Vogtle 3 & 4 - Level IV NRC Violation

During an NRC inspection conducted between October 1 and December 31, 2010, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Criterion VII, “Control of Purchased Material, Equipment, and Services,” of Appendix B, “Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,” to Title 10 of the 

Article 5, “Quality Assurance,” of the Engineering, Procurement and Construction Agreement (EPC Agreement) between SNC and a consortium consisting of Westinghouse Electric Company, LLC (WEC) and Stone & Webster, Inc. (S&W); required, in part, that safety-related activities contracted to the consortium be performed in accordance with 10 CFR Part 50, Appendix B and American Society of Mechanical Engineers (ASME) Nuclear Quality Assurance (NQA) Standard NQA-1-1994, “Quality Assurance Requirements for Nuclear Facility  Applications.”

The containment vessel (CV) procurement document between WEC and their contractor, Chicago Bridge & Iron (CB&I), SV0-MV50-Z5-006, “Purchase Order For Vogtle 3 & 4 Containment Vessels,” Revision 0; required, in part, that activities which could affect the quality of the containment vessel be performed in accordance with 10 CFR Part 50, Appendix B and ASME NQA-1-1994.

Contrary to the above, as of October 15, 2010, SNC failed to establish adequate measures to assure that safety-related services, purchased through WEC and CB&I, conformed to the quality requirements prescribed by the VEGP Unit 3 CV procurement document (SV0-MV50-Z5-006); in that SNC failed to ensure that CB&I had established and implemented an adequate quality assurance program that complied with 10 CFR Part 50, Appendix B and ASME NQA-1-1994, as evidenced by the following examples:

1. SNC failed to ensure that CB&I had established adequate procedures to implement the receipt inspection and storage requirements of Subpart 2.2, “Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants,” of ASME NQA-1-1994. Specifically, as of October 15, 2010, CB&I had not established procedures that adequately prescribed the applicable receipt inspection and storage requirements of ASME NQA-1-1994.

Consequently, as of October 15, 2010, regarding the VEGP Unit 3 CV bottom head plate material, CB&I had not performed the required receipt inspections prior to the material’s release for fabrication, and failed to store the plate in a manner that would prevent its damage or deterioration.

2. SNC failed to ensure that CB&I had established and implemented a corrective action program that complied with the requirements of 10 CFR Part 50, Appendix B, in that, 2 CB&I had not established measures to assure that all conditions adverse to quality were promptly identified and corrected. Specifically, CB&I procedure, CMS-720-03-PR-11051, “Handling of Corrective Action,” Revision 0, failed to meet 10 CFR Part 50, Appendix B requirements since it only prescribed a system to document and correct significant conditions adverse to quality.

This is a Severity Level IV violation (Enforcement Policy Section 6.5.d).

Code of Federal Regulations (10 CFR) Part 50, “Domestic Licensing of Production and Utilization Facilities,” states, in part, that “Measures shall be established to assure that purchased services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.”

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