ML20136H149

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Notice of Violation from Insp on 850311-0517
ML20136H149
Person / Time
Site: River Bend Entergy icon.png
Issue date: 08/01/1985
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20136H136 List:
References
50-458-85-19, NUDOCS 8508200200
Download: ML20136H149 (2)


See also: IR 05000311/2005017

Text

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APPENDIX A

NOTICE OF VIOLATION

Gulf States Utilities Docket: 50-458

River Bend Station Permit: CPPR-145

During an NRC inspection conducted on March 11-May 17, 1985, violations of NRC

requirements were identified. The violations involved, (1) incorporation of

Engineering and Design Coordination Report (E&DCR) information into drawings,

and (2) use of external historical data in evaluation of suppliers. In

accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions," (10 CFR Part 2, Appendix C) (1985), the violations are

listed below:

1. Incorporation of E&DCR Information into Drawings

Criterion V of Appendix B to 10 CFR Part 50 requires that activities

affecting quality be prescribed by and accomplished in accordance with

appropriate instructions, procedures, or drawings. This equipment is

part of the approved quality assurance plan for Gulf States Utilities.

Paragraph 4.7.1 of Stone and Webster Engineering Assurance (EA) Procedure

EAP 5.4, Revision 3, through Change Notice No. 7, dated September 28, 1983,

" Review and Approval of Project Production Drawings," states, in part,

" Revised drawings shall be reviewed and approved using the same review

and approval cycle (including documentation) that applied to the original

issue . . ." Paragraph 4.5.5 of this procedure requires the responsible

engineer to review drawings to ensure, in part, that correct design

inputs and proper design approach were used and that the drawings are

technically adequate and in accordance with engineering technical

standards, guidelines, and procedures. Paragraph 4.5.6 similarly requires

review of drawings for technical adequacy by the responsible Lead Engineer.

Contrary to the above, engineering review of EE 340 series drawing

revisions did not ensure the technical adequacy of drawings, as evidenced

by the NRC and Stone and Webster EA identification of drawing errors and

omissions associated with incorporation of information from E&DCR

Nos. C21272, C21800, C22021A and 8, CC22041, C22475, C23020, C232208,

C232918, C23439, and C24785A and B.

This is a Severity Level IV violation (Supplement II.D) (458/8519-01).

2. Use of External Historical Data in Evaluation of Suppliers

Criterion VII of Appendix B to 10 CFR Part 50 states, in part, " Measures

shall be established to ensure that purchased material, equipment, and

services . . . conform to the procurement documents. These measures shall

include provisions, as appropriate, for source evaluation and selection,

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objective evidence of quality furnished by the contractor or subcontractor,

inspection at the contractor or subcontractor source, and examination of

products upon delivery . . . The effectiveness of the control of quality

by contractors and subcontractors shall be assessed by the applicant or

designee at intervals consistent with the importance, complexity, and

quantity of the product or services."

Paragraph 3.9 in Procedure QAI-2.11, Revision 3, states, in part, with

respect to the Qualified Supplier List (QSL), " Suppliers on the QSL will

be classified in one of the following categories . . . 'C' - Conditionally

Approved Supplier: Suppliers whose quality programs have been evaluated

and found not to meet the specified requirements but are conditionally

approved pending corrective action. Examples are as follows: ...

b. Supplier evaluations based on historical data from CASE, AE, other

utilities, NRC Inspection Reports / Bulletins / Notices, etc. in which these

sources have identified problem areas, conditional approval will be

granted providing source inspection is imposed and stipulated in the

procurement document. Source inspection may not be required, depending on

the nature of the problems identified, and if adequate followup corrective

action is specified and can be verified . . ."

Contrary to the above, suppliers whose evaluations included use of

external historical data showing quality programs did not meet specified

requirements, were not indicated as conditionally approved on the QSL,

e.g., Transamerical Delaval Engine and Compressor Division, Guildline

Instruments. Accordingly, source inspection or followup corrective actions

were not specified as a procurement requirement. An example was also noted

of apparent failure to consider this category of external historical data

in evaluation of a supplier; i.e., Hayward Tyler Pump Company.

This is a Severity Level IV violation (Supplement II.D) (458/8519-02).

Pursuant to the provisions of 10 CFR 2.201, Gulf States Utilities is hereby

required to submit to this office within 30 days of the date of of the letter

transmitting this Notice, a written statement or explanation in reply,

including for each violation: (1) the reason for the violations if admitted,

(2) the corrective steps which have been taken and the results achieved,

(3) tha corrective steps which will be taken to avoid further violations, and

(4) the date when full compliance will be achieved. Where good cause is shown

consideration will be given to extending the response time.

Dated at Arlington, Texas,

this 1st day of Aug ,1985.