ML20030C786
| ML20030C786 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 08/17/1981 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20030C785 | List: |
| References | |
| 50-409-81-12, NUDOCS 8108280156 | |
| Download: ML20030C786 (4) | |
Text
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t Appendix A NOTICE OF VIOLATION Dairyland Power Cooperative Docket No. 50-409 As a result of the inspection conducted June 22-26, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
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 pro-gram which complies with the requirements of this appendix. This program shall be documented by written policies, procedures, or in-structions and shall be carried out throughout plant life in accor-dance with these policies, procedures, or instructions."
Dairyland Power states in part in Section XVIII of the January, 1975, Quality Assurance Program Description (Revision 1) under storage requirements:
"1.
Originals of permanent records are stored in a closed, fire-retardant cabinet (vault) designed to accomodate all records on file at the home office.
"2.
On-site storage facility is constructed in such a manner as to safeguard the contents from extreme temperature and moisture variations.
"5.
Storage requirements shall meet the intent of ANSI N45.2.9,
" Requirements for Collection, Storage and Maintenance of Quality Assurance Records," as it applies to identification and retention of records."
ANSI N45.2.9 - 1974 states in part in paragraph 3.2.2, "The quality assurance records shall be listed in an index. The index shall indicate, as a minimum, record retention times, where the records are to be stored and the location of the records within the storage area."
ANSI N45.2.9 - 1974 states in part in paragraph 5.3, " Prior to storage of records in a quality assurance record file, a written storage pr'o-cedure shall be prepared and a custodian shall be designated with the responsibility to enforce the procedure. This procedure shali include the following as a minimum:
8108280156 810817 PDR ADOCK 05000409 G
I Appendix A AUG 1 7 081 2.
The filing system to be used 4.
A method of verifying that the records agree with the pre-establised records check list."
Contrary to the above, the following examples of noncompliance were identified:
a.
The record vault, where completed QA records are stored, has a wooden access door that is not fire retardant and would not safeguard the records from an external fire.
b.
An index has not been formulated, indicating where the records are to be stored and the location of the records within the storage area.
c.
A procedure hac not been written that includes the filing system to be used and the method for verifying that the records agree with the pre-established records check list. A filing system has not been established and approved by management.
This is a Severity Level VI violation (Supplement 1).
2.
10 CFR 50, Appendix B, Criteria XIII, states in part, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."
In accordance with the provisions of 10 CFR 50.55(a), Dairyland Power has committed to Section XI of the ASME B & PV Code,1974, IWB-4423, which requires that covered electrodes be kept in ovens at temperatures between 225 F to 350 F and not be out of an oven for over 20 minutes unless returned to the holding oven and held at 225 F to 350 F for at least eight hours before reissue.
Contrary to the above, measures have not beem established to control the stocage of weld rod to prevent damage or deterioration with respect to E7018 dry, covered electrodes as stated in 1WB-4423, in order to insure specific moisture content levels, and the following examples of noncompliance were identified:
The Control of Weld Material Procedure, QCP 10.3, Revision 3, has not established oven temperature parameters for dry, covered electrodes.
In addition, ACP 10.3 does not address the issue of dry, covered electrodes being out of an oven for an extended period of time and subsequent return to a holding oven before reissue. As a result, E7018, Heat No.
/
Appendix A $UO I 67482, 3/32, was being stored in an oven at only 115 F, and (E7018, Heat No. 74208-3/32 and E7018, Heat No. 68745-1/8),
were stored in a cabinet without temperature controls and the mechanical maintenance supervisor was not aware of temperature requirements prior to issue.
This is a Severity Level V violation (Supplement I).
3.
10 CFR 50, Appendix B, Criteria IV, states in part, " Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for pro-curement of material, equipment and services, whether purchased by the applicant or by its contractors or subcontractors."
Dairyland Power Quality Assurance Program Description (Revision 1),
January, 1975,Section V requires that:
" Quality Assurance Supervisor is responsible for developing procedures to control the preparation, review, and approval of purchase orders for material, equipment, end services covered by the Quality Assurance Program."
" Changes in technical content in procurement documents shall be initiated and reviewed in accordance with the same procedures utilized in preparation of the original document."
Contrary to the above, the following examples of noncompliance were identified:
a.
Procedures have not been developed to control the preparation, review, and approval of purchase orders as purchase orders can be placed prior to a Quality Assurance or Technical review with i
I the subsequent written order marked "cenfirming", resulting in orders being shipped and received prior to adequate procurement j
document review.
In addition, procedures have not established criteria defining what is a "QC Controlled Item", with respect to the QA Program and procurement statements involving documenta-tion, receipt inspection, vendors' QA Program and the safety relatedness of the item.
l l
b.
Change orders do not go through the same procedure utilized in preparation of the original document.
c.
Purchase orders do not reference 10 CFR 50, Appendix B require-ments or Q.A. Program requirements. Specific examples are identified in Section 5 of the inspection report.
1
Appendix A This is a Severity Level V violation (Supplement I).
4.
IACBWR's Quality Assurance Program Section II.B. states that the program will meet the requirements of ANSI N18.7 - 1976 ANSI 18.7 - 1976 paragraph 5.3.10 " Test and Inspection Procedures" states in part that the test and inspection procedures shall:
(1) Contain the acceptance criteria that will be used to evaluate the test results.
(2) Provide for documentation and evaluation of the results by re-sponsible authority.
(3) Require recording As-Found and As-Left conditions.
Contrary to the above, Reactor Pressure Calibration Data Sheet S-8 has no acceptance criteria and has a single As-Found/As-Left data point.
Reactor W ter Level Calibration Data Sheet S-11 has acceptance criteria for only the low level scram set point and also only a single As-Fouad/As-Left data point.
Power Flow Data Sheets S-9 a & b also have only the single As-Found/As-Left data point.
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 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) time 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.
AUG 17 198f Dated C. E. Norelius, Director Division of Engineering and Technical Inspection