ML19310A547
| ML19310A547 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/09/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19310A540 | List: |
| References | |
| 50-373-80-15, NUDOCS 8006200136 | |
| Download: ML19310A547 (4) | |
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Appendix A NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-373 Based on the inspection conducted February 19-22, 26-29, March 4-7 and 19-22, 1980, it appears that certain of your activities were in noncom-pliance with NRC requirements as noted below.
Items 1, 2, and 3 are Infractions and Item 4 is a Deficiency.
1.
10 CFR Part 50, Appendix B, Criterion II requires in part, that activities affecting quality be accomplished under suitable con-trolled conditions, such as adequate cleanliness.
Criterion XIII requires, in part, that measures be established to control the storage and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterior-ation.
The Quality Assurance Program, Quality Requirement QR2.0, contains a Commonwealth Edison Company commitment to the regulatory positions of Regulatory Guide 1.38, Rev. 2, and Regulatory Guide 1.39, Rev. 2.
The regulatory positions of Regulatory Guides 1.38, Rev. 2 and 1.39, Rev. 2, endorses the requirements of ANSI N45.2.2-1972 and N45.2.3-1973 respectively. ANSI N45.2.2-1972, Section 6.2, states, in part, that, " Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas.
The storage areas shall be cleaned as required to avoid the accumulation of trash, discarded packaging materials and other detrimental soil...The use or storage of food, drinks...in any storage area shall not be permitted...
Periodic inspections shall be performed to assure that storage areas are being maintained." Section 6.5 states, in part, that, " Items released from storage and placed in their final locations within the power plant, shall be... cared for in accordance with the require-ments of Section 6 of this standard." ANSI N45.2.3-1973 requires in part that control of all tools, equipment, materials and supplies be maintained to prevent the inadvertent inclusion of deleterious materials or objects in critical systems.
Contrary to the above, the licensee does not have a program to maintain adequate cleanliness as evidenced by the following:
a.
On February 19 and 20, welding and grinding of overhead HVAC equipment was being conducted in the Control Room without adequate protection for the instruments below.
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Appendix A b.
During an inspection of the Control Room control panels on February 28 and March 6,'
1980, dust, grit, and other debris was found inside the cabinets containing electronic equipment for such systsms as the Building Unit Exhaust Monitor, Off-Gas Monitor, Radiation Recorders, Division I and 2 Leak Detection, Division 1 Diesel Generator, and TIP Machine Controls, c.
During plant tours on February 28 and March 6,1980, combust-ible material, discarded food, concrete block chips and grit, dust and other detrimental soil was found on 24V battery charg-ers IDC38E and 37E, 130V battery charger 2DC09E, control and relay cabinets for Diesel C-nerators IA, IB, and 0, and High Pressure Core Spray instrument rack H-22-P024.
d.
On March 4-5, 1980, difficulty was encountered in starting the 1A and IB recirculation pumps due to dirt in the incomplete sequence trip relay contacts.
e.
On March 22, 1980, a foreign substance high in chlorides, sulfur, copper, and tin was found inside the Unit I reactor vessel adhering to sections of the vessel wall, head, core support plate, and feedwater sparger inlet box. The material was apparently left inside the recirculation system or vessel internals prior to the performance of an integrated recircula-tion system-vessel internals testing at elevated temperature and pressure.
2.
10 CFR Part 50, Appendix B, Criterion V, states that, " Activities affecting quality shall be prescribed by documented instructions procedures, or drawings of a type appropriate to the circumstances...
Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Quality Requirement 11.0, Section 11.2, states that, " Written test procedures will be developed to demonstrate design and performance characteris-tics as specified in design and operating requirements. The proced-ure will include....the data to be obtained and requirements and acceptance limits to be fulfilled." Startup Manual procedure LSU 400-1, Section F.1, requires that preoperational test procedures include precautions needed for safety of equipment and that it contain acceptance criteria against which the success or failure of the test will be judged.
It also requires that these items be clearly described, highlighted or identified. Contrary to the above:
0 Appendix A a.
Revision 29 to test procedure PT-RR-101, dated February 18, 1980, which was issued to provide for the measurement of the time from turbine control valve fast closure signal to complete suppression of the electronic arc between the open contact of the recirculation pump motor circuit breaker, did not include acceptance criteria listed in design or licensing documents.
b.
Procedure PT-RR-101 did not contain any precautions, limitations or steps designed to protect the reactor vessel against thermal transients.
3.
10 CFR Part 50, Appendix B, Criterion XII, requires in part, that
" Measures shall be established to assure that tools, gauges, instru-ments and other measuring and testing devices used in activities affecting quality are properly... calibrated
...at specified periods to maintain accuracy within necessary limits." Quality Assurance Program Quality Requirement 12.0, Section 12.1, states that
" Measuring and test equipment which is used...to perform the preoper-ational testing... will be periodically calibrated or adjusted to assure that accuracy is maintained within necessary limits in order to verify design requirements."
The Quality Assurance Manual introduction contains a licensee commit-ment to comply with applicable Regulatory Guides as listed in the FSAR. Furthermore, the FSAR, page B.1-37, states that testing of instrumentation and electrical equipment is in accordance with ANSI N45.2.4 (1972) and IEEE 336-1971.
IEEE 336-1971, Section 2.5.2, states, in part, that " Measuring and test equipment used to determine compliance with specifications shall be adjusted and calibrated at prescribed intervals against certified equipment having known valid relationships to nationally recognized standards." Section 6.2.1 states, in part, that " Tests shall be performed to verify that the quality of installed equipment has not deteriorated during the construction phase" and that " Tests shall be made to assure that instrumentation and control channels are properly calibrated." IEEE Standard Dictionary of Electrical and Electronic Terms defines " calibrate" for nuclear stations as
" Adjustment of the system and the determination of system accuracy using one or more sources traceable to the NBS."
" System" is de-fined as "The entire assembled equipment excluding only the sample collecting pipe."
Contrary to the above:
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Appendix A
- a.
Calibrations of the entire instrument loop are not always performed prior to preoperational testing, as was the case for the recirculation loop suction temperature instrumentation and jet pump flow instrumentation.
b.
The licensee has no program for conducting periodic calibra-tions during the construction phase of the plant prior to the acceptance of a system for operation.
4.
10 CFR Part 50, Appendix B, Criterion XVII, requires in part, that
".. test records... identify... action taken in connection with any deficiencies noted." Appendix B of the FSAR, page B. 1-33, and the Quality Assurance Manual include a licensee commitment to comply with the requirements and guidelines of Regulatory Guide 1.28, which endorses ANSI N45.2.
Paragraph 18, " Quality Assurance Records," of ANSI N45.2 requires that sufficient recoros be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality.
Contrary to the above:
a.
The reactor vessel bottom head drain temperature thermocouple was known to be damaged as early as December 5,1979, but sufficient records were not generated until a Deficiency Report was written on December 19, 1979.
b.
The recirculation loops suction temperature instruments were known to bc giving inaccurate readings as early as February 4, 1980, but sufficient records were not generated entil a Deficiency Report was written on March 3, 1980.
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