ML19242B581
| ML19242B581 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/07/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19242B580 | List: |
| References | |
| 50-269-79-10, 50-270-79-10, 50-287-79-10, NUDOCS 7908090020 | |
| Download: ML19242B581 (3) | |
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APPENDIX A NOTICE OF VIOLATION Duke Power Company License Nos. DPR-38 Oconee Nuclear Station, Units 1, 2 and 3 DPR-47 Based on the NRC inspection April 2-6, 1979, certain of your activities were apparently not conducted in full compliance with NRC requirements as indicated below. These items have been categorized as described in correspondence to you dated December 31, 1974.
A.
As required by 10 CFR 50, Appendix B, Criterion V, " Activities affecting quality shall be... accomplished in accordance with instructions, procedures...".
The accepted Quality Assurance Program, Paragraph 17.2.5 requires that, "With regard to specific operational activities...it is reqaired that such activities be accomplished in accordance with procedures".
1.
The accepted Quality Assurance Program, Section 17.2.16, requires,
"...taking appropriate corrective action whenever any deficiency in the implementation of the requirements of the program is determined".
Contrary to the above, as of April 6,1979, corrective action had not been taken to resolve the lack of measures to satisfy QA progran requirements for protection of items in storage such as monitoring of inert gas pressure, monitoring of desiccant and shelf-life control.
This item was originally identified by the licensee on July 10, 1975, and subsequently in September 1977, in February 1978, and December 1978.
2.
The accepted Quality Assurance Program, Section 17.2.1.1 states in part that, "The policies described in the Corporate Quality Assurance Program Manual are implemented through departmental program manuals and proce-dures". The Policy Statement contained in the Corporate Quality Assurance Program Manual stated in part: "All matters concerning quality assurance which cannot be resolved at the normal interfaces among departments shall be referred to the Senior Vice President, Engineering and Construction".
Additionally, the Accepted Quality Ar,surance Program, Paragraph 17.2.2 states in part, "... Procedures and work instructions necessary to imple-ment the requirements of the operational quality assurance program are developed...".
Coatrary to the above, on April 6,1979, the requirement for following up audit responses which are late, inadequate, or improperly implemented was not prescribed by documented instructions or procedures and no documented method existed for bringing matters which cannot be resolved at the norraal interfaces among departments to the attention of the Senior Vice President, Engineering and Construction.
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Duke Power Company Appendix A Oconee Nuclear Station, Units 1, 2, and 3 Notice of Violation 3.
QA Procedure No. QA-210, Revision 6, dated October 1978, requires in paragraph 5.5.1.4 that audit reports include an evaluation regarding the effectiveness of that portion of the quality assurance program audited and in paragraph 5.5.3 that within thirty (30) calendar days after receipt of the audit report, responsible departmental management shall reply in writing to the audit report. Additionally, paragraph 5.5.3.2 requires that a follow-up report shall be provided by the audited organization stating the corrective action taken and the date corrective action was completed.
Contrary to the above, activities were not accomplished with procedures, in that of the audits reviewed for the periods March 1978, through March 1979, none had a follow-up report provided by the audited organization as required. Also, the response by the audited organization exceeded the thirty (30) calendar days (overdue from 4-19 days), for four of the five audits reviewed for which responses were required as of April 3, 1979. Additionally, one of the six audits reviewed did not contain the required evaluation.
4.
The accepted Quality Assurance Program Table 17.0-1 commits to ANSI N45.2.2-1972.
Section 6.1.2 of the Standard requires a level B ware-house to be weathertight. Additionally, Section 6.2.4 of the Standard prohibits the use or storage of food and drinks in the storage area.
Contrary to the above, rainwater leakage into the level B warehouse was noted in April 1979. Additionally, the consumption and storage of drinks and lunches was observed in a portion of the warehouse which was not segregated from the level B warehouse.
This is an infraction.
B.
As required by 10 CFR 50, Appendix B, Criterion XVIII, "A comprehensive 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 ef fectiveness of the program". The accepted Quality Assurance Program, Table 17.0-1, states that the program conforms to ANSI N45.2.12, Draf t 3, Revision 4, dated February 1974. ANSI N45.2.12, Draf t 3, Revision 4 dated February 1974, Paragraph 3.4.2 requires that " Applicable elements of the quality assurance program shall be audited at least annually" Contrary to the above, a comprehensive system of audits for all aspects of the QA program was not carried out in that no audit of General Office activities which affect the QA program at the Oconee site was conducted during the period from January 1, 1978 through April 5,1979. Specifically, the following activities were not audited:
1.
Document control and records (Criteria VI and XVII) 2.
Administrative procedure and staff review activities thereof (Criteria II and V) c ) {:
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Duke Power Company Appendix A Oconee Nuclear Station, Units 1, 2, and 3 Notice of Violation 3.
Staff review and inputs to procurement activities (Criteria IV, II and VII) 4.
Activities of the calibration lab (Criteria XII, X, XI and SVII) 5.
Staff review and input to plant modifications (Criteria III, II and V)
This is an Infraction.
C.
As required by 10 CFR 50, Appendix B, Criterion TII, " Design Changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization". The accepted Quality Assurance Program, Paragraph 17.2.3 states in part, "The control measures to each such modification revision are equivalent to the rontrol measures applied to the modification originally...".
Contra ry to the above, provisions were not established to require that revisions to safety-related Nuclear Station Modifications (NSM) be reviewed by the originating design organization; in that NSM-ON-0089, Revision six, changed the approved design modification as generated by the Design Engineering Department without submission of the design package back to the originating design group for review prior to approval and implementation of the revised NSM.
This is a deficiency.
D.
As required by 10 CFR 50, Appendix B, Criterion XIV, which states in part,
" measures shail be established to indicate, by the use of markings such as stamps, tags, labels,...the status of inspections and tests performed upon individual items of the nuclear pever plant..."The licensee's accepted QA program imposes ANSI N45.2.4-1972/IEEE Std. 366-1971.
ANSI N45.2.4-l')72, Paragraph 2.5.2, " Calibration and Control" states in part, " Measuring and test equipment used to determine compliance with specifications shall be adjusted and calibrated,... Records of the calibrations shall be maintained and equipment suitably marked to indicate date of next required calibration.. ".
Contrary to the above, measures were not established to indicate, by the ure of markings, the status of calibrations of installed safety-related instruments not identified in the Technical Specifications. None of the eleven installed safety-related instruments reviewed were marked to indicate the status of calibration.
This is a deficiency.
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