ML19308A184
| ML19308A184 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/29/1978 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19308A182 | List: |
| References | |
| NUDOCS 7812290061 | |
| Download: ML19308A184 (3) | |
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':: :::2.,,:.O.S!. *lJ' November 29, 1978 Docket No. 50-336 Mr. Boyce H. Grier Director, Region I Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Grier:
SUBJECT:
NRC Inspection Report 50-336/78-31 This is in response to your letter dated November 2, 1978, concerning Inspection 50-336/78-31 conducted by Mr. R. Conte on September 26-29, 1978, at Millstone Nuclear Power Station, Unit No. 2.
Your letter identifies two areas where our activities were not conducted in full compliance with NRC requirements. The purpose of this letter is to describe the corrective steps which have been taken and the results achieved, corrective steps that will be taken to avoid further items of noncompliance, and the date when full compliance will be achieved.
Item A 10 CFR 50, Appendix B, Criterion II, requires in part:
"The applicant shall identify the structures, systems, and components to be covered by the Quality Assurance Program...' Criterion VII requires in part:
"These measures shall include provisions...for... examination of pro-ducts upon delivery...." Criterion VIII requires in part:
"These measures shall assure the identification of the item is maintained...
either on the item or on records traceable to the item as required throughout...use of the item.... "
With respect to Criterion II, the Northeast Utilities Quality Assurance Manual, Volume II, Revision 4, December 1, 1976, Section 2 defines Category I Material Equipment and Parts List (MEPL) as material parts and equipment that prevent or mitigate the consequences of postulated accidents that could cause undue risks to the health and safety of the public.
Contrary to the above, as of September 29, 1978 the below listed safety related parts were not identified on the MEPL and, as a result of this, requirements for receipt examination, material identificatinn, and con-trol were not implemented.
This oc. curred for the folicwing safety related maintenance activities:
7812290n 78122900GI
Mr. Boyce H. Grier November 29, 1978 1.
J0 80012, completed January 9, 1978, Diesel Generator "A" maintenance - replacement of various internal parts such as pistons and liners, thrust bearings; and 2.
J0 80227, completed May 16, 1978, Charging Pump "B" maintenance -
replacement of various internal parts such as oil seals, and plunger.
Response A The Material, Equipment, and Parts List (MEPL) identifies the safety-related components in Millstone Unit No. 2; however, it does not identify every replacement part that may have to be installed in a safety-related component. Therefore, we have identified this con-dition and all holders of controlled copies of the MEPL will be issued a notice of revision that clearly states this fact on or before. December 15, 1978.
In addition, our previous vehicle for requesting / revising MEPL listings has been upgraded and will appear as a procedure at the beginning of each controlled copy of the PEPL.
This procedure entitled " Determination of QA Category I Applicability," will be applicible to all work on QA Category I components.
The procedure requires a consistent and predescribed evaluation to determine whether or not replacement parts in a Category I component should be identified as QA Category I based on their function in the com-ponent, potential failure modes and whether or not failure cou d cause Category I equipment to malfunction when needed.
We have ovaluated the parts identified in the notice of violation using this procedure and have concluded that (a) pistons, linors, and thrust bearings of the diesel generator are safety-relateo parts and (b) the plungers (but not the oil seals) of the charging pumps are safety-related parts. These parts will be added to the MEPL by December 15, 1978.
Although these items were not classified as QA, it should be pointed out that they were controlled. A receiving inspection is performed on all parts by the storekeeper for damage and conformance to the purchase order. Additionally, the items were stored under controlicd conditions commensurate with their importance. They were released, installed and an installation inspection performed under NNEC0's Job Order system.
Subsequently, all systems were demonstrated to be in an operable status.
Evaluations for future replacement parts will be conducted utilizing the " Determination of QA Category I Applicability" portion of the MEPL. The results of these evaluations will be summarized in periodic evisions to the MEPL.
We believe these actions will ensure that all parts ordered for safety-related components will be properly classified as to their safety-related status and preclude a reoccurrence of this infraction.
Mr. Boyce H. Grier November 29,1978 Item B 10 CFR 50, Appendix B, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instruction, procedures...and shall be accomplished in accordance with these instructions, procedures....The Northeast Utilities Qual'ty Assur-ance Manual, Volume II, Revision 4, Dect iber 1,1976, pragraph 2.3.1.1, states in part:
... Volume II of this manual was established to comply with the requirements of... WASH 1284, " Guidance on Quality Assurance Requirements During the Operations Phase of Nuclear Power Plants...as related to Category I (safety related) systems, structures, and com-ponents...." WASH 1284 references ANSI N18.7-1972. ANSI N18.7-1972, paragraph 5.3.5(3), states in part:
... Instruction shall be included or referenced for returning the equipment to its normal operating status. Operating personnel shall... document its functional accept-ability...." Administrative Control Procedure, ACP-QA-2.03, Revision 0, At. gust 7,1977, Maintenance Requests, prescribes the requirements for documenting functional acceptability of safety related equipment using the Maintenance Request Form.
Contrary to the above, during the conduct of four safety related main-tenance activities from January 1,1978, to June 30, 1978, instructions were not included or referenced in the associated Maintenance Request Document for returning the equipment to its normal operating status and operating personnel did not document the functional acceptability of the associated equipment. The maintenance activities were performed on the following equipment:
"A" Diesel Generator, "A" Boric Acid Pump, Motor Driven Auxiliary Feed Pump (P-9B).
Response B In each of the above cases, it is felt that there was a problem of incompletely filling out the Maintenance Request.
All applicable personnel have been informed by the Station Superintendent of the need to clearly state what the functional chack is and the need to document it. Additionally ACP-QA-2.03 shall be revised to more clearly indicate the need to describe the functional check. This shall be completed by 1/1/79.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
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W. G. Counsil Vice President WGC:FD/kwc