ML20058F264
| ML20058F264 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 07/15/1982 |
| From: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058F259 | List: |
| References | |
| 50-263-82-01, 50-263-82-1, NUDOCS 8207300375 | |
| Download: ML20058F264 (3) | |
Text
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Appendix A-NOTICE OF VIOLATION Northern States Power Company Docket No. 50-263 As a result of the inspection conducted on March 1 through April 30, 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 V, requires that activities affecting quality be accomplished in accordance with instructions, procedures, or drawings.
The Northern States Power " Operational Quality Assurance Plan" Section 1.0 states that the program shall incorporate "...the following standards to the extent specified by ANSI N18.7-1976..."
One of the standards is ANSI N45.2.2-1972 (Reg. Guide 1.38 Rev. 2) which states:
" Periodic inspections shall be performed to assure that storage areas are being maintained in accordance with these requirements." Section 6.6.1 of the licensee's procedure 4 ACD-9.5, " Handling, storage, shipping and preservation of materials", requires that:
" Periodic inspections shall be performed and documented by the storage area supervisor...."
Contrary to the above, no periodic inspections were being performed.
This is a Severity Level V violation (Supplement I).
2.
10 CFR 50. Appendix B, Criterion V, requires that activities affecting quality be accomplished in accordance with instructions, procedures, or drawings. The Northern States Power " Operational Quality Assurance Plan" Section 1.0 states that the program shall incorporate"... the following standards to the extent specified by ANSI N16.7-1976...."
One of the standards is ANSI N45.2.2-1972 (Reg. Guide 1.38 Rev. 2) which requires the following:
" Items in storage shall have all covers, caps, plugs or other a.
closures intact."
(3.5.1) b.
" Nonmetallic plugs and caps shall be brightly colored." (A3.5.1(1))
" Packages and items containing dessicant shall be marked. The total c.
number of separate bags and/or containers in the packages shall be indicated." (A3.6.3(7))
d.
"All items and their containers shall be plainly marked so that they are easily identified...."
(6.3.4) 8207300375 020715 PDR ADOCK 05000263 G
Appendix A 2
" Barrier and wrap materials shall be non-halogenated when used in e.
. direct contact with austenetic stainless steel, shall be non-cor-rosive, shall not readily support combustion and shall not be otherwise harmful...." (Section 3.6)
The licensee's Administrative Work Instructions (AWI) 4 AWI 9.1.4, "In Storage Maintenance Program," requires the following:
" Items in storage shall have all covers, caps, plugs or other a.
closures intact."
(6.2) b.
"Non-metallic plugs and caps shall be brightly colored."
(6.2.1.1.1)
" Packages and items containing dessicant shall be marked. The total c.
number of separate bags and/or containers in the packages shall be indicated." (6.4.2.3.7) d.
".... Barrier and wrap materials shall be non-halogenated when used in direct contact with austenetic stainless steel, shall be non-corrosive, shall not readily support combustion and shall not be otherwise harmful.... "
(6.4.2)
The licensee's Administrative Control Directive (ACD) 4 ACD 9.5, "lfandling, storage, shipping and preservation of materials," ~ requires, in part, the following:
a.
A separate area within the storage area shall be set aside and designated, as necessary, as a nonconforming item storage area.
(6.4.1.3) b.
The proper identification traceable to the associated QA docu-mentation shall be maintained during receiving process, storage, and if shipped offsite.
(6.4.3.1)
Contrary to the above:
a.
Many end caps on safety related tubing and pipe were missing.
b.
In many cases, grey tape was used as an end cap instead of a bright colored tape, c.
Several containers containing dessicant were not marked to indicate the number of containers of dessicant.
d.
Several instances were found of safety related austenetic stain-less steel in contact with carbon steel and painted surfaces, Several items requiring hold tags were not tagged and were not e.
in a segregated hold area.
Appendix A 3
f.
Many untagged items were in the aisles.
In many cases, these were found to be placed in the warehouse to await disposal.
This is a Severity Level V violation (Supplement I).
3.
10 CFR 50, Appendix B, Criterion V, requires that the licensee accomplish activities affecting quality in accordance with instructions, procedures, or drawings. The Northern States Power Company " Operational Quality Assurance Plan" Section 1.0 states that the program shall incorporate
"(1) the requirements of ANSI N18.7-1976...." ANSI N18.7 requires written procedures to control the documentation and performance of maintenance activities affecting safety-related structures, systems or components.
The licensee's procedure 4 ACD 3.6 Section 6.2.19 governing Work Request Authorizations states:
Upon completion of the work, the job supervisor or job leadman shall fill out or assure that a workman has filled out Section V on pages 2 and 3, describing as applicable:
a.
Work actually performed b.
Results of work / test results c.
Replacement parts d.
Disposition of parts removed e.
Stores requisition (s) used f.
Identification of additional WRA(s) initialed to complete work if work performed is temporary or beyond the scope of the original WRA.
Contrary to the above, the inspector reviewed five safety-related WRAs and found that three did not contain all of the required information.
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 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.
Dated R. L. Spessard, Director Division of Project and Resident Programs