ML19273B528
| ML19273B528 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/27/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19273B523 | List: |
| References | |
| 50-324-79-02, 50-324-79-2, 50-325-79-02, 50-325-79-2, NUDOCS 7904090067 | |
| Download: ML19273B528 (6) | |
Text
V APPENDIX A NOTICE OF VIOLATION Carolina Power and Light Company License Nos.:
DPR-62 DPR-71 Based on the results of the NRC inspection conducted on January 8-12, 15 and 16, 1979, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below. These items have been categorized as described in our correspondence to you dated December 31, 1974.
A.
10 CFR 50, Appendix B, Criterion XIII states in part: " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment..." The accepted Quality Assurance Program (Letter dated September 11, 1975) Paragraph 6.A states in part:
" Packaging, shipping, receiving, storage and handling of BSEP items are in accordance with applicable requirements of ANSI N45.2.2-1972.." ANSI N45.2.2-1972, Section 2 states in part: " Measures shall be
. implemented for the packaging, shipping, receiving, storage, and handling of specific items.
.2.2 Procedures and instructions shall be generated, used, and maintained current; these shall contain a basis for packaging design, shipping requirements, receiving, storage and handling procedures, implementation thereof, and inspection, in accordance with this standard."
as of January 10, 1979, measures had not been Contrary to the above, established to control activities in accordance with the requirements of the accepted QA Program in that, as examples not to be considered as all inclusive, the requirements for packaging delineated in Sections 3.1, 3.5, and 3.7 were not met; the shipping requirements of Section 4.3 were not met; the receiving activities were not in accordance with the requirements of Section 5.2; the storage of material was not in accor-dance with the requirements of Sections 6.1, 6.2, 6.3, 6.4, and 6.6; and, the handling activities did not comply with the requirements of Sections 7.2 and 7.5.
This is an Inf raction.
B.
10 CFR 50, Appendix B, Criterion II states in part:"The applicant shall establish at the earliest practicable time, consistent with the schedule quality assurance program which for accomplishing the activities, a cor: plies with the requirements of this appendix. This program shall be dscumented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions..." The accepted Quality Assurance Program
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Carolina Power and Light Company Appendix A License Nos. DPR-62 and DPR-71 Notice of Violation (Letter dated September 11, 1975) Paragraph 12 states in part: "The applicable requirements of N45.2.3 - 1973 are followed at BSEP..."
(Letter dated February 27, 1975) Paragraph 10 states in part: "The requirements for collection, storage, and maintenance of QA records at BSEP will be in accordance with ANSI N45.2.9-1974..."
Contrary to the above, as of January 10, 1979, the licensee had not established a program for activities which were being conducted in the housekeeping and records areas consistent with his accepted Quality Assurance Program submitted to meet the requirements of Appendix B, in that, as examples not to be considered as all inclusive, the ANSI N45.2.3 requirements were not implemented in the housekeeping area as required by Section 1.1; in the control of site areas as described in Section 3.1; in the areas of fire prevention and protection as described in Section 3.2.2; and, the surveillance and inspection requirements of Section 3.5 were not being fully met. With respect to ANSI N45.2.9, the index requirements of Section 3.2.2 and the storage requirements of Section 5.2 were not implemented.
This is an Infraction.
C.
10 CFR 50, Appendix B, Criterion XII states in part: " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods..." The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 6.4 states in part: "A calibration program shall be developed..." and "shall include:...d. The calibration f requency..."
Contrary to the above, as of January 16, 1979, measures had not been established to assure that instruments used in activities affecting quality were properly calibrated at specified intervals in that:
there was no program in effect for periodic calibration of Instrument and Control group safety-related instruments which are utilized in verification of Technical Specification values listed as Limiting Conditions for Operations; and, one procedure which had been used during the preoperational cali-bration of instruments in this category could not be used as currently written because it (MP3-3F) could not be physically booked up as it was during the original bench test and it incorrectly specified that out-of-specification readings obtained prior to adjustment be averaged with correct reading obtained after adjustment to provide the "as lef t" setpoint.
This is an Infraction.
Carolina Power and Light Company Appendix A License Nos. DPR-62 and DPR-71 Notice of Violation D.
10 CFR 50, Appendix B, Criterion V states in part: " Activities affecting quality shall be prescribed by documented instructions, procedures...
and shall be accomplished in accordance with these instructions, proce-dures..." The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 5.4.2 in states part:"... Procedures or instructions shall be developed which:
a.
Define handling, storage, cleaning, and preservation requirements...." Administrative Instruction 1 (AI-1),
Section 5.4.1 states in part: "...Q List material shall be stored so as to meet or exceed the storage requirements set forth in Appendix A.
Section 5.6 of the same AI-1 states in part: "All items with a shelf-life will be indicated...to remove these items at expiration of their shelf-life."
Contrary to the above, as of January 10, 1979, activities affecting quality were not accomplished in accordance with written instructions in that there was no segregation of Q list items into the four levels specified in Appendix A of AI-1 in Warehouse H, and no method existed for identification or control of shelf-life items.
This is an Infraction.
E.
10 CFR 50, Appendix B, Criterion V states in part: " Activities affecting quality shall be prescribed by documented instructions, procedures...and shall be accomplished in accordance with these instructions, procedures..."
The accepted Quality Assurance Program (Letter dated March 30, 1977),
Paragraph 5 states in part: " Radiation Survey / measuring instruments utilized for determination of emanating / airborne radioactivity, as required for personnel safety, and chemical / radiochemical analysis instruments shall be calibrated...as outlined in Volume VIII of the Plant Operating Manual..."
Contrary to the above, as of January 16, 1979, activities affecting quality were not prescribed by documented procedures and/or not accomplished in accordance with procedures as follows:
Volume VIII of the Plant Operating Manual did not contain procedures for calibration of radiation survey / measuring instruments; and, Section 13 of the CP&L Radiation Control and Protection Manual which does specify a calibration program for chemical and radio-chemical analysis equipment was not implemented in that:
1) no approved procedures existed for the calibration of the Chemistry Laboratory Conductivity Meter; 2) no records were maintained to document the calibration of the resistance standard used to calibrate the Conductivity Meter on the thermometer used when calibrating the pH Meter; and
Carolina Power and Light Company Appendix A License Nos. DPR-62 and DPR-71 Notice of Violation 3)
Volume III of the Plant Procedures Manual did not contain the required calibration procedures.
This is an Inf raction.
F.
10 CFR 50, Appendix B, Criterion 11 states in pa rt <.
..The program shall provide for indoctrination and training of personnel performing activities quality..." The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 9.3.1 states in part: " Training plans shall be developed which provide personnel with adequate proficiency of per-formance of quality achievement and quality verification activities..
The accepted Quality Assurance Program (letter dated September 11, 1975) further states in Paragraphs 2.A and 6.A respectively that: "The quali-fication of BSEP inspection, examination, and testing personnel will be in accordance with ANSI N45.2.6 - 1973.
and " Packaging, shipping, receiving, storage, and handling at BSEP items are in accordance with applicable requirements of ANSI N45.2.2 - 1972.
Contrary to the above, as of January 16, 1979, there was no program for the indoctrination, training, and certification of receipt inspectors as required by Section 1.3 of ANSI N45.2.6 nor was there a program for demonstrating satisfactory ability in handling lifting equipment used in the warehouse as required by ANSI N45.2.2, Section 7.5.
This is an Infraction.
G.
10 CFR 50, Appendix B, Criterion V states in part: " Activities af fecting quality shall be prescribed by.. procedures...and shall be accomplished in accordance with these... procedures.. " The accepted Quality Assurance Program (Corporate QA Manaul, Part 2), Section 11.2.5 states in part:
" Audits shall be planned, conducted, and reported in accordance with procedures... "
Procedure QAAP-1, Pa ragraph 6.5. 2. c states that the Manager-Corporate Nuclear Safety and Quality Assurance Audit shall..."
- c. Confirm that corrective action is accomplished as ccheduled."
Contrary to the above, finding two on audit QAA/21-09 was closed before the corrective action was completed.
This is an infraction.
H.
10 CFR 50, Appendix B, Criterion XIV states in part: " Measures shall be established to indicate, by the use of markings such as.. labels..the status of inspections and tests performed upon individual items of the nuclear power plant..." The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 6.5.2 states in part:
"...Where practical, the calibration status shall be indicated on stickers or tags attached to or accompanying the equipment..."
Carolina Power and Light Company Appendix A License Nos. DPR-62 and DPR-71 Notice of Violation Contrary to the above, as of January 16, 1979, measures had not been established to indicate the status of calibration performed on individual items in that, except for instruments designated "M&TE", there were no stickers on installed plant safety-related instruments.
This is a Deficiency.
I.
10 CFR 50, Appendix B, Criterion XVIII states in part:
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program.
The accepted Quality Assurance Program (letter dated February 27, 1975)
General Paragraph 3. A states in part:
.The CP&L Quality Assurance Audit Program conforms to, and QA audits are conducted in accordance with N45.2.12 (Dra f t 4,
Rev.
1)."
ANSI N45.2.12 (Draft 4,
Rev. 1)
Paragraph 3.5.2 states in part:
" Applicable elements of the quality assurance program shall be audited annually or at least once within the life of the activity, whichever is shorter.
Contrary to the above, periodic annual audits were not carried out as required in that, as of January 16, 1979, audits for the elements of Organization and Responsibility, Procurement Control, Material and Equipment Control, General Plant Operating Procedures, Annunciator Procedures, and Document Control had not been audited during one or more annual periods between issuance of the Operating license (1974 for Unit 2,1976 for Unit 1) and date of the inspection referenced above.
This is a Deficiency.
J.
10 CFR 50.59 states in part:
.(b) licensee shall maintain records...These records shall include a written safety evaluation which provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question..." The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 3.4.1.4 states in part:
"..This safety analysis shall provide the technical data, supporting evaluations, and the safety questions considered and analyzed as safe that form the basis for the determination that the modification does or does not involve an unreviewed safety question."
Contrary to the above, as of January 16, 1979, the records of the five (5) design changes reviewed by the inspector did not include a written safety evaluation which provided the basis for the determination that the change did not involve an unreviewed safety question.
This is a Deficiency.
Carolina Power and Light Company Appendix A License Nos. DPR-62 and DPR-71 Notice of Violation K.
10 CFR 50, Appendix B, Criterion I states in part: "...The authority and duties of persons...shall be clearly established and delineated in writing..The quality assurance functions are those of assuring that an appropriate quality assurance program is established.." The accepted Quality Assurance Program (Corporate QA Manaul, Part 2), Section 2.4.5 states the responsibilities of the Plant QA Supervisor, in part, as:
"m. Initiating of Procedures or instructions necessary for accomplishment of QA activities."
Contrary to the above, the function of assuring the establishment of quality assurance program had not been carried out by the Plant QA Supervisor in that, when originally inspected on January 10, 1979, instructions which covered QA activities (AI's 1, 2, 2.1, and 6) were not initiated by or issued with either the approval or concurrence of this plant employee.
This is a Deficiency.