ML18085A479
| ML18085A479 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/17/1980 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18085A478 | List: |
| References | |
| NUDOCS 8101090852 | |
| Download: ML18085A479 (5) | |
Text
.rick W. Schneider Vice President Pub I ic Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201 /430-7373 Production October 17, 1980 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Gentlemen:
COMBINED INSPECTION 50-272/80-19 AND 50-311/80-14 We have reviewed the report of the subject inspection conducted by Messrs. G. Napuda and G. Simonetti of your office on July 28-31, August I, and 4-8, 1980.
Our response to the deficiencies identified in Appendix A is as follows:
Item A Deficiency 10 CFR 50, Appendix B. Criterion V, states in part, "Activities affecting quality shall be prescribed by documented instructions, procedures *** of a type appropriate to the circumstances and shall be accomplished with these instructions, procedures.** ".
Listed below are examples of-the licensee's failure to implement/
follow established procedures:
- a.
FSAR Amendment 43, Section D.2.2 states in part, "The QA program shall be applied during the pre-operational and operational phases to.the extent consistent with the items or activities important to safety."
"These activities shall be performed in compliance with... quality-related regulatory requirement which include *** (5) Regulatory Guide 1.38 *.. 10/76."
Regulatory Guide 1.38 (10/76) endorses ANSI N45.2.2 Section 5.4 of the Standard states in part, "A system or method of identifying the status of items **. shall be employed that clearly indicates whether items are acceptable or unaccepta-ble for installation." A controlled physical separation is an acceptable equivalent method."
"When tags are used **. ;
Boyce H~ Grier, Dir.
2 -
10-17-80
- t~gs shall be securely affixed to the.items and displayed in*
an area that is_readily accessible.".
AP-19, Revision 3., Section 6. 4. 3 states in part, "The QA reject tag shall* be attached to the item and the rejected.
item shall remain in the hold.area *** ".
SR-3, Revision 2, Section 4.5.2 states in part, "If required documentation is incomplete *** (a) the storekeeper shall attach a QA rej*ec:t tag *** ".
Section 4. 5. 3 states in part, "If the *
... inspection of the safety related, QA required or CCI is un-acceptable-. ** (a).the storekeeper shall *** attach a QA reject tag* (Appendix C) to the item."
"(b), All. deficient items shall remain in the Hold Area. in* warehouse #2."
"If the designated Ho.ld Area: is filled **.* a temporary hold area Inay be des~gnated. "
Contrary,to the above, lot 26 of Boric Acid shipment P.O. 727471, received at Warehouse #2 on July 2, 1980, and designated unacceptable during the receipt inspection was not being held l.n a Hold Area.nor.
was the referenced QA reject tag fixed to. the shipment and dis-played in a readily accessible area.
b.*
QAP-17, Revision 5, Paragraph 4.2.3 states in part
" ***. inspection records. shall identify the *** inspector or data recorder. "
Contrary to the above, warehouse inspectiori records for the period November 1979 - June 1980 (with the exception of April 1980) were without appropriate means of identifying the* inspecting of:Cicial.
c *.
SR-8, Revision 1, Section 4. 3. 2 states in part, "The Office Administrator or his designee shall perform monthly inspections of all safety related storage areas ***
Results of storage inspections shall be forwarded to the Technical Document Room for. microfilming per AP-11."
Contrary to the above, the licensee was unable to provide data indicating the monthly inspection for April 1980 had been completed.
Furthermore, the results of. the storage inspections were not being forwarded to the Technical Document Room for microfilming.
Item B, Deficiency Technical Specifications, Section 6. 8.1 states in part, *iwri tten procedures shall be established, implemented and maintained cover-ing activities referenced.below:
- a.
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33 (2/78)."
Boyce H. Grieri Dir~
3 -
10"'.'"11-ao
. Regulatory Guide 1.* 33, Appendix A, states *in part, nThe following are typical safety~related activities that should be *covered b~7..
- wr'i tten procedtires ** ~ 8 *.. Procedures for.Control of Measuring anci *
- Test Equipment *.** "
AP-22, Section 3*.1 states in part, "All measuring and test equip-
. ment *** shall be calibrated and checked in accordance with approved procedures."
"Procedures and data sheets shall be consistent with the vendor's manual requirements *** "
The John Fluke Instrument Manual for Model 8120A Digital Multi-meter,:* Section
- 4.-6 3 states in part, "Calibration should. be per-.
formed under the following test conditions:
ambient temperature.
25.°C + 5°C, relative hurnldity.less than 70%."
Contrary.to' the above,*the li~ensee was UI'lable to produce records.
- that the following John Fluke Digital Multimeters~ Model.8120A, calibrated on juiy 28, 1980 and* subsequently used on safety-related equipment were calibrated under the environmental con-ditions specified by the vendor.
Serial Number (SN) PD-003 SN PD-004 SN PD-187 Reply to Item A(a)
Due to the quantity of boric-acid drums received, it was impos-sible to store all the drums in the Hold Area; the requirement for a temporary Hold Area was overlooked.
A reject tag was placed-on one of the drums, but this tag evidently had fallen off.
Prior to the completion of your inspection, a temporary Hold Area for the drums was established by placing plastic stanchions and yellow rope with a "Hold" sign on the rope.
A new reject tag was placed on the drums.
In the future, temporary Hold Areas will be established to segregate the b_oric acid drums on hold and a reject tag will be affixed to those drums which face out.
We are in compliance now.
Reply to Item A(b)
The requirement to identify the inspecti~cj official was overlooked
- Boyce H *. Grier, Dir.
4 -
10-17""!80 The for:i:n. used to perform the inspections has a blank space with.
.. the heading "Office *Administrator or Designee.,. intended to iden- *.
. tify *who made the. "inspection *.. *All previous inspection forms have..
. *.now been signed by the Office Administrator who performed the.
inspectio~~-
In th.e *future the Off ice Administrator, or designee, shall sign the form used to perform the inspection.
We are in compliance now.
Reply.. to Item *A (c)
. The micrqf ilming. of monthly inspection reports.. was.inadvertently overlooked.
The April storage inspection was complet~d.
How~
- ever, due to the heavy work load the proper docurnentatj_on was overlooked.
In the future the monthly* storage inspections will be microfilmed at the end of each year.
A suspense* file has been established and will be pulled each month.to ensure the inspections are made and inspection reports are. microfilmed at year end.
We are in compliance now.
Reply to* Tterri B This inspection took place during the 'time period when the Per-formance I&C Department,. including the Calibration Lab, was in the process of changing locations.* During this move the temper-ature and relative humidity recorder (RHT-IV) became misplaced.
This discrepancy was not noticed until the time of the inspection.
As soon as this deficiency was brought to our attention, a new recorder was calibrated and placed* in the Calibration Lab.
- Also, at the. same time,.the mul timeters listed were taken out of service and subsequently recalibrated~ they were not found to be *out of calibration.
This is an isolated case. *caused by the department relocation.
Additionally, any time an instr.ument calibration becomes suspect for ariyreason the instrument is recalibrated to verify accuracy.
If it is found out of calibration, all equipment measured* by the
- suspect instrument is evaluated in accordance with AP-22,. Section
- 10.
Boyce H.
Grie~, Dir.
- 5.
We are in compliance now.
- If* you h~ve ~ny further questions with regard to this matter we
- will be pleased to. discuss _them with you*.
Sincerely, CC** Director, Office of Inspection and Enforcement Nuclear Regulatory Commission Washington~ DC 20555