ML20042B188
| ML20042B188 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/19/1974 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B187 | List: |
| References | |
| 50-247-74-16-01, 50-247-74-16-1, NUDOCS 8203250065 | |
| Download: ML20042B188 (4) | |
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ENCLOSURE DESCRIPTION OF VIOLATIONS Consolidated Edison Company of New York, Inc.
4 Irving Place Neu York, New York 10003 Dochet 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.
10 CFR 50, Appendix B, Criterion XVIII requires, in part:
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program," and "....Follou-up action, including reaudit of deficient areas, shall be taken where indicated."
10 CFR 50, Appendix B, Criterion NVI requires, in part:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective caterial and equipment, and non-confor=ances are promptly identified and corrected."
QA-7320 Concolidated F41r/
Audit Program for Operational Nucient Facilitics, 2
Revision 0 dated 10/24/73 states in section 5.3.2 Audit Conduct, item c:
"Implementatien of procedures by the station shall be cudited in sufficient depth to determine conpliance or delineate non conform 2nce" and in section 5.5 Follow-up, that:
"Re-audits shall be scheduled as necesst.ry to insure that corrective measures have been effected or remedial action initiated."
Contrary to the above, the following were noted:
a) The non-conformance item identified as item A.c.4 of the Operational l
Audit of Indian Point Unit Nos. 1 and 2 for the last quarter of 1973 was found to be unresolved one year after identified.
No remedial l
action had been initiated, l
b) The re-audit failed to verify compliance with an aspect of the quality assurance program in that several cards in the instrucent history file failed to conform with the requirements of attachment 2 of PE-AD-8, " Calibration and Control of Measuring and Test l
Equipment."
8203250065 741219 PDR ADOCK 05000003 G
s o-2.
Technical Specificatien 6.8.1 states in part:
" Detailed written procedures covering the arcas listed below,..., shall be prepared, approved as specified in section 6.8.2, and adhered to:
- f. Surveillance and testing requirenents of the nuclear facility."
Technical Specification 6.8.2 states in part: "All written procedures required by 6.8.1, and any changes to them shall be reviewed and approved for inplesentation in accordance with written administative control pro-cedures...."
The adminictrative control procedure required by this specification shall, as a ninitum, clearly establish the criteria which will govarn when pre-implecentation review by the Station Nuclear Safety Committoc and the nuclear Facilities Safety Committee is required."
Station Administrative Order 102, 5/23/74, Procedure / Procedure Change Approval Policy" states in part:
"If a procedure /precedure change does involve safety related cccponents and or operation of same a pre-implementation rev'icu by the SUSC is required..."
Contrary to the above, 19 of a sample of 25 surveillance procedures involving safety related components required by Technical Specification to be periodically perforned were not revieued by the SNSC.
3.
10 CFR 50, Appendix B, Critorion V, requires in part:
" Activities affecting quality shall be prescribed by documented instructions, pro-
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cedures, or drawings...and shall be accomplished in accordance with these instructions, procedures or drauings."
f Contrary to the above, the following verc noted:
I a)
Procedure SAO-117, " Calibration and Centrol of "easuring Tools, Gages, and Test Equi; cont for use en Class "A" Nucicar Systems" requires in part:
"b*henever an iten is beyond the required calibration due date, a red tag vill be affixed indicating that it cannot be used until it has been calibrated." Red tags were not affixed to test gages IC-47, IC-48, IC-49, IC-63, IC-120, IC-132, IC-150 and IC-157, which were beyond the calibration date.
b)
SAO-117 requires in part:
"Each Sub-Section is responsible for maintaining a list of equipment under their control.
The list will contain, as a minimum, the follouing:
- 1. Identification number, unique Indian Point Station assign =cnt (assigned by Sub-Section in-volved)."
The Chemistry Sub-Section list of instruments did not have the required identification numbers.
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c)
QA-AD-11, " Calibration and Control of Measuring Tools, Cages and 4
Test Equipment for Use on Class "A" Component" requires (under 2.0.
B Master List) in part:
"QA is responsible for maintaining a list of equipment under its control.
The list must contain, as a minimum, the follouing:
.. 4. Calibration frequency, activity, date calibrated and cethed."
The Master List currently being maintained does not contain the re-quired date calibrated.
Certain activities under your license appear to be in violation of AEC requirements.
These apparent violations are considered to be of Category III severity.
4.
10 CFR 50, Appendix B, Criterion VII, states in part:
Measures shall be established to assure that purchased material... conform to the procurement documents.
Thes'e measures shall include provisions, as appropriate.... examination of products upon delivery."
Contrary to the above, no activity exists to assure the cceeptability of the delivered or stored number 2 fuel oil procured for the Emergency Diesel Generators.
5.
10 CFR 50, Appendix B, Criterion V, requires in part:
" Activities affecting quality shall be prescribed by documented instructions, pro-cedures or drawings of a type appropriate to the circu= stances and shall be in accordance with these instructions, procedures..."
Contrary to the above, the following were noted:
a)
The required quarterly summary of abnormal occurrences by procedure t
l SAO-124, " Reporting of Anomalous Conditions" was not available and apparently had not been written.
l b) Procedure 2AD-9, " Conduct of Operation" states in part:
" charts -
all charts to be maintained as follows:
- 1. --- 2.
--- 3.
Pens checked for proper inking at least once per watch." Two different (2) pen recorders were not inking on one pen each for periods beyond one watch period.
6.
10 CFR 50, Appendix B, Criterion VI, requires, in part:
" Measures shall l
be established to control the issuance of documents, such as instructions, procedurcs, and drawings, including changes thereto, which prescribe all activitics affecting quality.
These measures shall assure that documents, including changes, arc reviewed for adequacy and approved for release by authoriacd personnel and are distributed to and used at the location where the prescribed activity is perforued."
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Contrary to the above, the folletting was noted:
Procedure Q/,-AD-11, " Calibration and Control of IIeasuring Tools, Gages and Test Equipment for Use on Class "A" Components" fails to include i
all of the minir.un requirements (accuracy to which it can be used) of the controlling procedure SAO-117.
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