ML20137E142

Notice of Violation from Insp on 850923-27

ML20137E142
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/19/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137E140	List: ML20137E135 ML20137E142 ML20137E165
References
50-370-85-29, NUDOCS 8511270207
Download: ML20137E142 (3)

Text

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ENCLOSURE I NOTICE OF VIOLATION Duke Power Company Docket No. 50-370 McGuire Unit 2 License No. NPF-17 The following violation was identified during an inspection conducted on September 23-27, 1985. The Severity Level was assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

10 CFR 50, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Duke Power Company's approved Quality Assurance Program, states in part, that Duke Power has estabitshed and implemented a quality assurance program which conforms to the criteria established in Appendix B to 10 CFR 50. The basic written instructions and procedures for operating activities affecting quality are contained in the Nuclear Production Department's Administrative Policy Manual for Nuclear Stations.

Technical Specification 6.8.1.a, states in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, states that the following are typical safety-related activities that should be covered by written procedures:

Administrative Procedures on: (1) Procedure Adherence and Temporary Change Method, (2) Procedure Review and Approval, and (3) Log Entries, Record Retention, and Review Procedures.

Procedures for Performing Maintenance. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, as of September 27, 1985, NRC identified the following examples of failure to meet these requirements.

a. Work Request 123686 OPS,Section III, states, Note: Any tubing work, contact quality control prior.

f 0011270207 e51119 PDR G ADOCK 05000369 PDR

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. Duk6 Power Company 2 Docket No. 50-370

. McGuire Unit 2 License No. NPF-17 x Administrative Policy Manual,. Section 3.3.2.3(b) states, for

> maintenance. activity which affects the pressure boundary of systems or

! components classified as ASME Boiler and Pressure Vessel Code Class 1,  ;

2, or 3, a code authorized inspector shall be provided an opportunity i to review the proposed activity prior to the beginning of work if required.

Contrary to the above, Quality Control was not provided an opportunity 9

to review a tubing test, tee replacement on Cold Leg Accumulator Level Transmitter 2NILT 5110 which was within a safety class boundary, f

b. McGuire Station Directive 2.1.1, Control of Master File Documents, i states, document retention requirements are six (6) years or service ,

life whichever is greater for copies of completed work request and  !

equipment histories for measuring and test devices and installed process instrumentation.

Contrary to the above, work request 123686 OPS, was missing a completed '

calibration data sheet for a cold leg accumulator level transmitter 2NILT5080 and the independent verification sheet for the April 24, 1985, calibration of level transmitters 2NILT5060 and 2NILT5070.

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c. McGuire Station Directive 4.2.1, Handling of Station Procedure, states  :

in part, that this directive applies to all, both safety-related and l non-safety-related. If any deviation from the method and steps

, specified in a procedure is necessary, a procedure change shall be initiated. It is the responsibility of each person using the procedure i

to insure the procedure is followed or appropriate procedure changes are initiated and approved prior to using the procedure.

Contrary to the above, the licensee failed to follow procedure IP/0/A/3214/04, Calibration Procedure for Rosemount Model 1152 Transmitters, while performing work request 123686 OPS on cold leg accumulator level transmitters 2NILT5060 and 2NILT5070, in that, Step 10.1.7 of the procedure required " applying input pressure at approxi- l mately 0, 25, 50, 75, and 100% of input range specified for this transmitter." The licensee only applied input pressures to the transmitter at the 0 and 100% ranges. Additionally, the calibration reference data and method of calibration was unreviewed and a procedure

. change was not initiated and approved for this method of calibration. '

d. Contrary to the above, the licensee failed to have appropriate

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quantitative or . qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished on procedure I

IP/0/B/3000/03, revision 15. The procedure was inadequate, in that,

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l Unit 2 cold leg accumulator level transmitter calibration reference data was deleted and all Unit 2 cold leg accumulator level transmitters  !

were calibrated with Unit I data when performing work requests 023345 PM through 023352 PM.  !

e.

McGuire Station Directive 3.2.1, states in part, that a functional

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Duk'e Power Company 3 Docket No. 50-370 McGuire Unit 2 License No. NPF-17 verification shall be performed on QA conditions 1, 2, 3, and 4, security systems and Technical Specification related components following maintenance. The functional verification will be the responsibility of the Maintenance Supervisor performing the work and shall be documented in Section V or VIII of the work request by stating method and results obtained in the space provided.

Contrary to the above, the licensee failed to conduct a functional verification and documentation of work request 123686 OPS, investigate and repair cold leg accumulator level loops and work requests 023345 PM through 023352 PM, perform preventative maintenance and performance test on accumulator level instruments. Cold leg accumulator level instruments are Technical Specification r21ated instruments (TS 3.5.1.1.e).

This is a Severity Level IV violation (Supplement I).

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or dental of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

Date: November 19, 1985 I

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