ML20039E982
| ML20039E982 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/05/1982 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20039E980 | List: |
| References | |
| 50-456-81-14, 50-457-81-14, NUDOCS 8201110686 | |
| Download: ML20039E982 (4) | |
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Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on November 18-20, 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 VII, states in part, " Measures shall be established to assure that purchased... equipment... conform to the procurement documents. These measures shall include provi-sions, as appropriate, for... inspection at the contractor or subcon-tractor source, and examination of products upon delivery."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations," Revision 15, states in Section 7, that "The control of the quality of purchased material, equipment and services is achieved through the evaluation of vendors, surveillance of their operations and required source inspection, documentation, receiving inspection..."
Contrary to the above, separation barriers between adjacent redundant indicatErs in main control board panels IPM04J and 2PM04J were not installed during their manufacture as required by Westinghouse Speci-fication 952538, Revision 1.
This is a Severity Level VI violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion VI, states in part, " Measures shall be established to control the issuance of documents... including changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are... distributed to and used at the location where the prescribed a:tivity is performed."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assur-ance Program for Nuclear Generating Stations," Revision 15, states in Section 6, that "a document control system will be used to assure that documents such as specifications, procedures...are reviewed for adequacy...
Such documents will be distributed to and used at the locations where the prescribed activity is performed.
Changes to these documents will be handled similarly..."
r-hO
Appendix Contrary to the above, the revision to Sargent and Lundy Specifica-tion 2790A, which changed the specified terminal lugs to be used on Class IE electrical terminations, was not translated into t
L. n. Comstock " Cable Termination Installation" Procedure No. 4.3.9.
As a result, unapproved terminal lugs were stored in Class IE storage facilities and L. K. Comstock electricians were being l
instructed to use these unapproved lugs on Class IE terminations.
I This is a Severity Level VI violation (Supplement II).
3.
10 CFR 50, Appendix B, Criterion XVI states in part, that " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected...the identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
Commonwealth Edison Company Topical Report CE-1*A, " Quality Assurance Program for Nuclear Generating Stations," Revision 15, Section 16 1
requires that, items such an " deficiencies, deviations, defective i
material and equipment and nonconformances which are adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected."
Contrary to the above, the following nonconforming conditions were either (1) not promptly identified or (2) not properly corrected:
Two stressing gauges were found to be out of the required a.
accuracy range and were sent out for recalibration. However, corrective action was not taken to identify and correct any potential deficiency caused by the use of the nonconforaing gauges.
b.
The specified disposition of NSCI NRC No. 137 did not address the nonconformance re ort subject (i.e. failure to follow the specified tendon stressing sequence).
Seventeen tendons were installed for more than 180 days without c.
being greased. This condition was not in accordance with Sargent and Lundy (S&L) Specification L-2722 requirements and was not identified as nonconforming.
This is a Severity Level IV violation (Supplement II).
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Appendix 4.
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 crganization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.... " Examinations, measurements, or tests of material or products processed shall be performed for each work operation to assure quality."
Commonwealth Edison Company Quality Assurance Program for Nuclear Generating Stations, Topical Report CE-1-A, Revision 15, Section 10, Inspection, states in part, page 10-2 "The applicable Edison site Quality Assurance Superintendent or Designee or Station Quality Assurance Engineer or Inspector will assure that required inspection of purchased items as required and determined by engineering is carried out, that inspection procedures, instructions or checklists specify the necessary measuring and test equipment including accuracy requirements, that contractor test procedures approved by Edison or the Architect Engineer are judiciously implemented and that procure-ment requirements are being fulfilled."..." The plan for each inspec-tion will also identify, for example, the parameters to be checked, accept / reject criteria, equipment needed for the inspection or con-tractor documentation to be reviewed;" page 10-3 "In process and final inspections and tests will be used to assure conformance to design requirements for fabrication and construction work."
" Written pro-cedures or checklists will be used to specify and verify final in-spections and tests,"..." inspection and test records will provide objective evidence that inspections and tests were performed in compliauce with instructions and procedures to verify design and code requirements."
S&L Specification L-2722, Revision 14, " Injection of Corrosion Preventive Grease," Section 13-508.2, states in part, "In addition, each tendon which is not stressed within 90 days after it is in-stalled in its sheathing, shall be greased within that 90 day period.
... Time from initial placement of the tendons to greasing may be increased to 180 days, provided a Random Sample of 10% of the tendons are withdrawn monthly between the 90 and 180 day period and inspected for corrosion. Tendons which show signs of corrosion during the 90 to 180 day period shall be rejected."
Contrary to the above the inspector found that Unit I tendons had been installed f~or over 90 days without being greased, and that inspection and test records did not provide objective evidence that inspection and tests were performed as required by the refer-enced inspection specification. Furthermore, an inspection instruction / procedure had not been prepared for the required inspections, addressing the requirements of Specification L-2722.
Appendix This is a Severity Level V 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 statement or explanation in reply, including for cach item of noncompli-(1) corrective action taken and the results achieved; (2) correc-ance:
tive action to be taken to avoid further noncompliance; and (3) the date I
when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as arended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.
,,...- -. > 5.. c.2. l'o r @5" p....er.,
Dated C. E. Norelius, Director l
f Division of Engineering and Technical Inspection i
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