ML20038B646
| ML20038B646 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 09/14/1981 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20038B632 | List: |
| References | |
| LAC-7773, NUDOCS 8112080459 | |
| Download: ML20038B646 (7) | |
Text
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D DA/RYLAND COOPERAT/VE
- PO BOX 817 2615 EAST AV SOUTH LA CROSSE, WISCONSIN S4601 (608) 788 4 000 September 14, 1981 In reply, please refer to LAC-7773 DOCKET N0. 50-409 Mr. C. E. Norelius, Director Division of Engineering & Technical Inspection U. S. Nuclear Regulatory Commission Directorate of Regulatory Operations Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE B0ILING WATER REACT 0P (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 IE INSPECTION REPORT NO. 50-409/81-12
Reference:
(1) Letter, Norelius to Linder, dated August 17, 1981 Gentlemen:
In response to your letter (Reference 1) which fonvarded a notice of apparent non-compliance with NRC requirements as a result of the subject inspection, we are submitting the following information:
ENFORCEMENT ITEM VIOLATION 1.
10 CFR S0, Appendix B, Criteria II, states in part, "The applicant shall establish at the earliest practical time, consistent with the schedule for accomplishing the activities, a quality assurance program which conplies with the requiremente of this appendix.
This progran shalt be documented by unitten policies, procedures, or instructione and shall be carried. out throughout plant life in accordance uith these policies, procedures, or instructions."
Eciryland Power states in part in Section XVIII of the eTanuary,1975, Quality Assurance Program Description (Revision 1) under storage requiremente:
"1.
Originale of permanent recorde are stored in a closed, fire-retardant cabinet (vault) designed to accommodate all recorde on file at the honc office.
8112080459 811202' PDR ADOCK 05000409 G
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Mr. C. E. Norelius, Director September 14,.1981 Division of Engineering & Technical Inspection LAC-7773 "2.
On-site storage facility is constructed in euch a manner as to cafeguard the contente from extreme temperature and moisture variations.
"5.
Storage requiremente shall meet the intent of ANSI N45.2.9, "Requiremente for Collection, Storage and Haint2 nance of Quality Assurance Reco&e," as it applies to identification and retention of records."
ANSI N45.2.9 - 1974 states in part in paragraph 3.2.2, "The quality assurance recorde shall be tietad in an index. The inde: ehatt indicate, as a minimum, record retention times, where the reconde are to be stored and the location of the recorde within the storage area."
ANSI N45.2.9 - 1974 states in part in paragraph 5.3, " Prior to storage of recode in a quality assurance record fils, a written storage procedure shall be prepared and a custodian shall be designated u<'.th the responsibility to enforce the procedure. This procedure shalt include the foltouing as a minimi.m:
2.
The filing eyetem to be used.
4.
A method of verifying that the recorde agree uith the pre-established reconia chenk tiet."
Contrary to the above, the following exanples of noncompliance vere identified:
a.
The re:ord vault, where completed QA recorde are stored, has a wooden accese door that le not fire retardant and voutd not safeguard the records from an e=varnal fire.
b.
An inde: has not been formulated, indicating uhere the records are to be stored and the location of the recorde within the storage area.
c.
A procedure has not been unitten that includes the filing system to be used and the method for verifying that the recorde agree uith the pre-established reccris check tiet. A filing eyatem has not been established and approved by management.
DPC RESPONSE.
The concrete and masonry record storage room is protected by an automatic Halon fire suppression system..The external building is alm constructed of concrete and masonry materials. The only entrance door to is area will be replaced with a two-hour steel fire rated door. Procur" of this door has been initiated and it will be installed shortly after remipt, with completion estimated to be prior to January 1,1982.
LACBWR Administrative Control Procedure (ACP) 18.1, " Collection, Storage and Maintenance of LACBWR Quality Assurance Records," establishes the requirements for the collection, storage, maintenance and retention of Quality Assurance - - -
c Mr. C. E. Norelius, Director September 14, 19 81 Division of Engineering & Technical Inspection LAC-7773 records associated with the design, manufacture, construction and operation of LACBWR. LACBWR Administrative Control Procedure (ACP) 07.2, Central Subject File," describes the subject classification system used in the LACBWR central subject file.
Material which is transferred from the central subject file from the general office area is placed in the record storage room by topics identified in the central subject file index. The location has not been specified; however, the arrangement is simple and documents are retrievable. The filing system which is used for the central subject file is in accordance with an approved procedure. ACP 18.1 will be revised to include specific instructions for the use of the record storage room.
Construction and pre-operational records were turned over to Dairyland for possession and use by Allis Chalmers in Mcordance with the tenns and conditions of the Supplemental Agreement between Dairyland Power Cooperative and the U. S. Atomic Energy Commission dated August 6,1973. The index of these records will be incorporated by reference in Administrative Control Procedure 18.1.
VIOLATION 2.
10 CFR 50, Appendi: B, Criteria XIII, states in part, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance oith work and inspection instructions to prevent damge or deteriorati?n."
In accordance with the provisions of 10 CPR 50.SS(a), Dairyland Power has committed to Section XI of the ASVE B & PV Code,1974, IWB-4423, which requires that covered electrodes be kept in ovens at temperatures between 225*F to 350*? and not be out of an oven for over 20 minutes unless returned to the holding oven and held at 225*F to 350*P for at least eight hours before reissue.
Contrary to the above, measures have not been established to control the storage of veld rod to prevent damage or deterioration vith respect to E7018 dry, covered electrodes as stated in 1WB-4423, in order to insure specific moisture content levels, and the follouing examples of non-compliance were identified:
The Control of Weld Material Procedure, ACP 10.3, Revision 3, has not established oven temperature parameters for dry, covered electrodes. In addition, ACP 10.3 does not address the issue of dry, covered electrodes being out of an oven for an extended period of time and subsequent return to a holding oven before reissue. As a result, E7018, Heat No. 67482, 3/32, t>1e being stored in an oven at only 115*F, and (27018, Heat No. 74208-3/32 and E7018, Heat No. 68745-1/8), were stored in a cabinet tJithout temperature controls and the mechanical maintenance supervisor Das not aoare of temperature requiremente prior to issue... -
Mr. C. E. Norelius, Director September 14, 19 81 Division of Engineering & Technical Inspection LAC-7773 DPC RESPONSE The foreward to Section XI of the ASME Code states, in part, " Application of this section of the Code begins when the requirements of Section III, Rules for Construction of Nuclear Power Plant Components, have been satisfied.
The foreward to Section III, Subsection NB states, in part, "The specifications for welding materials given in Section II, Part C, are identical with or similar to those of the American Welding Society. All materials allowed by these various sections and used for construction within the scope of their rules shall be furnished in accordance with ASME Materials Specifications contained in Section II except where otherwise provided in code cases or in applicable section of the Code."
Section II, Part C, SFA-5.1, " Specifications for Mild Steel Covered Arc-Welding Electrodes," paragraph A1.9.3, states " Electrodes....can be restored..
..as indicated in Table A1."
The storage conditions for E7018 electrodes listed in Table Al is 50 to 250'F above ambient temperature.
Minor revisions to Administrative Control Procedure 10.3, " Control of Weld Material," will be written to insure that the control of coded welding rods will be in compliance with the above specifications.
If, however, a defect requires repair based on our Inservice Inspection Program, then Article IWB-4000, " Repair Procedures", of Section XI will be applicable.
The above procedural change will be completed by January 1,1982.
VIOLATION 3.
10 CFR 50, Appendix B, Criteria IV, states in part, " Measures shall be established to assure that applicable regulatory requiremente, design bases, and other requiremente which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment and services, whether purchased by the applicant or by its contractore or subcontractors."
Dairyland Power Quality Assurance Program Description (Revision 1),
January,1975,Section V requires that:
" Quality Accurance Supervisor is responsible for developing procedures to control the preparation, reviev, and approval of purchase ordere for material, equipment, and amica covered by the Quality Assurance Program."
" Changes in technical content in procurement documente shali be initiated and reviewed in accordance uith the same procedures utilized in preparation of the original document."
Contrary to the above, the follouing examples of noncompliance vere identified:,
T
.Mr. C. E. Norelius, Director September 14', 1981
~
Division of Engineering & Technical Inspection LAC-7773 -
a.
Procedures have not been developed to control the preparation, reviev, and approval of purchase ordere as purchaea ordere can be placed prior to a quality Assurance or Technical revieu uith the cubecquent critten order marked " confirming", reautting in ordere being shipped and received prior to adequate procurement document revieu. In addition, proceaures have not established criteria defining uhat is a "qc Controtted Item", uith respect to the QA Program and procurement statemente involving documentation, receipt inspection, vendors' QA Program and the cafety relatedness of the item.
b.
Change ordere do not go through the same procedure utilized in preparation of the original document.
Purchase ordere do not reference 10 CFR SO, Appandix B require-c.
mente or Q.A. Program requiremente. Specific examptee are identified in Section S of the inepection report.
_DPC RESPONSE
- a. & b.
Administrative Control Procedures 01.1, " Preparation, Format and Content of Administrative Control Procedures," and 05.1, " Procurement Document Control," will be revised to require adequate procurement document review for change orders and confirming purchase orders.
Additionally, "QC Controlled Item" criteria will be defined.
c.
Procurement documents generated for LACBWR have not referenced 10 CFR
~ 50, Appendix B. _ However, QA Program requirements have been referenced on all purchase order documents, to the extent necessary, with the exception of change orders and confirming orders. For example, the six purchase orders referenced in Section 5 of the subject report did specify QA requirements which are contained in 10 CFR 50, Appendix B criterion.
APPLICABLE P.O. NUMBER OA REQUIREMENTS SPECIFIED APPENDIX B CRITERION-74208 Typica! chemical and physical V, VII, VIII, IX, X certifications and XIII 74937 Documentation of:
V, VI, VII, VIII, Environmental Conditions to IEEE XI and XII 323-19 74, Drawings, Manuals and Instructions 73257 Certification of material, V, VII, VIII, IX, X chemical properties by Lot. No.
and XIII 78454 Certification of material to IV, V, VI, VII, ASTM A-36 and ASTM A-53 VIII, IX, XI, XIII, XIV ard XV 78152 Supply per letters LAC-7300 and V, X, and XI LAC-7277, inspect and repair and test 67459 Fabricate fuel racks in accordance All criteria with Specification 80A1770
.Mr. C. E. Norelius, Director September 14, 1981 Division of Engineering & Technical Inspection LAC-7773 Although the procurement documents do not contain the specific criterion of 10 CFR 50, Appendix B, they do address, in our opinion, all applicable QA requirements necessary to assure adequate quality of the purchase.
VIOLATION 4.
LACBWR's Quality Assurance Program Section II.B. states that the program oill meet the requirements of ANSI N18.7 - 1976.
ANSI 18. 7 - 1976, paragraph 5.3.10, " Test and Inspection Procedures,"
states in part that the test and inspection procedures shall:
(1) Contain the acceptance criteria that vill be used to evaluate the test resulte.
(2) Provide for documentation and evaluation of the results by responsible authority.
(3) Require reconfing Ae-Found and As-Left conditione.
Contrary to the above, Reactor Pressure Calibration Data Sheet S-8 has no acceptance criteria and has a eingle As-Found/As-Left data point.
Reactor Water Level Calibration Data Sheet 5-11 has acceptance criteria for only the too level scram set point and also only a single As-Found/
As-Left data point. Power Floo Data Sheets S-9 a & b also have only the eingle As-Found/As-Left data point.
DPC RESPONSE The above listed data sheets are being reviewed and will be revised to incorporate the requirements of ANSI-18.7-1976.
The revisions will be completed by January 1,1982.
Very truly yours, DAIRYLAND POWER OPERATIVE r
7 f
x Frank Linder, General Manager l
FL:RRW:dh cc:
NRC Resident Inspectors i
f l t
.Mr. C. E. Norelius, Director September 14, 1981 Division of Engineering & Technical Inspection LAC-7773 STATE OF WISCONSIN )
)
COUNTY OF LA CROSSE )
Personally came before me this
/b E day of September,1981, the above named Frank Linder, to me known to be the person who executed the foregoing instrument and acknowledged the same.
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Notary Public!,/La Crosse County Wisconsin My commission expires Feb. 26, 1984