ML20050M331
| ML20050M331 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/30/1982 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20050M169 | List: |
| References | |
| 50-454-82-02, 50-454-82-2, NUDOCS 8204140305 | |
| Download: ML20050M331 (3) | |
Text
-
Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 As a result of the inspection conducted on January 25-27, 29 and February 2, 3, 16-19, 1982, 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 XIV requires that measures be established to indicate by the use of markings such as stamps, tags, labels, routing cards or other suitable means, the status of inspec-tions and tests performed upon the individual items of the nuclear power plant. Measures shall also be established for indicating the operating status of structures, systems and components of the nuclear power plant.
The Byron Station Startup Manual states in Paragraph 4.1 that the System Status Notice is a system of tracking the system status during the completion of construction, flushing and testing, until turnover for normal unit operation. The System Status Notice con-sists of:
the type of marking (or taping) required.
In paragraph 4.1.2, Re-entry Control, the Startup Manual states that re-entry control consists of:
blue or yellow tape on all system components, except piping, indicating the portion of the system under re-entry control.
Contrary to the above:
a.
Six components (instruments) in the RHR system and one component in the SI system were observed which had not been blue taped to indicate release for preoperational testing as shown on the System Status Notice.
b.
A second system of taping which involved blue tape (and other colors) of almost identical color was identified as being used at the site to aid in establishing separation for safety related 8204140306 82lD330 PDR ADOCK CHS000454 G
PDR I
Appendix 2
instrumentation. This taping system meant nothing as far as the system status notice was concerned, yet further confused the determination of the status of any particular instrument.
This is a Severity Level V violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion XIII states, in part, that " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment... to prevent damage or deterioration.
,i The Commonwealth Edison Company Quality Assurance Program contains, in Quality Requirement QR 2.0 a commitment to the regulatory position of Regulatory Guide 1.38 Revision 2 which endorses the requirements of ANSI N45.2.2-1972.
Section 6.5 of ANSI N45.2.2 states, in part, that, " Items released from storage and placed in their final locations within the power plant, shall be... cared for in accordance with the requirements of Section 6 of this Standard." Section 6 of ANSI j
N45.2.2 states in part that, "(6.1.1) Levels and methods of storage i
necessary are defined to minimize the possibility of damage or lowering quality due to corrosion, contamination, deterioration, or i
physical damage.
(6.2.2) Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas.
(6.2.4) The use or storage of food, drinks in controlled storage areas shall not be permitted.
(6.4.2) Items shall have all covers, caps, plugs or other closures intact covers removed for i
internal access at any time for any reason shall be immediately 1
replaced and resealed after completion of the purpose for removal."
Contrary to the above:
The licensee does not have an adequate program to ensure proper care and preservation of safety related equipment as evidenced by approxi-mately 15 instances of conditions potentially damaging to safety related equipment identified while observing the performance of RHR and DG l
tests on January 26, February 3 and 18, 1982.
i This is a repetitive item of noncompliance in that similar problems were identified in NRC Inspection Report No. 50-454/81-12-01, dated l
September 2, 1981, and subsequent followup Inspection Repc:ts No.
50-454/81-18 and 50-454/81-14, dated November 17, 1981.
Also In-spection Reports No. 50-454/82-03 and 50-455/82-02 indicated that l
progress in this area was insufficient to close the item.
4 4
I i
t 3
., ~ ~.,
tv-
_=
-.~.
i l
Appendix 3
This is a Severity Level IV violation (Supplement II).
I 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 each item of noncompli-ance:
(1) corrective action taken and the results achieved; (2) correc-tive action to be taken to avoid further noncompliance; and (3) the date when full compliance 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 ex-i tending your response time for good cause shown.
-::Ir.:.I_Sicr. d. Ly C.E, Horclic.
pp'>
. g.s Dated C. E. Norelius, Director Division of Engineering and Technical Programs I
1 l
l i
t l
l l
...