ML17199G492
| ML17199G492 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/23/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199G471 | List: |
| References | |
| EA-87-026, EA-87-26, NUDOCS 8704280603 | |
| Download: ML17199G492 (8) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Commonwealth Edison Company Dresden Nuclear Power Station Units 2 and 3 Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 EA 87-26 NRC inspections conducted during the period December 2-6 and 16-20, 1985, January 6-11 and 13, 1986; May 19-23, 1986; and April 21 through May 7, June 9-13 and July 7-16, 1986, identified violations of NRC requirements.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:
A.
10 CFR Part 50, Appendix B, Criterion XVI, requires measures to be established to assure that conditions adverse to quality and nonconfor-mances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
B.
Contrary to the above, measures did not assure that corrective action was taken to preclude repetition of a design error identified on Dresden Unit 2 from being implemented in Unit 3.
For modifications M12-3-84-27 and M12-3-84-28 (Replacement of Solenoid Valves which Operate the Torus to Reactor Building Vacuum Breakers), procedures and drawings were in error and resulted in the air lines being reversed during the installation.
This error may have prevented the proper functioning of the valves.
The error was identified and corrected during the modification on Unit 2.
- However, with regard to Unit 3, as of April 21 - May 7, 1986, the dates of the 1nspect1on, the design documents were not corrected and the air lines were reversed.
(50-249/86012 - Deficiencies 2.2-10 and 2.5-6).
10 CFR Part 50, Appendix B, Criterion III, requires in part that measures be established to assure that appropriate quality standards are specified and included in design documents, and that deviations from such standards are controlled.
Measures shall be established for the identification and control of design interfaces and coordination among participating design organizations.
Design control measures shall provide for verifying and checking the adequacy of the design.
Design changes, including field changes are subject to design control measures commensurate with those applied to the original design.
Contrary to the above, measures were not established to assure that appropriate quality standards were specified and included in design documents, coordination was conducted between organization, adequacy of designs were properly verified, and design changes were subject to control measures commensurate with those applied to the original design in that:
APR 2 3 1987
- 1.
For Modification Ml2-3-84-42 (High Pressure Coolant Injection Pipe Whip Restraints), shims were added in the design to the bottom 180 degrees of the inside diameter of the restraint sleeve.
This design did not recognize the increased interference between the pipe and restraint creating unanalyzed loads on each during thermal expansion.
(50-249/86012 - Deficiency 2.2.-2)
- 2.
For Modification Ml2-3-84-8 (HGA Relay Replacement), design changes were recorded on drawings rather than by processing the required design chang~ documents.
This resulted in the actual installation not conforming to the latest wiring diagrams.
Handwritten notes on drawings caused changes to connection points, addition of jumpers, invoking of a different drawing revision, and provided options if an earlier modification had not yet been completed.
(50-249/86012 -
Deficiency 2.2-4)
- 3.
For Work Requests (WR) 39291 and 39292 (Replace Operator Mounting Bolts, Install Anti-Rotation Bars, Alter Operating Times and Inspect Seats on Valves 3-1601-20A and 208), unreviewed and undocumented design changes were made and lack of coordination between participating design organizations led to the following:
- a.
Mechanical Maintenance Department (MMD) while attempting to add orifices in the exhaust ports of the solenoid operated valves which operate the vacuum breaker valves was not aware that Electrical Maintenance Department was replacing the solenoids operated valves.
The addition of orifices would not work on the new valves and would not comply with vendor req*Jirements for placement of orifices.
- b.
Stroke times for vacuum breaker valves was specified as 2U seconds maximum in the Drc~dcn Operating SurvaillinCi tiit procidurQ (DOS) 1600-1, "Quarterly Valve Timing."
WRs 39291 and 39292 specified a stroke time of 10-25 seconds after the solenoid operated valves were fitted with orifices.
There was no indication that the original design basis was reviewerl for the modification.
- c.
The Mechanical Maintenance Department determined that actuation failures experienced in the past (sheared bonnet bolts caused by slamming the valve closed) could be minimized in the future with the addition of 11anti-rotation 11 stop blocks and stronger fasteners.
There were no drawing revisions or other formal engineering reviews or documentation of either the "anti-rotation" blocks or fastener modifications to assure that the modifications as completed were acceptable and that future work on the valves would comply with the latest design and material requirements.
(50-249/86012 - Deficiency 2.2-11 and 2.5-7)
APR 2 3 1987 C.
10 CFR 50.59 states that a licensee may make changes in the facility as described in the FSAR without prior Commission approval unless the proposed change involves a change in the technical specifications or an unreviewed safety question.
Further, records shall be maintained which include a written safety evaluation which provides the bases for determining that the change does not involve an unreviewed safety question.
Contrary to the above, the licensee made the following changes in the facility without prior Commission approval and did not perform a documented review and safety evaluation which would provide the basis for determining that these changes did not involve unreviewed safety questions:
- 1.
Lead Shielding was placed on safety-related piping without design controls or a safety evaluation.
Had a seismic event occurred, possible overstressing of piping or components could have occurred due to unanalyzed loading or possible damage to other safety-related equipment could have occurred because of shifting or falling shielding.
(50-249/86012 - Deficiency 2.2-1)
- 2.
The as-built, accepted penetrations for Modification M12-2/3-85-34 (Reactor Building Hose Penetration) did not conform to the original Sargent and Lundy design requirements thereby negating the original 10 CFR 50.59 safety evaluation and a new safety evaluation was not performed.
(50-249/86012 - Deficiency 2.2-8)
D.
10 CFR Part SO, Appendix B, Criterion V, requires activities affecting quality to be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings, and that these instructions, proce-dures, and drawings shall include appropriate acceptance criteria.
Contrary to the above, activities affecting quality were not prescribed or conducted in accordance with documented instructions, procedures, or drawings, and appropriate acceptance criteria was not included in that:
- 1.
The licensee did not have an approved procedure for selecting over-lo2d protection fur motor operated valves (MDV).
Although the Station Electrical Engineering Department did use a draft procedure for setting A.C. overloads it was used only to review MOVs when requested by Station Nuclear.
There was no procedure for selecting overload pro-tection for D.C. motor operated valves.
(50-249/86009 - Deficiency 05.3-1)
- 2.
Work packages, including seven different modification packages, a special procedure, a work request and an AE specification, contained inadequate acceptance criteria for inspection and testing modifications for running current, insulation resistance and rotation tests; recorder calibration linearity; turns to back seat valves; seismic requirements; as-found location, inspection requirements or clearances for pipe whip restraints; slopes of instrument lines and drain lines; repair manual requirements and material selection for replacement parts.
(50-249/86012 - Deficiency 2.4-1)
APR 2 3 1987
- 3.
QA or QC hold points were not specified for Modification Ml2-3-83-37 which relates to calibration and hydrostatic testing; Modification Ml2-3-83-40 which relates to splices made in environmentally qualified equipment; and Modifications Ml2-3-84-49 and 50 for repairs made to power leads on environmentally qualified Low Pressure Coolant Injection room cooler motors.
Dresden Administrative Procedure (OAP) 15-1 requires hold points for each of these activities.
(50-249/86012 -
Deficiency 2.4-6)
- 4.
Dresden Administrative Procedure 15-1, 11Work Requests~" did not adequately address revisions of work requests for work in progress in the areas of management review, 10 CFR 50.59 review, QA/QC involvement and work scope changes.
Further, the Total Job Management (TJM) manual (referenced in OAP 15-1) referenced out of date work request forms.
(50-249/86012 - Deficiency 2.4-10)
- 5.
For Modification Ml2-3-83-40 (IEB 79-01 Instrumentation Replacement),
safety-related cables were bundled with non safety-related cables in Panels 2203-73A and 2203-738.
Note 2 on Drawings 12E7860, Revision E and Drawing 12E7861, Revision E required non safety wiring to be in conduit or have six inches of separation from safety-related wiring.
(50-249/86012 - Deficiency 2.5-1)
- 6.
Modification Packages Ml2-3-84-27 and 28, Ml2-3-83-40, Ml2-3-84-49 and 50, and Ml2-3-84-9 contained examples of cable splices that were not made in accordance with documented instructions including severe bend radius, braided jacket extending under the splice insulation, damage to splice sleeve including exposed bare conductors, sleeves shorter than required length, kinked wires and damaged insulation.
(50-249/86012 - Deficiency 2.5-3)
- 7.
For Modification M12-3-84-8 (HGA Relay Replacement) the Low Pressure Coolant Injection (LPCI)/Core Spray (CS) relay wiring was not con-nected strictly in accordance with the wiring diagram.
The wiring, as installed, was electrically equivalent due to a jumper.
(50-249/86012 - Deficiency 2.5-4)
- 8.
For Modification M12-2-84-14 (CCSW Pump Room Cooler Piping Modification Unit 2) installation was not in accordance with as-built or design documentation in that fiber gaskets were installed instead of specified Flexitallic gaskets, 150 psi flanges were installed instead of specified 300 psi flanges, dimensions did not match as-built drawing, and piping, valve and cooler designators were incorrectly intermixed.
In addition, work instructions were not followed in that work was accomplished which replaced CCSW piping and components and which was outside the scope of the modification.
(50-249/86012 - Deficiency 2.4-11 and 2.5-8)
E.
10 CFR Part 50, Appendix B, Criterion VI, requires that measures be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes which prescribe all activities
APR 2 3 1987 F.
affecting quality and that these measures assure that documents including changes are reviewed for adequacy and approved for release by authorized personnel.
Contrary to the above, the licensee's document control measures for activities affecting quality were not adequately implemented in that numerous documents did not reflect proper control or assurance that documents, including changes, were not sufficiently reviewed for adequacy and consequently did not reflect the condition of the plant.
For example:
- 1.
Drawings and other work package documents for Modification Packages M12-3-84-14 (Unit 3) and M12-2-84-14 (Unit 2) were inaccurate regarding Containment Cooling Service Water (CCSW) Pump Room Cooler piping modi-fications in that design drawings specified 150 psi reversing valves and adjacent flanges; however, the architect engineer specification specified 300 psi valves and flanges.
Piping and Instrumentation Diagram (P&ID), M-360, showed flow elements and temperature indicators as actually installed; however, the piping drawings and field instal-lation did not contain these elements.
Also, line and cooler designa-tors were in error, the drawings did not specify an orientation for the reversing valves, and there was no documentation of source and QA acceptance of the eight installed 300 psi flanges.
(50-249/86012 -
Deficiency 2.3-4)
- 2.
On May 21, 1986, several individual discrepancies existed between the configuration shown on the designated electrical drawing and what actually existed in the field.
These discrepancies included several examples of wires shown on drawings, but not found installed in the field, two conductors attached to a terminal where the drawing showed only one, a wire connected to a terminal point which was different than that shown on the drawing, use of a 11Critical Drawing 11 revision in the Control Room different than the designated as-built revision, and an incorrect status for drawings in the Records Retention Vault.
(50-237/86015; 50-249/86017 Paragraph 4.a.(1) and 4.a.(2)-(8))
10 CFR Part 50, Appendix B, Criterion XI, requires in part that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test proce-dures.
Test results shall be documented and evaluated to assure that test requirements have been satisfied.
Contrary to the above, the licensee's test program failed to identify and document all testing necessary to demonstrate that systems and components will perform satisfactorily in-service or to assure that tests were performed in accordance with written test procedures in that:
APR 2 3 1987
- 1.
In several instances there were no requirements for documentation of
-test completion, test acceptability, or temporary changes to test requirements.
As a result, test failures or deviations were not properly documented.
This included:
two relay failures during Core Spray Logic and LPCI/CCSW logic testing, failure of LPCI pump discharge pressure to meet acceptance criteria, use of equipment other than that required by the procedure, failure of a computer point position indication for a Reactor Water Cleanup Valve and performance of testing with initial conditions other than those req~ired by the test.
(50-249/86012 - Deficiency 2.7-3; 2.8-1; 2.8-2; 2.8-4; and 2.8-5)
- 2.
Undervoltage and ECCS integrated functional tests were inadequate in the areas of performance and test changes in that changes were made to procedures without the appropriate test change request (TCR) and its associated documentation of review and approval.
Procedures did not specify the restoration position for switches and breakers for the reactor cleanup recirculation Pump 38.
Breakers were found out of position despite signed verification to the contrary.
In addition, test steps were repeatedly missed without reviewing the test and at-tempting to re-establish conditions.
(50-249/86012 - Deficiency 2.8-7 and 2.8-8)
G.
10 CFR Part 50, Appendix 8, Criterion II requires that the licensee carry out a quality assurance program and shall identify the structures, systems, and components to be covered by the quality assurance program and the major organizations participating in the program.
The quality assurance program shall provide control over activities affecting the quality of the identified strurt11rP5, systPms, ~nd ~nmpnnPnts, tn ~n PXtPnt rnnsistPnt with their importance to safety.
Contrary to the above, the licensee and its contractors did not provide adequate control over activities affecting quality of identified structures, systems, and components with their importance to safety in that the Master Equipment List for Dresden Unit 3, dated September 1, 1985, incorrectly classified (as non safety-related) the actuator motors for the steam supply valve to the High Pressure Coolant Injection (HPCI) turbine, two HPCI pump suction valves, the HPCI pump cooling leakage water return line valves, and the motors for the pumps which provide service water to the containment cooling heat exchanger in the Low Pressure Coolant Injection (LPCI) System.
(50-249/86009 - Deficiency 04.3-2)
Collectively, these violations have been evaluated as a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $25,000 (assessed equally amoung the violations).
1*
APR 2 3 1987 Pursuant to the prov1s1ons of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the U.S Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, and a copy to the NRC Resident Inspector, Dresden Nuclear Power Station, within 30 days of the date of this Notice.
This reply should be clearly marked as a 11 Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) th~ corrective step that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken may be issued.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201 Commonwealth Edison Company may pay the civil penalty by letter addressed to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555 with a check, draft, or money order payable to the Treasurer of the United States in the amount of Twenty-Five Thousand Dollars ($25,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555.
Should Commonwealth Edison Company fail to answer within the same time specified, an order imposing the civil penalty in the amount proposed above will be issued.
Should Common-wealth [di!on Company !l!ct to fil~.an A1Hw12r in dLLur'ud!ILI::! with 10 CFR 2.205 protesting the civil penalty, such answer should be clearly marked as an "Answer to a Notice of Violation" ~nd mav; (l) d~ny th~ violation~ li~tPrl in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1987) should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g. citing page and paragraph numbers) to avoid repetition.
Commonwealth Edison Company's attention is directed to the other provisions of 10 CFR 2.250, regarding the procedure for imposing a civil penalty.
./.
APR 2 3 1987 Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
Dated At Glen Ellyn, Illinois this il~day of April 1987.
FOR THE NUCLEAR REGULATORY COMMISSION A. Bert Davis Regional Administrator