ML17285A146

Responds to NRC 881123 Ltr Re Violations Noted in Insp Rept 50-397/88-24.Corrective Actions:Procedure PPM 1.5.4 Will Be Revised to Include Time Limits for Review & Corrective Action on All out-of-calibr Measuring & Test Equipment

ML17285A146
Person / Time
Site:	Columbia
Issue date:	12/21/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-274, NUDOCS 8812280272
Download: ML17285A146 (24)

Text

ti WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 December, 21, 1988 G02"88"274 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, .D.C., 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88"24 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated November 23, 1988. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, each violation is addressed with an explanation of our, position regarding validity, corrective action and date of full compliance.

G. C. Sorensen, Manager Regulatory Programs REF/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Williams BPA NRC Site Inspector - 901A

APPENDIX A Page 1 of 8 APPENDIX A During an NRC inspection conducted from August 22 to September 2, 1988, several 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), as modified by 53 Fed. Reg. 40019 (October 13, 1988), the viola-tions are listed below:

A. Paragraph 6.8.1 of the Technical Specifications requires written procedures to be established, implemented, and maintained for surveillance and test activities of safety-related equipment.

Paragraph 6.8.2 of the Technical Specifications requires these procedures and changes to these procedures to be reviewed by the POC and approved by the Plant Manager, as set forth in administrative procedures.

Paragraph 6.8.3 of the Technical Specifications allows temporary changes to be made to procedures provided that the intent of the original procedure is not altered, the change is approved by two members of management staff (at least .one of whom holds a Senior Operator license), and the change is docu-mented, reviewed by the POC, and approved by the Plant Manager within 14 days of implementation.

Administrative Procedure 1.2.3, "Use of Procedures" (Rev. 12 dated September 18, 1987), requires procedures to be followed in the performance of plant activities. When procedures cannot be followed, a revision to the procedure or a procedure deviation must be completed. In the case of a procedure deviation, documentation prior to its implementation is not required provided the deviation has been approved by two members of plant management/supervi-sory staff and the Shift Manager is of the opinion that the work must continue.

Contra y to the above, changes were made to Surveillance Procedur e 7.4.4.3.1.4 dur ing the performance of a drywell sump flow monitor calibration on August 24, 1988, and a procedure revision or procedure deviation was not completed.

This is a Severity Level IV violation (Supplement I).

Validit of Violation The Supply System does not acknowledge the validity of this violation.

Just prior to August 22, 1988 the Drywell Sump Flow Monitor. indicated a flow that was approaching the Tech Spec limit, Section 3.4.3.2b, 5 gpm unidenti-fied leakage. A volumetric flow test (using buckets), PPMs 2. 11.3 and 2.11.5 was performed which determined that the indicated flow was greater than the actual flow. Operations requested that the loop be recalibrated. On August 22, 1988 at 0958, surveillance procedure 7.4.4.3.1.4, "Drywell Sump Flow Monitors," was started. During the performance of the procedure the Technicians noted that there were problems with the procedure which required

Page 2 of 8 a deviation. The Technicians obtained the assistance from the Maintenance Engineers to provide guidance on the procedure deviation required to remedy the problems identified with the procedure and ensure the deviation would not cause new problems. Permission was then obtained from the Shift Manager and the 18C Maintenance 'Supervisor to deviate from the procedure as necessary per PPN 1.2;3.C.3, and to provide the deviation and completed procedure for signature and approval prior to declaring the flow monitor, back in service.

This was considered acceptable because the floor drain sump flow monitoring instrumentation system does not provide any automatic actuation, but instead, provides indication and high flow alarm only'. Therefore, volumetric flow tests were performed within the required frequency to monitor, leakage flow rates relative to the allowable Technical Specification limits. The Shift Manager had decided the work must continue because the accuracy of the drywell sump flow monitor. system was in question and the sump flow indicator was approaching the Technical Specification limit.

The procedur e was completed the afternoon of August 24, 1988 'and the proce-dure deviation was written from the notes made during the performance of the procedure. The deviation received approval signatures on August 25, 1988 at 0800 and the procedure was signed off as .completed satisfactorily at 0826 on August 25, 1988. The equipment was not .returned to service prior to imple-mentation and sign off of the procedure deviation.

Per Plant Procedure 1.2.3, Section C.3, the deviation is not required to be documented prior, to its implementation providing it . has been approved verbally by two members of the. Plant Management Supervisory Staff. This process should be followed only when, in the judgment of the Shift Manager, work must continue as was the case here.

Corrective Ste s Taken/Results Achieved PPN successfully performed.

Corrective Action to be Taken No further corrective action is planned.

Date of Full Com liance The Supply System is currently in full compliance.

APPENDIX A Page 3 of 8 10 CFR 50.72(b)(2)(ii) requires the licensee to notify the NRC as soon as practical and in all cases within four hours of any event or condition that results in an automatic Reactor- Protection System (RPS) actuation that is not part of a preplanned sequence during testing or reactor operation.

Contrary to the above, the following RPS actuation were not part of the preplanned'equence during testing or reactor operation, and were not reported to the NRC as required:

o At 0844 on May 29, 1988, during Node 5 operation, an .RPS actuation occurred during initial testing of the alternate rod insertion (ARI) system. The RPS actuation occurred when air. pressure bled off the scram valves after the ARI system was placed in the test mode and the scram air. header was isolated. Control rod drive air, system leakage resulted from undocumented air, system leaks, and the RPS actuation was not a normal occur rence and was not anticipated in the ARI system test proce-dur.e.

At 1553 on August 26, 1988, during Node 5 operation, an RPS actuation occurred when Division II RPS power was transferred from the alternate to the normal source. The RPS actuation was due to switch over-travel during the power transfer evolution. The control room logs did not indicate that testing was in progress at the time of the RPS actuation, and the licensee could not produce a maintenance work order or other documentation to demonstrate that testing was in progress during the August 26 event.

This is a Severity Level IV violation (Supplement I).

Validit of Violation The Supply System does not acknowledge the validity of this violation:

"Actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor operation need not be reported" (10CFR50.72(b)(2)(ii) and 10CFR50.73(2)(2)(iv)). "Operation of an ESF as part of a planned. operational procedure or test (e.g., startup testing) need not be reported. However, if during the planned operating procedure or test, the ESF actuates in a way that is not part of the planned procedure that actuation must be reported." (Page 13 NUREG 1022)

Scram Discharge Volume High High Reactor Protection System Actuation.

As stated in the regulations quoted above, any RPS actuation that is part of a preplanned sequence during testing need not be reported. The event cited in this violation occurred as part of a preplanned testing sequence and therefore is not reportable. P'erformance of the Pre-Operational (pre-op) Test Procedure for the Anticipated Transient Without Scram (ATWS) Alternate Rod Insertion (ARI) System was the cause

APPENDIX A Page 4 of 8 of this event. A step in the ARI Pre-Operational Test Procedure required isolation of the Control Rod Drive Scram Air Header. Some bleed off of air pressure in the header was expected, and in. fact, there was a procedure step to record the amount of pressure lost during the test. While the amount of bleed down was not known prior to the test, the consequences of a large decrease in air header pressure were known.

That is the scram valves open and 'the Scram Discharge Volume (SDV) drain valves close whereby the "'scram water, fills the SDV and causes an RPS actuation on high water level. The test procedure purposely did not open the bypass valve which would have prevented the actuation. The Event Precursor reviewer stated to the Reactor Systems Supervisor that if the sequence of events in the procedure establish a condition where an RPS actuation could occur, thi s would constitute preplanning. There-fore, the RPS actuation was the result of a preplanned sequence of testing, and the actuation did not occur in a way that was not part of the procedure.

The condition of the control rod drive system having "undocumented air system leaks" is irrelevant since the Control Rod Drive System, includ-ing the scram air header meets all operational requirements. The scram header. air leaks were investigated following this event because of concerns expressed about the rapidity of the bleed down., No major leaks were discovered and it was judged to be determined impractical to fix most of the minor leaks found during power operation. Those leaks which can be repaired without major piping disassembly scheduled to be repaired in R-4.

August 26, 1988 RPS Actuation.

"On August 25, 1988, at 2211 hours0.0256 days <br />0.614 hours <br />0.00366 weeks <br />8.412855e-4 months <br />, while performing a channel functional test and calibration of the Reactor Protection System RPS Bus "A" EPA breakers, a full RPS actuation occurred due to momentary loss of power to both divisions of RPS. The cause of this event is switch over travel, which'eenergized both divisions of RPS simultaneously" (from WNP-2 Licensee Event Report 88-30).

On August 26, 1988; Contr ol Room Operators (CROs) (Licensed Reactor Operators) were preparing to transfer RPS "B" power from its alternate to normal power supply. Because of the full RPS trip of the previous day, the Shift Manager, Control Room Supervisor, and System Engineer determined that an opportunity existed to investigate the August 25, 1988 event. This process was consistent with the approved Plant Troubleshooting Procedure. -

The same CRO who performed the power transfer the previous day was instructed to do the power transfer in the exact manner of the previous day with RPS System Engineer watchi.ng. CRO duties are rotated daily and it is unlikely that the same CRO would have performed this task on both days and by observing the August 26, 1988 RPS power transfer, the RPS System Engineer was able to determine the cause of the August 25, 1988 event. Therefore, this RPS actuation is considered a preplanned test and is not reportable.

APPENDIX A Page 5 of 8 Corrective Ste s Taken/Results Achieved Pre-op procedures were successfully performed.

II Corrective Action to be Taken No further corrective action is planned.

Date of Full Com liance The Supply System is currently in full compliance.

ACCELEPCTED +STRIBUTIO.'l DEMO4RXTIOY, SYSTEM I,

'EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8812280272 DOC.DATE: 88/12/21 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME 'ECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to 50-397/88-24.

NRC 881123 ltr re violations noted in Insp Rept DISTRIBUTION CODE: XE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response N.OTES RECIPIENT ID CODE/NAME COPIES LTTR ENCL RECIPIENT ID CODE/NAME COPIES LTTR ENCL j

PD5 PD 1 1 SAMWORTH,R 1 1 A INTERNAL: ACRS 2 2 AEOD 1 1 D AEOD/DEIIB 1 1 'EDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DLPQ/QAB 10 1 1 NRR/DOEA DXR 11 1 1 NRR/DREP/EPB 1 1 NRR/DREP/RPB 10 2 2 DIR 9A 10'RR/DRIS 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 .WEBB N,J 1 1 OGC/HDS2 1 1 R G ILE 02 1 1 RGN5 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 R

I NOTE rO ALL "RIDS RECIPIENTS.

PLEASE HELP US K) REDUCE WASTE.'CT 'lHE DOCUMEMI'XKQRL DESK, RXM Pl-37 (EXT. 20079) %0 EIlIMINA!PE KR3R NAME HKH DISTBZK7ZION LISTS FOR DOCUMENIS YOU DONiT NEED)

TOTAL NUMBER OF COPXES REQUIRED: LTTR 25 ENCL 25

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 December, 21, 1988 G02-88-274 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Nail Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88"24 RESPONSE TO NOTICE OF VIOLATION T he Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated November 23, 1988. Our reply, pursuant to the .

provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, each viotation is addressed with an explanation of our, position regarding validity, corrective action and date of full compliance.

Very truly yours, G. C.'Sorensen, Manager Regulatory Programs REF/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Williams - BPA NRC Site Inspector - 901A yPo/

APPENDIX A Page 1 of 8 APPENDIX A During an NRC inspection conducted from August 22 to September 2, 1988, several 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), as modified by 53 Fed. Reg. 40019 (October 13, 1988), the viola-tions are listed below:

A. Paragraph 6.8.1 of the Technical Specifications requires written procedures to be established, implemented, and maintained for. surveillance and test activities of safety-related equipment.

Paragraph 6.8.2 of the Technical Specifications requires these procedures and changes to these procedures to be reviewed by the POC and approved by the Plant Manager, as set forth in administrative procedure es.

Paragraph 6.8.3 of the Technical Specifications allows tempo ary changes to be made to procedures provided that the intent of the original procedure is not altered, the change is approved by two members of management staff (at least one of whom holds a Senior Operator license), and the change is docu-mented, reviewed by the POC, and approved by the Plant Manager within 14 days of implementation.

Administrative Procedure 1.2.3, "Use of Procedures" (Rev. 12 dated September 18, 1987), requires procedures to be followed in the performance of plant activities. When procedures cannot be followed, a revision to the procedure or a procedure deviation must be completed. In the case of a procedure deviation, documentation prior to its implementation is not required provided the deviation has been approved by two members of plant management/supervi-sory staff and the Shift Manager is of the opinion that the work must continue.

Contrary to the above, changes were made to Sur veil l ance Procedure 7.4.4.3.1.4 during the performance of a drywell sump flow monitor calibration on August 24, 1988, and a procedure revision or procedure deviation was not completed.

This is a Sever ity Level IY violation (Supplement I).

Validit of Violation The Supply System does not acknowledge the validity of this violation.

Just prior to August 22, 1988 the Drywell Sump Flow Monitor. indicated a flow that was approaching the Tech Spec limit, Section 3.4.3.2b, 5 gpm unidenti-fied leakage. A volumetric flow test (using buckets), PPMs 2. 11.3 and 2.11.5 was performed which determined that the indicated flow was greater than the actual flow. Operations requested that the loop be recalibrated. On August 22, 1988 at 0958, surveillance procedure 7.4.4.3.1.4, "Drywell Sump Flow Monitors," was started. During the performance of the procedure the Technicians noted that ther e were problems with the procedure which required

APPENDIX A Page,2 of 8 a deviation. The Technicians obtained the assistance from the Maintenance Engineers to provide guidance on the procedure deviation required to remedy the problems identified with the procedure and ensure the deviation would not cause new problems. Permission was then obtained from the Shift Manager and the IEC Maintenance Supervisor to deviate from the procedure as necessary per PPN 1.2.3.C.3, and to provide .the deviation and completed procedure for, signature and approval prior to declaring the flow monitor back in service.

This was considered acceptable because the floor drain sump flow monitoring instrumentation system does not provide any automatic actuation, but instead, provides indication and high flow alarm only. Therefore, volumetric flow tests were performed within the required frequency to monitor, leakage flow rates relative to the allowable Technical Specification limits. The Shift Manager had decided the work must continue because the accuracy of the drywell sump flow monitor. system was in question and the sump flow indicator was approachi ng the Technical Specification limit.

The procedur e was completed the afternoon of August 24, 1988 'and the proce-dure deviation was written from the notes made during the performance of the procedure. The deviation received approval signatures on August 25, 1988 at 0800 and the procedure was signed off as completed satisfactorily at 0826 on August 25, 1988. The equipment was not returned to service prior to imple-mentation and sign off of the procedure deviation.

Per Plant Procedure 1.2.3, Section C.3, the deviation is not required to be

, documented prior to its implementation providing it has been appr oved verbally by two members of the Plant Management Supervisory Staff. This process should be followed only when, in the judgment of the Shift Manager, work must continue as was the case here.

Corrective Ste s Taken/Results Achieved PPN successfully performed.

Corrective Action to be Taken No fur ther corrective action is planned.

Date of Full Com liance The Supply System is currently in full compliance.

APPENDIX A Page 3 of 8 10 CFR 50.72(b)(2)(ii) requires the licensee to notify the NRC as soon as practical and in all cases within four hours of any event or condition that results in an automatic Reactor. Protection System (RPS) actuation that is not part of a preplanned sequence during testing or reactor operation.

Contrary to the above, the following RPS actuation were not part of the preplanned sequence during testing or reactor operation, and were not reported to the NRC as required:

o At 0844 o'n May 29, 1988, during Mode 5 operation, an RPS actuation occurred during initial testing of the alternate rod insertion (ARI) system. The RPS actuation occurred when air. pressure bled off the scram valves after the ARI system was placed in the test mode and the scram air, header was isolated. Control rod drive air, syste~ leakage resulted from undocumented air. system leaks, and the RPS actuation was not a normal occurrence and was not anticipated in the ARI system test proce-dure.

o At 1553 on August 26, 1988, during Mode 5 operation, an RPS actuation occurred when Division II RPS power was transferred from the alternate to the normal source. The RPS actuation was due to switch over-travel during the power, transfer evolution. The control room logs did not indicate that testi ng was in progress at the time of the RPS actuation, and the licensee could not produce a maintenance work order or, other documentation to demonstrate that testing was in progress during the August 26 event.

This is a Severity Level IV violation (Supplement I).

Validit of Violation The Supply System does not acknowledge the validity of this violation:

"Actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor, operation need not be reported" (10CFR50.72(b)(2)(ii) and 10CFR50.73(2)(2)(iv)). "Operation of an ESF as part of a planned operational procedure or, test (e.g., startup testing) need not be reported. However, if during the planned operating procedure or test, the ESF actuates in a way that is not part of the planned procedure that actuation must be reported." (Page 13 NUREG 1022)

Scram Discharge Volume High High Reactor. Protection System Actuation.

As stated in the regulations quoted above, any RPS actuation that is part of a preplanned sequence during testing need not be reported. The event cited in this violation occurred as part of a preplanned testing sequence and therefore is not reportable. Performance of the Pre-Operational (pre-op) Test Procedure for. the Anticipated Transient Without Scram (ATWS) Alternate Rod Insertion (ARI) System was the cause

APPENDIX A Page 4 of 8 of this event. A step in the ARI Pre-Operational Test Procedure required isolation of the Control Rod Drive Scram Air Header-. Some bleed off of air pressure in the header was expected, and in fact, there was a procedure step to record the amount of pressure lost during the test. While the amount of bleed down was not known prior to the test, the consequences of a large decrease in air header pressure were known.

That is the scram valves open and 'the Scram Discharge Volume (SDV) drain valves close whereby the scram water. fills the SDV and causes an RPS actuation on high water level. The test procedure purposely did not open the bypass valve which would have prevented the actuation. The Event Precursor reviewer stated to the Reactor Systems Supervisor that if the sequence of events in the procedure establish a condition where an RPS actuation could occur, this would constitute preplanning. There-fore, the RPS actuation was the result of a preplanned sequence of testing, and the actuation did not occur in a way that was not part of the procedure.

The condition of the control rod drive system having "undocumented air system leaks" is irrelevant since the Control Rod Drive System, includ-ing the scram air header meets all operational requirements. The scr am header air leaks were investigated following this event because of concerns expressed about the rapidity of the bleed down. No major leaks were discovered and it was judged to be determined impractical to fix most of the minor leaks found during power operation. Those leaks which can be repaired without major piping disassembly scheduled to be repaired in R-4.

August 26, 1988 RPS Actuation.

"On August 25, 1988, at 2211 hours0.0256 days <br />0.614 hours <br />0.00366 weeks <br />8.412855e-4 months <br />, while performing a channel functional test and calibration of the Reactor Protection System RPS Bus "A" EPA breakers, a full RPS actuation occurred due to momentary loss of power to both divisions of RPS. The cause of this event is switch overtravel, which deenergized both divisions of RPS simultaneously" (from WNP-2 Licensee Event Report 88-30).

On August 26, 1988, Control Room Operators (CROs) (Licensed Reactor Operators) were preparing to transfer, RPS "B" power from its alternate to normal power supply. Because of the full RPS trip of the previous day, the Shift Manager, Control Room Supervisor, and System Engineer determined that an opportunity existed to investigate the August 25, 1988 event. This process was consistent with the approved Plant Tr oubleshooting Procedure. The same CRO who performed the power transfer the previous day was instructed to do the power transfer in the exact manner of the previous day with RPS System Engineer watching. CRO duties are rotated daily and this it is unlikely that the same CRO would have performed task on both days and by observing the August 26, 1988 RPS power transfer., the RPS System Engineer was able to determine the cause of the August 25, 1988 event. Therefore, this RPS actuation is considered a preplanned test and is not reportable.

APPENDIX A Page 5 of 8 Corrective Ste s Taken/Results Achieved Pre-op procedures were successfully performed.

Corrective Action to be Taken No further, corrective action is planned.

Date of Full Com liance The Supply System is currently in full compliance.

APPENDIX A Page 6 of 8 Technical Specification 6.8.1 states, in part, that "Written procedures shall be established, implemented, and maintained covering ... the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978." These include "Procedures for Performing Maintenance".

Paragraph E of Administrative Procedure 1.3.9, Revision 9, "Control of Elec-trical and Mechanical Jumpers and Lifted Leads," states in part that any deviations to the determination/retermination data sheet following Shift Manager approval shall be reauthorized by the Shift Manager.

Contrary to the above, each of the "determination/retermination" sheets associated with completed maintenance work requests NWR-A-0110 (trouble-shooting blown fuses on the power supply to solenoid pilot valves for NS-V22A-D) and NHR-AU9257 (repair of leaking valve RHR-V53-B) contained a cable which had been determinated but not reterminated. The changes to the work instruction had not been authorized by the Shift Manager.

This is a Severity Level IV violation (Supplement I).

Validit of Violation The Supply System acknowledges the validity of the violation relative to the incompleteness of data sheets.

Changes to the work scope require Shift Manager. approval. However, changes to the work instructions do not require authorization from the Shift Manager provided the work scope is not changed.

Successful operability -tests demonstrated the cables with undocumented r eter-mination had been properly reterminated. This indicates that the scope of work had not been changed, but that checkoff and verification had not been documented on the data sheets.

Corrective Ste s Taken/Results Achieved Training was performed on 10-21-88 on PPN 1.3.9, Contr ol of Electrical and Mechanical Jumpers and Lifted Leads, emphasizing Determ/Reterm requirements.

Corrective Action to be Taken The procedures and Determ/Reterm Data Sheet in PPM 1.3.9 will be revised to provide more overview that will reduce the probability of documentation omissions.

Date of Full Com liance Revise PPN 1.3.9 prior to R-4 outage, expected to begin during April 1989.

~

APPENDIX A Page 7 of 'S 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action", requires measures to be established to assure that conditions adverse to quality, such as defective equipment and nonconformances, are promptly identified and corrected.

Contrary to the above as of September, 2, 1988, two torque wrenches and one leak rate monitoring instrument had been identified 12-18 months prior. to the inspection as being out of calibration, but an evaluation of the impact of this lack of calibration had not been performed.

This is a Severity Level IV violation (Supplement I).

Yalidit of Yiolation The Supply System agrees with the violation in that the resolution corrective action was not taken in a timely manner,.

Corrective Ste s Taken/Results Achieved A review was completed of the Plant installed equipment that was calibrated and torqued using the three pieces of M8TE in question. The results were as follows:

o Torque Wrench //39433

- Corrective Action - None

- Any work performed utilizing this torque wrench had been redone undei later work packages prior, to the discovery of this violation.

o Tonque Wrench 843121

- Corrective Action - None

- A review of the MWRs utilizing this torque wrench indicated the bolting was gC-II non-pressune boundary or, that it was a temporary installaton (AY1144, Spool Piece).

o Leak Rate Monitor. 827221 Corrective Action - None

- The calibration error. was in the conservative direction, i.e.,

indicated leakage higher, than the actual leakage. On all plant equip-ment the monitor, was used during the period of out-of-calibration, the total leakage indications for. each were well below the allowable 1imi ts.

The review revealed that recalibration and/or. retorquing was not necessary and the disposition was closed. If the review would have revealed a recali-bration was needed, an NCR/PDR would have been generated and appropriate action taken.

0 APPENDIX A Page 8 of 8 Corrective Action to be Taken bilityy The 18C Supervisor, and/or Engineer will be counseled as to their responsi-per PPM 1.5.4 and the timeliness of any required corrective action.

The procedure, PPM 1.5.4, will be revised to include time limits for, review and corrective actions on all out-of-calibration measuring and test equip-ment. Also, the procedure is void on the tracking of these deficiencies. A tracking mechanism will be incorporated in this revision to the procedure.

All supervisors will be reminded of their. need to take prompt action in helping resolve outstanding deficiencies of measuring and test equipment.

Date of Full Com liance:

February 1, 1989.

i@.

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