ML17053C273
| ML17053C273 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/27/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053C269 | List: |
| References | |
| 50-220-80-05, 50-220-80-5, NUDOCS 8102050734 | |
| Download: ML17053C273 (10) | |
Text
APPENDIX A NOTICE OF VIOLATION Niagara Mohawk Power Corporation Docket No. 50-220 Based on the results of an NRC inspection conducted on May 19 through 23, 1980, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Facility License No.
DPR-63 as indicated below.
Items A and B are infractions and Item C is a deficiency.
A.
Technical Specification 6.8.1 requires, in part:
"Mritten procedures...shal1 be established, implemented and maintained that meet or exceed the require-ments and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972...."
ANSI N18.7 paragraph 5.3.4.1(l) requires, in part:
"...Startup procedures shall include determination that...valves are properly aligned....
Checkoff lists should be used for this purpose."
Final Safety Analysis Report (FSAR),Section V, "Reactor Coolant System,"
Figure V-1, requires that Main Steam Relief Valve blocking valves be normally locked in the open position.
Nl-OP-20, "Service, Instrument and Breathing Air Systems,"
Figure OP-20-1, specifies that valve TCLC-97, Bypass valve for regulator valve No. ll ACCM, be normally in the shut position.
Contrary to the above, valve lineup checkoff lists in were not adequately established in that system valves lineup or valve lineup sheets required improper valve following procedures were observed to have incomplete valve lineups:
several procedures were omitted from the alignment.
The or incorrect Relief valve blocking valves MS Nos.
1-6 were not included on the Main Steam System valve lineup in procedure Nl-OP-01, "Nuclear Steam Supply System,"
nor on any other initial system lineup procedure.
Mhile it could be established by valve position indication that these valves were open; there was no documentation available to establish that these valves had been locked as required by the FSAR.
Cardox System supply valve and Cardox System supply'alve bypass valve were not included on the fire protection system valve lineups in procedure N1-0P-21, "Fire Protection System."
Hence, there was no documentation of the alignment of these valves.
Valves IA-40 and BA 114-30 were omitted from valve lineup sheets which are part of Nl-OP-20, "Service, Instrument and Breathing Air Systems."
Regulator bypass valve TCLC-97 is lined up in the "open" position rather than the "'shut" position as required by Figure OP-20-1.
alos050 72 g
'1
Appendix A Makeup Demineralizer Valve 44, Suction Valve to Makeup Demineralizer Resin Waste Pump No. 12, was omitted from valve lineup for N1-0P-17, "Makeup Demineralizer System."
B.
Technical Specification 6.11, "Radiation Protection Program," requires that procedures
'for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20, and that they be approved, maintained and adhered to for all operations involvi.ng personnel radiation exposure.
Procedure RP-2, Radiation Work Permit Procedure (RWP), developed pursuant to the above states
>n Sect>on 5.2, that, "...the lead man is responsible for familiarizing personnel with all the instructions on the permit, and insuring that these instructions are strictly followed...."
RMP 09596 indicated shoecovers were to be worn as required.
P d
RP1,A d~Rdi1 i
1C t i, t
i S
4.4.4(c),
"A step-off pad encountered at the entrance to an area...indicates
- that, as a minimum, shoe covers are required for entry...."
Contrary to the above, on May 22, 1980 two workers, wearing street clothes and without donning shoecovers en/ered a posted, roped off contamination area (up to 1,640 dpm/100cm
) by entry across a step off
- pad, remained in the area then subsequently exited the area without using the step off pad or taking precaution to minimize the-spread of radioactive contamination.
,C.
Technical Specification 6.8.1 requires, in part:
"Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections
- 5. 1 and 5.3 of ANSI N18.7-1972...."
Technical Specification 6.8.2 requires, in part:
"Each procedure...of 6.8.1 above, and changes
- thereto, shall be reviewed by the SORC and ap-proved by the General Superintendent Nuclear Generation...."
Listed below are examples of failure to develop/establish appropriate instructions/procedures:
(1)
ANSI N18.7 Paragraph 5.1.3 states, in part.
"A mechanism shall be provided for dissemination to the plant staff of instructions of general and continuing applicability to the conduct of business...
standing orders...should deal with job turnovers and relief, desig-nation of confines of the control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions, and other such matters...."
'1
Appendix A
3 Procedure APN-6, "Preparation of Procedures, Instructions and Orders,"
paragraph 3.14. 1 states in part "Standing Orders - Orders and instructions may be issued as standing orders on subjects which do not involve plant modifications or actions which might affect the quality of systems or components or on matters which do not require prior SORC review before coming effective...."
Procedure APN-5, "Procedure for Control of Procedures; Instructions and Orders,"'aragraph 5.4.1. 2 states, in part, "Standing orders... do not require SORC review prior to implementation, however,-all standing orders issued since the last regular SORC meeting shall be presented for review at the next regular SORC meeting...."
Contrary to the above, two-standing orders observed in use-in the Control Room were outside the scope of the type of procedure which can be issued as a standing order as defined in ANSI N18.7.
They were NMPS0-18, "Recirculation Pump Operation,"
issued August 23, 1979, which provides some operating instructions for circumstances when operating with less than five recirculation pumps; and NMPS0-22, "Valve Monitoring System,"
issued April 25, 1980, which provides an alarm response procedure should the reactor relief or safety valves lift.
In addition, the above procedures, which are safety-related, did not receive SORC review prior to issue nor is there any documentation that the above procedures received any SORC review subsequent to their
. issue..
(2)
APN-l, "Procedure for Administrative Controls," paragraphs 7-.4 and 7.5 state, in part, "One copy of...fadministrativej procedures shall be maintained in the Control Room...[Thisj procedure will be marked "Master Copy"...
It shall be the responsibility of the Operation's Supervisor that the "Master Copy"... maintained in the Control Room, is up-to-date and contains all procedural material required by the Control Room operator."
APN-5, "Procedure for Control of Procedures, Instructions and Orders,"
paragraph 3.3 states, in part: "... Each person receiving a [controlledl copy [of procedures]
shall be required to return receipt along with certification that he has destroyed any superseded copies or pages...."
Contrary to the above, an out-of-date set of administrative procedures was available to Control Room operators in that controlled Copy No.
3 of Administrative Procedures assigned to a Senior Shift Supervisor and being maintained in the Control Room did not have the latest revisions posted.
Certification was on file in the Document Control Office showing receipt of these revisions.
This set of administrative procedures was being maintained in an official station procedures binder and was being used
~
Appendix A interchangeable with other sets of administrative procedures in use in the Control Room.
Two other sets of controlled copies of Administrative Procedures
- the "Master Copy" 'and one set maintained by another Senior Shift Supervisor
-were also being maintained in the Control Room and appeared to be up to date.
(3)
Procedure Nl-ST-(6, "Containment Spray and Raw Water Pumps Operability Test,"
Oata Sheet paragraph A.4 states "Required pressure gages be calibrated prior to test (eight sheets attached)."
Procedure Nl-ICP-80, "Containment Spray System Flow and Pressure,"
paragraphs,5.1.2 and 5.1.5 provides for calibration of containment spr'ay flow instruments and technician sign-off that the calibration is complete.
Procedure APN-8, "Test and Inspection Program," provides for review of test results for determination of unsatisfactory test results.
Contrary to the above, it was observed that the above procedures were not'dequately implemented in that:
Nl-ST-(6, data sheet, performed January 26, 1979, prerequisite step,A.4 was'ot signed off that the required pressur e gages had been calibrated prior to test although the test was performed.
Containment Spray Flow Test for pump No.
111 per Nl-ST-g6, appears to have been performed with an out-of-calibration flow meter, in that the data sheet indicates an incomplete calibration (although a completed data sheet, not attached to the surveillance test, was found to be on file) had been accomplished on the flow transmitter 80-49A, flow converter 80-49B, and flow indicator 80-49C.
Containment spray flow instrument data sheet was signed off as completed when data recorded on the sheet indicated calibration had not yet been completed; Review of test results was apparently inadequate in that the discrepancies noted above were not observed or corrected.
J
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APPENDIX 8 NOTICE OF VIOLATION Niagara Mohawk Power Corporation Docket No. 50-220 Based on the results of an NRC inspection conducted May 19 through May 23, 1980, it appears that one of your activities was not conducted in full compli-ance with conditions of your NRC Facility License No.
DPR-63 as indicated below.
Thi.s is an infraction.
TMIS PAGE CONTAINING 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, IS INTENTIONALLY LEFT BLANK.