ML20024D414
| ML20024D414 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 07/20/1983 |
| From: | Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024D413 | List: |
| References | |
| 50-305-83-09, 50-305-83-9, NUDOCS 8308050002 | |
| Download: ML20024D414 (3) | |
Text
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4 Appendix NOTICE OF VIOLATION Wisconsin Public Service Docket No. 50-305 Corporation As a result of the inspection conducted on June 6-8, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9,1982), the following violations were identified:
A.
Technical Specification Section 6.5.3.8 requires that audits include conformance of the plant operation to the provisions contained within the Technical Specifications and applicable license conditions at least annually.
10 CFR 50, Appendix B, Criterion XVIII, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Quality Assurance Program.
Contrary to the above, audits which are conducted to verify conformance of plant opers. tion to the provisions contained within the Technical Specifications and applicable license conditions were not adequate, in that provisions contained in the Technical Specifications have been randomly audited with no program established to audit all the provisions within a specified time period.
This is a Severity Level V violation (Supplement I).
B.
10 CFR 50, Appendix B, Criterion II, requires that the Quality Assurance Program be documented by written policies, procedures, or instructions, and be carried out in accordance with these policies, procedures, or instructions.
Operational Quality Assurance Program, Section 13, requires that plant personnel who will be performing inspection, examination and testing activities be qualified in accordance with ANSI N45.2.6-1973,
" Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants".
ANSI N45.2.6-1973 requires in Section 2 that each person who verifies conformance of work activities to quality requirements be certified by his employer as being qualified to perform his assigned work and a documented certificate shall include the basis used for certification.
The WPSC Operational Quality Assurance Program committed to Regulatory Guide 1.58, Revision 1, position 6 on September 15, 1982. This was in response to Generic Letter 81-01 and delineated specific education and experience requirements for personnel performing inspection, examination and testing activities.
8309050002 830720 PDR ADOCK 05000305 G
Appendix 2
Contrary to the above, the following examples of noncompliance were identified:
1.
The Level II certified quality control inspectors, who verified conformance of work activities to quality requirements, were not certified in accordance with the education and experience require-ments stipulated on September 15, 1982 by the licensee in response to Generic Letter 81-01.
2.
Two Quality Control inspectors were verifying conformance of work activities to quality requirements prior to their certification as Level I inspectors.
Tnis is a Severity Level V violation (Supplement I).
C.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures.
Contrary to the above, the following examples of noncompliance were identified.
1.
Forms which were not referenced by procedures or instructions were being used to document the results of inspections, examinations, and tests important to quality. Procedures or instructions had not been established to control the use, distribution, or retention of the forms.
2.
Procedures or instructions had not been established which prescribed the methods to assure that conditions adverse to quality are identi-fied, enntrolled, and corrected during maintenance or modifications to structures, systems, or components.
This is a Severity Level V violation (Supplement I).
D.
10 CFR 50, Appendix B, Criterion II, states in part that the Quality Assurance Program shall provide for indoctrination anu iraining of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
The WPSC Operational Quality Assurance Program Description, dated September 28, 1982, states that the program complies with the provisions of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." ANSI N18.7-1976, Section 3.3, requires that proviolons shall be made for indoctrination and training of those personnel in the owner organization performing activities affecting quality to assure that suitable proficiency is achieved and maintained, including as a minimum procedures or instruc-tions which implement the program related to the specific job-related activity. Additionally, the WPSC Operational Quality Assurance Program,
Appendix 3
Section 13, states that the training program shall provide suitable training of other station personnel who do not have to obtain an NRC operating license, and the training shall be provided to achieve special skills required in the performance of plant operation, including job-related procedures and instructions.
Contrary to the above, a training program has not been established which includes formalized training in job-related procedures, instructions, codes and standards for personnel such as supervisors, engineers and other professionals.
This is a Severity Level V violation (Supplement I).
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.
y."
^ 0 1983 1hh Dated J. F. Streeter, Chief Engineering Branch 1