ML19317G060
| ML19317G060 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/03/1970 |
| From: | Butler W, Dodds R, Vetter W US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19317G051 | List: |
| References | |
| 50-312-70-01, 50-312-70-1, NUDOCS 8002210757 | |
| Download: ML19317G060 (15) | |
Text
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9 U. S. ATOMIC ENERGY Cole (ISSION DIVISION OF COMPLIANCE
, REGION V Report of Inspection CO Report No. 50-312/70-1 Licensee:
Sacramento Municipal Utility District License No. CPPR-56 Category A Date of Inspection:
January 12-14, 1970 Date of Previous Inspection:
December 16, 1969 Inspected by:
R. T. Dodds, Reactor Inspector, CO:V (Principal Inspector)
W. E. Vetter, Reactor Inspector,CO:V W. R. Butler, Senior Project Leader, DRL Compiled by:
[7 2[2.[70 R. T. Dodds, Reactor Inspect 6r,CO:V l
Reviewed by:
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!70 G. S. Spen'cer, Senior Reactor Inspector, CO:V Proprietary Information:
Yes - Specifics of QA program SCOPE Tvoe of Facility:
Pressurized Water Reactor Power Level:
2452 Mwe Location:
Rancho Seco, California i.
Tvoe of Inspection:
Initial Quality Assurance Inspection
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SUI 9fARY The Sacramento Manicipal Utility District (SMUD) home offices located in Sacramento, California, the Bechtel Corporation. facilities located in Vernon, California and the Rancho Seco reactor site were visited on January 12, 13, and 14 1970 respectively to perform a Quality Assurance
-Audit inspection.
-In general, the e aults of the audit indicat,e that:
1.
The applicant's QA manual and associated progians are con-sistent with the proposed 18 point criteria and with SMUD's description of the QA program as provided in a submittal to DEL dated November 13, 1969.
,2 SMUD, through Bechtel Corporation, has generated programs, procedures and an organization sufficiently adequate to implement the QA program.
3.
Objective evidence encountered during the audit was such as to validate statements 1. and 2. above.
The following items were identified for which additional activity is warranted to bring the QA program into full compliance with the pro-posed criteria:
1.
The Bechtel-Vernon reorganization for the purpose of separa-ting QA and Startup from the Engineering Division needs to be incorporated into the SMUD Project Quality Program Manual.
(Criterion I) 2 The class I items have been identified but have not yet been included in the QA Manual.
(Scheduled to be included within a few weeks.)
(Criterion II) 3.
Organized systems for document control are in use at the site; however, detailed procedures that govern these systems were not available. There were no written procedures to govern the logging system used by SMUD for items -that require review and approval of the SMUD Project Engineering Group. (Criterion VI) 4 The requirement for Leavill-Dravo to inform Bechtel of the need for a receiving inspection has not been governed by written procedures. (Criterion VIII) 5.
Additional wording appears necessary to assure that the QA manual provides for (a) an alternate means of assuring quality whenever normal inspection practice is impossible or disadvan-tageous and (b) establishing and iglementing mandatory inspec-tion hold points. (Criterion X) l l
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2 6.
Words were lacking in the QA Manual to impose instructions when particular products require special protective environ-ments as well as words to provide that the existence of such be verified.
(Criterion XIII) 7.
The QA M nual procedures did not require the dating of stamp, a
tag and/or label entries used for the status of inspections and tests performed upon individual items and plant operating equipment.
(Criterion XIV) 8.
A program such as a report status log to monitor the status of nonconforming material has not yet been initiated at the
-site.
That is, a formal program to "close the loop" between intiation of a nonconforming material report and ultimate i
disposition.
(Criterion XV) 9.
The period for record retention following completion of construction and plant licensing has not yet been established by written procedure.
(Criterion XVII) 10.
The SMUD contract for the NSSS, which was awarded prior to implementation of SMUD's QA program, does not include QA provisions that meet the proposed Appendix B to 10 CFR 50.
Negotiations between SMUD and B&W are in process to correct this deficiency.
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II.
General A.
Background and Purnote The intial QA inspection was conducted to meet the objective out-lined in CO PI 4000, Sections 4005 and 4015. The purpose of the inspection was to obtain information relative to the licensee's QA program to determine the degree and manner in which the licensee is implementing the proposed 18 point AEC QA criteria for the Rancho Seco project.
January. 12,_1970 was spent at SMUD's offices in Sacramento, California,
_ January 13, 1970 at Bechtel-Vernon offices in the Los Angeles, California area, and January 14, 1970 at the Rancho Seco site.
B.-
Tena Membershin sad Assianments R. T. Dodds - Reactor Inspector. CO V. Principal In*9ector Responsible for inspection of licensee conformance with Criterion I, II, III, XVI, XVII and XVIII.
W. R. Butler - Senior Proiect Leader. DRL Responsible for inspection of licensee conformance with Criterion i
IV, V, VI, VIII and II.
W. E. Vetter - Reactor Inspector. CO V Responsible for inspection of licensee conformance with Criterion X, XI, III, XIV and IV.
C. S. Soencer - Senior Reactor Inspector. CO:V Overall responsibility for the inspection effort, including the pisaning and conduct of the inspection, and the review of the results.
C.
Personnel Contacted
!.tER J. J. Mattimoe Assistant Chief Engineer, SMUD D. G. Raasch Project Engineer, Rancho Seco J. P. Jackson Quality Assurance Director, Rancho Seco R. Wilson Nuclear Engineer L. Keilmen
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Mechanical Engineer J..Dunn.
Electrical Engineer Bechtel Cornoration - Vernon Office l
I. Ibsen Chief Engineer, Quality Assurance l
J.,F. O'Sullivan Asst. Chief Engineer, Quality Assurance l-R. A. Norry Project Engineer, Rancho Seco H. Joseph Inspection Supervisor, Rancho Seco J. S. Dallam Project Administrator Document Control Clerk M. E. Snead L. D. Johnson Print Control Clerk
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W. A. Brandes Civil-Structural Group Supervisor
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Mechanical Group Supervisor
. L. R. Brown R. Koshiba.
Civil-Structural Assistant. Group Supervisor S. Tashjian
. Quality Assurance Engineer C. Christian Mechanical Engineer j
I. Stoka Senior Mechanical Engineer l
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5 Bechtel Cornoration - Rancho Seco Site Rancho Seco Construction Manager l
W. Stinchfield Project Quality Assurance Engineer V. P. McMahon Quality Assurance Engineer
,M. Wilms Quality Control Engineer W. M. Taylor Document Control Clerk-L. Blackburn Manager, Civil Construction R. H. Cutler Concrete Laboratory Supervisor A. L. Erickson Configuration Control Engineer A. Rivera Materials Supervisor C. E. Marquess Leave 11 - Dreno (Construction Contractor)
Assistant Project Engineer J. Metzger QA Coordinator J. Gonzales III.
Inspection Findinas The significant findings during the inspection are suussarized as follows.
The supporting details are retained in the CO:V files.
D A.-
Criterion I - Ormanization 1
' Discussion The SMUD Nuclear Project Organization was compared with Figure 1 of SMUD's description of the Quality Assurance (QA) program that was submitted to DRL on November 13, 1969 and with the provisions of Criterion I.
The Bechtel organization as shown in the QA manual was identical to that shown in Figure 2 of SMUD's description of the program as submitted to DRL. However, while looking at the Bechtel organization chart in Vernon,it was observed that the Chief Engineer-Quality Assurance was the same person as Chief Engineer-Startup. Organizationally the Chief Engineer-QA reported to the Division Manager, Engineering and Cons truction while the Chief Engineer-Startup reported to the Assistant Manager of Engineering.
When confronted with this possible conflict of interest, Mr. Ibsen, Chief Engineer-QA, stated that Bechtel had also recognized this weakness. He produced a copy of a new Startup and QA Department Organization Chart that showed a reorganization of departments and job assignments. Ibsen now holds a newly-established position, Startup and Quality Assurance Manager, and will be reporting directly to the Vice President and Manager i
Division Utility and Industrial Operations.
o 4-The Chief QA Engineer and the Chief Startup Engineer now have separate line functions and report independently to the Startup and Quality Assurance khnager, Ib Ibsen. The QA Program Nhnual will be revised to reflect these administrative changes.
2 Findinas The crganization for the Rancho Seco QA progren appears to be consistent with AEC Criterion I and with the Organization as described in SMUD's submittal dated November 13, 1969.
However, the Bechtel-Vernon reorganization needs to be' incorporated into the QA Manual.
B.
Criterion II - Quality Assurance Prorrem 1
1.
D_iscussion The QA program for SHUD and Bechtel has been documented in the Rancho Seco Quality Assurance Program NWnual. The annual contains written policies, procedures, program management checklists and instructions.
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QA Procedure No. 3 provides the basis for determining QA classifications. All systema, components and equipment have been classified in accordance with this procedure. However, the "Q" list had not yet been incorporated into the Rancho Seco QA Manual. This was expected to be accomplished within the immediate future (2-3 weeks from time of inspection).
Nevertheless, the " Preliminary Q List" has always been e part of Bechtel's " Project Procedures Manual.
2 Findinas Except for the fact that the "Q" list has not been included in the QA Manual, the QA program appears to be consistent with proposed Criterion II.
C.
Criterion III - Design Control 1.
Discussion QA Procedure No. 2 establishes a system of d' rawings and specification generation that will include an independent review of all design disclosure documents to assure design adequacy, inspection, testing and compatibility with the PSAR and/or FSAR and to assure the inclusion of appropriate QA provisions. The design review program objectives of 1) l
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compliance with the Safety Analysis Report, 2) designed tech-nically correct and 3) appropriata QA program,are achieved
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7 through a series of design reviews by independent Bechtel reviewers (includes independent calculations), independent staff specialists, Engineering Group Supervisor (s), Quality Assurance Engineer, Project Engineer and the SMUD Project Engineer (s).
.2 Findinas The S)EID-Bechtel QA program for design control appears to be consistent with AEC Criterion III and with the suemory program as described in SPRID's submittal dated November 13, 1969.
Evidence of the application of the above statements was obtained during the review of design details and specifications at Vernon and SMUD Offices.
D.
Criterion IV - Procurement Docn= ant Control
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Discussion i
Procurement specifications for both construction and supply type contracts are originated by Bechtel's cognizant engineers.
A " Quality Program Check List" is used for each procurement specification to_ assure inclusion of appropriate design bases, regulatory requirements, and quality assurance requirements such as standards and codes;. instructions and procedures; and i
special processes and tests. Bechtel approval of these speci-fications is indicated by signatures of both the Bechtel Project Engineer and Quality Assurance Engineer.
The Bechtel approved documents are then sent to SMUD for final approval prior to their release for bid.
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. The documents examined by.the inspector indicated that a program for procurement document control was in use at SMUD and.Bechtel. - The program appeared to be consistent with Criterion IV.
E.
Criterion V - Instructions. Procedures sud Drewinas
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Discussion Instructions, procedures, and drawings for the Rancho Seco project are prepared by Bechtel's cognizant engineers and are included with'the purchase specifications in both construction i
l and supply' type contracts. The SMUD Project Engineering Group i
and. Quality Assurance Director review these specifications to l
assure the inclusion of a reasonable set of instructions, g
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.Findinnd The SMID and Bechtel QA program for instruction, procedures and drawings appears to be consistent with Criterion V.
F.
Criterion VI - Document Control 1
Discussion Instfuettunsr,# procedures, and drawings originating from Bechtel-Vernon, or vendors, require review and approval by the SHUD project engineering group. Although a logging system is in use to record the disposition of items subjected to this review, procedures that g'overn the logging system have not been written.
AlleBechtel originated design and construction drawings are processed and controlled from the Vernon office in accordance with the Bechtel Project Reference Manual. An organized system is in use for identification of these documents and for control of their disposition. '
A working file of Bechtel and vendor originated configuration s
control documents is maintained at the site. However, written procedures have not been issued for this activity.
2.
Findinzs A system for document control consistent with Criterion VI is in use by both SMUD and Bechtel. However, procedures that govern this system have not been written.
G.
Criterion VII - Control of Purchased Material. Eauinment. and Services 1.
Discussion The QA organizations and programs of all bidders for Class I items are evaluated by the SMUD Quality Assurance Director.
This evaluation is performed in conjunction with the Bechtel evaluation. "In-process" inspection trips are also made for
. selected items by the SMUD Quality Assurance Director to evaluate QA program implementation.
Bechtel has an established and functioning nation-wide system for control of purchased material, equipment, and services.
It includes a detailed and comprehensive system for evaluation of vendors, for in process inspections, for documentation, and for corrective action when required. Receiving inspection data-
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sheets are prepared by onsite QA engineers. for use by the w
onsite receiving inspector.
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Findinas The SMID and Bechtel system for control of purchased material, equipment and services conforms to the inspector's understanding of Criterion VII.
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H.
Criterion VIII - Identification and Control of Materials. Parts.
and Components 1.
Discussion I
As contract provision, all vendors for Class I items are l
required by SMID to have in effect a system for identification of materials, parts, and components for work-in process. The identificatt.s and control of materials, parts, and components received at t.ae plant site is performoa by Bechtel's receiving inspection personnel. However, since shipments to the site j
arrive et the Leave 11-Dravo receiving office, the Leave 11-Dravo office calls the Bechtel receiving inspector for inspection of the shipment prior to acceptance. The Leave 11-Dravo receiving office did not have written procedures for its relationships, with the Bechtel receiving inspection office.
2 Findinas 1
The QA program for the identification and control of meterials, parts and components appears to comply with the provisions of-proposed Criterion VIII except that the Leave 11-Dravo and Bechtel inspection interface are not governed by written procedures.
I.
Criterion IX - Control of Specisl Frocesses 1
Discussion The SMID Quality Assurance Director and the Project Engineering Group review all purchase specifications and drawicqs to assure that requirements for applicable codes and special processes are clearly identified for all Class I items. Identification of the need for.special processes in the purchase specifications and drawings is made by the cognizant Bechtel design engineer and reviewed ~by the appropriate Engineering Group Supervisors and by the Bechtel Quality Assurance Engineer. The qualifica-tions of' persons performing special processes at the site is filed in the Documentation control Center, also at the site.
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O 2 Findinas The organizational machinery for control of special processes appears to be functioning in accordance with criterion II with some objective evidence already available at the site's Documentation Control Center.
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Criterion I - In Process and Final Insoection 1.
Discussion The provisions of Criterion I were reviewed in detail against the provisions of the S) RID QA Manual. Section 6.1, 2., 3. and
- 4. (General)through Section 6.5 of the SMUD QA Manual adequately establishes. in process and final inspection related QC programs (instructions, procedures, drawings examinations, measurements and tests). However, additional wording appears to be necessary to assure that the QA manual provides for the application of a
Criterion I requirements in the areas of:
(a) Alternate means of assuring' quality whenever normal practice is ingossible or disadvantageous.
(b) Establishing and implementing :nandatory inspection hold points.
2 Findinas With the exceptions noted above, Criterion I appea s to be adequately provided for by SMUD and Bechtel.
K.
Criterion II Test Control 1.
Discussion a.
fdgE The S) RID QA Manual Quality Assurance Procedures No. 5 and 6, collectively require a comprehensive, sign-off effort to establish the acceptability of all suppliers QA-QC programs and-impose appropriate inspection activities.
(Vendor QA evaluation, source inspections and receiving inspections),
S) RID QA Manual QA Procedure No. 11 relates Criterion II (Test Control) to construction site activities in a similar manner.
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.., 2 Findinas The SWD QA Program for test control appears to be fully i
consistent with AEC Criterion XI.
Bechtel functional programs, identified in the form of organization responsibilities and QC mechanics, assure adequate implementation of this espect of the SED QA Program.
L.
Criterion III - Calibration of Measurina and Test Eauinment 1
Discussion SED QA Procedures No. 5 and 14 provide measures to ascure that all tools, gauges, instruments, etc., used in activities j
affecting quality are calibrated and properly adjusted at specified intervals. The applicable Bechtel source inspection procedure (4.7, enclosure 4.1) requires that the necessary steps be taken to implement the provisions of SMUD QA Procedures No. 5~and 14 I
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Findings The SWD QA Manual appears to adequately provide for programs, procedures, etc., to assure consistency with the requirements of Criterion III. The results of an extansive review of the test equipment calibration programs carried out by Bechtel at the Rancho Seco site, including a review of calibration manuals and results of calibrations, indicates that the SMUD QA Manual requirements are being adequately implemented.
M.
Criterion Mo. IIII - Handlinn. Storane. Shinnine and Preservation 1
Discussion A review of the asterial contained in SMUD QA Procedures No. 2.,
4 (procurement review) and 6 indicated that measures have been established to assure that work anc' inspection instructions will be provided for handling, storago, shipping and preservation of materials and equipment to prevent damage or deterioration.
Activities both at the. Rancho Seco site and at vendor. locations have been considered.
Although the SED QA Manual Procedure No.10 (Receiving Inspec-tion) appears to provide for an adequate program, words are lacking to impose instructions when particular products require special. protective environments as well as are words to provide that the existence of such be verified.
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Findings With the exception of wording to establish special shipping protection, discussed above, the SHUD QA Manual adequately provides for the requirements of AEC Criterion XIII.
N.
Criterion No. XIV - Insnection. Test and Operatina Status 1.
Discussion A review of SMID QA Manual Procedures No. 4. (for off-site material, systems and components) and Procedure No.16 (on-site activities) established that measures have been established to indicate, by the use of tage, stags, labels, etc., the status of inspections and tests performed upon individual items and plant operating equipment. These measures provide for identification of those items which
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have conformed to inspection and test requirements and provide for clear marking and subsequent disposition of those items which do not conform.
- 2.
Findinas With the exception of an absence of procedures which require dating of stamp, tag and/or label ent. ries, which could lead to confusion in the event of smaltiple entries, the SH0D QA provisions for denoting inspection, test and operating status appear to be adequate and in accordance with the provisions of AEC Criterion No. XIV.
O.
Criterion No. IV - Control of Nonconformina 7tems 1.
p.iscussion SMID QA Manual Procedures No. 4, 5 and 17 collectively constitute a program to assure that material, parts and components which do not conform to requirements are not inadvertantly used or installed. These procedures pro-vided for identifying, documenting, segregation and dis-position of nonconforming items. The procedures also provide for expedient notification te affected organizations, i
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Findines The SIRID QA Manual procedures were found to be comprehensive and adequately consistent with the requirements 'of ARC l
Criterion No. IV.
However, a review of nonconforming asterial 1
reports generated to date by Bechtel (approximately 15 reporta had been processed at the time of the audit) indicates that the SMUD QA program does not include provisions to monitor the status of nonconforming materials by such means as a report
. status log with mandatory, specific frequency, status review i
requirements. That is, a formal program to "close the loop" between initiation of a nonconforming material report and I
ultimate disposition.
P.
Criterion IVI - Corrective Action l
1.
Discussion
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QA Procedure No. 17 requires an evaluation of all conditions adverse to quality. Adverse conditions are documented in either a "Non-Conforming Meterial Report" or a " Quality Deficiency Report". A " Quality Deficiency Report Log" is maintained at the Rancho Seco document control center to I
keep track of the status of deficiencies observed by inspectors
'r auditors. The quality deficiency report system is documented in Bechtel's written procedures and is used as a tool to meet SM' D QA manual requirements.
J All Class I or II items that have been determined to be acceptable or repairable must receive the approval of an
" Engineering Review Board" comprised of the SMUD Project i
Engineer, Bechtel Project Engineer and the Quality Assurance Engineer, or their designated representatives. Repair proce-dures must be approved by the Board.
2 Findinas The SMUD-Bechtel QA program for corrective action appears to i
be consistent with AEC Criterion XVI and with the summary program described in SMUD's submittal dated November 13, 1969.
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Criterion IVII - Quality Assurance Records i
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Discussion By QA Procedure No.18, Bechtel is required to establish a central point (Rancho Seer site) for controlling all records i
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-lk-that represent objective evidence of the quality status of all aspects of the Rancho Seco Nuclear Generating Station. Such a document control center has been established to furnish documentary evidence of activities affecting quality for use in the management of the QA program. A QA Document Clerk is responsible for maintaining these files. The record retention period following. completion of construction and plant licensing has not yet been established by written procedure.
2.
Findinas Except for record retention following construction, the SIGID-Bechtel QA document control center appears to' be consistent with Criterion XVII and the SIWD submittal dated Nobember 13, 1%9.
R.
Criterion XVIII - Audits 1
Discussion 4
3 QA Procedure No. 19 defines a system of auditing to communicate QA deficiencies to.asnagement on a timely basis to provide a i
systeestic method of corrective action. These audits are being performed on a planned systeestic basis by the SMID Quality Assurance Director, Bechtel Quality Assurance. Director who are independent of the activity being audited. All S1 RID, Bechtel, contractor, or supplier organisations engaged in-Rancho Seco operations ore required.co provide prompt corrective action to rectify QA inadequacies found in their area of control.
Followup audits are required to determine adequacy and effect-iveness of corrective action taken. The review of sudits conducted at Bechtel-Vernon and Rancho Seco disclosed that the i
audit program was functioning in accordance with the plan as stated above.
2 Findinas The SMID-Bechtel QA audi.t program-appears to be consistent with proposed Criterion XVIII, through an oversight, SMJD failed to include the audit program in the submittal to DEL-dated November 13,.1969, i
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DIVISION OF COMPLIANCE MONTHLY REPORT JANUARY 1970 e
4 50-3fL Sacramento Mricipal Utility District (Pancho Seco) - An initial inspection of the quality assurance progam was perfomed at the SFUD main offices, reactor site, and the Bechtel Vernon offices on January 12-14. In general, the results of the audit > revealed that the SED-Bechtel Quality Assurance Manual and associated programs are censistent with the proposed AEC 18 point criteria. Several program deficiencies that were found.will be reviewed with the li-censee during a management meeting in the near future.
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