ML20010B811
| ML20010B811 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/01/1976 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010B798 | List: |
| References | |
| FOIA-81-95 50-267-76-06, 50-267-76-6, NUDOCS 8108180131 | |
| Download: ML20010B811 (3) | |
Text
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l' ort St. Vrain 50-267/76-06 CNCLOSURE (1)
-_O.T_ ICE OF VIOLATION N
i 10-14, 13-21, 3nsed on the results of an NRC ins' action conducted en May and June 7-10, 1976, it appears that certain of your activities were not conducted in full compliance virh URC requirements as indiented below:
- that, Criterion V of Appendix B to 10 CFR 50 requires in part A.
"Activitics af fecting quclity shall be prescribed by documented and shall be accomplished instructions, procedures or drawiras.
d or drawings."
in accordance with these instructions, proce ures, The IIconsee's approv ed QA Plan, Final Safety Analysis, Section B.5(c) states in part, "The various aspects of plant operation will be defined and controlled by written procedures...."
Contrary to the above requircments, the following li:ensee proc' tures were not adhered to for the followi.1g quality related activitics.:
Administrative Procedure I.DM 18 requires in part that the Plant (1)
Operations Review Co==ittee (FORC) review and approve nodifica-tions to the plant.
A review of the cenpleted Change Notice 59 records revealed (a) a neco change to the inst:11ation procedure which was issued by the design engineer to the contractor performing the podification. This change made a substantive alteratien to the installation procedure by the deletien of a step calling for the receval at the orifice plate downstrean i
l of Flow element FI 4210-2. This change ceto was not re-l viewed and approved by the PORC.
I (b) The addition of are suppressors to the operating circuit for valve liv 2189-1, a safety related valve, accomplished i
l under Plant Troub'.e Keport (PTR) 231 of 1975, constitutes
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a rodificati:n using the definition of nodification con-l tained in the licensee's Administrative Procedure ADM-27.
l This modification was not' reviewed and approved by the PORC.
"Modificatien Quality Assuran:e Plan QAP-1400 requires in part th..t.
l (2)
Procedures shall contain appropriate and detailed QA requirements and check lists for all phares of the work including, where
.(h) Post modification checkout; applicabic:
"hc Modification Procedurcs for Change Notices 34, 58 and 59, i
although co plete, did not include a post modification checkout of the codified components.
0108100131 910514 PDR FOIA LIVEDALEB1-95 PDR
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(3) The Quality A:,surance Mar.ual, Section 6.7.3 states in part.
"An loterdepartmental wur': Procedure.shall be prepared to prescribe in detall the nethods and control neasures to be
- Further, applied to control of design and design nodification."
this section identifics this procedur7 by stating in part, "This procedure (IUP-2)...."
Interdepartmental Work Procedure IUP-2 has not ' et been issued.
In its place, o temporary guidance document is ir. use to speclif the above design control proceduces.
"Trecedures.
Administrative Procr dure ADM-12 requires in part, (4) shall be used for uurk on equipnent designated as safety
.unless no precedure is required, 4.n which case the related.
PTR or work request shall be so carked." ADM-12 defines naia-tenance procedures as "uritten instructions which define main-tenance activitics and prescribe the nethods, materials, special (if any), cuauale and proecsses to be used, trade qualifications, rectired in.<pections ars post caintenance calibration and teating."
Plant Trouble Report 7!h A-377 indicated the "aintenance Supervisor's instructions as Troubleshoot and correct problea" whereas PTR 2-63 and F ? 3-13 stated in the Maintenance Super-visor's Block "Per ADM-12."
The nbove PTR's for work on safety related equipnent fail to provide a proper caintenance procedure or to clearly indicate that no procedure was required.
Plant Trouble Report 9-223, issued to correct the improper (5) asse=bly of Belleville washers on the control shaft for the 25.
control orifice of Control Drive Mechanism (CDM) No.
required the accomplish ent of this maintenance per Maintenance Procedure MP 12-6.
This procedure was a prev' ausly approved general procedure cavering the disassembly and reassembly of a The completed M? 12-6 filed with PTR 9-233 did not CDM.
indicate that disasse bly of the CDM was accomplished per procedure.
St ation Battery Dis:har e Test (5-11-76) states in part, "The (6) entnal review process should be utilized to chanac procedurcs wacnever practicchic; havever, changes may be made with the approval of the ?50 Shift Supervisor and one other person holding a Scaior Operators License.
The functionti test perforced on the new instrument bus bat tery in accordance v3.the above referenced procedure was terminated 103.! Volts DC vice the 105 Volt DC termination voltage at
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urucIIIed. An approced th.mge was not obtalaed for this variation froa procedure.
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(7) Administ rative Procedure 27, Revision 1, states in part, j~
"Iequest for nadifiestion or routine taintenar.ce and repair activities r. hall be prepared on a Work Authori:ation ("A) forn.
Clasa I cabic tray dividers have been noved tnd/ar extended without formal Work Authorizations.
1 (8) Tne contractors (1-26-76 Approved Procedure) " Approval of j
Procutement and Control o,f Welding Material Precedure for j
rort Saint Vrain Nuclear Generating Station" s:stes in part,
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"Only enough covered cicetrod.as will be removed f rom the rod ovens to cover a maximus tice of four hours."
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The inspector fou,d unclaimed and unused 701S eld rod in the l
IACM Building and on an adjacent fitup table.
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l This is an infraction.
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B.
Criterion VI of Appendix B ta '0 CF; 50 requires in part that, f
. measures shall be established to control the issuance of j
documents such cs.
. drawings and changes thereto.
.." This requir. ment is neplified by the licensee's approved QA Plan, rinal 4
Safety 7.,alysis, Section E.3.5 which states in part, "Where necessary, becau.e of design nodifications...necessary revisicas vill be made to thu "As-Built" drawings and specifications...
l The nystem codifications perfcrmed under the completed Change Notices CN34 and CN58 were not reflected in their corresponding Piping and j
Instrumentation drawings PI S2-1 and PI 41-1 respectively, either i
by a drafted change or an er.try indicating that the abova change j
notices were issued and would affect these drawings.
I This is an infraction.
C.
Two other infractiens !!entified through your internal audit pro-gram and for which corrective action was initiated ar." set out in the attached inspecti:n report. No additional infornation is j
neaded at this time.
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