AECM-87-0106, Responds to NRC Re Violations Noted in Insp Rept 50-416/87-10.Corrective Actions:Training Session Conducted by QA Dept for All QA Insp & Audit Personnel & Procedure 01-S-06-3 Re Temporary Alterations Will Be Revised

Responds to NRC Re Violations Noted in Insp Rept 50-416/87-10.Corrective Actions:Training Session Conducted by QA Dept for All QA Insp & Audit Personnel & Procedure 01-S-06-3 Re Temporary Alterations Will Be Revised

ML20214P779
Person / Time
Site:	Grand Gulf
Issue date:	05/29/1987
From:	Kingsley O SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
AECM-87-0106, AECM-87-106, NUDOCS 8706040017
Download: ML20214P779 (8)

Text

e EVEREM ENEREW REEDUNCEE,INC.

OM9 D K:tssuv.JP

[gC5$m3 May 29, 1987 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Report No. 50-416/87-10 dated April 30, 1987 (MAEC-87/0116)

AECM-87/0106 System Energy Resources, Inc. hereby submits responses to violations 50-416/87-10-04,87-10-09,87-10-10.

Yours ly, ODK:mbl -

Attachment cc: Mr. T. H. Cloninger (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Comission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323

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8706040017 870529 PDR G ADOCK 05000416 PDR

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r Notice of Violation 50-416/87-10-04 The Operational Quality Assurance Manual, MPL-TOPICAL-1, Revision 5, Section 16.0 as approved by the NRC requires, in part, that measures shall be established to assure that conditions adverse to quality such as deficiencies are promptly identified and corrected. MPL-TOPICAL-1 implements this requirement through Administrative Procedure 01-S-03-2, Quality Deficiency Reports (QDRs), which states in Section 6.1.1 that all quality deficiencies, unless identified on another deficiency document, must be documented in accordance with this procedure.

Contrary to the above on March 12, 1987, Standby Liquid Control pump relief valve C41-F029A leaked profusely through the gagging screw plug when the valve was placed in service for retesting, due to deficient reassembly (the plug was left loose). Licensee operations and QA personnel at the scene failed to identify and document the deficiency by issuing a QDR or other document.

I. Admission or Denial of the Alleged Violation System Energy Resources, Incorporated (SERI) admits to the alleged violation; however, there were no effects on the health and safety of the public.

II. The Reason for the Violation The reason for the individual's failure to document any deficiency pertaining to the conditions observed is that the individuals did not recognize that a deficiency existed that required documentation.

III. Corrective Steps Which Have Been Taken and the Results Achieved l

A training session was conducted by the QA department for all QA inspection and audit personnel. The training session utilized the

( scenerio of activities observed during the retest activities which

led to the issuance of the notice of violation and described the I conditions that were adverse to quality that required documentation.

l Additionally, various methods of questioning techniques that could be used to help in recognizing deficiencies were also discussed.

The Mechanical Maintenance Section initiated QDRs 144-87 and 145-87 which identified a lack of knowledge on the part of the mechanic reassembling the valve and failure of the maintenance work order to provide adequate instructions.

The GGNS General Manager has issued a letter to all GGNS employees which stresses the responsibility of each individual to document any nonconformance at the time it is identified.

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1 IV. : Corrective Steps Which Will be Taken to Avoid Further Violations

~SERI considers the actions taken in III above. sufficient to prevent further violations.

V. Time When Full Compliance Will be Achieved Full compliance has been achieved.

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Notice of Violation 50-416/87-10-09 Technical Specification 6.8.1 requires that written procedures be established, recommendedimplemented, in Appendix A ofand maintained Regulatory Guidecovering)the activities (RG 1.33, Revision 2, February 1978. RG 1.33 recommends procedures covering the bypass of safety functions and jumper control. Administrative Procedure 01-S-06-3, Control of Temporary Alterations, requires temporary alterations to be documented and controlled.

Contrary to the above, on March 27, 1987, the installation of the Standby Service Water basin acid storage tank and related piping was found to differ from that specified by temporary alteration 86-0034.

I. Admission Or Denial Of The Alleged Violation System Energy Resource Incorporated (SERI) admits to the alleged violation; however there were no effect on the health and safety of the public.

II. The Reason For The Violation On October 10, 1986, Temporary Alteration #86-0034 was generated to provide a facility at the Standby Service Water basins for the addition of MSP-03, a molybdate based compound which inhibits corrosion, to the Standby Service Water basins. This Temporary.

Alteration was performed under Maintenance Work Order (MW0) M-39334.

Piping leading from the chemical storage tank to the basins was routed to the east quadrants of basins A and B. When Standby Service Water is circulated through the plant, the pumps take suction from and discharge back to the west quadrants. When MSP-03 is added to the east quadrants it does not mix thoroughly nor effectively.

This situation required that piping and valves be installed to allow MSP-03 to be fed to the west quadrants. Since MWO M-39334 was left open, the decision was made to install the additional piping and valves under that MWO. Therefore, additional work was performed under MW0 M-39334 which deviated from the original scope of the MWO because procedural controls did not exist for modifying the scope of an approved temporary alteration.

It was later realized that a new temporary alteration was required to reflect the changes from the original approved temporary alteration and a temporary alteration request form was initiated.

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e-III. The Corrective Step Which Have-Been Taken And The Results Achieved The.new temporary alteration request form showing .the complete temporary alteration was approved and the original temporary alteration was superseded.

IV. The Corrective Step Which Will Be Taken to Avoid Further Violation

~ Procedure 01-S-06-3 (Control of Temporary Alterations) will be rtvised to to include instruction for changing the scope of a temporary alteration after final approval of a temporary alteration has been obtained.

V. Date Full Compliance Will Be Achieved Full compliance will be achieved by June 26, 1987.

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Notice of Violation 50-416/87-10-10

'1'O CFR Part 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be accomplished in accordance with documented instructions and drawings of a type appropriate to circumstances.

Contrary to the above, on February 6, 1987, the inspectors found the upper left mounting fastener for reactor control rod Hydraulic Control Unit-(HCU) 36-13 missing. It appeared to have never been installed as required by General Electric drawing 105D4988, Outline, Hydraulic Control Unit. Subsequent inspections conducted by the licensee revealed loose or missing mounting fasteners on about 35 other HCUs, a condition that could have existed since before licensing. The HCUs were operated in an unanalyzed condition for an indeterminate' length of time until discovery of the deficient condition on February 6, 1987, and subsequent correction. Subsequent analyses conducted by the licensee showed that the HCOs would have performed their intended safety function while they were in the as-found, unanalyzed condition noted above.

I. Admission or Denial of the Violation System Energy Resources, Inc. (SERI) admits to the alleged violation.

This violation did not affect the health and safety of the public. ,

II. The Reason for the Violation if Admitted The control rod drive hydraulic control units (HCU's) were originally installed by Reactor Controls, Inc. (RCI) during the construction of GGNS. The condition of missing mounting bolts occurred during construction when the mounting holes were drilled in the support steel before the HCU modules were onsite. The holes were drilled based on drawing dimensions and did not take into account the as-built condition of the HCU floor with its variations in elevation.- When the HCU's were to be installed, the bolt holes in the HCU's did not match the holes drilled in the support steel in every case. In some instances the holes were too close to the web of the beam to allow installation of the bolt and nut.

The condition was identified in 1978 during an RCI Quality Control (QC) inspection which led to a QC Hold on further RCI work activities pertaining to HCU's. RCI evaluated the condition and determined that the mounting bolts could be left in a "use as is" condition.

During a September, 1980-audit of RCI by Bechtel Power Corporation, Bechtel found that there was no objective evidence that an engineering analysis had been performed to justify the "use as is" disposition of the QC Hold. In October, 1980 Bechtel issued a Stop Work Notice to RCI.

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p In response to the Bechtel audit, RCI stated that although their engineering report could not be found, their files still contained all the data for the analysis. The RCI report was rewritten and submitted to Bechtel and General Electric for review and approval. In September, 1981, GE and Bechtel stated that, based on the RCI data, the installed condition was not sufficient to provide adequate support.

In November, 1981, RCI performed a 100% re-inspection of all HCU's to identify any missing bolts. Forty-five (45) were found missing. RCI then recommended that all HCU's be welded to the support steel where bolts were missing. Bechtel, with cooperation from GE, generated a weld detail procedure to support the HCU's. In January, 1982, GE approved welding in those cases where it was physically impossible to install mounting bolts.

RCI performed the required welding and in May, 1982, RCl QC accepted all HCU's. Bechtel accepted the HCU's from RCI during construction turnover and SERI later accepted the HCU's from Bechtel following completion of construction. The condition of the missing HCU mounting bolts continued to go unnoticed until NRC Inspection 87-01 was conducted which identified one missing bolt from the mounting frame of HCU 36-13. This condition was documented on Material Non-Conformance Report (MNCR) 0062-87.

The reasons for this violation can be summarized as follows:

A. RCI failure to properly install the mounting bolts during the original installation.

B. RCI failure to perform an adequate QC inspection before release of the HCU's to Bechtel.

C. Bechtel failed to perform an adequate QC field inspection of RCI's work; therefore, not ensuring that SERI was provided with a quality product.

III. Corrective Steps Which Have Been Taken and the Results Achieved Material Non-Conformance Report (MNCR) 0062-87 was issued for the bolt discovered missing in NRC Inspection 87-01. Maintenance Work Order (MW0) 70767 was issued which replaced the missing bolt. Some other missing or visibly loose bolts were subsequently added to MNCR 0062-87 after their locations were later discovered by Plant Mechanical Maintenance. MWO 70820 was then issued to replace or tighten the remainder of the bolts which had been identified in MNCR 0062-87.

Another action carried out through the issuance of MW0 70820 was the inspection by Mechanical Maintenance of all HCU mounting bolt locations for missing bolts or visibly loose bolts.

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I. 3, MNCR 0079-87 was issued to document bolts identified in MNCR 0062-87 which could not be attached or tightened in MW0 70820. MWO 71192 was issued to verify torque on all HCU mounting bolts and to retorque as necessary. The scope of MNCR 0079-87 was then expanded to encompass all undertorqued bolts, missing bolts and inadequate or missing welds which had existed prior to NRC Inspection 87-01.

A QA inspection was performed to verify that welds installed on HCU's by RCI in 1982 were installed as per the approved Bechtel weld detail procedure.

Nuclear Plant Engineering (NPE) was requested to perform an engineering analysis to resolve the question of whether GGNS has been operating in an unanalyzed condition. NPE was to address the worse case for: (1) those conditions which existed after implementation of the rework activities taken following NRC Inspection 87-01, and; (2) the pre-existing conditions prior to the inspection.

The NPE final disposition of MNCR 79-87, issued on April 9,1987, ,

concluded that the conditions which exist after implementation of rework activities described therein do not jeopardize structural integrity of the HCU's and do not invalidate the original qualification basis. In addition, the conclusion was also made that conditions which existed prior to the noted rework activities did not result in safety concerns which would have jeopardized the integrity of the reactor coolant pressure boundary, reduced capability to achieve and maintain reactor shutdown, or reduced capability to prevent or mitigate accident consequences.

These conclusions were based on calculations performed by NPE as well as evaluations conducted by the original HCU equipment supplier, General Electric.

IV. The Corrective Steps Which Will Be Taken to Avoid Further Violation A walkdown of items constructed / installed by RCI that were easily accessible during plant operations was conducted. A comon sampling scheme was used; however, the acceptance or rejection of each identified deficiency varied based upon the assessed significance.

The primary focus is confirmation that the components as installed will perform their intended design function as determined by engineering evaluation. This evaluation is still on-going.

V. Time When Full Compliance Will Be Achieved The engineering evaluation is scheduled for completion by June 30, 1987.

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