ML20206U186

Notice of Violation from Insp on 860616-27

ML20206U186
Person / Time
Site:	Columbia
Issue date:	09/18/1986
From:	Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206U176	List: IR 05000397/1986031 ML20206U172 ML20206U186
References
50-397-86-31, NUDOCS 8610070339
Download: ML20206U186 (10)

Text

_ _ _ . _ _ _ _

ls- Sa' .4 y

w: s

~

t APPENDIX A. .

I NOTICE OF VIOLATION '

Washington Public Power Supply System Docket No. 50 1397 ,

Nuclear Plant WNP-2 License No. NPF-21 I. As a result of the inspection conducted on June 16-27, 1986 (Inspdction Report No. 86-11), and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C) the following violations were identified. *

-4.

A. 10 CFR 50 Appendix B, Criterion V states, in part, that:

" Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...and shall be accomplished in accordance with these instructions, procedures or drawings."

Further, Section 5.2.1 of WNP-2's Operation Quality Assurance Program Description Manual, states, " Activities that affect safety-related functions of plant items shall be described by and accomplished through implementation of documented procedures, instructions or drawings as appropriate."

1-a. Step 1)a. of Procedure No. 7.4.8.2.1.10, 60 Month Battery Testing of E-B1-HPCS, requires that the test coordinator

" Verify all prerequisites have been read and understood and these prerequisites have been met."

Contrary to the above, during the retest of the HPCS battery on May 25, 1986 the prerequisites were not verified.

1-b. Section 1.5.1.3.E of procedure 1.5.1, Technical Specification Surveillance Testing Program, states, regarding test instruments used in the conduct of surveillance tests: "The manufacturer's model number, name and range (if applicable) shall be recorded, as well as, calibration void date as applicable."

Contrary to the above, on May 25, 1986, the calibrated instruments used during the retest of surveillance procedure number 7.4.8.2.10, 60 Month Battery Testing of the E-B1-HPCS, were not identified in the record.

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

2-a. WNP-2 Administrative Procedure 1.5.4, Section 2 states, in part, "This procedure establishes responsibilities and methods for the control and calibration of all M&TE used by plant personnel and other groups or contractors who may be issued such equipment."

, Contrary to the above, at the time of this inspection, the records pertaining to the following three items indicated the tools were in the tool crib, when, in fact, the tools were not in the crib.

i 8610070339 860918 PDR ADOCK 05000397 O PDR

4 2

s a) Master List Item No. 40377,"O.D. Micrometer (s) b) Master List Item No. 42477, Oxygen Analyzer c) Master List Item No. 39366, Pyrometer 2-b. WNP-2 Administrative Procedure 1.5.4 Section 5.E.8 states, in part:

" Return M&TE to the M&TE Cool Crib in less than or equal to seven days from time of checkout EE when need exceeds seven days, the person using the M&TE will return to the M&TE Tool Crib and sign it out for another seven days."

" NOTE: This may be repeated until the calibration cycle is expired."

Contrary to the above:

(1) Torque wrench EQ 262 was checked out of the tool crib on April 30, 1986 and checked in on June 2, 1986 without any interim recorded history to demonstrate that the seven day rule was satisfied.

(2) Torque wrench EQ 265 was checked out of the tool crib on May 3, 1986 and checked in on June 6, 1986 without any interim recorded history to demonstrate that the seven day rule was satisfied.

2-c. WNP-2 Administrative Procedure 1.5.4 Section 7.B.1 states in part, "All M&TE shall have a Supply System identification number permanently attached. Some equipment due to their size and/or usage will not have a Supply System ID number or tag, these items shall be etched or otherwise permanently marked."

Section 7.B.4 states in part, "The Supply System identification number and the noun name of the piece of M&TE shall be entered into the computer listing of all Plant M&TE."

Contrary to the above:

At the time of the inspection 62 crimping tools were found in the plant which had not been identified with a calibration code number nor recorded on the M&TE master list.

This is a repeat Severity Level IV Violation (Supplement I).

3. Plant Procedure Manual (PPM) 1.3.7 states "The Maintenance Work Request (MWR) shall be used to control all corrective maintenance activities...." Step 1.3.7.7.A of the procedure requires that "the smallest piece of plant equipment that requires the work be used to identify what is worked on."

a 3

This procedure also states that the maintenance section supervisor " Reviews and ensures that NWR and any supporting documentation is completed.... Signs ' Reviewed by' block of work section and indicates that the work has been accurately and completely performed in compliance.with applicable plant procedures."

Contrary to the above, on May 31, 1986, MWR #AU3181,_ issued on February 7,1986 for RHR-M0-6B, was " continued" af ter the work section supervisor had reviewed and approved the completed MWR; however, work was performed under NWR '#AU3181 on another valve (RHR-V-278) and the " continued" MWR was not reviewed by the Maintenance Section Supervisor for the additional work.

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

a. Section 2.B of Plant Procedure Manual 10.20.10, Rev. 1 entitled

" Diesel Air Start Motor Maintenance," reads, " Data Sheet 1 must be filled out for rebuilt air motors. Several steps require an independent check and signature."

Contrary to the above, subsequent to April 26, 1986, four (4) air start motors (Serial Nos. 119197, RBJ 06581, RTM 31854 and 116294) to be used on the emergency diesel generators were rebuilt as prescribed on Maintenance Work Request UA 3423. No independent checks or inspections were performed by Quality Control personnel. Also, no signatures were on the associated maintenance documents to show that independent checks had been performed. '

4-b. Step 7.C.16 of Plant Procedure Manual 10.20.10 Rev. 1, entitled, " Diesel Air Start Motor Maintenance," states, "Use a inside micrometer to measure the bore of the cylinder. If the

' bore exceeds 3.460 inches replace the cylinder."

Contrary to the above, on January 16, 1986 during rebuilding cf air start motor RHB 07334, the: cylinder bore was not measured.

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

5. Plant' Procedure 10.25.19, Revision 2, " Termination and Splicing Instruction", sets forth the procedures for terminating electrical cables. Section 9, Paragraph A.2.c of this procedure states, " Prior to terminating the conductor (s), the electrician shall install lugs / connector on both the 'to' and

'from' ends of the conductor (s) and verify conductor (s) integrity by performing a continuity check." The procedure also states that if continuity results are satisfactory, the electrician shall sign and date the " Wire Termination List" in the block identified as " Continuity Test". Paragraph A.2.d of this section states, "The electrician shall complete the directions called out on the ' Wire Termination List' or the

' Interconnect Termination Instructions' as applicable, for each conductor. When the modification has been made, the

4 electrician shall. sign and date the ' Wire Termination List' and/or'the ' Interconnect Termination Instructions'."

Contrary to the above, on February 5, 1986, the electrician performing the work on.the Emergency Diesel Generators excitation circuit motor-operated potentiometer pursuant to Maintenance Work Request AW'6886, did not sign or date the Wire Termination List'and/or the Interconnect Termination Instructions.

This is a Severity Level V Violation (Supplement I).

~

6. Administration Procedure 1.3.19, Housekeeping, Section 2,

" Individuals Responsibilities," reads, in part, "Each employee will perform the following at the end of each assignment or at the end of'the work day if assignment is not complete."

"a. Wipe up minor oil spills, pick up rags, papers and other foreign material....

"b. At the end of the job, return all tools and equipment used to assigned storage locations....

"f. Control panels and all escutcheons, engravings, etc. are to be inspected weekly and cleaned as needed by operator on duty."

Contrary to the above requirements, at the time of the inspection, foreign materials were located in the areas described below and no work assignments were in progress.

wrenches and hand saw in Room 213 rubber glove in RHR pump 2A sump "

, debris in pit under RHR pump 2B .

paper blocking metal bar screen on drain under RHR pump 2C

• cigarette butts and package.in RHR pump 2C room Bisco foam on floor near open drain in'RHR pump 2C room, The following materials were also found loose inside control room panels 601, 602 and 603:

b

• electrical crimping lugs

• one replacement electronic module

• Jumper cabling (unused)

• approximately one dozen metal plates (covers for electrical equipment) plastic cable tray covers approximately thirty loose screws

• three metal annunciator back guards electrical solder fuse identifiers two electronie. isolators phone jack

} M. 9 o s L r y - * ) ., ..

a , ^

5' >

E'- T

~.

'; i,

. .s

?

.3, electrical' lamps (replacement bulbs) m_ fuses s a two-foot copper ground wire, fastened at one end This is a Severity Level IV Violation (Supplement I).

B. 10 CFR 50 Appendix B, Criteria XVI, states that " Measures shall be established to assure that conditions adverse to quality, such as...nonconformances are promptly identified and corrected."

Quality Assurance Surveillance Report 2-85-086,' issued in August 1985,cidentified conditions wherein Plant Procedures-Manual Procedure 1.3.7, " Maintenance Work Request," was not being completely followed in that significant omissions were identified on completed Maintenance Work. Requests. Plant management stipulated in a response letter, issued December 26, 1985, that as part of the corrective action, the surveillance report would be required ' reading for all maintenance supervisors. This action was to be accomplished by January 10, 1986.

Contrary to the above, as of June 23, 1986, the QA surveillance report.had not been issued to the maintenance supervisors and they had not reviewed it. Similar omissions were also noted to have occurred on recently completed Maintenance Work Requests (e.g.,

'AU1430,,AU2128, AU3181 and AU538).

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

C. 10 CFR 50 Appendix B', Criterion X,- states in part, "A program for

. inspection of activities affecting quality shall be established and executed by or for the' organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity. If mandatory inspection hold points, wuich require witnessing or inspecting by the applicant's designated representative and beyond which work shall proceed without the consent of its designated representative are-required, the specific hold points shall be incorporated in the

.y. ,

. appropriate documents." '

s Contrary to the above, on June.27, 1986, criteria for the

} --

designation of appropriate quality control inspections and the,,

establishment of hold points for safety related maintenance

~

, activities, not specifically prescribed by applicable codes, had not

, been established.in written procedures. As a result, the following "

> were identified: ,

1. Residual Heat Removal flow control valves FT-15B and FT-15C '

were installed on May 25, 1986. No QC inspection was made'of _

.the torque values applied to the attachment bolts for thelflow control valves.

2. .There was no QC inspection of the torque values applied or of 4 torque wrenches used during installation of the bolts for the

.. ._ . ., . .-- . . __ _. _ . __ . ~ .- . .

g- t 6

. ' air start motors on the eme'rgency diesel generators in April-May, 1986'.

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

~

II. As a result of the inspection conducted between June 10 and July-10, 1986 (Inspection Report No. 86-22), and in accordance with the NRC Enforcement j

Policy (10 CFR Part 2, Appendix C), the following violations were identified.

_ Technical Specification 6.8.1 reads, in part:

i " Written procedures shall be established, implemented, and maintained covering the activities referenced below:

g. Fire Protection Program Implementation."

A. Administrative Procedure 1.3.35 Revision I dated January 6, 1986, reads, in part:

"1.3.35.6 Flammable or Combustibles Procedures "B. Flashpoint 100 F or less.

1. Examples acetone, alcohol, thinner, etc.

2. Less than one gallon - all plant areas.

l

a. Safety can required

< 5. Flammable liquids must be removed and put into storage.

a. At end of job or i b. At end of shif t if job is not continuous between shifts.

i "E. Aerosol Containers i

i 1. Al'ohol c and Petroleum base or flammable contents.

4

a. Kept at work site in limited quantity.

. b. Removal from jobsite at end of job or shift.

', d. _ Storage in approved cabinets in designated areas" Contrary to the above:

1. On June 11 and 12, 1986, a 1 pint plastic spray bottle (not an approved safety container) containing alcohol was unattended on i the 606' elevation of the Reactor Building (a plant vital t area).

.~.w , - - , - - . ,.-- w , - < , - - , ,.n , ,_ ,., . , . . . . . . ~. -. ,c r--: - -- , - , - - ,a, .,

g.

-7

. -o .

2. On-June 12, 1986, in battery charger room #1 a one pint plastic .

poly bottle (not an approved safety container) of " Age Guard I Silicon Fluid" labeled " Keep Away From Heat or Flame" was unattended 'No work was in progress.

3. On June 12, 1986, in the Division 1 Switchgear Room, Room C208, an aerosol can labeled " enamel" " Extremely Flammable" was

- unattended in an open crew box (not an approved cabinet or a designated area). No work was in progress in the area.

This is a Severity Level IV violation (Supplement 1), and is similar to-a violation cited in inspection report 50-397/85-22.

B. Administrative Procedure 1.3.35, Revision 1, dated January 6, 1986 reads, in part:

t 1

="F. Combustible Materials - Vital Area

1. .Ill combustibles that can be eliminated as part of the

. work process should.be. This would include the removal of packaging materials, boxes, wrapping, etc.

2. Combustibles that enter the vital area should be removed at the end of the' job or shift if. work is not continuous between. consecutive shifts.

t

3. When removal is not possible, a Transient Combustible Permit is required.

"I. All waste, debris, scrap, oil spills, or other combustibles resulting from the work activity shall be removed from all

! vital and critical plant areas immediately following completion of the job or the end of shift if work is not continuous l between consecutive shifts.

"J. All. temporary wood / blocking used in the plant shall be treated' with a U.L. listed pressure impregnated process."

! Contrary to the above:

1. On June 11, 1986 and on June 12, 1986, after the end of the i normal workday shift, the following described combustible materials were in vital areas of the plant as indicated below,

. with no transient combustible permit posted at any of the locations and no work in progress at any of the locations.

a. Reactor Building 501' elevation

i'

• A large (approximately 2' x 3' x 3') cardboard box on an untreated wood block stand was located beside the Standby Liquid Control area.

1 1

1

l

. 8 0

A large yellow plastic bag containing some clothing was located inside of the shielded area in the NW corner.

b. Reactor Building 522' elevation:

Two (2) large cardboard boxes of combustibles were located in the NW corner.

A 10 gallon trash can full of oil-soaked paper, such that the lid was propped open, was located in the N.W. corner. The label on the~can read " empty nightly".

A pile of trash on the floor including cloth, plastic and cardboard, located in a corner under an instrument labeled TB&R 494.

In front of the primary containment entry was an accumulation of combustible materials, both inside and outside of a roped off area. These materials included:

A number of hoses outside of the roped area.

A barrel overflowing with used protective clothing.

c. A cardboard box of trash was in the Remote Shutdown Room.

2. On 6/12/86 after the end of the normal work day and shift the following described combustible materials were in vital areas of the Reactor Building and the Radwaste Building,'with no transient combustible permit posted at any of the locations and no work in progress at any of the listed locations. The types of material and locations were as follows:

a. 606' elevation of Reactor Building:

Two Brag boxes of paper towels and various other cleaning materials were in the area above the reactor vessel,

b. 522' elevation of Reactor Building:

A cardboard box (approximately I' x 2' x 2') full of plastic sheets was in front of the electronics counting room.

Small piles of cloth and plastic were under instruments labeled as IR 71 and RRC PT 38A.

9 An accumulation of combustible materials, both inside and outside of a roped off area, was in front of the primary containment entry. These materials included:

A lab coat hanging from scaffolding (outside the roped off area), and another hanging on a nearby cart A full Brag box of paper A large plastic cart filled with full bags of radwaste and protective clothing.

c. 548' elevation of Reactor Building:

A large pile of hoses, protective clothing and plastic was near the entry to door R-504 by the stairwell.

A large plastic cart filled with full bags of rad waste and protective clothing was in the S.W. corner.

An enclosure built with plastic sheets for thermolag work contained 2 cardboard boxes and 1 brag box.

Outside of this enclosure was a large (approximately 2' x 2' x 3') cardboard box of filters.

d. 501' elevation of Reactor Building:

A pile of hoses and a Brag box of paper towels was in the N.W. corner.

e. Radwaste Building:

A pile of hoses and electrical cord was in the Control Room Emergency Ventilation Room.

This is a Severity Level IV violation (Supplement 1), and is similar to violations cited in inspection reports 50-397/85-05, 50-397/85-20 and 50-397/85-22.

C. Administrative Procedure 1.3.35 Revision 1 dated January 6, 1986 reads, in part:

"1.3.35.8 Fire Protection System Impairment Check List Procedure "A. Required when

6. Leaving a normal closed fire door or damper in open position.

"E. Approval and Use

1. Completed permit to shif t Manager /Shif t Support Supervisor for approval.

10

4. Hard copy posted at job site."

Contrary to the above:

1. On June 11 and on June 12, 1986 Fire door R 5-17 (a required 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier) on the 522' elevation of Reactor Building

, was propped open with a scaffolding clamp and no fire systems impairment permit was posted in the area. Hourly fire watch

, tours were being performed in the area to meet other i requirements of the fire protection plan.

2. On June 12, 1986 fire door R-408 (a required 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier) on the 522' elevation of the Reactor Building was propped open with'a wooden broom. Also, tape was over the latch, thereby rendering the door inoperable. No fire system impairment permit was posted in the area. Hourly fire watch tours were being performed in the area to meet other requirements of the fire protection plan.

This is a Severity Level IV Violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply System is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2)'

corrective steps which will be taken to avoid further items of noncompliance; and (3) the-date when full complisnce will be achieved. Consideration may be given to extending your response time for good cause shown.

SEP 181986 e Dated . P. H. nson, Chief React r Projects Section 3 4

f J

. , . . . . _ - - _ _ - - _ - . , - , - . . - _ - - . _ - . . . .