ML19290E562
| ML19290E562 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19290E544 | List: |
| References | |
| REF-QA-99900510 99900510-79-4, NUDOCS 8003140210 | |
| Download: ML19290E562 (4) | |
Text
,d.
United Engineers and Constructors, Inc.
Docket No. 99900510/79-04 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on December 10-14, 1979, it appears that certain of your activities were not conducted in accordance with NRC requirements.
Criterion V of Appendix B to 10 CFR 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, pro-cedures, or drawings shall include appropriate quantitative or qual tative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Deviations from these requirements are as follows:
A.
UE&C QA Manual for WPPSS Nuclear Projects 1 and 4, Procedure QA-2-1, Indoctrination and Training, requires that mandatory Indoctrination Sessions 1 and 2 (which cover the major elements of QA requirements and their implementation) be completed and records of completion main-tained for personnel performing safety-related work.
Additionally, the prior revision of this procedure (in effect from 6/29/78 to 8/10/79) required completion prior to performance of activities affecting WPPSS Quality Class I (safety-related) equipment and services.
Contrary to the above, no records of attendance or completion were maintained of mandatory Indoctrination Sessions 1 and 2 for four (4) design supervisors or engineers performing safety-related functions who had been on the project for one year or longer.
UE&C provided corrective and preventive actions relative to this deviation before the end of this inspection; therefore no further written response to this finding is necessary.
(See DetailsSection II, paragraph B.3.b)
B.
UE&C Manual of Procedures for WPPSS Projects 1 and 4, Project Procedure No. P.P. 9 requires (paragraph 5.2):
" Recipients of UE&C Controlled Manuals and WPPSS Controlled Manuals shall enter changes to controlled manuals, return change package re-ceipts to originator, and return controlled manuals to originator when separated from the project."
8003140 210
2 Contrary to the above and concerning Copy No. 24 of the controlled Manual of Procedures assigned to the previous Project Quality Assurance Engineer (PQAE):
1.
The changes of change packages Nos. 58 (October 17, 1979) and 59 (November 8,1979) had not been entered into the controlled manual, although the change package receipts had been returned to the originator; 2.
The controlled manual had not been returned to the originator when the PQAE to whom it was assigned left the project.
It was also noted that controlled copies 24 and 57 of the Manual of Procedures were missing procedures P.P. 32 and P.P. 37, and P.P. 37, respectively.
UE&C provided corrective and preventive actions relative to this de-viation before the end of this inspection; therefore no further written response to this finding is necessary.
(See DetailsSection II, para-graph B.3.c)
C.
UE&C Nuclear Quality Assurance Manual (ASME Code,Section III, Divi-sion 2) Section 5, Procedure 5-B requires:
1.
Re-evaluation of job performance of certified per- :nel at periodic intervals not to exceed two (2) years.
2.
Evidence of qualification including:
Qualification documented on Form 7010, including date of certi-fication, date of certification expiration, and results of peri-odic re-evaluation and certification documented on Form 4514; and file maintained including these forms for each certified individual.
Contrary to the above, one person certified on August 8,1977, as Level III to ASME III, Division 2, had not been re-evaluated at a periodic interval not to exceed two years (i.e. no results of re-evaluation and certification were entered on Form 4514 and no new Form 7010 was issued).
Evidence of qualification on his certificate showed an expiration date of August 8,1979, although he had performed duties since that date, such as signing as a Level III on certificates for Level I and II personnel.
UE&C provided corrective and preventive actions relative to this devi-ation before the end of this inspection; therefore no further written
3 response to this finding is necessary (See DetailsSection II, paragraph B.3.d)
D.
UE&C Project Quality Assurance Frecedures for Seabrook Station, pro-cedure QA 2-2, Indoctrination, Training, Qualification cnd Certification, states in part (paragraph IV.B.2):
" Personnel pcrforming quality related activities for the project are qualified and certified as follows:
Inspection and Test Personnel - to the requirements of the QA Manual - Corporate Standard II-3 which complies with ANSI N45.2.6."
Also, QA Manual - Corporate Standard II-3 states as purpose (para-graph 2.2).
"To describe UE&C's qualification programs which meet the applicable requirements of ANSI N45.2.6 and Regulatory Guide 1.58."
Contrary to the above, QA Manual - Corporate Standard II - 3 does not meet the applicable requirements of ANSI N45.2.6 and Reg. Guide 1.58 in that, although it requires an initial eye examination for near-vision acuity prior to certification, it does not require annual verification by re-examination of near-vision acuity.
This is a requirement of paragraph 3.2.1 of ANSI N45.2.6 (For additional pertinent information, see DetailsSection II, paragrr.oh B.3.e).
E.
UE&C Project Quality Assurance Procedure for Seabrook Station, procedure QA 2-2, Indoctrination, Training, Qualification and Certification, paragraph IV.B.3. states in part:
" Personnel performing quality related activities for the project are qualified and certified as follows:
Inspection and Test Personnel - to the requirements of the QA Manual - Corporate Standard II-3, which complies with ANSI N45.2.6" Also, QA Manual - Corporate Standard II-3 states that it applies to inspection, testing and surveillance personnel and requires (paragraph 2.4.5) in part:
"The job performance of inspection, testing and surveillance per-sonnel shall be re-evaluated for recertification at periodic in-tervals not to exceed two years."
Contrary to the above, one vendor surveillance person certified to the above requirements on 11/14/77 was not re-evaluated for recertification within the required two year period, although he continued to perform
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UE&C provided corrective and preventive actions relative to this devia-tion before the end of this inspection; therefore no further written response to this finding is necessary.
(See DetailsSection II, para-graph B.3.f).