ML19347F702
| ML19347F702 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/16/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347F699 | List: |
| References | |
| 50-454-80-25, 50-455-80-23, NUDOCS 8105260072 | |
| Download: ML19347F702 (6) | |
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Appendix A' NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 Docket No'. 50-455 As a result cf the inspection conducted on December 15-23 and 31, 1980,.
January 9 and 12, and March 27, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980) the following violations were identified:
'1.
10 CFR 50 Appendix _B, Criterion II, states, in part, "The quality assurance program shall provide control over activities affecting the quality of... components...to an extent consistent with their importance to safety. Activities affecting quality shall be acco.nplished under suitably controlled conditions."
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 9, Section 2, states, in part, "The Quality Assurance Program takes into account the need for special control...to attain and maintain the.equired quality and the need for verification of quality by inspection and test."
Contrary to the above, cable entrance frames for seismic category 1 safety related equipment identified as IPA 03J were designed without engineering approval, built without an approved QA Program, and purt' lased and installed without QA approval.
It is recognized that the licensee's QA organization identified this matter. At the time of this inspection, this matter had not been adequately resolved.
This is a Severity Level IV violation (Supplement II).
2.
10 CFR 50 Appendix B, Criterion III, states, in part, "Dasures shall be established to assure that applicable regulatory requirements and.
the design basis, as defined in 50.2 and as specified in the license application...are correctly translated into specifications, drawings, procedures, and instructions."
Commonwealth Edison Company Quality Assurance
.ogram CE-1-A Topical Report, Revision 9, Section 3.1, states, in pa t, "... designs and materials will conform to... standards, regulatory requirements, SAR, commitn.cnts, and appropriate quality standards as applicable."
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' Appendix A
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' Contrary to the above:
a.-
.The FSAR in Paragraph 8.3.1.4.2.1 commits to compliance with
-IEEE~384-1974 which states in Section.<4.6.1 that."Non-Class IE. circuits ~shall be separated'from Class IE Circuits by.the minimum separation requirements.specified in Sections 5.1.3, 5.1.4, or 5.6 or'they become associated' circuits."- IEEE 384-1974 Section 4.5 identifies separation requirements ~for associated J
circuits.. As of December 23,?1980,-safety related cables were bundled with non-safety related cables at six, locations in the Lower Cable Spreading Room where cables exit : trays to enter panels installed directly above in the Control Room.
b.
The : commitment in PSAR Paragraph 7.1.2.b is, 'in part, " Redundant transmitter impulse lines will.be physically separated'at a--
minimum distance of eighteen in'ches^(18 in.) in any' direction."
As of December 23, 1980, this commitment had not been translated; into specifications, drawings,: procedures, and instructions.
This is a Severity Level IV violation--(Supplement.II).
3.-
10 CFR 50 Appendix B, Criterion XVI,' states, in part, " Measures shall be established to assure that conditions adverse to quality,Jsuch-as... deviations...and nonconformances_are promptly identified and corrected."
Commonwealth Edison Company Topical Report No. CE 1-A. Revision 9, Section 16, states, in part, "A corrective' action system will-be used~
to assure that such items as... deviations...and.nonconformances which are adverse to cuality and might affect the safe operation; of a nuclear generating station are prcmptiv identified and corrected."
Contrary to the above:
a.
As of December 23, 1980, measures were not established to assure that deviations from cable routing specifications were promptly l
identified and corrected. This is exemplified by the misinstal-lation of cable number IS1257.
b.
As of December 23, 1980, measures were not established to assure' that unacceptable welds were not present on installed cable tray stiffeners in that corrective action on NCR F-529 was limited to identifiel nonconforming welds andidid not require' inspection of additional welds on cable-tray stiffeners'to assess.the extent-l of the problem.
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Appendix A,
~As of. December'23,.1980, measureswere:notestablish[d-toassure c.
that deviations-from cable tray. filling specifications were a-
'promptly identified and corrected. -This islexemplified by cables l
.being'placed above the~ side rails'of Cable: Tray l12015C-CIE i.C thel 4
. Upper Cable Spreading Room.
This is a Severity.LeveliIV violation (Supplement II).
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- 4.
10 CIR 50 Appendix B,-Criterion V',' states,--in part,l" Activities:
affecting quality-shall be' prescribed by documented; instructions, procedures,. or drawings, of a: type: appropriate' to the circumstances and shall be' accomplished'in accordance with the~se instructions, J
procedures, or drawings."~
l Commonwealth Edison-Company Topical Report No. CE-1-A,' Revision'9, Section 5, states, in part,.."The. quality 1 assurance. actions carried-out for... construction... activities will-be. described'in documented M:
l instructions, procedures, drawings, specifications,'or. checklists.
These documents will assist personnel in assuring that.important-l activities have been performed."
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Contrary to the.above, documented instructions, procedures,' drawings.
specifications, or che'cklists for certain activities affecting quality j
were either not developed or implemented as follows:
j a.
.As of Decsmber 23, 1980, appropriate instructions, procedures', = >
-drawings, specifications, or checklists had not been developed for temporary storage of partially pulled cables in.that Hatfield--
j.
Electric Company (HEC) Procedure 10, " Class I Cable Installation,"
l Revision 4, Issue 1, dated August:5,.1980, recommended but did not require that care be exercised to assure that the bend radius
. criteria (Appendix D of HEC Procedure 10) were not exceeded. fAs-a result, five partially pulled cables were coiled such that the.
j bend radii of the inner turns were less than the minimum bend l
radii criteria.
b.
As of December 23, 1980, appropriate. instructions, procedures, j.
drawings,. specifications,~or che'cklists had not.been developed i
for cable pulling temperatures in that HEC Procedure 10 did not reflect cable manufacturers' recommendations regarding precon-ditioning (storage time and temperature) criteria for reels of cable stored outside during cold weather prior to pulling.
c.
Paragraph 8A of Sargent & Lundy (S&L) Standard EA-121 requires,:
in part, " Cable ends shall not be left unsealed.... Ends...shall' be... sealed...as promptly as possible af ter being pulled..."
On December 22, 1980, Cable ISIO42 which was not be'.ng pulled was not sealed on one end as required by EA-121.
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Appendix A d.
Paragraph 7.1.4 of S&L Standard EB-146 requires, in part,.
" Conduit bends shall be supported on each side of.the bend."
On December 22, 1980, Conduit IC2E at Cable Tray 11750J-C2E in the Lower Cable Spreading Room had no support between the tray
- t and the conduit bend as' required by EB-146.
Paragraph 302.2.b of S&L Specification F-2906 requires, in e.
Part, "After installation,.all instrument' sensing lines shall be identified with color coded metal. tags to denote system separation requirements." On December 23, 1980, several safety-related instrument lines were installed which were not identified-with color coded metal tags as_ required by F-2906. Additionally, the contractor's installation procedures did not include this requirement nor were the contreetor personnel aware of this requirement.
This is a Severity Level IV violation (Supplement II).
5.
10 CFR 50 Appendix B, Criterion X, states, in part, "A program for inspection of activities 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 activity."
Commonwealth Edison Company Topical Report No. CE-1A, Re' vision 9, Section 10, states, in part, " Quality Assurance inspection...will be conducted...during construction...to verify conformance' to applicable drawings, instructions, and procedures as necessary to' verify quality."
i Contrary to the above, the electrical contractors-QC inspections of cable pulling activities on March 7 and 21, 1980, failed to verify-conformance to Paragraph 2.1 of S&L-Standard EA-122 which states, in part. "Before pulling, the cable trays...shall be thoroughly inspected...Any sharp edges that might cause damage to cable sheaths or jackets during pulling operations shall be removed." Furthermore, these QC inspections did not verify the quality (i.e., acceptance /
rejection criteria for cable jacket damage) of pulled cables ISI211 and ICC005. As a result, the damaged conditions of the cables were not identified.
l This is a Severity Level V violation (Supplement II).
6.'
10 CFR 50, Appendix B, Criteria XV, states, in part, " Measures shall be established to control... parts, or components which do not conform-to requirements in order to prevent their inadvertent use or installa-tion. These measures shall include, as appropriate, procedures for identification..."
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Appendix A -
Commonwealth Edison' Company Topical Report No. CE-1-A, Revision'9, Section 14, states, in part, " Nonconforming material and equipment will be identified through the use of a Quality Assurance " Hold" tag...Such " Hold"... tags shall only be removed at the direction of
-Quality Assurance personnel."
Contrary to.the above, as of December 23,7 1980, measures established by the licensee to identify nonconforming' components did not assure the identification of nonconforming equipment as follows:
480 volt substation IAP98E and 4160V switchgear buses 141, 142, a.
241, and 242' identified in NCR F-580 to be in nonconformance.with IEEE 384-1974 cable separation criteria were not identified with
" Hold" tags and the switchgear buses were energized and.being operated for conducting construction tests.
b.
Electrical. penetrations which form part of the reactor contain-ment boundary identified in NCR F-562 as having been installed by a non-ASME stamp holder, and therefore, in violation of ASME Section III, were not identified with " Hold" tags.
c.
Main control board panels identified in NCR F-545 as having structural welds unacceptable to American Welding Society Code D1.1 were not identified with " Hold" tags and portions were. energized.
d.
Cables numbered IDC089 and IDC030 identified in NCR F-539 as having minimum bending radii less than the specified 18 inches were energized and were not identified with " Hold" tags.
e.
Welds on cable tray stiffeners identified in NCR F-529 as being unacceptable were not identified with " Hold" tags.
This is a Severity Level V violation (Supplement II).
7.
10 CFR 50 Appendix B, Criterion XIII, states, in part, " Measures shall be established to control the... preservation of... equipment in accordance with work and inspection instructions to prevent damage or deterioration."
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 9, Section 13, states, in part, " Written instruction for handling, preservation, 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, as of December 23, 1980, measures established by the licensee did not control the preservation of equipment to prevent damage or deterioration in that:
E a
Appendix A' '
a.
Paper cartons, paper,and other combustible material were in the Auxiliary Diesel Generator Cable Tunnel Room.
b.
Two scafiold supports were lying on cables inside Cable Tray 11455Q-C2E at elevation 432 in the Auxiliary Building.-
. c.
Loose nails were in Cable Tray 12030C-CIE in the Upper Cable Spreading Room, d.
A chisel was in Cable Tray 1920E-P2E in the Auxiliary Diesel Generator Cable Tunnel Room, Partially consumed weid rsds were in Cable Tray 11464Q-C2E'at e.
elevation 439 in the Auxiliary Building.
This is Severity Level VI violationJ(Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of.this Notice a written statement 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. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
AIIs 3 i 193)
Dated James G. Keppler, Director-t O
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