ML18085A152
| ML18085A152 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/04/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18085A147 | List: |
| References | |
| 50-272-80-04, 50-272-80-4, 50-311-80-01, 50-311-80-1, NUDOCS 8010300245 | |
| Download: ML18085A152 (3) | |
Text
APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Docket Nos. 50-272 50-311 Based on the results of an NRC inspection conducted on January 28-31 and February 1, 4-7 and 11-13, 1980, it appears that certain of your activities were not conducted in full compliance with conditions *of your NRC Facility License Nos.
DPR-70 and CPPR-53 as indicated below. Items A and B are Infractions and Item C is a Deficiency.
A.
10 CFR 50, Appendix B, Criterion V, states in part, "Activities affecting quality shall be prescribed by documented instructions, proc~dures *.. of a type appropriate to the circumstances *... "*
Listed below are two examples of failure to develop/establish appropriate instructions/procedures:
FSAR Amendment 43, Section D.2 states in part, "The Engineering De-partment **. (3) Is responsible for identifying structures, systems and components covered by the QA Program *...
11 Station Procedure AP-17, The Electric Production Department Quality Asssurance Program at Salem Generati_ng Station, Revision 5, PaY'.agraph 2.4.1 states in part, "The General Manager-Engineering is responsible for: a) Maintaining and Updating the Master Equip.ment List (MEL) **..
11 Contrary to the above, as of February 13, 1980, the licensee had not developed MEL's for either unit.
FSAR Amendment 43, Section D.2 states in part, "These activities shall be performed in compliance with.*. (8) Regulatory Guide 1.64 *...
11 which endorses ANSI N45.-2.ll-July 1973, Qualfty Assurance Requirements for the Design of Nuclear Power Plants. Paragraph 4.3 of the standard
- states *in part, "Procedures shall be es.tablished for the preparation*
and control of drawi_ngs. Typical subjects to be covered by such pro-cedures are:.*. (10) As-Built Drawings..*. "
Contrary to the above, as of February 13, 1980, the 1 icensee had not established procedures that:* addressed how users of controlled drawings from the station Technical Document Room would be alerted that a given drawing was affected by a recent modification; nor how Control Room operators are alerted to and receive as-built information on recent modifications that affect those drawi_ngs utilized f9r plant operation.
APPENDIX A 2
B.
10 CFR 50, Appendix B, Criterion V, states in part, 11Activities affecting quality shall be prescribed by documented instructions, procedures... and shall be accomplished in accordance with t~ese instructions, procedures....
11 Listed below are three examples of failure to accomplish activities in accordance with established instructions/procedures:
Station procedure AP-8, Station Design Changes, Tests and Experiments, Revision 4, requires that the design change package (DCP) forwarded from the corporate offices to the* station for implementation have attached or include: the written safety evaluation which provided the bases for the determination that the modifications/tests did not involve unreviewed safety questions; material lists; applicable speci-fications; the mode of operation, priority and implementation request date entered on the "Design Change Request Form"; and, all required ADCN's (detailed instructions from appropriate e.ngineers).
Contrary to the above, six DCP 1s did not include or have attached in one instance or another all of the required information (this example applies to Unit 1 only).
FSAR Amendment 43 establishes a commitment to ANSI N18.7-1976, Admini-strative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants. Paragraph 5.2.7 ~f that standard states that the guidance of ANSI N45.2.8,' Supplementary Quality Assurance Requirements
- for Installation, Inspection and Testing... of Nuclear Power Plants, shall be applied to operating plants. ANSI N45.2.8 requires that a system of controls be established to* assure that as-built information is being processed. Station procedure AP~.17, paragraph 5.4 states in part,
- 11The General Manager-Engineering is re.spon.sible for: *.. Ensuring the copies of these documents* {e.g., drawings} at the station are kept current by incorporation of implemented de.sign cha.nges.
11 Contrary to the above, five controlled drawings in the Control Room and eight controlled drawings in the station* Technical Document Room did n*ot depict the latest *as-built conditions, were not annotated in some fashion attesting to this fact, nor was there a method by which a user could determine* the as-built condition (this applies to Unit 1 only).
The 11 Introduction 11 to the Engineering Department Operating and Design Procedures (EDODP) Manual e'stablishes a requi.rement that all department procedures be reviewed on an annual.cycle and revised as necessary if the review so indicates.
APPENDIX A 3
Contrary to the above, the Controls, Design, Electrical and Mechanical Divisions of the Engineering Department did not review on an annual cycle fifteen pro,c.edures {"five each) that were sampled..
C.
10 CFR 50, Appendix B, Criterion XVII, states in part, " **. the applicant shall~ establish requirements concerning record retentions, such as duration, location, and ass_igned responsibility."
FSAR Amendment 43, Section D.2.17 states in part, 11 Records... shall be identified and maintained in accordance with Regulatory Guide 1.88... Design and construction records are replicated via microfilm and stored in the
- record facility maintained at the generati_ng station and off.,.site locations.".
Contrary to the above, original single copy records associated with five Design Change Packages which were transmitted from the station to the corporate *offices between July, 1977 and January, 1978, had not been micro-fi lmed and were stored at one location only (corporate engineering offices) in non-fire rated steel cabinets (this applies to Unit 1 only).*