ML18046A512
| ML18046A512 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/09/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18046A511 | List: |
| References | |
| 50-255-80-20, NUDOCS 8103190268 | |
| Download: ML18046A512 (6) | |
Text
Appendix A NOTICE OF VIOLATION Consumers Power Company Docket No. S0-2SS As a result of the inspection conducted on November 3, thru December S, 1980 and January 16, 1981 in accordance with the Interim Enforcement Policy 4S FR 66754 (October 7, 1980), the following violations were identified:
- 1.
10 CFR SO, Appendix B, Criteria IV, states, "Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably referenced.in the documents for procurement of material, equipment and services, whether purchased by the applicant or by its contractors or subcontractors.
To the extent necessary, procurement documents shall require contractors or subcontractors
- 2.
to provide a quality assurance program consistent with the pertinent provisions of this appendix."
Contrary to the above, there are numerous procurement documents which do not reference applicable regulatory requirements or necessary quality assurance program requirements.
Quality Assurance program requirements have not been referenced in the procurement documents in regards to 10 CFR 50 Appendix B, ANSI N4S.2, or NA-4000 of the A. S. M. E. Section III-Boiler and Pressure Vessel Code.
10 CFR 21 statements have also been omitted in procurement documents.
Examples of these omissions are purchase orders 1001-4411 and 1001-6960 for weld rod and putchase orders 1001-6797 and 1001-S489-for fittings.
Other examples are referenced in Paragraph 7.
This is a Severity Level V violation (Supplement I).
10 CFR SO, Appendix B, Criteria V states in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Quality Control Procedure, QCP-P-OS Rev. S-Processing of Nonconforming Material, states in paragraph 5.2.1:
"Upon notification from the stockman that materials which are not in an "Accept" status li.ave been requested for issuance, the QC Supervisor reviews the appropriate receipt inspection file and NMR Logs (i.e., receipt and source inspection) to verify that an NMR has already been generated.
If no NtIR exists, he initiates one in accordance with Section S.1.1 of this procedure, unless the material is being issued for repair, rework, inspection or test and is to be returned to the stockroom."
- I
Appendix A Contrary to the above, Nonconforming Material Reports were not being written on material lacking or deficient in documentation when releasing the material for installation in the plant.
The following purchase orders are examples of this practice:
Purchase Order Nos. 1001-0820, 0006-0645, DY-150, and DY-152.
(paragraph 8)
This is a Severity Level V violation (Supplement I).
- 3.
10 CFR 50 Appendix B, Criteria XVII states in part..... "Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following:
Operating logs and results of reviews, inspections, test audits, monitoring of work performance, and material analyses.
The records shall also include closely-related data such as qualification of personnel, pro-cedures, and equipment... Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning records retention, such as duration, location, and assigned responsibility."
Quality Assurance Program Procedure, 17-52, Revision 3, Collection Storage and Maintenance of Quality related Records for Operations states... "Records are stored according to ANSI N45 2.9 requirements, as modified by QA Policy 2, for duplicate record storage locations."
Quality Assurance Program Procedure, 2~54, Rev. 2, Training for Opera-tions states... "Records of training are maintained to provide evidence of personnel qualification, and to support certification where such is required."
Contrary to the above requirements, the following noncompliances were identified:
- a.
Numerous records are not stored according to ANSI N45.2.9 requirements, as modified by QA Policy 2, for duplicate record storage locations.
Examples are nonconformance material reports and personnel training records.
Other examples are referenced in paragraph 9b.
- b.
The technical superintendent was certified as a Level III, according to ANSI N45 2.6, without records to justify or support this qualification.
Furthermore, the technical superintendent qualified a Level II on March 5, 1980, in specific areas requiring special training, without records that supported his own qualifi-cations in these areas.
(paragraph 9)
This is a Severity Level VI violation (Supplement I).
Appendix A 4.
Technical Specification, Section 6.8, states in part... "Temporary changes to procedures for surveillance and testing activities of safety-related equipment may be made, provided the change is docu-mented, reviewed by the PRC at the next regularly scheduled meeting and approved or disapproved by the plant superintendent."
Contrary to the above, two test procedures, MI-2 and Rr-2; had tempo-rary changes T-80-137 and T-80-138 respectively, and were not reviewed by the plant review Committee at the next regularly scheduled meeting.
Procedure, MI-2, is entitled Reactor Protective Trip Units and procedure, RI-2, is entitled Thermal Margin/Low Pressurizer Pressure Channels.
These changes were* reveiwed in a later Plant Review Committee meeting.
(paragraph 10)
This is a Severity Level VI violation (Supplement I).
- 5.
10 CFR 50; Appendix B; Criteria VI, states in part... "Measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed
- 6.
to and used at the location where the prescribed activity is performed."
Quality Assurance Program Policy No. 6, Revision 8, Document Control paragraph 3.1 states... "A system for the preparation of documents and revisions, and their interdepartmental and intradepartmental review, approval and administration which preclude the possibility of the use of outdated or inappropriate documents is defined by specific department procedures. 11 Contrary to the above, measures have not been established to assure that changes to controlled drawings are distributed and used at the location where the prescribed activity is performed, to preclude the possibility of the use of outdated or inappropriate documents.
The following are examples of controlled drawings which are not up to date and are being used in the control room.
Other examples are referenced in paragraph lOb.
M - 220 Makeup Domestic Water and Chemical Injection M - 224 Gas Analyzing Systems M - 225 High Pressure Air Operated Valves The required red line changes had not been made on these drawings.
This is a Severity Level V violation (Supplement I).
10 CFR 50; Appendix B, Criteria VII states in part... "Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents...... Measures shall include provisions as appropriate, for source evaluation and
Appendix A selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and that the effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services."
Quality Assurance Program Policy No. 7, Control of Purchased Material, Equipment and Services states in Section 3.2,... " Selection of Suppliers is based on the Quality Assurance and technical evaluations and the capability of the supplier to provide established procurement requirements."
Contrary to the above requirements, the licensee failed to meet the program requirements as follows:
- a.
Three items that were purchased did not meet the procurement document but were accepted and released for installation and use.
Items purchased on Order Nos. 85378Q, 42604-Q, and 19144-Q did*
not meet purchase order specifications.
(paragraph 7)
- b.
Two* suppliers were placed on the approved suppliers list for "Q listed" safety related items contrary to Quality Assurance Technical evaluations.
The quality assurance evaluation on Hidco Pipe and Tube, on September 8, 1978, stated that Midco was only approved for non ASME B & PV Code,Section III, pipe and fittings.
Midc6 was placed on the approved suppliers list for AS~1E B & PV Code,Section III, pipe and fittings, and orders were placed on Purchase Order Nos. 1001-6797Q and 10015489Q for safety related, code items.
Also, ITT Harper was approved in a quality assurance technical evaluation for nuts and bolts only, but, they were placed on the approved suppliers list for special extruded shapes and fasteners, in addition to nuts and bolts.
(paragraph 7)
- c.
Consumers Power does not evaluate the effectiveness of their suppliers quality assurance programs either thru analysis of nonconforming material reports, for material received and inspected at the site, or thru inspections at manufacturing and supplier facilities.
(paragraph 7)
This is a Severity Level V violation (Supplement I).
- 7.
10 CFR 50, Appendix B, Criteria XVIII, states in part... "A comprehen-sive 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. 11
Appendix A Quality Assurance Program Policy No. 18, states,... "A reprel:!entative portion of the procedures and records related to each area is audited during the scheduled period to assure a review of all safety-related activities within a two-year period."
Contrary to the above, the audits performed for 1979 and 1980 did not cover all aspects of the Q.A. Program.
The following criteria of 10 CFR SO, Appendix B, did not appear to be audited at all:
Criteria II, VII, X, and XIII.
(paragraph 12)
This is a Severity Level V violation (Supplement I).
- 8.
Palisades Nuclear Generating Plant Technical Specification paragrap*h 4.7.2.a in reference to the station battery states... "every month, the voltage of each cell (to the nearest 0.01 volt)... shall be measured and recorded."
- 9.
Contrary to the above, Technical Specification Surveillance Procedure ME-12, Battery Checks, has been performed since at least May 1980 utilizing measuring instruments which did not comply with the required accuracy.
(paragraph 15)
This is a Severity Level V violation (Supplement I).
Technical Specification 6.8.1.C states that... written procedures shall be established, implemented and maintained covering surveillance and testing activities of safety-related equipment."
Contrary to the above, Special Test T-131B for the Endurance Test of Steam Driven Auxiliary Feedwater Pump P-8B was performed not adhering to the cooldown time requirement of step 5.5 and missing several required verification signatures for taken data.
(paragraph 6)
This is a Severity Level V violation (Supplement I).
- 10.
10 CFR 50, Appendix B, Criteria XVI, states in part... "Measures shall be established to assure that conditions adverse to quality, such as failures, malfuntions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be docwnented and reported to appropriate levels of management."
Quality Assurance Program Policy No. 16 Section 3.1 states in part...
"conditions which require additional action to prevent recurrence are a matter of judgement, but the following conditions are always evaluated:
... a failure of safety-related structure, system, component, or part which is significant to safety."
Appendix A Quality Assurance Program Procedure 16-51 states in part... "Within 40 days of the date orginated, the individual who received the *DR for pro-cessing... assures that the nonconforming items are controlled according to QAPP 15-51... 11 Contrary to the above, the following examples of noncompliance were identified:
- a.
On August 24, 1980, following the discovery of a wiring error, maintenance was performed on pressurizer pressure indicator PI-103B and a deviation report (DR) was not initiated as required.
(paragraph 15)
- b.
On September 29, 1980 Channel B high power reactor trip became erratic and was bypassed.
No deviation report was initiated.
(paragraph 17)
- c.
Four deviation reports were not resolved for corrective action in accordance with established completion dates and one deviation report did not meet the 40 day requirement concerning evaluator assignment, evaluation due date and priority.
The deviation reports are D-QG-78-24, D-QG-78-24A, D-QG-78-24C, D-QP-76-107, and D-QP-80-21.
(paragraph 17)
This is a Severity Level V violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance 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.
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