ML20028B269
| ML20028B269 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/12/1982 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028B265 | List: |
| References | |
| 50-454-82-19, 50-455-82-14, NUDOCS 8211300225 | |
| Download: ML20028B269 (4) | |
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i Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 Docket No. 50-455 As a result of the inspection conducted on September 16-17, 1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:
1.
10 CFR Appendix B, Criterion III, states in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis...as specified in the license application, for those structures and components to which this appendix applies are correctly translated into specifications.... These measures shall include that appropriate quality standards are specified and that deviations from such standards are controlled."
Criterion III further states that, " Measures shall be established for the identification and control of design interfaces and for coordina-tion among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release...of documents involving design interfaces."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for NucleTr Generating Stations, Revision 15, Section 3.1, dated January 2,.381, states in part "... designs and materials will conform to... standards, regulatory requirements, SAR commitments, and appropriate quality standards as applicable."
Topical Report CE-1-A further states, "... design evaluations or reviews are conducted to written standards and include consideration of quality standards, quality assurance requirements,... interface control...as appropriate."
Contrary to the above, the following instances of inadequate design control were identified:
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F Appendix 2
a.
The FSAR in Paragraph 8.3.1.4.2.1 commits compliance to IEEE 384-1974 which states in Section 4.6.1 that "Non-Class 1E circuits shall be separated from Class IE circuits by the minimum requirements 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 circuits. As of September 22, 1982, safety related raceways were in direct contact with non-safety related raceway in three locations two of which occurred in the Auxiliary Building and one in the upper Cable Spreading Room.
In addition, in three other instances the spacing between Class 1E and Non-Class 1E cable trays was less than the one inch minimum as specified in IEEE 384-1974 and Section 8.3.1.4.2.2.C of the FSAR.
b.
The inspector observed that safety related cable raceway Section 12031C CIE and the cables inside the tray were supporting a section of an HVAC duct.
It appeared that the HVAC duct was braced against the insides of the Class IE tray. Although, the raceway and the HVAC duct were installed independently to the correct elevations as specified per their respective drawings, it appeared that inadequate design interface control and design review caused the nonconforming condition.
'lhe inspector observed the following circumstances:
(1) There is no assurance that Class 1E cables have not been damaged as a consequence of the pressure applied by the duct and brace against the cables.
(2) Class 1E raceway Drawing 6E-0-30720, Revision L, had not specified that cable tray Section 12031C CIE was to support the HVAC duct.
(3) The HVAC duct was apparently supported by a Class 1E tray without an engineering analysis being performed.
(4) As of September 22, 1982, the condition had not been identified and consequently no discrepency report issued.
(5) The licensee had not identified the apparent conflict among design organizations in placing the tray and duct within the same space coordinates.
This is a Severity Level IV violation (Supplement II).
Appendix 3
i 2.
10 CFR Appendix B, Criterion X, states in part, "A program for in-spections of activities affecting quality shall be established and executed...to verify conformance with documented instructions, procedures...for accomplishing the activity."
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 20, Section 10, states in part, " Quality assurance inspections...will be conducted...during construction...to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality."
Hatfield Electric Company Procedure No. 10, Revision 15, dated July 27, 1982, Section 5.1.34, states in part, "If a cable cannot be physically routed according to the routing shown on the cable pull card or if routing tolerances of Drawing 6E-0-3000A are exceeded,... cable instal-lation will stop and the owner or S&L will be notified."
Contrary to the above, routing tolerances were exceeded for three of the nine cables the inspector reviewed.
In each of the three instances QC inspectors failed to identify and correct routing discrepancies that exceeded the tolerances of specification Drawing 6E-0-3000A.
As a result, QC inspectors signed off the inspection reports, although the routing of these cables were not in accordance with the cable pull cards. This is exemplified by the mis-installation of cables:
IVA156, IVE034 and 25X345.
This is a Severity Leve1IV 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, such as...
deficiencies, deviations...and noncompliance are promptly identified and corrected."
Commonwealth Edison Company Topical Report No. CE 1-A, Revision 15, states in part, "A corrective action system will be used to assure that such items as... deviations...and nonconformances which are adverse to quality and might affect the safe operation of a nuclear operating station are promptly identified and corrected."
Contrary to the above, the inspector observed four Class 1E cables and two associated cables within six inches from the top of Non-class 1E tray with associated cable 1MS148 in actual contact with non-safety cables. Hatfield Electric Company Procedure No. 10 requires that separation of Class 1E and Non-class 1E cables be not less than twelve inches in free air.
Additionally, in the licensee's response to item of noncompliance 81-16-01 and 81-12-01 for Byron Units 1 and 2 respectively,
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Appendix 4
the licensee made a commitment that all cable separation problems for Unit 1 be identified and a log established by March 1982, and for Unit 2 by June 1982. However, the licensee could not provide documented evidence that the nonconforming condition had been previously ident2fied.
This is a Severity Leve1IV violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written state-ment 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. Consideration may he given to extending your response time for good cause shown.
NOV 121982
" original signed by C.E. Morelius" Dated C. E. Norelius, Director Division of Engineering and Technical Programs