ML20050C028
| ML20050C028 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/19/1974 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20050C026 | List: |
| References | |
| 50-247-74-16, NUDOCS 8204080031 | |
| Download: ML20050C028 (4) | |
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s ENCLOSURE DESCRIPIION OF VIOLATIONS Consetidated Edicon Company of New York, Inc.
4 IrvJng Place New York, New York 10003 Docket No. 50-247
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License No. DPR-26 Certain activitics 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, Critorion 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 "....Fo11ou-up action, including reaudit of deficient areas, shall be taken where indicated."
10 CFR 50, Appendix B, criterion XVI requires, in part:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviatione. defective material and equipment, and non-conformances are promptly identified and corrected."
QA-7320 Consolidated Edison Audit Program for Operational Nuclear Facilities,
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Revision 0 dated 10/24/73 states in section 5.3.2 Audit Conduct, item c:
"Impicmentation of procedures by the station shall be cudited in sufficient depth to dctormine compliance or delineate non conformance" and in section 5.5 Follow-up, that:
"Re-audits shall be scheduled as necesscry 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 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 action had been initiated.
i b)
The re-audit failed to verify compliance uith an aspect of the quality assurance program in that several cards in the instrument history file failed to conform with the requirements of attachment 2 of PE-AD-8, " Calibration and Control of Measuring and Test i
Equipment."
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8204080031 741219 PDR ADOCK 05000003 O
PDR i
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I 2.
Technical Specificatien 6.8.1 states in part:
" Detailed written procedures j
covering the areas listed below,..., shall be prepared, approved as-specified in section 6.8.2, and adhered to:
- f. Surveillance and testing require =ents of the nuclear facility."
Technical Specification 6.8.2 states in part:
"All written procedures l
required by 6.8.1, and any changes to thcm shall be reviewed and approved for inplenentation in accordance with written administative control pro-cedures...."
The adninictrative control procedure required by this specification shall, as a mininum, clearly establish the criteria which will govern when pre-implecentation review by the Station Nuclear Safety Committec and the Nuclear Facilities Safety Committee is required."
l Station Administrative Order 102, 5/23/74, Procedure /Precedure Change Approval Policy" states in part:
"If a procedure /precedure change does i
involva safety related cctponents and or operation of same a pre-implementation revicu by the SNSC is required..."
m 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, Criterion V, requires in part:
" Activities affecting quality shall be prescribed by documented instructions, pro-I cedures, or drawings...and shall be acco plished in acccrdance with these instructions, procedures or drawings."
e Contrary to the above, the following were noted:
I a)
Procedure SAO-117, " Calibration and Centrol of ':casuring Tools, Gages, f
and Test Equi; tent for use on Class "A" Nuclear Systems" requires in part:
"Whenever an iten is beyond the required calibration due date, a red tag uill be affixed indicating that it cannot be used until it l
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 J
maintaining a list of equirnent under their control. The Ifst will contain, as a ainimum, the following:
- 1. Identification number,-
unique Indian Point Station assignment (assigned by Sub-Section in-volved)."
The Chemistry Sub-Section list of instruments did not have the required identification nutbers, i
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c)
QA-AD-11, " Calibration and Control of Measuring Tools, Gages and 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 mi.ima:.,
the following:
.. 4. Calibratien frequency, activityr date ca_ brated and method."
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 j~
requirements.
These apparent violations are considered to be of Category III severity.
1 4.
10 CFR 50, Appendix B, Criterion VII, states in part: Measures shall-be established to assure that purchased material... conform to the procurement docu.nents. Thes'e measures shall include provisions, as appropriate.... examination of products upon delivery."
Contrary to the above, no activity exists to assure the ceceptability 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 j
affecting quality shn11 be prescribed by documented instructions, pro.
cedures or drawings of a type appropriate t-
_he circumstances and shall be in accordance with these instructions, procedures..."
Contrary to the above, the following were noted:
i a) The required quarterly summary of abnormal occurrences by procedure SAO-124, " Reporting of Anomalous Conditions" was not available and apparently had not been written.
b) Procedure 2AD-9, " Conduct of Operation" states in part:
" charts -
all charts to be maintained as follows:
1.
2.
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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 be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activitics affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authori cd personnel and are distributed to and used at the location where the prescribed activity is performed."
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Contrary to the above, the folletting was noted:
Procedurc QA-AD-11, " Calibration and Control of lieasuring Tools, Gages and Test Equipment for Use on Clacs "A" Cocpenents" fails to include cll of the ulnicum requirements (accuracy to which it can be used) of the controlling procedure SAO-117.
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