ML18044A497
| ML18044A497 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/18/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18044A496 | List: |
| References | |
| 50-255-79-20, NUDOCS 8002070374 | |
| Download: ML18044A497 (2) | |
Text
Appendix A NOTICE OF VIOLATION Consumers Power Company Docket No. 50-255 Based on the results of the NRC inspection on October 22-26,29 and 30, 1979, it appears that certain of your activities were not conducted in full compliance with NRC requirements as noted below. These items are infractions.
- 1.
Technical Specification 6.8.1 and 6.8.3 require that written pro-cedures for surveillance activities be followed unless temporary changes are made which are approved by two members of the PRC at least one of whom holds a Senior Reactor Operators license and that the change subsequently be reviewed by the PRC and approved by the Plant Superintendent.
Administrative Procedure 10-3-1, "Temporary Procedure Changes," which is also required to be followed by techn-ical specification 6.8.1; establishes a system to make these changes and to incorporate them permanently into the procedure where required.
Contrary to the above on July 5, 1978, changes were made to surveill-ance procedure A0-3, "Shutdown Cooling System" test without reviews, approvals and docume~tation required above.
The change affected the after test position of sodium hydroxide system valves 3363ES and 3364ES and corrected an error in the procedure.
Failure to make the change properly resulted in the error still existing in the procedure and in these valves being incorrectly positioned when the procedure was performed a year later.
- 2.
Technical Specification 6.9.2.a(6) requires that a prompt report with written followup within fourteen days be made of procedural inadequcies which prevent or could prevent, by itself, the fulfill-ment of the functions required of systems required to cope with an accident analyzed in the FSAR.
Contrary to the above procedure, inadequacies in the valve check off sheets of surveillance test A0-3, "Shutdown Cooling System Tests",
which resulted in valves in the sodium hydroxide portions of the iodine removal system being inadvertently closed for a period of time on July 29 and 30, 1979, was not reported within the required time.
- 3.
Technical Specification 4.5.3.a, Recirculative Heat Removal Systems requires the portion of the shutdown cooling system that is outside the containment be tested either by use,~in normal operation or hydrostatically tested at 255 psig at the intervals specified in
'4.5.3.d.(twelve months).
Appendix A Contrary to the above procedure A0-3, Shutdown Cooling System Test, Rev 4 which was performed on July 29, 1979 and July 5, 1978, to fulfill the above requirement tested the piping at less than 255 psig and did not test piping outside the containment between valves 3199 and 3190 and MOV3016.
- 4.
10 CFR 50 Appendix B Criteria XII Control of Measuring and Test Equipment requires measures be established to assure instruments used are properly controlled, calibrated and adjusted at specified periods to maintain accuracy.
Administrative Procedure 17.0 re-quires test equipment be traceable.
QAPP 12-51 requires test eq-uipment which is not recalibrated within its specified calibration interval to be considered nonconforming and not used until correc-tive measures have been taken.
Contrary to the above, the serial number of the test gauge used in performing surveillance test A0-3 on July 5, 1978, was not recorded.
Three different serial numbers were recorded for the performance of A0-3 on July 29, 1979.
Deadweight tester serial number 8428-100018 was used to test a gauge on June 20, 1978, the calibration due date for the tester was June 13, 1978.
- 5.
10 CFR 50.55a(g) requires inservice testing of ASME Code Class 1,2 and 3 valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Co4e 1974 Edition and Addenda through Summer 1975.
Article lWV-3410 of this code requires that the valve be tested monthly if an increase in stroke time of 25% or more from the previous test is found.
Contrary to the above, data obtained from Q0-5, "Valve Test Procedure" on January 17, 1979 and April 17, 1979, show that valve CV-0533B, steam supply to turbine driven auxiliary feedwater pump, increased from 42.2 seconds to 57.0 seconds (35% increa~e) and the test fre-quency was not increased to monthly.
This item appears to be re-petive as IE Inspection Report 50-255/78-23 contained a similar item of noncompliance regarding inservice testing of ASME Code Class 1,2 and 3 components.
- 6.
Technical Specification 4.13.c requires that during normal plant operations, Phase I measurements (Reactor Internals Vibration Monitoring) shall be recorded and analyzed once per seven days.
Technical Specification 4.0.2 allows extension by 25% of the inter~
val provided any three consecutive intervals do not exceed 3.25 times the specified interval.
Contrary to the above, measurements were made on July 2, 11, 20 and
.31, 1979, which exceeds the 3.25 times the interval for three inter-vals and in one instance the 25% allowable extension.
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