ML19276H537
| ML19276H537 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1979 |
| From: | Costello J, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19276H525 | List: |
| References | |
| REF-QA-99900505 99900505-79-3, NUDOCS 7911290380 | |
| Download: ML19276H537 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900305/79-03 Program No. 51200 Company-E3ASCO Services, Incorporated Two Rector Street New York, New York 10006 Inspec e n at: New York, New York and Lyndhurst, New Jersey Inspa--
Cc-Au:;nst 7-10,1979 Inspecters:
b.
bb8$
7//7/79 J.(R)Costello,PrincipalInspector
'Date Frogram Evaluation Section Vendor Inspection Branch 9.>> Ga -
g/o/75 J
. Johns n, Contractor Auditor
'Dake '
P.ogran E(r luation Section
~
Vendor Inspection Branch Approved by:
VLM 1
O C.J. Hale, Chief,PrygramEvaluat[onSection Date '
Vendor Inspection Branch Summary Inspection on August 7-10, 1979 (99900505/79-03)
.. 2 2-In=nected: Implementation of Topical Report No. ETR-1001 in the
^
areas of Design Change Control, Procurement Source Selection and follow-up on previous inspection findings. The inspection involved fifty-six (56) inspector-hours on-site by two (2) USNRC inspectors.
Results:
In the three (3) areas inspected, three (3) deviations were identified in two (2) areas. No unresolved items were identified.
\\h2"L hk 7911290
__. ___._ _ _ _ ___ _ Deviat' ens:
(1) Design Change Control: Failure to follow procedures for prses-ing General Arrangement Design Change Notices, (2) QA Records were corrected but were not signed and dated, and (3) Procurement Source Selectiem: No procedure has been issued to authorize and prescribe the methocL of deviating project-related QA programs from the Ebasco QA Preg _ _ M'-
a'-
and project deviations have been issued.
/
DETAILS SECTION I (Prepared by J. R. Costello)
A.
Pe sons Contacted J. H. Ferris, Assisrant Project Engineer
- F. 7 Fori, Suoerv'edag Quality Assurance Engineer M. S-Gi=iger, Assistant Project Engineer
- 2. E. "t*--Tic, Project Manager N. 2. ?~mco, Lead Quality Assurance Auditor J.
"J. ?'-M m, T md Quality Assurance Auditor F. I. Townsend, Project Quality Assurance Engineer
- E.
F. 'Jillia=s, Supervisor Quality Assurance Engineering R. J. 71ckers, Project Engineering W. L. Yarer, Enginecring Coordinator
- De ctes those present at the Exit Meeting B.
Action on Previous Insoection Findings 1.
(Open) Deviation (Report No. 77-03): A significant number of "Q" designated project documents have not as yet reached the cuplicate controlled file.
In Ebasco's letter of response dated April 28, 1978, the esti=ated completion date for this effort was stated as August 1978. This estimated completion date was changed to December 31, 1979, in Ebasco's letter of response (March 1, 1979) to Inspection Report No. 79-01.
2.
(Closed) Deviation (Report No. 78-01): Design interface records for interdisciplinary review of drawings were not being maintained as required. The inspector verified that the log-in/ log-out system described in Ebasco's letters of response is working satisfactorily and that the revision to procedure E-7 (formerly E-71) was issued on April 2, 1979. This revision clarifies the requirements for interdisciplinary review and maintenance of records to document this review.
3.
(Closed) Deviation (Report No. 78-01): A document review list for specifications issued on a project was rejected and then issued without resolution. The inspector verified that revision 8 (March 30, 1979) of the Documentation Review lequirements for WPPSS 3&5 incorporates all of the outstanding com=ents.
Examina-tion of the document transmittal sheets shows all open items closed. A letter was issued by the Project Engineer on May 30, 1979, to all concerned personnel cautioning them regarding this
=atter.
1422 543
- 4.
(Closed) Deviation (Report No. 79-01): Failure to enter i=ternal and =anage=ent audit reports and associated records in QA Records system. The inspector verified that audit reports are acw in the QA Racords system. In order to prevent recurrence, records will be forwarded to the duplicate record file as they are received rathar than waiting until all correspondence for a pc. J ~Te- = 44t is rec eived.
5.
(Closed) Devia*'m (Recort No. 79-01): Failure to maintain
>avahla "
s-ant audit records for 1976, perform follow-uc 2==
closu=a. 1 1977, and maintain current status of outstandiLg d=^'-*---4==
La deficiency log per procedural requirements. The i=scector verified that the Quality Program Coordinator is main-taining audit records and the deficiency log.
Management Audit No. 1/79 was cc=pleted on June 29, 1977 and all open items for the Management QA Audits of Nos. 4/76, 1/77, and 1/78 were closed one. Retrievable management audit records for 1976 were a questionable entity due to an organizational change and a change in topical require =ents.
All of the necessary records are now available.
6.
(Closed) Deviation (Report No. 79-01): Failure to perform audit follow-up for external audits to assure a written reply to non-conformances~and to assure corrective action is accomplished.
The inspector verified that the Vendor Corrective Action Follow-Up Log is being maintained. The inspector also verified that follow-up audits of ACF Industries - WKM Valve Division and Lunkenheimer have been conducted and all open items have been closed.
7.
(0 pen) Unresolved Item (Report No. 79-02): It does not appear that the programmatic re-evaluation of the supplier / contractor quality assurance program and facilities described in the Ebasco Topical Report No. ETR-1001 is in compliance with the require-
=ents of 10 CFR 50, Appendix B, Criterion VII.
This item will be considered further during a subsequent inspection.
C.
Design Change Control 1.
Objectives The ' objectives of this area of the inspection were to verify that:
a.
Procedures have been established and implemented for controlling changes to approved design documents.
}k22
- - -.. b.
Design changes are:
(1) reviewed for the impact of the change; (2) docu=ented as to the action taken; and (3)
& nee"*ed to all affected persons and organizations.
2.
The design. changes are justified and subjected to review and a =roval by the same groups or organizations as for the w
<-c i-q 7 d.
Tsen resuc=sibility has been changed, the designated organiza-tion shall have access to the pertinent information, competence in the specific area of design, and an understanding of the re-quirements and intent of the original design 2.
Method of Accerolishment The preceding objectives were accomplished by an examination of:
a.
E3ASCO Topical Report ETR-1001, Revision 7 (EBASCO Nuclear Quality Assurance Program Manual)
(1)
QA-I-4, Revision 1, Design Control.
(2)
QA-I-6, Revision 0, Quality Assurance Records.
(3)
QA-II-1, Revision 1, Instructions, Procedures and Drawings.
(4)
QA-II-2, Revision 1, Document Control.
(5) Appendix II, Revision 0, Ebasco Positions on U. S. Nuclear Regulatory Commission Regulatory Guides.
b.
Allens Creek Project Procedures Manual, Part 1.
c.
Company Procedures Manual Engineering (1)
E-7, April 2, 1979, Processing Drawings for Review and Approval.
(2)
E-8, February 20, 1978, Approval Signatures Required on Ebasco Drawings.
(3)
E-10, April 2, 1979, Identification of Information Required for Completion of Design Drawings.
1422 545
_ (4)
E-65, January 26, 1979, Control of Project-Related Design Docu=ents.
(5)
E-69, May 20, 1979, Design Change Notice / Field Change Request.
(6)
E-70, May 20, 1979, Notification of Proposed Design D-m ges,in General Arrangement Drawings.
d.
Dc.
- '; to verify implementation of quality assurance program ec=s, procedural and project guide requirements, and to satisfy che intent of the objectives section. These docu-ments are as follows:
(1)
Design Change Notice No. 5 (DCN 5) dated Au_ist 8, 1978, covering drawings HOV-7023 and M130006 - Reactor Con-tain=ent Building Sections.
(2) Design Change Notice No. 11 (DCN 11) dated August 4, 1978, covering drawings M150001 through M150009 - General Arrangement Radwaste Building.
(3) Design Change Notice No. 26 (DCN 26) dated October 6, 1978, covering drawings M180001 and M180004 - General Arrangement Diesel Generator Building.
(4) Design Change Notice No. 55 (DCN 55) dated January 22, 1979, covering drawing M140001 - Fuel Handling Building, Eleva-tion 116.17'.
(5) Design Change Notice No. 57 (DCN 57) dated January 22, 1979, covering drawing M120001 - General Arrangement Reactor Auxiliary Building, Elevation 116.17'.
(6) Design Change Notice No. 53 (DCN 53) dated January 22, 1979, covering drawings M120001 and M120003 - General Arrangement Reactor Auxiliary Building, Elevation 116.17' and 164'.
(7) Design Change Notice No. 67 (DCN 67) dated February 22, 1979, covering drawings M120001 through M120004 - General Arrange-ment Reactor Auxiliary Building.
(S)
Design Change Notice No. 75 (DCN 75) dated March 5, 1979, covering drawing M120001 - General Arrangement Reactor Auxiliary Building.
}k2 (9) Design Change Notice No. 77 (DCN 77) dated March 19, 1979, covering drawing M160001 - General Arrangement Control Building.
3.
Findings I: :his area of the inspection two (2) deviations from commitment were identified (See Notice of Deviation enclosure, Items A and B).
D.
r^-
%H?
A _ e neaH-:; was held with management representatives on August 10, 1979.
Ir. add " mn to those persons indicated by an asterisk in p.
mh A of the Details Sections, those in attendance were:
B. E. Marc, Chief Quality Assurance Engineer S. Sparacino, Supervisor Quality Assurance Engineering
- 3. I. Tenrer, Director, Materials Engineering and Quality Assurance The inspector s e Arized the scope and findings of the inspection for those present at the meeting. Management representatives acknowledged the statements of the inspector.
1422 547
_. DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Pe s es Conracted E. '
, Vendm-Evaluation, and Corporate Radiation Monitoring
-c=a-,-
- F. F. 7 erd, O"=14 7 Program Coordinator, Supervising QA Engineer J. 2 21=, Superr c' r Engineer (Piping)
- E.
7-
'r' QA And*- Coordinator D.
7-- aersicy, Tr '--+- I Coordinator V. '.'.minta, En>r (Piping)
G. ?"u o, Se=ior Engineer (Civil)
P. G. Eyan, vendor Ivaluation Group Leader J. Stevens, E:gineer (Applied Physics)
J. T:=ceck, Project QA Engineer R. Tidal, Lead Discipline Engineer (Electrical)
- Denotes those present at exit meeting.
B.
Procurement Source Selection 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for the selection of qualified suppliers of services, materials, and components that provide for:
a.
Requirements and methods for evaluation of the potential supplier's capability to prcvide items or services in accordance with the technical and quality assurance specifi-cations of the procurement documentr.; methods are consistent with applicable regulatory, code end contract requirements and include source eva'atation audits, review of historical performance, and/or re..aw and evaluation of the supplier's QA Program, manual and procedures.
b.
Qualification requirements for personnel performing source evaluation and audits.
c.
Periodic re-evaluation of suppliers, maintenance and distri-bution to purchasing of an up-to-date listing of the evaluation status, and contract awards made only to companies designated in these documents.
d.
Measures to assure that the supplier's bid conforms to the procurement document requirements and/or has been evaluated
\\h for acceptability of exceptions taken of technical or Quality Assurance nature, and resolution of unacceptable conditions identified during bid evaluation prior to contract award or co=mencement of work.
2.
Method of Accc =lishment The preceding objectives were accomplished by an examination of:
a.
Ibasco To7'-,T Report No. ETR-1001, Revision 7, Sections QA-I-l (QA Preg =2m), QA-I-5 (QA Evaluation of Suppliers / Contractors),
CA-::-5 (S=pplier Surveillance), QA-II-9 (QA Audits) and Appendd-II (Ibasco Positions on US Nuclear Regulatory Commis-sien Regularor7 Guides), to identify program commitments.
c.
Ebasco Nuclear Quality Program Manual, Procedure QP-5, Deviating Ebasco Project-Related QA Programs from the Ebasco Nuclear Quality Assurance Program Manual, to identify authorization requirements for deviating from the standard Ebasco QA program.
c.
Ebasco Services Manual of Procedures for Project 3240, Procedure No. Part I, Quality Assurance Modifications to ETR-1001, to identify project-related deviations from the standard program for source selection for one project and Section 8 Procedure C8-2, Preparing Bid Evaluations. Vendors are selected and procurement contracts are awarded and issued by the licensee on this project.
d.
Ebasco QA Engineering Manual, Procedures G-3 (Qualifications of QA Audit Personnel), P-6 (Evaluation of Bid Exceptions),
and P-9 (QA Vendor Evaluations), to identify procedural re-quirements.
e.
Ebasco Vendor QA Department Procedure No. VQAD-19, Qualification of Inspection, Examination and Testing Personnel for Nuclear Facilities, to identify procedural requirements.
f.
Ebasco QA Capability List dated August 2, 1979, listing approved vendors for designated items, g.
List of Class I Vendors for Prepurchased Contracts for the WPPSS project.
h.
List of contracts awarded for the Waterford and Shearon-Harris projects.
\\h
. 1.
Docc=ents related to the procurement of nuclear and non-nuclear Bucterfly Valves from McNally-Pittsburg for Project 3240: QA Manual Evaluation datel March 28, 1978; QA Facility Survey dated March 29, 1978, and supplier sta:us; letrar to vendor with copies to licensee dated April 3, 1978, and internal memo dated April 5, 1978, from And'ent to Project Quality Assurance Engineer; bid evaluation with =c-'*'-
of need to obtain N stamp (the company had an T--
- _wer and has since obtained an N stamp).
j.
Dc.
- - ='= ad to the procurement of Containment Spray Educ
~
"raham for the Shearon-Harris project: QA P.anual review dated October 31, 1977; QA Facility Survey z=d r_1csure of findings dated January 19, 1978.
k.
Doc"-a-ts related to the procurement of mechanical penetra-tions from Nissho-Iwai, contracting agent for fabricator IHI (Ishikawaji=a-Harima Heavy industries Co.), for Project 3240:
QA Facility Survey dated May 20, 1977; QA Manual Evaluations dated January 18, 1977 and May 9,1977; bid evaluation dated March 2, 1977, and post-award and technical clarification meeting dated June 25, 1977.
1.
Documents related to the procurement of station valves 2 "
and larger from Nissho-Iwai, contracting agent for fabricator Hirata, for Project 3240: QA Manual Evaluation, QA Facility Survey dated May 16, 1977, of Hirata; bid evaluation dated February 17, 1977.
m.
Docu=ents related to procurement of Electrical Penetrations from Conax for Project 403: QA Facility Audit dated November 9, 1978, and vendor status and subsequent internal and external correspond-ence dated December 7,1978; bid evaluations dated March 28, 1973, and May 7, 1973; QA Manual Evaluation dated March 4, 1974; Facility Survey dated April 8, 1974; Recommendation for Purchase dated April 23, 1974, noting that Conax is in the process of obtaining an N stamp, which was subsequently received.
n.
Documents related to the procurement of Special Doors (including Fuel Load Bay Doors and Spent Fuel Pool Gate) from Ray Proof Division of Keene Corporation for Project 3240: bid evaluations dcae by the licensee site personnel for Contract 33 and by Ebasco for Centract 234. A facility audit was being performed at this time, by report.
(Note that there is prior history of this vendor's performance for the licensee, by report.)
)kS.
c.
Docu=ents related to procurement of Plant Radiation Monicoring Systes from Kaman Sciences for Project 3240:
QA bid evaluatics done by licensee site personnel.
(Note that F-a e is prior history of this vendor's performance for -le 1. ice =see, by report.)
p.
Dor--=
=-'~m related to procurement of containment spray nc::les Z..a Spray Engineering for Shearon-Harris and WPPSS proj ec:s: hid evaluation dated January 1977, noting acceptable c.-
,-e - dd *+-4 mus.
q.
Trni-+ 3 and certification records for four (4) auditors who performed certain of the above facility surveys.
3.
Findings a.
In this area of the inspection, one deviation was identified (See Notice of Deviation enclosure, Item C).
Related to this deviation, Quality Program Procedure No. 5 exists in draft fors, and the requirements of the draf t version have been followed to process some but not all deviations from Ebasco QA Program.
b.
No unres'51ve~d items were identified.
c.
Concerning procurement source selection for Project 3240, it was noted that the Ebasco Manual of Procedures, Volu=e 2, for this project states:
"Due to the Project Unique Ebasco/WPPSS Specification /
Contract award cycle of events (see Figure 1-4.1),
obtaining quality assurance prequalification of prospective bidders is not permitted under the WPPSS method cf public-bidding as required by Washington State Law."
"Accordingly, each safety-related item inquiry shall include a requirement for prospective bidders to submit adequate quality assurance program information to assure Ebasco/WPPSS that the bidder has a Quality Assurance Program implemented. Subsequent to contract award and if the Contractor is not on the Ebasco Quality Assurance approved Suppliers List, a detailed quality assurance program evaluation and facility survey will be performed to assure contractors confor=ance to Ebasco Quality Assurance Program requirements.
In the event that either Ebasco or WPPSS has no previous experience or historical 1422 551 records pertsaing to one or more bidders, then Ebasco, with WPPSS written approval, may perform a pre-award survey."
Final selection of supplier and award of contract for this proj ect ars =ade by thic licensee.
1 =" speWd e procurements examined, it appeared that prior to award, vendor quality history was available, or a QA Manual ev e,*'
was made, or, in one case, a facility survey was
== +
=d,
= " rugh the result was " unsatisfactory" due to d
ed'" r to evaluate implementation of McNally-Fittsburg's QA Prrg as at that time. No deviations in procurement areas vere identified in any Ebasco functions for the documents ee.
e 1422
'52
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