnal training in assignment of QC hold

points had been received, and no documentation to the contrary

l

was presented.

1

These five examples of failure to provide adequate training, or to

document completed training, or to follow training procedures, or

to have an adequate training procedure have been combined to

collectively constitute a violation (325/80-42-05; 324/80-39-05).

f.

Failure to Audit Actions Taken to Correct Deficiencies

As documented in paragraph 22.d above, lack of adequate corrective

action has been in existence for a period of two years at the

Brunswick site.

Because Technical Specification 6.5.4.1.c requires

a semi-annual audit of corrective action by the CNS & OAA Section,

the inspector requested audits of this function for the period

from November 1977 to October 1980. The inspector identified that

only two audits (QAA-21-9 on 12/16/77 and QAA-21-13 11/9/79) had

. - .

_ _ _

_ _

- -

_

_ _ .

__ __

-

_

.

-

.

31

been conducted during the period noted. This failure to conduct

required audits is a violation (325/80-42-04; 324/80-39-04).

A similar item (Item I) was brought to the licensee's attention in

NRC enforcement correspondence dated February 21, 1979.

g.

Failure to Review Training and Qualifications of Facility Staff

As documented in paragraph 22.e above, lack of up-to-date training

and lack of retraining existed for QA/QC personnel.

Because

Technical Specification 6.5.4.1.b requires the training and

qualifications of the entire staff to be reviewed at least every

twelve months by the CNS & QAA Section, the inspector requested

audits of this area for the period January 1979 through October

1980. Although the required audits of the area were conducted

(QAA-21-9 on 4/13/79 and QAA-21-14S on 3/14/80), and although the

inadequate training procedure was referenced (QAI-2); neither of

these audits identified any of the five examples of inadequate

training documented in paragraph 22.e above. This failure to

conduct an adequate audit of training is a violation (325/

80-42-07; 324/80-39-07),

h.

The inspector interviewed the newly appointed (11/3/79) Director

of Nuclear Safety and Quality Assurance. The Director has not yet

completed his self-designed QA study program which includes:

study of the accepted QA Program and study of all QA implementing

procedures used at the plant.

Completion of this study program

will be reviewed during a future inspection and is designated as

an inspector followup item (325/80-42-30, 324/80-39-30).

1.

Surveillance Repcrt Comment on Stabilization Pond (Spoil Pond)

Surveillance Report 0QAS-80-10(B) conducted May 27-28, 1980,

contains comments relative to the operation of the stabilization

pond (Spoil Pond) and the radiation levels contained therein. A

technical evaluation of possible release pathways from this pond

to the environment will be evaluated during a future inspection.

Until this evaluation is completed, this item (325/80-42-13;

324/80-39-13) is unresolved.

,

e

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, , - . - - - ,

,-, ,

.

32

23.

Index of Findings of Inspection Report 50-325/80-42 and 50-324/80-39

Item

Report

Numbers

Description

Location

325/80-42

324/80-39

'

VIOLATIONS

01

Failure to Include Releases in Semi-Annual

22.b

Report

02

Failure to Establish Measures to Assure

22.d

Conditions Adverse to Quality Are Identi-

fied and Corrected

03

Failure to Perform Corrective Action on

22.c

items Identified 3aring Surveillance

04

Failure to Audit Actions Taken to Correct

22.f

Deficiencies

05

Failure to Provide Adequate QA/QC Personnel

5.a,

Training

22.e

l

06

Fail dre to Review Documents by QA prior

3.c.(1)

to Release

t

07

Failure to Review Training and Qualifications 22 9

of Facility Staff

I

08

Failure to Correctly Identify Audit

16.c

l

Findings

09

Failure to Follow Procedures

ENP-3 Updating Plant Procedures

9.b

ENP-3 Identify Drawings Undergoing Revision 9.c

ENP-3 Notification of Training Supervisor

19

l

RMI-3 Stamping of Drawings

14.a

AP Limiting Dates on Special Procedures

10

Failure to Establish Measures for Design

9.a

l

Analysis

l

11

Failure of CNSU to Review Safety Evaluation 9.d

12

Failure to Provide Conditional Release

12.a

Control

. _ _

'

.

_

33

UNRESOLVED

13

Surveillance Report Comments on

22.1

Stabilization Pond (Spoil Pond)

OPEN ITEMS

14

Operations Manual Does Not Reflect

7.a

T/S Organization

15

Training Programs do Not Include Necessary

18.a

Subjects

16

General Einployee Training Does Not Provide

18.b

Criteria for Satisfactory Completion of

Training

17

Master Drawing Index Does Not Include

14.b

Engineering on Distribution

,

18

5

Records Generated Prior to New Index

13.b

s

System Do Not Have a Documented Index

19

Construction Records Not Controlled by

13.a

Written Procedures

20

Clarification Between CNSU Procedures

15.a

and Technical Specification

21

Revise QAP-17 to Include Additional

5.c

Guidance For Determining Hold Points

22

Revise QAP-22 To Make Procedure Workable

5.d

23

Revise QAP-2 To Provide Controls For PQA

5.b

'

Items

24

Document Cases Where QA/QC Technician's

5.e

Decision Is Overridden By QA Supervisor

INSPECTOR FOLL.0WUP ITEMS

25

Housekeeping Inspection

20

26

Outdated References In Operating Manual

9.e

27

Include Handling of Defective Rigging

12.b

Equipment In MP-6

28

Evaluate Upgraded Retraining Program

18.c

,

-

.

,

1

34

29

Evaluate General Employee Retraining

18.d

30

Review Director NS & QA Self Study Program

22.h

In QA Area

31

Evaluate Implementation Of Program For

21.a

Control Of Consumables

4

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1

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ML20003F300

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