ML19225A934
| ML19225A934 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19225A927 | List: |
| References | |
| REF-QA-99900519 NUDOCS 7907230067 | |
| Download: ML19225A934 (3) | |
Text
.
Bechtel Power Corporation Gaithersburg Power Divisior.
Docket No.
99900519/79-02 NOTICE OF DEVIATIO}
Based on the results of an NRC inspection conducted on April 9-13, 1979, it appears that certain of your activities were not conducted in full ccopliance with NRC requirements as indicated below:
A.
Section 4.4 (Conference Notes and Unresolved Issues Log) of Engineering Department Project Instruction E0PI-4.35-00 (Engineering Management Design Review), Revision 1, dated June 30, 1976, of the Project Engineering Procedures Manual containing the projects implementing procedures for Topical Report BQ-TOP-1 states in part, "The Project Engineer will establish a log for unresolved issues and a positive closure system for their resolution."
Contrary to the above, the project has not establist ed a log for unresolved issues and a positive closure system for their reso: ution. The Management Design Review Meeting of August 17, 1978, on the Decay Heat Removal, High Pressure Injection, and Component Cooling Water Syst-m= ot Project No. 10467 identified unresolved issues which were not logged nor placed i~to a positive closure system since neither had been established.
B.
Section 2.2 (Program Procedures) of ANSI N45.2.11-1974; committed by Bechtel in Appendix A to Topical Report BQ-TOP-1, Revision 2A, dated July 1977; states in part, " Procedures shall be employed to assure that design activities are carried out in a planned, controlled, orderly, and correct manner.
Program procedures shall cover the following as applicable:
Preparation of Design Documents.
Contrary to the above, program procedures do not exist that govern the preparation of " System Descriptions" which are defined by Bechtel (EDP-4.27, parsgraph 3.0) as key design documents.
C.
Sc. tion 4.4 (Reporting) of ANSI N45.2.12-1974, Draf t 3, Revision 4, February 22, '974; committed by Bechtel in Appendix A to Topical Report BQ-TOP-1, Revision 2A, dated July 1977; states in part, ".
The audit report shall be issued within thirty days after the audit."
Contrary to the above, the audit report of the Special QA Management Audit of Reprographics and Micrographics and the Project Interface con-ducted on February 5-9, 1979, had not been issued as of April 11, 1979, sixty-one (61) days after the audit.
412 33CD 170.0723 oc c,37
2 D.
Section 17.1.3.2 (Bechtel Design Control) of the PSAR for Project No. 9645 and Section 17B.I.3 (Desiga Control) of the FSAR for Project No. 7597 states thst several levels of design review and approval are applied to the design of Bechtel work. These standard procedures include:
Checking and review by design and engineering pers inel within the project engineering team having technical qualifications comparable to those of the engineer or designer who originated the work and shall be contained in Project Engineering Procedure Manuals.
Coritrarv M the above, neither of the Project Engineering Precedures Manual contain procedures that a dress the level of review ccnaprising the c'.ecking and review by desi;;n and engineering personnel within the proj.ct engineericg team having tec'_nical qualifications comparable to those of the engineer or designer who originates the project specifications.
E.
Subsection a.
(Internal) to Section 7.4 (Distribution) of EDPI-4.46-01 (Project Engineering Drawings), Revision 11, dated Jul,* 21, 1978, of the Project Engineering Procedures Manual for Project No. IC466 containing the implementing procedures for Chapter 17 of the PSAR states in part, "All drawing prints or DCNs distributed internal to Bechtel will be stamped or otherwise identified.
Internal distribution of half-size drawing prints shall..
The prints shall be stamped either " controlled copy" or "non-controlled - not to be used for design."
Contrary to the above, at least nine (9) of the drawinga presented to the inspector had both the " controlled copf" and "non-controlled - not to be used for design" stamped ou them e.g. C-0R1111(Q) Revision 1, C-0R1121(Q) Revision 1, C-0R1131(Q) Revision 4, C-0R1311(Q) Revision 2, C-0S1001 Revision 3, C-0S1222(Q) Revision 1, C-0S1242(Q) Revision 3, C-0S1311(Q) Revision 1, and C-0S1341 Revision 3.
F.
Bechtel Quality Program Policy, No. TP0 Q-7.3, and the Nuclear Quality Assurance Manual for Project 9645, procedure QGG-7.3, both titled " Review of Supplier's Documents," state in part:
" Supplier's document review (by Bechtel for documents specified in procurement documents) shall be performed either by the Bechtel Procur r.aent Inspector, engineering, or jobsite quality control persannel. The documents shall be reviewed for accuracy, complete-nesa and conformance to the procurement documents."
Also, Purchase Order 9645-E-009.2 in Appendix C requires that changes to approved designs be verified or checked by control at es commensurate with the original. The P. O. also invokes AN5' N45.2 ond 10 CFR 50, Appendix B, which include similar requirements; it also requires submittal of certain drawings to Bechtel.
412 3M
3 Contrary to the above, revised vendor design drawings which had been reviewed and approved by Bechtel were not in conformante with the procure-ment document requirements, in that the changes to approved design drawings were not verified or decked by vendor c.
trol measures com-mensurate with the original. The drawings includ.d Nos. 33-50470-E-70, Revision 5, 33-50470-B-68, Revision 4, 33-50470-L-53, Revision 7, 33-50469-E-132, Revision 6, required by P. O. Q9645-E-009.2 to be sub-mitted to Bechtel. Although the original issue of the drawings shows three vendor signatures (" drawn by," " checked by," and " approved by"),
subsequent revisions show only the initial for " drawn by."
G.
Bechte~ Engineering Departnent Procedures, Gaithersburg Power Division, Procedure No. EDP 5.34 (Project Quality Program Indoctrination and Training), wh:ch is applicable to Project 10467, states in part:
"Within the first six months period on any Bechtel nuclear project the following individuals shall complete the indoctrination sessions equivalent to those outlined in Exhibit A, " Engineering Indoctrina-tien Prograu "
Project Engineer Assistant Project Engineers Group Supervisors and Group Leaders Disciplir.e Quality Engineers Project Quality Engineers Project Administrators."
Contrary to the above, the Project Engineer assigned to Project 10467 in July,1973, and the Project Administrator assigned to Project 10467 in August 1978,, have not yet attended indoctrination sessions 3, 4, and 5, or equivalent, as required.
4/p J2a