ML20024F275
| ML20024F275 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/25/1983 |
| From: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024F267 | List: |
| References | |
| 50-374-83-18, NUDOCS 8309090165 | |
| Download: ML20024F275 (3) | |
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Appendix NOTICE OF VIOLATION j
Commonwealth Edison Company Docket No. 50-374 As a result of the inspection on June 29 through August 5, 1983, and in accordance with the ERC Enforcement Policy 47FR9987 (March 9, 1982), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion V, " Instruction, Procedures and Drawings", states in part, " 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 these instructions, procedures or drawings."
a.
The following are examples of failure to follow procedures:
(1) Sargent and Lundy (S&L) Specification Drawing IE-0-3333, Revision C, Note 5, states in part, " Minimum separation between redundant divisional conduits is 3'-0" horizontal and 5'-0" vertical except at crossings where the vertical separation may be 12" "
Contrary to the above, Engineered Safety Features (ESF)
Division 1 Conduit 2JB117C was not separated by the minimum distance and was in contact with ESF Division 2 Conduit 2JB114C.
(2) Note 9 on S&L Drawing IE-0-3070 requires each cable to be affixed with a color coded tag to identify its association with the respective ESF Division.
Contrary to the above, the inspectors observed associated ESF Division II Cables 2NB683 and 2CT018 were incorrectly identified' with yellow tags with white stripes (instead of a blue t'ag with white stripes) indicating that they belonged to' associated ESF Division 1 cables, in raiser R-385 inside the' primary containment.
(3) Notes 6, 7, 8, 9 and 10 on S&L Drawing IE-0-3070 requires each ESF Division junction box to be identified with a color coded label.
Contrary to the above, at approximate elevation 745' inside the containment, the inspectors observed that cable junction box 2JB058C was incorrectly identified as belonging to ESF Division II instead of ESF Division I.
(4) Morrison Construction Company, the mechanical instrumen-tation installation contractor, in Work Instruction Wl-19 Revision 0, dated January 1982, requires all safety-related 8309090165 830825 gDRADOCK 05000374 PDR
Appendix 2
j instrument lines to be identified with color code tapes to indicate their' association with their respective ESF Division or Reactor Protection System channel. Contrary to the above, the inspectors observed several instrument lines to instrument panels 2H22-P004, 2H22-P005, 2H22-P006 and 2H22-P022 identified with the incorrect Reactor Protection System segregation code.
b.
The following is an example of failure to establish a procedure.
S&L Specification Drawing 1E-0-3333 specifies the minimum separation distances to be maintained between the ESF Division I and ESF Divi-sion II raceways but does not specify the minimum separation distance to be maintained between cables after they exit raceways inside the containment.
i As 6 tesult,.the inspectors observed the following at approximate elevation 783' ins 3de the primary containment:
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c (1) ESFDivision12able2NB11wasincontactwithESFDivision2 Cable 2NB12.
(2) ESF Divisio:t 1 Cable 2NB894 was in contact with ESF Division 2
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Cable 2NB896...
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(3) ESF Division 1 Cable 2NB917 was in contact with ESF Division 2
~ Cab 1c-2NB418.
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(4) ESF Division 1 Cable 2NB911 was in contact with ESF Division 2
' Cable ~2NB912.
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This is a Severity Level V. violation (Supplement II).
m 2.
'10 CFR 50, Apperdix B, "driterion VI, states in part, " Measures shall be established to control the issuance of documents, such as instructions, procedures and drawings, including changes thereto, which prescribe
~ ll activities affecting quality. These chaages shall assure that a
documents, including. change, are reviewed for adequacy...and are
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distributed to and used at-the-locstion where the prescribed activity is performed."
' Commonwealth Edison Topical Report No. CE 1-A, Revision 11,Section VI, states in part, "A document control system will be -used to assure that documents such as specifications...and drawings are reviewed for adequacy....
A!so,;this system includes as-built drawings and provisions to assure as-built drawings are kept updated, properly maintained, and a
controlled.
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. Contrary to the above, S&L as-built Drawings 1E-2-4000EC, Revision C, dated 2/12/81, and.1E-2-4000FB, Revision E, dated 1/28/83, had not been
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I h updated'th reflect tine correct information pertaining to MCC panel 221 Y and D.C. distribution panels 211 Y and 211 K.
Consequently, the above drawinggccntained numerous errors involving the actual breaker ratings for the individual cubicles.
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'This ~is 'a Severity Level V violation- (Supplement li).
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- 3. : IG LTIS, AppEddir/ B, Criiterion XVII, states in part, "Suf ficient records shall be ma.intained to' furnish evidence of activities affecting quality. The recordt shall includelat least the following:
...the results of reviews, inipections, tests,' audits... inspection and test records shall, as a minimum, identify...the type of observation, the results,'the acceptability, and the action taken in connection with o,
any deficiencies noted."-.
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Commonwealth Edison Topical Report No. CEl-A, Revision 2,Section XVII,
/y s 3 states in part, " Fabrication and Construction docurnentation is generated i'
A by contractors,...for Commonwealth Edison Company and will be available at Me construction site.... Records generated during site construction, i
A-y tes M g...will be available at the Station. Files shall be maintained g
'u current, complete and available for audit...."
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im 1~ Contra'ry Jo the above,' no documente'd evidence existed to indicate s
that insulation resistance tests were performed on replacement modules h
in electrical penetcations as required by the n~inufacturer (CONAX) in Section 7.0 of their Instruction Manual IPS-1064.
CONAX replacement j
modules had already,been installed and the conductors terminated in four Bunker-Rimo ' penetrations. The manufacturer requires that all the con-ductors n the replacement; modules be tested for insulation resistance prior to termina' tion. Thq licensee stated that the conductors in the penetrations lhad been tested; however,' no documented evidence exists to suggest thattthe required insulation resistance tests were performed.
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x This is~a Severity Level V violation, t
"" Pursuant to the provisions of 10 CFR 2.201,.you are required to submit to this office within thirty days of the date of4 this Notice a written statement nb
, or explanation in reply, including for each iten of noncompliance:
(1) cor-lective action taken and the results achie'ved; (2) corrective action to be
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\\g taken to avoid further noncompliance; and (3) the date when full compliance
.i s N will be achievedc Consideration may be given to extending your response time
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Ifor go6d cause shewn.
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-Cated { LG B 3 V. S./ Lit %Ie, Chief
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Engineering Branch 2
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