ML19341A438
| ML19341A438 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1980 |
| From: | Fox D, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19341A434 | List: |
| References | |
| REF-QA-99900524 NUDOCS 8101230510 | |
| Download: ML19341A438 (11) | |
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V U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900524/80-02 Program No. 51200 Company:
Gibbs and Hill Incorporated 393 Seventh Avenue New York, New York 10001 j
i Inspection Conducted:
October 20-23, 1980 Inspector:
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/[d/dd D. F{ Fo], Contractot* Inspector Date Progthrivaluation Section Vendor Inspection Branch
}lNk J. M. Qphnson, Cont [Sectionf1 tor Inspector Date Program Evaluation Vendor Inspection Branch n
Approved by:
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C. J. Halgi Chfef Date Program EWluation Section Vendor Inspection Branch Summary Inspection on October 20-23, 1980 (99900524/80-02)
Areas Inscected:
Implementation of Title 10 CFR Part 50, Appendix 3, including supplier nonconformance and corrective action,10 CFR Part 21 inspection and action on previous inspection findings.
The inspection involved fifty-four (:;4) inspector hours on site by two (2) NRC inspectors.
Results:
In the four (4) areas inspected there was one violation, three (3) unresolved and two (2) followup items were identified.
Violations:
10 CFR Part 21 Inscection - Failure to meet 10 CFR Part 21 posting requirements in tne facilities wnere safety related activities were being con-ducted.
(See Notice of Violation enclosure).
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2 Unresolved Items:
Action on Previous Insoection Findings - The apparent incon-sistencies cetween tne committed ANSI N45.2.12 requirenients and the implemented Gibbs and Hill Vendor Audit Program could not be resolved during the inspection.
(See DetailsSection I, paragraph B.1.)
10 CFR Part 21 Insoection - The inspector could not determine by review of documentation curing the inspection that the evaluation of the following G&H identified safety concerns and subsequent actions taken, meet the intent of the 10 CFR Part 21 requirements.
(See DetafisSection I, paragraph C.3.b.(1)).
G&H is not following their Part 21 procedures and NRC Headquarters has been requested to review the enforcement action to be taken.
(DetailsSection I, paragraph C.3.b.(2)).
1
3 DETAILS SECTION I (Prepared by O. F. Fox)
A.
Persons Contacted
- R. E. Ballard, CPSES Project Manager E. F. Chelotti, Manager, Electrical Engineering Department
- B. Czarnogoriki, Engineer, Quality Assurance P. P. DeRienza, Vice President, Quality Assurance "J. A. Gaynor, Assistant Engineer, Quality Assurance F. W. Gettler, Vice President, Power Generation "F. D. Hutchinson, Vice President, Power and Energy Division
- N. N. Keddis, Manager, Quality Assurance
- M. S. Miller, Supervisor, Quality Assurance J. A. Rudy, Counsel, LeBoeuf, Lamb, Leiby and MacRae J. R. Stange, Manager, Mechanical Engineering Department "J. E. Triolo, Supervisor, Quality Assurance
- E. J. Zadina, Supervisor, Quality Assurance
- Denotes those present at the Exit Interview.
8.
Action on Previous Inspection Findings 1.
(Closed) Deviation A (Report 80-01):
Audit procedures do not contain committed ANSI N45.2.12 requirements for report signatures, program evaluation statements, and maintenance of qualification and training records.
The inspector verified the corrective actions and preventive measures described in Gibbs and Hill letters of response dated April 25, 1980, and June 23, 1980.
Specifically, Gibbs and Hill prepared a matrix of the requirements contained in their audit procedures versus the committed ANSI N45.2.12 requirements and revised procedures QA-4 (CPSES-Internal Audit Procedure), QAI-4 (Auditor Training and Certification) and QAI-7 (Audit Performance and Followup) accordingly.
Unresolved Item Gibbs and Hill procedure QA-2 (Vendor Audit and Surveillance Procedure) establishes guidelines for vendor audits.
QA instruction QAI-6 (Vendor Audits - Interface Between TUGC0 and G&H) provides instructions for interaction between G&H and TUGC0 personnel with respect to the planning, executing, reporting and closing of audits.
Letter QGH-67 dated January 22, 1980, from TUGC0 to G&H, transmits an " interface document" with respect to vendor audits.
4 Based on the aforesaid and other documentation made available to the
. inspector during the inspection, and on personal interviews with G&H responsible management conducted during the inspection, the inspector could not resolve the apparent inconsistances between the CPSES PSAR commitments, the January 22, 1980 " interface document", the committed ANSI N45.2.12 requirements, the G&H vendor audit procedure (QA-2), the vendor audit interface instruction (QAI-6), and the vendor audit program actually being implemented by G&H.
i Gibbs and Hill management agreed to uniquely identify the G&H responsi-bilities with respect to the vendor audit program and to delineate the applicable elements of the G&H quality assurance orogram for control thereof.
2.
(Closed) Deviation B (Report 80-01) Procedure manuals were not controlled in accordance with procedural requirements.
The inspector verified the corrective actions and preventive measures described in Gibbs and Hill letters of response dated April 25, 1980, and June 23, 1980.
Specifically, a current index was provided to, and recepit acknowledged by, each manual holder, and procedure QAI-1 (Issuance, modification, and Control of Project Procedures Manual) was revised to incorporate a followup system for control of Project Procedure Manuals.
3.
(Closed) Deviation C (Report 80-01) A vendor specification was approved that did not meet requirements.
The inspector verified the corrective actions and preventive measures described in Gibbs and Hill letters of response dated April 25, 1980, and June 23, 1980.
Specifically, G&H specification MS-43A was revised by change order OE/CD-2116 to clarify the requirements for solution annealing (vendor specification JS-136 had been correctly revised by ITT Grinnell prior to inspection 80-01) and Project Lead Discipline Engineers were instructed by memo in the methods for reviewing and approving vendor procedures / specifications and to use the services of the project metallurgical engineer to review procedures involving metallurgical processes.
C.
10 CFR Part 21 Inspection 1.
Objectives The objectives of this area of inspection were to examine the establish-ment and implementation of related 10 CFR Part 21 procedures to verify that:
a.
10 CFR Part 21 is posted in accordance with the requirements.
5 b.
Deviations and nonconformances are evaluated and adequate records are maintained and properly dispositioned by the responsible organizations or persons.
c.
Methods of analyses for a defect, deviation or failure to comply are clearly described and responsibilities assigned to organiza-tions or persons in each related phase of analysis.
d.
A director or responsible officer has been appointed to notify the commission of evaluated defects, deviations or failures to comply.
e.
Procurement documents for safety related items specify that 10 CFR Part 21 requirements apply.
f.
Evaluation of deviations were timely and appropriate.
g.
Items determined to be substantial safety hazards were timely and appropriataly reported to the NRC.
2.
Method of Accomolishment Review of the following documents to accomplish the above objectives:
a.
Gibbs and Hill New York facilities were inspected to verify that copies of Section 206 and the 10 CFR Part 21 Regulations and implementing procedures in their entirity, or that an abbreviated notice containing Section 206 and describing the content and location of the Regulations and procedures, and the name of the individual to whom reports may be made, were posted in all Gibbs and Hill facilities where safety related activities were being conducted.
b.
Revision I and Draft Revision 2 of Gibbs and Hill (G&H)
Operating Procedure OPD-1 (Reporting Safety - Related Defects and Noncompliance Pursuant to 10 CFR 21); G&H purchase orders CP-15, CP-46, CP-71, CP-96 and CP-485 and change notices thereto; and summary of G&H 10 CFR Part 21 safety concerns 77-1, 79-1 thru
-4, 80-1 and N8E1 thru 3.
In-depth review of safety concerns 79-3 (Control Room Inhabitability, deemed to be not reportable by G&H),
79-4 (Inadequate Auxiliary Coolant Piping Supports, deemed to be reportable by G&H), and 80-1 (Lack of Seismic Qualification of HEPA Filters and Demisters, deemed to be not reportable by G&H).
10 CFR Part 21 Report (Inadequate Auxiliary Coolant Piping Supports -
Fort Calhoun) dated May 14, 1979; and eight letters, one telecen memorandum and one memo to file related to identified safety concerns.
c.
The FSARs for the Comanche Peak Steam Electric Station (CPSES) and the Fort Calhoun Unit 1 nuclear power plants and two specifi-cation? relating to ESF (Engineered Safeguard Feature) HEPA filters and dewisters.
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3.
Findings a.
Violation One violation was identified in this area of the inspection, failure to meet 10 CFR Part 21 Section 21.6 posting requirements.
(See Notice of Violation).
Gibbs and Hill took immediate action to post all documents required by 10 CFR Part 21 during the inspection with respect to the Notice of Violation.
Gibbs and Hill is to provide a descrip-tion of the remaining actions they have taken or plan to take.
b.
Unresolved Items (1) The following are identified safety concerns with respect to the Comanche Peak (under construction) and Fort Calhoun (operational) nuclear power plants.
(a) Safety concern 80-01; Lack of Seismic Qualification of HEPA Filters and Demisters.
(b) Safety concern 79-3; Control Room Inhabitability.
The safety concern evaluation board convened and evalu-ated these items and concluded they were not reportable under tna requirements of Part 21.
It does not appear the boards actions meet the intent of Part 21 concern-i ing the requirements for evaluating and reporting defects or deficiencies that could create a substantial safety hazard.
This matter has been forwarded to NRC Head-quarters for further review.
(2) At least three (3) examples were identified during this inspection where G&H were not following their Part 21 pro-cedure, OPD-1.
This matter has been forwarded to NRC Head-quarters for enforcement policy guidance.
c.
Follow-uo Items (1) The existing procedure (s) for evaluating and reporting safety concerns do not appear to contain sufficient guidance sucn that a G&H employee, who believes that an identified safety concern is a " substantial safety hazard" under the provisions of 10 CFR Part 21, will ultimately express the concern to the responsible reporting official of Gibbs and Hill.
This item will be followed during future inspections.
7 (2) The timeliness of reporting to the NRC under the provisions of 10 CFR Part 21 by the responsible officer on his designee after he obtains information reasonably indicating that G&H failed to comply with the Atomic Energy Act of 1954 as amended, or that a safety related design or component contains a defect or deficiency which would create a substantial safety hazard, will be followed during future inspections.
D.
Exit Interview An exit interview was held with management representatives on October 23, 1980.
In addition to those individuals indicated by an asterisk in para-graph A of each Details Section, those in attendance were:
H. R. Rock, Manager of Projects M. A. Vivirito, Manager, Analytical Engineering The inspector summarized the scope and findings of the inspection.
Management comments were generally for clarification only, or acknowledgement of the statements by the inspector.
I
8 DETAILS SECTION II (Prepared by Janet M. Johnson)
A.
Persons Contacted "R. Ballard, Project Manager (CPSES)
- N. N. Xeddis, Quality Assurance Manager
- B. Czarnogorski, Project Quality Assurance Engineer (CPSES)
G. M. Reiner, Project Engineer (CPSES)
- D9 notes those present at the exit interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Unresolved Item III.C.3.c. (Inspection Report No. 80-01).
This item is closed, based on Gibbs and Hill monitoring of humidity /
temperature conditions in storage areas containing microforms, and the commitment to install a dehumidifier if these exceed industry recommendations. Also, for certain records, including acerture cards, duplicate storage has been transferred to TUGC0 at the site, and a TUSI letter to Gibbs and Hill, referenced on Gibbs and Hill Interoffice Memorandum dated October 10, 1980, indicates that the site storage facility meets ANSI N45.2.9 requirements.
2.
(Closed) Followup ites (Inspection Report No. 80-01).
This item is closed, based on Gibbs and Hill completion of the transfer of QA records to their new facility.
Records previously identified in 80-01 as missing were verified to be present in the storage facility.
3.
Followuo Item l
A new followup item is identified relative to records identified by Gibbs and Hill as missing from duplicate storage.
These records includa design reviews, calculations, drawing revisions and specifi-cations and are listed on attachments to the Gibbs and Hill Inter-office memorandum dated August 13, 1980.
Certain of these missing records have been located since that date, but others are still missing.
Therefore, further review will be made during a subsequent inspection to assure that all QA records identified by Gibbs and Hill as missing have been located (or ratroft) and placed in the storage facility.
Also, the attachment to Interoffice Memorandum dated March 17, 1980, indicates that location of duplicate storage files for certain QA records required by ANSI N45.2.9 has not yet been determined by TUSI.
Since Gibbs and Hill is awaiting TUSI direction to see whether Gibbs and Hill or TUGC0 site will provide duplicate storage, this item will be examined during a suosequent inspection to determine satisfactory resolution and disposition 7f these records, l
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9 which include applicable codes and standards used, "As Constructed" Drawings, and System Process and Instrumentation Diagrams.
C.
Supplier Nonconformance and Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for:
a.
Disposition of nonconformances that provide for:
(1) Measures by the purchaser and supplier for identification, control, review, and disoosition of items or services ' hat do not meet procurement document requirements.
(2) Submittal of nonconformance notice to purchaser by supplier which shall include recommended disposition and technical justification.
(3) Submittal to the purchaser for approval of dispositions con-taining one or more of the following nonconformances:
(a) Technical or material requirement violated.
(b) Violated requirement in supplier document approved by purchaser.
(c) Noncortformance cannot be corrected by continuation of the origir;al process or by rework.
(d) Original requirement is not met but the itam can be restored so that its function is unimpaired.
(4) Purchaser disposition of supplier recommendations, verifica-tion of disposition, and maintenance of records of noncon-formance.
b.
Corrective action that provides for:
(1) Identification of and timely corrective action for conditions adverse to quality which occur during the procurement process that are the responsibility of the purchaser.
(2) Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
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10 (3) Reporting these conditions and the corrective action to management.
(4) Assuring that corrective action is implemented and maintained.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
CPSES, PSAR, Section 17.1.1.2 and CPSES, FSAR, Section 17.1.2 to determine project commitments relative to vendor nonconformances and to ANSI N45.2.11 and ANSI N45.2.13.
b.
Gibbs and Hill Quality Assurance Procedure Nos. QA-9 concerning nonconformances and their records.
c.
CPSES Project Procedure Manual, Procedures PC-9 and PC-5 to determine project procedures for handit.g deviations to design, fabrication and installation documents.
d.
Design Engineering Change Deviations:
DECD-S-2290 (re vendor Telex 5199; DECD-5-1158, Revision 1; DECD-S-2043; DECD-5-6985, and DECD-5-6985, Revision 1 (related to Design Change Authorization no. OCA 8071);
OECD-S-2042 (related to DCA 6590);
DECD 1157 (Superceding DECD-5-873 and related DCA 3169 Most of these DECDs related to contracts 43A, 43. A.1 and 438.
They were reviewed for conformances to the above - listed program and procedural requirements and the intent of the Objectives section above.
e.
QA attachment GS903 to contract 46A ana Design Change / Design Deviation requests nos. OC/00 254 and 255.
These were reviewed for conformances to the above - listed program and procedural requirements and the intent of the Objectives section above.
f.
DECD-5-1972 related to Problem 1-54A.
g.
Memorandum dated 10/26/79 (CPP-2082), 2/6/80 (CPPA-4041), no date (CPP-2160), 10/10/80, and Telexes dated 3/6/80 (GTT-4842) and 3/18/80 (TWX 11, 991) concerning the freeze imposed by TUSI on revision of drawings to incorporate changes, including DECDs.
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11 h.
Drawing El-0500-03-S (Reactor Bldg. Cable Tray Support plan Elev. 808, Quad 3) and seven (7) unincorporated DECDs and 30 unincorporated CMCs (Component Modification Cards).
i.
Printout of Drawings listing unincorporated revision documents.
3.
Findinas a.
Deviations and Unresolved Items No deviations or unresolved items were identified in this area of the inspection.
b.
Followuo Item Further review will be made during a subsequent inspection to determine the status of the freeze on revision to Flow Diagrams and Composite Piping Drawings to reflect design changes, including DECDs. This freeze was instituted by TUSI on October 26, 1979 and appears to still be in effect except for specific TUSI authorization permitting Gibbs and Hill to update specific requested drawings.
It was noted that Gibbs and Hill Interoffice Memorandum dated October 10, 1980 stated that the TUGC0 auditors recommended that this freeze he lifted on a system basis because updated drawings will be needed in startup.
Although the need updated drawings during construction was not mentioned, it
. gears self-evident.
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