IR 05000460/1979002
| ML19224D519 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 04/03/1979 |
| From: | Eckhardt J, Haynes R, Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19224D514 | List: |
| References | |
| 50-460-79-02, 50-460-79-2, NUDOCS 7907120419 | |
| Download: ML19224D519 (33) | |
Text
{{#Wiki_filter:P . I- ' . ' . . U. S. !!UCLEAR REGULATO?,Y C0iiMISS10il 0FFICE OF IllSPECTI0il AND EllF0.CEMEllT I
m M ' REGI0il V ei] 50-460/79-02 Report flo. 50-513/.79-02 j, ' h 50-460, 50-513 f Safeguards Group .tj Docket flo.
License !!o.
Washington Public Power Supply System % Licensee: P. O. Box 963 Richland, Washington 99352 . Facility Name: WitP 1 and W:IP_4 Construction Site, Corporate Office Inspection at: , Febru ry 12,16,, 197,p A Inspection Conducted: Inspectors;
3
f , Ig'W/Gv4d ' t, %dc&rinspdctor / Dat/ Siefid i D cish~D 3/29/7c) T. W. : Bishop, Reahkor Inspector Date Signed 3/h: Vf7[ ^ / / Data Signed H.
ckh rdt, Rea tor Inspector lDdo 3-sos 9 , D. F. Psirsi'h, Reactor Inspector Date Signed k) 3/hhy Approved By: Date Signed R. C. Haynes, Chief, Froject Sect.o P,eactor - Construction and Engineering Support Branch - Sumary-
Inspection on February 12-16,1979 (Report flos. 50-460/79-02 and 50-513/79-02 < Areas Inspected: Routine, announced mid-term quality assurance in- ! spection by regional inspectors of changes made to the licensee's QA
program subsequent to issuance of the construction permits, including 'n those commitments made by the licensee as a consequence of the t!RC enforcement conference on May 18, 1978.
The inspection involved 148 inspector hours onsite by four NRC inspectors and one supervisor.
. . 79071204'//
Q) ,b,0 - .........mn m .
. . Washiagton Public Power Supply System -?- Dil 50-460 and 50-513 Summary: _
Results: Of the eighteen areas inspected, three items of noncompliance t were identified.
(Failure to foiiow procedures in area of design !;I control, p.
,raph 5,b. - infraction; failure to follow procedures in 1; area of document control, paragraph 8,b.
deficiency; and failure to A include applicable requirements in procureme t acuments, paragraph 6,a - jj deficiency.)
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Individuals Contacted a.
Washington Public Power Supply System (WPPSS) - %l G. L. Conger, Quality Systems Engineer . ,]
R. D. Crisp, QA Engineer M. F. Dreher, Senior U. Engineer a
- G. K. Dyekman, Unit 1-4 Project Engineer
- (
C. R. Edwards, Manager, QA Audits ,i J. L. Gilbert, Field Engineer Supervisor ] T. A. Gross, Senior QA Engineer, Records - "
- A. G. Hasler, Licensing Engineer
- T. J. Houchins Project QA Manager D. L. Howard, Operational QA Manager
- M. W. Hultgren, Division Manager, WriP 1 and 4 D. F. Johnson, Construction Supervisor R. T. Johnson, Manager, Quality Services
- W. M. Lazear, Project QA Supervisor
- F.
D. McElwee, Assistant Director, Pr, : cts R. J. Mills, Manager, Training and Dev iopment J. R. Nickol us, QA Engineer D. D. O'Sullivan, QA Analyst .
- N. S. Porter, Unit 1-4 Project Design Supervisor J. Powell, Construction Engineer
- D. L. Renberger, Assistant Director, Technology K. H. Savitz, Construction Engineer
- J.
P. Thomas, WPP3S Project Manager
- M. E. Witherspoon, Division Manager, Quality Assurance b.
United Engineers and Constructors (UE&C)
- R. H. Bryans, Field Project Engineering Manager V. E. Cichocki, Assistant Construction Manager R. N. Devers, Document Control Supervisor
- H. L. Dibbern, Jr., Management Staff Assistant
- G. L. Faust, Liaision QAE M. D. Feagin, Lead Contract Administration D. Gardner, Document Control Clerk P. Hammill, Field Supervisor, Mechanical Engineer
"{ ~ E. C. Haren, Deputy QA Manager tl B. Hopper, Assistant Document Control Supervisor
- P K. Iverson, Field Supervisor, Naclear Engineering
, il J. A. Raymo.'d. Project Specialist, Audits c.
J. A. Jones Construction Company, Inc. (Jones) j E. Freeman, NDT Supervisor
T. D. Higginbotham, NDE W. S. Roe, QA Manager
- Denotes those present at the exit interview.
321 30?
-2-2.
General Scope _of Inspection g This inspection was an examination of licensee approved chang 9s . t{ made to the Wr1P 1 and 4 Quality Assurance Program since the filing i 3 of Amendment tio. 24 to the WriP 1 and 4 PSAR.
In this report, these j; changes are referred to as PSAR deviations or changes. Other QA 3* program items examined during the inspection included the control ,, of changes to the " quality class" of components or systems, the licensee's compliance with 10 CFR 50.55(e), field procurement d controls, and test and mea.;uring equipment calibration controls The inspection was limited to those QA programs described in the PSAR and implemented at the construction site or WPPS5 corporate offices.
The licensee's commitments made to the flRC as a result of an tiRC enforcement conference held in May 1978, were also examined.
Referencer in this report to " Tasks" or "Sub Tasks" refer to those commitments listed in the licensee's letter to the tiRC, dated September 1, 1978.
For convenience, all inspection activities were orhanized ender the related criteria of 10 CFR 50, Appendix B.
3.
Criterion I Organization a.
FSAR Section 17.1.1 Changed, to Provide a Higher Pecorting Level in the Organization for Quality Assurance (QA As described in a PSAR deviatica and in a cormlitment by the licensee for corrective action following the f41978 t'RC enforcement conference (Sub Task 1.4.b), the licensee has elevated the WPPSS QA organization to " Division" status.
This places the manager of QA at the seccnd ievel of canagement below the managing director of WPPSS.
The reporting level of Quality Assurance is shown in the organization chart provided by the licensee, Figure 1.
In the $_ previous organization. QA repo.2d to the Technical Division.
fj Also changed frcm the organization shown in Figure 17.1-1 of j the PSAR, are the functions of Generation and Technology which
reported to one assistant director in the PSAR but are now .] under separate assistant directors. The separation of Gen-Q eration from the rt porting chain for quality assurance appears
ap, ropriate considering the continued development of QA programs
ior reactor operation. This separation is shown in Figure 1 x and is also part of an i',em of corrective action from the May 1978 enforcement conference (Sub Task 1.4.c) fio items of noncompliance or deviations were identified.
321 300 .,
-3-b.
PSAR Section 17.1.1 Changed to Redistribute Resoonsibilities Within Various Components of the QA Organization m The changes were examined and discussed with the licensee by , the inspector.
No dilution of QA responsibilities or authority ti from that described in the PSAR was found. Figure 2 illustrates !) the current Quality Assurance organization.
[j i _Section 17.4.1 Changed to Provide one Onsite QA Organization If c.
'or the Construction Manager UE&C and WPPSS) t On July 10, 1978, WPPSS and UE&C reorganized the site QA activities of both organizations into a single unit.
This means that the activities described in Section 17.4 of the PSAR titled " Quality Assurance During Design and Construction United Engineers and Constructors (Field QA)" is now being implemented by a joint WPPSS-UE&C crganization.
This effort is now referred to as the "Proiect Quality Assurance Program."
The manager (WPPSS employee) is kne'.. as the " Project QA Manager." The activity continue", to c audited by both UPPSS and UE&C as a joint effort by rie curpora*.e quality assurance organizations.
Figure 2 sho'.s the WPPSS Project QA organizations and their reporting level.
The addition of c speciJ auditor, called a " principal inspe ctor," is not reflected in the r'SAR changes and is not consiered to be part of the WPPSS QA commitoent.
The joint QA organizution far WNP 1 and 4 is typical of similar joint organizations established for other WPPSS nuclear projects. The merger is rart of the licensee's proposed corrective actions as 2 result of the NRC enforcceent con-ference of May, 1978.
It is described in Sub Task 1.2.b in the licensee's September 1,1978 letter.
Figure 3 shows how the total site management structure was merged and the relationship of the project QA organization to other organi-zation elements.
The inspector found the merged organization to be as described 7{1 and to be adequately staffed by qualified people.
No deviation from the intent of the original PSAR or 10 CFR 50, Appendix B ' was found, nor was there any evidence that the necessary l independence of the site QA organization had been lost as a g result of the merger.
The qualifications of the WNP 1 and 4 J project QA manager were examined against those stated originally ]j ? in Section 17.4.1 for the " Field Superintendent-Quality Assurance," a UE&C position.
In the >SAR deviation statement, these same g " qualifications are roe applicable to the WPPSS " Project QA . Manager."
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la d .t .J ' - - (CCMU!f C"> WFPSS UNITED ENG;NECnS AND CONSTRUCTORS 03GANizATf CN) v.NP-1/4 PROJLCT DIVISION MAN AC(ft 4/9837'44 UL&C WPPf, _,,, Ph [[CiMANkGtft C WA5A kR t 11 ?'l t )) o CUONESS CONSTRUCT:ON UE & C HOME OFFICE ACCCUNTING ' (1 (1) (1) ; (3) (3) CPEMAT:cNS A PHlt.AD E LPHI A. P A.
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, I I I I I I I PROJECT CONT ROL I WNP.1/4 CPER ATIONS FICLO CNCINEERING ' (2) (3) (1) lr- --- , I t i I i . ' sTAaruP ANo (1) Organizations Composed of UE&C Personnel s.
cre n A noNs (3) (2) Organizations Camposed of WPPSS Personnel . .. _ _.. . _ _ - , (3) Organizations Composed of both WPPS^, and UE&C Personnel V FIGURE 3 . N I . _.
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Criterion II - Quality Assurance Program ~ f
a.
PSAR Deviations
3 The following deviations from the PSAR were examined: ' 3 , (1) Deviation 17.1-4 and 17.4-1 (2/6/79) j This deviation constitutes a reorganization of Sections
17.1 and 17.4 of the PSAR to reflect organization changes ] A descrihed in Paragraph 3 above.
(2) Deviation 17.1-3 (6/22/78) Changes 17.1 and 13.1 of the PSAR to reflect the change in the reporting level for the WPPSS QA organizatior.
(3) Deviation 17.1-2 (6/22/78) Deletes references to QA procedure QAP-ll on Site Receiving Inspection and QAP-12 on Construction Inspection.
These procedures were deleted from the WPPSS QA Manual since WPPSS does not perform either function.. (4) Deviation 17.1-1 (4/15/77) Deletes requirentent in PSAR Paragraphs 17.1.18 for WPPSS to audit site contractor activities.
WPPSS, at that time, stated that the AE/CM was responsible for such audits.
However, it is to be noted that in the merged site QA organization, this responsibility again becomes a WPPSS responsibility in accordance with the commitments of Section 17.4.
The inspector's questions regarding these deviations from the PSAR were satisfactorily resolved. The inspector's only conment was that PSAR deviations were being prepared and approved up to seven months after the fact. This appeared to be excessive and contrary to the intent of EDP 8.4 " Origination, Approval and Distribution of PSAR Deviations." The licensee's w- - position was that PSAR deviations could be approved after the
fact and that this was the only practical thing to do with ~; Jlt regard to such things as organization changes.
However, they did agree that excessive time had been taken in the case of Deviations t'o.17.1-4 and 17.4-1 which were pr epared immediate' -
prior to the announced i: 'C inspection and approximately seven j months after the change was implemented.
The WP?SS QA manager j stated that this would be monitored more closely in tne future.
n The inspector had no further questions on this matter.
321 313 - .. O
-5-b.
QA Training Program Records Records of QA indoctrination training were examined for a m
randomly selected sample of four WPPSS field engineers.
fio
discrepancies were identified by the inspector.
,b c.
Training Program Applicability _ ,{ 'e The original Section 17.4 of the PSAR did not contain a h! specific commitment for training of UE&C QA personnel nor is j; such a commitment part of Section 17.2.
In the absorption of
UE&C personnel into the WPPSS organization it was not clear t to the inspector how the WPPSS train 49 corrmitment applied to those UE&C personnel absorbed into the site QA organization.
WPPSS stated that site QA training orientation for UE&C personnel was the same as WPPSS orientations and that UE&C QA auditor certification was equivalent but from a UE&C source.
The area will be examined during a future inspection.
(460/79-02-01) d.
Quality Control Training for Contractors ' As part of corrective actions in response to the NRC enforce-ment conference of May,1978, WPPSS made a commitment to provide and implement an action plan to upgrade QA/QC training (Sub Task 1.1.a.6).
The ongoing program developed as a result of this commitment is known as Quality Training and Indoctrination Program (QTIP). This program is intended to provide the individual QC inspector with training in specific functions such as receiving inspection, cadweld inspection, structural steel inspection, as well as providing training in the admin-istration of quality programs involving such matters as the handling of nonconformances, document control and auditing.
The training is being provided by the development of video tapes which.till be presented to the inspectors by qualified trainers according to the lice,;see. Also, inspectors from all contractors will be scheduled to attend training.
Approximately 50 training modules are being developed initially with training i_ scheduled to start in April, 1979.
j g The program will be examined further during a future inspection.
j (460/79-02-02) j . c.
Management Attention t.a QA Program A Corrective Action Sub Tasks 1.1.a.3,1.3.a, and 1.3.c from the May, 1978 enforcement conference address the subject of trend analysis reports. The inspector examined samples of such reports and had no questions.
bLb b$l _ , .
b li E, ' -6-y ' [/ In Sub Task 1.1.a.3 the licensee was aho committed to the i revision nf position descriptions to enphasize individual
responsibility for quality.
Included in this task were other actions such as letters from the Managing Director and pro- - > ~ $
The inspector noted that the revised position cedure changes.
t , received all of the required approvals.
.i descriptions had not r WPPSS said this was an oversight to ba cort acted immediately.
} { ' The inspector had no fur ther questions at this time.
f.
Mandated Solutions and Enforcement Guidelines _ E g, In Sub Task 1.3.b of the (.orrective actions from the NRC i enforcement conferance of May,1978, the licensee comrnitted to ' evaluating a basic change in philosphy which would provide contractors with more mandated solutions to quality problems.
For instance, uniform guidelines had been established previously Essentially the for contractor weld rod control procedures.
philosophy is to provide contractors with uniform procedure guidance stating what the contractor must have in his procedures WPPSS has embarked for such procedures to be found acceptable. Initial work consists of on a program to accomplish this.
compiling construction precedures from several sources and Follow-on work will then consist of wunowing the material.
act ual development of the guidance.
In the same commitment, WPPSS revised procedure PMP 5-117 to provide more guidance T.o management in the enforcement of This same corrective action is a quality related action. response to Sub Task 1.4.a titled " Evaluate more drastic enforcement techniques."
The developent of mandated procedure contents will be further examined in future inspections.
(460/79-02-03) WPPSS management also stated that new contracts have specific provisions which allow WPPSS to withhold payment for any work Further, many existing which is deemed to be nonconforming.
contracus have been subjected to a legal review to establish that such a provision can be enforced in the context of the "~ contracts as presently written.
l .g Site Program of NSSS Supplier M g.
The activ ties and program of the suall (one man plus a part-i ll time man) onsite organization maintained by P'W were examined j) including audits by thc corporate office to assure that the J B&W QA program was being implemented.
E The inspector found that the applicable quality assurance functions were being accomplished.
321'315 i _7 5.
Criterion III - Design Control H The licensee's design control system was examined for compliance y with changes in PSAR Sections 17.1.3 and 17.4.3.
The examination ,y consisted of selected procedure and implementation reviews.
J
- ?
a.
Review of Quality Assurance Implementing Procedures J k) The following proceduces effecting the licensee's design /l control system were examined for compliance with the PSAR J " commitments: (1) QAP-2: Organizc ion (2) QAP-4: Design Control (3) QAI-4-4: QA Review of Design Documents (4) FGS-6-2: Control of Contract Change Document: (5) FGCP-35: Field Change flotices - Initiation and Processing (6) PMP-4-99: Technical Review of AE Prepared Specifications (Superseded by EDP-6.3 on June 30, 1978) (7) EDP-6.3: Technical Review of AE Prepared Specifications (8) PMP-5-lli. Design Change (9) PMP-6-102: Project Review of AE Prepared Specifications (10) PMP-5-lll-2: Field Change flotices (11) EDP-2.1: Engineering Division Charter (12) EDP-3.4: Change Control Policy (13) EDP-4.2: External Design Interface Control .. - (14) EDP-4.3: Design Calculations, Preparation, Review, Approval and Control [E (15) EDP-4.8: Performance of Design Ver-fications el (16) EDP-4.16: Control of Design Change Requests /liotices , " (17) EDP-5.3: Preparation and Control of Design Criteria 321 316 .
-8-EDP-2.1 requires that WPPS3 engineering division perform periodic audits of project design and construction activities n for technical adequacy.
Discussions with licensee personnel
indicated that the engineering division had not performed
- !
these audits and that the audit activity was actually performed (J ' by the QA division. Audit records indicated that QA divisicn i had performed the audits of design control as required by the d PSAR. The licensee stated that the procedure would be revised y to delete the requirement for periodic audits by engineering.
J EDP-2.1 states that WPPSS engineering division approves design concepts, layouts, general arrangements, plot plans, access planning and design critoria prior to release to the AE.
Discussions with licensee personnel indicated that engineering division had reviewed and approved design criteria, system P&ID's and selected other drawings, and that they met the intent of the procedure. The licensee's commitment in the PSAR was that engineering review only selected drawings.
Consequently, the licensee stated that the procedure would be revised to conform with current practices regarding drawing review which are consistent with the PSAR.
_ The inspector observed that the design review checklist of PMP-4-99 was much more comprehensive than the checklist of EDP-6.3.
Licensee representatives noted that this difference had been identified by them previously and that the checklist of EDP-6.3 was being revised to more closely correspond to that of PMP-4-99.
The PSAR, Paragraph 17.1.3, requires that WPPSS licensing, operations, project management, engineering and QA review and approve specifications. The inspector observed that the release for bidding sheet (Form WP123) of PMP-6-102 contains no approval signature blanks for operations and licensing.
Examination of selected specification review documentation indicated that licensing ana operations had conducted the required reviews and exercised tacit approval by signature on the specification comment / resolution forms.
The licensee ]_ indicated that form WP 123 would be revised to include WPPSS i licensing and operations approval :,ignature blanks to assure j) that the approvals are properly documented.
q The review of WPPSS and A/E procedures reviewed indicated that j ' the design control commitments of the PSAR appear to be j properly implemented.
Only minor discrepancies in form, not a substance, were observed by the inspector.
The inscector has -.. no further questions on these items at this time.
32\\ h\\,' .
-9-b.
Review of Quality Records - The following quality related records were examined to ascertain G comoliance with selected PSAR and design control implementing y procedure commitments: O H (1) Design review checklists, review and approval r.heets and h (flSSS Piping and Equipment), 218 (Main Electrical Contract),
- ")
comment / resolution forms for specifications 97/9-211 ' 254 (General Services Building Superstructure Above Finot [. Lift and Adjacent Structures) and 257 (Piping and Mechanical Installation).
(2) Evidence of proper reviews approvals and quality classifi-catien for selected Field Change flotices (FCils) as indicated below: (a) specification 9779-211: 8 FCris examined (b) specification 9779-218: 7 FCfts examined (c) spec ification 9779-254: about 30 FClis examined (d) specification 9779-257: 11 FCris examined The inspector questioried the quality classification of FCfl flos. 257-1-79-028 and 254-1-79-058 to specifications 9779-257 and 254, respectively.
FCN 254-1-79-058 identified that non-class I electrical conduit sleeves interfered with Quality Class I rebar and provided the technical direction that the interfering rebar should be cut or bent (a Quality Class I activity \\. Revisions 0 and 2 of FCil 254-1-79-058 were properly classifud as Quality Class I while Revision 1 was improperly classified as Quality Class II. The change effected by this FCf1 vias implemented as ~ a Quality Class I activity by Revlsior 2 and had received the _ ' proper reviews and app. ovals. The contractor's procedure for field fabrication and adjustment of reinforcing steel (AWSh 'd ]{ QCCP-17) was examined and appeared to provide adequate controls ' for heat bending of rebar.
The inspector had no further questions regarding FCil 254-1-79-058.
Q
The inspector found that FCfl 257-1-79-028, approved on January 26, u 1979, was improperly classified as Quality Class II and should ~ hve been classified as Quality class I.
The FC,1 identified trat anchor bolts for the eme.gency diesel generator sole plates were improperly located.
The resolution provided by 321 318
-10-the FCit was that the existing holes in the sole plates would be slotted, to permit correct location, and then plug welded to return the sole plate to original configuration.
Specifi-cation 9779-053 (Diesel Generators) under which the emergency diesel generators and nounting attachments were supplied, was
defined as Quality Class I.
The backun ?!CR defining the y problem, necessitating the FCil, had been properly classified
as Quality Class I.
The provisions of FGCP-35 (Field Cnange
flotices - Initiation and Processing) Paragraph 6.1, which states that quality assurance will " review and approve FCNs efj that direct field changes to Quality Class I activitieo" was not complied with since quality assurance did not reviaw and ? approve FCil 257-1-79-028.
This is an item of noncompnance.
(460/79-02-04) fio other items of noncemoliance or deviations were identified.
c.
Control of Changes to Quality Classification of Equipment _ The method of contral of quality classification of equipment has been established in WPPSS procedure QAP-3 (Quality Assuraace Classification). The QAP establishes a formal sequence of responsibilities for initially establishing equipment quality classification and for controlling changes in classification, as well as requiring the AE to caintain a quality classification list.
The implementation status of the procedure was reviewed with cognizant QA, engineering, and licensing personnel and two changes in quality classification were examined for evidence of compliance to the procedure.
While no items of noncompliance or deviations were identified, it was noted that changes in quality classifications are not handled in strict accordance with the QAP.
Specifically, engineering evalu-ations and subsequent QA review documentation does not clearly indicate that all aspects of consideration have been addressed in the evaluation.
In addition, a specific document titled " Quality Classification List" does not exist, although other documents which contain similar information do exist (e.g., the Equipment List).
Licensee representatives stated that the procedure for controlling the quality classifications would be examined and appropriate action. taken.
This item will be . - reviewed during a subsequent inspection.
(/60/79-02-12) ,/ ' C.
Criterion IV - Procurement Document Control h3 Procurement document control program changes principally involved a d consolidation of WPPSS QA and UE&C onsite QA responsibilities.
The ? other aspects of procurement document control (e.g., development, d engineering reviews, and procurement quality requirements) were not e " changed.
To assess the inplementation of the established procurement documt.t control requirements the inspectors reviewed five procurement 321 3i9 .
-11-packages.
The review of three of the packages included an exam-ination of the procurement document (contract specification) and review documentation, bid evaluation documentation, and appropriate - correspondence. These packages were: Contract 9779-257, Piping
and fiechanical Installation; Contract 9779-218, Electrical Instal-
lation; and contract 9779-249, Field Coatings.
In addition contract ti specification 9779-211, flSSS Piping Installation, and bidding j documentation for contract 9779-2, flSSS and fluclear Fuel, were -,e sampled for incorporation of selected PSAR criteria.
The following l{ items were identified from the examination: i a.
Quality Assurance Provisions Sectior, 17.1.12 of the PSAR requires that "WPPSS and UE&C generated procurement documents be reviewed and approved to verify tnat requirements have been included which provide for the development cnd implementation of measures to control measuring and test equipment." Among the requirements listed in the PSAR are the following: " Calibration intervals for each device are based on the type of equipment, required accuracy, intended usage, and other conditions affecting inspection, measurement, testing, and maintenance control.
"Calibrath n standards are maintained, calibrated and used in an environnent taving temperature and humidity controls that are compatible with required accuracy and operating characteristics of the standards.
" Records are maintained that indicate that calibration history and the next scheduled calibration date for each controlled device.
" Devices that have not been properly maintained or calibrated in accordance with specified schedules have been identified and removed from service.
"An investigation will be conducted and documented to Q-determine the validity of previous inspections performed $. when measuring and test equipment are fourd to be out of calibration."
The contractor QA requirements section of specifications 9779-h 211 and 257, which had been rev ewed and approved by WPPSS and j i UE&C personnel, did not contain or reference the PSAR comitments n regarding control of measurement and test equipment.
It 321 320 . .
-12-appearc that the reviews and approvals of these specifications failed to verify that the above PSAR requirements were included in the procurement documents containing these specifications.
, i This is an item of noncompliance (460/79-02/05).
'" d b.
Bidding Document Reviews The bidding documentation for contract 9779-2 contained design S.J criteria for the reactor vessel, reactor coolant pumps, and W steam generators which differed from the PSAR.
pecifically
"" the PSAR, Section 5.1, indicates the design temperature of these components is 670 F, whereas the Babcock & Wilcox Bidding Documentation, A24-2, Vol. I, Section 4.5, identify the design temperature for thase components to be 650 F.
Investigation by the licensee into this siwation established that the reactor vessel and steam generators were constructed to a design temperature of 670 F while the reactor coolant pemps were constructed to a design temperature of 650 F.
These temperatures are consistent with data provided in the NRC approved B&W topical report B-SAR-205, Vol. 2.
Licensee representatives stated that the PSAR would be amended to correct the inconsistency.
This item will be re-examined in a subsequent inspection.
(460/79-02-06) c.
Bid Evaluation The bid evaluation documentation for one contract examined included a memorandum which contained a statement indicating that the QA manager proposed in the contractor's bid was un-acceptable to WPPSS QA due to limited construction experience.
Although the licensee stated that the proposed QA manager was later found to be acceptable, they were unable to provide documentation addressing this resolution.
This item is un-resolved and will be examined further in a subsequent inspcction.
(460/79-02-07) 7.
Criterion V - Instructions, Procedures and Drawings n.- This area was not inspected because the licensee had not significantly } changed the PSAR specified QA requirements.
p >+ 8.
Criterion VI - Document Control I' s The licensee's document control system was examined for compliance j with commitments specified in changed PSAR Sections 17.1.6 and
17.4.6.
The examination consisted of selected procedure and imple-a mentation reviews.
321 321
-13-a.
Review of Quality Assurance Implementing Procedures The following procedures were selected and exanined for com-m pliance with PSAR comitments.
r3 (1) QAP-6: Document Control i ? (2) FQS-5-1: Initiation, Issue, Control and Revision of Field Quality Standards d (3) FQS-5-2: Control of Contractor QA Programs, QA Procedures e and Construction Procedures (4) Control of Contract Change Documents (5) Development and Preparation of Field General Construction ibnagem- : Procedures . (6) FGCP 38: Document Control of ConPactor/ Vendor Information (7) FGCP-39: Design Document Control ' The WPPSS and A/E procedures reviewed indicated that the document control comitments of the PSAR appear to be properly implemented.
flo items of noncompliance or deviations were identified.
b.
Review of Quality Records The following quality related records and activities were examined to ascertain compliance with selected PSAR and docu-ment control implementing procedure requirements: (1) Field document control center utilization of engineering purchasing schedule to assure specifications contain the latest information as required by FGCP-39.
(2) Contract modification and document transmittal activities I as required by FGCP-39.
fp (3) Document control number listings and distribution lists U for FGCP's and FQS's.
' - (4) Current revisien status of FGCP controlled copy fios. 1 ] and 55 end FQS controlled copy rios. 6 and 69.
(5) Evidence of proper reviews and approvals of FQS and FGro procedures and field changes.
321 322 .. _
-14-(6) Change orders 10 and 11 to specification 9779-218 and change orders 25 and 26 to specification 9779-213.
,_ m (7) Ten drawings in drawing control files effecting installation f1 of the emergency diesel generators.
/j An examination of emergency diesel generator supplier I furnished master installation drawings in the UE&C drawing il control files identified that ten drawings were not j posted with the WPPSS quality class.
These drawings i "" were: (a) 9779-20243, Revision 1: Foundation (b) OMS 9, Revision S: fio.190 AC Synchronous Generator Top Air Discharge (c) 09-810-76084, ~ Revision D: J W Piping Schematic (d) 09-835-75084, Revisicn H: Starting Air Piping Schematic , (e) 09-805-75084, Revision D: Exhaust Intake and Crankcase Piping Schematic (f) 09-820-75084, Revision H: L.O. Piping Schematic (g) 09-827-75084, Revision D: Fuel Oil Piping Schematic (h) R3939, Revision E: Installation Drawing DSRV-16 (1) 9779-20238, Revision 1: Engine Mount fictes (j) 100232: Suggested Concrete Foundation Details and Engine Erection and Installation Notes Specification 9779-053, Revision 5 (Diesel Generators) is r defined as WPPSS quality class I and states in Paragraph 11.2
that "A71 contractor's drawings submitted shall be posted with M the WPPSS quality class as designated in these documents and as called for on the engineer's design drawings." The licensee i and AE were unable to shev that the supplier had notified the j owner and engineer of any deviation from the contract con-
cerning drawing posting requirements.
- -
This is an item of noncompliance (460/79-02-08).
-, 9, b* ..._.
-15-An examination of the UE&C field document control center's method of transmitting change orders to site contractors identified that the method used was not as specified by FGCP- ' 39. The method being used was specified in a departmental procedure which had not been reviewed as required for the ' y FGCP's and had not been formally established as a part of Q{l FGCP-39 requirements. The new method was an improvernent over the previous practices. The licensee took inmediate action to f issue a properly appropriate field change to FGCP-39. The r !> inspector had no further questions.
4: No other items of noncompliance or deviations were identified.
- 9.
Criterion VII - Control of Purchased Material, Equipment and Service Programmatic changes in the control of purchased material, equipment, and services were examined. The principal change involved the consolidation of onsite WPPSS and UE&C representatives.
UE&C (home office) has retained the responsibility for vendor (including ilSSS) surveillance offsite.
Implementation of the onsite and offsite surveillance activities was reviewed with licensee and UE&C repre-sentatives and selected records of surveillince were examined.
It was noted that surveillance activities are being conducted in accordance with the WPPSS approved UE&C surveillance procedure QA 7-2, Vendor Surveillance.
Six surveillance reports conducted by UE&C and WPPSS QA representatives were examined in detail. The reports appeared to be comprehensive, and corrective actions sufficiently thorough to control activities.
No i ems of nor.ampliance or deviations were identified.
t 10. Criterion VII.
Identification and Control of Materials, Parts and Components This area was examined to verify the inclusion in procedures of changed PSAR commitments. All of these changes stem from the combining of the WPPSS and UF&C site QA organizatior.s.
The following procedures were examined: TJ ~ (1) QAP-8: Identification and Control of Material, Parts and 'q- ' Components
(2) FQ5-8.1: Identification and Control of Prepurchased Items l ' (3) FQS-8.2: Material and Equipment Transfer ^ (4) FQS-8.3: Control of Material Traasferred or Placed in Scrap or Salvage (5) FQS-10.1: Receiving.nspection of Prepurchased Items 321 94 ~ .
-16- %2;t)' FQS-13.2: Storage Inspection m (7) FQS-14.1: Prepurchased Item Status [i ,, . (8) FQS-14.2: Inspection Stamp Control 1,1y flo items of noncompliance or deviations were identified.
11.
Criterion IX - Special Processes j The NRC inspector reviewed the construction procedures of AWSH (contract 253) and J. A. Jones (contracts 211 and 257) and deter-mined that special process procedures covering welding, nondestructive testing, rebar bending, and cadwelding were included as required by the PSAR and any changes to the PSAR, Also, the procedures were checked to ascertain that reviews of the special process procedures by appropriate licensee and CM personnel were performed.
fio items of noncompliance or deviations were identified.
12.
Criterion X - Inspection ' Programmatic changes in the inspection program consisted of con-solidating onsite QA responsibilities of UE&C and WPPS!. The consolidated QA organization (Project QA) has responsib1?ity for receiving inspection of prepurchased materials, approval s site contractors' inspection procedures, and secondary verificatio.. of work (when required). The inspector examined four site-contractor inspection proceduces for evidence of satisfactory project QA review and approval, and examined receiving inspection activities.
While no items of noncompliance or deviations were identified, it was noted that personnel involved in receiving inspection were not fully knowledgeable regarding procedures for handling certificates of cenformance when received in lieu of documentation.
Receiving inspection personnel reported to the inspector that certificates of conformances (in lieu of documentation) would be accepted if the '~ certificate was stamped by UE&C surveillance personnel, whereas WPPSS procedures (QAP-7, Revision 4, " Control of Purchased Material,
Equipment, and Services") requires AE engineering revicw and approval y ' of certificates. However, no actual instances were found where ? equipment had been accept 2d on a certificate of conformance without
AE engineering review.
Licensee representatives stated that actions .I would be taken to assure receiving inspection personnel were i knowledgeable of pertinent requirements. This item will be re-j examined during a subsequent inspection.
(460/79-02-09) L fio items of noncompliance or deviations were identified.
321 325 ., e
-17-The amended PSAR also added requirements for final acceptanc( inspection of contractor's work by Project OA.
This aspect af the - QA program will be examined as part of the routine fiRC inspection ] program when these final inspections are being performed.
l
13. Criterion XI - Test Contro_1_ g The consolidation of onsite WPPSS and UE&C QA organization re-sponsibilities was examined in the area of test control.
The ! J inspector found that the Project QA organization has responsibility ' for assuring test control requirements have been established in procurement documents. This action was verified as satisfactorily implemented by a review of two procurement documents (contracts 9779-218 and 257).
No items of noncompliance or deviations were identified.
14. Criterion XII - Control of Measuring and Test Eouipment The licensee's system for control of measuring and test equipment was examined for compliance with commitments specified in changed PSAR sections 17.1.12 and 17.4.12.
The examination consisted of selected procedure and implementatier, reviews.
a.
Review of Quality Assurance Implementing Procedures The following procedures and specifications were selected and examined for compliance with PSAR commitments.
(1) QAP-15: Control of Measuring and Test Equipment (2) Division 52 Section 52A: Contractor Quality Assurance Requirements for WPPSS fluclear Projects 1 and 4 (Issue 4) (3) WPPSS-0005: Quality Assurance Requirco nts (4) Specification 9779-257: Piping and Mechanical Installation _ (5) Specification 9779-211: fiSSS Piping and Equipment (6) P0P-fi-704 W, Revision 0: J. A. Jones QA Procedure for $ Calibration and Control of Measurement and Test Equipment' ] (7) J. A. Jones QA Training and Certification Program, Section II, Part A: General Procedure and Criteria for flon-
destractive Examination Personnel
321 326 _
. -18-Sections 17.1.12 and 17.4.12 of the changed PSAR require, in part, that site contractor end projcet approved procedures require that the following detailed control requirements be { implemented at the site as part of the site measuring and test , equipment calibration program.
The J. A. Jones QA program was ? sdmpled to determine implementation of PSAR requirements.
The .j following items were identified from the review: Cs d (c) "flaintenance and control of the appropriate standards j facilities with the associated records." This - requirement was not addressed oy J. A. Jones procedure fio. P0P-fi-704W, Revision 0.
'f (b) " Primary and secondary standards are mair.tained at a proper site facility by the va onsible site con-tractor along with certificati,n data." The controls necessary to maintain standaras certification data were not addressed by procedure P0P-fi-704W, Revision G.
(c) " Site contractor procedures provided for thest calibrations to have certified -icrz:f r traceable to the f1BS and to be performed under applicable controlled conditions of temperature, temperature rate of change, relative humidity and dust."
J. A. Jones procedure POP-fi-704W, Revision 0 did not address the control of environmental conditions applicable to standards or measuring and test equip-ment.
(d) " Site contractor calibration frequency charts provide o requirements for fcequency of calibration and a certified percent of accuracy..." The calibration record card used by J. A. Jones did not have an entry point for calibration accuracy requirements I nor did POP-N-704W, Revision 0, require that accuracy requirements be entared on the calibration record card.
,r The J. A. Jones procedures diC not reference the above require-ments.
Procedure P0P-h-7044, Revision 0, had beu approved by ,; UE&C QA, engineering, construction and mechanicai departments j on Jul, 12, 1978 and by the UE&C project manacer on July 13, h 1978.
fio instructions to reviewers or checklists are utilized
in procedure review.
j e J. A. Jones had recently submitted a revised procedure for the " control of measurement and test equipment for review and approval of the WPPSS/UE&C organization.
This procedure revision was under the review process.
J. A. Jones had not 321 327 __
' L , ( -19-performed any accept / reject inspections of quality class I items using their measuring and test equipment.
This area - will be examined furthcr during a subsequent irspection.
(460/79-02-10) \\> b.
Observation of Work and Work Activities and Quality i; Record Review , ', The following test equipment and activities were examined in l ^ the J. A. Jones measuring and test equipment storage area.
The findings are listed below the item examined.
l (1) Torque arench testor - a new instrument which had never been used.
(a) flo serial number was attached to the device.
J. A. Jones personnel immediately vibraetened the assigned SilqJAJ-47 onto the device.
' (b) J. A. Jo ies had not attached a calibration sticker to the uevice.
A supplier's calibration sticker was attached.
(c) The instrument was mounted on a 3/4" fiberboard and not on a steel plate as specified by manufacturebs recommendations.
(d) Instrument recall system and instrument usage log were established.
(e) Instrument tolerance requirements were not entered on calibration record card.
(2) Torque wrench-usage log established indicates the wrench had never been used.
@_ ' (a) Calibration sticker was not attached to the wrench.
(b) The wrench was marked with serial number 0JAJ-46.
] (c) Recall system was established.
(d) flo tolerance indication or calibration record card.
A 371 320 -.,
-20-(e) Purchase Order tio. 1-0338-391 specified that the torque wrench accuracy requirements were i 1%. The manufacturer's certifications and calibration data _ did not meet the + 1% requirement and tiCR-008 was written documentiiig the fact.
The t1CR was resolved ,3 " Accepted-as is" based on a determination that i 1%
- p accuracy was not required, however, the resolution lj'
Jid not state what accuracy requirements were ! necessary.
'; '1 '3 . (3) Thermometer - S/fl QJAJ-45 - (a) tio calibration sticker was attached.
J. A. Jones personnel stated that the calibration sticker was removed because the thermometer read 0 F low at the upper region of the scale.
The thermometer's usage log indicated that it had been used to measure weld rod oven temperature and contained no entry docu-menting that the thermometer was removed from service due to inaccuracy er that the rod oven temperature had ever been rechecked to verify acceptability.
J. A. Jones personnel noted that since the thermome-ter read low and an acceptable reading had been obtained, the oven temperature was obviously above the required minimu:: An flCR had not been written documenting the out-of-calibration condition as required by procedure P0P-ti-704W, Revision 0.
The out-of-calibration thermometer was not segregated from acceptable measuring and test equipment and contractor personnel subsequently provided segregation.
(4) Dial indicator - S/l1 QJAJ-68 (a) tio calibration sticker was attached.
(b) tio tolerance indicated on calibration record card.
(c) Instrument recall card, usage log and inspection me r calibration report appeared satisfactory.
,q (5) Pyrometers - S/t1 QMJ-51, 52, 53 (a) Calibration sticker, manufacturer's calibration 'l certification, usage log and recall log were sat-q isfactory.
' - (b) Calibration record card did not record a tolerance requirement.
32i 329 - .
-21-(6) Paint gauges - S/ll QJAJ-55 and 56 (a) tio calibration stickers were attached.
, !)! (b) Calibration check strips were not identified uniquely.
(c) Recall card usage log were established.
<j Based upon the above findings, it appears that J. A. Jones had !l not established full procedure compliance; howevu, the con-J tractor was just bc3 inning to set up the measuring and test - equipment laboratory and issue area.
tio test equipment had been used for acceptance of a quality class I activity. This area w.ll be examined further during a future inspection.
(460/79-02-13) 15.
Criterion XIII - Handling Storane and Shipping Programmatic changes in the handling, storage and shipping included consolidation of most onsite QA responsibilities between UE&C and WPPSS and transfer of storage, handling and pre.cervation surveillance responsibilities from UE&C to WPPSS QA. Genercl implementation has been accomplished through WPPSS QAP-16 (Handling, Storage and Shipping) and UE&C QA-13 (Handling, Storage and Shipping).
fio items of noncompliance or deviations were identified.
16.
Criterion XIV - Inspection, Test, and Operating Status In additic i to the consolidation of onsite UE&C and WPPSS QA organizations responsibility, the amended PSAR also expands the equipment tagging status categories.
Formerly the PSAP. identified only three status categories (Accept, Reject and Hold). The current requirement includes five categories (Accept, Reject, Hold, Condi-tional Release, and Awaiting Inspection) to more definitively control material status.
The amended program has been implemented onsite by UE&C procedures QAP-14 (Taggir.;;, and FQS 8-1 (Identifi-cation and Control of Prepurchased Equipment).
7-fio items of noncompliance or deviations were identified.
+ fi 17.
Criterian XV - f;onconforming Materials, Parts or Comoonents ll a] a.
Elinination of " Discrepancy" and " Deviation" Categories ' i Section 17.4.15.1 cf the PSAR was changed in PSAR Deviation f 17.4-1 to eliminate the seriousness categories in favor of F direct reliance on the commonly accepted " reject," " rework," 321 330
. . 22- " repair," or " accept-as-is" categories.
A universal UE&C non-conformance report form is provided which site contractors are required to use.
Field Quality Standard FQS 15-1, revised ~ flovember 1978, constitutes the procedure governing such usage.
WPPSS QAP-18 also governs such usage but the revision of flarch
1977 was not definitive regarding site contractor requirements.
d The inspector did not find any direct inconsistencies between Mi the Field Quality Standard and the WPPSS QAP.
tionetheless, Jf l the licensee reported that the later document was under revision.
f The inspector idcntified no items of noncompliance or deviations.
!j
b.
Reporting in Accordance With 10 CFR 50.55(e) Licensee actions in the evaluation of 50.55(e) items was examined. The evaluation and reporting system, which is implemented by four procedures specifically directed to 50.55(e) and Part 21 reporting, appeared to be cumbersome and time consuming. Of eleven items evaluated, five took over seven months to decide whether or not the item was reportable.
This item was discussed at the exit interview and the licensee agreed to streamline their evaluation system. This will be further examined during subsequent inspections.
(460/79-02-14) 18.
Criterion XVI - Corrective Action Enforcement conference commitment item 1.2.a deals with shortening of response time to quality findings.
The tiRC inspector reviewed QAP-20, Revision 8, (February 2,1978), " Audits," which identifies response times and discussed the levels of escalation for delinquent responses with the licensee.
Review of recent audit:: indicated that response times have been adequate.
19. Criterion XVII - Quality Assurance Records The systen of storing, filing, and retrieving quality records was discussed with the licensee.
During the course of this discussion it was determined that the system being used is presently evolving and thus FQS-17-2, Revision 2, " Retention and Control of Quality - Records" does not reflect the actual system that exists.
The
licensee was aware that this procedure needs revising, and the 'l
revised procedure will be reviewed and compared to the new system during a subsequent inspection.
(460/79-02-11) h o;0 20. Criterion XVIII - Audits The WPPSS audit system was examined to ascertain compliance with S PSAR commitments included in Paragraphs 17.1.18 and 17.4.18.
The examination consisted of review of 1978 and 1979 audit schedules of 321
.
. ' . ' -23-WPPSS corporate, WPPSS project, and UE&C home office audits; review of 1978 monthly audit status reports; review of audit team leader ___
certifications; and review of five WPPSS corporate QA audit reports
- q performed in 1978.
In addition, Project QA audit reports for 1978 were reviewed.
It was noted that not all 10 CFR 50, Appendix B lh criteria had been audited for J. J. Welcome Construction and Welk
Bros. Construction during 1978 as required (these contractors were y not onsite during all of 1978).
Review of the corporate QA audit
of Project QA (December 1978) revealed that WPPSS was aware that
not all of the 18 criteria had been audited during 1978 for these L1 two contractors and a quality finding report had been issued.
-- Enforcement conference commitment items 1.1.a.1 and 1.1.a.2 are related to increasing surveillance of contractors in order to strengthen the QA program.
A new procedure, "UE&C FQS 10-6, Revision 4, February 2, 1979" was reviewed by tha NRC inspector and was found to provide for earlier and more frequent surveillances.
Also, Amendment No.1 to PMP 7-105, " Award of Contracts," August 15, 1978, requires discussion of quailty commitments during post-award meetings. The notes for the HVAC pLst-award meeting were reviewed and indicated that quality commitments had been emphasized to the contractor by the licensee.
No items of noncompliance or deviations were identified.
21.
Exit interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on ebruary 16, C 1979 and summarized the scope and findings of the in cction as e stated in this report.
Each of the eighteen 10 CFR 50, Appendix B criteria as it relate to the U;iP 1 and 4 quality assurance program and the enforcement conference commitments were summarized.
Enforcement action regarding the findings was discussed without particular comment by the licensee.
n: t -.'l t ! , ..h '
= 321 33;L .__ O }}