ML20052B303
| ML20052B303 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/15/1982 |
| From: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20052B296 | List: |
| References | |
| 50-254-82-07, 50-254-82-7, 50-265-82-08, 50-265-82-8, NUDOCS 8204300271 | |
| Download: ML20052B303 (2) | |
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Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-254 i
Docket No. 50-265 As a result of the inspection conducted on March 11, 1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violation was identified:
10 CFR 50, 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 complies with the requirements of this Appendix. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with these policies, procedures, or instructions."
Commonwealth Edison Compnay had committed to the requirements of ANSI N45.2.9 1974 and to ANSI N18.7-1972 through Regulatory Guide 1.33 (Safety Guide 33 - November 1972) as stated in the Quality Assurance Program Topical Report, CE-1-A, Revision 19.
1.
ANSI N45.2.9 states " Permanent and temporary record storage facilities shall be constructed or located as to protect contents from possible destruction..." and "A satisfactory alternative to the establishing of a record storage facility is maintenance of duplicate records stored in a separate storage location."
Contrary to the above, the following completed records were not stored in two or more locations or stored so as to be protected from possible destruction:
(1) Completed Work Requests.
(2) Completed Work Packages.
This is a repetetive item of noncompliance since the same problem was identified in Inspection Reports No. 50-254/81-03; 50-265/81-03 dated May 1, 1981.
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Appendix 2
2.
ANSI N18.7-1972 states in Paragraph 5.1.2, " Procedures shall be followed...."
i Commonwealth Edison Quality Assurance Procedure Q.P. 17-51 stated that lifetime station generated Quality Assurance records are to be transferred to the Office Supervisor.
QDM-6 states " Active files are purged of lifetime retainable QA records by the Central File Supervisor according to the QDM procedures, retention schedule, and R3 system."
Contrary to the above, lifetime QA records were retained in the active files in excess of one year as specified in the Master Retention Schedule. Examples include completed surveillance data sheets and completed Work Requests.
This is a Severity Level IV 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 state-ment or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved. Consideration may be given to extending your response time for good cause shown.
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J Dat'ed W. S. Little, Chief Engineering Inspection Branch i
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