IR 05000518/1981004
| ML19346A120 | |
| Person / Time | |
|---|---|
| Site: | Hartsville  |
| Issue date: | 03/19/1981 |
| From: | Blake J, Herdt A, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19346A114 | List: |
| References | |
| 50-518-81-04, 50-518-81-4, 50-519-81-04, 50-519-81-4, 50-520-81-04, 50-520-81-4, 50-521-81-04, 50-521-81-4, NUDOCS 8106050145 | |
| Download: ML19346A120 (14) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION e
i aeoio ii
101 MARIETTA ST., N.W., SUITE 3100
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ATLANTA, GEORGIA 30303
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Report Nos. 50-518/81-04, 50-519/81-04, 50-520/81-04 and 50-521/81-04 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility Name:
Hartsville Docket Nos. 50-518, 50-519, 50-520 and 50-521 License Nos. CPPR-150, CPPR-151, CPPR-152 and CPPR-153 Inspection at Hartsville site near Har*sville, Tennessee Inspectors:
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/1 J. J. Blake (
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Date Signed
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E. IL OLrtA~,
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shshfi W. P.,leinso ge
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Date Sigried J//9/[/
Approved by:
A. R.'Herdt, ~Section Chief Oftte* Signed Engineering Inspection Branch Engineering and Technical Inspection Diviaion SUMMARY Inspection on March 3-6, 1981 Areas Inspected This routine, unannounced inspection involved 60 inspector-hours onsite in the areas of licensee identified items (50.55(e) Reports); previously identified inspection findings; licensee program for conditions adverse to quality; safety-related piping; and steel structures and supports.
Results
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Of the five areas inspected, no violations or deviations were found in three
areas; three violations were found in two areas (Violation
" Failure to Follow Bead Width Procedure Requirements" paragraph 8.b.(1); Violation
"Inadequa.te Measures to Control Welder Qualification and Repair Welding" paragraphs 8.b.-
(3)(a) and 8.b.(5)(a); Violation
" Inappropriate Handling of Conditions Adverse l
to Quality" - paragraph 10.)
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REPORT DETAILS 1.
Persons Contacted Licensee Employees R. T. Hathcoc Project Manager
- W. T. Quinn, Ccestruction Engineer
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- R. E. Young, Assistant Con:truction Engineer
- H. S. Sheppard, Assistant Construction Engineer, QC
- J. T. McGehee, Engineering Management Assistant
- F. E. Laurent, Mechanical Project Engineer, STRIDE
- D. Thornton, Mechanical Project Engineer, B0P
- K. H. Stewart, Assistant Construction Engineer, Engineering Services
- H. F. Bates, Civil Project Engineer, STRIDE
- S. P. Stagnolia, Welding QC Unit Supervisor
- J. W. Davenport, Civil QC Unit Supervisor
- E. D. Loope, Welding, QC
- T. L. Carden, Welding, QC
- R. E. McClure, Mechanical QC
- M. U. Rudolphi, Hanger Engineering Unit Supervisor
- P. F. Gillespie, Technical Services
- D. F. Jaquith, Construction QA Unit
- R. B. Stamps, Construction QA Unit
- D. E. Felts, Construction QA Unit
- K. L. Ramsey, Construction QA Unit
- J. R. Gelzer, Construction QA Unit
- J. E. Wills, Regulatory Staff (Chattanooga)
Other licensee employees included construction craftsmen, technicians, QC inspectors and office personnel.
NRC Resident Inspector
- W. B. Swan
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on Murch 6,1981 with a
those persons indicated in paragraph 1 above. The inspectors discussed the
violations in detail. There were no questions from licensee representa-tives. The Welding QC Unit Supervisor indicated that corrective action and/or further investigation was already in process on the problems with the welding area. The licensee was not prepared to discuss the item concerning the QCIR Reports, as it had only developed on the morning of the exit meeting.
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3.
Licensee Action on Previous Inspection Findings i
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(Closed) Unresolved Item (50-518, 520/80-20-01) - Inspection Requirements for AWS Welds.
TVA letter dated October 20, 1980 (L. M. Mills to J. P. O'Reilly) "Bellefonte Nuclear Plant Units 1 and -2 - Construction-QA
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Audit Deficiency Safety-Related Non-ASME Weld Inspection BN-W-80-08 - First Interim Report" stated that "Although the deficiency was originally written-on Bellefonte Nuclear Plant, it has been determined to be generic to all TVA nuclear plants under construction." Based on this report the unresolved item is closed and the item will be tracked as a. 60.55(e) item for all units with the number 50-518, 519, 520, 521/81-04-01.
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4.
Unresolved Items Unresolved items are-matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 8.b.(2)(c) and 8.b.(3)(b).
S.
Independent Inspection Effort
a.
Construction Activities (Units Al and A2)
The inspector conducted a general inspection of the Units Al and A2.
l fuel, auxiliary and reactor buildings, and pipe fabrication shop to observe construction progress and construction activities such as welding, nondestructive examination, material handling and control, i
housekeeping and storage.
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i (Units B1 and B2)
The inspector made a general inspection of the "B" plant construction site to observe preservation activities.
Within the areas inspected no violations or deviations were identified.
6.
Licensee Identified Items (50.55(e) Reports)
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The following previously identified items were reviewed during this inspec-g tion:
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a.
(Closed) Licensee Identified Item (50-519/79-17-01) - Containment Anchor Bolt Chair Weld Deficiencies'. This item was originally opened against both Al and B1 units (50-518 and 50-519). The Al portion was closed in Inspection Report No. 80-23-based on the licensee's final report which was forwarded on July 24, 1980 and the-rework required by NCR HNP-A-062. During this inspection it was verified that the rework l
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required to close NCR HNP-B-029 concerr.ing the anchor chair welds in Unit B1 is b:ing done at this time utilizing the same procedures and program that corrected the problem in Unit A1. Based on this review,.
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there are no further questions at this time and this item is closed.
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i b.
(0 pen) Licensee Identified Item (50-518/80-05-03) - RPV Shield Wall Deficiencies. The inspector reviewed the= licensee's' fourth interim report dated December 22, 1980, and reviewed the actions being taken on NCRs HNP-A-087, HNP-A-108, HNP-A-109, and HNP-A-115. This item will
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remain open pending receipt of the final ~ report.
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(Closed) Licensee Identified Item (50-518/80-08-01) - Cracks in RPV i
Shield Wall. The inspector reviewed the - licensee's ^ final 50.55(e)
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report dated December 31, 1980, discussed the corrective actions with Welding Engineering personnel, and reviewed NCR HNP-A-091. There are no further questions at this time.
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(0 pen) Licensee Identified Item (50-518, 519, 520, 521/80-10-02) -
Design Deficiency of T-Head Section of Anchor / Darling Gate Valves. The
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inspector reviewed the licensee's final report on this subject, dated November 3, 1980, in which the licensee stated that the subject valves would be shipped back to the manufacturer by December 15,1980 for I
replacement of deficient disks. At the time of this inspection the valves have still not been shipped.
The inspector -was told that-additional contractural difficulties concerning costs had been' intro-duced since the preparation of the final report. This information was purportedly telephoned to the RII office _ in late December when the December 15, 1980 date was missed. The inspector informed the licensee that.an amended report would be required prior to closing of this item.
e.
(0 pen) Licensee Identified ' Item (50-518, 519, 520, 521/80-13-01) - ~
Atlas Machine and Iron Works QA - Steam Tunnel Embedment Stiffener Plate Weld. The licensee submitted a final report on this item on December 18, 1980. This report stated that the vendor, Atlas Machine and Iron Works, Gainesville, Virginia (Atlas) had reorganized in the area of QA and that TVA was now satisfied with the quality of the work being produced. During this inspection it was learned that Atlas has gone out of business and TVA is in the process of obtaining materials owed them through the courts.
The licensee stated that a written notification concerning the termination of the Atlas contract would be forwarded as an amendment to the final report. This item will remain
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open pending receipt of the amendment to the report.
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7.
Previously Identified Inspector Followup Items - (i.e., Items of Concern)
(Closed) Inspector Followup Item (50-518, 519,.520, 521/80-15-06) -' Follow Resolution of Welding Audit Findings. The inspector reviewed the report of the review and evaluation of OEDC welding and NDE Program, QAE 80-2, dated September 8,1980. This was a final report, applicable to Watts Bar and
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later nuclear plants, of a review conducted during June and July 1980. The review did not identify any specific deficiencies in the Hartsville welding i
and NDE area.
The report provides recommendations for improvirg the
effectiveness of the welding program through additional training in the craft and inspection areas. Based on the review of this report, the item is
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closed.
i (0 pen) Inspector Followup Item (50-519/80-01-01) - MT Indications on Anchor /
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Darling Globe Valve. This item was originally opened in January 1980 when
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the valve.(Serial No. E-6318-40-8) was magnetic particle inspected at the-i request of NRC.. As reported in Inspectico Report No. (50-518, 519, 520, 521/80-01), the MT inspection identifiea 22 linear indications scattered
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I The inspector reviewed the status of this item to determine if the reported indications had been dispositioned.
Discussion with the engineer and a review of correspondence between the site and TVA Knoxville offices showed that the problem has not been resolved yet. The correspondence and other j
documentation reviewed included the following:
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a.
Memo - R. T. Hathcote to H. C. Russell dated 4/14/80 b.
Letter - C. A. Chanley to A/D Valve Co. dated 6/3/80
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TLX from A/D Valve Co. to C. A. Chanley dated 6/25/80 d.
Memo - R. T. Hathcote to H. C. Ru'ssell dated 10/1/80 e.
QCIR No. 26082 f.
Informal sketch documenting relative size and location of MT indica-tions on valve body l
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Results of review of valve body RT film at A/D Valve Company h.
Documentation package (code data package) for valve detailing fabri-cation history.
I During the review of the documentation and the ensuing discussion with the l
engineer responsible for the valve problem, it became apparent that there i
had been a lot of effort expended by TVA and the valve manufacturer to justify acceptance of the valve based on a review of the results (RT film, a
documentation) of the inspections conducted prior to the MT examination m
requested by NRC. The was no documentation that indicated that anyone with
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knowledge of casting metallurgy or NDE had made any attempt to correlate the existing condition with the NDE history.
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i After this discussion, the engineer met with the supervisor of the Welding and NDE Unit to initiate action to get.an evaluation of the valve by a TVA Level III MT inspector.
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During the discussion, it became apparent to the inspector that the primary site document being used to track this problem was QCIR No. 26082 which had been completed with an N/A in the block titled "NCR No."
This appeared to be in violation of Site Construction Engineering Procedura No. CEP-16.03,
" Handling Conditions Adverse to Quality",.which defines what level items can be corrected by disposition of the QCIR and which items must be escalated to a Nonconformance Report for disposition. The major differences between a -
minor II category item which can te handled by QCIR and a major category item which must be escalated to an NCR are the need for Design Project
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Organization and/or Authorized Nuclear Inspector Concurrence with the disposition or the need for appropriate management review / action to prevent recurrence.
Bated on the amount of correspondence between the site and Knoxville offices concerning this problem it appears that the proper method of tracking should have been a Nonconformance Report.
This is another example of the problem identified in paragraph 10. of this report.
This item will remain open pending the results of additional inspection of the valve by the licensee.
8.
Safety-Related Piping (Units Al and A2)
The inspector observed non-welding and welding work activities for safety-related piping outside of the reactor coolant pressure boundary as described below to determine whether applicable code and procecure requirements were being met. The applicable code for safety-related piping is the ASME B&PV Code,Section III, Subsections NC and ND, 1974 edition with addenda through summer 1974.
a.
Observation of Non-Welding Activities Observation of specific work activities were conducted to determine conformance, where applicable, with the following; inspection and/or work procedures, record keeping requirements, installation specifica-tions or plans, specified materials, specified NDE, calibration requirements and use of proper test equipment and qualified inspection and NDE personnel.
System Activity Component Unit procedure Storage Pipe, Fittings, and Al & A2 RIS&PN M415 R5 Piping Assemblies RIS&PN M413 R9
(Various)
RIS&PN M401 R7 CEP 13.03 R1 n
CEP 13.02 R3 Handling Piping Assemblies Al & A2 Hazard Control (Various)
Standard - 525 l
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b.
Observation of Welding Activities I
The inspector observed in process welding i.t.ivities of safety-related piping field welds as described below to deaermine whether appltcable
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code and procedure requirements were being met.
(1) Welding The below listed welds were examined in process to determine:
whether work was conducted in accordance with travelers; welder identification and location; welding procedure; WPS assignment; l
welding technique and sequence; materials identity; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interpass temperature;. interpass cleaning; process control systems; identity of welders; qualification of inspection personnel; and weld history records.
Stage of Joint No.
Unit Size Fabrication System l
RH0211004 Al 18"x0.562 Welding Out Residual Heat Removal i
ES0680004 A1 8"x0.322 Welding Out Essential Service Water With regard to the above inspection, on March 5, 1981, the inspector accompanied by a representative of the licensee noted l
l that the single bead cover pass, in process, on weld ES0680004, deposited with 3/32-inch diameter type E7018 electrode, was 7/8- -
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inch wide.
TVA General Construction Specification G-29M, Process Specifi-cation 1.M.1.2(b), paragraph 14.9.1(a) requires that the bead width for 3/32-inch diameter type E7018 electrodes not exceed 9/16-inch maximum. Therefore the welder failed to follow pro-cedure.
Failure to follow procedure, for activities affecting quality, is in violation of 10 CFR 50, Appendix B, Criterion V.
This violation will be identified as 518/81-04-04, " Failure to Follow Bead Width Procedure Requirements".
(2) Visual Inspection of Welds The inspector visually examined completed and accepted safety-related welds as described below to determine whether applicable code and procedure requirements were being met.
(a) The following welds were examined relitive to the following:
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location, length, size and shape: weld surface finish and
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appearance, including inside diameter of pipe welds when accessible; transitions between different wall' thicknesses; weld reinforcement-height and appearance; joint configu-rations of permanent attachments and stuctural supports; removal of ' temporary attachments; arc strikes and weld spatter; finish grinding or machining of weld. surface--
surface finish and absence of wall thinning; serface defects--cracks, laps, lack of penetration, lack of fusion',
porosity, slag, oxide film and under cut exceeding prescribed limits.
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Weld No.
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Unit No.
System
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RC0021003 Al Reactor Core Isolation Coolir'a
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CN0040001 Al Condensate RC0090001 Al Reactor Core Isolation Cooling RH0250010 S1 Al Residual: Heat Removal
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RH0250009 Al Residual Heat Removal-RH0211002 Al Residual Heat Removal
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RliO211003 Al Residual Heat Removal
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RH0130004 Al
RH0130003 Al Residual Heat Removal
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RH0130002 Al Residual Heat pemoval
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(b) Quality records for the following welds were ex0 mined rela-tive-to the following:
records covering visual and dimensional inspections indicate that the sp0cified inspections were completed; the records reflect adequcte weld quality; history records are adequate.
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Weld No.
Unit No.
System CN0040001 Al Condensate RH0250010 S1 Al Residual Heat Removal RH0211003 Al Residual Heat Removal RH0130004 Al Residual Heat Removal RH0130003 Al Residual Heat Removal i
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(c) With regard to the inspection of paragraph 8.b.(2)(a) and 8.b.(2)(b), the inspector noted t,at welds A1ARH0130002, 3 and 4 were marked with welder symbol "FAVC" only. TVA Weld
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Monitoring Printout, Program CXHTWMA indicates that the above
,1 welds were made by welders "FAVC" and "FAUC".
The licensee indicated that they would look further into the matter and determine the significance. The inspector stated that the l
above would be identified as unresolved item 50-518, 519, 520, 521/81-04-05; " Printout Does Not Agree With Pipe Mark-ings".
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(3) Welder Qualification The inspector reviewed the TVA program for qualification of welders and welding operators for compliance with QA procedures and code requirements. The applicable code for welder qualifi-cation is ASME B&PV Code,Section IX.
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(a) The' inspector reviewed TVA General Construction Specification G-29M, Process Specification 1.M.2.2(a), Performance Quali-fication Test No. GT-SM-6-4-0-11, Revision 2, to determine conformance with the applicable code. On March 4, 1981, the inspector noted that the above test consists of 3/16-inch thick gas tungsten are weld (GTAW) metal deposit followed by 9/16-inch thick shielded metal arc weld (SMAW) metal deposit in a 3/4-inch wall thickness, groove pipe butt weld t:::t assembly. Paragraph 8.1 of the above test specifies that the qualificattorr test assembly qualifies a welder for welding pipe butt joints from 3/16-inch to unlimited wall thickness.
The preceding is contrary to ASME Interpretation IX-78-92 dated September 25, 1978 in that the above test conditions would only qualify the tested welder for a maximum thickness of 1-1/2-inch.
Therefore the licensee has been granting welders unlimited thickness qualifications when the welders are actually only qualified to 1-1/2-inch thickness maximum.
The above condition indicates dequate measures for the control of special processes are 3 an example of violation 50-518, 519, 520, E21/81-04-03 as discussed further in paragraph 8.b.(5)(a)1.
(b) With regard to the welder qualification program review in paragraph 8.b.(3), the inspector could find no documented controls to assure that welders with Itmited thickness qualifications do not e.xceed their thickness limit when welding on material thicknesses greater than their limit.
The licensee indicated that they would look further into the matter. The inspector stated that the above would be iden-
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tified as unresolved item 50-518, 519, 520, 521/81-04-06,
" Control of Limited Thickness Welders".
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(c) The following welder qualification status records and
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" Records of Performance Qualification Test" were reviewed
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relative to the weld joints listed in paragraph Nos. 8.b.(1),
8.b.(2)(b), 8.b.(5)(a) and 9.a.
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Welder
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Symbol Unit Application FAAT Al Safety-Related Piping isepair FAUQ Al Safety-Related Piping FABQ Al Safety-Related Piping
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FAUZ Al Safety-Related Piping FAOK Al-Safety-Related Piping FAVC Al-Safety-Related Piping FAUC Al Safety-Related Piping FAND Al Safety-Related Piping Repair
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FAFN Al Safety-Related Piping Repair
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FACA-A1&AZ Safety-Related Piping Repair FABL A2 Safety-Related Piping Repair FAAX A2 Safety-P. elated Piping Repair FACB A2 Safety-Related Piping Repair FALQ A2 Safety-Related Piping Repair
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FA0Z A2 Safety-Related Piping Repair FMA Al Steel Structures and Supports (4) Welding Filler Material Control (Unit A1)
The inspector reviewed the TVA program for control of welding materials to determine whether materials are being purchased, accepted, stored, and handled in accordance with QA procedures, and applicable code requirements. The following specific areas were examined:
Purchas'ing, receiving, storing, distributicg and handling
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procedures, material identification, and inspection of welding material issuing stations.
Welding material purchasing and receiving records for the
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following materials were reviewed for conformance with
applicable procedures and code requirements:
Heat Lot or Process *
Type Size Batch No.
Application SMAW 7018 1/8" B217 Safety-Related Piping SMAW 7018 3/32" 7216 Safety-Related Piping SMAW 7018 3/32" 8303 Steel Structures and
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- Shielded Metal Arc Welding (SMAW)
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(5) Special Welding Activities The inspector examined special welding activities including weld repair as described below to deter:nine whether applicable code and procedure requirements were being met.
(a) Records of the foll.owing repair welds were examined relative to the following:
welding procedure used; repair welding procedure includes all pertinent requirements; repair welding procedure qualification; repair welder performance qualiff-Cation; ANI witnessed performance qualification; repair area does not exceed limits; base and filler material as specified; base material repairs documented; NDE performed, and records complete.
Wald No.
Unit No.
System HP0201005-R1 Al High Pressure Core Spray LP0021003-R1 Al Low Pressure Core Spray AP0320045-R1 Al Air Positive Seal RH0320R01-R1 Al Residual Heat Removal CN0010001-R1 A2 Condensate CN0010001-R2 A2 Condensate CN0010001-R3 A2 Condensate CN0020003-R1 A2 Condensate CN0020003-R2 A2 Condensate
With regard to the above inspection, on March 4,1981, the inspector noted all the above weld repairs required visual inspection of the repair area prior to welding.
The inspector could find no documented acceptance
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criteria for visual inspection prior to repair welding.
The licensee stated that they required visual inspection prior to all safety-related pipe repair welding as a matter of policy, however, there is no documented acceptance criteria for that inspection.
Therefore inspectors are inspecting without acceptance criteria.
The above combined with the example as discussed in paragraph 8.b.(3)(a) indicate that the licensee does not have adequate measures for the control of special
processes.
Failure to establish adequate measures to
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control special processes including welding is in
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violation of 10 CFR 50, Appendix B, Criterion IX. This violation will be identified as 518, 519, 520, 521/81-04-03; " Inadequate Measures to Control Welder Qualifi-cation and Repair Welding".
Within the areas examined, no violations or deviations were identified except as noted in paragraph Nos. 8.b.(1), 8.b.(3)(a) and 8.b.(5)(a) (
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9.
Steel Structures and Supports (Unit A1)
The inspector observed welding work activities for steel structures and supports as described below to determine whether applicable code and pro-cedure requirements were being met.
The applicable code for structural supports is the ASME B&PV Code,Section III, Subsection NF,1974 edition with addenda through summer 1974.
The inspector observed in process welding activities of structural field welds outside of containment as described below to determine whether applicable code and procedure requirements were being met.
a.
Welding The following welds were examined in process to determine: whether work is conducted in accordance with a traveler; welding procedures
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available; welding technique and sequence; weld geometry; fitup elec-trical characteristics; equipment condition:
System Control Member Chart Number Number Support
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X18-14-API. R0 C
System Support b.
Welder Qualification i
Welder qualification is discussed in paragraph 8.b.(3)
c.
Welding Filler Material Control Welding filler material control is discussed in paragraph 8.b.(4).
Within the areas examined, no violations or deviations were identified.
10.
Handling of Conditions Adverse to Quality The licensee's program for the control of nonconforming items at the site is contained in three basic construction engineering procedures. These are
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t CEP-16.03, Handling Conditions Adverse to Quality; CEP-15.01, Control of Quality Control Investigation Reports; and CEP-15.03, Control of Noncon-
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formance Reports.
The Quality Control Investigation Report (QCIR) is used to document questionable and/or minor conditions adverse to quality. If the condition is determined to be a major or significant condition as defined by CEP-16.03, the QCIR must be supplemented with an NCR L port. (It is important that this evolution take place because only NCR items are reviewed for reportability under 10 CFR Parts 21 and 50.55(e).)
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The inspector selected QCIRs on file in the QA records vault to determine if the QCIRs and dispositions conformed to procedures-CEP-15.01-and CEP-16.03.
The QCIRs reviewed were in the number 50900 through 50996 numbering sequence, with No. 50996 being the highest number on file in the vault.
There were a tota 1 of 60 QCIRs reviewed.
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During this review the inspector noted the following QCIRs which appeared to have-been mishandled in that action to prevent repetition is not addressed or design project organization concurrence is obtained indicating the need for an NCR.
a.
QCIR 50985 Weld A1W00020R1'on weld map 17RBW-1 welded with wrong
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electrode and wrong preheat.
Problem:
No action to prevent repetition.
b.
QCIR 50968 Weld AIRF00150 unacceptable root condition.
Problem:
No action to prevent repetition.
c.
QCIR 50951 High pressure fire protection piping Dwg.
No.
3KE6467-KE-07, 11,12.
Problem:.
QCIR contains statement that disposition was coordinated
and approv?d by EN DES d.
QCIR 50927~
Concrete forar would only allow 3/8-inch coverage of rebar-instead of the 2-inch called for by Dwg. 4KE2407-K6-01 R3.
Problem QCIR discpostion states - Pull form to obtain 1-inch coverage ok'd by Knoxville.
e.
, CIR 50944-Curb angle fabricated to wrong dimension. Change print
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to agree with fabrication.
Problem:
No action to determine how, or prevent repetition.
f.
QCIR 50901 Pieces fabricated from wrong size material 2-1/2"x2-1/2"-
angle rather than 2"x2" angle.
Problem:
No determination of why or how to prevent repetition.
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There were also a number of QCIRs which contained either the signature of the C F. Braun site representative or the authorized nuclear inspector.
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There was no indication if these were required concurrence.s which would have reclassified the problem as a major item requiring an NCR or if the signa-tures were only indicative of an unrequired. review.
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The inspector questioned whether problems with C. F. Braun designed items should not automatically be in the nonconformance report category to ensure that they. are screened for potential Part 21 reportability in that the design drawings represent goods and services offered for acceptance. The QCIRs listed in a. through f. above should have been elevated to noncon-formance report status for screening as potential 50.55(e) and/or Part 21 items and for the reasons stated above.
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The licensee was informed that the handling of the QCIRs listed above appear
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to-be a violation of the licensee's program for handling of conditions adverse to quality. This item will be carried as violation No. 50-518, 519, 520, 521/81-04-02, "QCIR Report Mishandling."
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