ML16341B817
| ML16341B817 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16341B816 | List: |
| References | |
| REF-QA-99900513 NUDOCS 8206280462 | |
| Download: ML16341B817 (8) | |
Text
APPENDIX A
'eledyne Engineering Services
" Docket No. 99900513/82-01
.'OTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted
.on March 29-April 2; 1982, it appears that. certain of your activities were not conducted, in full com-
'pliance with NRC requirements as indicated below:
.Criterion V of 'Appendix B to 10 CFR Part 50 states:
"Activities affecting quality shall. be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and-shall be accomplished in accordance with these instructions,, procedures, or drawings.
Instructions, procedures',
or drawings shall include appro-
'priate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily-'accompl'ished.-"
Nonconformances with this criterion are.as follows:
A.
Project 5511 Program Plan (Di.ablo Canyon Nuclear Power Plant " Design
'Reverification Prog'ram) imposes Pacific Gas and Electric specification, dated. November 11,.1981.
(Specification for Consultant's equality Assur ance Program),
on Teledyne Engineering Services (TES).
Paragraph
- 4. 1.3 of. the specification requires that 'records be retained in accordance with the storage requirements of ANSI/ASME NgA-1-1979 and that "Record storage shall.include measures for protection from inadvertent destruction and include, as a minimum, two hour fire protection or duplicate storage 'at 'separate. locations.",
Contrary to the above, the gA record storage facility does not include measures for protection from i'nadvertent destruction descri.bed in, ANSI/ASME N/A-1-1979, does not provide, for 2-hour fir'e protection, nor were duplicate records stored at separ'ate locations.
Specifically, the TES single-record storage facility does not meet the'gA-1 criteria for facility construction, drainage control, 2-hour minimum fire rating, piping penetrations,.and'ocumentation of review for adequacy by an individual competen't in the technical fi'eld of fire protection and fire extinguishing.
Furth'er, certain, records, relating to gA in-doctrination and 'training; historical file's'f s'uperseded issues of guality Assurance Procedures'nd Technical Engineering Procedures, and.specifications,and other technical documents referenced in pro-curement documents, were neither stored i'n a single. storage facility nor were duplicates stored 'at separate locations.
Teledyne Engineering Services B..
Section 3.1 of'the TES Quality Assurance Manual (QAM) states in part,
- that, "Design activities shall be prescribed and accomplished in accordance with this manual Contrary to the above, certain design activities were not being accom-plished in accordance with the QAM.
Deficiencies observed in the hydrodynamic analyses and design modifications for the torus of the Mark I containments of the Fitzpatrick, Millstone, Nine Mile Point, Pilgrim, and Vermont Yankee Nuclear Power Pl,ants are as follows:
1.
. Section 3.0. 1 of the QAM states in part that, "The Analy'st shall include sufficient, referencing of source data, principles, equations, etc., to permit the ready traceability of his efforts for calculations Contrary to the above, the analyst did not include sufficient referencing of principles, equations, and source data, to permit ready traceability of his efforts for torus calculations (e.g.,
2253-3 and 2252-2).
Furthermore, the checker'id not perform his prescribed duties as evidenced by the fact that thyrse calculations, exhibiting his signature, did not accurately reference principles, design equations, data sources, and other
'eans which provide'traceability of the work.
2.
Section 3.6.3 of the"QAM states in part that, "Design verification documentation is a Project QA Record Contrary to the above, design verification documentation was not treated with the status of a.Project QA record as evidenced by the fact that completed calculations which exhibited'the signatures of the originator, checker, and design verifier were not entered into the TES document control system, nor were they stored in accordance with QA record storage requirements.
C.
Attachment 2 to the Project Quality Assurance Programs (PQAP) for the J.
A. Fitzpatrick, Millstone, and Vermont Yankee projects, states in part, "The latest revision of the following documents are applica-.
ble TES Engineering Procedure EP-1-001, General Control Proce-dure Sections 1.1 and 2.1 of EP-1-001 state'n part that, "The work controlled by this Engineering Procedure is being performed for the Power Authority of the Statq of New York (PASNY) under TES project number 2386 (J.
A. Fitzpatrick)
. the following Technical Engineering Procedures are invoked...
. TEP-1-003 (Design/Analysis Control)
. (and) TEP-8-008 (Project Personnel Assignment)
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Teledyne Engineering Services Contrary to the above:
2.
Engineering Procedure EP-1-001 is not imposed on the Millstone'r Vermont Yankee plants.
Technical Engineering Procedures TEP-1;003 and TEP-8-008 were not being implemented on the Fitzpatrick project.
D.
PgAP's establish maximum intervals between audits'f project activi-ties by the guality Assurance organization and the conditions and requirements under which they can be waived.
Contrary to the above, audits of project activities were not accomplished within the maximum allowed intervals, nor were they waived in accordance with the prescribed conditions and requirements as evidenced by the following examples:
Revision 1 of the PgAP for Fermi 2 established a requirement for bimonthly audits beginning in November 1981.
Provisions for waiving a 'scheduled audit are also contained in the PgAP; however, the waiver must be documented and concurrence of the project manager and -quality assurance manager is required.
- Contrary to the above, an audit of the Fermi 2 project was not accomplished in November 1981, nor were records supporting a
waiver of audit available.
I
k Teledyne Engineer ing Services
<<4>>
2, Revision 6 of the PgAP for Vermont Yankee (October 29, 1981) established.a requirement for internal gA audits to be conducted every 3 months.
Revision"5 (August 8,. 1980) established a
requirement for bimonthly audits.
Contrary to the above, bimonthly audits of the Vermont Yankee project were not accomplished during the peri-od from August 8, 1980, through October 29,
- 1981, nor has the quarterly audit scheduled for February 1982 been conducted to date.
3.
Revision 4 of the PgAP for Millstone Unit 1 (October 30, 1981)
, established a requirement for internal audits to be conducted every 3 months.
Revision 3 (August 8; 1980) established a
requirement for bimonthly audits.
E.
Contrary to the above, bimonthly audits of the Millstone Project were not accomplished during the period August 8, 1980, through October 30, 1981, nor have any quarterly audits, required since October 30, 1981, been conducted to date.
/
Section 17.3.b of the Teledyne Engineering Services guality Assurance Manual (Record Retention),
contains a 6-year retention requirement for audit records.
Contrary to the above, all PgAP's examined (eight different projects) contained a gA Records Requirement List which required retention of 'audit reports for only 1 year.
P'