IR 05000397/1981001
| ML17275A918 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/12/1981 |
| From: | Andrea Johnson, Spencer G, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A917 | List: |
| References | |
| 50-397-81-01, 50-397-81-1, NUDOCS 8103240697 | |
| Download: ML17275A918 (27) | |
Text
U.
S.
NUCLE'AR REGULATORY COHMISSION OFFICE OF INSPECTION AND ENFORCEMr"".iT
REGION V
Report No.
50-397 81-01 Docket No.
50-397 License No. CPPR-93 Licensee:
Washin ton Public Power Su
S stem Safeguards Group P. 0.
Box 968 Richland Washin ton 99352 Facility Name: Washin ton Nuclear Project No.
(WNP-2)
Inspection at: WNP-2 Site, Benton County, Washington Inspection conducted:
January 8-30, 1981 Inspectors:
A, D. Toth, Senior Resident Inspector Date Signed e
A. Johnson Reactor Insp ctor Date Signed Date Signed Approved By:
G. S.
Spenc r, Chief Reactor Construction and Engineering Support Branch Summary o
C Ins ection on Januar 8-30 1981 Re ort No. 50-397 81-01)
Date Signed Areas Ins ected:
Routine, unannounced inspection of licensee and contractor activities to re-evaluate and improve detailed work methods.
The inspection involved 89 inspector-hours on-site by the NRC resident inspector.
and 60 inspector-hours on-s$ te by a regional based inspector.
Results:
No items of noncomp1$ ance or deviations were ident$ ffed.
,8 go s s40@<F RV Form 219 (2)
C~
DETAILS Persons Contacted Washin ton Public Power Su
S stem R.
G. Natlock, lNP2 Program Director W. C. Bibb, WNP2 Project Manager A. M. Sastry, Deputy Project Manager Systems Turnover B. A. Holmberg, Deputy Project Manager Engineering
- R. I. Johnson, guality Assurance Manager D. C. Timmons, Director Contract 215 Engineering R.
M. Tanner, Director Contract 215 guality Control R. T. Grant, Manager Construction guality Burns and Roe En ineers B&R)
G. Harper, Site Engineering Manager
- H. Tuthill, Assistant gA Manager R.
D. Carmichael, Supervisor gA Surveillance
- L. F. Akers, Senior Supervisor - Welds Wri ht-Schuchart-Harbor Boecon Cor
. General Ener Resources 'nc.
WBG)
I P. Garcia, Project Manager M. Houck, Manager-Engineering M. H. Brenner, Manager-guality Assurance P. Webster, Manager-gA Engineering D. W. Tolley, Deputy Project Manager Containment Fishbach Lord Electric Com an F L W. D. Brown, gA Site Administrator Johnson Controls Incor orated JCI)
R. Swift, Manager-guality Assurance Bonneville Power Administration BPA)
J. Lewis, Project Engineer Other eneral contacts and notes
- Denotes personnel present at monthly sumoary management meeting.
Also, the WPPSS gA Manager met weekly with the resident inspector to discuss current status of licensee activities and NRC inspection findings.
In addition to the persons identified above, the inspector also routinely interviewed construction, engineering, and quality control staffs of various site contractor organization Pro 'ect Personnel During this period the following key personnel changes were made on this project:
B. Holmberg, WPPSS Deputy Project Manager Engineering.
(Previously held by R. Foley, who has now left WPPSS).
R. Grant, WPPSS Construction guality Manager.
(Returning to this previously held position, from temporary assignment as Reverification/Task Force II Phase-I/Restart Supervisor.
The Phase I Supervisor post is not planned to be filled.)
M. Clinton, WPPSS Systems Turnover, coordinator of Task III data at WNP-2.
(Assuming the responsibilities of T. Gross, who resigned in December.)
The mechanical contractor organization has experienced a very high turnover of personnel since August 1980.
In addition to gC and Engineering personnel who were laid off during the July work stoppage, many key personnel have resigned during the past few months.
This includes the general superintendent, procurement gC supervisor, containment building lead piping/hanger engineer, reactor building lead engineer, and several lead gC inspectors.
General site morale is low, apparently due to the wor k stoppage, difficulties in effecting the program reviews in progress, and the work loads involving continued shifting priorities.
Shifting organizational structures, including phasing in of the Bechtel contractor for system turnover activities, also appears to contribute to this situation.
The inspector has probed for quality discrepancies arising from this consideration, and has not identified any directly relatable problems which would represent violation of regulatory requirements.
However, due to the high turnover rate, the inspector has increased his emphasis on personnel qualifications, indoctrination, and training.
General
'I The resident inspector was on-site January 8-9, 12-17, 19-23, and 26-30, 1981.
During this period, the inspector continued examination of daily activities of the licensee, the architect-engineer, and the mechanical contractor, concerning efforts to re-evaluate and improve detailed work methods.
Attendance at meetings, examination of correspondence, and interview of personnel at all organizational levels was involved.
Emphasis was on examination of a work restart package and related documentation for the sacrificial shield wall repair girth weld.
The inspector sought to ascertain the scope, criteria, personnel, data base, conclusions, and corrective actions involved in the implementation of the commitments in the WPPSS July 17, 1980 reply to the NRC 10 CFR 50.54(f) inquiry.
An NRC Region V inspector was on-site January 13-16, and 19-22, 1981 to assist the resident inspector in the review of specific items.
The inspector reviewed WBG procurement activities/controls, WBG inspector qualifications, nonconformance dispositions by the electrical (F/L) and instrumentation (JCI) contractor lg
-3-Three Region V inspectors were on-site January 27-29, 1981 to follow-up on recent allegations, review licensee actions on bulletins and circulars, and review the welding procedure qualification activities of the mechanical contractor.
These activities were separate from the resident inspector activities (except for the welding procedure work) and are reported in a separate NRC inspection report.
The resident inspector's supervisor, Chief of the Region V Reactor Construction and Engineering Support Branch, was on-site January 20, 1981.
The Branch Chief reviewed the resident inspector's activities and his basis for conclusions regarding WBG restart of work on the sacrificial shield wall repair girth weld.
The Branch Chief provided WPPSS senior site management with an NRC Region V letter dated January 20, 1981 which concurs with start of this work activity by the mechanical contractor.
On the evening of January 27, 1981 the resident inspector addressed an audience of gC inspectors and documentation control personnel at local 8598 of the pipefitters union.
He discussed the invited topics of:
1) role of the NRC, 2) role of the gC inspector/clerk, 3) reporting defects under
CFR 21 and
CFR 50.55(e).
This union provides gC personnel to the WNP-2 and HNP-1/4 sites.
WBG Indoctrination
& Trainin The inspector attended a typical orientation and indoctrination session which is given to new HBG employees.
At the session there were field engineers and craftsmen.
The session was about 1-1/2 hours duration.
Subjects included safety, job-site general rules, site lay-out, and procedure HP-153 (which describes restrictions for making changes to quality records).
The employees were also introduced to
CFR Part 21, and were told where they could view the detailed procedures.
The instructor described the engineering/construction/quality control relationship.
For the WP-153 and safety presentations, the employees were given examinations, with 100% as the passing criteria.
Isolated missed questions were discussed with the employee.
The questions seemed reasonable and appeared to adequately probe the employees'ecognition of the principal points.
Written handouts, visual presentation aids, verbal presentation, invitations to question, written open-book-type examination, and test result review appeared to provide learning reinforcement techniques consistent with the intent of the WBG general, training program instruction criteria.
The inspector also visited the WBG on-site training trailer, which includes office space for the ten instructors/planners, and a classroom.
Much of the current effort of the training staff is addressed to preparation of lesson plans and examinations for training personnel in WBG procedures.
Due to the recent long labor dispute and shut-down of work, coupled with general revision of all work procedures, the training, workload is especially extensive.
The training effort is also much more rigorous than it had been previously.
To assist in the preparations, WBG has contracted with a local consultant firm for personnel to contribute to this effor t l'
Comnensurate with the status of the training activity, the WBG audit group has initiated an audit of the training function.
The lead auditor advised the inspector on January 29, 1981 that instructor qualifications are being assessed in this audit.
The inspector observed that WPPSS site quality assurance engineers have been attending various WBG training sessions for surveillance and training.
The inspector found the current scope of the training program, and the resources allocated to it, to reflect WBG'anagement's current serious attention to this previously deficient area.
En ineerin Personnel ualifications Performance of work by unqualified personnel was a subject of the June 17, 1980 NRC 10 CFR 50.54(f) inquiry to WPPSS.
The NPPSS July 17, 1980 reply discussed reviews which would include evaluation of engineering personnel qualifications.
Additional NRC concerns were conveyed to WPPSS via general Circular number 80-22, relating to job-shop personnel.
The inspector has made routine inquiries in this matter since July 1980, both with WPPSS and with NBG.
NPPSS has not yet compiled an evaluation and position relative to this matter, however, the following information has been provided to the inspector regarding individual aspects of the matter:
Burns
& Roe permanent employees - The inspector examined typical engineering employment applications, which include authorizing clauses which permit inquiry to past employers and educational institutions to verify data on resume's and applications.
The inspector also examined standard form letters which are used to solicit such data.
Contractor permanent employees - WPPSS representatives stated that they presume that site contractors have personnel hiring/verification practices commensurate with those of Burns
& Roe.
However, they provided no evidence that such practices had been evaluated for acceptability.
(
Burns and Roe job-shop employees - The inspector examined memoranda F-80-3017 and -3560, which show that WPPSS had performed detailed checking of 25 resumes in June 1980, identified some discrepancies, and took corrective actions at that time.
The memos stated that contract-engineering-agencies were required to maintain files of certifications
.that resumes have been verified.
Also, random audits were to be performed by the Burns
& Roe personnel manager.
The inspector examined letters dated October 22, 1980, addressed to contract engineering agencies providing personnel to Burns
& Roe.
The agencies were requested to provide written verification that the agencies had verified resumes of listed personnel.
Reverification Task Force personnel were included on the lists, as requested by the task force supervisor's memorandum of October 14, 1980, RCSW-80-125.
Agencies contacted included 1) Piping Design Services, (2)
HEPCO Incorporated, (3)
TAD Technical Services, 4) Yolt Technical Corporation, (5) Lehigh Desig The inspector interviewed the Burns
& Roe site personnel manager and, the responsible contract specialist.
They stated that they had no knowledge of any audits directed at assuring the proper implementation of the verification provision of the contracts.
Contractor Job-Shop Employees - The inspector examined correspondence (June 10, 1980 MNP2WBG-215-F-80-2015, August 4, 1980 WBGWNP2-215-80-4163)
which showed that WPPSS performed detailed checking of 17 resumes, of 48 submitted by WBG.
Of the 17, questions arose relative to four, and corrective measures were taken relative to these four.
The memoranda did not identify any additional action relative to the other 31 of the 48 submitted resumes, nor any technical evaluations of implications of questionable qualifications.
On the contrary, MBG declined. further evaluation of three of the four questionable resumes on the basis that the individuals were no longer employed by WBG.
This matter is unresolved pending evidence that the details have been considered relative to work restart, and have been incorporated into Phase II Reverification Planning.
(50-397/81-01-09)
The inspector examined three MPPSS memoranda (October 30, 1980 gA2-80-433, January 28, 1981 F-81-700, and January 29, 1981 gA2-81-061) which show Engineering and guality Assurance management attempts to identify, evaluate and assure compliance with engineering personnel screening and evaluation systems.
This matter relates to all safety related commodities and is unresolved pending adequate MPPSS evaluations and corrective actions, (50-397/81-01-01)
Functionin of MPPSS Task Forces Task force II continues to function as described in the licensee July 17, 1980 reply to the NRC 10 CFR 50.54(f) inquiry.
Task force II activities are still generally confined to review of contractors revised procedures and preparations for work restart.
Hardware reinspection activities and record reviews have not yet started.
Task force II activities have resulted in manuals of data which document reviews performed and corrective actions effected.
Such manuals receive review by the project gA organization, and the WPPSS independent review team from the WPPSS corporate office.
Task force III functions were transferred to the WPPSS corporate office during the last report period.
A function has been retained on-site to compile information and submit it to the corporate office.
A WPPSS memorandum to the Managing Director describes the intended program to inform all WPPSS projects of lessons learned at all projects.
The program is not incorporated into formal project management procedures at this time.
Currently, this activity is implemented by a system of Lessons Learned Bulletins, similar to NRC Bulletins, as the mechanism for disseminating this information between WPPSS project offices.
At least one such bulletin has been issued this pe'riod.
The system has not yet been used to transmit much of the significant'ata identified during MNP-2 reviews conducted in the past six months.
The commitment to NRC relative to this activity does not yet appear to be significantly implemented.
(Open) Followup Item (50-397/80-18/02)
s
Review of WNP-2 Mana ement S stem The inspector completed a review of the details supporting the management system description in the WPPSS to NRC letter dated November 12, 1980.
The inspector ascertained that the features described have been established, and where appropriate, governing procedures issued to formally define requirements.
The details discussed in the six appendices to the letter appeared to be adequately supported by procedures, WPPSS and contractor actions taken as witnessed by the inspector, and records of audits/evaluations/
directions, with exception of four items in Attachment 3, (paragraphs 3.5.2, 3.6.2, 3.6.3, and 3.6.4).
The inspector discussed the apparent program weaknesses with WPPSS management representatives, with regard to the following:
Paragraph 3.5.2 - Performance Indications.
Some performance standards have been incorporated in recent revisions of WPPSS Project Management Instructions, such as time limits for processing information requests, audit findings and nonconformance reports.
For specific work activities, the mechanical contractor (WBG) has defined performance indicators in the WBG report for the sacrificial shield wall girth weld repair (task 6 report).
Also, the WPPSS Task Force II Checklist includes performance parameters as an item to look for during work restart reviews.
However, WPPSS apparently has not issued formal instructions to all site contractors, nor-do the contractors yet have internal procedures which require that performance standards be established for all work activities.
This was not a parameter on the model flow chart, nor on the management systems evaluations checklists.
Also, WPPSS has not included performance standards in all appropriate work controls.
For example, gA Instruction k'4-4 was issued 2/2/81 to provide gA review of design change documents to verify that existing codes, standards or Safety Analysis Report are not violated.
The gA review is not a prerequisite to release of the change for construction, and the procedure defines no standards to monitor timeliness of the reviews.
The issue of performance standards is considered unresolved.
(50-397/81-01-02)
Paragraph 3.5.3 - Orientation on Superintendent.
Neither WPPSS nor the contractors appear to have defined any minimum corrective actions, such as suspension of certifications, retraining, reassignment, or other measures for failure of personnel to meet performance standards.
This item will be examined during a subsequent inspection.
(50-397/81-01-03)
Paragraph 3.6.2 - Inspection Criteria Clarification.
Review criteria have not been imposed upon contractors, and have not been addressed by the management systems reviews performed by WPPSS.
The WPPSS personnel did not have available identification of implementing documents for each contractor.
This item will be examined during a subsequent inspection.
(50-397/81-01-04)
Paragraph 3.6.3 - Traceability Definition.
The mechanical contractor adopted a traceabi lity policy to be used fn the preparation of procedures/
WPPSS personnel could not identify any traceability clarification provided by the architect engineer.
This item will be examined during a subsequent inspection.
(50-397/81-01-05)
Paragraph 3.6.4 - gC Supervisor Overchecks.
There appears to be no WPPSS formal instruction to site contractors for routine overchecks of gC inspectors.
Minimum frequency and documentation requirements are undefined.
This is not an item in the management logic network, and was not included in WPPSS evaluations of contractor management systems.
In the case of the mechanical contractor, this concept appears to be used as a basis for abolishing the Engineering guality Assurance over-checks of hanger inspections, previously comnitted to NRC as a corrective action item in 1979.
This item will be examined during a subsequent inspection.
(50-397/81-01-06)
The MPPSS representative stated that these matters will be examined to identify or institute measures to assure implementation 'of the management features described to NRC. These items wi 11 be subject to further NRC review.
Work Restart:
Sacrificial Shield Re air Girth Meld On January 14, 1981 the licensee provided the NRC Senior Resident Inspector with a four volume compilation of review results, relating to r eadiness to release the mechanical contractor (WBG) for installation of the new girth-weld at elevation 541'f the sacrificial shield wall (SSW).
The manuals included the following types of information:
a.
Some of the results of the WBG internal efforts to review its quality assurance program.
b.
Results of the Reverification (Task Force II) review.
c.
Results of the Project guality Assurance special team.review.
d.
Results of the MPPSS Independent Review Team review.
e.
Results of the WPPSS WNP-2 Program Director's executive review.
f.
Also included were a compilation of preliminary comments offered by the inspector in November 1980.
The results mentioned above included compilations of review comments, responses to comments, descriptions of corrective actions taken, and corrective action commitments.
The Program Director's review included direction to the project staff to resolve specific matters prior to the start of work,. and development-of action plans to resolve other secondary concerns.
The inspector examined the manuals with consideration of previous comments he had offered on the preliminary versions of the manuals, and data compiled and observations made while WPPSS and WBG were engaged in the review processes July-.December 198 The inspector considered the commitments made to the NRC by HPPSS in response to the NRC 10 CFR 50.54(f) inquiry, some of the clarifications/
data provided in the WPPSS first bi-monthly report to NRC, and the WPPSS November 12, 1980 management system description submitted to NRC.
The inspector considered the comprehensiveness of the reviews, and the apparent appropriateness of corrective actions and corrective action schedules.
The inspector identified several items which appeared to warrant resolution prior to work start, as had the project gA reviewers and independent review team.
Also identified were items 'whose resolution did not appear to be prerequisite to start of work on the SSW girth weld.
The inspector informed the licensee gA manager of his concerns and comments at the routine weekly exit meetings; Responses and resolutions were provided by copies of documents, meetings, and subsequent exit meeting presentations.
The status of several such items is discussed in other paragraphs of this report.
Many items identified by the various tiers of reviews involve quality assurance program deficiencies which require resolution, but which do not relate to the SSH repair girth weld, and which may be addressed subsequent to the start of work on this activity.
Many such items recognize:
The limited scope of this activity, (one circumferential girth weld, plus shielding material installation, performed at a limited location within the plant),
and the nontypical method of specifying the technical requirements, (including detailed technical directions reviewed and approved by NRC Licensing Staff).
On January 20, 1981, the NRC Region V office issued a letter concurring with the start of mechanical contractor work on this sacrificial shield wall only.
SSW Weld Procedure uglification The FCAH weld procedure (HPS-26) for the SSH repair girth weld was tested and qualified by HBG.
Welders were tested and qualified to this procedure.
These qualifications were done with setting the FCAW welding machines at a specific setting, and marking that setting on the console.
The work procedure was written to require that the console markings used in the test booths were to be used in the field for the production welding, and were to be subject to sole control of the welding engineer.
Calibrated electrical instruments were not used in the test booths, but were required to be used in the field by quality control personnel, to assure welder compliance with electrical parameters shown in the procedur The project gA surveillance staff questioned the lack of calibrated instruments for defining electrical parameters in the weld procedure, and during the qualification of welders.
The welding engineers did not consider this necessary; however, the gA personnel arranged for such monitoring during some welder qualification testing.
It was found that the welders generally could not make weld specimens which pass required testing, if they were held to the parameters shown in the procedure.
The WNP-2 Program Director has prescribed requalification of procedure WPS-26 and requalification of welders to 'this procedure to be prerequisites to start of welding.
The inspector identified a related concern to the licensee in November 1980:
"Do procedures define the need and frequency of weld machine test and calibration"7 The licensee response acceptably addressed the subject of production welding (Procedure WP-170).
However, at that time there was no procedure identified for the SSW girth weld which prescribed the methods of conducting qualification testing.
The need for such a procedure has been addressed by NRC regional inspectors in a separate report regarding a January 27-29 inspection.
Verification of SSW Defect Data The inspector identified that some reinspection activities were in-progress in January, to verify characteristics of defects in 140 existing welds of the sacrificial shield wall.
The responsible Burns 5 Roe welding engineering manager initiated this task due to reservations expressed by one of the weld engineers who had participated in the original inspections.
The NRC inspector interviewed that welding engineer, and determined that the individual had not been fully aware of the purposes of the original inspections nor the accuracy required of his observations.
The data is currently being used by NRC in evaluation of Burns 5 Roe analysis of acceptability of existing defects.
This matter is unresolved pending review of qualifications of personnel performing the original inspections, and instructions which had been provided.
(50-397/80-01-07)
ualit Class II Interfaces The inspector pursued rumors of ASME Class I valves being reworked by WBG without appropriate quality controls.
The rumors were accurate to the extent that 3/4-inch Class I valves had apparently been cut out of piping systems.
The valves were in the WBG pipe shop, where the socket-fillet welds were being cut off in an attempt to salvage the valves.
Care was being taken to avoid contact with the valve body, but in some cases the saw did make contact with the socket end of the valve.
No inspection activities were assigned by WBG.
The on-site ASME authorized nuclear inspector and the WBG auditor had identified this matter and were investigating controls of material salvage operation The inspector observed preparations for start of work for the SSW repair girth weld.
Various interferences were being removed in the work areas under WPPSS approved work orde'r.
Some weld pad plates were to be removed from the SSW, by grinding the fillet welds.
(In-process work showed that the fillet welds actually were partial penetration fillet-reinforced welds and that some arc-gouging of the plates would be required, including preheat of the SSW.
Burns
Roe issued a Project Engineering Directive (PED) for this).
The inspector interviewed one assigned gC inspector, who demonstrated confusion regarding his inspection criteria f'r this work, which had been designated guality Class II.
The WBG quality assurance management and WPPSS quality assurance management were already involved when the inspector brought this to their attention.
Stop work actions were already being formulated, pending resolution of inspection criteria questions.
They stated that the quality assurance controls for removal of materials were being examined.
Provisions for WBG gA review of PED's, for assuring incorporation of inspection criteria, wer e being considered.
The inspector pursued rumors of wor k being performed on a guality Class I hanger/support contrary to the WPPSS general stop work order N9.
The inspector requested a
WPPSS gA surveillance engineer to review the matter, and examined the support himself.
An area on a large Main Steam Line support had been ground in preparation for attachment of a guality Class II hanger.
Paint had been removed, and a material identification number had been transferred (reportedly properly witnessed by a WBG quality control inspector).
No welding had been done, however there appeared to be no constraint against proceeding with that activity.
The weld was made and painted, however, WBG gC inspectors subsequently issued hold tag 841630.
The above items appear to be receiving attention under the WBG quality assurance program.
The WBG auditor especially stated that the reject material controls are being subject to review.
This matter of salvage and other control of guality Class-I/Class-II interfaces will be subject of further review for additional work restart authorizations.
(50-397/80-01-08)
Limited Work Start Authorizations The inspector attended a month-end restart status meeting.
The inspector receives copies of wor k restart authorizations as they are issued to site contractors; he verified that reported status was as shown in these authorizations.
For each authorization, the inspector verified that the item was reviewed by the project gA organization, and the RCSW task force, if appropriate.
The following work release items were reviewed as per above:
a.
HVAC contractor (216) - performance of ultrasonic testing on anchor bolts.
b.
Instrumentation contractor (220) - performance of training onl I U
-11-c.
Coatings contractor (234) - performance of training for concrete coatings only.
d.
Containment structure contractor (213A) - installation of weld pads only.
e.
Mechanical contractor (215) - performance of sacrificial shield wall repair girth weld.
f.
Electrical contractor (218) performance of cable tray bolt re-torqueing.
In each case there appeared to have been appropriate referral to and review by the project gA organization.
MPPSS A Surveillance Plannin The inspector interviewed the WPPSS/Burns
Roe site quality assurance surveillance lead engineers and the surveillance manager.
These personnel described the quality class I limited authorizations for work restart for the various contractors on-site.
They briefly described the planned surveillance activities.
Their descriptions were consistent with authorized wor k releases with which the inspector was familiar, by virtue of routine copies of release letters to the contractors.
The inspector concluded that the MPPSS/BRI gA surveillance personnel were sufficiently aware of the scope of ongoing activities, and were planning their activities accordingly.
The inspector also examined a file of typical surveillance checklists which this group planned to use for the SSW repair girth weld activities.
Associated with the checklists was a hold-point flow chart for integrating the SSM surveillance activity with the production work.
The inspector identified no departure from gA program or RCSW program cormitments.
'll Corrective Action Verifications The WPPSS gA organization has recently found that some commitments made to NRC in 1976 and 1980 were not implemented as described.
MPPSS is currently formulating actions specific to these items.
Additionally, necessary reviews have been defined for other commitments previously made to NRC.
The review activities-have been identified for MNP-2 plus all other WPPSS nuclear projects, in view of the absence of a well defined/
documented system for assuring proper followup implementation.
At the MNP-2 site, an individual had already been assigned in 1980, to compile/expedite/and monitor such activities.
A procedure has been implemented to record NRC findings stated at the exit meetings, and assign action for resolution.
The coordinator documents the items and provides routine checks of progress.
Checklists have been developed for review of responses; these include emphasis on verification of implementation of corrective action The inspector has also noted a similar emphasis in Corrective Action Reports issued by the NPPSS gA organization to the site contractors.
For example, CAR-1502 has been issued to a contractor (JCI) for lack of proper gA program controls to verify implementation of corrective actions on other CAR's.
Super Review Reins ection Activities The WPPSS October 1980 First Progress Report - 10 CFR 50.54(f), Attachment 2 described WPPSS plans to examine records and work completed during the 90 day period prior to the June 2, 1980 work shutdown.
The purpose was to identify matters which would warrant changes to work methods and procedures.
The MPPSS December 1980 Second Progress Report - 10 CFR 50.54(f), Attachment 2 described WPPSS plans to omit such examinations.
This would be supplemented by conditional work releases and initial intensive MPPSS QA surveillance.
The basis for the change was reported to be the fact that all principal contractors already had committed to revise their procedures, and these were to be reviewed for compliance with regulatory requirements/commitments by the WPPSS turnover/restart (Task Force II) group.
However, as described in Attachment 2-A of the December report, 90-day re-inspections have already been conducted for three commodities (special coatings, electrical receipt inspection, and weld pads in containment).
The inspector interviewed Task Force II staff and management relative to the results of these reinspections.
These activities identified some items which would possibly not have been identified solely by procedure reviews (e.g.,
such as controls for painting limited access areas).
However, no major omissions were identified.
The Task Force II management affirmed the opinion that the 90-day reinspection activity is not necessary in view of other review activities.
The inspector identified no departure from the
CFR 50.54(f) commitments and had no further question on this matter.
MBG Procurement ualit Assurance On August 26, 1980, at WPPSS direction, the mechanical contractor (WBG)
discontinued issuing additional purchase orders, except as individually and specifically authorized by MPPSS assigned Directors.
Releases were contingent upon WPPSS reviews and/or audits.
Continuing activities under existing purchase orders were made contingent upon successful audits of the suppliers, or other such conditions.
A more general release to proceed in this area appears to be contingent upon completion of the ongoing WBG efforts to upgrade the vendor control program.
Such efforts include revision of procedures, addition of auditors, review of vendor files and resolution of discrepancie '
-13-A regional office inspector reviewed the current status of the procurement QA controls, examined the records associated with activities in progress since August 26, 1980, and interviewed currently assigned personnel.
Pre-award surveys-, re-surveys, approved vendor list, source surveillance/
inspection, and vendor file maintenance activities were reviewed.
The inspector examined the following particular records:
a.
The ASME QA Manual and the Field QA manual provisions relating to procurement; the applicable ASME Code Section III 1971 with Addenda to Winter 1973 was referenced.
b.
Current revised or new procedures including QAP-364 and 365, and WP-154, 783, and 784.
(These are in place only for quality class II or G work, pending WPPSS release of the work hold).
c.
Approved vendor list, including monthly index, sequential certificate/
survey expiration list, source inspection/surveillance log, vendor survey/survey-finding log.
(These items appeared to be as prescribed in the new procurement procedures).
d.
Approved vendor file - The inspector ascertained that a vendor file was present for those vendors on the approved vendor list.
For several of the vendors, he ascertained the presence of the required pre-survey questionaire, supplier QA program/manual evaluation, supplier information sheet, ASME system certificates and authorization letters, source surveillance reports and qualification update correspondence.
The inspector particularly examined the Vickery-Simms file, due'o questions by the Senior Resident Inspector.
It included sufficient evidence that questions had been resolved and ASME Class I and II capabilities were ascertained by WBG.
e.
Supplier QA manual file - This file appeared to contain'A manuals for all those vendors which WBG has recorded on the approved vendor list as having been pre-surveyed/surveyed.
Quality class I purchase orders which have been released since the August 26, 1980 stop work, under the special provision of WPPSS Director approvals.
No significant discrepancies were noted, and the controls of the vendor files appeared to be better defined than prior to the stop work order.
17.
WBG Internal Audit of Trainin The regional inspector examined an early November 1980 WBG internal audit of the newly revised training procedure HP-157 Revision 5.
The auditors identified three findings and obtained appropriate replies.
Incomplete corrective action was evaluated and rejected by the audit group.
Re-audit was completed in January 1981.
The inspector had no questions regarding the handling of the audit findings, at this tim ~18.
MBG C Ins ector uglification The regional inspector reviewed the roster of 15 WBG gC personnel, and identified no deviations from the requirements of the WBG procedure WP-157.
19.
Electrical Contractor Actions on CAR NCR Deficienc Re orts The regional inspector reviewed 36 Corrective Action Reports (CAR) issued since t1ay 1976.
He also examined all Nonconformance Reports (NCR) issued since August 1979.
This review was confined to evaluation of the technical basis for the disposition of the identified conditions.
Of the 36 CAR's, four remain to be resolved by the contractor.
The inspector had no questions regarding these items.
20.
Instrumentation Contractor Actions on CAR NCR Deficienc Re orts The regional inspector reviewed the 8 Corrective Action Reports (CAR)
issued for the pneumatic instrument line and sampling line contract.
He also examined the 36 Nonconformance Reports associated with this work.
This review was also confined to evaluation of the technical basis for the disposition of the identified conditions.
Of the 8 CAR's, two remain to be resolved by the contractor.
Of the 36 NCR's, only four have been resolved.
The inspector had no question regarding the dispositions he reviewed.
21.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items identified during this inspection are discussed in paragraph nos.
5, 7 and 10.
22, Mana ement Neetin s
The inspector met with the WPPSS site gA manager on January 30, 1981 to discuss status of his inspection efforts and to receive a status report of principal WPPSS activities.