ML19259B684
| ML19259B684 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1978 |
| From: | Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19259B672 | List: |
| References | |
| REF-QA-99900507 NUDOCS 7903130541 | |
| Download: ML19259B684 (10) | |
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l U. S. NUCLEAR REGULATORY COMMISSION h
0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900507/78-03 Program No. 51200 Company:
Sargent and Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 Inspection at:
Chicago, II,linois Inspection Conducted: December 4-8, 1978 Inspectors: D ) (12,.1 g2/2;/g d'. f. Costello, Principal Inspector, Vendor Date UnspectionBranch
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/ D O/-vsr C. J( Ha)e, Chief, Vendor Program Evaluation Date l
Secti-on, Vendor Inspection Branch Approved by:
Q M -M97 C. J.@,' Chief, lendor Program Evaluation Date Section, Vendor Inspection Branch Summarl Inspection on December 4-8, 1978 (99900507/78-03)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria in the areas of audits, action on previous inspection findings and a Management i
Meeting. The inspection involved thrity-eight (38) hours on site by two (2) USNRC inspectors.
I Results:
In the three (3) areas inspected there were no unresolved items.
i Two (2) deviations were identified in two (2) areas.
i Deviations:
(1) Audits - Contrary to 10 CFR 50, Appendix B, Criterion V, there is no provision for a final approval date on the audit schedules and 1
the Head, Quality Assurance Division has not been dating his final approval i
signature (enclosure, " Notice of Deviation," item A).
(2) Followup on j
Previous Inspection Findings - Contrary to Sargent and Lundy's response I
790313 0 N
'susr-
. DETAILS 4
A.
Persons Contacted I
G. Horb, Project Leader
- W. J. Kulinski, Supervising Design Engineer J. E. McFarland, Head, Quality Assurance Division D. C. Patel, Supervic'ng Design Engineer i
L. R. Stensland, Head, Electrical Project Engineering Division J. J. Talamo, Senior Quality Assurance Auditor i
- H. S. Taylor, Assistant Head, Quality Assurance Division P. J. Wattelet, Project Manager
- Denotes those present at exit meeting.
B.
Action on Previous Inspection Findings 1.
(0 pen) Deviation (Report No. 77-03):
Duplicate record storage practices and facilities are not being maintained as required.
Sargent and Lundy (S&L) and the Quality Assurance Branch (QAB) of NRC have agreed to an alternate method for complying with the regulations.
The alternate method is in the process of being implemented and will be checked out during the next regular inspection.
2.
(Closed) Deviation (Report No. 78-02):
Requested comments are not always obtained and documented.
Sargent and Lu-dy cautioned all responsible personnel to conform to all requirements of the procedures, obtained and documented the missing comments and performed an audit to determine this deviation did not exist on other documents.
Sargent and Lundy did not maet the commitment dates in their response letters.
(See enclosure, " Notice of Deviation," item B.)
I 3.
(Closed) Deviation (Report No. 78-02):
Sargent and Lundy does not have procedures for review and acceptance, rejection, or other
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disposition of vendor NCRs (nonconformance reports) when they are submitted directly by the vendor to Sargent and Lundy. Project Instruction PI-MH-014 (Processing of Vendor Nonconformance Reports) has been issued to cover vendor nonconformances reports, and all nuclear Project Managers have been reminded at the regular October t
project management meeting that documented pro.cedures are required for all activities 'affecting quality.
C.
Management Meeting 1.
Objectives
t
. The objectives of this metting were to accomplish the following:
a.
Meet with Sargent and Lundy (S&L) L.anagement and those persons respmsible for the administration of the S&L QA Program, b.
Describe the 1.censee Contractor / Vendor Inspection Program (LCVIP) organization.
c.
Describe the LCVIP, its implementation, and the more significant changes in the LCVIP.
d.
Describe the Vendor Inspection Branch (VIB) inspection methods and documentation.
e.
Describe the NRC evaluation of the ASME system of inspection.
f.
Summarize our previous inspections of S&L.
2.
Method of Accomplishment
.The preceding objectives were accomplished during a meeting on December 4, 1978.
a.
Attendees were:
L. E. Ackmann, Director of Services (Partner)
W. A. Chittenden, D; rector of Engineering (Partner)
R. I. Gavin, Project Director (Partner)
R. F. Hartstern, Supervisor Quality Assurance W. G. Hegener, Manager, Mechanical Department (Partner)
G. C. Kuhlman, Project Director (Partner)
D. L. Leone, Project Director (Partner)
R. J. Mazza, Project Director (Partner)
D. C. McClintock, Manager, Electrical Department (Partner)
J. E. McFarland, Head, Quality Assurance Division (Associate)
J. M. McLaughlin, Assistant Manager, Structural Department (Partner)
R.W. Patterson, Senior Partner R. F. Scheibel, Project Director (Partner)
H. S. Taylor, Assistant Head, Quality Assurance Division S. A. Zych, Head, Quality Control Division (Associate) b.
The VIB organization was described including its relationship to NRC Region IV and the NRC Headquarters component of the Office of Inspection and Enforcement.
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. c.
The LCVIP was described including its objectives, its implementation structure, and the more significant program changes relative to S&L.
d.
The conduct of VIB inspections was described and how our inspections are documented including the report, responses to reports, how proprietary information is handled, the Public Document Room, and the White Book.
The purpose, scope, and status of the NRC's two year program e.
l for evaluation of the ASME inspection systems as an acceptable in - andent third party were discussed.
f.
sur previous inspections of S&L were reviewed, including findings of a recurring nature and difficulties encountered during certain of these inspections.
3.
Findings l
The meeting was well attended by S&L's management and they a.
were attentive during the presentation.
i a
b.
Previous inspection findings that appeared to be recurring
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were in the areas of document control and QA records. The document control findings were not specific to any given functional area thus no adverse trend is indicated, but increased attention to procedural implementation should lessen these type findings. The findings concerning QA records dealt principally with the storage facility. Those findings continued during an extended period of discussions between S&L and NRR:QAB. These discussions have now concluded and S&L's committed records facility should be functional by our next inspection.
During two previous inspections of S&L, the NRC inspectors c.
had difficulty in obtaining certain documents necessary for the completion of their assigned inspection responsibilities.
In both cases the inspectors obtained the information nec-essary to complete their assignments, but this matter was discussed for the purpose of avoiding similar difficulties in the future.
In one case tne requested information was considered proprietary by S&L and they felt its disclosure could adversely affect their competitive positirn. One solution to this item would be for the inspector to sIca a non-disclosure agreement should this situation present itself again.
S&L will be considering other methods for avoiding this difficulty in the future and the NRC inspectors will attempt to obtain any necessary information through less involved, non-proprietary pathways.
In the other case the requested information was not provided in a timely manner for potentially one of two reasons:
(1) the NRC inspector's request was not efinitive enough for S&L's timely retrieval, or (2) the S&_ personnel were not certain they were authorized to make the requested information available to the inspector.
In the future the NRC personnel will strive to make requests as clear and unambiguous as possible, and the S&L personnel accompa..ying our inspectors will provide the assurance / authorization to other S&L perscnnel necessary for making the requested information tvailable.
No action further than that described above appears necessary at this time.
d.
No deviations or unresolved items were identified in this area of the inspection.
D.
Audits 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
An audit system is established which has organizational independence, authority, and is documented in procedures and/or instructions in accordance with commitments, b.
Audit records include a written audit plan, team selection, audit schedule, and audit notification to the person or organization to be audited.
c.
Members of the audit team are independent of any direct reponsibility for the activities being audited.
d.
Provisions exist for the reporting of the effectiveness of the Quality Assurance program to responsible management.
e.
The audit includes the use of checklists or procedures, detailed audit reports, and timely identification, acknow-ledgement, documentation of nonconformances, and subsequent corrective action and verification.
. f.
Audit reports contain the audit scope, identification of auditors, persons or organizations contacted, summary of the results of the audit, the details of any nonconformances noted, the recommendations for correction, and distribution of the report to responsible management.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Sargent and Lundy Topical Report SL-TR-1A, Revision 5, which establishes QA Program commitments.
b.
Implementing procedures to satisfy topical commitments and satisfy items (a) through (f) of the objectives section above including the following General Quality Assurance Procedures:
GQ-1.02 Project Organization Structure GQ-1.04 Employee Experience Records and Qualification Statements GQ-2.04 Quality Assurance Training GQ-2.05 Technical Training GQ-2.07 Project Instruction Training GQ-3.02 Project Scope of Work
.GQ-5.01 Project Instructions GQ-16.01 Corrective Action Reports GQ-16.02 Significant Conditions Adverse to Quality and Stop-Work Orders GQ-18.01 Internal Audits GQ-18.02 Qualification of Auditors GQ-18.03 External Audits of Technical Service Consultants.
c.
Documents to verify implementation of topical commitments and procedural requirements and to satisfy implementation of (a) through (f) of the objectives section.
These documents are as follows:
(1) Project Internal Audit Schedule Index for calendar year 1978 (This document is issued quarterly)
Revision 0 January 3,1978 Revision 1 March 31, 1978 Revision 2 June 30, 1978 Revision 3 September 30, 1978 (2)
Internal audits listed below.
These internal audits included audit checklists, notification of audits and audit reports.
, (a) Audit No. 29 - To determine compliance with GQ-3.09, 3.13, 6.01; QCP-7.1, 8.4, 8.4.1, 10.1, 10.2, 10.4, 10.5, & 10.6 (b) Audit No. 33 - To determine compliance with GQ-1.02, 2.03, 3.02, 3.12 &
PI-MH-001 (c) Audit No. 32 - To determine compliance with GQ-3.05, 3.04 & 3.13 (d) Audit No. 28 - To determine compliance with GQ-3.07, 3.13; PI-BB-05, 06, 08 & 10.
(e) Audit No. 30 - To determine compliance with GQ-3.08, 3.09, 4.01, 4.02; SAS-22; EDSI-72; GDS-5.1.1, 5.3.1 (f) Audit No. 16 - To determine compliance with GQ-4.07, 4.09, & 4.10 (g) Audit G Generic Audit of Design and Drafting Division (h) Audit G Generic Audit of Quality Control Department (i) Audit G Generic Audit of Engineering Mechanics Division (3)
External Audits listed below:
(a) Audit E Dames & Moore Field Office Activities at Carroll County Station Site (b) Audit E Wiss, Janney, Elstner and Associates, Inc. facilities at Northbrook Illinois (4) Training and qualification records of quality assurance auditors Sargent & Lundy presently has six (6) qualified auditors all of whom are well qualified graduate engineers with an extensive background of experience.
_g_
(5) Report on the effectivity of the Sargent & Lundy quality assurance program and procedures January 1977-December 1977.
(Issued September 27,1978)
The report showed there were 92 internal audits conducted, 457 procedures were audited and 167 nonconformances were identifled.
(6) All of the corrective action reports generated as a result of the audits listed in this report were examined.
This is the method used by Sargent & Lundy to obtain resolutions of nonconformances identified during an audit.
3.
Findings One deviation was identified in this area of the inspection (See enclosure " Notice of Deviation" Item A.).
In addition, no unresolved items were identified.
The inspector observed the following concerning clarity of requirements in General Quality Assurance Procedure GQ 18.01.
i a.
GQ 18.01, Section C.2 - The Responsible Individual shall determine and schedule corrective action, including action, when necessary, to preclude recurrence of the nonconformance.
The corrective action and its scheduled completion date i
shall be entered in Block 4 of the Corrective Action Report The Responsible Individual shall sign and date Black 4, retain a copy of the report and distribute the report....
It is not clear whether the responsible individual is supposed to date his signature or not. Some individuals have dated their signatures, but many have not.
b.
GQ 18.01, Section B.3, B.4 - The Audit Team Leader shall conduct c pre-audit conference with the Project Manager or Division Head as applicable.... The Audit Team Leader shall conduct a post-audit conference with the responsible individual audited and with the Project Manager or Division Head as appropriate.
Very few of the internal audit reports reference either a pre-audit conference or post-audit conference.
Language in this section of the procedure needs to be clarified as to whether there is a reqairement foi a formal conference or just an informal exchange of information.
. E.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on December 8,1978.
In addition to the individuals indicated by an asterisk in paragraph A of the Details Section, those in attendance were:
L. E. Ackmann, Director of Services W. A. Chittenden, Director of Engineering A. P. Gillis, Senior Quality Assurance Coordinator G. C. Kuhlman, Project Director D. C. McClintock, Manager Electrical Department J. M. McLaughlin, Assistant Manager, Structural Department S. A. Zych, Head, Quality Control Division The inspector summarized the scope and findings of the inspection for those present at the meeting. Management representatives acknowledged the statements of the inspector.
.