ML20212E191

Notice of Violation from Insp on 861024-1218

ML20212E191
Person / Time
Site:	Braidwood
Issue date:	12/29/1986
From:	Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212E162	List: IR 05000456/1986063 ML20212E158 ML20212E191
References
50-456-86-63, 50-457-86-44, NUDOCS 8701050272
Download: ML20212E191 (3)

Text

O 1

NOTICE OF VIOLATION Commonwealth Edison Cospany Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on October 24 through December 18, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violations were identified:

1. 10 CFR 50, Appendix 8 Criterion II, Quality Assurance Program, states inpartthattheQualItyAssuranceProgramshallbedocumentedbywritten policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions.

The licensee's Quality Assurance Manual, Revision 107, Quality Procedure (QP) 4-1, " Request for Bid, Proposal Evaluation, and Reccamendation,"

Section 4.7.2 states:

" Materials, parts, and items which are to be used in safety-related applications that are a manufacturer's standard product (commercial grade item) and not purchased to special requirements of a Ceco specification . . . can be purchased from a supplier or manufacturer listed on the company commercial approved bidders list and be accepted and upgraded to safety-related (this reclassification is called dedication) at the plant site by documented receipt inspection . . . ."

" Acceptance solely by receiving inspection for safety-related dedication only can be accomplished if the item or service is:

(a) relatively simple and standard in design manufacture or test . . . ."

"For items, materials, and parts procured as commercial grade that do not fall under the simple receipt inspection method of dedication, a documented technical evaluation shall be performed to provide verification of the acceptability of such items, materials, and parts to requirements for dedication to a safety-related classification."

Contrary to the above the procurement process for replacing the Nickel Cadmium batteriesfortheAuxIliaryFeedwater(AFW)DieselPumpwasinadequateinthat these replacement batteries, which were procured as commercial grade, were upgraded to a safety-related application without an adequate technical evaluation. The original batteries were procured utilizing Sargent & Lundy Specification L-2891 which required seismic qualification to IEEE-344-1975, and therefore, were not simple in design.

This is a Severity Level V violation (Supplement II).

0701050272 DR 061229 ADOCK 05000456 PDR

i Notice of Violation 2

2. Technical Specification Section 6.8.1(a) requires that written procedures shall be established, implemented, and maintained concerning activities referenced in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978. Sections 8.a and 8.b of Appendix A of RG 1.33 requires that procedures of a type appropriate to the circumstances should be provided to ensure that instruments, controls, and other measuring and testing devices are properly calibrated and adjt.sted to maintain accuracy, and also requires that specific procedures for surveillance tests should be written (implementing procedures are required for each surveillance listed in the Technical Specifications). Additionally, the licensee's Quality Assurance Manual requires that procedures developed shall meet the requirements of ANSI 18.7 which requires the procedures to be adhered to.

Contrary to the above, the licensee failed to comply with the administrative controls outlined in their procedures which ensure that components addressed in the Technical Specifications are properly surveillance tested. Examples of these failures to adhere to the surveillance program procedures are as follows:

a. The surveillance program for the Engineered Safety Feature undervoltage, Grid Degraded voltage, and the Reactor Coolant Pump undervoltage was inadequate in that:

(1) Two relays were accepted by the technical staff with data which did not meet technical specification acceptance criteria.

(2) The procedure to implement this surveillance program did not contain the acceptance criteria as defined in the technical specification.

(3) The procedure to implement this surveillance program did not comply with administrative procedure BwAP 1400-7, Section 3, which defines the requirements for content of a station surveillance procedure.

(4) The technical staff has not submitted, as required by Procedure BwHP 300-003, a list of relays to be Inspected / tested to the Electrical Maintenance Department.

b. The monthly surveillance of the IB Diesel Generator, described in Surveillance Procedure 18w05 8.1.1.2.a-2, was noted as acceptable on the Surveillance Data Package cover sheet even though the data recorded did not comply with the specified acceptance criteria,

c. A Mode 4 monthly surveillance for the Essential Service (SX) Water system describad in Surveillance Procedure 18w05 7.4.A-1 was utilized in Modes 5 and 6 to document the current valve lineup for the SX system. The data indicated the valve and breaker position

t Notice of Violation 3 was unsatisfactory; however, a note indicated the lineup recorded in the data package was acceptable for the current plant mode (5 and 6). However, the Surveillance Data Package. cover sheet indicated the surveillance was found with acceptable criteria. This surveillance was documented in the licensee's computer data base used for scheduling surveillances as satisfactory.

This is a Severity Level IV violation (Supplement 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 violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

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Dated W. 5. Little, Director BraidwoodProject

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