ML19263C556
| ML19263C556 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263C551 | List: |
| References | |
| REF-QA-99900510 NUDOCS 7902260549 | |
| Download: ML19263C556 (3) | |
Text
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Unitea Engineers & Constructors, Inc.
Docket No. 99900510/78-04 NOTICE OF DEVIATI0il Based on the results of an ilRC "1spcction conducted on flovember 13-17, 1973, it appeared that certain of your activities were not conducted in full com-pliance with NRC requirements as indicated below:
A.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), states in part, " Activities affect ng quality shall be pre-i scribed by documented instructions, procedures or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings."
UE&C Corporate Standard No. XVIII-1, Revision 5 (Auditing), states in part (Appendix XVIII-B), "Within 30 days, supplier prepares response to audit report and sends to project manager.
Should it be imoossible for supplier to complete the determination and implementa-tion of corrective actions... a reply must be made by this date indicating the present status of the investigation with estimated completiori dates for each corrective action."
Contrary to the above, on audit NH181, PO 9763.006-248-48, no reply was made to letter transmitting findings dated March 17,1978, until May 18, 1978. Actual response to findings was not made until August 29, 1978.
B.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures and Drawings), states in part, " Activities affecting quality shall be pre-scribed by documented instructions, procedures or drawings... and shall be accomplished in accordance with these instructions, proce-dures or drawings."
WPPSS Quality Assurance Procedure QA-5, Revision 6 (Instructions, Procedures and Drawings), states in part (paragraph IV.D.2.d), "The latest procedure status identifying all revisions and changes that have been approved and implemented will be incorporated into the Quality Assurance Manual in the QAP Change Status flatrix (Page vi of the manual)."
Contrary to the above, Quality Assurance Procedure / Change Status Matrix, Revision 36, issued on September 25, 1978, did not show change No. 1 to Revision 5, QA-18, which was incorporated by Change Package No. 36 dated April 14, 1978.
C.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures and 7 9 0 2 26 0 SW Drawings), states in part, " Activities affectinq quality shall be prescribed by documented instructions, procedures or drawings... and shall be accomplished in accordance with these instructions, procedures or drawings."
UE&C Corporate Standard flo. IX-2, Revision 4 (Qualification and Certification of riondestructive Examination Personnel), states in part (paragraph 9.7.2), " Personnel responsible for acceptance shall obtcin an eye examination once each year...."
Contrary to the above, two inspectors at the Salem site did not have their eyes examined one year following their previous eye examination.
D.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...
and shall be accomplished in accordance with there instructions, procedures or drawings."
WNP-1, PSAR, amendment 2, January 1974, states in part (paragraph 17.2.
2.g), " Pre-award evaluations of prospective contractors and post-award evaluation of successful bidders are conducted to assure compliance with contact requirements."
UE&C Quality Assurance Procedure QA-7-1 for WNP-1/4 (Vendor Evaluation
& Selection), states in part (paragraph IV. A.2), "If the proposal of the recommended bidder indicates no previously implemented QA program complying with the codes and standards imposed by the contract, a pre-award evaluation shall be made at the prospective contractor's facility, if necessary, to assess the adequacy of his proposed quality assurance system."
Contrary to the above, contract No. 9779-136 was awarded without a pre-award evaluation at the supplier's facility to a new supplier who had no previously implemented QA program complying with the codes and standards imposed by the contract.
Subsequent to the award and as a result of the post-award audit of May 31, 1978, a Site / Vendor Stop Work Order was issued on May 31, 1978, due to an apparently inadequate and improperly implemented QA program (See DetailsSection I paragraph C.3.c.).
E.
10 CFR 50, Appendix B, Criterion XVII, states in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality."
This requirement is implemented by the Preliminary Safety Analysis Report (PSAR) WNP-1, Amendment 8, dated July 1974, Chapter 17.0, Section 17.2, Subsection 17.2.17.3., " Record Examination," that states in part, ".
. Vendor, Contractor Quality Assurance records will not be altered, changed, modified or corrected without proper justification and in accordance with a Vendor or Contractor procedure which provides for appropriate review or approval.
Any change or correction includes the date and identification of the person authorized to make the change or correction."
Contrary to the above, Document Ho. D275-NC037, " Stress Report for RCP Supports," was apparently prepared in 1975 and was reviewed in flay 1978, and certified by a Professional Engineer in June 1978.
This document had changes made on the majority of the 124 pages that were not signed and/or dated.
F.
10 CFR 50, Appendix B, Criterion XVII, states, " Sufficient records shall be maintained to furnish evidence of activities affecting quality."
This requirc...ent is implemented by the commitment in the PSAR-WNP-1, Amendment 8, dated July 1974.
Chapter 17.0, Section 17.2, Subsection 17.2.5.2, " Drawings," that states in part, "... Vendor, Contractors,
... drawing submittals are also reviewed, distributed and commented on... with UE&C R&QA Department in the sequence of review. The R&QA Department ensures, by their review, that the drawing contains, as as minimum, the necessary conformance limits, the effective methods of identification of the item, reference to appropriate process specifications which detail adequate inspection and test methods and those necessary characteristics determined to influence quality.:
Contrary to the commitment above, the Project flanual of Procedures, Procedure No.10, permits the responsible engineer to delete the R&QA Department from the sequence of review for certain vendor or contractor drawings, thus not providing assurance that the drawing contains tha necessary conformance limits or reference to appropriate process specifications which detail adequate inspection and test methods.
Reference, DetailsSection II, paragraph B.2. )
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