ML20011A332
| ML20011A332 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/29/1981 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011A329 | List: |
| References | |
| 50-219-81-05, 50-219-81-5, NUDOCS 8110090322 | |
| Download: ML20011A332 (6) | |
Text
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APPENDIX A NOTICE OF VIOLATION Jersey Central. Power and Light _ Company Docket No. 50-219 Oyster Creek Nuclear Generating Station License No. DPR-16 As a result of an inspection conducted on March 9-13, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
A.
10 CFR 50, Appendix B, Criterion XII, states, in part, " Measures shall be established to assure that... gages... used in activities affecting quality are procerly controlled, calibrated, and adjusted... to maintain accuracy within necessary limits."
Jersey Central Perer and Light Company Generation Division Operational Quality Assurance Plan,Section III, Operational Quality Assurance Program, Paragraph 3.A states, in part, " ANSI N45.2.4 Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan..."
ANSI N45.2.4-1971, " Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear-Power Generating Stations," paragraph 2.5.1 states, in part, " Inspection and testing equipment with acceptable accuracy for performing the required function shall be selected..."
Contrary to the above, surveillance tests are being performed using test gages with less than acceptable accuracy and readability in that 0-1500 psi test gages having 5 psi scale increments were calibrated to accuracies of f 0.5 percent (1 7.5 psig) of full scale and were then used in the perfornance of the following tests:
619.3.008, Turbine Load Rejection Scram Test (< 40% Load), performed February 13, 1981, with test setpoints established at 180 1 5/0 and 165 1 0/5 psig.
602.3.004, Electromatic Relief Valve Pressure Sensor Test and Calibra-tion, performed December 1, 1980, with test setpoints established at 1059 2 0/5 psig, 1084 1 0/5 psig, 1076 1 0/5 psig, 1062 1 0/5 psig, and 1082 1 0/5 psig.
609.3.003, Isolation Condenser Automatic Actuation Sensor Calibration and Test, performed February 5, 1981, with test setpoints established at < 1068 1 0/2 psig and < 1066 1 2 psig.
l 619.3.007, Low Pressure Main Steam Line Functional Calibration Test 1
While Shutdown, performed July 4, 1980, with test setpoint established f
at 850 + b/0.
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8110090322 810529 PDR ADOCK 05000219 0
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-Appendix A 2
619.3.017, Reactor High Pressure Scram Test and Celibration, performed February 10, 1981, with test setpoints established at 1068 1 0/2 psig and 1066 1 0/2 peig.
This is a Severity Levol V Violation (Suoplement I).
B.
Technical Specifications. 6.8.1 and 6.8.2, stated, in part, " Written procedures shall be established, implemented and maintained that meet or exceed the requirements of Section 5.1 and 5.3 of American National Standard N18.7-1972...
Each procedure... shall be reviewed by the Plant Operations Review Committee and approved by the Director Oyster Creek Operation prior to implementation..."
paragraph 5.3.6, 'tates, in part, " Procedures shall be
. ANSI N18.7-1972, s
.provided for periodic calibration and testing of safety-related plant instrumentation...
The procedures shall have provisions for... assuring measurement accuracies adequate to keep safety parameters within operational and safety limits."
Contrary to the above, calibrations were being performed on safety-related instruments without using established and approved procedures.
The
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following are typical examples of safety-related calibrations performed without procedures.
Other cases were also noted:
ILO4, Standby Liquid Control System Level Transmitter; ILOS, Standby Liquid Control Systems Level Indicator; RD04, Control Rod Drive Water Pressure Indicator; RD18, Control Rod Drive Water Pressure Transmitter; IG07B, Emergency Condenser Level Indicator; EDST, Emergency Diesel Fuel Storage Tank Level Meter; and FPn7, Fire Pump Discharge Pressure.
Further, in addition to procedures not being established, ca.fbrations have not been accomplished for the following safety-related instruments:
Diesel Generator Kilowatt meters used to verify Diesel Generator operability; l
Diesel Generator Kilovar meters used to verify Diesel Generator operability; and
a Appehdix A 3
Fire Pump revolution; per minute (RPM) mecer used to verify fire pump operability.
Thi~ is a Severity Level V Violation (Supplement I).
C.
1(... 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented... procedures... of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures..."
Jersey Central Power and Light Company Generation Division Opeeational Quality Assurance Plan, Revision 3,Section III, Operational Quality Assurance Program, states, in part, "For activities falling within the scope of Part I of the Quality Assurance Systems List, Jersey Central Power and Light Company shall utilize the guidance of..
- 13. ANSI N18.7-1972,
" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants..." ANSI N18.7-1972, paragraph 6.2, states,
" Tasting of safety-related plant parameters, structures, systems, and couponents shall be performed in accordance with approved written test procedures, which set forth the requirements and acceptance limits."
10 CFR 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as...
de Iciencies... are promptly... corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective acticn taken shall be documented and reported to appropriate levels of management."
Contrary to the above, test procedures have not been prepared, issued, or implemented for Inservice Testing of numerous valves identified for testing in your Inservice Inspection Program, Section 2, " Pump and Valve Test Program." The following are sone axamples of valves listed in the ISI Program, Section 2, whose testing is not documented in an approved procedure:
a.
Core Spray System valves V20-60, V20-61 and V20-10.
b.
Containment Spray System Valve V21-10.
c.
Closed Cooling Water Valve VS-154.
d.
Fire Protection System Valve V9-13.
Many additional valves were also identified during the inspection.
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a Appendix A-4 Further, this is a recurrent item, in that a similar item of noncompliance was cited.in our letter to you dated May 9,1980 (NRC Inspection 219/80-10) which noted that pump and valve operability tests required by Section XI, Subsection IWP and IWV, of the ASME Code had not been completed nor had procedures been approved to implement the required tests for components contained in various systems within the scope of the Inservice Test Program (IST).
Your letter dated June 3, 1980, in response to our letter stated that procedures would be written and implemented by July 31, 1980.
As evidenced by the deficiencies cited above, your corrective actions and management action to assure proper corrective actions were incomplete and inadequate.
This is a Severity Level V Violation (Supplement I).
D.
10 CFR 50, Appendix 8, Criterion XVIII, states, in part, "... audit results shall be documented and revieved by management having responsibility in the area audited.
Followup action... shall be taken where indicated."
Technical Specification 6.5.2.8 states, "The PORC shall maintain written minutes of each meeting and copies of minutes and detarminations shall be provided to the Director Oyster Creek Operations; V President, JCP&L; Director, Oyster Creek; ISRG Coordinator and the Cha. man of the GORB."
Contrary to the above, minutes of the PORC meetings have not been provided to applicable managers in that, as of March 13, 1981, the last meeting minutes which have been issued and provided to the Director Oyster Creek Operations; Vice President, JCP&L; Director Oyster Creek; ISRG Coordinator and the Chairman of the GORB were those of PORC Meeting 104-80 conducted July 1,1980.
Additionally, management action to correct this deficiency was inadequate, in that the above deficiency was identified by your Company Audit No.
79-37 dated April 9, 1980 and was further identified for corrective action as an unresolved item during NRC Inspection 219/80-16 conducted May 5-9
90, and, as of March 13, 1981, adequate corrective actions have nc en taken.
This is a Severity Level V Violation (Supplement I).
E.
10 CFR 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure.that conditions adverse to quality, such as...
deficiencies are promptly.. corrected..."
Technical Specification 6.8.2 states, in part, "Each proc = dure and adminis-1 trative policy... shall be reviewed..
periodically as specified in the Administrative Procedures."
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. g Appendix A 5
Administrative Procedure 107,'" Procedure Control," req'uires that operating procedures be reviewed annually and documented in the PORC meeting minutes.
Contrary to the above, the following operating procedures were not reviewed on an annual basis.
'202.1, Power Operation;_
302.2, CR0 Manual Control System; l
l 315.2, Turbine Lube Oil; and 340.2, 24 VDC Distribution System.
.Further, action taken to correct this discrepancy was inadequate, in that it was identified to you for corrective action as an unresolved item by NRC inspection 219/80-16 conducted May 5-9, 1980 and, as of March 13, 1981, corrective action has not been taken.
l This is a Severity Level VI Violation (Supplement I).
F.
Technical Specification 6.8 states, in part, " Written procedures shall be established, implemented and maintained..."
(
Plant Procedure 112.1, " Calibration of Technical Specification Supporting Installed Instrumentation," paragraphs 5.4 and 5.7 state, in part, "5.4 l
When the calibration (s) are complete, the "As Found" and "As Left" data l
shall be entered on the appropriate history card."
"5.7 The Group I&C&E Supervisor shall review the... app opriate instrument history cards for completeness, and for instrument problems and trends..."
Contrary to the above, calibration data was not recorded on the instrument history cards for the following instruments:
l IL-05, Standby Liquid Control System Discharge Pressure, for calibration l
performed June 20, 1980; l
RD-04, Control Rod Drive Hydraulic Pump Discharge Pressure, for j
calibrations performed May 9, 1980 and January 9, 1981; and l
RD-15, Control Rod Drive Hydraulic Pump Flow, for calibration performed January 7, 1981.
Further, as evidenced by the missing calibration data, supervisory review of the instrument history cards, which contain the actual calibration data, is not being performed.
This is a Severity Level VI Violation (Supplement I).
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Appendix A 6
-G.
Technical Specificatio:, 6.8.1 states, in part, " Written procedures shall be established, implemented, and maintained..."
Procedure 610.4.002, " Core Spray Pump Operability Test," states, in part,
".. 6.2.5.1 Verify Fill Pump trips (on start of Core Spray Pump NZ01A)...
6.2.13.1 Verify Fill Pump starts (on stopping of pump NZ01C)...
6.4.5.1 Verify Fill Pump trips (on start of Core Spray Pump NZ018)...
6.4.13.1 Verify Fill Pump starts (on stopping of pump NZ010)...
7.0 Acceptance Criteria...
7.1.2 Fill pumps... operate as specified in the instructions..."
Procedure 107, " Procedure Control," paragraph 5.1.3, states, in part, "Should any written procedure prove to be inadequate, corrective action shall be initiated through established channels as described herein.
Any written procedures which are determined to be inadequate shall be revised, temporarily if necessary..."
Contrary to the above procedure, 610.4.002 has been performed at least month'. Mnce November 1980 although the procedure was no longer applicable to the ac,.ual system status for fill pump operation, in that the fill pumps for Core Spray Systems I and II have been temporarily wired in such a manner as to allow the fill pumps to run continuously rather than to automatically start or stop in conjunction with Core Spray Pump Operation.
Data sheet verifications for these steps were marked as "Not Applicable".
Further, although the procedure no longer applied to actual system status for fill pump operation, no revision or temporary change to the procedure had been made.
This is a Severity Level VI Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Jersey Central Power and Light Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) admission or denial of the alleged violations; (2) the corrective steps which have been taken and the results achieved; (3) corrective steps which will be taken to avoid further violations; and (4) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Dated MAY 2 91981 M
~y Thomas T. Martin, Acting Director, Division of Engineering and Technical Inspection