ML20023C301
| ML20023C301 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/27/1983 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20023C298 | List: |
| References | |
| 50-155-83-04, 50-155-83-4, NUDOCS 8305170168 | |
| Download: ML20023C301 (3) | |
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Appendix 1
1 Consumers Power Company Docket No. 50-155 As a result of the inspection conducted on January 1 - March 4, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality shall be pre-scribed by documented procedures of a type appropriate to the cir-cumstances and shall be accomplished in accordance with these pro-cedures.
The licensee's approved Quality Assurance (QA) Topical Report (CPC-2A) has been established to implement the requirements of 10 CFR 50, Appendix B.
CPC-2A states that the licensee's program complies with Regulatory Guide 1.33(2/78, Rev. 2) which endorses ANSI N18.7-1976.
Paragraph 5.2.2 of ANSI N18.7-1976 states in part, " Procedures shall l
be followed..."
Volume 13, Procedure 13-3, " Material Control," Rev. 35, establishes material storage, preservation and identification requirements.
Contrary to the above, the following discrepancies were found in the plant controlled storage areas:
The ends of pipe and tubing stored in the warehouse were not capped or taped.
(Procedure 13-3, Section 5.2.2)
Tape and shipping stickers which were not chloride-free were used on stainless steel tubing stored in the warehouse.
(Procedure 13-3, Section 5.2.2)
Storage areas of the warehouse were not maintained clean and dry.
Tags and empty crates littered the warehouse floor, and some card-board boxes located directly on the cement floor showed signs of water damage.
(Paragraph 13-3, Section 5.2.2)
Q-listed items stored by various plant groups in their own storage areas did not retain their " Accept" tags. Examples included electri-cal contacts, switches, resin barrels, tubing, piping, insulation, weld rod and an incore detector.
(Procedure 13-3, Section 5.9.1)
This is a Severity Level IV violation (Supplement I).
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Appendix 2
2.
10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program," requires that the applicant shall establish a quality assurance program which complies with the requirements of this appendix and that this program shall be carried out throughout plant life in accordance with these policies, procedures, or instructions.
The licensee's approved Quality Assurance (QA) Topical Report (CPC-2A) has been established to implement the requirements of 10 CFR 50, Appendix B.
CPC-2A states that the licensee's program complies with Regulatory Guide 1.38 (5/77, Rev. 2) which endorses ANSI N45.2.2-1972 (as modified by exceptions stated in CPC-2A, Appendix A, Part 2).
Contrary to the above, measures were not established in the Big Rock Point Plant Manual, Volume 13, to implement the following requirements of ANSI N45.2.2-1972:
Section 3.5.1 requires the use of caps and plugs to seal openings in items "having sensitive internal surfaces, and to protect threads and weld end preparations." The licensee's procedures only specify the use of caps or tape on the ends of all pipe. As a result, a valve and a heat exchanger having sensitive internal surfaces were stored without the use of caps and plugs.
Section 6.2.4 prohibits the use or storage of " food, drinks and salt tablet dispensers in any storage area..."
The licensee's exception to section 6.2.4 in their QA Topical Report permits the storage of " packaged food for emergency or extended overtime use...",
but their procedures do not prohibit the storage or use of other food and drink items in storage areas.
Lunch and soft drinks were stored in the storeroom.
Section 6.3.1 requires that all items be stored so as to permit
" ready access for inspection or maintenance without excessive hand-ling, to minimize risk of damage." No licensee procedures could be found which implemented this requirement. As a result, over-crowded pipe racks caused excessive handling which resulted in
" Accept" tags becoming separated from items.
Section 6.4.1 requires inspections and examinations of items in storage on a periodic basis. These inspections shall include such items as identification and marking, coatings and preservatives, desiccants and inert gas blankets and physical damage. The li-censee's procedures did not provide for inspections of items in storage areas other than the stockroom or warehouse and did not include the items listed above. As a result, items such as reagents, resins, and gas cylinders stored by various plant department were not inspected on a periodic basis.
This is a Severity Level IV violation (Supplement I).
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Appendix 3
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 statement or explanation in reply, including for each item of noncompliance:
(1) cor-rective 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 achieved. Consideration may be given to extending your response time for good cause shown.
Dated W. D. Shafer, Chief Projects Branch 2 1
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