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-D:ckat No. 50-219 License No. DPR-16 APPEtmIX A OCT 171975 NOTICE OF VIOLATION j'
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Based-on the resuts of an NRC inspection conducted on March 10-14,
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1975, it appears that certain of your activities were not in full compliance with NRC regulations and the conditions of your license as indicated below. Each item is also a requirement of the Oyster Creek Operational quality Assurance Plan-(0QAP) which you cubmitted to the j
NRC as implementation of 10 CFR 50, Appendix 11 - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
1.
Criterion II, Appendix B, 10 CFR 50 requires that the quality i:
assurance progran shall be documented by written policies, proce-dures, or instructions and shall be carried out throughout plant life in accordance with those policies,' procedures or instructions; that the program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to i
assure that suitable proficiency is schieved and maintained; that the quality assurance program provide control over activities j
affecting quality to an extent consistent with their importance to safety.
The Operational Quality Assurance Plan, Revision 1, dated a.
September 30, 1974,Section II, states that the licensee will utilize the guidance of ANSI N45.2.6-1973. Articles 3 and 5
- N of ANSI N.2.6-1973 require qualification and certification of Level I, Lovel II and Level III inspection, Examination and Testing Personnel.
Contrary to the above, certain site personnel engaged in maintenance testing, examination, and inspection activities did not have the required certification defining levels of capability, in that persons performing testing following maintenance were not certified as Level I or II, nor were persons interpreting test data certified as Level II as specified by Section 3 of ANSI N45.2.6-1973.
This is a deficiency.
b.
Section III of the Operational Quality Assurance Plan states that the Oyster Creek Superintendent is responsible for l
preparation, review and approval of the plant maintenance procedure which specifica che ncnner in which plant mainte-nance and repair is controlled by distinguishing between f
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1 Appendix A OCT 171973 different types of maintenance and repair and specifying the applicable requirements for the control of each.
Implementing Prodedure 105, " Maintenance, Repair and Modifi-S cation Cantrol," states that items which fall under the cognizance of the QA Plan shall be segregated and handled in accordanco with this procedure.
Contrary to these requirements, twelve job ordera reviewed during the inspection, all of which involved raaintenance of safety related systems, were not segregated and handled as being under the control of the quality assurance program.
This is a deficioney.
2.
Criterion III, Appendix B, 10 CFR 50 requires establishment of measures to 1) assure that the design basis, as defined in 10 CPR 50.2, is correctly translated into specifications, drawings, procedures, and instructions, and 2) for the identification and control of design interfaces and for coordination among participating design organizations. The OQAP,Section III, Revision 0, dated December 14,, 1973, states that design control is implemented by Generation Engineering Procedures which include denign review requirements, internal and external interface control considerations.
and appropriate design bases.
M Contrary to the above, regarding plant codifications, measures were not taken to include 1) consideration of design bases, 2) control of design interfaces, and 3) the coordination among participating design organizations, until the issuanco on March 7, i
1975, of Proceduro 6003, "!!odifications, Non-routine Maintenance, and Repair." Even then, the referenced procedure did not provide j
for the consideration of the design bases, not for coordination among participating design organizations in design review require-monts for plant modifications.
This is a defiefency 3.
Criterion V, Appendix B, 10 CFR 50 requires that activities affecting quality shall be prescribed by documented instructions, i
procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these inotructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
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The Operational Quality Assurance Plan Section IV requires a.
that procurement documents prepared by or for the Generation Department be approved in accordance with the Generation
/t?A Department Procedure. Generation Department Procedure 2001,
??O Administration of Procurament, Revision 1, dated October 4, 1974, Section 3.2.2 requires Operational Quality Assurance review of and concurrence with procurement documents.
Contrary to the above, procuroment documents for chemicals had not received Operational Quality Assurance review.
This is an infraction.
b.
Section V of the operational Quality Assurance Plan requires that instructions and procedures associated with maintensnce be Laplemented in accordance with the OQAP. Instruction SQA-1-74-G-004 requires a QA Specialist to review and then log QA related jobs in the inspection log, including the name of the job or system, the present plans for, and nature of the work to be done.
Contrary to the above, twelve safety-related job orders were neither reviewed nor logged by a QA Specialist.
j This to an infraction.
i 34Af Tho Operational Quality Assurance Plan, Revision 0, dated c.
December 14, 1973, provides in Section III, for a System Boundary and Classification Book for expanding the Quality Assuranco Systems List (QASL) into categories of cafety classes using Regulatory Guides 1.26 and 1.29 for guidance and specifying the basic codes, standards and regulatory requircaents for each category. Tha OQAP, Appendix C, i
Revision 0, dated Decociber 14, 1973, " Preliminary List of Procedures Impicmenting the Quality Ascurance Program,"
lists, es one of the procedurco which should be ready and issued by April 1974, the System Boundary and Classification Book.
Contrary to the above, required definition of equipment and component oafety classification had not been secomplished:
in that the System Doundary and Classification Dook was not provided as of March 12, 1975.
Th$a is a deficiency.
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. Appendix A OCT 171975
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Technical Specification 6.2.C requires that operating proce-dures be followed.Section V of the OQAP states that Oycter Creek Superintendent is responsiblo for ensuring the instruc-
.i'M tions and procedures associated with operational testing are
'W prepared, reviewed, approved, and innplemented in accordance with the OQAP.
Contrary to the above, 1) the diesel fuel inventory log entries which serve to document maintenance of minimum fuc1 levels established by the Technical Specifications were not made ao required by Procedure 301 for the period January 6 - February 3, 1975, 2) Station Dattery "B" discharge test log entries required by Procedure 601 were not made on Uccereber 18-20, 1974, and 3) Control nod Drive Syntem costing log entries. required by Procedure 603.3 were not made on January 27, 1975.
This is a deficiency.
a.
The Operational Quality Assurance Plan,Section V, states that the Oyster Creek Superintendent is responsible for ensuring that instructions and procedures are implemented. Proceduro 102, Train $ng of Nucinar Gennrating Stad on Pernor.nni, Ecvision 0, dated July 18, 1974, states that sito training is conducted in accordance with detailed procedures specified in the Oyster Crack Training Manual.
Contrary to the above, detailed proceduren specified in the Oyster Creek Training Manual vero not being used to train non-licensed techniciano and repair personnel, in that non-licensed technicians and repair personnel training was being conducted pursuant to Job Qualification Review Sheets pro-pared on each individual.
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This is a deficiency.
4.
Criterion VI, Appendix B, 10 CFR 50 requires that safety-related documents be reviewed for adequacy and approved for release by authorized personnoit that safety-related document changes be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization; and that safety related docu-ments be distributed to and used at the location where the prescribed activity is performed.
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- OCT 171975 Appendix A-Technical Specification Sections 6.1.C.1.d., 6.2.D and 6.2.E a,
Jefh require Plant Operations Review Committee (PORC) review and y
'f Station Superintendent approval of plant operating and surveillance procedures prior to implementation, t
Contrary to the above, procedure review and approval require-ments were not met at the site: in that the procedure used on March 12, 1975, to obtain an Air Ejector radioactive Off-Gas sample had not received PORC review and Station Superintendent approval; and in that eight (8) of twenty-five (25) surveil-lance test procedures sampled were not reviewed by PORC prior to their implementation.
This is an infraction.
I b.
Technical Specification 6.2.F provides that temporary procedure 4
changes which do not change the intent of the original procedure may be made under specified circumstances which includo subse-quant review by PORC and approval by the Station Superintendent.
Contrary to the above, a temporary chnoge nade on January 24, 1974, to Procedure 609, was not subsequently reviewed by PORC and approved by the Station Superintendent.
awsg This is an infraction.
The Operational Quality Assurance Plan, Revision 0, dated c.
December 14, 1973,Section VI, states that 1) a standard Generatiop Department proceduro for document control includes basic generic controls to be incorporated by each manager,
- 2) the Generation Department document control procedure requirec measures to insure documents are available when re-
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quired, 3) the impicmenting procedures, including the document control procedure, should be complete and issued during April, 1974, and, 4) the Oyster Creek Superintendent is responsible for the j
implementation of the document control system for documents received or prepared at the generating station.
1 Contrary to the above, required document control was not provided in that 1) the docunent control procedure, or en equivalent control over as-built drawings and site issued documents was not provided as of March 12, 1975, and 2) as-built engineering drawings were not distributed to the C'
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- p OCT hi D Appendix-A' e licensee's Morristown Pinza Offices where Generation Engi-Jneering Departoont personnel are regularly engaged in 1
decision-making engineering work requiring the use of as-Nii.
built' drawings.
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This is an infraction.
j 5.
Criterion VIII, Appendix B, 10 CFR 50 requires establishment of measures for identification and control of materials, parts and con:ponents to assure that identification of the item is maintained throughout installation end use.
Section VIII of the OQAP states that the Oyster Creek Superintendent is responsible for maintaining identification and control of materials, parts, or components received, stored, installed, and used at the plant site.
Procedures covering the identification and control of materials, parts, and components-are prepared by.the plant staff, revieued by PORC, and approved by.
the Plant Superintendent. These procedures will be reviewed and concurred with by the Quality Ascurance Supervisor for compliance with the CQAP. The Quality Assurance Supervisor is responsible for surveillanen and audit of the implementation of these procedures by the plant ctaff and by site contractors. Station Procedure 1
3003 states that ence an item is inetslied er u::cd, th:: "REL"ASED POR USE" tag is removed and returned to Quality Assurance who records this fact on the Peterial Identification and Control Sheet.
I and dentroys the tag.
Contrary to the above, " RELEASED POR USE" tags for materials used in the Core Spray System and the Puel Pool Filter dated February 17, 1975, were neither on the equipment nor recorded on the Material.
Identification and Control Sheet.
This is a deficiency.
4 6.
Criterion KI, Appendix B, 10 CFR 50 requires establishment of a test program to assure that all testing, including operational testing, required to demonstrate that structures, systems, and 8
components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporato the requirements and acceptance limits contained in applicable design documents. The OQAP,Section XIV, requires,
- 1) that maintenance testing be conducted in accordance with
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specifications, maintenance procedures, etc., 2) that the work
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prepared and approved by the responsibic organization, and 4)
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that the procedures be reviewed and audited by Operational Quality.
Contrary to the above, written and approved procedures which
- 1) defined the testing required. 2) identified individuals responsible for procedure and test revicw, and 3) specified the required tcat documentation, were not provided for at least one of the routine post maintenance testing activities covered by the twelve job orders referred to in Items 1(b) and 3(b) above.
This is an infraction.
i 7.
Criterion XV, Appendix B, 10 CFR 50 requires establishment of measures to control materials, parts, or couponents which do not confom to requirements in ordor to prevent their inadvertent use 1
or installation.Section XV of the OQAp requires that nonconfoming items found during checks of modification, naintenance or repair j
work be clearly identified and docunented, and that supervision and i
management be notified so that appropriate corrective action can be
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taken. In the event prompt corrective action is not taken, the QA Supervisor notifies thel'.anager-0perationni Quality Ansurance and the Oyster Creek Superintendent so that corrective action can be y@
. expedited.
Section XVI of the OQAP states that corrective action procedures include provisions for evaluation of nonconformances, determination of suitable corrective action, responsibility for timely disposition and followup action, authority for approval of i-proposed corrective action, and the required documentation.
Evalu-ation of a nonconformance includes consideration of the cause, other areas which eculd experienco similar nonconformances, and solutions i
that would prevent a repetition of the nonconformance.
Section XVI also states that Operational Quality Assurance procedures include 4
provisions to assure that corrective action and documentation are accomplished.
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. Contrary to the above, the Condensate Transfer System was returned to service with unresolved nonconformances involving use of' backing ringe in welded pipe joints which is not permitted by the Engineering Specifications.for the project (identified by licensee 10/25/74),
failure to apply a protective coating before other welds are made
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Appendix A OCT 171975 as specified by the welding procedure (identified by licensee 10/24/74), field fit-up of a pipe section not provided for in civs proceduro (identified by licensoe 10/24/74), cutting and revolding a 20-foot scetion of pipe not covered in the procedure.or in a written Engineering authorization (identified by licensee 10/24/74), and failure to conduct a required hydrostatic test (identified by licensco 3/8/75). As of !! arch 12, 1975, these matters had not been resolved.
This is an infraction.
8.
Section 4, Appendix A, 10 CFR 55 requires annual written examinn-tions of licensed operators. The licensee's operator requalifica-tion program, approved by Reactor Licensing letter dated.Novetr.ber 13, 1974, states that December 17, 1973 is the starting dato for the annual cycle of the requalification program.
Contrary to the above, written examinations of licensed operators were not given when required, in that none of the twenty licensed operators vara given written examinations on or before December 17, 1974.
This is a doficiency.
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