ML18095A437
| ML18095A437 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/21/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A436 | List: |
| References | |
| 50-272-90-200, 50-311-90-200, NUDOCS 9009060035 | |
| Download: ML18095A437 (4) | |
Text
APPENDIX A NOTICE OF VIOLATION Public Service Electric & Gas Company Docket Nos. 50-272 & 50-311 License Nos. DPR-70 & DPR-75 Salem Nuclear Generating Station, Units 1&2 During the period April 9 - 13 and April 23 - 27, 1990, a maintenance team inspection identified apparent violations of NRC requirements involving failure to maintain design features of the facility required to mitigate the consequences of flooding, including modification to a design feature of the facility without performance of a 10 CFR 50.59 safety evalution, and multiple examples of failure to establish, maintain and follow written procedures for variou~ pla~t activities.
In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1990), the following are identified as violations.
- 1.
10 CFR 50.59, Changes, Tests, and Experiments, states that the hold~r of a license authorizing operation of a production or utilization facility
- 2.
. may make changes in the facility as described i.n the safety analysis report without prior Commission approval, unless the proposed change involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question.
Further, 10 CFR 50.59(b) states that the.
licens*ee shall maintain records of changes in the facility made pursuant to Section 50.59, to the extent that such changes constitute changes to the facility a*s described in the safety analysis report.
These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question as defined in 10 CFR 50.59.
Salem Updated FSAR, Section 3.4, 11Water Level (Flood) Design, 11 states that the auxiliary building is watertight up to elevation 115 feet.
All doors in the outer auxiliary building walls below elevation 120.4 feet are watertight.
Contrary to the above, as of April 9, 1990, modified hatch covers were installed in the service water rooms of both units that did not meet the water tightnl:!SS specified by the Updated Final Safety Analysis Report, Section 3.4 (delineated by design documents drawing 201044 and Cambell Foundry Co. Figure #1866227, Type 2).
No written safety evaluation was available for this modification pursuant to 10 CFR 50.59.
This is considered a Severity Level IV Violation (Supplement I).
10 CFR 50, Appendix 8, Criterion XVI requires that conditions adverse to quality, such as defective material and equipment, be promptly identified and corrected.
9009060035 900821 PDR ADOCK 0~000?7?
0
~Be-
fr. r Appendix A 2
Updated FSAR Section 17.2.16 states that the station general manager is responsible for assuring that conditions adverse to quality are promptly identified and corrected for all activities involving station operations, maintenance, testing, refueling, and modification.
Administrative procedures that govern station activities covered by the QA program provide for the timely discovery and correction of nonconformances.
Contrary to the above, as of April 9, 1990, water tight doors between the service water valve rooms and the surrounding areas of the auxiliary buildings had not been adequately maintained in that the door latching dogs required to be operated to make the door closure water tight were unmovable from their undogged position when reasonable force was applied.
This condition had not been promptly identified and corrected.
This is a Severity Level IV Violation (Supplement I) 3~
Salem Nuclear Generating Station Unit 2 Technical Specifications, Section 6.8.1, requires that written procedures be established, implemented, and maintained for various plant activities, including those recommended in Appendix A of Regulatory Guide 1.33, Revision 2; February 1978.
As of April 27, 1990, the followin~ examples of failure to follow written*
procedures were identified:
- a.
Administrative Procedure AP-9, "Work Control Process, 11 Revision 1, Section 5.1.5.b, requires that, when performing a task which requires a written procedure, the procedure shall be present and followed step-by-step (unless deviation is permitted in the body of the procedure). while the task is being performed.
Further the licensee's "Written Instruction Use Standard" part of the Salem Handbook of Standards, dated August 14, 1989, requires step-by-step use and sign-off of procedures categorized as "Category 1 11 instructions.
Contrary to the* above, work on valve 22BF19 performed using procedure IC14.1.058, 11BF-19 Maintenance.Procedure, 11 Revision 0, which was categorized as a 11Category 1 11 instruction was completed w*1thout st~p-by-step sign-offs having been performed.
- b.
Procedure M14A-2, "General Instructions for Bolted Globe, Stop, and Stopcheck, Plug and Piston Valve Maintenance, 11 Revision 2, Step 7.3 requires that thread engagement for bolted fasteners be a minimum of one thread past the nut.
- c.
Contrary to the above, feedwater control valve actuator diaphragms for valves 21BF19 and 23BF19 incorporated several bolts which did not extend through the nuts.
Administrative Procedure AP-15, 11Station Tagging Program, 11 Revision 5, Section 6.1 requires that red blocking tags be removed only by authorized Operations Department personnel.
AP-15, in Section 6.8, further prohibits operation of equipment tagged with a red blocking tag until the tag has been properly released and removed.
' J Appendix A 3
Contrary to the above, valve 21MS81 had been cut from the associated piping system while red tagged by blocking clearance #057385 without being properly released and removed.
- d.
Piping Specification No. S-C-MPOO-MGS-001 for Piping Schedule SPS27, "Service, Fresh and Salt Water, 11 Revision 2, requires that copper alloy-to-steel dissimilar metal flange joints be installed with Maloney Standard Flange insulation style E-N-0-W 1/8 inch thick or approved equal.
Contrary to the above, Maloney isolating washer kits were not installed in several bolt holes in dissimilar metal flange joints in the service water system during reassembly of the joints under DCP No. 2SC2018 and work orders 890914164, 891026108, 90030911, 89102611 and 900319121.
These examples are collectively considered as one Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted; (2) the corrective steps which have been taken to and the results achieved; (3) corrective steps which will be taken to avoid further violations; and, (4) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending this response time.
~t--.
Weakness Description APPENDIX B
SUMMARY
OF WEAKNESSES Management of maintenance backlog items and an absence of an effective backlog reduction program.
Lack of root cause analysis training for system engineers.
General lack of adequate root cause analyses.
Lack of capability to readily analyze older maintenance data for performance monitoring and evaluation.
Inadequate technical procedures, absence of formal maintenance procedures for important and repetitive tasks.
Poor control of contractor maintenance activities.
Report Section 3.2.4 4.1.6 3.3.2 4.1.3 4.1. 7 4.2.3