ML19351G117
| ML19351G117 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/12/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19351G111 | List: |
| References | |
| 50-329-80-32, 50-330-80-33, NUDOCS 8102230143 | |
| Download: ML19351G117 (3) | |
Text
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Apper. dix A NOTICE OF VIOLATION IConsumersPowerCo.
Docket No. 50-329 Docket No. 50-330 As a result of the inspection conducted on December 8 - 11, 1980, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion XVI states, in part, that "Heasures shall be established to assure,that conditions adverse to quality such as... deficiencies...are promptly... corrected. The measures shall assure that the cause...is determined and corrective action taken to preclude repetition."
Consumers Power Co. QA Program, Policy No. 16, corrective action states,'
in part, that " corrective action is that action taken to correct and pre-clude recurrence of significant recurrc ace of significant conditions advctse to the quality of items... Conditions or trends observed or identified which are adverse to quality are considered for corrective action..."
tie "FSAR Re-review Procedure" instructions for Block 8 requires that "t he engineering sign documents against which the FSAR review package is to be reviewed are listed by the primary review engineer."
CPC0 Audit No. M-01-53-0 states, in part, "the following significant items were revealed by this audit...in many instances not all of the design documents were listed as required by the instructions for per-forming the re-review."
Contrary to the above, CPCO did not initiate preventive action to pre-clude repetition of not identifying design documents for the remaining re-review packages as evidenced by the inspectors review of other FSAR re-review packages which did not include all of the design documents.
In addition, interviews with some of the primary reviewers indicated that they were not reviewing the FSAR for technical accuracy against references at the end of the FSAR chapter as required by the procedure.
Based on the above, the adequacy of the FSAR re-review is in question.
This is a Severity Level IV violation (Supplement II).
2.
10 CFR 50, Appendix B, Criteria III, states, in part, that " Measures shall be established to assure that... design bases...are correctly translated into specifications...and for the identification and control of design interfaces...these measures shall include the establishment of procedures...for the review of documents involving design interfaces."
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Appendix A,
Consumers Power Co. QA Program, Policy No. 3 states, in part that "Each group... performing detailed design t ranslates the applicable regulatory requirements... design criteria into design documents, such as specifica-tions... procedures.
The design organization... establishes and controls the interface with other design organizations, a.
Bechtel EDPI 4.25-1, Section 6.1, states, in part "Each originating design group shall maintain a log of all documents which are routed to personnel external to the design group. These logs shall be re-tained...providing visibility of the projects design interface control.
Contrary to the above, Bechtel Civil Project Engineering group did not maintain a coordination log of specification and specification change notices as evidenced by our review of soils related specifica-tions C-211 and C-210.
b.
ANSI N45.2.11, Paragraph 4.1 requires that applicable design inputs are correctly translated into specifications drawings, procedures or instructions.
In addition, Paragraph 7.0 requires that documents including changes are reviewed for adequacy.
Consumers Power Co. 's 50.54(f) response, Page I-17, Paragraph 4(a) required that specification change notice (SCN)-9004 be issued to require a laboratory compaction test to be performed for each field density test.
SCN-9004 was initiated on 4/13/79.
Contrary to the above, Revision 16, dated 8/24/79, to the present Revision 20 of specification C-208 did not correctly translate SCN-9004 as a requirement into the specification. Revision 16 permitted laboratory density tests to be performed at a frequency as determined by the geotechnical engineer rather than for each field der.sity test performed.
c.
ANSI N45.2.11, Paragraph 8.2 requires that design changes be reviewed and approved by the same groups or organizations which reviewed and approved the original design documents.
Consumers Power Co. 50.54(f) response, Page 23-11 committed to revise existing design control measures and require design interfaces on design changes. EDPI 4.25.1, Revision 7 added Section 4.2 which states, "It is the responsibility of the originator of a design change to effect coordination of the change with all groups which reviewed and/or used the original or subsequent revisions of that design document."
Contrary to the above, Revision 8 to EDPI 4.25.1 permits the group supervisor to waive the design interface requirement by adding to Section 4.2, "as determined by the group supervisor of the discipline which originated the document." Revision 8 does not establish adequate measures as required by ANSI N45.2.11 or as committed per 50.54(f) response.
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Appendix A.
l This is a Severity Level IV violation (Supplement II).
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. 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 i
or explanation in reply, including for each item of noncompliance:
(1) correc-tive action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be I
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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