ML14176A776
| ML14176A776 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/14/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A775 | List: |
| References | |
| 50-261-89-11, NUDOCS 8910040027 | |
| Download: ML14176A776 (4) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-261 H. B. Robinson License No. DPR-23 During the NRC inspection conducted on July 10 - July 28, 1989, violations of NRC requirements were identified.
In accordance with "General Statement of Policy and Procedure For NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1989),. the violations are listed below:
A.
10 CFR 50.59 states:
"(a)(1)
The holder of a license authorizing operation of a production or utilization facility may (i) make changes as described in the safety analysis report...
without prior Commission approval, unless the proposed change,.... involves a change in the technical specifications incorporated in the license or an unreviewed' safety question."
"(2) A proposed change,...shall be deemed to involve an.unreviewed safety question (i) if the probability of occurrence or the consequences of an accident *or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased....
"(b)(1)
The licensee shall maintain records of changes in the facility...These records must include a written safety evaluation which provides the bases for the determination that the change...does not involve an unreviewed safety question."
Contrary to the above, the licensee made changes to the heat transfer characteristics of the Component Cooling Water System Heat Exchangers which are described in the UFSAR, by plugging tubes. in both of the heat exchangers, without accomplishing the required safety evaluation.
This is a Severity Level IV violation (Supplement 1).
B.
10 CFR 50, Appendix B, Criterion V, and the licensee's accepted QA
- Program, UFSAR section 17.2, require that: "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative and qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Additionally, 10 CFR 50, Appendix B, Criterion XVII, and the licensee's accepted QA Program, UFSAR section 17.2, require "Sufficient, records shall be maintained to furnish evidence of activities affecting quality....
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Carolina Power and Light Company 2
Docket No. 50-261 H. B. Robinson License No. DPR-23 Also, the licensee's accepted QA Program, UFSAR Section 17.2, commits to ANSI N45.2.8. ANSI N45.2.8., paragraph 4.4 *states in part that:
"Inspections of the work areas and the work in progress shall be performed to verify that mechanical items are being located, installed, assembled or connected in compliance with the latest approved-for-construction drawings, manufacturers instructions, codes, installation instructions and procedures. Inspections performed shall include as appropriate, but not be limited to, the following:
(e.)
Tightness of connections and fastenings..."
Contrary to the above, inadequate instructions were provided to ensure proper torquing of various system closure fasteners.
In addition, independent inspection or verification of the torquing of fasteners was not provided. Examples of the above include:
-WR/JO 89-AACY1, CCW system check valve CC-721C: Instructions were not provided to control the torquing of the valve body to bonnet fasteners, resulting in incorrect-torquing.
Documentation of the actual applied torque was not performed.
-WR/JO 88-AITF1, CCW system check valve CC-731:
An incorrect procedure (CM-120) was referenced for performance of work resulting in incorrect torquing.
Documentation of actual applied torque was not performed.
-WR/JO 89-ABYBI, CCW flange joint between the "B" RCP upper oil cooler and valve CC-719B:
The work request failed to require lubrication of the fasteners to obtain the required torque as specified by notes in the generic vendor manual.
-WR/JO 89-ACRC1, CCW blind flange between valve CC-795J and the CCW cooler to the "B" Safety. Injection Pump: The work request provided instructions for torquing the flange which failed to consider the type of gasket installed.
-WR/JO 87-AKWN1, CCW system relief valve CC-791L: The work order and the associated maintenance procedure (CM-102) did not provide the vendor manual specified torque values for assembly.
Documented evidence of proper assembly does not exist.
The types of deficiencies addressed above are typical of maintenance work performed on site where torquing is applicable.
The specific examples cited are not considered to be all inclusive of deficiencies which exist with the program for application of and documentation of torque.
This is a Severity Level IV violation (Supplement 1).
C. Technical Specifications Section 6.5.1.1.1 states that written procedures shall be established, implemented, and maintained covering activities referenced in Appendix A of Regulatory Guide 1.33, Rev 2, February 1978.
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ina Power and Light Company 3
Docket No. 50-261 H. B. Robinson License No. DPR-23 Appendix A of Regulatory Guide 1.,33, Revision 2, February 1978 states in Paragraph 9.a that Maintenance that can affect the performance of safety related equipment should be performed in accordance with written procedures, documented instructions, or drawings.
Contrary to the above, the following deficiencies concerning failure to follow approved procedures were noted in review of WR/JOs:
-WR/JO 88-AIFTI, CCW system check valve CC-731:
The-procedure referenced for the work on this check valve (CM-120) was incorrect for performing the work.
Maintenance personnel performed the work, signed off portions of this procedure and filed the procedure as a permanent record. Some of the instructions in this procedure were not applicable to the valve being worked;
-WR/JO 87-AKWN1, CCW system relief valve CC-791L: Paragraphs 7.1.1, 7.1.11 and 7.3.13 of maintenance procedure CM-102 attached to this work order required data to be recorded concerning the "as found" and "as left" position of the blowdown ring. This information was not recorded during the performance of work as required.
-WR/JO. 89-ABIS1, motor operated valve CC-749B:
The work request required the packing gland of CC-749B.to be torqued to a value of 6 ft-lbs.
It allowed the packing gland torque to be increased in 0.5 ft-lbs increments to a value of 7 ft-lbs, if necessary, in order to stop the packing leak.
Work was to be stopped and the maintenance planner was to be notified if more than 7 ft-lbs of torque was required. During performance of work, the packing gland was torqued to 8.5 ft-lbs and the planner was not notified as required.
This resulted in failure to repack the valve in accordance with vendor packing instructions.
This is a Severity Level. IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, H. B. Robinson within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as.a "Reply to a Notice of Violation" and should include for each violation:
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken. to avoid further violations, and (5) the date when full compliance will be achieved.. Where good cause is shown, consideration will be given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show.cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
III
Carolina Power and Light Company 4
Docket No. 50-261 H. B. Robinson License No. OPR-23 FOR THE NUCLEAR REGULATORY COMMISSION Stewart 0. Ebneter Regional Administrator Dated at.Atlanta, Georgia thisl4thlday of September 1989