ML19309B457
| ML19309B457 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/30/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19309B452 | List: |
| References | |
| 50-334-79-24, NUDOCS 8004040170 | |
| Download: ML19309B457 (3) | |
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APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 Based on the results of an NRC inspection conducted on November 5-9, 11-26, and December 3-14, 1979, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC License No. DPR-66 as discussed below. These items are infractions.
A.
10 CFR 50, Appendix B, Criterion IV, states, in part, " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed..." The facility FSAR, Appendix A, Section A.2.2.6, Document Control, states, in part, "...The Operations Quality Assurance Program includes provisions for assuring that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel, and are distributed to and used at the location where the prescribed activity is performed, prior to the onset of work..."
Quality Assurance Procedure No. OP-8, Administrative Controls, Revision 4, Section 3.3.4, states, in part, "The administrative procedure shall require that the documents... including any revisions or changes thereto are:
(a) reviewed for adequacy b authorized personnel, (y) distributed to the personnel performing theauthor c
activity, (d) used by the personnel performing the activity." The BVPS Maintenance Manual, Chapter 1, Conduct of Maintenance, Section 7, Revision 6, states, in part, "...a.5. Safety related... provisions shall be reviewed by the Onsite Safety Committee and comments resolved.
a.6. The Station Superintendent or his designated alternate shall sign for the approval of all surveillance procedures...
c.1 Any revisions necessary shall follow the same review and approval procedure as outlined above..."
The BVPS Maintenance Manual, Chapter 1, Section A, Revision 9, states, in part,
". 7.f On-the-s?ot revisions to maintenance procedures that for some reason may become unworkable may be made with the concurrence of a maintenance supervisor and a Shift Supervisor... provided the intent of the procedure is not changed, and a design change is not involved..."
Contrary to the above, on August 28, 1979, calibration of RCS hot leg RTD amplifier TM-RC-432H was performed utilizing data from an Instrument Cali-bration Data Sheet, Fonn 147, which had not been reviewed, approved, or distributed as a revision or on-the-spot change to Meintenance Surveillance 8004040;70
O Appendix A 2
Procedure No. 6.40, T-RC-432 Delta-T/Tavg Protection Instrument Channel III Calibration, Revision 2, in accordance with the above requirements.
B.
Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below:
- a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November,1972..." Appendix A to Regulatory Guide 1.33, Quality Assurance Requirements (Operations), November,1972, recomends that the following typical safety-related activities be covered by written procedures:
"...C. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems,...
- 22. Process Radiation Monitoring System..." and "...H.
Procedures for Control of Measuring and Test Equipment...
- 2. Specific procedures for... calibrations should be written:...
a(29) Process Radiation Monitoring Calibrations."
The BVPS Operating Manual, Section 1.43.4.F. Revision 4, provides operating instructions for particulate and gaseous radiation monitors which state, in part, "F.2 Periodically check the local enclosure for the flow rate of each particulate or gaseous monitor. The flows should be the same as noted in Table 43-1."
The BVPS Radiological Control Manual, Form No. RCM-F229, Revision 3, is the log sheet utilized to document the actual "as found" and "as-left" flow rate data during weekly checks perfomed by members of the Radiological Cont ml Department.
The BVPS Operating Manual, Sections 1.43.4.A and B, Radiation Monitor i
Startup Procedures, Revision 4, each require that the operator:
" Observe that the High or Low Flow lights are extinguished," and that "If required (flow) values are not observed, adjust the flow to the desired value (Table 43-1)."
Contrary to the above, on November 29-30, 1979:
Procedures for the startup and operation of gaseous and particulate radiation monitors were improperly established and implemented in that Fom N0. RCM-F229, Revision 3, the document in use for periodic checks and adjustment of sample flow rates, included incorrect acceptance criteria for the sample flow rates required to be maintained on radiation monitors RM-1VS-102A and B, RM-lVS-105, RM-lVS-106, RM-lVS-107, RM-1RM-215, and kH-lGM-101.
Procedures for the operation of gaseous and particulate radiation monitors were improperly established and implemented in that operatir.g data collected on Fom No. RCM-F229 during the period of October 3, 1979 through November 28, 1979, documents operation of the following radiation monitors for periods of one week or more at flow rates which
Appendix A 3
did not meet the applicable acceptance criterion, or operation with sustained flow alarms present, or both:
RM-1GW-108, RM-1VS-102A and B, RM-IVS-105, RM-IVS-106, RM-1RM-215, and RM-1RM-217. Flow adjustments performed in accordance with existing procedures were unsuccessful in correcting out of specification sample flow rates, and effective, further corrective action was not taken.
Neither procedures nor appropriate setpoints have been established for the calibration and maintenance of process radiation monitor sample flow alarm equipment.
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