ML20207T518

Notice of Violation from Insp on 861113-870129.Violations noted:program-specific Indoctrination & Training Not Conducted for Personnel Performing IE Bulletin 79-14 Piping Configuration & Pipe Hanger Design Walkdown Insp

ML20207T518
Person / Time
Site:	Kewaunee
Issue date:	03/20/1987
From:	Chrissotimos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207T511	List: IR 05000305/1987002 ML20207T518
References
50-305-87-02, 50-305-87-2, IEB-79-14, NUDOCS 8703240091
Download: ML20207T518 (3)

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NOTICE OF VIOLATION ,

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Wisconsin Public Service Corporation Docket No. 50-305 As a result of the inspection conducted on November 13, 1986, through January 29, 1987, and in accordance with 10 CFR Part 2, Appendix C - General StatementofPolicyandProcedureforNRCEnforcementActions(1985),the following violations were identified:

1. 10 CFR 50, Appendix B,' Criterion II, as implemented by Wisconsin Public Service Corporation (WPS) Operational Quality Assurance Program Description, Sections 2.5 and 10.0 require indoctrination and training be provided for personnel performing activities affecting quality.

Contrary to the above, program specific indoctrination and training was not conducted for the WPS ar.d contractor personnel who perfonned the IE Bulletin No. 79-14 piping configuration and pipe hanger design walkdown inspection. (305/87002-01)

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

2. 10 CFR 50 , Appendix B, Criterion V, as implemented by Wisconsin Public Service Corporation Operational Quality Assurance Program Description, Section 5.0, requires activities affecting quality be prescribed by procedures and drawings. Appropriate qualitative or i quantitative acceptance criteria shall be included in these procedures.

! Contrary to the above, (1) the WPS procedure for conducting the IE Bulletin  :

No. 79-14 walkdown inspection did not contain acceptance criteria for  :

hanger design inspection, (2) the computer analyzed small bore piping was  ;

not included in the walkdown and evaluation program, and (3) there were  !

i no engineering procedures developed and issued for conducting IE Bulletin l No. 79-14 evaluations. (305/87002-02 A, B, and C)

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

3. 10 CFR 50, Appendix B, Criterion X, as implemented by Wisconsin Public j Service Corporation Operational Quality Assurance Program Description, Section 10.0, requires that a program for inspection of activities i affecting quality be established and executed to verify confonnance with >

procedures and drawings.

Contrary to the above, the original construction hanger QC inspection

program, the IE Bulletin No. 79-14 hanger inspection program, and the

i hanger modification inspections perfonned during plant operation were not effectively executed in that, (1) no specific requirements were 1

1 8703240091 870320 PDR ADOCK 05000305 G pg ,

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i Notice of Violation 2 provided for verification of pipe support configuration, orientation or dimensions, and (2) small bore hanger detail drawings did not rovide sufficient information for installation and inspection.

305/87002-03AandB)

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

4. 10 CFR 50, Appendix B, Criterion V, as implemented by Wisconsin Public Service Corporation Operational Quality Assurance Program Description, Section 5.0, requires activities affecting quality be implemented in accordance with procedures.

Contrary to the above, as prescribed by documented procedures, (1) valve operators were not marked on the walkdown isometric drawing, (2) as-built iping dimensions did not reflect the actual installation configuration, p(3) support installation nonconformances were not identified by QA inspection, and (4) the location plans on the pipe support detail drawings were not updated to show the as-built locations. (305/87002-04)

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

5. 10 CFR 50, Appendix B, Criterion III, as implemented by Wisconsin Public Service Corporation Operational Quality Assurance Program Description,

' Section 3.0, requires that measures shall be established to assure that applicable regulatory requirements and design basis are specified and included in design documents; and design modifications receive

. design control measures coninensurate with those applied to the original design.

r Contrary to the above, (1) the IE Bulletin No. 79-14 reevaluation for several motor operated valves was performed without vendor information or l a documented calculation to ensure that the piping analysis met Code requirements, (2) the implementation of design specifications was i

indeterminate due to the absence of hanger design calculations,

! (3) installation deviations on small bore piping were not evaluated for I acceptance, and (4) there was no documented engineering justification for deviations from original' piping design dimensions that were less than l

i two pipe outside dianeters. (305/87002-05 A, B, C and D)

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

6. 10 CFR 50, Appendix B, Criterion XVI, as implemented by Wisconsin Public Service Corporation Operation. Quality Assurance Program Description, Section 16.0, requires that for situations detennined to be significantly

-adverse to quality, corrective measures should be taken to preclude L

repetition.

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Notice of Violation 3 Contrary to the above, the NRC inspection identified many of the same ,

problems identified in WPS Audit Report No. 79-73. These audit findings were closed on December 1979 even though many of the piping walkdown dimensional inconsistencies continued to exist. (305/87002-06)

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

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this

- office within thirty days of the date of this Notice a written statement or

- explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

3 -lo 'S T f~. .'ryssot4mos

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Dated T.~J .

Acting Director, Division of Reactor Safety

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