ML17326A921
| ML17326A921 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/18/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17326A920 | List: |
| References | |
| 50-315-81-21, 50-316-81-24, NUDOCS 8112010304 | |
| Download: ML17326A921 (5) | |
Text
A endix A NOTICE OF VIOLATION American Electric Power Service Corporation Docket No. 50-315 Docket No. 50-316 As a result of the inspection conducted on August 1 through September 30,
- 1981, and in accordance with the interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
l.
10 CFR 50, Appendix B, Criterion XVI states, "Measures shall be estab-lished to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected.
In the case of significant, conditions adverse to quality, the measures shall assure that the cause of the condition is determined and correc-tive action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
AEPSC General Procedure No. 32, "Preparation of Submittals to the USNRC" states in part, "The AEPSC Nuclear Safety and Licensing Section shall be responsible for overall administration of preparation includ-ing the draft, input to commitment program, preparation of review
- copy, and final submittal."
AEPSC (}uality Assurance is responsible for verifying the draft sub-mittals are factual.
The PNSRC is responsible for verifying that plant operations, originated draft submittals are factual.
Contrary to the above on September 10, 1981, while confirming the licensee's corrective action letter dated May 30,
- 1980, responding to the items of noncompliance identified in IE Report No. 50-315/80-04, and 50-316/80-03 the inspector observed that Demineralized water valves (DW-182 and DW-181) in the vicinity of the spent fuel pit had not been padlocked nor had a check valve been installed at outlet DW-182 as stated in the corrective action letter.
This is a Severity Level V violation (Supplement I).
2.
Technical Specification 6.8.1 states in part, "Written procedures shall be established, implemented and maintained covering activities recommended in Appendix A of Regulatory Guide 1.33; and for refueling operations."
Si120i0304 Biiii8 PDR ADQCK OS0003iS PDR
Appendix A Contrary to the above, the licensee was unable to provide the inspector with a procedure addressing the use of a fire hose for filling and making up water to the Refueling Transfer Canal/Spent Fuel Pit 'from the Boric Acid Blender during the recent refueling outage.
This is a Severity Level V violation (Supplement I).
3.
10 CFR 50, Appendix B, Criterion XVI states, "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and cor-rected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is deter-mined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
The licensee's letter of July ll, 1979, (AEP:NRC:00224) responding to a noncompliance item cited in IE Report No. 50-315/79-11 stated
- that, corrective action would be to have the cognizant AEPSC Design Division review the effects of'he RFC (12-2254) on containment integrity and then submit their findings for PNSRC review.
Additionally, it was stated that the installation of the temporary roof and proposed mod-ification would receive a proper review.
Contrary to the above, during an inspection of the item on September 1-3, 1981, it was.noted that the Design Division review was lacking and that a review by the PNSRC was never done.
In addition, although the repair procedure for the temporary roof attachments were onsite and approved by September 17, 1979, the repairs still had not been completed on September 3,
1981.
This is a Severity Level V violation (Supplement I).
4.
Technical Specification 6.5.1.6.d states, "The Plant Nuclear Safety Review Committee (PNSRC) shall be responsible for review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety."
10 CFR 50, Appendix B, Criterion V requires activities affecting quality be prescribed by documented instructions, procedures or drawings and that they be accomplished in accordance'ith these instructions, procedures or drawings.
Appendix A I Contrary to the above, the required safety review was not conducted for a revision to design change No.
RFC 12-2500.
Further AEPSC General Procedure No.
25 was not,followed in that documentation was not transmitted to the site, prior to implementation of the design
- revision, showing that the required review and approvals had been conducted at the New York offices.
This is a Severity Level XV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written state-ment or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and 'the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.
Under the authority of Section 182,of the Atomic Energy Act of 1954, as
- amended, this response shall be submitted under oath or affirmation.
Consideration may be given to -extending your response time for good cause shown.
I)
Dated James G. Keppler Regional Administrator
I y
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