ML17157A586
| ML17157A586 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/22/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157A585 | List: |
| References | |
| 50-387-90-81, 50-388-90-81, NUDOCS 9103050004 | |
| Download: ML17157A586 (9) | |
Text
APPENDIX A NOTICE OF VIOLATION Pennsylvania Power & Light Company Susquehanna Steam Electric Station Units 1 and 2 Docket Nos.:
50-387/50-388 License Nos.:
NPF-14/NPF-22 During an NRC inspection conducted from October 9 to 19 and November 5 to 9, 1990, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:
1.
10 CFR 50.59 requires that the licensee shall maintain records of changes in the facility arid that 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.
10 CFR 50, Appendix B, Criterion XVII, "Quality Assurance Records", requires that sufficient records shall be maintained to furnish evidence of activities affecting quality.
Susquehanna Operational Quality Assurance Manual, OPS-9, Revision 2, paragraph 5.1.1 requires that modifications shall be proposed by established procedures which assure a documented, controlled process, and paragraph 5.1.2, requires that, prior to installation, Modifications shall be subjected to a safety evaluation in accordance with the requirements
'of 10 CFR 50.59, and paragraph 5.1.3 requires that Modifications and the related safety evaluations shall be reviewed by the Plant Operation Review Committee (PORC) and the Susquehanna Review Committee (SRC).
Contrary to the above, the following are examples where modifications were made without the required written safety evaluations:
a.
"Temporary" general area lighting has remained installed near the Unit 2 Control Rod Drive hydraulic control units since on or before March 26, 1984, without a written safety evaluation.
b.
On October 9, 1990, the Unit 2 Standby Liquid Control Accumulator (2T207B) charging connection cap was modified to accommodate a replacement valve.
Since the replacement valve is of a different design than the original valve, a hole was drilled in the accumulator cap.
This modification was installed without a written safety evaluation.
c.
On October 10, 1990, a "temporary" structure was found attached to the Unit 2 Main Steam Flow Panel (2C041) and containment wall mounted instrument tubing supports.
This structure has been installed without any documented design modification or written safety evaluation.
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d, On October 13, 1990, a Unit 1 Reactor Protection System panel (1C611) was found modified by the installation of banana jacks.
This modification was installed under a work authorization without a documented design modification or written safety evaluation.
This is a Severity Level IV violation (Supplement 1).
2.
10 CFR 50.49 requires, that licensees shall establish a program for qualifying safety-related electrical equipment relied upon to remain functional during and following design basis events.
Additionally, a record of the qualification must be maintained to permit
, verification that each item of electric equipment'important to safety covered by this section is qualified for its application and meets its specified performance requir'ements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.
Susquehanna Operational Quality Assurance Manual, OPS-13, Revision 3, paragraph 5.1.3, requires that maintenance and modifications must be evaluated for their impact on environmental qualifications.
Appropriate actions shall be taken to maintain existing qualifications, and qualification binders shall be updated to reflect the qualification status upon completion of the maintenance or modifications.
Contrary to the above, on October 11, 1990, a Unit 1 environmentally-qualified Reactor Core Isolation Cooling Pump Rosemount discharge fiow transmitter (FT-E51-1N003) cover cap was found loose.
The cap was found to be torqued to 65 inch-pounds.
This torque value is less than the 200 inch-pound specification which indicates that appropriate actions had not been taken to maintain existing environmental qualifications.
This is a Severity Level IV violation (Supplement 1),
3.
Technical Specifications 6.8.1 states:
"Written procedures shall be established, implemented and maintained covering the activities referenced below:
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."
Regulatory Guide 1.33 states "comply with the 'requirements'f ANSI N18.7-1976/ANS-3.2."
ANSI N18-7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," paragraph 5.2.15, requires that plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine ifchanges are necessary or desirable.
Paragraph 3.2 requires persons or organizations performing functions of OFFICIAL RECORD COPY SUSQ-MTI.DC
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Notice of Violation assuring that the administrative controls and quality assurance program is, established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to identify quality problems.
Additionally, it requires that the verification of conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing or directly supervising the work, Contrary to the above, during the period October 1988 to October 1990, required procedural reviews and verification of approximately 2,000 Unit 1 and 2 procedures, including safety related maintenance procedures, surveillance procedures and checklists were conducted, but were not accomplished with independent personnel not having responsibility for performing or directly supervising the procedure.
This is a Severity Level IV violation (Supplement 1).
4.
10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings", requires that activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances which shall include appropriate'uantitative or qualitative acceptance criteria necessary for determining that important activities have been satisfactorily accomplished.
ANSI N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," paragraph 5.2.7, requires that maintenance or modifications of equipment shall be preplanned and performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances, and paragraph 5.3.5 requires the procedures to contain enough detail to permit the mainte-nance work to be performed correctly and safely.
Contrary to the above,'two examples of inadequately preplanned work were observed:
a.
On October 10, 1990, inadequately preplanned work was performed during the initial stages of the Unit 1 High Pressure Coolant Injection (HPCI) turbine six-year inspection in which the preplanned work package procedure was not detailed enough or appropriate to the complexity of the work for removal of the throttle trip valve, throttle valve, glands, and upper case which was performed by a work crew who had no previous experience doing the work or observing the work resulting in inadequate performance, for example, work stoppages and lack of control over work.
b.
On October 11, 1990, inadequately preplanned maintenance work and testing sequenc-ing was evident by activities associated with work to replace Unit 1 service water system butterfly valve, Work Authorization (WA) No. S03509.
After installation, but before torquing the flange bolts, the emergency service water pumps were restarted to OFFICIAL RECORD COPY SUSQ-MTI. DC
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K Notice of Violation perform testing for another work activity, resulting in leakage out of the flange, indicating inadequate preplanning.
This is a Severity Level IV violation (Supplement 1).
5.
Technical Specification Section 6.8.1 requires that procedures shall be implemented, covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
I Susquehanna administrative procedure, AD-QA-502, "Work Authorization System",
paragraph 6.5.3 requires Work Instructions for all modification WAs and for all work on, "Quality" equipment, and that Work Instructions shall be included on the WA as part of Section III.B, "Work Plan".
Paragraph 6.7 requires that work. shall be performed in accordance with all Work Instructions and referenced procedures.
Contrary to the above, three examples were found where procedures were not followed and work was performed outside the scope of approved procedures.
a.
On October 13, 1990, while performing work in Unit 1 under WA No. P02214, workers failed to follow instructions of Radiation'Work Permit (RWP) No.90-583.
The RWP required constant health physics (HP) coverage to breach the system, and workers broke open flanges in the contaminated system without an HP technician being present.
b.
On October 11, 1990, while working in Unit 1 under WA No. S06850 for the removal of vibration transducers and thermocouples on the HPCI turbine,technicians failed to follow procedures by performing work outside of the scope and authorization of the WA by removing speed sensor connections, limit switches, position transformers, and pressure sensing lines.
c.
On October 11, 1990, while performing work in Unit 1 on the Reactor Recirculation System Motor Generator Set under WA No. F94140, a worker failed to follow the procedure by going beyond the scope and authorization of the WA by testing the insulation resistance of the generator.
This is a'Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Susquehanna Steam Electric Station is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter OFFICIAL RECORD COPY SUSQ-NTI.DC
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Notice of Violation transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a, "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation; or, if contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that willbe taken to avoid further violations, and (4) the date when full compliance will be achieved. Ifan adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the licensee should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration willbe given to extending the response time.
Dated at King of Prussia, Pennsylvania this/~day ofhng/v.
1991
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