ML19260A440
| ML19260A440 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 10/03/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19260A437 | List: |
| References | |
| 50-546-79-11, 50-547-79-11, NUDOCS 7911210122 | |
| Download: ML19260A440 (3) | |
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Appendix A NOTICE OF VIOLATION Public Service of Indiana Docket No. 50-546 Docket No. 50-547 Based on the results of the NRC inspection conducted on July 26, 27, 31 and August 1-3, 1979, it appears that certain of your activities were in noncompliance with NRC requirements, as noted below. These items are considered infractions.
1.
10 CFR Part 50, Appendix B, Criterion II requires, in part, that applicants shall establish a quality assurance program at the earliest time. "This program shall be documented.
. and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions." It also requires that the licensee's quality assurance program take into account the need for skills to attain the required quality and the need for verification of quality by inspection.
It requires the program to provide the necessary training of personnel performing activities affecting quality and requires the program to provide the control over activities affecting quality.
The Marble Hill PSAR Chapter 2, Section 1.7 and Chapter 17, Section 17.1.2 commits Public Service of Indiana to Regulatory Guide 1.58 and thereby ANSI N45.2.6 (1973). ANSI N45.2.6 Section 3.1 outlines the educational and experience requirements for personnel performing inspections and tests or who participate in approval of procedures, the evaluation of test data and the control of related quality records. The Marble Hill Generating Station Construction Manag-ment Manual Procedure CMP 3.10 and PSI QA Procedure QAP 6.8 address the educational and experience requirements for PSI QA/QC personnel.
Further, the Marble Hill PSAR Chapter 17, Section 17.1.1.1 states in part; "The PSI Quality Assurance Construction Group will be responsible for assuring that.
. activities performed by the construction contractors are in compliance.
This group will reside at the site, will perform surveillance of quality and quality related activities,
. control quality verification records... perform receipt inspection.
The personnel in this group have "stop-work" authority to prevent unsatisfactory work.
Contrary to the above, Public Service of Indiana has not sufficiently implemented its quality assurance program at the Marble Hill plant site.
For example:
a.
The management support, qualifications, numbers, and methods of operations of the site QA/QC group have been inadequate to assure that extensive licensee and contractor noncompliances have been identified, documented and corrected.
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Appendix A b.
At least 25 of 29 members of the site based Quality Control Organization do not have sufficient QA/QC and construction experience to qualify them for their current QC organization assignments and to this extent PSI procedures for personnel qualifications (CMP-3.10 and QAP 6.8) are nonconforming as implemented.
c.
The PSI Marble Hill Generating Station Construction Management Procedure Number CMP 3.7 which provides instructions for "stop-work" authority does not provide adequate independent authority to the QC organization, inspectors and engineers to prevent unsatis-factory work and assure control over subsequent resolution of identified nonconformances.
2.
10 CFR 50, Appendix B, Criterion IX states, in part, that " Measures shall be established to assure that special processes, including welding, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Paragraph 17.1.9.6 of Section 17 of the Marble Hill PSAR states in part that procedures, equipment and personnel connected with special processes are qualified as applicable in accordance with code, standards, and specifications or when necessary, supplementary procedures.
Contrary to the above, it was determined that, even though Chicago Bridge and Iron Weld Procedure Specification E7018/7303, Revision 1 dated June 20, 1977, underwent reviews by various orgonizations, including Sargent & Lundy, the reviews failed to ide_tify the omission of the weld technique to be used for passes other than vertical up and overhead, and included the same omission in subsequent revisions.
This weld procedure was being used to weld safety-related tanks on the site.
3.
10 CFR 50, Appendix B, Criterion XV, states, in part, that " Measures shall be established to control materials,
.. which do not conform to requirements.
These measures shall include, as appropriate, procedures for identification, documentation,
. disposition, and notification to the affected organizations ="
The Marble Hill PSAR Chapter 17, Section 17.1.15 reiterates the same requirement and further states that " PSI shall verify adherence to procedures and instructions for control of nonconforming materials through audits of principal contractors.
[
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Appendix A
- Contrary to the above, on August 1, 1979, it was determined by record review that Cherne nonconformance report number 6.94 involving piping material certification records, had been voided without adequate basis and made reference to other documentation which did not justify or provide a reason for voiding this NCR. Moreover, the licensee's representative could provide no other basis for the
" disposed" status of this nonconformance report.
4.
10 CFR 50, Appendix B, Criterion XVI requires, in part, that " Measures shall be established to assure that conditions adverse to quality are promptly identified and corrected." These measures are to preclude repetition of significant conditions that are adverse to quality.
The Marble Hill PSAR Chapter 17, Section 17.1.16 requires that PSI review and evaluate the reply to identified nonconformances in accordance with written quality assurance procedures to assure that the causes of the condition have been determined.
Contrary to the above, established measures did not assure that conditions adverse to quality were promptly identified and corrected.
For example:
a.
PSI Construction Management Procedures numbers CMP 3.1 and CMP 1.4 are insufficient in both text and implementation in that in many instances sufficient corrective action to prevent repetition of significant conditions adverse to quality has not occured.
For example:
over a twelve month period Newburg-Marble Hill issued ninety-one (91) field nonconformance reports identifying areas of defective concrete (i.e. honeycomb). However, this condition was not viewed by PSI as a serious trend requiring additional corrective action until April 1979.
b.
PSI was made aware of serious issues involving noncompliance and potential nonconpliance with ASME Code requirements regarding owners responsibilities and material certification documents in July 1977, June 1978, July 13, 1978, May 14, 1979, March 9, 1979, June 6, 1979, and July 27, 1979, by virtue of letters on these dates from site contractors identifying these issues.
However, no comprehensive and conforming corrective actions were initated until July 1979 after a National Board of Boiler and Pressure Vessel Inspectors inspection report regarding these matters was issued.
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