ML17285A655
| ML17285A655 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/20/1989 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A654 | List: |
| References | |
| 50-397-89-06, 50-397-89-6, NUDOCS 8908110337 | |
| Download: ML17285A655 (7) | |
Text
APPENDIX A NOTICE OF VIOLATION Washington Public Power Supply System Washington Nuclear Project Unit 2 Docket No.
50-397 License No.
NPF-21 During an NRC inspection conducted from March 27 through April 7, 1989, 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:
A.
10 CFR Part 50, Appendix B, Criterion III requires that measures be established to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2 and as specified in the license application, are correctly translated into specifications,
- drawings, procedures and instructions.
Section 50.2 provides that the design basis includes "... specific values or ranges of values chosen for controlling parameters as reference bounds for design."
Contrary to the above, on December 13,
- 1983, an incorrect engineering calculation was issued, which defined values of reference bounds that were subsequently incorporated into Technical Specification Surveillance Procedure 7.4.5.1.8.
This resulted in incorrect acceptance criteria of 122 psig minimum discharge pressure at 7450 gpm flow at the discharge of the Residual Heat Removal
- System, whereas the actual value should have been 130 psig.
This is a Severity Level IV violation (Supplement 1).
B.
10 CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
WNP-2 installation drawing DO-502-1 specified the required location of pipe support DO-918 for an emergency diesel generator fuel oil drain system; WNP-2 installation drawing DSA-4806-1 similarly specified the required locations of pipe supports DSA-4806-12 and -13 for the diesel starting air system.
WNP-2 procedure 10.2.29, Revision 2, part 10.2.29.5.E specifies an installation tolerance of 2 inches for specified pipe support locations.
Contrary to the above, on May 8, 1989 pipe support DO-918 was installed and accepted by craft personnel at a location 3-1/4 to 5 inches from the location specified on drawing D0-502-1. Pipe supports DSA-4806-12 and -13 were installed 8 and 7 inches, respectively, from the specified locations.
This is a Severity Level IV violation (Supplement I).
gpp81 f Q337 8
Qp03cy7 qppnO pgp ADQCL( 0>
p~()
6
C.
10 CFR Part 50, Appendix B, Criterion VI requires that "Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings.
including changes ihereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed.
Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible'organization."
Page II-4 of the WPPSS Operational guality Assurance Program Description (WPPSS-gA-004),
Revision 9, commits that "The Supply System will implement the Regulatory Position of Regulatory Guide 1.33, Rev.
2
( February 1978)".
The Regulatory Position of RG-1.33 provides that "The overall quality assurance program requirements for the operation phase that are included in ANSI-18.7-1976/ANS-3.2 are acceptable to the NRC staff and provide an adequate basis for complying with the quality assurance program requirements of Appendix B to 10 CFR 50...".
Contrary to the above, as identified during the inspection period May 8-26, 1989, the above requirements were not fully incorporated into WNP-2 procedure PPM-1.3.7, "Maintenance Work Request",
nor were the requirements adequately implemented, for the following work and documentation then in progress:
l.
ANSI N18.7, Part 5.2.15, provides that document control measures shall provide for identification of individuals or organizations responsible for reviewing and approving documents and revisions
- thereto, and ascertaining that proper documents are being used.
Document control procedures did not identify individuals/approvals for revisions being made under all circumstances, i.e. for MWRs AT8858 through AT8861 (electrical switch replacement work on Target Rock valve operators),
the Maintenance Engineer responsible for work made minor revisions to work instructions of the MWRs without written concurrence by original reviewers/approvers, i.e. guality Control and the originating department (Plant Technical).
For MWR AS-0045 (Maintenance on DG Engines 1B1 and 1B2), the Operability Check Sheet of the MWR had a retest added as a result of the new MWR step 15, without evidence of gC rereview.
2.
ANSI N18.7, Part 5.3.2, provides that procedures shall contain a
revision number or date.
Revisions to WNP-2 work instructions (a form of work procedure) did not include revision numbers.
For example, procedure PPM 2.7.2 (Emergency Standby A.C. Generator),
Paragraph C, step 16.'d, was changed with an undated informal adhesive note; also, for MWR AS-0045 (Maintenance on DG Engines 1B1 and 1B2), the Operability Check Sheet of the MWR had a retest added as a result of new MWR step 15 without a revision number or date indicated for the change.
I
3.
ANSI N18.7, Part 5.3.5, provides that applicable sections of the related documents shall be referenced in the procedure.
Mork Requests NWRs AU9988, AT7644, AS0045
- AS0112, AT4377 and AT4378 invoked related procedures without identification of applicable sections.
4.
ANSI N18.7, Part 5.2.1, provides that if documentation of an action is required, the necessary data shall be recorded as the task is performed.
Administrative procedures did not define when tasks performed should be documented.
The "work performed" section of certain wor k instructions were documented after the jobs had been completed, e.g., installation work performed on valve RHR-RV-1B (OR AU9988),
and quality control inspection of testing of diesel generator fuel oil drain piping (MWR AT8496) and service water valve SM-V-12B (OR AT7644).
This is a Severity Level IV violation (Supplement I).
D.
10 CFR Part 50, Appendix B, Criterion XI, provides that testing shall be identified and performed in accordance with written test procedures that include requirements and acceptance limits contained in applicable design documents, provisions for assuring that all prerequisites for the given test have been met, and documentation of test results to assure that test requirements have been satisfied.
Contrary to the above, during the inspection period May 8 - 26, 1989, the above requirements were not implemented for test procedures utilized for PNR 86-332 (pressure testing emergency diesel oil day tank piping).
The procedure neither identified nor specified the position of gate valves DO-V-56A, 56B and 56C (located within the test boundary);
the test procedure did not identify/specify any of the four new screwed joints in each pipe run; and flanged joints in the pipe runs were not listed in the test data sheets.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply System 'is hereby required to submit a written statement of explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Mashington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the NRC Senior Resident Inspector, Washington Nuclear Project Unit 2, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for hach 1 violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results
- achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not
- 4 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.
Consideration may be given to extending the response time for good cause shown.
FOR THE NUCLEAR REGULATORY COMMISSION Dated at Walnut trek California.
this~ day of
, 1989 Q/
R. P.
Zimm rman, ct ng Director Division of Reactor Safety and Projects