ML19345C732
| ML19345C732 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345C711 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8012080265 | |
| Download: ML19345C732 (5) | |
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4 Gilbert / Commonwealth Docket No. 99900525/80-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on July 21-25, 1980, it appears that certain of your activities were not conducted in full compliance with your commitments as indicated below:
A.
G/C (Gilbert / Commonwealth) letters of response to NRC inspection reports describe corrective actions and preventive measures and commit to comple-tion of the actions in accordance with prescribed schedules.
i Contrary to the above, G/C did not complete the corrective and preventive l
actions in accordance with their committed schedule.
i The following are examples of this deviation:
1 1.
G/C letter dated April 29, 1980, responding to NRC Report 79-04, states in part that "... the (V.C. Summers) Project Management Manual will be revised to reflect the procedural requirements (to assure that a listing of the identification number of all druwings applicable to a purchase order for safety related items will be maintained with the procurement records for the purchase order).
This effort will be completed by June 30, 1980.
Contrary to the above, the V. C, Summers Project Management Manual was not revised to reflect the' procedural requirements by June 30, 1980.
2.
G/C letter dated May 20, 1980,. responding to NRC Report 80-01, states in part that "... The (Perry Project electrical discipline safety related) drawings have been revised, where required, to indicate completion of the design verification.
Contrary to the above, several of the Perry Project electrical discipline drawings that were identified to G/C personnel during inspection 80-01 as not being marked to indicate that.the design review had been completed, were not revised, as required, to indicate completion of the design verification prior to their issue.
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 circuustances and shall.be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance cri-teria for determining that important activities have been satisfactorily accomplished." ' Deviations from these requirements are as follows:
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1 B.
Section 2.0 (Quality Assurance Program) of the Gilbert / Commonwealth NQAM (Nuclear Quality Assurance Manual) states in part that, "The Gilbert / Common-wealth Nuclear Quality Assurance Program satisfies the requirements of 10CFR50, Appendix B.
(and)
. implementation of this program is mandatory for all Gilbert / Commonwealth organizitions involved in the i
design, procurement, construction, or testi. af nuclear power plant (safety related) structures, systems and compenents.
l Specific requirements delineated in Section 2 the NQAM and deviations therefrom are as follows:
1.
"A project Quality Assurance Plan, prepared under direction l
of the Quality Assurance Program Manager, is integrated in the Pro-ject Management Manual or is issued as a separate document."
Contrary to the above, an approved Project Quality Assurance Plan was not integrated in the TMI-1 Restart Project Management Manual prior to being identified as an unresolved item in NRC Report 80-01 nor was it issued as a separate document.
2.
"Any variation (in a Project Management Manual) from the requirements delineated in the Nuclear Quality Assurance Manual or the implementing procedures shall be approved by the Division General Manager, who approved the procedures, and the Quality Assurance Division General l
Manager. This approval is granted after review by the appropriate subcommittee of the Quality Assurance Policy Committee for intent, impact, and source."
Contrary to the above, a variation (negation) from the requirement for identifying drawings depicting safety related items as " Nuclear Safety Related" contained in implementing procedure DCP:1.30 was taken in paragraph 2:07.1 of Appendix E to the TMI-1 Continuing Services Project Management Manual uithout approval of the Quality Assurance Policy Committee and without obtaining the required approvals.
Items B.1 and B.2 were identified as an unresolved item and as a follow-up item respectively in NRC report 80-01.
Corrective action was taken by G/C prior to this inspection and need not be addressed in the G/C response, however the generic considerations and appropriate preventive measures must be evaluated by G/C and delineated in the response to this inspection.
C.
Paragraph 5.3.1 of Section 5.0 (Instructions, Procedures, and Drawings) of the G/C NQAM states in part that all discussions will,
. a.
Prescribe divisional activities affecting quality in instructions, procedures, or other types of documents appropriate to the circumstances and perform such activities in accordance with these documents
. c.
Delineate the sequence of actions to be accomplished in preparing, reviewing, approving, and controlling instructions, procedures, and drawings.
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L The Project Management Manual (PMM) for the.TMI-1 Continuing Services Pro-ject states that ".
. engineering design is accomplished in accordance
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with the Design Control Procedures... as complemented by this PMM.
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Paragraph 5:05 of the PMM states in part that,
. interim drawing (s)
(which is the designation for a G/C design output drawing) may be either j
a new GAI drawing or a reproduction of a GAI original master drawing showing the proposed changes.
. each (such) drawing.
is assigned a (GAI j
identification) number (or carries the same basic number as the original
-GAI drawing)... so as to indicate the applicable work order, drawing i
number,-(revision, etc).
. in accordance with DCP:1.30, GAI Draw-l' ings.
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Paragraph 5:11 of the PMM states in part that,
. control of (safety j.
related) manufactures' prints (vendor drawings).
(is) in accordance i-with Design Control Procedure 3:05, ' Vendor Drawings'
. which in turn 4
requires that such drawings be identified in accordance with the CISM i
(Comprehensive Identification System Manual)."
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Section 2.14 of the CISM defines the vendor drawing identification j
system, the drawing identification number coding (CISID), and contains I
i the requirement that, ".
. as in the case of G/C created drawings, the CISID (Coding) will be preceeded by the project work order num-ber.
Contrary to the above,' certain vendor drawings for safety related i
equipment being used by the Instrument and Control discipline of the TMI-1 Restart Task of the Continuing Services Project did not exhibit 1
the requisite GAI identification number, CISID Coding, and project work order number.
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D.
The TMI-1 PMM imposes project unique additional requirements for design
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verification and endorses DCP:1.25 (fluid System Diagrams) whose purpose is ".
. to control (the) identification, preparation, review, verification, approval, issue,. revision, and retention of Fluid System Diagrams Paragraph 3.2.8 of DCP:1.25 states in part that, after the drawing is prepared and reviewed, "the Originator notifies the Project Engineer that the Fluid System Diagram is ready for verification in accordance with 2
j procedure (DCP) 2.05 " Design Verification.
Contrary to. the above, fluid system diagrams 4692-C-302-661 Revision 7, i
4 4692-C-302-231 Revision 3, 4692-C-302-671 Revision 7, 4692-C-302-692
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Revision 0, and 4692-C-302-640 Revision 0, were not design verified in i
accordance with procedure DCP:2.05-(Design Verification).
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4 Specific examples of this deviation are as follows:
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1.
Contrary to Paragraph 2.1 of DCP:2.05, fluid system diagrams generated by the mechanical discipline of the TMI-1 Restart Task were not design verified in accordance with DCP:2.05 prior to their release for con-struction.
2.
Contrary to Paragraph 3.1.9.3 of DCP:2.05, the Project Engineer did not enter the verification documents for fluid systems diagrams into the -
record in accordance with Procedure DCP:3.15 as required.
3.
Contrary to Paragraph 5:10.3 of the PMM for the TMI-1 Continuing Services Project,- the GPUNC Design Review General Checklist was not completed by-the GAI verifier of certain fluid system diagrams (nor was it forwarded to the Project office for distribution) as required.
4 E.
Paragraph 3.3.of the NQAM requires that the " Power Engineering Divisions.
(h) Identify and control design interfaces.
Contrary to the'above, design interfaces were not identified and controlled on fluid system diagrams 4692-C-302-661, 4692-C-302-231, 4692-C-302-640, 4692-C-302-671 and 4692-C-302-692, and piping drawings 4692-E-304-666 and 4692-E-304-736 as required by the NQAM.
Specific examples of'this deviation are as follows:
1.
Contrary.to paragraph 3.2.9.2. of DCP:1.30 (which is endorsed by the PMM of the TMI-1 Continuing Services Project), the Originator (the mechanical discipline) did not initiate revisions to fluid system diagram 4692-C-302-611, instead the instrumentation and control discipline of the TMI-1 Restart Task' initiated the changes.
2.
Contrary to Paragraph 3.2.5.7 of DCP:1.30, the interfacing organization (the instrumentation and control discipline of the TMI-1 Restart Task) did not document their review of the identified drawings, and revisions thereto that were originated by the mechanical discipline, to assure that the drawing properly presents their interface comments an indi-cated by their signing the drawing.
F.
Section 12.9' Paragraph VI.D.1.b of the Gilbert Associates Quality Assurance
- Manual for the V. C. Summers Nuclear. Station Unit 1 Project states-in part:
"The Documentation and Procedures. Section of the Quality Assurance Divi-sion shall be' responsible for assignment and accountability of the Correc-tive Action Request serial numbers.
. In turn the Project Manager main-tains a log which as a minimum shall note:
"(1) CAR no.
(2) Assigned to or initiator 8
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(3) Client (4) Date issued (5) Affected organization (6) Date resolved" Contrary to the above, a Project Manager's CAR log had not been maintained (updated) by the Quality Assurance Project Manager for approxiaately tha past 4 years.
G.
Section 9.9.1.1 of the Gilbert Associates Project Management Manual for the V. C. Summers Nuclear Station Utit 1 project states in part, " Deviation Change Requests (D/CR) are used to. request approval of a deviation or a non-conformance of material,. parts, or ccaponents to specified terms (conditions)
Copies of all correspondence on safety related Deviation / Change Requests are sent to GAI/QA for review.
If GAI/QA has no comments, the GAI/QA program manager or his desigaee signs the D/CR form in the lower right corner."
Contrary to the above, out of approximately 30 Deviation / Change Requests initiated by the Reliance Electric Company under Contract Purchase Order SN-10174-SR, about 50% of the D/CR's were without GAI/QA comments, and were not signed by the GAI/QA program manager or his designee.
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