ML19344F405
| ML19344F405 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/1980 |
| From: | Fox D, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344F394 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8009150234 | |
| Download: ML19344F405 (30) | |
Text
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Y U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900525/80-01 Program No. 51200 Company: : Gilbert / Commonwealth P. O. Box 1498 Reading, Pennsylvania 19603 Inspection Conducted:
Ma rch 24-28,1980 l
Inspectors:
n O
di
~[ -[d D.7@ Evaluation SectionW, Contract /f~ Inspector Date Program Vendor Inspection Branch Vm Ch%~
4/n/ro J.f ty. Johap6n, Contractor Inspector
'Date PrVgram Waluation Section Vendor Inspection Branch k
dL h t/-/Mo S. IT.Jbneter, Chiff Date Engineering Support Section 2 Reactor. Construction and-Engineering Support Branch Region I, I & E k~SO l
/
1 Engin(eeringSupportSection2pgef,Reactoffnspector Date L. W Reactor Construction and Engineering Support Branch Region I, I & E Approved by:
k
/
C. J. Ikflf, Chief.
Date Program Evaluation Sec/ /
tion Vendor-Inspection Branch Summary
-Inspection on March 24-28, 1980 (99900525/80-01) 80C9'15023Y j
2 Areas Inspected:
Implementation of Title 10 CFR 50 Appendix B, and Topical Report GAI-TR-106, including QA Manual Review, Initial QA Program Inspection, and action on previous inspection findings.
The inspection involved one hundred and twenty seven (127) inspector-hours on site by four (4) USNRC inspectors.
Results:
In the three (3) areas inspected, three (3) deviations from commitment were identified in two-(2) of the areas.
One unresolved item wa. identified.
Deviations: QA Manual Review - Procedure for conducting annual management reviews of the QA Program does not exist (See Notice of Deviation, Item A).
Initial QA Program Inspection - Certain design activities were not performed in accordance with approved procedures (See Notice of deviation, Item B).
Certain audits were not performed in accordance with approved procedures.
(Cec Notice of Deviation, Item C).
Unresolved Item:
Initial QA Program Inspection - A defined quality assurance plan for TMI-1 (Restart) does not appear to be in place (DetailsSection I, paragraph D.3.b. (1)).
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1
3 DETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contacted W. Anderson, Management Consultant
- N. R. Barker, General Manager, Quality Assurance Division J. H. Brendien, Jr., Electrical Engineer A. J. Bullock, Assistant Project Manager, Perry Project L. B. Cranick, Manager, Specification Section
- J. C. Daily, Senior Q.A. Program Manager G. ' Gibson, Project Quality Coordinator H. N. Goldstein, Sr. Mechanical Project Engineer J. R. Gordon, Mechanical Drafting Squad Leader
- P. B. Gudikunsty, Project. Manager, Perry Project
- R. C. Holswarth, Corporate QA Program Manager D. N. Kelley, Electrical Engineer N. S. Lewis, Specification Writer
- A. G. Maino, Manager, Quality Engineering
- T. M. McMahon, Manager, Electrical Engineering Department
- W. E. Meek, Manager, Engineering Department
- F. L. Moreadith, Manager, Structural Department
- R. E. Pages, Assistant Manager, Structural Department
- R. C. Patton, Project Control Engineer B. Piasecki, Jr., Piping Designer
- F. R. Ricci, Manager, Design Control R. S. Richards, Drafting Squad Leader
- R. M. Roge.s, Project Manager, TMI-1 Continuing Services
- W. F. Sailec, Manager of Projects J. F. Schollinberger, Mechanical Engineer J. M. Smith,-Droject Electrical Engineer S. A. Steinbergh, Manager, Vendor Print Service Department D. F..Vandegrift, Engineering Specialist P. H. Wentzel, Manager, Engineering Support D. P.' White, Manager, Nuclear Section Mechanical Engineering
- E. Wielkopolski, Project Manager, VC Summer Project -
- Denotes those present at the. exit interview.
B.
Action on Previous Inspection Findings 1.
(Open) Deviation-(Report No. 79-01):
Copies of quality assurance records that are stored in the QA and Engineering Division Files have not yet been forwarded to the records retention center.
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The inspector determined that copies of the QA Division quality assurance records have been forwarded to the records retention center but the transmission of copies of all quality' assurance records ~ stored in the Engineering Division Files, due to be completed by March 31,11980, was.not completed.as of March 28, 1980. : Gilbert / Commonwealth requested in writing (letter dated March 27,
.1980) an extension of their ccanitment date for completing this transfer to June 30, 1980. This acknowledges that requested extensica for duplication of the subject records.
2.
(Closed) Deviation (Report No. 79-04):
The table of contents of the
' VCS-1 QA Manual had not been updated as required by procedures.
The inspector verified the corrective action.and preventative measures described in the letter of response dated January 28, 1980, i.e. the table of contents was properly hand annotated and future revisions to the manual, if any, will be accompanied by a revised table of i
contents thereby precluding similar errors of omission in the table of contents.
3.
(0 pen) Deviation (Report 79-04): A purchase order for a nuclear safety related item did not contain, nor reference, all of its
- technical requirements fer the item, i.e. the design drawing numbers for safety related pipe rupture restraints were not included nor referenced in the purchasing documents. Additional information about corrective action and preventative measures is required beyond that. described in the-letter of response dated January 28, 1980.
j' 1C.
QA Manual Review
-1.
Objectives t
..The objectives of this area of the inspection were to determine that the Nuclear Quality Assurance Manual (NQAM):
a.'
Accurately reflects the commitments in the approved Gilbert /
Commonwealth (G/C) Topical Repors GAI-TR-106: (Revision 2A) with respect to the G/C Organization,-Quality Assurance Program and Design Control' Sections.
b.-
Contains or references appropriate procedures, and identifies 2
applicable codes, standards.and regulatory requirements, for
-perfooming. quality related activities for items and services important to safety in a nuclear power plant with respect to criteria I, II and III (Organization, Quality Assurance Program and Design Control) of Appendix B to 10 CFR Part-50.
f a
1
c.,
5 2.
Method of Accomplishment Review of the following documents to determine if the above objectives were accomplished relative to Organization, QA Program and Design Control:
The GAI (Gilbert Associates Incorporated) Topical Report a.
GAI-TR-106 (Gilbert / Commonwealth Quality Assurance Program for Nuclear Power Plants) Revision 2A dated February 1980, to determine the corporate QA programmatic commitments
, relative to the three identified quality assurance programmatic areas.
b.
The following sections of the G/C NQAM (Nuclear Quality Assurance Manual) Revision 1 dated September 29, 1978, to determine that the corporate commitments relative to the three identified programmatic areas were accurately reflected in the approved quality assurance program:
Sections: 1.0 (Organization); 2.0 Quality Assurance Program);
and 3.0 (Design Control).
Figures:
1 thru 7, Revision 1 (Organization Charts);
Appendices A, (Applicable Codes, Standards, and Regulatory Requirements); and B, (Matrix, Gilbert / Commonwealth Procedures versus 10 CFR 50, Appendix B Criteria).
The following sections of the G/C QAPM (Quality Assurance c.
Procedures Manual) Revision 7. dated December 28, 1979, to determine that the NQAM requirements relative to the three identified programmatic areas were correctly translated into timely _ Quality Assurance Division procedures:
QAPs: 1.0 (Quality Assurance Division Organization); 2.1 (Preparation of Quality Assurance / Control Plans); 3.1, (Drawing, Specification and-Technical Document Review); 3.2, (Review of the Safety Analysis Report); and 3.3 (Preparation of Quality Assurance Specification),
d.
The following sections of the PEDPM (Power Engineering Division Procedures' Manual) dated August 21, 1978, to determine that the NQAM requirements relative _to the three identified pro-grammatic areas were correctly translated into timely Power Engineering Reading Division procedures:
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PERDPs: 115, (Project Equipment List Initiation and Maintenance);
116, (Vendors' Procedures Drawings and Calculations);
- 118, (Computer Programs); 126, (Systems Descriptions);.129, (Environ-mental Reports); 130, (Topical Reports); 404 (Seismic Criteria s
Boundary for Support Design); and 406 (Pipe Rupture Protection).
The following sections of the G/C DCPM (Design Control Procedures e.-
Manual) Revision 8 dated February'14, 1980, to determine that
.the NQAM requirements relative to the three identified programmatic areas were correctly translated into timely engineering design control procedures:
DCPs:
1.05 (Classification); 1.10, (Design Input); 1.30, (GAI Drawings);- 1.35, (Piping Design); 1.50, (Computer Program Use Control); 2.05 (Design Verification); 2.20, (Change Notices);
2.45, (Interface Control); 3.05, (Vendor Drawings); 3.15 (Design Records); 4.05 (Technical Qualification of Vendors); 4.15, (Procurement Documents); 4.20, (Nonconformance to GAI Design Documents); 5.10, (Project Management Manual); and 6.05, (Safety Analysis Report).
l f.
The appropriate-sections (procedures) of the Procurement Control Procedures Manual,-the Construction Control Procedures Manual and l
the Comprehensive Identification System (CE) Manual to determine l
that the NQAM requirements relative to procurement specifications i.
and field changes were correctly translated into implementing l
instructions and procedures.
3.
Findings a.
Deviations from Commitment or Unresolved Items None.
b.
Follow-up Items (1)
It could not be determined during this inspection that the
. safety classification of a structure, system or component was prominently identified on the " Design Input" form for the item as required by DCP 1.05.
The " Design Input"~ form l
-(as defined.in-Appendix C to DCP 1.10) lists twenty.nine items to be considered as design input but appears to have no provision for entering or recording the safety.
' classification of the item as-required.
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. (2) 'The basis for commitment to different issues of ANSI N45.2 j
in.the Topical and-the NQAM could'not be. determined.
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7)
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7 during this inspection.
The Topical Report endorses the 1977 issue whereas the NQAM imposes the 1971 issue.
The above two follow up items will be further evaluated during a future inspection.
c.
Comments (1) The Topical Report and the NQAM both state that the NQAM is _ the controlled corporate document that describes the Nuclear Quality Assurance Program and that the Program is Laplemented through approved procedures contained in the following controlled divisional manuals:
Design Control Procedures Manuals (Reading and Jackson)
Construction Control Procedures Manuals (Reading and Jackson)
Procurement Control Procedures Manual Quality Assurance Procedures Manual The above commitment constitutes the basis for this inspection, i.e. first, the NQAM should accurately reflect the commitments contained in the Topical Report and second; procedures which implement the Topical Report commitments would be contained in either the NQAM or the six (6) identified divisional manuals.
(2) With respect to the G/C Organization section of the Topical Report, the corresponding section of the NQAM does not reflect the recent organizational changes (i.e. re-structuring of the Utilities Group and the Power Engineering Division), the elimination of the Construction Service Division, the establishment of the Quality Assurance Advisory Committee, and other organizational changes of a lesser nature.
G/C Management.(Reading) is in the process of revising Section-1.0 (Organization) of the NQAM. A draft of the revision is currently in the final stages of review and approval.
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8 (3) 'With respect to the Quality Assurance Program section of the. Topical Report, the corresponding section (Section 2.0) of the NQAM does not reflect the effect of recent organi-zational changes on the implementing manuals, procedures and interdepartmental interfaces, the formation of the Quality Assurance Advisory Committee, the quarterly Quality Assurance Program effectiveness ' evaluation meeting, the i
annual G/C management review of the Quality Assurance Program, the functions executed by the Quality Assurance Division, and other QA Program elements of a lesser nature.
GC Management acknowledged that differences.between the two documents exist and is in the process of evaluating the changes needed to Section 2.0 (Quality Assurance Program) of the NQAM to reflect the Topical Report commitments.
(4) With respect to the Design Control Section of the Tonical Report, the corresponding section (Section 3.0) of the NQAM does not specifically reflect certain commitments to design verification (i.e. purpose, qualifications and independence of verifiers, and the basis for selection of items to be verified), documentation of interface reviews, consideration of safety factors, consumable and expendable items, use of off-the-shelf items, use of industry standards, and other Design Control elements of a lesser nature.
G/C management acknowledged that differences between the two documents exist and plan to determine the changes to Section 3.0 (Design Control) of the NQAM that would be required to accurately reflect the Topical Report commitments.
(5) The Matrix of G/C procedures vs 10 CFR 50 Appendix B criteria contained in the NQAM does not reflect the recent organizational changes.
d.
Except as noted in paragraphs b. through c. above, the inspector concluded that the NQAM appears to accurately reflect the the commitments contained in the Topical Report with respect to the G/C Organization, Quality Ass trance Program and Design
- Control sections of.the Topical R c t and'contains, or references, implementing proce. ",i and applicable codes,
. standards and regulatory requiremcats for performing quality related activities for items and services important to safety in a _ nuclear power plant.
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9 D.
Initial QA Program Inspection 1.
Objectives The objectives of this area of the inspection were to determine, with respect to criteria I, II and III (Organization, Quality Assurance Program and Design Control) Appendix B to 10 CFR Part 50, that:
a.
The necessary facilities, organization, written and approved procedures end instructions, and practices for the quality assurance program are being implemented.
b.
The quality assurance program is being implemented within the defined scope of supply for current nuclear projects.
c.
The quality assurance program, as implemented, is capable of assuring a quality product.
2.
Method of Accomplishment Review of the following documents to determine if the above objectives were accomplished relative to G/C Organization, QA Program and Design Control:
The appropriate sections (policies and procedures) of the a.
following Project Management Manuals and Project Quality Assurance Plans to determine thrt corporate programmatic commitments relative to G/C Organization, Quality Assurance Program, and Design Control were accurately reflected in the approved in place quality assurance program for the individual nuclear projects consistent with the G/C scope of supply for the project:
(1)
Perry Project Project Management Manual, Rev. 12, August 18, 1979 Project Quality Assurance Plan, Rev. 6, January 15, 1980.
(2)
V. C. Summer Project Project Management Manual, Rev. 23, November 19, 1979 Project Quality Assurance Plan, Rev. 5, July 5, 1978 (3) Crystal River Continuing Services Project Management Manual, Rev 0, February 28, 1979 d
7 10 (4)
R. E. Ginna Continu'ing Services 4 '
Project Management Manual, Rev 7, May 5,1978 Project Quality Assurance Plan, Rev 3, December 1, 1976 (5) TMI-1 Continuing Se.rvices 4
Project Management Manual, Rev 0, October 23, 1978 Project Quality Assurance Plan, Draft b.
The appropriate sections (procedures) of the Engineering 4
Department Section' Manuals for the following departments
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to determine that the NQAM requirements relative to Design Control were correctly translated into timely engineering procedures: Architectural, Building Services, Chemical Engineering, Drafting Services, Electrical Drafting, Electrical Engineering, Instrumentation and Control, Mechancial Drafting, Mechanical Engineering, Piping Engineering, Plant Layout, Project Services, Specificaticas and Bills of Material, Structural Drafting, and Structural Engineering.
The following documents. to determine if procedures are c.
being Osplemented consistent with corporate and project commitments:
six (6) Calculations, one Design Input Record, two (2) Design Review /Verfications, seven (7) Design Specifi-cations, and twenty-one (21) Internal and Vendor Drawings.
. 3.
Findinas a.
Deviations from Commitment.
I See Notice of Deviations, Items B.1 thru B.4 and the additional comments below.
(1) With respect to Item B.1, the current Perry Project practice is for the Checker to check and sign the previously approved and issued System Flow Diagram at the same time as the Piping Drawings, that were generated from the subject system Flow Diagram, are checked and signed by the e
checker. This is'not in compliance with the requirements of DCP 1;30.
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11 (2) With respect to Item B.3, although required by DCP1.30, the TMI-1 Continuing Services Project Manual permitted G/C drawings for the project, to be issued for safety related items without the " NUCLEAR SAFETY RELATED" notation.
l Paragraph-2.5 of DCP 5.10 (Project Management Manual) and paragraph 2.7 of Section 2.0 of the NQAM (as well as the Quality Policy Statement in the NQAM by the President of Gilbert Associated) recognize the need for project unique quality requirements and both require that deviations from i.
j the NQAM requirements be requested of, and approved by, the l
Division General Manager and the Quality Assurance Division General Manager. No exception to the DCP 1.30 requirement for identifying safety related drawings as " NUCLEAR SAFETY j
RELATED" was obtained by the TMI-1 Continuing Services Project.
b.
Unresolved Item l
l It could not be determined during this inspection that the Quality Assurance Program for the TMI-1 Continuing Services l
(Restart) Project was defined in either the current Project i
Management Manual or the project Quality Assurance Plan as required by the NQAM Manual and the DCPM Manual.
G/C personnel were unable to locate the program plan before the end of the inspection.
This unresolved item will be further evaluated during a future inspection.
l c.
Follow-up Items I'
(1) With respect to drawings, the relative frequency of occurance of drawings with duplicate drawing or revision numbers, and drawings with inaccurate references, will be evaluated during a future inspection.
I (2) With' respect-to calculations, the relative frequency of calculations that did not reference the source of design inputs, and' calculations that were not signed as being Design Reviewed /Verifi ' will be evaluated in a future inspection.
(3)' It could not be determined during this inspection that all l
deviations (exceptions or variances) from NQAM require-ments or approved Divisional Procedures that were taken in the individual Project Management Manuals were.
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12 approved in advance of their implementation by both the Division General Manager and the Quality Assurance Division General Manager as required by approved procedures.
d.
Comments (1) The Engineering and Quality Assurance managment acknowledged the'non-adherences to procedural and committed requirements and discussed' plans for both corrective and preventive action.
The management further stated that the current manuals and procedures would be reviewed and revised as necessary.
(2) Except as noted in paragraphs a. thru c. above, the inspector concluded that (with respect to the G/C Organization, Quality Assurance Program and Design Control Program sections of the Topical Report): (1) the commitm6nts to quality contained in the Topical Report and/or the Nuclear Quality Assurance Manual appear to be correctly translated into a viable quality assurance program; (2) the necessary facilities, organization, written and approved procedures and instructions and practices for implementing the quality assurance program are defined and appear to be in place; (3) the quality assurance program appears to be implemented within the defined scope of supply for current
. nuclear projects; (4) the quality assurance program, as implemented, appears to be capable of assuring a quality product.
E.
Exit Interview An exit interview was held with management representatives on March 28, 1980.
In addition to these individuals indicated by an asterisk in paragraph A of each Details Section, those in attendance were:
R. B. Archibald, Manager of Projects, Perry Project H. A. Glando, Manager, Mechanical Engineering Department H. E. Yocom, Deputy Project Manger The inspector summarized the scope and findings of the inspection.
Management comments were ' generally for clarification only, or acknow-ledgement of statements by the inspector.
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.3 13 DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Persons Contacted
G. Gibson, QA Program Coordinator
- R. Holzwarth, Corporate QA Project Manager J. F. Hunter, QA Project Engineer J. Sockel, Project-Mechanical Engineer J. J. Urbaniak, Audit Coordinator
- Denotes those present at exit interview.
B.
Quality Assurance Manual Review Objectives The objectives of this area of the inspection were to determine whether the Gilbert / Commonwealth (G/C) Nuclear Quality Assurance Manual (NQAM):
Accurately reflects the commitments in the approved G/C Topical a.
Report no. GAI-TR-106, Revision 2A, with respect to 10CFR50,
' Appendix B, criteria IV through XVIII, including activities performed by G/C in Procurement Document Control; Instruc-tions, Procedures and Drawings; Document Control; Control of Purchased Material, Equipment and Services; Inspection; Cor-rective Action; QA Records; and Audits; and activities invoked on vendors and reviewed or monitored by G/C, such as Identifi-cation and Control of Materials, Parts and Components; Control of Special Processes Test Control; Control of Measuring and Test Equipment; Handling, Storage and Shipping; Inspection, Test and_ Operating Status; and Nonconforming Materials, Parts or Components.
b.
Contains or references appropriate procedures, and identifies applicable codes, standards and regulatory requirements for performing quality related activities, or invoking requirements on vendors 'and reviewing or monitoring vendor performance of quality-related activities, for items and services important to safety in a nuclear power plant with respect to 10CFR50, Appendix B criteria IV through XVIII.
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14-12.
Method of Accomplishment
.The preceding objectives were accomplished by an examination of:
Gilbert / Commonwealth.(G/C)' Topical Report number GAI-TR-106, a.
4 Revision 2A, Sections 17.4 through 17.18 and Figure 1-8 to
-determine.QA' program' commitments.
4
-b.
G/C Nuclear Quality Assurance Manual (NQAM), Sections 4.0 through 18.0 and Appendices A and C to determine. corporate QA program commitments _and their c.onformance to Topical commitments.
G/C Quality Assurance Procedures Manual, procedure numbers c.
QAP 4.1, 4. 2,.4.3, 4.4, 5.1, 5.2, 5.3, 6.1, 6.2, 7.1, 7.2, 8.1, 8.5, 8.6, 9.1, 10.1, and 10.3 to' determine that procedures i
bMplement Topical and NQAM requirements.
d.
G/C Design Control Procedures numbers DCP 3.05, 4.10 and 4.15 concerning bid evaluations.
3.
Findings a.
Deviations and Unresolved Items None were' identified.
b.
Follow-up Items (1)
Ini he area.of. Procurement Document' Control, neither the t
- Topical, the NQAM, nor the QAPM requires a documented
. yearly evaluation of vendors with active contracts to determine the need for an audit, or that a minimum audit frequency of three years be-imposed for active vendors.
.(2)' All requirements which' appear in the Topical Report are not reflected in the NiQAM, and certain ones do not appear
'in'subtier' manuals (e.g. 3.b. above).
Hence, the NQAM.
appears to be less definitive and.less restrictive than
- the Topical Report in certain areas.
(3) Regulatory Guide (JR.G.) requirements in the NQAM are i
.different fronjand'less restrictive than those in the Topical' Report..R. G. 1.54,.which endorses ANSI N101.4, is committed to in the Topical Report; it is not listed in the NQAM.
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15 Other than the-above noted items, the G/C QA program appears c.
to' adequately address-the QA commitments in the Topical Report and to.contain or reference appropriate procedures, codes, standards,'and regulatory requirements as applicable to areas in'which G/C has. prime responsibility for performance, in areas.inLwhich interface with-the licensee may be involved
_(e.g. procurement), and in areas in which G/C imposes require-ments for performance on others (e.g. vendors), and reviews and/or monitors the performance of others, d.
The' scope of G/C responsibilities differs for different projects.
'However, the delineated QA~ program adequately covers the following areas (within the scope of current projects and anticipated or projected work):
Criterion IV (Procurereat Control); Criterion V -(Instructions, Procedures and Dr1/ings);
Criterion VI (Document Control); Criterion VII (Control of Purchased Material, Equipment and Services); Criterion VIII (Identification and Control of Material Parts and Components -
primarily a vendor or site function, as correctly reflected in G/C QA program); Criterion IX (Control of Special Processes -
primarily a vendor or site function, subject to review and-approval and vendor _ surveillance by G/C); Criterion X (Inspection); Criterion XI:(Test Control primarily a vendor-or' site-function); Criterion XII (Control of Measuring and-Test Equipment primarily a _ vendor or site function), Criterion XIII (Handling, Storage and Shipping primarily a vendor or site function); Criterion-XIV (Insp'ection, Test and Operating Status primarily a site function); Criterion XV (Nonconforming' Materials, Parts and Components - Vendor and site function subject to review and approval by G/C); Criterion XVI (Corrective Action); Criterion XVII (QA Records); and Criterion XVIII (Audits). The G/C QA program properly addresses each' criteria within the G/C scope of work.
C.
Initial ~QA Program Inspection 1.
Objectives The objectives of this area-of the inspection were to verify the following with respect to'10 CFR 50, Appendix B, criteria IV through XVIII, including activities performed by G/C such as Procurement Document Control;. Instructions, Procedures and Drawings; Document Control;; Control of Purchased Material,' Equipment and-Services;
- Inspection;! Corrective: Action; QA Records; and Audits; and activities
. invoked on vendors and reviewed or monitored by G/C for the Perry Project, such asLIdentification and Control of Materials, Parts and i
Components; Control:of Special Processes; Test Control; Control of i;
-St 11
16 Measuring and Test Equipment; Handling, Storage and Shipping; Inspec-tion, Test and Operating Status; and Nonconforming Materials, Parts and Components:
The necessary facilities, written and approved procedures and a.
instructions, and practices for the quality assurance program are being implemented.
b.
.The quality assurance program is being implemented within the defined scope of supply for current nuclear projects; c.
The quality assurance program, as implemented, is capable of assuring a quality product.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
The documents listed in Section II B.2. as applicable to either a.
corporate functions or Perry Project unique functions.
b.
Perry Nuclear Power Plant QA Program Plan; Perry Nuclear Power Plant Procedures Manual; and Cleveland Electric Illuminating Company (CEI) Corporate Nuclear QA Manual (invoked by Preliminary Safety Analysis Report (PSAR) deviation no. C-4, Revision 1 to the PSAR for Perry, Chapter 17.1 "QA During Design and Construc-tion", and original PSAR Chapter 17.1 to determine Perry project quality requirements and implementing procedures.
G/C Records Management Manual to determine procedural require-c.
ments for retention of QA records.
d.
Procurement Control Procedures, numbers PCP III 1.2 and 1.3 concerning approval of bidders, etc.
G/C Quality Assurance Advisory Committee Bulletin number QAAC e.
79-2 to determine time requirements for design verification.
f.
Documents related to procurement from Bingham-Willamette Company (BWC) for Perry Nuclear Project of eight (8) pumps for HPCI, LPCI,-CS and RHR systems (active, seismic Class I,
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safety-related, Class II single-stage centrifugal pumps):
(1) Technical specification number SP-506-4549-00 and changes which requires the vendor to design, manufacture and test the pumps.
17 (2) QA Attachment Specification number SP-702-4549-00 delin-eating QA requirements.
(3) Results of review of BWC QA Manual on August 23, 1973.
(4) Qualified Bidders List dated April 29, 1974.
(5) Preaward survey dated September 2, 1976 to CEI, transmittal number PY-GAI-CEI-701QA.
(6) Proposal Review Summary Sheet dated April 22, 1976.
(7) Letter concerning BWC exceptions to R.G. 1.48 to CEI on transmittal number PY-GAI-CEI-4768.
(8)- Memorandum dated February 15, 1977 with attached Engineering Statement of Resolution of technical items and QA Statement of Resolution, which provide basis for conforming the specification.
(9) BWC manufacturing and QA plan approved by G/C on September 12, 1978, including hold points.
(10) BWC procedures reviewed and approved by G/C including:
Performance Test Procedure E30.39 (6/22/79); Wald pro-cedure CS 1-4 (8/24/78); Hydrotest procedure E30.125.2 l
(2/28/79).
(11) Vendor Surveillance Report of witness of hydrotest for eight (8) pumps dated September 28, 1979.
(12) BWC QA Manual H40.27, Revision 11, which covers non-code i
parts.
l (13) BWC outline Drawing no. E-17409X for pumps numbers FD-1A 015/22 and G/C approval dated May 25, 1979.
(14) GE (NEED) interface drawing number 762E455 and P&ID 105D 5025A reviewed to verify system design pressure.
(15) BWC Seismic Analysis (sealed by Registered Professional Engineer) and review and approval by CEI and G/C.
g.
Documents related to procurement from TRW Mission Manufacturing Crapany for Perry Project 'of wafer-style duo check valves (safety-related), and TRW Mission Nonconformance Reports (NCRs) numbers 041-003 and 041-004 and G/T: approvals.
l
i 18 h.
Documents related to procurement for Perry of Class IE 13.8 kV switchgear:
(1) Technical specification number SP-556-4549-00.
(2) QA attachment specification number SP-707-4549-00.
(3) Seismic analysis and testing requirement attachment no.
(4) Perry PSAR Deviation number 11 adding two (2) 13.8 kV Class IE breakers with 500 MVA interrupt rating.
(5) Bidder evaluation worksheets.
(6) Preaward survey.
l i.
Vendor surveillance trip report numbers 036-8 and 036-9 of Westinghouse in Hyde Park, Massachusetts.
j.
G/C Internal Audit Schedule for 1980.
k.
G/C Internal Audits performed for 1979, including responses to Audit Finding Reports (AFRs), evaluation of responses, veri-fication of corrective action, and current status of AFRs and committed corrective actions:
(1) Audit IA-79-5 of Power Engineering performed in March, 1979 (no closure of AFRs).
l (2)' Audit SA-79-1 of Three Mile Island One (TMI-1) Restart per-l formed in August, 1979 (No response to AFR number 1).
(3) Audit IA-79-1 of design areas (Six (6) AFRs open).
(4) Audit IA-79-10 of Audits (seven (7) AFRs closed and six (6) AFRs still open, although unissued audit IA-80-1 appears to close these).
(5) Notes concerning follow-up audit IA-80-1 of open AFRs, which was just performed and has not been issued yet.
It appears.that many AFRs still remain open because committed corrective action has not been performed, although committed dates for corrective action were last year.
~(6) Oualification/ certification records for:
- (a) Two lead auditors c
L
. u-
'i' e,
19 (b). Three vendor surveillance persc anel (including eye exams and NDE level certificat:.ons, as applicable).
.l.
Duplicate files (e.g. one in department; one in Record Retention Center) for the 'following records:
(1) Four (4) of above listed audits; (2) Qualification / certification of two (2) lead auditors and three (3) vendor. surveillance personnel; (3) -Six (6)-calculations as follows: N21-4; RWCV G33-1, G-33-2, G-33-3, and G-33-4; and E-32.
3.
Findings a.
Deviations (See Notice of Deviation, Items C.1 thru C.4) b.
Unresolved Items None identified.
c.
Follow-up Items (1)
In the QA' Records area,-Records Management Manual Pro-cedure 3.4 allows checkout of boxes of records from the-Record Storage Retention facility.
A review of the
. log of records checked out indicating their retention at other locations for long periods of time (2 years and more) raises concern that this-practice may negate dual storage.
(It.did not appear that these records had been microfilmed)..Also, control over who could check records out appeared lacking; the legibility of certain calculations (xeroxed) retained in the Engineering Department appeared-inadequate, and retrievability of records in the Record Storage Retention facility was difficult because. it is necessary to know the shipment number in order to 1ocate the box number that the
~
record is in.
This seems contrary to the Topical require-ment for an'index (section 17.17.3.3).
-(2). Certain calculations do not appear to have been reviewed and/or. verified, although the systems had been designed and procured. Specifically, there were the following calculations for Perry:
m J
20 (a) RWCV G33-1 (RW Pressure drop and Line Sizing); G33-2 (RW Cleanup);_G33-3 and G33-4.
These were generated in 1977 and none appear verified. Review appeared to have been made of G-33-1 which resulted in significant comments tad questions which do not appear to have been resolved.
(b) E-32 (MSIV Leakage Control).
This was generated in 1978 and does not appear verified.. It could not be determined during this inspection whether the require-ment in QAAC Bulletin 79-2 dated 11/20/79 was applicable to prior calculations, or whether there was a similar requirement within procedures applicable to the Perry project for design verification prior to design and procurement of the respective system.
(3) In the area of Document Control, it could not be determined that manuals were adequately controlled.
For example, the following manuals were identified as either missing pro-cedures or not current:
(a) QA Procedures Manual number 77, issued to an employee who has since left the company, was missing procedures QAP2.1, 2.2, 4.1, 4.2, and 4.3.
The manual was marked "For Use by External Auditor."
(b) QAPM number 215 was missing two (2) memos.
(c) Structural Engineering Department Manual was unnumbered and unassigned.
(4) Further review will be made to assure that all applicable ANSI daughter standard requirements were imposed on BWC for Perry pumps (in SP-506-4549-00, SP-702-4549-00, etal.).
(5) During the inspection of QA Records, it was noted that one calculation was not dual stored; specifically RWCV G-33-1 was not in the Engineering file.
This appeared to be an isolated instance, and was corrected during the course of'the inspection.
d.
Additional Comments Scope of QA program implementation for G/C Corporate activities and for the Perry project for the criteria examined was as follows:
e
~
21 (1) Procurement Document Control: This is an interface activity on Perry with CEI. Technical attachments, selection of bidders (subject to CEI review), bid evaluation, etc. are performed by G/C; the actual Purchase Order is awarded by CEI. G/C scope' activities appeared to be controlled and to meet requirements.
(2)
Instructions, Procedures and Drawings:
This criterion is within the G/C scope.
G/C activities appear to be con-trolled and to meet requirements except as noted.
(3) Document Control: This criterion is within the G/C scope.
G/C activities appear to meet requirements except as noted in the unresolved item identified above.
(4) Control of Purchased Material, Equipment and Services:
'This criterion is part of the G/C scope for the Perry pro-ject by virtue of a separate contract with the licensee for G/C to perform vendor surveillance.
These activities appear acceptable.
(5)
Identification and Control of Mate' rial, Parts and Components:
This criterion is imposed on vendors and monitored during surveillance activities. Activities appear acceptable.
r-(6) Control of Special Processes: This criterion is invoked on vendors in attachments to procurement documents, and is monitored by G/C in two ways:
(a) Review and approval of vendor welding, NDE and other special process procedures.
(b) Vendor surveillance activities Both areas appear controlled and acceptable.
(7) Inspection:
Hold and witness points are identified to vendors, and G/C inspection is performed.
G/C inspectors are certified to ANSI N45.2.6 requirements to NDE levels as applicable. Also, this criterion is imposed on vendors.
(8) Test Control: This is imposed on vendors as required; no instance was observed of testing being within G/C scope, but it is not precluded. Vendor test procedures such as hydrotest are reviewed and approved by G/C.
c
22 (9)L Control of Measuring and Test Equipment: This is' imposed on vendors and reviewed during vendor audits and vendor surveillance.
(10), Handling, Storage and Shipping: This criteria _is imposed on vendors. One~ item related to the BWC procurement was identified-(See paragraph C.3.c. above.)
(11)- Inspection,_ Test and Operating Status:
Primarily a site function and out of G/C scope currently, although not precluded.
(12) Nonconforming Materials, Parts and Components: This criterion is imposed on vendors and monitored in two ways by G/C:
(a) Vendor nonconformances dispositioned "use-as-is" or
" repair" which violate specification requirements are reviewed and approved by G/C.
(b) Audits of vendors and vendor surveillance activities monitor nonconformances.
(13) Corrective. Action: This criterion falls within G/C scope of activities.
(14) -QA Records: This criterion falls within G/C scope of activities and also involves. interface with the licensee.
One follow-up item was identified in this area and one prior _ deviation remains open.
(15) Audits: This criterion falls within G/C scope of activities and one deviation was identified.
e.
Conclusion Other than the identified deviation, and follow-up items, the
~
~G/C QA program: appeared to be effective and controlled and
-had_been' translated into a viable QA program; the necessary pro-cedures and practices are defined and-in place; the program is being implemented wi'.nin the defined scope on the-Perry project and for Corporate QA activities; and the implemented. QA program appears' capable of sisuring a quality product.
s
23 DETAILS SECTION III (Prepared by S. D. Ebneter)
A.
Persons Contacted W. A. Anderson, Management Consultant
- N._R. Barker, General Manageg, Quality Assurance Division
- J. C. Daily, Senior QA Program Manager
- R. C. Holswarth, Corporate QA Program Manager
- A. G. Marino, Manager Quality Engineering
- R. M. Rogers, Project Manager, TMI-1 Continuing Services J. Urbaniak, Audit Coordinator-
- Denotes those present at the exit interview.
l B.
Initial QA Program Inspection 1.
Objectives The objectives of this area of the inspection were those identified in Details section I.D.1 except that the scope of this inspection was limited to Criterion II (Quality Assurance Program) of Appendix B to 10 CFR 50 as applicable to the Three Mile Island No. 1 Continuing Services (Restart) Project.
2.
Method of Accomplishment Review of the following documents to determine if the objectives l
identified above were accomplished.
The documents identified in the following I.C.2, I.C.2.a.,
a.
I.C.2.b., and I.C.2.c.
b.
The charter of the Quality Assurance Policy Committee.
'The charter of the Quality Assurance Advisory Committee, c.
d.
Management audit report entitled " Management Review of Gilbert /
Commonwealth Quality Assurance Program" dated November 19, 1979.
Minutes of the Quality Assurance Policy Committee meeting number e.
40 dated November 19, 1979.
N u
24 3.
Findings a.
Deviation from Commitment See' Notice of Deviation, Item A.
b.
Unresolved Items or Follow-up Items None identified.
j 9
s.
r 25 DETAILS SECTION IV (Prepared by L. W. Gage)
A.
Persons Contacted
- J. C. Daly, TMI-I Continuing Services QA Program Manager R. Hottensteui, Instrument Engineer
- R. Rogers, Project Manager, TMI-1 Continuing Services (Restart) Program
- W. Sailer, Manager of Projects C. Stremeke, Project Engineer E. Toll, I&C Engineering Department Manager J. Urbaniak, Audit Coordinator
- Denotes those present at the exit interview.
B.
Initial QA i ogram Inspection The scope of'this area of the inspection was limited to Criterion III (Design Control) and XVIII (Audits) of Appendix B to 10 CFR 50 as applicable to'the Three Mile Island No. 1 Continuing Services (Pescart) Project.
1.
Design Change Control a.
Objective The objective of this area of inspection was to verify that' the TMI-1 Restart Project quality assurance program addressed safety-related design modifications.
b.
Method of Accomplishment The inspector' reviewed selected Engineering Change Memos (ECMs) that had been prepared by G/C for the TMI-1 restart program.
(These ECMs_are listed in paragraph B.3.b. of this section.) ECMs that are incorporated into the TMI-1 QA Program are identified by a check in a box marked "GPUSC QA safety related" on the sign-off page. This identification is made by GPUSC~(the licensee) during their review / concurrence of the G/C ECM.
The inspector, in reviewing ECM 017, Revision 0 (an ECM associated with TMI-I restart task No. LM-4, re. low-level alarming of the borated water storage tank) noted that the "GPUSC QA safety related" box was not checked, although the ECM had-been released for construction.
)
-.1 26 i
The ECM, however, contained a purchase requisition for a Barton, Model 288 indicating switch which required submission of seismic qualification data and a box-checked "QC required."
c.
Deviations or Unresolved-Items None.
d.
Follow-up Item The inconsistency between the purchase-requisition quality requirements ECM 017, and the failure to designate the ECM as "GPUSC QA safety related" on the ECM sign-off page, was identified by the inspector as a follow-up item.
i 2.
Design Input a.
Objective The objective of this area of the inspection-was to determine if TMI-1 design modifications, being prepared for the TMI-1 restart program, incorporated the applicable design input i
l requirements.
l b.
Method of Accomplishment The inspector reviewed selected ECMs that had been prepared by G/C for the TMI-1 restart program and the corresponding design verification records.
(These ECMs are listed in paragraph B.3.b. of this section.
l The design verification records indicate the applicable codes, standards, etc. considered by the design engineer.
l Appendix I to the TMI-1 Project Management Manual, revision l
dated October 23, 1978, in paragraph 2.04 titled " Design Verification Bases," lists documents to be considered for design verification.
Among those examples are listed FSAR commitments.
The TMI-1 Restart Report was not included in the listing.
i The inspector asked the TMI-1 Project Office if the Restart Report was considered a design-input document. The Project Office stated that the Restart Report was not considered a design-input requirement.
9 C_
f
.:. e. 4 27 c.
Deviations and Unresolved Items None.
d.
Follow-up Item The exclusion of the TMI-I Restart Report from the list of design verification bases in the Appendix I to the PMM was identified by the inspector and will be further inspected during a future inspection.
3.
Design Verification a.
Objectives The objective of this area of inspection was to verify that design verification was being conducted in accordance with established procedures.
b.
Method of Accomplishment The inspector reviewed selected design verification records associated with issued Engineering Change Memos (ECMs).
The ECMs included:
- 070, Revision 0,-dated February 7, 1980
- 076, Revision 0, dated February 25, 1980
- 021, Revision 0, dated June 28, 1979
- 021, Revision 1, dated August 13, 1979
- 021, Revision 2, dated September 24, 1979
- 017, Revision 0, issued July 20,-1979
- 017,. Revision 2, issued October 18, 1979.
The inspector then reviewed the Project-(office) Engineer's reviews of design verification records.
G/C Engineering Procedure DCP 2.05 (Revision 2, dated June 19, 1978), in paragraph 3.2.11,' states:
"The. Project Engineer shall review Design Verification Records at least quarterly to assure that verifications based upon unresolved assumptions or preliminary data that require subsequent verificatica are pursued to confirmation or revision."
~The inspector reviewed records of instrumentation and control,
-mechanical, and' structural design verifications records.
The
28 last review of structural design verifications was conducted on January 30, 1979, although structural design verifications were performed subsequent to that date.
The failure of GAI to conduct reviews of design verification records, at least quarterly in the area of structural design, was identified by the inspector as a deviation.
c.
Deviations from' Commitment
~See Notice of Deviation, Item B.S.
d.
Unresolved Items None.
4.
The Audit Program for the TMI-1 Restart Project a.
Objectives The objectives of this area of inspection were to verify that an audit program has been established and that it also is being implemented, in accordance with the require-ments of the G/C Quality Assurance Program and 10 CFR 50, Appendix B, criterion XVIII.
b.
Method of Accomplishment The inspector interviewed the G/C Audit Coordinator, who provided a listing of audits scheduled for the year 1980, and a history of audits for the year 1979.
The inspector determined that the Audit Coordinator ccaducted special audits of'a program or of a problem-related nature when such requests for special audits were made. One special audit had been conducted on the TMI No. 1 Continuing Services Project. This was audit no. SA-79-1, conducted August 1-3, IS79, and transmitted to the TMI No.1 Continuing Services Project Manager on August 10, 1979 The audit report stated:
"Several areas of concern, which were not considered violations... were identified...
- 1. It is not clear whether the PMM-(the Project Management Manual)... (is) intended to apply to items other than " Safety-related,"...
There may also be some inconsistency between Met-Ed's and GAI's interpretation of which items the PMM applies to.
Met-Ed's Procedure GP-1008 is not available'to personnel for this
- purpose.
l r
i
7-3 29 The' inspector asked the GAI Project Manager if a " Safety-related"_ listing of equipment had been generated to replace Procedure GP-1008, a listing that was agreed to by both G/C and the licensee which met the NRC requirements.for TMI-1.
The response was that such a listing had not yet been generated.
The inspector asked the Audit Coordinator if audit follow-up-of the identified areas of concern could be documented.
The response was that audit follow-up'could not be d'o'cumented.
The inspector referred to the GAI Topical Report GAI-TR-106 (Rev. 2A, dated February,1980), paragraph 17.16.2, which states:
"The Gilbert / Commonwealth Quality Assurance Program requires that measures be established and implemented to assure that conditions adverse to quality are promptly.
. corrected."
and paragraph 17.18.4, which states:
"The audit system provides for... follow-up to assure implementation of corrective action."
The inspector also referred to the GAI Nuclear Quality Assurance F.anual (Revision 1, dated September 29, 1978),
which states, in paragraph 16.3.2: "(The) Quality Assurance Division (sn311)... identify conditions requiring corrective action, request corrective measures from respons-ible organizations, and verify implementation and paragraph 18.2, which states: " Procedures shall be established to implement
.. Necessary management action to correct any deficiencies revealed by the' audit.
. (and to reaudit) deficient areas on a time basis to verify implementation of corrective actions.
Criterion V of Appendix B to 10 CFR 50 states:
" Activities
-affecting quality shall be prescribed by documented instruc-tions.
. and shall be accomplished in accordance with these instructions."
The failure of G/C to effect corrective action to resolve defici~ency No. 1, identified in audit SA-79-1, performed on August 1-3, 1979, was identified by the inspector as a deviation.
c.
Deviation from Commitment See Notice of Deviation, Item C.S.
i
.e 30 d.
Unresolved Items None.
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