ML20053E195
| ML20053E195 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/17/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20053E185 | List: |
| References | |
| 50-461-81-15, NUDOCS 8206070686 | |
| Download: ML20053E195 (3) | |
Text
Appendix NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 As a result of the investigation conducted on June 2-19, 1981; January 5 and February 5, 1982, 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 II, states in part, that "... Activities affecting quality shall be accomplished under suitably controlled condi-tions. Controlled conditions include...that all prerequisites tor a given activity have been satisfied. The program shall take into account the need..., for verification of quality by inspection... The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure proficiency is achieved..."
The Illinois Power Company, Clinton Power Station PSAR, Amendment 20, dated August 9, 1974,.Section 17.1.2.1, states, in part, that "...The program provides for indoctrination and training of personnel performing activities affecting quality as necessary to provide assurance that appropriate proficiency is achieved..."
Contrary to the above, activities affecting quality were not accom-plished under suitably controlled conditions in that QC inspectors signed statements to the effect that, among other things, (1) answers to the certification examination were provided prior to and during the examination, and (2) incorrect answers were allowed to be corrected.
This is Severity Level IV violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion V, states, in part, that " activities affecting quality shall be prescribed by documented instructions, procedures,..., and shall be accomplished in accordance with these instructions, procedures..."
Example A The Illinois Power Company, Clinton Power Station, PSAR, Amendment 32, dated August 20, 1975, Section 17.1.5.1, states, in part, " Formal procedures, instructions, and drawings shall be developed and used, as appropriate, for activities affecting quality."
BA Project Procedures Manual, BAP 1.0, Nonconformances, Revision 6, Paragraph 6.1.1 states: "All Baldwin Associates personnel have
-the authority to initiate a Nonconformance Report (NCR) when a nonconformance is suspected." Paragraph 6.1.4 states:
" Quality h
O O
lppendix 2
Control / Technical Services inspector shall:
(a) obtain a NCR number from the Project Engineering Document Coordinator." The BA Quality Assurance Manual, Section 13.5, Requirements, states:
"When an individual identifies a suspected nonconformance, the initiator shall document it on a Nonconformance Report, Exhibit 35.
The initiator shall request an NCR number from the Project Engineer who assigns the number from a log which he maintains."
Contrary to the above, in some cases, Nonconformance Reports are prepared by initiators in draft form and not on a_Nonconformance Report. The nonconformance or suspected nonconformance is then documented on a Nonconformance Report at the discretion of i
personnel other than the initiator.
Example B Baldwin Associates " Quality Control Instruction for Raceway Ranger / Support Installation Inspection Instruction, " Revision 1, dated March 3, 1981, Paragraph 3.3 states that fabrication area nonitoring will be documented on Form JV-188 and inspections will be made daily for all areas.
Contrary to the above, activities affecting quality were not accomplished in accordance with prescribed instructions, in that the electrical fabrication shop was not inspected daily. Speci-j fically, from February through June 1981 only seven daily inspections of the electrical fabrication shop were made.
This is a Severity Level IV violation (Supplement II).
i 3.
10 CFR 50, Appendix B, Criterion XV, states in part, that " measures shall be established to control nonconforming..., components which do not conform to requirements in order to prevent their inadvertent use..."
The Illinois Power Company, Clinton PSAR, Amendment 8, dated March 15, 1974, Section 17.1.15.1, staten, in part, that " Requirements are estab-lished for positive identification and disposition of materials, parts, or components which do not meet technical or quality requirements of drawings or design specifications and to prevent the inadvertent use f
of such nonconforming items."
Contrary to the above, Nonconformance Report No. 4055 was dispositioned "use as is" and closed (without reinspection to determine that the cable for radiation monitoring equipment had been enclosed in conduit) rather than being dispositioned " rework" and being reinspected before being closed.
This is a Severity Level V violation (Supplement II).
Appendix 3
4.
10 CFR.50, Appendix B, Criterion XIV, states, in part, that " measures shall be established to indicate, by the use of markings..., or other suitable means, the status of inspections... performed upon individual items of the nuclear power plant...
In.,e measures shall provide for, the identification of items which have satisfactorily passed required inspections..., where necessary to preclude inadvertent bypassing of such inspections..."
The Illinois Power Company, Clinton PSAR, Amendment 8, dated March 15, 1974, Section 17.1.14.1, states, in part, that " Systems which identify the status of material...., and assemblies through..., inspection...,
installation..., are required to assure that only items that have passed the required inspections...are used or installed.
The inspection... status of items shall be clearly identified..."
Contrary to the above, measures were not properly established to preclude inadvertent bypassing of inspections, in that, anchor bolts and straps used to hang electrical conduit were torqued to prescribed values and painted green to indicate that they had been inspected and accepted prior to installing the conduit which requires loosening the anchor bolts without benefit of re-torquing and re-inspection.
This is a Severity Level IV violation (Supplement II).
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. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.
Dated James G. Keppler Regional Administrator 1
i i
i
, - -, - w
~w w
.-e
.-,m,,,,-
,,,-3.,,-
,,,----.---um.
4-r re+----.
y 7 -- -
.r
.---.,-.,-...--