ML20042B104
| ML20042B104 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/03/1974 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B103 | List: |
| References | |
| 50-247-73-19, NUDOCS 8203240576 | |
| Download: ML20042B104 (2) | |
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ENCLOSURE DESCRIPTION OF VIOLATIONS Consolidated Edison Company 4 Irving Place New York, New York 10003 Docket No. 50-247 License No. DPR-26 Certain activities under your license appear to be in violation of AEC requirements.
These apparent violations are considered to be of Category II severity.
1.
The following items associated with the Instrument Air System Modification were found to be contrary to 10 CFR 50, Appendix B and Corporate Instruction CI-240-1, Quality Assurance Program for Operating Nuclear Plants:
a.
Appendix B, Criterion II states, in part, "This program shall be documented by written policies, procedures or instructions and shall be carried out...".
CI-240-1,Section VI, Paragraph 3.2 states, in part, "This identification (of weld joints) will be accomplished in accordance with procedures approved by the Mechanical Engineering Department".
Contrary to the above, the Quality Assurance (QA) package (Revision 1) for this modification was found lacking approved identification procedures.
b.
Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials, parts and components including partially-fabricated assemblies...".
CI-240-1,Section VI, Paragraph 3.3 states, in part, "The Mechanical Engineering Department is responsible for preparation of weld joint -isometric drawings including a weld joint numbering system for all piping...".
Contrary to the above, the QA package for this modification 1
did not contain isoretric drawings.
c.
Appendix B, Criterion VI states, in part, " Measures shall be established to control the issuance of documents such as instructions, procedures, and drawings including changes th e re to... ".
CI-240-1,Section VI, Paragraph 3.3 s tates, in part, "A Weld Authorization Form (WAF) (Exhibit 10, including a unique weld joint identification number, shall be issued by the Mechanical Engineering Department for each weld on the isometric drawing.
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, I Contrary to the above, the QA package for this modification' did not contain one WAF for each weld. A memorandum dated September 11, 1973 from Director, QA to Station Mechanical Engineering presents an interpretation of CI-240-1,.
Paragraph 3.3 allowing for use of one WAF. The memorandum lacks control as stated in Appendix B, Criterion VI.
2.
Technical Specification 1.7, " Containment Integrity", states, in part, that, "At least one door in each pers nn l air lock is o e properly closed". Technical Specification 3.6 requires containment integrity (as defined in Specification 1.7) to be maintained at all times except when the reactor is in the cold shutdown condition.
Technical Specification 1.2.1 " Cold Shutdcwn Condition", states in part that; "The reactor is subcritical by at least 1% delta k/k and Tavg is - 140 F.
Technical Specification 6.8.1 states, in part,
.. procedures covering the areas lis ted below, including applicable checkoff lis ts and instructions, shall be prepared and approved in Section 6.8.2, and adhered to:
Section 6.8.1.c s tates, in part, " Actions to be taken in response to potential malfunctions of sys tems, or components...".
Contrary to the above, on September 13, 1973 both doors of the 80 foot level personngl air lock were in an open position with the reactor Tavg 140 F.
Also, documentation of inspection of personnel airlock doors was not found in the Watch Foreman's Log, for September 11, 1973 entry,, as required by UO2-10, Revision 1, October 3, 1973.
It is requested that the cause of this violation be stated in your response.
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