ML19325D346

Notice of Violation from Insp on 890710-21.Violation Noted: Failure to Provide Measures for Controlling Drawings to Preclude Possible Use of Outdated Drawings

ML19325D346
Person / Time
Site:	Millstone
Issue date:	10/11/1989
From:	Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19325D344	List: ML19325D343 ML19325D346 ML19325D348
References
50-336-89-13, NUDOCS 8910230118
Download: ML19325D346 (4)

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f APPENDIX A i

NOTICE OF VIOLATION l

Northeast Utilities Service Company Docket No. 50-336 Millstone Nuclear Power Station, Unit 2 License No. DPR-65 I

As the result of an allegation follow-up team inspection conducted on July 10-21, 1989 and in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Action, "10CFR 2, Appendix C, 53 Fed. Reg. 40019(1988), the following violations were identified:

A.

10 CFR 50, Appendix B, Criterion VII requires, in part, that measures be i

established to control the issuance of drawings and drawing changes for i

those activities affecting quality. These measures shall assure that i

drawings,and drawing changes are properly reviewed and approved and are i

distributed to and used at the location where the prescribed activity is 1

performed.

Northeast Utilities Quality Assurance Program (NUGAP) Topical Report, Revision II, dated May 18, 1988, Section 6.0, Dooment Control, requires that measures be provided for controlling drawings to preclude the possi-i bility of the use of outdated drawings.

UP-QA-3.03, Document Control, Revision 3?, dated June 29, 1988, Section 5.9 requires that department heads ensure that work under their cognizance is performed in accordance with the lates revisions of controlled documents; 4

and Section 6.2.1.2 requires that personnel using drawings for QA activities are responsible to ensure that they have the latest revision of the drawing.

f Contrary to the above, on or before July 21, 1989, measures had not been i

established to assure that the latest revisions to drawings affecting quality were distributed to or used in the Millstone Unit 2 Instrument and Control (I&C) Shop.

It was determined that most drawings in the.I&C shop which were routinely used by technicians including those maintained instru-ment loop folders, circuit diagram books, drawing stick files, and general i

file drawers were not controlled and often were not the latest revision.

The following drawings are examples of outdated versions found during the inspection:

j Revision In Latest Revision in Drawing No. and Title I&C Shop Nuclear Records

--E-18767-411-302, 6

9 Trip Unit Interconnection Module Wiring Diagram i

--E-18767-411-011, 4

5 Reactor Protective System Pin Assemblies Wiring Diagram 1

0FFICIAL RECORD COPY IR MILLSTONE ALLEG 89 0001.0.0 8910230118 891011 10/10/89 PDR ADOCK 05000336 Q

PDC

APPENDIX A 2

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--E-18767-411-033, 5

7 Reactor Protective System Fundamental Diagram i

This is a Severity Level IV Violation (Supplement I)

B.

Technical Specification (T.S.) 6.8.1 requires that procedures shall be established, implemented, and maintained covering applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, February,1978.

J T.S. 6.8.2 requires that each procedure and changes thereto shall be reviewed by the Plant Operations Review Committee (PORC) and approved by

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the Unit Superintendent.

T.S. 6.8.3 allows temporary changes to procedures i

to be made without prior PORC review and Unit Superintendent approval, provided the intent of a procedure is not altered, j

Contrary to the above, on or before July 21, 1989, it was identified that certain procedures could not, in part, be performed as written; however, they were performed without getting appropriate changes.

Further, a change was made to an in progress refueling activity procedure, Procedure No, j

IC 2419A, which changed the intent of the procedure and no documented change was made to the procedure nor was prior PORC review and Unit 2 Euperintendent approval obtained.

(1) Three examples of inadequately established, implemented and maintained procedures are given below.

Further examples are stated in the attached inspection report.

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--IC 2422G, Local Area Radiation Monitors Calibration, Model GA 2TM0 i

(a) Step 5.2.3, which functionally checks local alarms, fails to check the general control room alarm for the radiation monitors on console CO 6/7.

(b) Paragraph 5.2.4, which checks the alarm detectors, does not clearly state what the actual source fields are.

(c) Paragraph 5.4, which does the isotopic calibration does not specify the geometry for the calibration source.

(d) Paragraph 5.4.7.1, which is a contingency step, requires a bench test using the remote meter. However, the remote meter, i

by procedure, has not been removed from its panel and is not i

installed in the test circuit.

(e) Paragraph 5.4.14 removes the detector probe and CRM module from the test box and reinstalls the CRM module into the system.

l The step fails to specify reinstalling the detector.

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APPENDIX A 3

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--SP 2401J, Thermal Margin / Low 5 essure Calibration Test Steps, 7.2.4 and 7.2.5 requires obtaining the latest revision of SP 2401J and associated data sheets from a computer data diskette and entering it l

on to data sheet 240!J-2. Until this procedure was changed in December 1988 there was no place on the data sheet to make this entry. This procedure was performed monthly during Srsptember, j

October and November 1988 without any change being ma.ie to the procedure.

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--SP 2403A, E.S. A.S. Bistable Trip and Automatic Inserter Test, Revision 8.

In five places in this procedure, steps are reversed in that the first step calls for releasing the applicable test switch and the next step requires recording the data.

In actuality, the j

data must be recorded before the test switch is released. This procedure was performed at least five times before a procedure change was put in place to correct the error.

l (2) During refueling, operations conducted between 8 PM February 21, 1989 and 4 AM February 22, 1989, removal of incore instruments (ICI) was performed per IC 2419A, ICI Replacement Installation Procedure, Revision 8.

ICI's were removed entirely using the refueling floor l

polar crane rather than by an electric winch attached to the polar crane as required by the procedure.

This was an intent change to the procedure which was not documented nor was PORC review or Unit Superintendent approval obtained.

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

C.

Technical Specification 3/4.3.3, " Monitoring Instrumentation", requires,

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in Table 4.3-3, that a monthly channel functional test be performed for l

the " Spent Fuel Storage Criticality Monitor and Ventilation System Isolation". The Channel Functional Test is defined in Section 1.11, as the injection of a simulated signal into the channel as close to the r

primary sensor as practicable to verify operability including alarm and/or trip functions.

Contrary to the above, Surveillance Procedure SP 2404AN, " Spent Fuel Pool Area Radiation Monitor Functional Test", Revision 0, dated February 6,1986, does not include steps to verify operability of the local area alarm as required.

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

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D.

10CFR 50 Appendix B, Criterion III, " Design Control" states in part

" measure shall be established to assure that applicable regulatory requirements and the design basis, as defined in paragraph 50.2... for

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the structure, systems and components to which this appendix applies are correctly translated into specifications, drawings, procedures and instructions..."

l 0FFICIAL RECORD COPY IR MILLSTONE ALLEG 89 0001.0.2 i

10/10/89 l

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i APPENDIX A 4

Contrary to the above, on July 20, 1989, the inspector identified that seismic qualification of the conduit for Reactor Coolant Pumps "C" and "D" underspeed sensors was not specified in the pump motor modification packages and the seismic qualification was not established.

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

E.

Technical Specification 6.2.2.g requires that working hour limits of those persons performing safety-related functions follow the general guidance of the NRC Policy Statement (Generic Letter 82-12).

Generic Letter 82-12, Nuclear Power Plant Staff Working Hours, states, in part, "... the following guidance shall be followed:

...an individual should not be permitted to work more than.. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period...nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period... A break of at least eight hours should be allowed between work periods..." Further, it requires that under unusual circumstances any deviations from the foregoing guidelines shall be authorized by the plant manager or higher levels of management.

Contrary to the above, during the period January 30 through April 13, 1989:

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An Instrumentation and Control supervisor exceeded the limitations for working more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, less than an 8 l

hour break between work assignments and did not receive prior plant l

manager approval on multiple occasions.

2)

Multiple examples of Maintenance and Instrumentation and Control technicians working more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in overlapping 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> periods without plant manager approval.

3)

Multiple exameles of technicians working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without plant manager approval before the fact.

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

Pursuant to the provisions of 10CFR 2.201, Northeast Utilities Service Company l

is hereby required to submit a written statement or explanation to the U.S. Nuclear l

Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region I, and a copy to the NRC Senior l

Resident Inspector within 30 days of the date of the letter transmitting this l

Notice. This reply should be clearly marked as a " Reply to a Notice of j

Violation" and should include for each violation:

(1) the reason for the violation if admitted, (2) corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, an

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i APPENDIX A S

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I order may be issued to show cause why the license should not be modified, j

suspended, or revoked or why such other action as may be proper should not be taken.

Considerations may be given to extending the response time for good cause shown.

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I FOR THE NUCLEAR REGULATORY COMMISSION' orJcinal sisned 3y.4 I

i Marvin W. Hodges, Director

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Division of Reactor Safety Dated at King of Prussia, Pennsylvania this ll*

day of October 1989

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