ML20235H183

Notice of Violation from Insp on 870209-0521.Violation Noted:Activities Affecting Quality Not Prescribed by Documented Instructions

ML20235H183
Person / Time
Site:	Byron
Issue date:	07/09/1987
From:	Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235H163	List: IR 05000454/1987007 ML20235H159 ML20235H183
References
50-454-87-07, 50-454-87-7, 50-455-87-24, NUDOCS 8707150043
Download: ML20235H183 (2)

Text

-

NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 l

As a result of the inspection conducted from February 9 through May 21, 1987, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion V, as implemented by Ceco Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations,"

and CECO Corporate Quality Assurance Manual, Nuclear Generating Stations,

" Quality Requirements," requires that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these {

instructions. Instructions shall include appropriate quantitative or qualitative acceptance criteria for determining that activities affecting quality have been satisfactorily accomplished.

Contrary to the above, during the course of reviewing safety-related design efforts performed by Nutech Engineers, the NRC inspectors observed that activities affecting quality were not prescribed by documented instructions in that:

a. Instructions did not address selsmic effects for all portions of the piping subsystems. Paragraph 4.1.1 of Instruction BYR 19, Revision 2, states that seismic interaction walkdown shall be specified for portions of subsystems where seismic displacements exceed the original design seismic displacements by more than one inch.

(454/87007-01A)

b. Instructions did not include seismic anchor movement (SAM) effects during seismic walkdowns. (454/87007-01B)

c. Instructions were insufficient in the OPTPIPE User's Manual.

Seismic zero period acceleration (ZPA) was listed on Pages 3.6, 4.2, 4.61, 4.65 and 4.66; however, no instructions were given as to when and how the ZPA was to be utilized in the computer application. (454/87007-01C)

This is a Severity Level IV violation (Supplement 1).

2. 10 CFR 50, Appendix B, Criterion III, as implemented by CECO Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations,"

and CECO Corporate Quality Assurance Manual, Nuclear Generating Stations,

" Quality Requirements," requires that measures shall be established to assure that regulatory requirements and the design basis for those structures and systems are correctly translated into specifications, drawings and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and deviations from such standards are controlled.

8707150043 070709 PDR ADDCK 05000454 G PDR ,

Notice of Violation 2 Contrary to the above, during the course of reviewing safety-related design activities performed by Nutech Engineers, the NRC inspectors observed that the above criterion was not met in the following areas:

a. Zero period acceleration effects were not considered in the evaluation of safety-related piping systems. As a result, 106 supports and nine valves required requalification and one support required modification. (454/87007-02A)

b. No justification was made for the 3 inch criterion used for seismic interaction walkdowns and rattle point evaluations prior to the start of the snubber reduction program. (454/87007-028)

c. Other than engineering judgements, there were no technical bases for the 90% stress or insulation criteria used in the rattle point walkdowns. (454/87007-02C)

d. Design verification was not adequately performed. This resulted in an analytical error in an impact analysis, inappropriate use of seismic response spectrum, and omission of node points for rattle point evaluations. (454/87007-02D)

This is a Severity Level IV violation (Supplement 1).

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.

Dated 1 Tl kb k J. J. Harrison, Chief Engineering Branch