ML19350A663

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Notice of Deviation from Insp on 801103-06
ML19350A663
Person / Time
Issue date: 12/15/1980
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19350A658 List:
References
REF-QA-99900519 NUDOCS 8103160617
Download: ML19350A663 (1)


Text

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J Bechtel Power Corporation Gaithersourg Pcwer Divisien Occket No. 99900519 NOTICE CF DEVIATION 4

Based on the results of an NRC inspection conductec oa Lve:::er 3

,1950, it appears that certain of your activities were not eencucted in accorcance itn NRC recuirements.

A.

Criterion V of Acpencix 3 to 10 CFR 50 states:

" Activities affecting quality snall be ;:rescribed by ccc=ented instructions, procecures, or drawings, of a type a::preoriate to the circumstances and shall be acccanlished in accercance witn nese instructions, procedures, or crawings.

Instructions, prececures, or drawings shall incluce apprcpriate quantitative or qualitative acce:-

tance criteria for determining that i=::ortant activities nave ::een satisfactorily accomplished."

Deviations frem tnese requirements are as folicws:

Section 3.6.1. of Quality Assurance Decartment Prececure No. 16.1-1 (Evaluating Conditions Acverse to Quality for Significance anc Re::crtanility) Revision 1 cated July 1980 states in part that the Management Corrective Action Recort (MCAR) shall be used for peccessing re;crtacle ite=s as defined uncer the criteria of Sections 3.3 - 3.5, as determined ty tse assigned QAE or PQAM.

One of the criteria free Section 3.3 is "A significant ceficiency in final design as approved and released for construction so that the design dces not conform to the criteria and basis stated in the safety analysis rescrt."

Centrary to the abcve, an. EAR was not used for processing a rerortacle ites as defined by Section 3.3, whicn if left uncorrected could 'a,e resulted in a loss of shutdcwn cooling function to tne reacter curing a !.CCA.

(See Details Section 1, paragra::n C.3.b.)

3.

The SNUPPS Final Safety.$nalysis Report, Chacter 17. A., c mits Becntel to meeting the requirements of ANSI N45.2.11.

ANSI N45.2.11, Section 8, Design Change Centrol, recuires that "Occ= entec precedures shall be providec for cesign enanges to a:orevec design coc=ents, inclucing field enanges, which assure that ne i cact of tne cnange is carefully ansicered, equired actions cocumentec and infer:ation c::ncerning the cnanges shall be justified and subjected to cesign c::ntrol seasures commensurate with those acplied to the original cesign."

Contrary to this requirement, a design enange to the Ccenenent Cccling ' dater System (CC'45) of the SNUP?S project cid not cec =ent tne consicerec i=cact of the change nor was tne change justifiec anc suojectec to cesign c:ntroi

teasures cc:rnensurate with those a:: plied to tne original ccsign.

(See DetailsSection II, paragrapn 3.3.)

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