ML19260C320
| ML19260C320 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19260C311 | List: |
| References | |
| REF-QA-99900526 99900526-79-2, NUDOCS 7912260204 | |
| Download: ML19260C320 (2) | |
Text
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Black and Veatch Consulting Engineers Docket No. 99900526/79-02 NOTICE OF DEVIATION Based cc-th,e results of an NRC inspection conducted on August 6-10,19h9, it appears that cer
of your activities were not conducted in acco.'-
a with NRC 'M-ements.
Crit - V of Appa 24-3 to 10 CFR 50 states:
"A
- m aff*- g quality shall be prescribed by documented im
'ons, procadnres, or drawings, of a type appropriate to the circu=srances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, pro-cedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Deviaticas from these requirements are as follows:
A.. Black and Veatch Quality Assurance Program Standard Procedure SP 3.2 (Project Design Manuals), Revision 3, dated May 18, 1979, states in part, concerning the Project Design Manual, "... Records pertaining to reviews, hpprovals, (P-GN-181 or other information) and distri-bution of issues shall be maintained by the PDE-Systems...."
Contrary to the above, the PDE-Systems did not have complete records pertaining to the approval of the " original issue" or subsequent issues of the Project Design Manual.(PDM).
B.
Black and Veatch Quality Assurance Program Standard Procedure SP 3.2 (Project Design Manuals), Revision 3, dated May 18, 1979, and the superseded SP 3.3.7 (Project Design Manuals), Revision 1, dated July 10, 1975, state in part, respectively, "As Project QA Records, the PDCA shall maintain a current copy of the PDM in the working file and a historical copy (approved issues) of PDM in the Project Security File...,'.' and, "The PDM shall contain a Table of Contents and a List of Effective Page Dates which chall record the page number, issue date, and revision status of each page...."
Contrary to the above, the hirtorical copy of the Project Design Manual, located in the Project Security File, did not contain the 1617 014 2
7912 60
. uniquely identifiable Table of Contents nor a list of Effective Page Dates for the " original issue" of the Project Design Ma" val dated August 15, 1975.
C.
Section 3.7 (Design Document Control) of Appendix 17B.1 of the Project PSAR states in part, "... Design documents, records of renews, and changes thereto are collected, stored, and main-
-e4ned in a systematic and controlled manner to permit ready retrieval when needed." Further, Section 17.1 (Adequacy of 0" = 1 *y-As ="*=" r a Records) states in part, "The Quality Assurance Prog nm - N"~Ta=- contains provisions for records to be retained ir. acccrdance vien ANSI N45.2.9."
App H N A of ANSI N45.2.9 recommends a minimum retention period of one year following commercial operation for reports of design reviews.
Centrary to the above, Section 6.3.2 (Outline of Approval Procedure) to procedure SP 5.2 (Drawings and Lists) of the Quality Assurance Program - Nuclear allows the destruction, after one calendar year or when the applicable document is superseded, of Form P-GN-101 which serves as documented evidence of reviews and reconciliation of review comments on the document.
D.
Black and'Veatch" Quality Assurance Program Standard Procedure SP 6.3 (Project Document Control), Revision 1, dated April 25, 1977, states in part,
"...The PDCA will receive and record B&V memoranda, calcula-tions, reports, etc. for filing using the same procedures as for outgoing documents except for omission of mailing pre-paratione,,."
"...The PDCA will receive all outgoing documents, assign DIN numbers, type DIN on B&V originated correspondence...."
Contrary to the above, the current historical copy of the Project Design Manual, located in the Project Security File, was not identified with a DIN number.
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