ML20010J656
| ML20010J656 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/17/1981 |
| From: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010J654 | List: |
| References | |
| 50-271-81-07, 50-271-81-7, NUDOCS 8110060318 | |
| Download: ML20010J656 (3) | |
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APPENDIX A NOTICE OF VIOLATION Vermont Yankee Nuclear Pcwer Corporation Docket No.
50-271 License No. DPR-28 As a result of the inspection conducted on March 25-27 and April 1-3, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified:
10 CFR 71.12, " General license for shipment in D0T s>ecification containers, in packages approved for use by another person, and in packages approved by a foreign national competent authority," states, "A general license is hereby issued to persons holding a general or specific license issued pursuant to this chapter, to deliver licensed material to a carrier for transport, provided the licensee has a quality assurance program, whose description has been submitted to and approved by the Commission as satisfying the provisions of 10 CFR 71.51."
10 CFR 71.51(a), " Establishment and maintenance of a quality assurance program," states, "The licensee shall establish, maintain and execute a quality assurance program satisfying each of the applicab_le criteria specified in Appendix E, ' Quality Assurance Criteria for Shipping Packages for Radioactive Material,' and satisfying any specific provisions which are applicable to the licensee's activities including procurement of packaging.
The description of the quality assurance program shall include a discussion of which requirements of Appendix E are applicable and how they will be satisfied."
10 CFR 71.51(d), states, "A Commission-approved quality assurance program which satisfies the applicable criteria of Appendix B of Part 50, of this chapter and which is established, maintained and executed with regard to transport packages shall be deemed to satisfy the requirements of paragraph (a) of this section." Quality Assurance Program Approval for Radioactive Material Packages, Approval No. 0068, issued by the Commission authorized the use of Appendix B.
Contrary to the above, the licensee made at least four shipments of licensed material during 1980 without a license inasmuch as the following criteria of the licensee's Commission-approved quality assurance program had not been implemented as of March 26, 1981:
10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program" states in part that, "The applicant shall establish at the earliest practicable time, consistent with the schedule for accomplishing the 1
activities, a quality assurance program which complies with the l
requirements of this appendix...
The applicant shall identify the structures, systems, and components to be covered by the quality assurance program..."
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Appendix A 2
As of March 26, 1981, the licensee had not identified the packages for shipping radioactive material as covered by the quality assurance program.
10 CFR 50, Appendix B, Criterion IV, " Procurement Occument Control" states, " Measures shall be established to assurs chat app;icable regulatory requirements, design basis and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, l
and services, whether purchased by the applicant or by its contractors or subcontractors.
To the extcat necessary, procurement documents shall require contractors or subcontractors to provide a quality assurance program consistent with the pertinent provisions of this appendix."
As of March 26, 1981, the licensee's procurement documents for the purchase of Liners, integral parts of certain shipping packages, did not require the vendors to provide a quality assurance program for the Liners consistent with the pertinent provisions of Appenatx B.
10 CFR 50, Appendix B, Criterion VI, " Document Control," states,
" Measures shall be established to control the issuance of documents, such as instructions, procedures and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
On fiarch 26, Procedure No. 0.P. 2153, Revision 5, " Solid Radwaste,"
was not located in the solid radwaste compacting area, the area where the prescribed activity is performed.
10 CFR 50, Appendix B, Criterion XIV, " Inspection, Test and Operating Status," states, " Measures 2 hall be established to indicate, by the use of markings such as stamps, tags, labels, routing cards or other suitable means, the status of inspections and tests performed upon individual items of the nuclear power plant or fuel reprocessing plant.
These measures shall provide for the identification of items which have satisfactorily passed required inspections and tests, where necessary to preclude inadvertent bypassing of such inspections and tests."
As of March 26, 1981, the licensee had not established measures to indicate the status of inspections and tests performed upon the Liners and 55 gallon drums.
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Appendix A 3
l 10 CFR 50, Appendix B, Criterion XVIII, " Audits," states, "A compre-hensive system of planned and periodic audits shall be carried cut to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures j
or check lists by appropriately trained personnel not having direct l
responsibilities in the areas being audited."
The licensee performed an audit on April 30, 1981 and May 1 and 2, 1980 (Report No. VY 80-03), but the audit was inadequate, inasmuch as it did not verify compliance with the requirement for a quality assurance pregram for waste shipping packages.
This is a Severity Level IV Violation (Supplement V).
Pursuant to the provisions of 10 CFR 2.201, Vermont Yankee Nuclear Power Corporation is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be 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. Where good cause is shown, consideration will be given to extending your response time.
The responses directed by this Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Dated 17 SEP 1981 Original Signed Ey Eldon J. Brunner, Chief f
Projects Branch #1, Division of Resident and Project Inspection 1
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