ML20010C260
| ML20010C260 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/12/1981 |
| From: | Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010C257 | List: |
| References | |
| 50-461-81-18, NUDOCS 8108190292 | |
| Download: ML20010C260 (3) | |
Text
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Appendix A NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 As a result of the investigation conducted during the teriod April 1-June 18, 1981, 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 V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.'"
Clinton Power Station Quality Assurance Manual, Chapter 5 (Instructions, Procedures and Drawings), states, in part, "IP and its contractors shall meet the following requirements:
- 1. Written procedures, instructions, and drawings shall be developed and used, as appropriate, for activities affecting quality..."
a.
Clinton Power Station Quality Assurance Manual Chapter 16 (Corrective Action) states in part, "IP and its contractors shall meet the following requirements:
4.
Conditions adverse to quality shall be systematically analyzed for causes and referred to management for resolution..."
Zack Company Quality Control Procedure No. PQCP-20 (Procedure for Trend Analysis), Revision 0, approved for use on December 18, 1980, states in part, "7.1 On or before the 14th of every i
month each NCR, Surveillance and Audit Finding initiated and/or closed by the Zack Company...is review by the QAM (Quality Assorarce Manager).... On or before the 21st of every month a graph...is prepared which details the gross quantities of open items per location / category for the month.... On or before the 24th of every month the documents generat.d in Paragraphs 7.2 through 7.4 are transmitted to...Zack C_ mpany personnel for review and/or action...
Contrary to the above the Zack Company did not prepare a trend analysis for the Clinton site for January 1981, even though thirteen Nonconformance Reports (NCRs) were prepared at the Clinton site, during January 1981, for nonconformaning conditions pertaining to drawing M14-1108-6.
This is a Severit! Level V violation (Supplement II E).
8108190292 810812 PDR ADOCK 05000461 o
Appendix A b.
Sargent & Lundy Engineers Specification No. K-2910, Specification for HVAC Work, Clinton Power Station - Unit 1, Illinois Power Company, paragraph 303.12a, states in part, " Duct Modifications...
Contractor will be permitted minor duct modifications in the field with approval of Purchaser's or Owner's representative for non-seismic dact systems only..."
Contrary to the above, the Zack Company fabricated seismic duct pieces and hangers in the field at Zack's Clinton Power Station fabrication shop.
This is a Severity Level V violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion XV, states, in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
These measures shall include, as appropriate, procedures for identi-fication, documentation, segregation, dispostion, and notification to affected organizations..."
Clinton Power Station Quality Assurance Manual, Chapter 15 (Noncon-forming Materials, Parts, or Components), states, in part, "IP and its contractors shall meet the following requirements:
2.
Nonconforming items shall be clearly identified...
4.
Measures shall be established which control further use or installation of nonconforming items pending disposition...
5.
A technical review shall be performed to determine the dis-position of nonconforming items. The technical review shall be conducted by the same or equivalent organization which established the original design requirements...
8.
Procedures for control of nonconformances shall include mea-sures for notification to affected organizations..."
Clinton Power Station Quality Assurance Fanual Chapter 16 (Corrective Action), states, in part, "IP and its contractors shall meet the following requirements:
- 4. Conditions adverse to quality shall be systematically analyzed for causes and referred to management for resolution..."
Zack Company Procedure No. CB-FQCP-8, Revision 1 (Procedure for NCR), states, in part:
"5.1 Project Manager... responsible for the resolution of noncon-forming conditions related to material or fabrication...
Appendix A "5.2 Quality Control Manager... responsible for inspecting the ma-terial or equipment as it is... installed to ensure that proper control is maintained to prevent material or equipment that is nonconforming from being incorporated into the work... Responsible for controlling non-conforming items until the nonconformance has been corrected or the item removed from the project..."
Contrary to the above, Zack Nonconformance Report No. ZC-CB-325, prepared on December 12, 1980, was closed by the Zack Company on March 13, 1981, and was never forwarded to Baldwin Associates for review by the consulting engineers (Sargent & Lundy). Additionally, the nonconforming items were never individually tagged to identify the duct pieces as being nonconforming. The NCR pertained to the qualification of Zack welders performing butt welds.
This is a Severity Level V violation (Supplement II).
J With respect to Item Ib, the investigation showed action had been taken to correct the identified item of noncompliance and to prevent recurrence. Con-sequently, no reply to this item of noncompliance is required and we have no l
further questions regarding this matter. With respect to Items la and 2, pursuant to the provisions of 10 CFR 2.201 you are required to submit to this office within thirty days of the date of this Notice a written state-ment or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2)c orrective action to be taken to avoid further noncompliance; and, (3) the date when j
full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be sub-mitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.
l gur, T2 10M c-i MJ h73E~
Dated John'F. Streeter Actinh Director, Enforcement and Investigation Staff
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