ML19282D200
| ML19282D200 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1979 |
| From: | Brown R, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19282D196 | List: |
| References | |
| REF-QA-99900510 NUDOCS 7905230593 | |
| Download: ML19282D200 (15) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900510/79-01 Program No. 51200 Company:
United Engineers and Constructors, Inc.
30 South 17th Street Philadelphia, Pennsylvania 19101 Inspection Conducted: February 26 - March 2, 1979 Inspectors:
yet, G [W S -/O '7 f J. R. Costello,' Principayl dnspector, Vendor Dcte Inspec'ti'on Branch
- , o // s B-tV-79 R. L. Browr), Principal Ipspector, Vendor o
Date s
Inspection Branch Approved by:
~
C
[-k N C. J. ffaTeghendor Inspection Branch ief," Vendor Programs Evaluation Date
- Section, Summary Inspection on February 26 - March 2,1979 (99900510/79-01)
Areas Insoected:
Implementation of 10 CFR 50, Appendix B, criteria in the areas of design document control, design corrective action, verifica-tion activities, and followup on previous inspection findings. The inspection involved sixty-four (64) hours on site by two (2) USNRC inspectors.
Resul ts:
In the four (4) areas inspected two (2) deviations and one (1) unresolved item were identified in two (2) areas.
No deviations or unresolved items were identified in the other two (2) areas.
Deviations: Followup on Previous Inspection Findings - (1) Two (2) released stress reports were not revised in 'accordance with the committed 7 9 0 5 2 3 0 sie s
_2-corrective action completion date.
(2) Persons contacted during pre-audit, audit, and post-audit activities were not identified in a pre-award facility survey report.
Unresolved Item: Verification Activities - It is not apparent whether the Vencor Surveillance Representative is verifying that the applicable procedures submitted to UE&C have been reviewed and approved as required in Section A of the UE&C Vendor Surveillance Check Plan.
9 DetailsSection I (Prepared by J. R. Costello)
A.
Persons Contacted M. Botshon, Assistant Project Engineering Manager A. J. Friedman, Supervising Licensing Engineer
- R. H. Leonard, Assistant Department Manager, Quality Engineering
- R. C. Lesnefsky, Quality Assurance Engineer D. C. Marr, Supervising Engineer, Quality Planning
- R. H. Marsh, Manager Quality Services R. A. Miller, Manager of Audits
- G.
L. Visco, Project Administrator
- Denotes those present at exit meeting.
B.
Followup on Previous Inspection Findings 1.
(Closed) Unresolved Item (Report No. 78-02): Existing proce-dures 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.
NRR:QAB's position regarding the basis for source evaluation is that ASME certification of a vendor is not acceptable, at the present time, as the sole basis for vendor evaluation.
More specifically UE&C has included other controls for source evaluation in Section 17.1.7.1 of the topical report.
These include applicable quality requirements stated in the purchase documents as approved by the QA Engineer; and purchase order award only after mutual agreement by Purchasing, the responsible Engineer, and the QA Engineer.
Further, by a comitment to ANSI N45.2.13 (Draft 2, Revision 4, April 374),
UE&C will also utilize the methods for source evaluation describe in Section 4.2, items a, b, and c of the ANSI standard.
2.
(Closed) Deviation (Report No. 78-04): Contrary to 10 CFR 50, Appendix B, Criterion V, and UE&C Corporate Standard XVIII-1, supplier did not respond to audit NH181 within the required 30 days. The inspector reviewed the corrective actions described in UE&C's letter of response dated December 29, 1978, and confirmed that a monthly Status Report is being prepared listing the status of all open audits, including the current comitment date and appropriate followup action is being taken.
3.
(Closed) Deviation (Report No. 78-04):
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 change No.1 to Revision 5 of QA-18.
The inspector reviewed the corrective and preventive actions described in UE&C's letter of response dated December 29, 1978, and confirmed that the latest revision of the QAP Change
. Status Matrix incorporated change No.1 to Revision 5 of QA-18.
4.
(Closed) Deviation (Report No. 78-04): Contrary to 10 CFR 50, Appendix B, Criterion V, and UE&C Corporate Standard No. IX-2, two (2) field inspectors did not have their eyes re-examined within a one (1) year period. The inspector reviewed the corrective and preventive actions described in UE&C's letter of response dated December 29, 1978, and confirmed that the inspectors had there eyes re-examined, the certification files had been re-examined and responsible supervisors were reinstructed regarding maintaining scheduled examinations for their personnel.
5.
(Closed) Deviation (Report No. 78-04):
Contrary to 10 CFR 50, Appendix B, Criterion V; WNP-1 PSAR, Chapter 17; and UE&C Quality Assurance Procedure QA-7-1 for WNP-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.
The inspector reviewed the additional information described in UE&C's response dated December 29, 1978, covering the fact that the supplier selected on contract No. 9779-136 had previously supplied reinforcing bars on the Rancho Seco and William Zimmer nuclear projects.
ANSI N45.2.13-1976, permits procurement source evaluation and selection to be performed on the basis of the experience of users of identical or similar products of the prospective supplier. The utility involved in this procurement chose this method of evaluation and there is no evidence of violation of commitments by UE&C. Therefore, this item is not considered a deviation.
During this review the inspector examined the three (3) pre-award facility surveys performed on this project.
One (1) deviation from commitment was identified (See Notice of Deviation, Enclosure Item 8, and additional information below).
Concerning Item B, Enclosure (Notice of Deviation) the following corrective and preventive measures were established prior to the conclusion of the inspection.
(1) Corrective Action - The pre-award survey of Benjamin F.
Shaw Company was reissued on February 28, 1979, to correct an oversight on the Audit Attendance Sheet.
The Attendance Sheet has been revised to reflect audit participation taring each audit phase.
(2) Preventive Action - There were only three (3) pre-award surveys conducted for this project.
The other two (2) pre-award surveys had correctly filled out Audit Attendance Sheets.
Audit personnel have been cautioned by the Assistant Department Manager, Quality Engineering about properly following procedures on future pre-award surveys.
6.
(Closed) Deviation (Report No. 78-04) - Contrary to 10 CFR 50, Appendix B, Criterion XVII, and WNP-1 PSAR, changes made on several pages of a stress report were not signed and dated.
The inspector reviewed the corrective and preventive actions described in UE&C's letter of response dated December 29, 1978, and confirmed that the stress reports involved are all in the process of being revised. While reviewing the dates for completion of the stress report revisions, one deviation from comitment was identified (See Notice of Deviation, Enclosure Item A, and additional infonn-ation below).
Concerning Item A, Enclosure (Notice of Deviation) the following corrective and preventive measures were established prior to the conclusion of the inspection.
(1) Corrective Action - Stress report on Core Flood Tanks was revised on February 20, 1979, and stress report on Pressurizer Supports will be revised March 15, 1979.
(2) Preventive Action - A memo has been issued by R. H. Leonard, Assistant Department Manager, Quality Engineering to B. D.
Redd, Project Engineering Manager, WPPSS, dated March 1, 1979, requesting the Project Engineering Manager to advise Quality Engineering immediately when a comitment date cannot be met so the commitment to the NRC can be changed accordingly.
7.
(0 pen) Deviation (Report No. 78-04):
Contrary to 10 CFR 50, Appendix B, Criterion XVII, and WNP-1 PSAR some ven @ r drawings were not reviewed by the UE&C Reliability and Quality Assurance Department.
This method of not reviewing all drawings for inclusion of quality requirements appears to be inconsistent with NRC requirements and has been forwarded to NRR:QAB as an item for further consideration.
8.
(Closed) Unresolved Item (Report No. 78-04):
It is not apparent that adequate criteria have been established to define prompt corrective action c to estr.blish when the manager-audits will recommend follod-up actio be taken. The inspector verified that corrective action had been accomplished on the outstanding audit report findings and that procedures do exist for allowing the use of surveillance personnel to assist in closing out audit findings.
C.
Verification Activities 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for veri-fication activities that provide for:
a.
Qualified personnel (e.g. ANSI N45.2.6) to be assigned to check, inspect, audit or witness the activities of suppliers as early as applicable.
b.
The planning of verification activities including identi-fication of the inspection sequence, hold and witness points, acceptance criteria, documentation required by the procure-ment document, and receiving inspection plans.
c.
Implementing source surveillance including activities at supplier's facilities (i.e. inspections, audits) and receiving inspection dispositioning (i.e. accept, reject, hold).
d.
Measuring an'd test equipment including requirements for selection for accuracy and control sufficient to determine confomance to specified requirements and calibration and control to recognized standards to determine validity of inspection and test results.
e.
Reporting results of source surveillance activities and evaluation of reports.
2.
Method of Accomolishment The preceding objectives were accomplished by an examinaticn of:
a.
Chapter 17 (Quality Assurance) of WNP-1 PSAR (Preliminary Safety Analysis Report) Amendment 24 plus utility approved PSAR Deviation Requests.
In particular, Section 17.2.4 (Procurement Document Control) and 17.2.7 (Control of Purchased Material, Equipment, and Services).
b.
Implementing procedures to assure that procedural controls
. had been provided to satisfy QA conmitments in the PSAR and to satisfy items (a) through (e) of the Objectives section above.
(1) Quality Assurance Procedures - WPPSS Nuclear Projects No. I and No. 4.
(a) WPPSS QA-2-1, Revision 4, Indoctrination and Training and Qualification and Certification.
(b) WPPSS QA-4, Revision 2, Procument Document Control.
(c) WPPSS OA-7-2, Revision 4, Vendor Surveillance and Control.
(d) WPPSS QA-10, Revision 4, Inspection.
(e) Project Procedures, PP-26, Revision 1, Home Office Purchasing Controls Program.
(2) General Engineering and Design Procedures.
(a) GEDP-0034, Revision 1, Response to Audits, Corrective Action Requests, and other Quality Assurance Reports.
(b)
GEDP-0038, Revision 1, Procurement of Equipment, futerial, and Services.
(3) Quality Assurance Manual - Corporate Standards.
(a) Standard No. II-3, Revision 5, Qualification and Certification of Inspection, Testing and Surveil-lance Personnel.
(b) Standard No. IV, Revision 4, Procurement Document Control.
(c) Standard No. VII-2, Revision 4, Supplier Surveil-lance.
c.
Documents to verify implementation of QA commitments in the PSAR and Topical Report and to satisfy implementation of (a) through (e) of the Objectives section.
These documents are as follows:
(1) Bid Issue Contracts.
(a) 9779-62, Auxiliary Feedwater and Diesel Fuel Oil Pumps and Drives.
(b) 9779-090, Main Steam Safety Valves.
(c) 9779-134, Major Equipment Supports.
(d) 9779-137, Shop Fabricated Piping.
(e) 9779-145, Anchor Bolts.
(2) Quality Control Vendor Surveillance - Check Plans.
(a) Gould Pumps, Inc. - ASME Class 3 Pumps and Drives, September 22, 1977.
(b) Cameron Pump Division, Ingersoll Rand -
Auxiliary Feedwater Pumps and Diesel Oil Transfer Pumps and Drives, July 28, 1978.
(c) Dresser Industries, Industrial Valve and Instrument Division - Main Steam Safety Valves Class I, April 4,1976.
(d) Benjamin F. Shaw Company - Shop Fabricated Piping, January 23, 1978.
(3). Quality Control Vendor Surveillance Reports.
(a) 39B-GPI-3, January 8, 1979 - Gould Pumps.
(b) 62-IRC-23, January 30, 1979 - Cameron Pump Division, Ingersoll Rand.
(c) 90-DIV-4, April 6,1978 - Dresser Industries.
(d) 137-BFS-50, February 2,1979 - B. F. Shaw Ccmpany.
(4)
Four Quality Shipment Relases covering Gould Pumps, Cameron Pump Division, Dresser Industries, and B. F.
Shaw Company.
(5)
Four Vendor Notification Reports to Gould Pumps Inc.
-g-(6) Manufacturing and Quality Control Plan for 1X10A pump - document CQC 11-151-3, Revision 2.
(7) Gage Control Program for Cameron Pump Division, Ingersoll Rand - document No. QCP-l, Revision 12.
(8)
Procedure for qualifying non-destructive personnel -
QCP-410, Revision 1 - Cameron Pump Division, Ingerscll Rand.
(9) Qualification and Certification Records for four (4)
Vendor Surveillance Representatives selected at random.
(10) Sample examination questions for qualifying Vendor Surveillance Representatives.
3.
Findings a.
Deviations In this area of inspection no deviations from commitment were identified.
b.
Unresolved Item It is not apparent whether the Vendor Surveillance Represent-ative is verifying that the applicable procedures submitted to UE&C have been reviewed and approved as required in Section A of the Vendor Surveillance Check Plan (WPPSS QA-7-2, Revision 4, paragraph IV.B.6.b).
In reviewing the Vendor Surveillance Check Plans used on surveillance trips into Ingersoll Rand, Dresser Industries and Gould Pump, Inc., the inspector could not determine from the documentation that the Vendor Surveillance Representative had verified the approval of the welding procedures or the welders' qualifications as required by the Vendor Surveillance Check Plans.
D.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on March 2,1979.
In addition to the individuals by an asterisk in the Details Sections, those in attendance were:
G. F. Cole, Project Manager R. A. Curnane, Vice President, Project Support Operations D. E. McGarrigan, Manager Quality Engineering B. D. Redd, Project Engineering Manager J. B. Silverwood, Manager Reliability and Quality Assurance R. J. Vurpillat, Assistant Department Manager, Quality Services The inspector summarized the scope and findings of this inspection and discussed the closing of the open items from previous inspections.
Management representatives acknowledged the statements of the inspector.
- - ~ ~ -
DetailsSection II (Prepared by Ross L. Brown)
A.
Persons Contacted G. E. Bignola, Administrator, Foreign Print Files D. D. Boyle, Assistant Manager Project Engineering H. E. Flora, Supervising Discipline Engineer
- R. H. Leonard, Assistant Manager, Reliability and Quality Assurance (R&QA)
W. N. MacIntyre, Quality Assurance Engineer (QAE)
- R. H. Marsh, Manager, Quality Services S. E. Rubenstein, QAE J. K. Shaw, Supervisor, Design Engineering
- Denotes those present at the exit meeting.
B.
_De_ sign Change Control and Design Corrective Action 1.
Objectives The objectives of this area of inspection were to verify that adequate procedures do exist and are being implemented for the control of design changes. That design changes are reviewed for the impact of the change, proper documentation, transmittal to all affected personnel, adequate justification, plus review and approval equal to that of the original design, also to verify that adequate procedures do exist and are being implemented for identifying deficiencies of a significant or recurring nature, determining the cause of the deficiencies, and initiating corrective action to prevent recurrence.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of the PSAR, Chapter 17.0 for one project (job number 9763) to detennine the comitments relative to control of engineering design changes and corrective action to prevent recurrence of identified design errors.
b.
Review of United Engineers and Constructors, Inc. (UE&C)
Topical Report UEC-TR-001-5A, Section 17.1.3 to determine the project (job number 6386) comitment relative to control of engineering design changes.
c.
Review of Project Quality Assurance Procedure (PQAP) QA-3, (Design Control)Section IV.E.6.
This procedce references the General Engineering Design Procedures (GEDP) for the required controls of activities.
d.
Review of the following GEDP's to detennine that the design change control responsibilities have been designated for:
the origination, the review and approval, distribution, notification of affected organization, and proper documenta-tion of changes to all engineering documents.
(1) GEDP-0005, Preparation, Documentation, and Control of Calculations, describes how revisions to calculations shall be accomplished and in all cases a Calculation Revision Control Sheet will be completed and placed on top of the Calculation Control Sheet.
(2) GEDP-0013, Preparation of Drawings, requires that after final approval and distribution, if corrections are detennined necessary, changes are to be documented and issued on a Design Change Notice (DCN).
(3) GEDP-0014, Preparation of Design Specifications for Structures, Systems, and Components, requires that should a change in design affect the information contained in the Design Specification, these changes shall be documented on a DCN.
(4) GEDP-0022, Project Level Design Review and Design Verification, requires that where changes to previously verified designs have been made, design review shall be required for the changes including evaluation of the effect of those changes on the overall design.
(5) GEDP-0032, Control, Evaluation, and Implementation of Design Changes, describes the use of the DCN to accomplish the following:
(a) To show the origin of the change.
(b) To explain the reason for the change.
(c) To identify who authorized the change to controlled document.
(d) To record completion of the change.
(e) To show documents affected by the change.
The procedure also requires control of DCN to be maintained through the use of a log.
(6) GEDP-0035, Engineering and Design Interface Control, assigns the cognizant Supervising Discipline Engineer the responsibility for addition and deletions to reflect changes in design or scope during the detailed engineering and design phase, e.
Review of Project Quality Assurance Procedure QA-3,Section IV.G. Corrective Action in the Design Process, describes how deficiencies in the design process are detected, provides for the implementation of corrective action for errors discovered in the design process, and requires the Project Engineering Manager to assure that the verification process that accepted the error is reviewed and modified as necessary.
f.
Review of Administrative Procedure No.15, Revision 9, dated February 15, 1979, changes to Project Documents, that provides the methods to document and convey changes to engineering documents (e.g. Design Change Notice, Engineer-ing Change Approval (ECA), Field Change Request (FCR), and Site Approved Change). The procedure also assigns the authority and responsibility for implementing, review and approval, documentation, distribution, and control of the above change requests.
g.
Review of Administrative Procedure No. 29, Revision 5, dated December 18, 1978, Document Control - Foreign Print System, that outlines the reponsibilities for documenting and controlling vendor documents.
h.
Review of General Administrative Procedure GAP-0004, Revision 1, dated October 13, 1975, Foreign Print System, that describes the standard method for documentation and control of vendor documents.
i.
Review of GAP-0014, Revision 3, dated September 17, 1975, Document Control Center, defines the responsibilities and activities of the Document Control Center with regard to the control, distribution, recording, and recall of all douments, including changes.
j.
Review of the following documents to verify implementation of the controls described in B.2.a through B.2.i.
(1)
Project Change Logs 2, 4, 5, and 7, that identifies the DCN, ECA, or FCR, references the affected documents and gives the disposition status.
(2) DCNs 01/00708, 08/0027A, and 08/0074A.
(3)
ECAs 01/0117A and 01/0318A.
(4) Drawing Nos. 805062 and 805025.
(5) Specification 9763-8-5, Revision 4, dated November 28, 1979.
(6)
Drawings, specifications, procedures and/or calculations related to the following purchase orders (P0).
(a) P0 238-3, Containment Spray Pumps.
(b) P0 248-25, Main Steam Isolation Valves.
(c) PO 246-2, Cooling Water Tanks.
(d) P0 248-34, Containment Penetrations.
(e) Vendor List dated January 24, 1979.
(f) Project 9763-006, Engineering Purchasing Schedule dated February 7,1979, that identified the component, supplier, status of the required documents, and manufacturing schedule.
(g)
Foreign Print File (Project 9763) this print-out identifies the procurement (drawings, specifi-cations, bills of material procedures, qualifi-cations, calculations, and correspondence), the latest revision, and status.
(h)
One set of calculations and three (3) changes thereto for containment Spray Pump. These were reviewed and approved by UE&C and the changes were reviewed and approved by the same persons and/or organizations as the original document.
(i) One Bill of Material and one Heat Treatment procedure (with two (2) revisions) for P0 248-34, Containment Penetrations.
These documents were also reviewed and approved by UE&C.
.. (j) One (1) specification No. 9763-8-5, original issue and Revision 4.
Revision 4 was approved by the same UE&C organizations as the original document.
(k) Three (3) vendor drawings and the attached Foreign Print label (FPL).
The FPL noted the job number, foreign print number, vendor document number, title, applicable correspondence, distribution, and approval.
k.
Review of a memorandum issued to the engineering super-visors, to verify implementation of the requirements described in B.2.e.
This memo identified a problem that had resulted in a design error. The memo also described the action to be taken to prevent recurrence of a similar erro r.
3.
Findings No deviations from commitments or unresolved items were identified in this area of the inspection.