ML17158A274
| ML17158A274 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/10/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158A273 | List: |
| References | |
| 50-387-94-06, 50-387-94-6, 50-388-94-06, 50-388-94-6, NUDOCS 9405170102 | |
| Download: ML17158A274 (2) | |
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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 February 26, 1994 - April 11, 1994, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering activities referenced in Regulatory Guide 1.33.
Regulatory Guide 1.33 requires licensees to establish and implement administrative procedures for safety-related activities.
A.
The following four examples describe circumstances where maintenance was not performed in accordance with licensee procedures:
Maintenance Procedure MT-AD-504, Scaffold Erection, Review and Inspection, Section 4.7 requires that the installer verify that the scaffolding does not interfere with plant operations or endanger the'safe operability of plant systems.
Specifically, the scaffold shall not obstruct manual or automatic movement of equipment.
Contrary to the above, on April 7, 1994, the 'B'oop of Residual Heat Removal (RHR) system was drained back to the suppression pool when scaffolding prevented the 'B'HR pump discharge check valve from properly seating after the 'B'HR pump was shutdown.
2.
Nuclear Department Administrative Procedure, NDAP-QA-502, Work Authorization System, requires a Work Authorization to perform work on plant equipment.
3.
Contrary to the above, on March 22, 1994, the scram pilot solenoid valves for hydraulic control units (HCUs) 02-35 and 06-39 were removed without an approved Work Authorization.
V NDAP-QA-506, Foreign Material Exclusion, requires temporary covers be installed on system openings during maintenance when the system is unattended.
Contrary to the above, on March 22, 1994, the inspector observed numerous openings on scram plot solenoid valve air piping that did not have temporary covers installed.
On March 24, 1994, the inspector observed an opening on HCU 18-51 did not have a temporary cover installed.
9405170102 940510 PDR ADOCK 05000387 Q
4.
NDAP-QA-442, Control of Ignition Sources; Cutting, Welding, and Hot Work Permits, form NDAP-QA-442-1, requires movable combustible materials be removed from below and within a 35 foot radius of the work area.
Contrary to the above, on March 25, 1994, the inspector observed combustible material ignite and burn below the work area in direct observation of the fire watch.
This is a Severity Level IV Violation (Supplement I).
B.
The following example describes a circumstance where a nonconforming condition on Unit 1 was not evaluated and dispositioned by the NCR procedure.
1.
NDAP-QA-0754, Nonconformance Reports - Control and Processing,
- requires, in part, that nonconforming conditions with generic implications be evaluated
. and dispositioned via the NCR process.
Contrary to the above, during the fall 1993 Unit 1 refueling outage, on October 14, 1993, overheated MSIV cables were discovered (while performing Work Authorizations C30165 and C30168) and replaced without documenting this nonconforming condition in an-NCR.
This is a Severity Level IV Violation (Supplement I).
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, AKIM Document Control Desk, Washington, D.C. 20555 with a,copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter 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 willbe achieved. Ifan adequate reply is not received within the time specified in this Notice, an order or a Demand for Information 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 willbe given to extending the response time.
Dated at King of Prussia, PA this day of April 1994