ML20072C376
| ML20072C376 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/11/1983 |
| From: | Giesler C WISCONSIN PUBLIC SERVICE CORP. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20072C371 | List: |
| References | |
| CON-NRC-83-107 NUDOCS 8306210041 | |
| Download: ML20072C376 (14) | |
Text
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NRC-83-107 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 May 11, 1983 Mr. C. E. Norelius, Director Division of Projects and Resident Programs U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Norelius:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant IE Inspection Report 83-01 The attachment to this letter addresses our response to the four items of noncompliance and your request to describe the investigation performed to assure that QA Type 2 and 3 components are not installed in QA Type 1 systems. After performing the reviews in question, we continue to be assured that our Quality Assurance Program requirements, procedures and directives are maintaining the quality level required to meet NRC and industry standards and to provide an efficient, economical and safe operating plant.
Furthermore, I have been advised of the dynamic overall program changes we are continuing to make which I feel are significant attempts to upgrade the procedural controls, documentation and personnel knowledge and understanding in the area j
of Quality Assurance.
Some of the changes and commitments for future improvement l
are related in the attachment to this letter.
Others not mentioned are the increased staffing in the QA and QC areas, the establishment of the new Quality Assurance Procurement Group to review all procurement requests, recently completed Quality Assurance training to all relatively new engineers responsible for design change implementation, and the recent organization change which brought an SR0 qualified engineer into the corporate Quality Assurance department.
I am especially pleased to know that our staff was intuitively aware of the programatic problem found in noncompliar.ce item 4, and had taken steps to revise the procedure even before the noncompliance was found. Perhaps the fact that our staffs are so burdened with regulatory requirements is in part responsible for this correc-tive action not having been accomplished before the incident in question occurred.
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e 4
Mr. C. E. Norelius
'Page 2
.May 11, 1983 As always, we will be glad to discuss any of the questions you may have with respect to our corrective actions for the noncompliances issued in the referenccd inspection report.-
Very truly your,
- ^
$&M ; : "
C. W. Giesler Vice President - Nuclear Power js Attach.
cc - Mr. Robert Nelson, US NRC Mr. S. A. Varga, US NRC f
Docket No. 50-305 Attachment I Responses to Items of Noncompliance IE Inspection Report No. 83-01 IE Inspection Report No. 83-01 listed four items of noncompliance. The following responds to each item of noncompliance listed in Appendix A of that report.
Item 1.
Technical Specification 6.8.1 states, " Written procedures and administrative policies shall be established, implemented and maintained that meet the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972"'. ANSI N18.7-1972, Section 5.1.2, states, in part, " Procedures shall be followed..."
ANSI N18.7-1972, Section 5.1.5, states, in part, " Procedures shall be provided for control of equipment as necessary, to maintain reactor and personnel safety and to avoid unauthorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status."
Preventative Maintenance Procedure, PMP 40-107, "480 V Supply and Distribution Supply Breeker Maintenance for Component Cooling Pumps", Section 3.2 states, in part, "For the unit to be isolated, have Operations place the following items in the indicated position and tag".
Section 3.2 further indicates, if the unit to be controlled is the supply breaker for component cooling pump 1A, the control switch on Mechanical Control Console A shall be placed and tagged in the PULLOUT position and the circuit breaker tagged in the open position. Administrative Control Directive 4.3, "Tagout Control" Section 3.0 states, in part, " Danger Cards shall be used to protect equipment or to warn of unusual or dangerous conditions".
Contrary to the above procedures were not followed in that:
a.
On February 16, 1983, authorization was granted and actions taken to remove component cooling water pump 1A from service, and to perform preventative maintenance without tagging as required by the licensee's procedures.
b.
On November 15, 1982, an instrument, which when connected to its sensing line is considered an extension of the containment, was disconnected and the instrument isolation valves were shut, but were neither tagged nor locked.
'Mr. C. E.'Norelius Docket 50-305 May 11, 1983 Page 2
Response
ANSI N18.7, endorsed by USNRC Regulatory Guide 1.33 (formerly Safety Guide 33),
states, "This standard provides requirements...to provide assurance that operational phase activities at nuclear power plants are carried out without undue risk to the health and safety of the public. The requirements of this Standard apply to all activities affecting safety-related functions of nuclear power plant structures, systems, and components."
In accordance with ANSI N18.7, administrative controls have been established via plant Administrative Control Directises (ACD's) to provide assurance operational activities at the Kewaunee Nuclear Power Plant are carried out in a safe manner.
Our ACD's are also established to provide for personnel and equipment safety, consistency in operation, and to ensure economical, efficient operation.
Specifically, Danger Cards are used to warn employees about an unsafe or unu-sual condition, and Hold Cards are used to protect personnel when working on de-energized circuits or equipment. The ACD's do not distinguish between the above considerations.
It is not appropriate to issue a violation against an ACD and Technical Specification 6.8.1 unless it can be shown that a safety related function was violated or undue risk to the health and safety of the public was involved, since that is the only time the Technical Specifications and ANSI 18.7 are applicable.
For item la., we contend that no safety related functions or undue risk to the health and safety of the public was involved.
We do agree that by our Admin-istrative Controls, tags (specifically, Hold Cards) should have been placed and were not. These tags were required by procedure to protect the personnel per-forming the work and thus was a violation of company Safety Rules. There was
'Mr. C. E. Norelius Docket 50-305 May 11, 1983 Page 3 adequate knowledge and indication in the Control Room to inform the operators that a safeguard component was out of service for testing. We also agree that a tag may have been the surest indicator to the operator that a safeguard com-ponent was out of service, but we still do not believe that this item warrants a noncompliance action.
For item lb., we have concluded that there existed a potential to lose control over a safety related function, containment integrity, in that although per-sonnel in the control room were aware that the containment pressure monitor was out of service and undergoing maintenance, they were not aware that it was removed and the containment boundary was established by an untagged isolation valve.
There existed the small possibility that someone could have inadver-tently opened one of the isolation valves.
In lieu of the fact that contain-ment integrity was not violated, the size of the pressure sensing line was only 3/8 inch, and the vent path would have been to a monitored, filtered exhaust had an accident and misalignment taken place, we feel that a severity level IV violation is inappropriate. At most, this is of minor safety signi-ficance and should be-severity level V under Rules of Practice 10CFR Part 2.
Regardless of the severity with respect to health and safety of the public, there is cause for concern because administrative procedures were not adhered to.
Personnel were reinstructed of the tagging requirements in our company Safety Rules Book and ACD 4.3 during the March 9, 1983 plant safety meeting. The Plant Operations Review Committee (PORC) has reviewed these items and plans to be more keenly aware of requirements for tagging in future procedure revisions brought in for review. Operations department supervisors will more carefully observe the requirement for placing and removing tags.
- Mr. C. E. Norelius Docket 50-305 May 11, 1983 Page 4 Item 2.
Technical Specification Section 6.8.1, states, " Written procedures and administrative policies shall be established, implemented and maintained that meet the requirements and recommendation of Sections 5.1 and 5.3 of ANSI N18.7-1972". ANSI N18.7-1972, Section 5.1.2, states, in part, " Procedures shall be followed, and the requirements for use_ of procedures shall be prescribed in writing. Rules shall be established that provide methods by which temporary changes to approved procedures can be made, including the designation of a person or persons authorized to approve such changes". Administrative Control Directive 5.2, " Maintenance Procedures", Section 5.6, states, in part, " Prior to implementation, the Temporary [ change to] Maintenance Procedure shall be reviewed and initialed by two members of plant management staff, at least one of which holds a Senior Reactor Operator's License. All Temporary [ changes to] Maintenance Procedures shall be reviewed by PORC and approved by the Plant Manager".
Contrary to the above, during the period of April 22-27, 1982, temporary changes were made by plant electricians to maintenance procedure 58-18469 " Rewire TD AFW pump to S/G 1B MV per DCR-1039" and these changes were neither initialed nor reviewed and approved as required by Administrative Control Directive 5.2.
Response
We concur after reviewing the procedure in question that a change was made without proper authorization. After discussion with the plant maintenance staff, we conclude that it was an isolated occurrence.
We do however, question the severity of the violation, since the change was made due to an obvious typographical mistake, and the prints associated with the procedure rewiring indicated the proper terminations.
In addition, the procedure retest requirements confirmed proper termination and the' Surveillance Procedure proved operability of the component, so there was little or no safety significance to the violation. Again as with the previous violation, we feel this is at most a severity level V violation in accordance with Rules of Practice 10CFR Part 2.
As a corrective measure, maintenance personnel have been re-instructed of the requirements of having changes to procedures properly reviewed and signed off.
Item 3.
10 CFR 50, Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions,
'Mr. C. E. Norelius Docket 50-305 May 11, 1983 Page 5 procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. The licensee's Operational Quality Assurance Program Description dated January 20, 1978, states, in part, "The program complies with the provisions of ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants". ANSI N18.7-1976, Section 5.2.7, states, in part,
" Maintenance of modifications which may affect functioning of safety-related structures, systems or components shall be performed in a manner to ensure quality at least equivalent to that specified in original design bases and requirements, material specifications and inspection requirements". Administrative Control Directive 3.2
" Materials Request" states, in part, "The requesting supervisor or person, for each part, component, or material needed, will mark the request with the QA Type 1, 2, or 3 from the Bill of Materials report, informational retrieval list or the QC Supervisor."
Contrary to the above, Material Request No. 82-2966, dated April 12, 1982, requested QA type 2 fitting for use on QA Type 1 components and the QA Type 1 requirement was clearly indicated on Maintenance Work Request No. 19261.
Response
The above work package was reviewed when brought to our attention by the resident inspector. We concur that the MWR clearly indicated a QA Type 1 activity and since all piping components and fittings associated with the replacement of the safety related containment pressure transmitter constituted part of the containment pressure boundary, QA Type 1 fittings were required and should have been requested on the Material Request for the job. Our investi-gation revealed that all parts and fittings were ordered QA Type 1 for this DCR.
When attempting to install the new pressure transmitters it was found that the originally ordered Swagelok fittings did not fit. A search of our warehouse revealed that fittings of the proper size were in stock. Material Request No. 82-2966 was initiated to retrieve these fittings from stock.
The personnel involved made an error in requesting these parts QA Type 2.
In reviewing our procedures and practices, several reviews should have caught this error and corrected it but did not.
Our procedures require a cognizant
Mr. C. E. Norelius Docket 50-305 May 11, 1983 Page 6 supervisor to sign the Material Request.
In this case the I & C supervisor did not recognize the error. All QA Type 1 MWR's are reviewed by the Quality Control Group. A QC technician is usually assigned to periodically observe the work in progress, provide code related consultation to the man performing the task, inspect and sign off QC hold points for critical functions, and ensure proper tools, materials, etc. are used for the job.
In this case again, the error went undetected. A final review of the entire MWR package is made by several responsible supervisors including the QC supervisor who is the final sign-off for the work package. Once again this error went undetected.
Our innediate corrective action was to pursue certification of the installed fittings since we were relatively certain all Swagelok fittings purchased for stock were purchased QA Type 1.
We were successful in verifying that all Swagelok fittings that were in stock were purchased QA Type 1.
We could not b3 100%
certain of the QA document number, because this was not recorded on the Material Request since the Material Request was issued as QA Type 2 and wasn't necessary by procedure.
Even though we are not 100% certain of the QA document nLmber, there was only one box of the size and type fittings taken out of stock ~and all fittings in that box were of the same lot and thus had the same QA document number. Furthermore, as added assurance that the parts in question could perform their intended function, we verified that pressure leak tests were performed at or above containment post LOCA design pressures. All penetrations were satis-factorily tested.
We believe this incident to be an isolated occurrence for the noncompliance stated in the report. Our review of MWR's and associated DCR's, requested in the cover letter to the referenced Inspection report, substantiates this statement,
' Mr. C. E. Norelius Docket 50-305 May 11, 1983
' Page 7 l
as no other similar mistakes were found. We feel this is an isolated occurrence
'because all personnel, when questioned about the specific requirements of the QA Type 1 components, knew and understood that QA Type 1 fittings should have been required. Since it.had been approximately one year since the incident l
no one could remember the circumstances and why they would not have detected the error. To substantiate our conclusion, a review of MWR's and DCR/MWR packages was performed. A sample of MWR's (see attached Table 1), an estimated 10% of the 1
. Type 1 safety related MWR's in a year, was reviewed with no finding of a similar error to the one noted in the noncompliance.
To prevent. future noncompliances of this nature, this incident was discussed with cognizant plant supervisory personnel, warehouse personnel, QC personnel, and design engineers in conjunction with our QA program and procedural requirements.
No specific procedural changes were identified which would prevent future non-i compliances. A procedural change which requires recording the QA Type 1 document control number of the material used on the material request forni, regardless of the QA type of the material requested, will ensure traceability
-if a similar error occurs in the future.
Increased awareness and renewed QA training in the areas of material control was determined to be the best pre-4 ventative measure to prevent future noncompliances. This training will be
[
given to appropriate plant and corporate personnel by August 15, 1983.
Item 4.
10 CFR 50, Appendix B, Criterion VII, states, in part, " Measures shall be established to assure that purchased material and equipment, conform to the procurement documents. Documentary evidence that material and equipment conform to the procurement requirements shall be available at the nuclear power plant prior to installation or use of such material and equipment". Operational Quality Assurance Program l
Description dated January 20, 1978, states, in part, "The program
^
complies with the provisions of ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants".
j ANSI N18.7-1976, Section 5.2.13.2, states, in part, "Where evidence t
4
' Mr. C. E. N:relius Docket 50-305 May 11, 1983 Page 8 that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items".
Contrary to the above, QA Type 1 items, ordered by Purchase Order No. 51565, were issued, installed, and used in a QA Type 1 component without documentary evidence that the items conformed to the procure-ment requirements. The licensee did not perform a receipt inspection /
test on the items which were received on May 11, 1982, as required by Purchase Order No. 51565.
Response
We have reviewed the above work package and purchase orders and concur that final documentation was not completed. The incident occurred because we did not have adequate procedures in place to detect and require follow up documentation when QA review of a written purchase order results in a change to the procure-ment requirements of a telephone order.
Our analysis of " Degraded Grid Voltage" concerns resulted in a requirement that motor overload heaters be changed for a number of safety related motors. The number and size were unknown prior to a physical inspection. Pressure from the NRC'0ffice of Nuclear Reactor Regulation to complete this review, and upgrade our degraded voltage protection in a prompt time frame, forced us into a situation where a telephone confirmed purchase order was required. The responsible engineer recognized that the motors were QA Type 1, but he did not know of any qualified supplier available in the industry for motor overload heaters. He thus ordered them QA Type 2 (standard "off-the shelf item") and felt justified that since the new heater replacements were more conservatively sized than the previous ones, and that all motors would be operationally tested, all safety concerns were satisfactorily resolved. The heaters were ordered, purchased and installed prior to the followup procurement paperwork being completed.
No special purchase specifications or tests were specified
O
- Mr. C. E. Norelius Docket 50-305 May 11, 1983 Page 9 to qualify them for QA Type 1 application.
4 During the review process of the procurement paperwork, the corporate Quality Assurance group evaluated that the heaters should have been ordered QA Type 1 (requiring special certification and/or testing), and changed the original purchase requisition to so indicate. This paperwork was processed but since the material had already been received and released, there existed no mecha-nism to detect and issue a nonconformance report.
Immediate corrective action was to determine which heaters were received and installed under the QA Type 2 telephone order.
These heaters were immediately replaced with heaters qualified for safeguard (Type 1) use internally under our own QA program testing requirements. Subsequently, all heaters in stock were internally qualified as QA Type 1 via bench testing procedures.
To prevent future occurrences of this nature our internal corporate and plant procurement control procedures were reviewed.
It should be noted that WPS had been aware of problems of this nature and had taken steps to revise ACD 3.4,
" Receiving", as a revised draft ACD had been prepared in December, 1982. The revised procedure places material received, regardless of QA type, on hold until the purchase order has been received. Only legitimate emergency items will be released prior to reviewing against the procurement documents, and these will be conditionally released and a document tracking file will ensure non-conformances are cleared before the QA package is closed out. Certain material is exempt from these requirements. This material includes nonappli-cable QA material such as office supplies, janitorial supplies, etc. This administrative directive has been informally carried out in part since the
- Mr. C. E. N:relius' Docket 50-305 4
May 11, 1983.
- Page 10 time of the notice of violation. The revised procedure has been subsequently issued.
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- Mr. C. E. N:relius Docket 50-305 May 11, 1983 Page 11 TABLE 1 List of MWR's and Associated DCR's Reviewed ACD 5.4 Work Requests ACD 3.4 Receiving ECD 4.1 Design Change Control ECD 6.1 Procurement Control MWR Packages & Associated DCR's 17955 721 18084 18267 18484 18535 18615 18636 18646 841 18674 18700 18724 18814 18878 1064 18883 18819 19013 19029 TCR 79-10 19095 1132 19142 19214 1126 19216 1126 19221 1125 19226 1149 19235 1118 19236 1118 19237 1118 19252 1120 19255 1120 19259 1122 19264 1132 19265 1132 19270 1161 19282 19286 1024 19287 1024 19321 19402 19412 1158 19661 19369 1046 19767 19778
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' Mr. C. E. N:relius Docket 50-305 May 11, 1983 Page 12 TABLE 1 Continued MWR DCR 19780 1118 19786 19795 19875 19939 19975 20039 20074 20210 1010 20273 20360 20361 20452 20565 20596 20803 20810 1274 20872 1274 20959 20987 20995 21004 1213 21005 1181 21006 1213 21030 21031 21085 21113 21124 21130 21156 21164 21471
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