ML17157C043
| ML17157C043 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/22/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157C042 | List: |
| References | |
| 50-387-92-22, 50-388-92-22, NUDOCS 9210270104 | |
| Download: ML17157C043 (2) | |
Text
APPENDIX A NOTICE OF VIOLATION Pennsylvania Power and Light Company Susquehanna Unit 1 and 2 Docket No.
50-387/50-388 License No.
NPF-14/NPF-22 During an NRC inspection conducted on August 18, 1992 - September 28, 1992, 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 (1990), the violations are listed below:
A.
Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering the activities referenced in Regulatory Guide 1.33.
Regulatory Guide 1.33 requires the licensee to comply with 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 5.2.7 requires that maintenance or modifications on safety related equipment 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 maintenance to be performed correctly and safely.
Contrary to the above, on September 9, 1992, insulation was removed from the Unit 2 High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC)
Systems with the plant operating at power without any procedure or instruction.
Additionally, the insulation was removed without any prior knowledge or authorization from anyone in the operations department.
This is a Severity Level IV Violation (Supplement I).
B.
Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering the activities referenced Regulatory Guide 1.33.
Regulatory Guide 1.33 requires that administrative procedures be implemented.
Licensee Administrative Procedure AD-QA-482, Post Maintenance/Modification Test Program requires that testing be performed following maintenance or modification to ensure proper system function prior to restoring a system to an operable status.
Contrary to the above, on August 2, 1992, after installation of a newly designed flow orifice, the "A" Control Structure Chilled Water System was returned to an operable status without performing the required post maintenance testing.
AD-QA-482 requires that post maintenance/modification testing be performed prior to returning a safety system to an operable status.
Subsequent testing identified flow rates which were slightly less than the design flow rate.
This is a Severity Level IV Violation (Supplement 1) 9210270104 921022 PDR ADOCK 05000387 6
C.
10 CFR 50.59 allows holders of a license authorizing operation of a facility to make changes to the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question.
Contrary to the above, on August 2, 1992.a change was made to the Control Structure Chilled Water System which altered the flow rate of the system to less than that required.
No safety evaluation was performed to determine whether the design change resulted in an unreviewed safety question as required by 10 CFR 50.59 This is a Severity Level IV Violation (Supplement 1)
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light 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 transmitting this Notice of Violation. This reply should be. clearly marked as a "Reply to a Notice of Violation" and should include:
(1) the reason for the violation, or, ifcontested, 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 willbe achieved. Ifan 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.
Where good cause is shown, consideration will be given to extending the response time.