ML19309F737
| ML19309F737 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 03/18/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19309F736 | List: |
| References | |
| 50-546-80-03, 50-546-80-3, 50-547-80-03, 50-547-80-3, NUDOCS 8004300528 | |
| Download: ML19309F737 (6) | |
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Q 8004800 @$h Appendix A NOTICE OF VIOLATION Public Service of Indiana Docket No. S'0-546 Docket No. 50-547 Based on the results of an NRC inspection conducted between January 7 and 31, 1980, it appears that certain of your activities were *.ot conducted in full compliance with NRC requirements as noted below. Each item is an infraction.
See the enclosed report details for a full description of these infractions.
1.
10 CFR 50, Appendix B, Criterion IV states in part that, " Measures shall be established to assure that applicable regulatory require-ments, design bases, and other requirements which are necessary to assure adequate quality are suitable and included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcon-tractor."
The Marble Hill Preliminary Safety Analysis Report, (PSAR) Chapter 17, Section 17.1.4.1 established the same basic criteria as Crite-rion IV and in addition states that, "a technical review.
shall be conducted by the PSI Project Engineering Group to assure.
technical requirements.
" and "a quality assurance review.
by PSI Quality Assurance Design and Procurement Group..., it should be noted that such reviews were conducted on a " selected basis". The Marble Hill PSAR Chapter 1, Section 1.7 also commits to the intent of Regulatory Guide 1.38 (March 16, 1973) and there-fore to ANSI N45.2.2 (1972); including Section 6 relating to stor-age and preservation of equipment and material.
Contrary to the above, Public Service of Indiana failed to assign the responsibility to a site contractor for the storage and pre-servation of the Reactor Vessels in a procurement document. There-fore an effective program in this area was not established.
It should be noted that during this inspection, field extra work authorizations were issued by PSI to assign this responsibility and control this activity.
2.
10 CFR 50, Appendix B, Criterion V in part requires that, "activi-ties affecting quality shall be prescribed by documented instruc-tions, procedures, or drawings, or a type appropriate to the cir-cumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Appendix A -
The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.5.1 states in part that, " PSI requires each contract-ing organization to develop and implement written instructions,
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procedures, or drawings for performance of all quality related activities... Clear delineation of the sequence of action to be accomplished in the preparation, review, and control of instruc-tions, procedures, and drawings is provided by a PSI quality as-surance procedure and is required of all PSI contractors. "
It further states that, " PSI shall verify the existence and satis-factory implementation of required instructions, procedures, and drawings through its audit and surveillance programs (internal and external).
Contrary to the above, approved and controlled procedures were not available relative to the storage and preservation of equipment such as the Reactor Vessel Heads, Reactor Vessels, and Reactor Vessel Internals.
3.
10 CFR 50, Appendix B, Criterion X in part requires that, "A pro-gram for inspection of activities affecting quality shall be es-tablished and executed by or for the organization performing the activity to conformance with the documented instructions, proce-dures, and drawings for accomplishing the activity".
The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.10.1 states in part that, " Inspection programs shall be established and implemented by or for contractors performing activities affecting the quality of safety-related products or materials.... Inspections or tests are performed for each work operation as necessary to verify quality.... PSI shall verify adherence to procedures and instructions by construction contrac-tors for inspection through surveillance.
Surveillance of storage and storage maintenance is required to be in accordance with Marble Hill Generating Station Construction Management Manual Procedure CMP 3.4.
Contrary to the above, Public Service of Indiana failed to implement an adequate inspection program in that:
Inspections were not conducted on a periodic basis as required a.
by CMP No. 3.4, Sections 4.1 and/or on a scheduled basis as required by Section 4.2.
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Appendix A
- b.
Inspections conducted did not include observation of special storage conditions as required by CMP No. 3.4, Section 4.1; i.e., nitrogen purges; desiccants. This includes equipment /
material stored by PSI and contractors.
Several surveill ace reports and checklists were reviewed and the applicable sec-tions for desiccant and purges were noted and were marked
("NA" not applicable),
c.
The inspections (surveillances) that were conducted failed to i
address the full scope of the inspection activity, for example, the surveillance reports related to storage of the reactor vessels and steam generators only reported conditions of the laydown areas in which this equipment was being stored and did not include inspection of the actual equipment.
4.
10 CFR 50, Appendix B, Criterion XIII in part requires that, " Mea-sures shall be established to control the handling, storage, ship-ping, cleaning, and preservation of material and equipment in accordance with 5 ek and inspection instructions a prevent damage or deterioration.'
Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.13 states that, " PSI Quality Program Manual includes procedures governing the handling and storage of owner furnished materials at the construction site.
Instructions will be developed by the PSI Marble Hill Construction Organization to supplement special pro-cedure and requirement issued by the suppliers and principal con-tractors. The PSI quality assurance specification governing prin-i cipal contractors and contractors provides for passing applicable requirements on to their subcontractors and suppliers as appropriate.
The Marble Hill Generating Station Construction Management Manual Procedure No. 4.2, " Storage and Handling of PSI Purchased Materials" establishes storage and handling requirements.
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Contrary to the above, Public Service of Indiana failed to comply with these requirements relative to storage and preservation in that:
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a.
S Mrage instructions were not provided for all equipment.
Those which were prepared were not completed in a timely man-ner, as required by Procedure No. 4.2, Section 4.1.6 for the equipment with special storage and preservation requirements.
Adequate and timely procedures for Units 1 and 2 Reactor Vessels, Reactor Vessel Heads, and Unit 1 Steam Generator and Pressurizer were not available and are examples of this finding.
b.
Storage instructions required Procedure No. 4.2, Section 4.1.6 were deficient in that the equipment manufacturer's requirements, recommendations, and inspection plans were not included. This i
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Appendix A
- is exemplified by the procedures for the Units 1 and 2 Reactor Vessels and Reactor Vessel Heads and Unit 1 Steam Generators and Pressurizer.
c.
Procedure CMP 4.2 does not clearly establish how storage and handling instructions are transmitted or communicated to the site contractors responsible for storage and preservation activities.
d.
The storage instructions written in accordance with Procedure No. 4.2, Section 4.1.6 for Unit 2 Reactor Vessel were deficient in that the applicable " Additional Storage" attributes were not identified.
5.
10 CFR 50, Appendix B, Criterion XV and the Marble Hill Preliminary Safety Analysis Report, Chapter 17, requires in part that, " Measures shall be established to control materials, parts, or components which do not conform to requirements... These measures shall include, as appropriate, procedures for identification, documenta-tion, segregation, disposition,.
The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.15 also states that, "The PSI Quality Assurance Program provides for control of nonconforming items discovered by PSI."
The Marble Hill Generating Station Construction Management Manual Procedure 3.1, " Control of Field Nonconformances", establishes measures for control of the subject documents.
Contrary to the above, Public Service of Indiana failed to comply with these requirements in that:
Procedure Nc. CMP 3.1 provides a dual system for reporting a.
field nonconformances.
Section 4.2 addresses use of Field Corrective Action Requests (FCAR) for those " Discrepancies or concerns..., that are not significant in nature.
i Section 4.3 addresses the use of Deviation Control Record l
(DCR) to report.
. a deficiency or nonconformance relating to a construction phase.
l However, nonconformances of a significant nature were reported l
on a FCAR in lieu of a DCR; as required. FCAR No. 253 and l
No. 290-79 are examples of this misapplication.
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,.pendix A -
b.
The description of the Discrepancy / Deviation on the FCAR's and DCR's failed to accurately identify the nonconformance substance as required by Procedure No. 3.1, Sections 4.,2 and 4.3. Therefore, proper corrective action was compromised.
For example, FCAR No. 253 was inaccurately reported leading to ineffective corrective actions.
c.
FCAR's were not being processed as required by Procedure No. 3.1, Section 4.2.3 thereby compromising the PSI Construc-tion Engineering, Design Control Supervision and Quality Engineering Departments ability to perform engineering and quality evaluations. The responsibility of these organiza-tions was not clearly stated in this procedure.
In numerous cases, the sane individual (QC Inspector) was the FCAR initia-tor, corrective action initiator, and QC representative verify-ing corrective action. Many of these corrective actions were inadequate.
6.
10 CFR 50, Appendix B, Criterion XVI requires that, " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, defective material, equipment, and nonconformances were promptly identified and corrected.
In 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 documented and reported to appropriate levels of management.
The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.16 states that, " Conditions adverse to quality may be identified through PSI review of documents, conduct of surveil-lance, performance of audits, and conduct of preoperational and startup testing. Failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances identified by PSI shall be documented on PSI Deviation Control Records by the cognizant PSI reviewer, auditor, or inspector."
Corrective action measures are required by Marble Hill Generating Station Construction Management Manual Procedure CMP No. 3.1, Control of Field Nonconformances.
Contrary to the above:
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Appendix A -
a.
Reporting of significant nonconformances, in accordance with Procedure No. CMP 3.1, Section 4.2, (issuance of the Field Corrective Action Request, FCAR) was inadequate in that a mechanism was not available to (1) identify the cause of the condition; (2) provide action to preclude repetition, and (3) report to appropriate levels of management.
b.
Corrective action taken in response to Field Corrective Action Requests (FCAR's) as required by Section 4.2.3, failed to adequately address the subject of the nonconformance, i.e.,
FCAR 190-79 dated August 15, 1979. Moreover, neither project engineering departments were involved in the corrective action process.
c.
Numerous nonconformance reports (twenty-five) were found where-in the corrective action was not timely or expeditious as is required by Procedure No. CMP 3.1, Section 1.0.
Considerable time passes with no actions taken or the actions taken were incomplete. Some of these issues were "open" for four to twelve months for no apparent reason. For example, FCAR No.
364-79 dated September 11, 1979 and FNR No. 083 d&ned October 17, 1978 had not been resolved.
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