ML20040F571
| ML20040F571 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/28/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20040F565 | List: |
| References | |
| 50-295-81-28, 50-304-81-26, NUDOCS 8202090355 | |
| Download: ML20040F571 (2) | |
Text
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Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-295 Docket No. 50-304 As a result of the inspection conducted on July 31, December 1-2, 8, and 21, 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 III, states, in part, that " measures shall be established to assure that applicable...
design basis...
for those structures, systems, and components are correctly trans-lated into...
drawings...".
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 15, dated January 2, 1981, states in Section 3, "The fundamental vehicle for design control involved multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures. Also, procedures are established to assure that verified computer codes are certified for use and that their use is specified.", and "These design evaluations or reviews are conducted to written procedures and include considerati;n of quality standards, quality assurance requirements, materials suitability, process suitability, interface control and suitability of analytical or testing requirements as appropriate."
Contrary to the above, relative to the slotted seismic restraints installed in many safety related small and large bore piping systems, there were apparent lack of original design basis and justification.
The ASME technical publications provided for the inspector's review showed inconclusive effects due to the mechanical snubber gaps much smaller than what were observed at the site. Evaluation for the systems that contained large amounts of the slotted restraints to ensure the actual stress levels are all within the committed code allowables was not conducted by the licensee.
This is a Severity Level V violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed in documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 15, dated F202090355 820128 PDR ADOCK 05000295 C
t Appendix January 2,_1981, states in Section 5 that "The quality assurance actions
' carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists. These documents will assist personnel in assuring that.important activities have been performed. These docu-ments will also reference applicable acceptance criteria which must be satisfied-to assure that the quality related activity has been-properly carried out."
SWEC-NY Procedure ZPP-1, " Pipe Stress and Support Evaluation",
Revision 8, dated July 27, 1981, where Paragraph 4.2.2.3, stated, in part, that "In accordance with construction specification, clamp bolts for skewed snubbers have to be tightened with a specific torque so that a sufficient friction force is developed to assure no slippage between the clamp and the pipe."
Contrary to the above, the torquing requirements on pipe clamp bolts developed by S&L to assure no slippage between the clamp and the pipe were not properly adopted in the site work procedure.
In fact, the
- subject matter relative to the torquing of-pipe clamp bolts in com-pensation of the lack of shear lugs observed at various piping systems to prevent pipe clamp slippage where axial loading exists during adverse conditions had not been reflected in any work implementation procedures.
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 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. Under the authority of Section 182 of the Atomic 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.
Dated C. E. Norelius, Director Division of Engineering and Technical Inspection
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