ML19263C557
| ML19263C557 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1978 |
| From: | Jonathan Brown, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263C551 | List: |
| References | |
| REF-QA-99900510 NUDOCS 7902260554 | |
| Download: ML19263C557 (12) | |
Text
.
U. S. NUCLEAR REGULATOR. C0t@11SSION OFFICE OF INSPECTIOTl AllD ENFORCEMENT REGIO?! IV Report flo.
99900510/78-04 Program No. 51200 Company:
United Engineers & Constructors, Inc.
30 South 17th Street Philadelphia, Pennsylvania 19101 Inspection Conducted:
November 13-17, 1973 Inspectors:
Idy bjMo I#[3#/77 J./fj. Costello, Principal Inspector
_Date Wndor Inspection Branch zahl$s ja i?_.L. B om l'f'#l7T R.
. Brown, Princibal Inspector Date
" ndor Inspection Branch Approved by:
D6 f --
-SC'7f C. J. Hale, Chief, Vendor Programs Evaluation Date Section, Vendor Inspection Branch Summary Inspection on November 13-17, 1978 (99900510/78-04)
Areas Inspected:
Implementation of 10 CFR 50, Appandix B, crite-ia in the areas ot QA records, audits, and actior, on previous inspection f:ndings.
The inspection involved sixty-four (64) hours on site by two (2) USNRC inspectors.
Results:
In the three (3) areas inspected six (6) deviations and one (1) unresolved items were identified in two (2) areas.
No deviations or unresolved items were identified in the other area.
Deviations: Audits - Contrary to 10 CCR 50, Appendix B, Criterion V, and UE&C Corpnrate Standard XVIII-1, supplier did not respond to audit NH181 within the required 30 days (See Notice of Deviation, enclosure, item A).
7902260 569 Contrary to 10 CFR 50, Appendix B, Criterion V, and WPPSS Quality Assurance Procedure QA-5, Quality Assurance Procedure / Change Status Matrix, Revision 36, did not incorporate chan e fio. I to Revision 5, QA-18 (See ilotice of Deviation, enclosure, item B.
Contrary to 10 CFR 50, Appendix B, Criterion V, and UE&C Corporate Standard fio. IX-2, two (2) field inspectors did not have their eyes re-examined within a one (1) year period (See flotice of Deviation, enclosure, iteia C).
Coni.rary to 10 CFR 50, Appendix B, Criterion V; WtiP-1 PSAR, Chapter 17; and UESC Quality Assurance Procedure QA-7-1 for Wi4P-1/4; no pre-award evaluation was made prior to award of contract to a new supplier who had no previously implemented QA program complying with the codes and standards imposed by the contract (See flotice of Deviation, enclosure, item D).
QA Records - Contrary to 10 CFR 50, Appendix B, Criterion XVII, and WriP-1 PSAR, changes made on several pages of a stress report were not signed and dated (See flotice of Deviation, enclosure, item E).
Contrary to 10 CFR 50, Appendix B, Criterion XVII, and Wi4P-1 PSAR some vendor drawings were not reviewed by the UE&C Reliability and Quality Assurance Department (See flotice of Deviation, enclosure, item F).
Unresolved Items: Audits - It does not appear that adequate criteria have been established to define prompt corrective action or to establish when the manager-audits will recommend follow-up action be taken (DetailsSection I, paragraph C.3.b).
. DETAILS SECTION I (Prepared by J. R. Co' f ollo)
A.
Persons Contacted
- M. Botshon, Assistant Project Engineering Manager
- J. Freeman, Supervising Engineer Project Quality G. S. Korin, Manager Field Quality Assurance
- R. H. Leonard, Manager Quality Engineering B. C. Low, Quality Assurance Engineer D. C. Marr, Supervising Engineer Quality Planning R. A. Miller, Manager of Audits H. M. Pfeffer, Indoctrination and Training Coordinator D. J. Reinert, Supervising Engineer Mondestructive Testing
- G.
L. Visco, Project Administrator
- Denotes those present at exit faceting.
B.
Action on Previous Inspection Findings 1.
(0 pen) Unresolved Item (Report No. 78-02):
Existing procedures allow a vendor to be placed on the Approved Vendors List if the vendor has an ASME Nuclear Certificate. This method of selection appears to be inconsistent with NRC requirements and ANSI N45.2.13 and has been referred to NRR:QAB for review and evaluation. This item will remain unresolved until NRR:QAB has completed their review.
2.
(Closed) Deviation (Report No. 78-03):
Contrary to 10 CFR 50, Appendix B, Criterion V, and Project Procedure No.19, reasons for rejection of a Contract Uaiver Request (CWR) were not always included on the CWR. The inspector verified that the corrective and preven-tive action described in UE&C letter of October 6, 1978, had been accomplished.
In particular, the CUR was replaced by another CWR which corrected the error; the files were sampled and no further errors were found. The proper method of processing CWRs was discussed with engineering personnel at a Project Engineering Meeting on October 9, 1978.
3.
(Closed) Unresolved Itera (Report No. 78-03):
Project procedures and instructions are not clear as how to fill out Contractor Waiver Request (CWR) forms and how to demonstrate confirmation of verbal approval of CWRs.
UE&C has revised the CWR form deleting the redundant blocks on the CWR form and adding a space in the lower right hand corner to document the owners verbal approval.
Interim change to Droject Procedure No. 19 was issued November 9, 1978, incorporating these changes and providing necessary instructions.
C.
Audits 1.
Objectives _
The objectives of this area of the inspection were to verify that:
a.
Audit system is established which has organizational independ-ence, authority, and is documented in procedures and/or instruc-tions in accordance with commitments.
b.
Audit records include a written audit plan, team selection, audit schedule, and audit notification to tM person or organization to be audited, Members of the audit team are independent of any direct c.
responsibility 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-ledgment, documentation of noncomformances, 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 Accomplishment The preceding objectives were accomplished by an examination of:
Chapter 17 of the PSAR (Preliminary Safety Analysis Report) a.
for WPPSS tluclear Projects, flos. I and 4.
b.
Topical Report UEC-TR-Onl-5A, Quality Assurance Program.
Implementing procedures to assure that procedural controls had c.
been provided to satisfy QA commitments in the PSAR and Topical Report, and to satisfy items (a) through (f) of the Objectives section above.
.. (1) Quality Assurance Manual - Corporate Standards (a)
Standard flo. II-1, Quality Assurance Program (b) Standard flo. II-2, Indoctrination and Training (c) Standard tio. II-3, Qualification and Certification of Inspection Testing and Surveillance Perst anel (d) Standard flo. IX-2, Qualification and Certification of flDE Personnel (e) Standard flo. XVIII-1, Auditing (f) Standard flo. XVIII-2, Selection. Qualification and Certification of Auditing Personnel.
(2) Project Quality Assurance Procedures - Seabrook Station QA-18, Quality Assurance Audits.
(3) Quality Assurance Procedures - WPPSS tluclear Project tios. 1 and 4 (a) QA-18, Audits (b) QA-18-1, Qualification and Certification of Auditing Personnel.
d.
Documents to verify implementation of QA commitments in the PSAR and Topical Report and to satisfy implementation of (a) through (f) of the Objectives section.
These documents were as follows:
(1) Monthly QA Audit Status Summaries for January 1978, April 1978, May 1978, July 1978, and September 1978.
(2)
Internal / External Audit Schedules (Published Quarterly)
(a) For WPPSS Nuclear Projects flos.1 and 4, dated December 1, 1977, March 17, 1978, June 5, 1978, and September 29, 1978.
(b) For Seabrook Station, Units 1 and 2, dated December 16, 1977, March 20,1978, June 13,1978, and September 20, 1978.
. (3) Audit Logs 9763.006/.007 and 9779.008.
(4) Graphs of Findings / Observations for selected criteria on Seabrook and WPPSS internal audits.
(5) Qualification records of four (4) Lead Auditors:
(6)
Sample examination quutions for Lead Auditors (7)
External Audits (a) HH152 and (1H222, Colt Industries (b) WPl09 and WP156, Klinger Steel Company (c) flH175, ITT Grinnell Corporation (d) flH177, Gould-ITE Control & Systems Division (e) NH182, J. E. Lonergan Company (f) NH181, TRW Mission Manufacturing Company (g) NH192, Control Components, Incorporated (h) NH193, Posi-Seal International s Incorporated (i) flH202, Buffalo Forge.
(8)
Internal Audits (a) WP27, QA-16 Corrective Action (b) WP57, QA-5 Instructions, Procedures and Drawings (c) WP107, QA-17 QA Records (d) NH195, QA-3 Design Control.
(9) Training Schedule for 1978 of home office R&QA Personnel.
(10) Certificate Index (Computer Printout) of Lead Auditors, eye examinations, and qualification per SNT-TC-1A.
.. 3.
Findings a.
Deviations See Notice of Deviation Enclosure, Items A, B, C, and D.
b.
_ Unresolved Item In a random sampling of audit reports it was noted that many audit findings were not closed for periods ranging from one to two years.
In particular, a review of audit reports flH152 and NH222 showed that there were sixteen 16 findings in audit report NH152; fourteen (14) of these findings viere closed one year later, but two (2) of these findings were not closed, and were transferred to audit report NH222 where they will not be closed for at least another year.
Section 17.1.16.1 of Topical Report UEC-001-5A states,
" Documented procedures and practices have been established which assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified, documented and corrected."
UE&C Corporate Standard No. XVIII-1, Revision 5 (Auditing),
states in part (Appendix XVIII-B, " Manager-Audits will recommend to Project Manager the followup action to be taken to confirm implementation of corrective action as scheduled."
It does not appear that adequate criteria have been established to define prompt corrective action or to establish when the manager-audits will recommend follow-up action be taken.
This item will be inspected furthe during the next inspection.
Relative to Item D in the Notice of Deviation, the inspector c.
was informed by UE&C personnel and by the UESC Supervising Engineer-Project Quality for the WPPSS project that facility audits or pre-award surveys by UE&C are not permitted for any WPPSS suppliers.
Consequently, the first post-award audit on contract No.
9779-136 (a new supplier and no pre-award survey), on May 23-25, 1978, resulted in a Site / Vendor Stop Work Order on May 31, 1978. The Stop Work Order has since been rescinded, but of the nineteen (19) original findings on this audit, six (6) still remain open as of November 8,1978.
. This does not appear to be consistent with the require-ments of Criterion VII of 10 CFR 50, Appendix B, for source evaluation and selection, or with the measures for source evaluation and selection, outlined in ANSI N45.2.13 (Quality Assurance Requirement for Control of Procurement of Items and Services for Nuclear Power Plc_cs).
D.
Exit Meeting A meeting was conducted with management representatives at the con-clusion of the inspection on November 17, 1978.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance were:
G. F. Cole, Project Manager G. F. Mcdonald, Senior Quality Assurance Engineer (Yankee Atomic Electric Company)
B. D. Redd, Project Engineering Manager D. Rhoads, Project Engineering Manager J. B. Silverwood, Manager Reliability & Quality Assurance R. J. Vurpillat, Assistant Manager Reliability & Quality Assurance The inspector summarized the scope and findings of the inspection for those present at the meeting.
Management representatives acknowledged the statements of findings, and made the following comment relative to the deviation presented as item F in the Notice of Deviation enclosure.
WPN-1, PSAR, states that drawing reviews will be done in accordance with project procedures.
Present project procedures allow the ce3nizant engineers to determine who should review vendor drawings.
Present UE&C policy is not to ask QA to review each vendor drawing unless they can contri bute.
The UE&C management representatives were advised that their comment would be further reviewed before documentation of the findings.
_9_
DETAILS SECTION II (Prepared by Ross L. Brown)
A.
Persons Contacted
'M. Botshon, Assistant Project Engineering Manager W. D. Braddock, Project Administrator F. N. DeAngelis, Supervising Discipline Engineer
- J. Freeman, Supervising Engineer Project Quality
- R. H. Leonard, Manager, Quality Engineering B. C. Low, QA Engineer D. E. McGarrigan, Supervisor Engineer, Project Quality G. Valentenyi, Supervisor, Structural Engineering
- G. L. Visco, Project Administrator
- Denotes those present at exit meeting.
B.
Quality Assurance Records 1.
Inspection Effort The following documents were examined to determine if the UE&C program provides requirements for the collection, storage, and maintenance of QA records consistent with regulatory requirenents.
United Engineers & Constructors, Inc., Topical Report a.
UEC-TR-001-5A (UE&C, TR), Section 17.1.17., Quality Assurance Records, to identify the organization responsible for estab-lishing a Record Management Prcgram (RMP) and to assure that sufficient records are maintained to furnish evidence of activities affecting quality.
b.
Engineering and Design Procedure No. QAP-0014, Revision 3, Document Contro Co. iter (DCC), to assure that the responsi-bilities and ac'.~ vities of the DCC have been defined with regard to the control, distribution, recording (indexing),
and recall of quality related records.
Corporate Standard No. XVII, Revision 4, Quality Assurance c.
Records, and two (2) project procedures:
QA-17, Revision 4 Reissue, and QA-17, Revision 0, to verify that record retention time and location of the quality records have been established.
d.
Preliminary Safety Analysis Report (PSAR), WNP-1, Amendment 8, dated July 1974, Chapter 17.0, Section 17.2, Subsection 17.2.5.2., to determine if vendor / contractor drawings are to be reviewed by UE&C R&QA.
PSAR-WNP-1, Amendment 8, dated July 1974, Chapter 17.0, e.
Section 17.2.0, Subsection 17.2.17.3., to assure that any changc.; to quality assurance records will include the date and identification of the person authorized to make the change.
f.
Corporate Standard No. VI, Revision 4, Document Control, and two (2) project documcat control procedures:
QA-6, Revision 4, and QA-6, Revision 8, to assure that the responsibilities have been established for the review, issuance, and distribution of quality documents including changes thereto.
g.
Project Quality Assurance Manual, Procedure QA-5,Section IX, Subsection B., to assure that the requirements of B.l.d. are described for project implementation.
h.
The following documents to verify that:
documents are identified, index numbers have been assigned, all disciplines sign-off to assure required quality, documents have been reviewed for adequacy and completeness, accurate retrieval of records and records classified as " Lifetime" or
" Nonpermanent":
(1) Foreign Print (FP) No. FP01467-01, Cont Sinment Liner Personnel Airlock Specification Review.
(2) FP10988-01, CP-03, Welding Operator Qualification Procedure.
(3)
FP10989-01, CP-04, Control of Weld Filler Metal at th-Construction Site.
(4)
FP10682-02, Equipment Hatch Stress Report.
(5)
Letter SBU-16741, comments relative to FP10682.
(6) Specification No. 9763-006-15-1, Specification for Containment Liner.
(7) Letter UV07247, Facility Survey Audit NH-78.
., (8) Letter SBU 21327, Audit Report flH225/NH156A.
(9) FPil612-01, Containment Liner SAW Weiding Procedure and Qualification.
(10) FP01531-03, Containment Liner SMAW, Welding Procedure and Qualification.
(11) External Audit Report, UP-136.
(12)
External Audit Report, WP-82A/WP145.
(13) External Audit Report, WP-86.
(14) Control No. A080041, Specification 9779-134, changes to specification.
(15) Document No. D275-N0037, Stress Report for RCP Supports.
(16) Job No. 6702, the following six (6) vendor drawings for the bottom head of the containment liner:
10256-04-0C, 10767-08-0H, 10767-09-0J, 10825-04-0D, 10826-04-0D, and 10827-10-0J.
(17) UE&C Drawing 9779-S-101240, Revision 4, and 9779-S-101241, Revision 4, covering the same bottom head of the con-tainment liner as the vendor drawing noted in B.l.(16).
2.
Inspection Findinas In this area of the inspection, no unresolved items were identified.
Two (2) deviations from commitment were identified.
(See Notice of Deviation, enclosure, Items E and F).
Relative to these deviations, these findings were not related to the record system, but was related primarily to the control of documentation, as required by 10 CFR 50, Appendix B, Cri?erion VI, that requires documents, including changes, to be reviewea for adequacy and approved by authorized persons.
Regarding enclosure item F, the inspector selected six (6) vendor drawings of the containment liner bottom head for Job No. 6702 (B.l.h.16).
These drawings ~ contained welding procedure numbers, inspection, and test methods for ' designated welds.
These drawings did not include an UE&C R&QA sign-off to indicate their review for items such as appropriate process specifications or adequate inspection or test methods as required by PSAR commitments.
. The UE&C management informed the inspector that UE&C R&QA performs a quality review of all UE&C drawings pe< tinent to the job 6702 prior to their release to the subconuractor vendor for his use.
UE&C management also stated that they were of the opinion this is adequate assurance that the required quality level can be determined when reviewed by the UESC Engineerir.g only.
The inspector selected the two (2) UE&C drawings (flos. 9779-S-101240 and 9779-S-101241) which are the drawings of the containment liner bottom head that were sent to their vendor for preparation of the detail drawings (the six (6) drawings identified above).
These UE&C drawings were reviewed by R&QA.
These two (2) drawings are general drawings and do not include any quality requirements (e.g. weld procedures, nondestructive examination, etc.) by either designation on the drawing or reference to another drawing; therefore, it would appear that the R&QA review could not assure thut the vendor drawings would contain the desired quality level required in this structure or as committed in the PSAR.
,