ML20212B975

Notice of Violation from Insp on 870112-16

ML20212B975
Person / Time
Site:	Salem
Issue date:	02/20/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212B909	List: IR 05000272/1987002 ML20212B903 ML20212B975
References
50-272-87-02, 50-272-87-2, 50-311-87-02, 50-311-87-2, NUDOCS 8703030680
Download: ML20212B975 (3)

Text

.

4 APPENDIX A NOTICE OF VIOLATION Public Service Electric & Gas Co. Docket Nos. 50-272 50-311 Salem Nuclear Generating Station License Nos. DRP-70 DRP-75 As a result of the inspection conducted on January 12 - 16, 1987, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), published in the Federal Register on March 8, 1984, the following violations were identified:

A. Criterion III of 10 CFR 50, Appendix B, requires that measures be established for the identification and control of design interfaces and for coordination among participating design organizations. It also requires these measures to include the establishment of procedures for the reviews, approval, distribution and revision of documents involving design interfaces.

Procedures QAI 3-1 of the licensee's Quality Assurance Manual requires the inclusion and implementation of design interface controls in the design control procedures. Also, PSE&G's procedure VPN-QAP-01 " Operational Quality Assurance Program" requires in section 7.3 for design control that design change procedures provide for the timely update of records and affected documents following design change implementation to reflect the as-built configuration.

Contrary to the above, procedures for implementing design interface measures in the following piping and support system modifications completed during the 1986 refueling outage were either non-existent or inadequately specified. This resulted in the failure to update affected safety related structural as-built configuration records and to evaluate the effects of increased mechanical component support loads on these structures.

1. Modification DCR NO. 2EC-01691 and 2EC-01692 for replacement of the carbon steel service water piping with stainless steel naterial involved the addition of eight (8) support attachments to the building structure. The modification was completed with no record addressing the above aspects of design interface.

2. Modification DCR No. 2EC-02236 of pipe support No. 2C-23RHG-13 involved the addition of support attachment to the containment floor at elevation 77' - 11". The design package for the modification was performed according to Procedure GM8-EMP-009'" Design Change Control".

Above aspects of design interface were not addressed in the procedure or implemented in the modification package.

This is a Severity Level V violation (Supplement I) applicable to DPR-70 and DPR-75.

0FFICIAL RECORD COPY CIR SALEM 87 0002.0.0 02/20/87 0703030680 870225 PDR ADOCK 05000272 G PDR

. Public Service Electric and Gas Co. 2 B. Criterion V of 10 CFR 50, Appendix 8 requires that activities affecting quality be prescribed by, and accomplished in accordance with, documented instructions and procedures of a type appropriate to the circumstances.

It also requires these instructions and procedures to include appropriate quantitative or qualitative acceptance criteria.

PSE&G's procedure VPN-QAP-01 " Operational Quality Assurance Program" reiterates, in section 7.5, the above requirements of 10 CFR 50 regarding the establishment of written and approved procedures in the performance of Q-listed activities.

Contrary to the above, piping and pipe support design activities were not performed in accordance with the above requirements in that:

1. Documented and approved criteria for the performance of piping stress analysis were not established.

2. Specification No. S-C-MB00-MDS-043 for " Design of Pipe Supports" required the checking of pipe supports displacements and rotations under applied loads without providing acceptance criteria for the evaluation of these parameters.

This is a Severity Level V Violation (Supplement I) applicable to DPR-70 and DPR-75. -

C. Criterion VI of 10 CFR 50, Appendix B requires the establishment of measures to control the issuance of documents such as instructions and procedures including changes thereto, which prescribe all activities affecting quality, and to assure that these documents are reviewed for adequacy and approved by authorized personnel. PSE&G's procedure VPN-QAP-01 " Operational Quality Assurance Program" reiterates, in section 7.6, the above requirements of 10 CFR 50 regarding the establishment and maintenance of a document control system for all instructions and procedures in the Nuclear Department. Contrary to the above, instructions governing the following design elements in the area of piping and pipe supports were not controlled or maintained in accordance with the above stated requirements.

1. The PSE&G mechanical standard for determining load capacities of rectangular U-bolts, referenced in section 10.1 of the criteria for design of pipe supports, was uncontrolled.

2. Evaluation of local stresses in piping walls at locations of integral attachments was described in section 10.4 of the criteria for design of pipe supports using ASME code cases No. N-392 and N-318-1.

However, the evaluation of local stresses in piping at locations of U-bolt components was described in, and performed using, another document which was uncontrolled.

This is a Severity Level V Violation (Supplement I) applicable to DPR-70 and QPR-75.

0FFICIAL RECORD COPY CIR SALEM 87 0002.1.0 02/20/87

. Public Service-Electric and Gas Co. 3 Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted 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 violations; and (3) the date when. full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

OFFICIAL RECORD COPY CIR SALEM 87 0002.2.0 02/20/87