ML19247B776
| ML19247B776 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1979 |
| From: | Brown R, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19247B771 | List: |
| References | |
| REF-QA-99900509 99900509-79-2, NUDOCS 7908130490 | |
| Download: ML19247B776 (13) | |
Text
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U. S. NUCLEAR REGULATOR't* COMMISSION OFFICE OF INSPECTION A.VJ ENFORCDENT REGION IV Report No.
99900509/79-02 Progran No.
51200 Company:
Stone and Webster Engineering Corporation P. O. Box 2325 Boston, Massachusetts Inspection at: Boston, Massachusetts Inspection Conducted:
May 7-11, 1979 Inspectors:
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J. R.NJostelle, Pringpal laspector, Vendor Date Inspection Branch R Q>}l h'b R. L.shown, Prih'cir#':/ IEspector, Vendor Date Inspection Branch c,
541-79 1
Mv n-Approved by: _
C. J. Hilj, Cnief, Vendor Progran Evaluation Date l
Section, Vendor Inspection Branch Si= mary Inspection on May 7-11, 1979 (99900509/79-02)
Areas Inspected:
Inplenentation of 10 CFR 50, Appendix B criteria in the creas of procurecent docunent control, procurecent source selection and QA records.
The inspection involved sixty (60) inspector-hours on site by two (2) USNRC inspectors.
Results:
In the three (3) areas inspected, one (1) deviation and one unresolved item were identified in one (1) area and oce (1) unresolved item was identified in another area.
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3 DetailsSection I (Prepared by J. R. Costello)
A.
Persons Contacted J. H. Brodeur, Records Administrator C. E. Cole, Project Buyer
- W. R. Curtis, Engineering Assurance Engineer P. W. Daly, Assistant Chiet' Engineer P. W. Day, Lead Engineer R. E. Foley, Assistant to Chief, Engineering Mechanics Division W. O. Glass, Manager Office Management, Technical
- J. W. Kelly, QA Progam Administrator D. L. Malone, Audit Supervisor
- J.
Medeiros, Project Record Administrator E. O'Connor, Assistant Supervisor, Records Retention Center F. L. Qualter, Assistan Mar.ager, Procurement Qirlity Assurance R. L. Schichtel, Supervisor Records Retention Center C. H. Wilbur, Coordinating Egnineer R. J. Yanis, Engineering Assurance Engineer
- Denotes those present at exit meeting.
B.
QA Records 1.
Objectives The cbjective of this area of the inspection was to examine the establishment and implementatica of quality related procedures for collecting, filing, storing, maintaining, and dispositioning of QA records to verify that; a.
A QA records system is defined, i:plemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups performing safety related activities including QA, design, procure:ent, administration, and sersices.
b.
QA reccrds are legible, cc:pletely filled out, adequately identifiable to the itas involved, validated, and listed in an index that indicates:
the record retentica.ine, where p. s c,c.n o o
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4 the record is to be stored, and the location of the record in the storage area. Any changes or modifications f.o these records are controlled.
c.
A specific submittal plan for QA records is established between the licensee sad contractor and records exir.t that acknowledge the licensee's receipt of QA records.
d.
A designated authority has been assigned to control the receipt of QA records by a system which includes a list of QA records required, a record of QA records received, and an inspection of incoming records including a current assessment of the status of inccming records.
e A custodian has been designated to assure that QA records are in accordance with b. above and to enforce a QA record storage filing system which includes a system description of the filing tecnnique and storage area, rules for access and
- ontrol of record files, accountability of records removed from record files and secrrity requirments.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
Section 17 of the Final Safety Analysis Report (FSAR) for a.
North Anna Power Station, Units 1 & 2.
b.
Section 17 of the Final Safety Analysis Report (FSAR) for Shoreham Nuclear Power Station.
c.
Implementing procedures to satisfy FSAR Quality Assurance Program commitments and to satisfy the intent of the cbjectives sectica above. These procedures are as follows:
(1) Quality Standard QS 17.1, Revision A, Quality Assurance Records System.
(2) Engineering Assurance Iracedure EAP 17.1, Revision 1, Collectica and Retention of Quality Assurance Records.
(3) Purchasing Department Instruction Manual, Sectic XII, Records and Files.
(4) Structural Division Administrative Guideline, No. SAG 2.6-0, Revision 0, Records Management.
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5 (5) Electrical Division Tecanical Procedure No. EAG-XXXI?-1-1, Revision 1, Records Management.
(6) angineering Assurnace Division Technical oracedure No.
01-07-0, Revision 0, Records Management.
(7) North Anna Project Procedure 1.2, Revision 4, Review of Boston Purchased Category I items Documentation.
(8) North Anna Project Procedure 1.9, Revision 3, Co).tection and Retention of Records.
(9) North Anna Project Procedure 2.9, Revision 0, Collection and Retention of Quality Assurance Records.
(10) Field Quality Control Procedure QC-5.3, Revision 0, Standard File and Record System.
(11) Construction Department Standard CMP No. 11.1-3.77, March 1977, Jobsite Jactment Control.
(12) Construction Department Standord CMP No. 11.2-11.75, November 1975, Indexing and Retrieval of Nuclear Plant Documentation.
d.
Jocuments to verify implementation,f FSAR Quality Assurance Program commitments and to satisfy the intent of the objectives sections.
These documents are as follows:
(1)
CSTG-15.76.7-0, Revision 0, Installation Criteria for Safety Related Instruments and Sensing Lines.
(2)
CSTG-10.5-0, Revision 0, Review of Reliability and Availability Calculaticas f or Instrumentation and Coatrol.
(3) EAG-XXVII-12-1, Electrical Lesign Criteria.
(4) STD.'IE-29-40, Revisica 2, Seismic Cable Tray Supports.
(5) DC 3903, March 31, 1978, Electrical Indepenuence, Category 1.
(6) EATP 3.6, Revision 0, Engineering Assurance Developaeat of Audit Plans.
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(7) EATG 50-100, Revision 0, Engineering Assurnace Pre-award Surveys of Engineering Services Suppliers.
(8) EMAG 37, Revisior 0, Conceptual Design Review.
(9) EMTR 400, Revision A, Material Properties for Pipe Rupture Analysis.
(10) ME-023-0303, Se'.smic Analysis of Piping Systems (SHOCK 3).
(11)
GAG-3.8, Revision 2, Geotechnical Design Criteria.
(12)
HTG-6.1, Revision 0, Determination of Hydraulic Head Losses Through Cooling Water Systems.
(13) W53M Weld Procedure, J. O. No. 12560.07.
(14) METG-1-0, Change 1, Preparation and Issuance of Weld Procedures.
(15) North Anna Project Records Type rist, Revision 0.
(16) Greene County Project Records Type List, Revision 2.
(17) Purchase Order Register for North Anna Power Station, Units 1 and 2.
(18)
PR-P-44, Februarf 18, 1975, Problem Report Response -
Te=porary Strainers for Canal.
(19) Engineering Assurance Record Index, January 31, 1979.
(20) Engineering Assurance. Audit of Beaver Valliy Unit 2 August 2, 1978.
(21)
P.O. NA1127, January 27, 1970, Recirculation Spray Purps -
Binghaa Willamette.
(22)
P.O. NA1456, February 26, 1976, Safety and Relief Valves -
Crosby Valve and Gage Company.
(23; P.O. NA 1574, December 8, 1978, Neutron Shield Material -
Cheatrol Corporation.
(24)
P.O. NA 442, January 2, 1976, Spent Fuel Storage Racks -
NES Corporation.
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7 3.
Findings a.
Deviation See enclosure No. 1, Notice of Deviation.
b.
North Anna Project Procedure 1.9, Revision 3, (Collection and.
Storage of Records) has a requirment in paragraph 7.1.3 that all QA records forwarded to the PPF/PRCF files shall be sent via a transmittal or Document Checklist with a receipt acknowledgement required.
In establishirg the PRCF (Project Record Copy File) for North Anna 2, existing engineering files were being incorporated into the PRCF file without transimittal or Document Issue checklist receipt acknowledgement.
It does not :ppear to be a viable requirement to require receipt acknowledgement for existing engineering files on this repc-t.
Procedure No. 1.9, was revised during the period of this inspectica to remove this anomoly.
The procedure was changed to read as follows:
All QA record tranmittalc from the Be'*on office to the PPF or from the construction office to the c..F shall be made using a tranmittal or Document Issue checklist.
Receipt acknowledgement is required.
c.
Unresolved Item Stone and Webs.er Quality Standard QS-17.1, Revision A dated September 30, 1977, (Qualty Assurance Records System) states in part (paragraph 4.3.4), "The Project Management Department is responsible for
. Establishing written procedures for the operation of the RRC (Record Retention Center)." QS-17.1 also states in part (paragraph 4.3.6), "The Of fice Facilities Department is responsible for implementing written procedures for maintaining the RRC facility."
At present time procedures prepared by the Project Management Department for the operation of the RRC are in draf t fo rm and have act been issued. As a consequence, the Office Facilities Department has not been able to establish the implementing written pr>cedures for maintaining the RRC facility.
This item will be further inspected during the next regular inspection.
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8 C.
Exit Meeting A meeting was conducted with management representatives at the conclurion of the inspection on May 11, 1979.
In addition to the individuais indicated by an asterisk in the Details Sections those in attendance were:
F. B. Baldwin, Assistant Manager, Quality Assur: ace R. G. Burns, Chief Engineer, Quality Systems Division G. J. Burroughs, Proj et Manager R. B. Kelly, Quality Assurance Manager L. S. Maciejewski, Vice Presideut, Engineering Manager L. D. Nace, Chief, Engineer, Engineering Assurance G. M. Schierberg, Manager, Procurement Qual ty Assurance H. W. Zassenhaus, Manager Records !!anagement Division The inspector summarized the scope and findings of the inspection for those present at the ceeting. Management representatives acknowledged the statements of the inspector.
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9 DetailsSection II (Prepared by Ross L. Brown)
A.
Persons Contacted J. Carney, Assistant Project Engineer
- E. B. Flecing, Senior QA Program Administrator R. E. Fortier, Principal Nuclear Engineer G. E. Gula, QA Engineer G. R. Heine, Lead Control Engineer E. L. Prendable, Engineering Aide F. L. Qualter, Assistant Manager, Procurement QA T. A. Rothschild, Principal Piping Engineer
- Attende.d exit =eeting.
B.
P_re curecent Document Control 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been prepared and are being implemented to assure that:
The organizations involved in the execution of procurement a.
activities have been identified and their respcasibilities delineated.
b.
Procurement documents include the scope of work to be performed by the supplier, the technical requirements, material and equipment specifications, procedures and instructions, test and inspection requirements, acceptance requirements, and identification, packaging, handling and shipping reqairements.
c.
Procurement documents require that the supplier have a docu-
=ented quality assurance program consistent with 10 CFR 50, Appendix B.
d.
The supplier is required to incorporate appropriate quality assurance program requirements in sub-vendor procurecent
_m documents.
e.
Procurecent documents provide rights of access to the supplier's plant facilities and records, identification of =anufacturing hold points, witness points and notification of the time of L.d M f '.O' i._
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these events, documentation requirements, records requirements, and requirements for reporting and approving of the disposition of nonconformances.
f.
Procurement documents are reviewed by the QA organization before transmitta_ to the prospective suppliers and these
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reviews are documented.
g.
Changes to procurement documents undergo the same degree of review and controls as the original documents.
h.
Measures to control the release and distribution of procurement documents are being implemented.
2.
Methods of Accomplishment The preceding objectives were accomplished by examination of:
Chapter li of the Final Safety Analysis Report (FSAR) for Job a.
Order No. 11600, Section 17.1.4B requires the Stone and Webster (S&W) QA program to provide for the contrcl of procurement docu-ments, and to assure that the engineering and quality recuirements are translated into procurement specification and associated drawings.
b.
Quality Assurance Directive Technical No. QAD-7.8 provides instructions for handling vendor documents including, the required documents, content, disposition and storage.
c.
Engineering Assurance Procedure EAP 15.2 provides instructions to engineering personnel for receipt, disposition, distributica and filing of all Nonconformity and Disposition (N&D) Reports forwarded to the project headquarters.
d.
The documents relative to procurement of the folicwing Category I items for Job Order No. 11600.
(1) Purchase Order (PO) No. 310475 for shcp fabricated pipe and associated documents:
(a) Specification No. SH1-024.
(b)
Inspection reports for 1977, 1973 and 1979.
(c) Ten (10) N&D reports and the resoluticas.
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11 (2) Purchase Order No. 310489 for service water pumps and related documents; (a)
Specification No. SH1-057.
(b)
Inspection reports for 1978 and 1979.
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(c) Twelve (12) N&D reports and the resolutions.
(3) Purchase Orde No. 310680 for safety and relief valves, ASME III and the related documents; (a)
Specification No. SH1-191.
(b)
Inspection reports for 1978 and 1979.
(c) Four (4) N&D reports and the resolution.
(4) Several of the documents (survey reports, audit reports, evaluation repo-ts, etc) are referenced in Paragraph C.2 of this Details Section.
3.
Findings In this area of the inspection, no deviations from commitments or unresolved item were identified.
C.
Procurement Source Selection 1.
Objectives The objectives of this area cf the inspection were to verify that procedures,have been established and implemented for the selection of qualifieu suppliers of services, materials, parts and cccponents that provide for:
a.
Requirements for evaluation of the potential supplier's capability to provide items or services in accordance with *he technical and quality assuran:e specifications of the prc ent documents.
b.
Methods of evaluating potential suppliers that are ccasistent with applicable regulatory, code and contract requirenents and should include source evaluation audits, review of historical performance, and/or review and evaluatica of the supplier's QA program, manual and precedures.
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12 c.
Consideration of the complexity, inspectability and safety significance of purchased items or services when selecting the method of source evaluation.
d.
Pe:formance of source evaluation audits that include appropriate checkl.;ts or instructions for systematic review of the prospective supplier's QA system.
e.
Qualification requirements Zor personnel perforcing source evaluation audits.
f.
Source selection being based on historical product performance that includes revie.. of past procurement and operating experience with identical or similar items and is limited to relatively simple services or off-the-shelf items.
g.
Periodic re-evaluation of suppliers and that an up-to-date listing of the evaluatica status is being maintained.
h.
Distributing of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to companies designated in these documents.
i.
Measures to assure that the supplier's bid conforms to the porcurement document requirements and that resolution of unacceptable conditions identified during bid evaluation are corrected before the contract award.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Chapter 17, Section 17.1.15B of the FSAR applicable to Jcb No. 11c00, which requires a semi-aanual summary review of all unsatisfactory conditions to ascertain significant trenda.
b.
Review of the Quality Assurance Directives - Technical, Section 7, Procedure QAD-7.9 that describes the system, that includes the responsibilities and procedures used to determine prospective vendor's capability to conform to the procurement quality requirements.
c.
Review of QAD-4.2 which describes the system for accumulating info rmation f rca surveys, audits, evaluations, and other f.1 R,k3d d v
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13 references of performance in order to evaluate and rate the quality c7pability of vendors.
d.
Review of QAD-4.3 that describes the system for the evaluation of the bidders QA manual and f acility survey if required.
e.
Review of Engineering As.urance Procedure EAP 4.1 that describes the activities of the engineering department in the system used to reccecend bidders, evaluate bidders, evaluate bidder's proposal and select suppliers.
f.
Review of EAP 7.1 which establishes the cethods and responsi-bilities for evaluation and monitoring of an engineering services supplier.
g.
' Examination of docura,ts pertinent to supplier selection to verif-conformance with the requirements referenced in y
Paragraphs C.2.a, b, c, d, and e of this Details Section; (1)
P.O. No. 310475; (a) Survey report.
(b) Vendor Evaluation Reports for 1976, 1977, 1978 and 1979.
(c) Recccmended Vendor List (including the successful bidder).
(2)
P.O. No. 3104S9; (a) Facility Survey Reports for 1973, 1975 and 1976.
(b) Vendor Evaluation Reports for 1977, 1978 and 1979.
(c) Audit Report for audit cenducted on March 12-15, 1973.
(d) Recc cended lendor List for this P.O.
(3)
P.O. No. 310680; (a) Facility Survey Reports for 1972, 1974, 1975 and re-evaluation reports for 1976, 1977, 1973 and 1979.
(b) Recc= rended Vendor List.
(c) Jegative report file, which includes the deficiencies identified against this vendor for all S&'s purchase orders with this supplier.
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3.
Findings a.
No deviations from cccmitments were identified in this area of the inspection, however, one unr solved item was identified.
b.
Unresolved Item It does not appear that S&W is imposing adequate requirements on their vendors in the case of significant conditions adverse to quality for assuring in a timely manner that the cause of the condition is determined and that corrective action is taken tu preclude repetition.
The Nonccaformance and Disposition Report No. 0684 describes one exa=ple of a conditica which apparently should have been analyzed by the vendor to determine the cause of the discrepancy and assign preventive action.
This report states that the wall thithness of several valve gressure parts was below the thickness specified on the vendor drawing.
It ap, ears that this condition should have been analysed by the vendor to determine if the manufacturing process shculd be changed or if the drawing require-meat is in conformance with the technical taquirements.
More especially the discrepancie, should have been identified, justified, and submitted by the vendor to S&W project engineering for evaluation and disposition prior to the S&W Shop Inspector's inspection and his identifying and reporting (via the NaD report) the discrepancies to S&W project engineering for action.
This area will be inspected further during a subsequent inspection.
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