ML20204G066

Notice of Violation from Insp on 830103-0302

ML20204G066
Person / Time
Site:	Kewaunee
Issue date:	04/11/1983
From:	Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204G051	List: IR 05000305/1983001 ML20204G047 ML20204G066
References
50-305-83-01, 50-305-83-1, NUDOCS 8305020352
Download: ML20204G066 (3)

Text

'

Appendix A NOTICE OF VIOLATION Wisconsin Public Service Corporation Docket No. 50-305

\

As a result of the inspection conducted during the period of January 1 -

March 2, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified.

1. Technical Specification 6.8.1 states, " Written procedures and admin-istrative policies shall be established, implemented and maintained that meet the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972". ANSI N18.7-1972, Section 5.1.2, states, in part, " Procedures shall be followed...." ANSI N18.7-1972, Section 5.1.5, states, in part, " Procedures shall be provided for control of equipment as necessary, to maintain reactor and personnel safety and to avoid unathorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status."

Preventative Maintenance Procedure, PMP 40-107, "480 V Supply and Distribution Supply Breaker Maintenance for Component Cooling Pumps",

Section 3.2 states, in part, "For the unit to be isolated, have Operations place the following items in the indicated position and tag". Section 3.2 further indicates, if the unit to be controlled is the supply breaker for component cooling pump 1A, the control switch on Mechanical Control Console A shall be placed and tagged in the PULLOUT position and the circuit breaker tagged in the open position.

Administrative Control Directive 4.3, "Tagout Control" Section 3.0 states, in part, " Danger Cards shall be used to protect equipment or to warn of unusual or dangerous conditions".

Contrary to the above procedures were not followed in that:

l l

l e. . On February 16, 1983, authorization was granted and actions taken to remove component cooling water pump 1A from service, and to perform preventative maintenance without tagging as

required by the licensee's procedures.

l l b. On November 15, 1982, an instrument, which when connected to l its sensing line is considered an extension of the containment, l was disconnected and the instrument isolation valves were shut, but were neither tagged nor locked.

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

8305020352 830411 PDR ADOCK 05000305 j G PM

e Appendix 2

2. Technical Specification Section 6.8.1, states, " Written procedures and administrative policies shall be established, implemented and

, maintained that meet the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972". ANSI N18.7-1972, Section 5.1.2, states, in part, " Procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing. Rules shall be established that provide methods by which temporary changes to approved procedures can be made, including the designation of a person or persons authorized to approve such changes". Administrative Control Directive

5.2, " Maintenance Procedures", Section 5.6, states, in part, " Prior to implementation, the Temporary [ change to] Maintenance Procedure shall be reviewed and initialed by two members of plant management staff, at least one of which holds a Senior Reactor Operator's License. All Temporary [ changes to) Maintenance Procedures shall be reviewed by PORC and approved by the Plant Manager".

Contrary to the above, during the period of April 22-27, 1982, temporary changes were made by plant electricians to maintenance procedure 5B-18469 " Rewire TD AFW pump to S/G 1B MV per DCR-1039" and these changes were neither initialed nor reviewed and approved as required by Administrative Control Directive 5.2.

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

3. 10 CFR 50, Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to *he circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. The licensee's Operational Quality Assurance Program Description dated January 20, 1978, states, in part, "The program complies with the provisions of ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants". ANSI N18.7-1976, Section 5.2.7, states, in part, l " Maintenance of modifications which may affect functioning of safety-related structures, systems or components shall be performed in a manner to ensure quality at least equivalent to that specified

, in original design bases and requirements, material specifications l and inspection requirements". Administrative Control Directive 3.2 i

" Materials Request" states, in part, "The requesting supervisor or person, for each part, component, or material need, will mark the request with the QA Type 1, 2, or 3 from the Bill of Materials report, informational retrieval list or the QC Supervisor."

l I

Appendix A 3 Contrary to the above, Material Request No. 82-2966, dated April 12, 1982, requested QA type 2 fitting for use on QA Type 1 components and

, the QA Type 1 requirement was clearly indicated on Maintenance Work Request No. 19261.

This is a Severity Leve1IV violation (Supplement I).

.4. 10.CFR 50, Appendix B, Criterion VII, states, in part, " Measures shall be established to assure that purchased material and equipment, conform to the procurement documents. Documentary evidence that material and equipment conform to the procurement requirements shall be available at the nuclear power plant prior to installation or use of such material and equipment". Operational Quality Assurance Program Description dated January 20, 1978, states, in part, "The program complies with the provisions of ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants". ANSI N18.7-1976, Section 5.2.13.2, states, in part, "Where required by code, regulation, or contract requirements, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items".

Contrary to the above, QA Type 1 items, ordered by Purchase Order Fo. 51565, were issued, installed, and used in a QA Type 1 component without documentary evidence that the items conformed to the procure-ment requirements. The licensee did not perform a receipt inspection /

test on the items which were received on May 11, 1982, as required by Purchase Order No. 51565.

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 state-ment or explanation in reply, including for each item of noncompliance:

(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved. Consideration may be given to extending your response time for good cause shown.

l APR 11 1983 gi.3a A Dated J. F. Streeter, Chief l

Projects Branch 2 I

,