ML19344F403
| ML19344F403 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344F394 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8009150231 | |
| Download: ML19344F403 (4) | |
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Gilbert / Commonwealth
. Docket No. 99900525/80-01 i
. NOTICE OF DEVIATION Based on theTresult's of an NRC inspection. conducted on March 24-28, 1980, it appears'that certain of'your' activities were not conducted in full compliance:with your commitments as' indicated below:
A.
The Gilbert / Commonwealth Topical Report (GAI-TR-106-2A) requires, in
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section 17.5.3,-that procedures be' prepared by Divisions to specify methods for complying with applicable requirements, and in section 17.2.6, that the G/C QA Policy Committee is responsible for conducting annual management reviews of the QA program to evaluate and assess its effective-~
ness.
Contrary to the.above, the Nuclear Quality Assurance Manual does not reflect these commitments nor does a procedure exist to specify methods of complying with_the commitment for conducting annual management reviews of the QA program to evaluate and assess its effectiveness. Specifically no procedural requirements ' exist for planning, scheduling, preparing, executing, reporting, distributing,-and following up on the annual '
management evaluation (which was performed by audit.in 1979).
. 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 accom-
-plished in accordance with these instruction, procedures, or drawings.
Instructions, procedures,.or drawings shall include: appropriate quantita-tive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." ' Deviations from these requirements are as follows:
.B.
Paragraph 3.3.1 of section 3.0 (Design Control) of the Gilbert / Commonwealth Nuclear Quality Assurance Manual states in part that, " Power Engineering Divisions.
. c. Perform design activities in compliance with approved procedures.
Specific Power Engineering _ Division procedural requirements, and deviations therefrom,_are as follows:
1.
Paragraphs 13.2.5.3, 3.2.5.4, and 3.2.5.5 of DCP 1.30 (GAI Drawings) respectively state in part that, "the Draftsman.
.. sends both the Drawing and1the checking print to the Checker.
.. the Checker back' checks the Drawing.... signs'his initials and the date on the-Drawing and sends it to the Drafting Squad Leader.... the
- Drafting SquadLLeader signs and dates'the Drawing."
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Contrary to the above, the Checker did not sign his initials and the date on any of,the approved and issued System Flqw Diagrams for the Perry Project prior to the Drafting Squad Leader signing and dating
.the Drawing.
~2.
Paragraph 4.1 and Exhibit.1.10-1 of Instruction 1.10 (Reproducing the Copy) contained in the' Specifications and Bills of Material Department Instruction Manual respectively state in part that ".
(safety related)...- Documents shall be prepared for reproduction as follows.... Refer to Exhibit 1.10-1 for Checklist.
Title Page.
(is)... imprinted with " SAFETY RELATED"....
(and)... cover... (is)... printed on Salmon color paper...
' Contrary to the above, none of the Title Pages of the safety-related Specifications for the Three Mile Island #1 Continuing Services (Restart) Project were imprinted with the words " SAFETY RELATED" nor were their~ covers printed on Salmon color paper.
3.
Paragraph 2.5 of DCP 1.30 (GAI Drawings) states in part that, ".
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if 'any part of a Drawing depicts safety class items, the Nuclear Safety Related safety classification notice shown in Appendix C, Section 1.30 page 4~(NUCLEAR SAFETY RELATED) shall be inserted adjacent to the title block...."
-Contrary to the'above, none of the Drawings depicting safety class items'for the Three Mile Island #1 Continuing Service (Restart)
Project exhibited the requisite Nuclear Safety Related safety classification notice.
4.
Paragraphs 2:08.1, 2:08.3 and 2:08.4 of Appendix G of the Perry
. Nuclear. Power Plant Project Procedures Manual respectively state in part that, " Safety related system diagrams and safety related one line diagrams: require design review.
Certification of this review is accomplished by marking the drawings with the following:
'Rev.
Design Review Complete:. Design Reviewer Date The blanks are filled in by the responsible Project Engineer with his. initials and the date... Design' review comple-tions for subsequent revisions-is indicated by revising the infor-mation contained in the ' blanks' above. This documentation is required for all revisions to the drawing regardless of the extent of the. review.
Contrary to the above, of the fifteen (15) original issue and revised
' Perry Project safety related drawings that.were examined by the inspector, over fifty.(50) percent did not exhibit the required docu-reentation that.the. design review was' completed by the responsible
. Project Engineer.~
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5.
Paragraph 3.2.11 of DCP 2.05 (Decign Verification) states in part that, "The Project Engineer shall review Design Verification Records at least quarterly...."
Contrary to the above, the Three Mile Island #1 Continuing Services (Restart) Project Engineer has not. reviewed the Design Verifcation
~ Records for structural designs at the required quarterly intervals since January 30, 1979.
C.
Paragraph 18.3.1 of section 18.0 (Audits) of the Gilbert / Commonwealth Nuclear Quality Assurance Manual states in part that, " Quality Assurance-
. Division... (shall)... Develop and implement a system of planned and periodic audits...."
Specific procedural. requirements, and deviations therefrom, are as follows:
1.
G/C NQAM, Section 18.3.2, requires all divisions to submit responses to audit deviations and to perform corrective action.
Contrary to the above, required responses had not been submitted for audit SA 79-4 and corrective action has not been performed for 6 deviations as delineated in response for audit IA 79-1 (and others).
2.
NQAM, Section 18.2(c) requires audit of indoctrination and training, and internal and external interface controls, and QAPM, 10.3, section 6.2.3, requires audits of each discipline performing activities affecting quality within Power Engineering and QA at least once a year or once within the lifetime of the activity.
Contrary to the above, audits performed during 1979 did not cover all areas, delineated above (e.g. indoctrination and training, each discipline within Power Engineering and each project, or all applicable 18 criteria areas of 10 CFR 50, Appendix B).
3.
QAPM, QAP 10.3 paragraph 6.2.7 requires follow up action scheduled
-to correspond with implementation of corrective action as identified in response.
' Contrary to the above, follow up action was not scheduled to correspond with implementation of corrective action as identified in response (performed as much as 2-8 months later for 1979 audits).
4.
QAPM, '(pu? 10.3 paragraph 6.8 requires formal notices transmitted to-
-responsible parties in cases of overdue responses.
Contrary to the :above, formal notices were not transmitted for over-due: responses-(e.g. audit SA 79-4).
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5.
Paragraph 18.2 of section 18.0 (Audits) of the Gilbert / Commonwealth Nuclear Quality Assurance Manual states in part that, " Procedures shall be established to implement the following requirements
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. Implementing necessary management action to correct any deficiencies revealed by the audit.
Contrary to the above, a procedure was not established, to implement the necessary management actions to correct any deficiencies revealed by the audit.
Consequently, no corrective action was taken to resolve deficiency No. I that was identified in audit SA79-1 that was. performed-on August 1-3, 1979.
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