ML19294B117
| ML19294B117 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/20/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19064A045 | List: |
| References | |
| 50-219-79-18, NUDOCS 8002270166 | |
| Download: ML19294B117 (6) | |
Text
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APPENDIX A NOTICE OF VIOLATION Jersey Central Power & Light Company Docket No. 50-219 Morristown, New Jersey License No. OPR-16 This refers to the inspection conducted by the NRC Performance Appraisal Branch at the Oyster Creek Nuclear Generating Station of activities authorized by NRC License No. DPR-16.
During the inspection conducted October 1 - November 8,1979, the following iterns of noncompliance were identified.
A.
Technical Specificatica 6.8.1 requires tha.t written procedures be established, implemented and maintained that meet or exceed the require-cents of Sections 5.1 and 5.3 of American National Standard N18.7-1972.
Section 5.1.5 of ANSI N18.7-1972 specifies that procedures provided for control of equipment require independent verification, where appropriate, to insure that necessary reasures, such as tagging of equipment, have been taken correctly.
Contrary to the above, Precedure 108, " Control of Tagging, Electrical Jurr.pers, Lifted Electrical Leads, Keys and Locked Valves," Revision 12, did not provide for irdependent verification, as appropriate, for the placing /
removing of tags, electrical jurrpers, and lif ting of electrical leads.
This item is an ir. fraction.
8.
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
and Operational 0.ality Assurance Plan,Section X, " Management and Use of Docurrents," Revision 2, require that activities af fecting quality be prescribed by doctmented instructions, procedures or drawings, and be accorrplisned in acccrcance with those instructions, procedures or drawings.
1.
Procedure 120, " Fire Hazards," Revision 5, October 12, 1979, paragraph 5.1.4, requires that stairway and fire doors be kept closed at all times when n:t being used for passage.
Paragraph 5.1.12 requires that all wood used in safety related areas be fire retardant.
Contrary to the above, on October 24, 1979, the inspector found that three fire / hall coors were blocked open.
The doors included the 480V hall door, the cable spreading room door, and the 119 foot elevation fuel storage area door.
Additionally, the fuel storage area contained wooden crates and boxes which were not fire retardant.
This ite:i is an infraction.
2.
Drawing A-800-204-002, " Type 2 Support," requires the use of two nuts for the installation of the "U" clamps for the described pipe support.
Contrary to the above, on October 24, 1979, "U" clamps were found installed with one nut.
The installation was at the 51 foot elevation YS
Appendix A of the Reactor Building.
The pipe supports were attached to the new fire protection water system piping.
This item is an infraction.
3.
Procedure 700.1.009, " General Concrete Core Drilling Procedure,"
Revision 2, Document Serial No. 217, paragraph 3.1, requires that a job supervisor sign the data sheet and attach the Job Order form.
Paragraph 5.1.4 requires the completion of the requirements of th? Job Order.
Procedure 6009, " Installation, Fabrication, Engineering, Test and Inspection Specifications," Revision ' paragraph 5.7.2, addresses installation, fabrication, engineering, test or inspection require-ments with respect to ANSI Standards.
Paaagraph 5.7.2 of Procedure 6009 specifies some examples of the types of requirements to be con-sidered for inclusion, including:
"grouti1g requirements for equip-ment foundations and for penetrations; bolt torquing and locking re qui recents. "
The Operational Quality Assurance (0QA) Plan, Revision 2, page 59, prescribes the use of ANSI N45.2.8 guidance in conjunction with the 0QA Plan.
Part I of Appendix A of the 0QA Plan lists the fire prctection system as one of the systems covered by the Quality Assurance Program.
a.
Cor,trary to the above, on October 30, 1979, the inspector, on reviewing field records for concrete core drilling, determined that a Job Order had not been completed.
b.
Cor.trary to the above, on October 24, 1979, an abandoned anchor boring was identified in the Reactor Building at the southeast corner of the 51 foot elevation.
The hole had been drilled in cor.nection with installation of a fire protection system pipe support but had not been properly grouted.
In addition, there were no written instructions available to address action when rebar was contacted, the relocation distance allowed for the placement of a new anchor bolt or for grouting abandoned holes.
This item is an infraction.
4 Administrative Procedure 105, " Maintenance, Repair, and Modification Control," Revision 5, requires that the following steps be accom-plished.
Step 5.2.7 requires that the Plant Operations Review Committee (PORC) ensure that plant operating procedures are updated to include changes required as a result of codifications.
Appendix A Step 5.2.8 requires that, following the implementation of a modifica-tion, the Manager, Generation Engineering, assure that "as-built" drawings have been revised.
Step 5.1.3 requires that maintenance which could affect the perform-ance of safety related equipment be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings.
Contrary to the above, Operating Procedures 316, " Main Con 'ensate System," and 316.1, " Condensate Transfer System," and Burns and Roe drawings 2003 and 2004 were not revised af ter completion of modifi-cation 213, CRD Water Quality, in November 1978.
Also, during this modification, additional work, consisting of weld removal and re-placement, was performed on a Q-list valve (an item of safety related equipment) without using written procedures, documented instructions or drawings.
This item is an infraction.
5.
QA Procedures 5002, " Training of Nuclear Generati..g Station Department Staff Personnel," Revision 0; 6002, " Training of Generation Engineering Personnel," Revision 0; and 9002, " Training of Generation Maintenance Personnel," Revision 0, describe the training requirements for corporate staff personnel and include requirements for formal schools or trd1ning orograms, procedure training and QA f amiliarization training.
Administrative Training Manual,Section IV, describes specialized employee training, including lectures and on-the-job training (0JT) which cover maintenance performance, procedure review and change review.
10 C.:R 50, Appendix B, Criterion II, " Quality Assurance Program,"
and OQA Plan,Section III, " Operational Quality Assurance Program,"
Revision 2, require the licensee to develop a training program for employees as described in ANSI N18.1-1971.
ANSI N18.1-1971, requires that a training program be established for the " operating organization."
The " operating organization" includes those personnel concerned with the day-to-day operation, maintenance, and certain technical services.
a.
Contrary to the above, as of November 2,1979, formal training had not been conducted for Nuclear Generating Station, Generation Engineering or Generation Construction Maintenance Department personnel, nor had hourly personnel in the Mechanical Maintenance Department participated in formal lectures or OJT relating to procedure review and change review.
Appendix A b.
Contrary to the above, as of November 2,1979, a formally pre-scribed and documented training program for the Health Physics Department had not been established.
This item is an infraction.
6.
Generation Department Procedure 2002, "Nonconformance and Corrective Action," Revision 2, establishes a system for the control and imple-mentation of nonconformance and corrective action.
This procedure requires, in part, the establishment of a corrective action target completion date within a ten working day period following notifica-tion of the nonconformance, and the resolution of the nonconformance in a timely and complete manner.
Contrary to the above, the September 1,1979, Open Nonconforma te/
Corrective Action Report identified 143 outstanding items.
Of these, 71 were overdue for establishing a target completion date, and 29 target dates were past due in that the nonconformances had either not been resolved or the target dates changed as required.
This item is an infraction.
7.
Procedure 3005, " Site Material Conformance Identification," Revision 3, December 7, 1977, paragraph 5.3.1, requires that Quality Assurance identify the conformance status of the item being returned to stofage and that the item be retagged or restickered, if required.
Paragraph 5.1.8 specifies that, prior to removal from storage, re-inspection.
is required for items (such as weldrod) used in various systems that are subject to obsolescense due to code changes.
Contrary to the above, on October 20, 1979, returned weldrod was observed to be in storage with tags identifying the item as released for use, without having been designated for re-inspection before reuse.
This item is a deficiency.
C.
Technical Specification 6.10.3 requires that Quality Assurance Records be retained as specified by the Operational Quality Assurance Plan.
Operational Quality Assurance Plan,Section III, " Operational Quality Assurance Program," Revision 2, requires that the licensee maintain a duplicate file system, consisting of a corporate document center and a duplicate docume~nt center at the Oyster Creek site.
Contrary to the above, modification packages 211, 297 and 313 were not filed at the Oyster Creek site document center as required.
The modifi-cation packages were filed at the corporate office except for modifica-tion package 297, which the licensee could not find.
This item is an infraction.
A Appendix A 5-D.
Technical Specification.6.5.3.3.b requires that the training and qualifica-tions of the entire facility staff be audited at least once per year.
Contrary to the above, for the three year period of 1977 through 1979, one audit in this area was started in 1977 and completed on January 1, 1978, and another audit was scheduled for completion in 1979.
Therefore, only two audits will have been performed in a three year period.
This item is an infraction.
E.
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained that meet or exceed the require-cents of Appendix A of the NRC's Regulatory Guide 1.33.
Contrary to the above, calibration procedures had not been written and implemented as of November 2,1979 for the following equipment:
New Radioactive Waste Facility Effluent Monitors New Radioactive Waste Facility Area Radiation Monitors Model R0-2A Portable Survey Meters Portal Monitors Constant Air Monitors Whole Body.'ounter Hand and Foot Monitors Environmental Air Sacplers Multiple Source Gamma Calibrator This item is an infraction.
F.
10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary to comply with the regulations in this part.
As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radia-tion hazards incident to the production, use, release, disposal or presence cf radioactive material or other sources of radiation under a specific set of conditions.
10 CFR 20.105 limits the amount of radioactive material that a licensee may release to an unrestricted area during possession, use or transfer of radioactive material.
Appendix A Contrary to the above, as of November 2,1979, surveys.of effluents released from the New Radioactive Waste Facility had not been performed in that the continuous gas and liquid effluent monitors had not been calibrated nor had samples been collected and analyzed in the laboratory since initial introduction of radioactive materials into this facility in October 1978.
This item is an infraction.
G.
Technical Specification 4.5.K.l.a.(2) requires that at least once per 18 conths a sample from the Standby Gas Treatment System charcoal adsorbers te analyzed to demonstrate 90 percent radioactive methyl iodide removal efficiency.
Contrary to the above, as of November 2,1979, no analysis of charcoal adsorber efficiency has been performed to indicate compliance with the above specification since initial operation of the Standby Gas Treatment System in 1969.
This item is an infraction.
H.
10 CFR 50.54(p) requires that changes made to the security plan which do not decrease the safeguards effectiveness of the plan are to be reported to the Director of Nuclear Reactor Regulation, with a copy to the appro-priate NRC Regional Office, within two months after the change is made.*
Contrary to the above, on April 1,1979, a new position, Assistant Site Protection Supervisor / Training, was added to the Security Organization.
As of October 19, 1979, a description of the change had not been furnished to the Director of Nuclear Reactor Regulation or to the appropriate Regional Office.
This item is a deficiency.
This Notice of Violation is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
You are hereby required to submit to this office, within twenty (20) cays of your receipt of this notice, a written statement or explanation in reply, including for each item of noncompliance:
(1) admission or denial of the alleged item of noncompliance; (2) the reasons for the item of noncom-pliance, if admitted; (3) the corrective steps which have been taken by you and the results achieved; (4) corrective steps which will be taken to avoid further noncompliance; and, (5) the date when full compliance will be achieved.
Jersey Centra 16 Power and Light Cortpany FEB 2 01930 Distribution:
POR NSIC LPDR W
State of New Jersey MAIL STOP ACRS (3)
H-1016 SECY H-1149 D. Thompson, IE CA (3)
H-1057 F. Ingram, PA MNBB-3709 J. P. Murray, ELD NMBB-9604 J. Liebercan, ELD NMBB-9604 R. Tedesco, AD/RS P-1122 J. Cocks, OMPA NMBB-12105 J. J. Cummings, OIA Landow-1200 Enforcement Coordinators:
Regions I, II, III, IV, V W. J. Ross P-314 T. W. Brockett, IE S. E. Bryan, IE P. F. McKee, IE B. H. Grier, IE IE Files Central Files Civil Penalty Book CON L-316 XCOS Reading File EDO Reading File IE Reading File Q
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