ML20032D655
| ML20032D655 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/06/1981 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20032D653 | List: |
| References | |
| 50-373-81-28, NUDOCS 8111170359 | |
| Download: ML20032D655 (4) | |
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Appendix A NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-373 As a result of the inspection coudncted on August 11, 12, 17-21, 25-28, September 1-4, 8-11, 15-18, and October 8, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the follow-ing violations were identified-1.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type approrriate to the circumstances.
10 CFR 50, Appendix B, Criterioa XI, requires that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requireeents and acceptance limits contained in applicable design documents.
It also requires that test results be documented and evaluated to assure that test requirements have been satisfied. The QA Manual, Quality Require-ment 11.0, Section 11.3 requires that test results be evaluated following each test to assure conformance with design and performance requirements.
a.
Contrary to the above, the licensee failed to incorporate applicable design requirements into two preoperational tests:
(1) The licensee wrote a test procedure, approved it, performed the test, and reviewed and approved the test results of PT-SC-101 which did not include testing of the air sparging subsystem to ensure that it would promote adequate mixing of the sodium pentaborate solution, as required by FSAR Table 14.2-54, Test Procedure Item #5 and Acceptance Criteria #7.
In addition the licensee failed to write a deficiency noting the above, as required by LSU 200-2, to ensure that the FSAR commitment would be complied with prior to fuel load.
(2) The licensee wrote a test procedure, approved it, performed the test, and reviewed and approved the test results 01 SD-PS-101 which did not include verifying that all sensors in the process sampling system are properly 1ccated in accordance with the design, as required by FSAR Table 14.2-71, Test Procedure item #4.
b.
Contrary to the above, the licensee failed to properly evaluate test results to assure that test requirements had been satisfied:
8111170359 811106 PDR ADOCK 05000373 G
Appendix A (1) The licensee performed, reviewed, and approved the results of PT-NB-101, Nuclear Soiler System, including a second review by the station nuclear engineering departcent (SNED),
all of which failed to note a potential safety system degradation through an apparent malfunction of the system's associated trip switches.
(2) The licensee performed, reviewed and appiuved the results of PT-AP-102 without identifying the fact that:
(a) During the service test of the 250 volt battery, step 10.3, B.2.C was not complied with in that the temperatute of every cell was not taken and recorded.
(b) During the performance of the 24 volt batteries accep-tance tests, step 10.3.G.2.g, and other similar steps, were not complied with in that the cell voltages for the three hour and 15 minute interval were not taken and recorded.
(3) The licensee evaluated, reviewed, and approved test PT-VP-101 which contained incorrect torque switch settings for four motor operated valves.
This is a Severity Level IV violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion III, requires that measures be established to assure that applicable regulatory requirements and the design basis, as defined in Paragraph 50.2 and as specified in the licensee application, for those structures, systems, and compo-nents to which Appendix B is applicable, are correctly translated into specifications, drawings, procedures and instructions. The QA Manual, Quality Requirement 3.0, Section 3.1 states that, "The extent of the design review and evaluation of the original designs and modifications will be determined by the complexity of the system and any safety-related function to be performed by that system.
Design evaluation of modifications will be commensurate with those applied to the original design. Review and evaluation by the Architect Engineer, the Nuclear Steam Supply System vendor, and/or the Project Engineering or the Station Nuclear Engineering Department, as wall as by other CECO organizations, and specially qualified people, such as Level III's for NDE and for concrete inspection and tests, will assure that designs, specifications and procedures will cor. form to the ASME and other applicable codes, standards, regulatory require-ments, SAR commitments and appropriate quality standards, as appli-cable."
Contrary to the above:
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'q iggI-Appendix A Modified sections of pipe in the IB and 2B diesel generators starting air, cooling water and fuel oil systems had not been designed and built to meet ASME Section III-1974 as stated in FSAR Table 3.2-1.
This is a Severity Level IV violation (Supplement II).
3.
10 CFR 50, Appendix B, Criterion VIII requires that measures shall assure that identification of the item is raaintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation, and use of the item. The QA Manual, Quality Requirement 8.0, Section 8.1 requires that the unique identificatien assigned to materials, parts, and components, including partially fabricated subassesbiies, will be documented and maintained by the respective vendors, contractors or organizations having respon-sibility for the items invo hed throughout fabrication, installation or erection and use of the ite. and be verified as to being terrect prior to release for fabrication, assembling, shipping or installation.
Contrary to the above, the as-built construction isometric drawings under the control of the piping contractor did not maintain correct traceability for five items in the standby liquid control system; and, one item in the drywell pneumatic system was found to have two heat numbers identifying it.
This is a Severity Level VI violation (Supplement II).
4.
Criterion XVII requires that sufficient records be maintained to furnish evidence of activities affecting quality. Criterion IX requires that special processes, including welding and nondestructive testing be accomplished by qualified personnel using qualified pro-cedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements. The QA Manual, Quality Requirement 9.0, Section 1.0, states in part, that "For some pro-cesses, the required level of quality defined in ASME Code and other applicable codes, standards and specifications cannot be assured by inspection of the item alone. For these processes, quality assurance is cbtained through reliance on personnel qualification and procedural contro) in force as appropriate for the processes being employed for a specific task in connection with plant contract work, maintenance repairs and modifications. The Edison Site Quality Assurance Super-intendent or designee and the Quality Assurance Engineer or Inspector at the operating station is responsible for assuring that records of qualified personnel are maintained by the contractor for work performed for Edison.
Contrary to the above, " temporary" brackets were welded to, and re-moved from the primary liner by the licensee subcontractors without instructions, procedures or drawings authorizing their installation.
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Appendix A, N0y g
No records exist to demonstrate that the welding, removal and NDE verification of the liner following removal were done by (1) qualified personnel, (2) in accordance with approved procedures and drawings and (3) with proper authorization to conduct the work.
This is a Severity Level IV violation (Supplement II).
5.
10 CFR 50, Appendix B, Criterion VI, requires measures to be estab-lished to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. The QA Manual, Quality Requirement 6.0, Section 6.1 requires that changes to controlled documents 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. Also that each document recipient is revonsible for insuring that only the latest authorized documents are in use and the void documents are so identi-'
fied. Section 6.4 states that, the Project Engineering, Project Engineer has the responsibility to establish document control pro-cedures and methods during design, construction, preoperational and start-up testing. Th.e plant modifications is to provide that docu-ments are reviewed for adequacy anu are approved by authorized per-sonnel for issuance s.nd use at locations where the prescribed activity will be performed before-the activity is started.
Contrary to the above, the licensee did not establish adequate measures to control the use of the " Motor Operator Data" Book as_ evidenced by the i
i fact that the book was not annotated for at least four months as being lacorrect for three valves found during the performance of PT-VP-202.
Additionally, the book was not updated for at least four months to account for six valves (3 in Unit I and 3 in Unit 2) which were missing.
This is a Severity Level VI violation (Supplement II).
Pursuant to the provisions cf 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:
E (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
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Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.
1 T:QV~
> '%f Dated C. E. Norelius, DiTestor Division of Engineeritg and Technical Inspection
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