ML19289E030
| ML19289E030 | |
| Person / Time | |
|---|---|
| Issue date: | 12/28/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19289E022 | List: |
| References | |
| REF-QA-99900524 NUDOCS 7903210370 | |
| Download: ML19289E030 (3) | |
Text
Gibbs & Hill Incorporated Docket No.
99900524/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on December 11-15, 1978, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
A.
10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings."
CPSES Project procedure DC-7 (Technical Calculation Procedure) states in Section 3 "The Engineer performing the calculations identifies each individual sheet, dates and initials as originator. The responsible Job Engineer checks and approves the results of all calculations and so indicates his acceptance with his initials on the first page. New work is reviewed, checkad and approved as indicated above."
Contrary to the above pages 10,11,12, and 13 of calculation NC-AA-13 (Containment Spray Iodine Removal) were revised ("New work") without the originator's initials as the revisor on each sheet nor the Job Engineer's initials as approver on the first page.
B.
10 CFR 50 Appendix B, Criterion III states in part, " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design."
Paragraph 5, Section 2. of CPSES Project procedure DC-5 (Specification Production & Solicitation of Bids Procedure) states in part, "The Engineer responsible for the specification prepares a " Specification Review Record Form... this sheet shows the record of reviews and appropriate approvals by the... supporting discipline Job Engineers Contrary to the above, the Specification Review Record Form for Revision 2 to specification MS-12 (Containment ; pray Pumps) was not approved by the structural Job Engineer listed on the form as a reviewer.
(Note-The structural Job Engineer was a reviewer of the original issue and Revision 1).
C.
Gibbs & Hill Topical Report, GIBSAR 17A, Section 17.1.18, states in part, "Gibbs & Hill QA Department personnel perform periodic audits of G&H engineering and design, project administration... scheduled on the basis of the status and safety importance of the activity being performed."
780321 o37o Implementing procedure QAI-G, paragraph 5.4.c states in part, "Sched-ule of QA Internal Audits: QA internal audits shall be performed by the Project Quality Assurance Engineer or assignee on Design and Engineering, Project Administration... based upon work load, but in no case less than on a semi-annual basis."
Contrary to the above, audits of GISBSSAR activities have not been performed on a semi-annual basis; the only audit that has been per-formed was completed on May 2, 1978 (although GIBBSSAR was submitted to the NRC in 1976, docketed in 1977, and is currently up to Ad-dendum 7.)
9.
Gibbs and Hill Topical Report, GIBSAR 17A, states in part, "Spe-cialized indoctrination courses in rpecific areas of nuclear and structural engineering and design are also provided to familiarize new personnel with the requirements peculiar to the development of a nuclear power plant and related quality requirements."
Implementing procedure QAI-D2, Section 5.1, Technical Indoctrination Program, states in part, "The In-house Nuclear Engineering Course is initiated, planned and implemented by the Vice President, Power Engineering, with the assistance of department heads... Enroll-ment is mandatory for all Power Engineering personnel involved in Nuclear Power Plant design and engineering.
Newly hired personnel or personnel transferred... will be assigned to attend the first course given."
Contrary to the above, five (5) personnel performing design and engineering for GIBBSSAR have not attended the Nuclear Engineering Course, although employed for several years by G&H, because they were exempted by memos from their supervisors on the basis of prior education.
E.
Gibbs & Hill Topical Report, GIBSAR 17A, Amandment 3, states in part, "All nonconformances found are recorded on the audit report and the audited organization is instructed to complete the corrective action reply section within a specified time lin' t... Followup action will be scheduled after the corrective action completion date to confirm that the corrective action indicated has been satisfactorily implemented."
Implementing procedure QAI-E states in part, "If the corrective action reply is unsatisfactory, the Project QA Engineer will bring the matter to the atten*.'on of the QA Manager, who will then notify the Project Manager and the appropriate Chief Engineer / Manager to discuss and resolve the situation..." and "When review of the corrective action is completed, the Project QA Engineer shall sched-ule a followup action sometime after the scheduled corrective action da'te, to verify... the corrective acti,on."
1' 1 Contrary to the above, (1) for three departments / disciplines audited during GIBBSSAR audit dated May,1978, the corrective action reply was unsatisfactory, but the Chief Engineer / Manager was not notified, the situation was not resolved, and to date no satisfactory corrective action replies have teen received; (2) No followup action date has been scheduled to verify corrective action for 5 departments / disciplines whose corrective act on responses were evaluated " Satisfactory" and corrective action dates have passed.
(Corrective action dates ranged from June to October 1978. )
.