ML19323H893
| ML19323H893 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/18/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19323H890 | List: |
| References | |
| 50-454-80-05, 50-454-80-5, 50-455-80-05, 50-455-80-5, NUDOCS 8006170213 | |
| Download: ML19323H893 (3) | |
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Appendix A NOTICE OF VIOLATION Commonwealth Edison Docket No. 50-454 Company Docket No. 50-455 Based on the inspection conducted on March 25-26, 1980, it appears that certain of your activities were in noncompliance with NRC requirements, as noted below.
These items are infractions, and apply to both Units 1 and 2.
1.
10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed in documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 5 that "The quality assurance actions carried.
out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, spe-cifications, or checklists. These documents will assist personnel in assuring that important activities have been performed. These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out."
Contrary to the above, the procedures established for installing safety related hangers and snubbers did not satisfy the above pro-gram in that manufacturer's installation requirements were not fully incorporated.
2.
10 CFR 50, Appendix B, Criterion X, states, in part, that "A program for inspection of cctivities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activities."
Commonwealth Edison Company Topical Report CE-1-A " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 10 that "QA inspection...will be conducted...
at the site during construction...to verify conformance to applicable drawings, instructions...to verify quality".
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O Appendix A-2-
Contrary to the above, many installed hangers and snubbers had not 4
been QC inspected. The inspection program did not include sufficient requirements-in the areas of verification of piping suspension system location, configuration, and condition, and did not require timely inspections to ensure prompt corrective action.
3.
10 CFR 50, Appendix B, Criterion VI, states, in part, that " Measures shall be established to control the issuance of documents... including the changes thereto, which prescribe all activities affecting quality.
These measures shall assure.that documents, including changes, are reviewed...and approved...by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 6, that "A document control system will be used to assure that documents such as specifications, procedures, and drawings are reviewed for adequacy and app:,ved for realease by authorized personnel. Such documents will be distributed to and used at the locations where the prescribed activity is performed.
ChangesEto these documents will be handled similarly and will be reviewed and approved by the same organization that performed the original review and approval, unless delegated by the originating organization to another responsible organization."
Contrary to the above, the contractor used inter-office memorandum to document procedure change and as a result bypassed the established document control procedures.
i 4.
10 CFR 50, Appendix B, Criterion III, states, in part, that " measures 4
shall be established to assure that applicable... design basis...for those structures, systems, and components...are correctly translated into... drawings..."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 3 that "The fundamental vehicle for design control involves multi-level review and/or evaluation of design 4
documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures. The design documents include, but are not limited to, system flow diagrams, design and construction specifications, load capacity data sheets, design reports, equipment specifications, process drawings."
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Appendix A Contrary to the above, design details shown on several installation drawings did not meet the manufacturer's design perimeters, and questionable adjustment requirements were specified.
5.
10 CFR 50, Appendix B, Criterion XII, states, in part, that " Measures shall be established to control the... preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration".
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generatirag Stations", Revision 9, dated July 16, 1979, states in Section 13 that " Written instructions for handling, preservatice, storage and shipping will be used to specify special protective conditions necessary to prevent damage or deterioration of materials and equipment".
Contrary to the above, several installed mechanical snubbers had not been properly protected and as a result hardware was damaged.
6.
10 CFR 50, Apsendix B, Criterion XVIII, states, in part, that "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 18, that " Audits will be performed by Common-wealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cogizance."
Contrary to the above, the licensee had not performed comprehensive audits on the site hanger contractor to ensure program adequacy for the installation and inspection of the pipe suspension systems.
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