ML19350A158
| ML19350A158 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 04/11/1977 |
| From: | Crane P PACIFIC GAS & ELECTRIC CO. |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8102060759 | |
| Download: ML19350A158 (4) | |
Text
. PAC I F I C G A S A N'D E IaE C T RIC C O M PANY E O W~11.5.1
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77 BEALE STREET. SAN F R ANCISCO C AL FOR NI A 94106.(415) 781 4211 i
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Mr. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch e-Office of Inspection and Enforcement Regio.1 V Um S. Nuclear Regulatory Commission
.7 1990 N. California Boulevard IltAnut Creek Plaza, Suite 202 Walaut Creek, California 94596 Re:
Docket.No. 50-133 License No. DPR-7
Dear Mr. Spencer:
This is in response to your letter dated March 21, 197'i con-carning the inspection of our Humboldt Bay Power Plant performed by Messrs. L. J. Garvin, T. W. Hutson, and D. F. Kirsch of your office on February 28 and March 1-2, and the discussion of your findings Appendix A of your letter consists of a Notice of Violation dsscribing one of our activities, rel*2 ting to maintenance, which has been categorized as an infraction with respect to NRC requirements (10 CFR 50, Appendix B Criterion Vi.
Item A of Appendix A states:
"10 CFR 50, Appendix.B, Criterion V requires that activities affecting quality be accomplished with in-structions.
The PGandE QA Manual. Procedure 4.1 requires that the Plant Superintendent be responsible for prepara-tic-and approval of procedures for the routine and special maintenance of components and that such procedures shall include provisions for inspection of work.
Contrary to these requirements, the instruments in two cabinets in the control room were removed without the existence of pro-cedures.
This item is an infraction."
.x We do not agree that the activity described in_ Item A above constitutes an item of non--compliance with NRC requirements or the following reasons:
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April 11, 1977 1
Nuclear Plant Administrative Procedure E-400, which implements the requirements of NRC Regulatory Guide 1.33, ANSI N18.7-1972, Rev. 1 and the PGandE " Quality Assurance Manual for Operating Nuclear Power Plants", describes those maintenance activities that require procedures and states:
9When a necessary maintenance job on Safety Related i
equipment falls outside the scope of existing mainte-nance procedures, the Foreman shall bring the matter to the attention of the Power Plant Engineer.
The l
Power Plant Engineer shall determine whether or not a written procedure is required."
The removal of the subject instruments from the reactor board for seismic modification work on the reactor board was brought to the attention of the Power Plant Engineer and the Senior Power Production Engineer as required and it was determined thataspec{alprocedurewasnotrequiredbecause:
Removal of the subject instruments, in this instance, a.
was not significantly different than their routine removal for maintenance and bench testing.
b.
Proper installation and reconnection would be verified by app'ropriate preoperational tests and by conducting the surveillance tests associated with the reactor protection system and engineered -sa.feguards initiation.
The conduct of thet a surveillance ~ tests was specifically addressed by the-Plant Staff Review Committee in a meeting held on February 4, 1977 to review the reactor board modification procedure to be used by General Construction personnel, and Removal of the subject instruments in no way affected c.
quality or safety or violated a requirement of the operating license because the reactor was in the " cold shutdown" mode and will' remain'so until all instruments I
are reinstalled and the associated surveillance tests completed.
2.
Maintenance of the type cited in your letter (removal of instru-ments) has been carried out without the use of specific procedures since initial operation of the Unit in 1963.
Detailed procedures do exist for bench testing all of the subject instruments.
The bench test procedure for ~ the reactor protection _ system logic modules does contain requirements for removal of the instrumenta-Ef on from the rhacte : board.
Even thor.gh this procedure.was not
-used specifically for this job, all of these requirements were
- f. met, i.e., Requirement No.1, a proper clearance from the operating I.
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Mr. G. S. Spencer 3
April 11, 1977 Department was obtained, Requirement No. 2, the wiring was verified with the appropriate diagram of connection 3.
In addition, all wires were identified as each instrument was disconnected and all associated wire ends were placed in poly bags to provide segregation.. The bench test procedures for the nuclear instrumentation channels and power supplies do not con-tain requirements for removal of the instrumentation because the instrument cables are of such length and connector types and are bot 7d so that improper connections are virtually impossible.
In conclusion, it is our belief that the removal of the subject instrumentation was simply a routine maintenance activity well within the normal competence level of our technicians, the manner in which the subject instrumentation was removed was in accordance with good industry practice, and that this work in no way compromised either quality or safety.*
Since we believe that this activity was carried out in full compliance with NRC regulatory requirements, no corrective action is contemplated.
In addition to responding to Appendix A of your letter, para-graph 4 of the details section of the report attached to your letter t
concerning Receipt Inspection of Safety Related Materials merits com-mant.
Our Nuclear Plant Administrative Procedure on Receipt Inspection requires that inspections of this level be conducted by plant personnel NRC Regulatory Guide 1.33 " Quality Assurance ' Program Resquirements (Operation)" states that the requirements.and recommendations of ANSI N18.7-1972 " Administrative Controls for Nuclear Power Plants" arn generally acceptable and provide an adequate basis for complying with the Quality Assurance Program requirements of Appendix B to 10 CFR 50.
Section 5.16-Maintenance of N18.7-1922 states
" Maintenance that can affect the performance of safety-related equipment shall be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances (for example, skills normally possessed by qualified maintenance per-Ronnel may not require detailed step-by-step valineation in a written procedure) which conform to applicable codes, standards, specifications, and criteria."
(Underscoring added)
"For comment" Regulatory-Guide 1.33-Revision 1 endorses ANSI N18.7-1976 " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."
S:ction 5.2.7-Maintenance and Modifications of N18.7-1976 states
" Maintenance or modification of equipment shall be preplanned and per-formed in accordance with written procedures, documented instructions 1
or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria.. Skill: normally possessed by qualified maintenance personnel may not require detailed step-by-step d711neations in a written procedure."
(Underscoring added) i.
"k Mr. G. S. Spencer 4
April 11, 1977 qualified and certified according to ANSI.N45.26.
The plant personnel conducting this inspection were appropriately qualified.
The PGandE Quality Assurance Manual for Operating Nuclear Power Plants currently requires that (1) receipt inspections also be conducted by Quality Atsurance Department personnel either concurrently or independently from the plant inspections or (2) that an audit of the plant's in-cpection be conducted.
Both an independent inspection (as witnessed by your inspectors) and an audit were conducted by Quality Assurance Department personnel.
It is correct that this was the first inspec-tion of this type conducted by the assigned Quality Assurance Department inspector.
However, 1) the inspector has had three years' experience cuditing and inspecting supplier quality Lssurance programs and is a qualified lead-auditor in accordance with ANSI N45.2.23., 2) the plant Quality Assurance Engineer checked at least twice on the progress of the QA inspection, 3) the inspection was con '.ucted utilizing a suf-ficiently detailed checklist to preclude ove.?looking any important a;pect of the inspection, and 4) a qualified plant receipt inspector was present during the entire receipt inspection to answer any questions that might have arisen.
In conclusion, it is our opinion that the subject inspection was properly carried out in accordance with established procedures.
Very truly vours, T_
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. J.'
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