ML19345C735
| ML19345C735 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1980 |
| From: | Breaux D, Fox D, Gage L, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345C711 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8012080268 | |
| Download: ML19345C735 (24) | |
Text
..
O U. C. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900525/80-02 Program No. 51200
' Company:
Gilbert / Commonwealth P. O. Box 1498 Reading, Pennsylvania 19603 Inspection Conducted:
July 21-25, 1980 m
u Inspectors:
g 2/2 F/ro
~
D. F. Fox, Inspector Date Program Evaluation Section Vendor. Inspection Branch h
R 7
17 7#
D. G. Bredux, Ihspettor T Date Program Evaluation Sectior Vendor Inspection Branch M
Y" k0 L. W.Mge, Reactor (Inipector Date Engineerir,g Support Section 2 Reactor Cocatruction and Engineering Support Branch Region I, I & E
~~[
Approved by:
C. J. Ihrfe, Chief Date Program Evaluation Section Vendor Inspection Branch Summary Inspection on July 21-25, 1980 (99900525/80-02)
Areas Inspected:
Implementation of Title 10 CFR 50 Appendix B and Topical Report GAI-TR-106 -in the areas of design interfaces, procurement document control, follow-up on regional requests, and action on previous inspection findings. The inspection involved eighty-four (84) inspector hours on site by three (3) USNRC_ inspectors.
8012080 2C7
2 i
Results:
In the four (4) areas inspected, seven (7) deviations from commitment were identified in three (3) of the areas.
One unresolved item was identified.
Deviations: Actions on previous Inspection Findings:
Corrective action committed in a Gilbert / Commonwealth (G/C) response to previous deviations had not been completed as scheduled-(See Notice of Deviation, Items A.1 and A.2);
i-an approved QA Program Plan or Manual was not in place for the TMI-I Continuing Services Project -(See Notice of Deviation, Items' B.1 and B.2). ~ Design Interfaces:
Vendor drawings ~were not identified with a C/C number upon receipt and were subse-i quently revised.and issued without a G/C identification number.(See Notice of Deviation, Item C.); Drawings were issued for construction prior to design verification _ (See Notice of Deviation, Item D.).
Drawings were revised and issued by other than_the originating organization and without interface review-(See Notice of Deviation, Item E.).
Procurement Document Control-A Corrective Action Request log was not maintained (See Notice of Deviation, Item F); Devia-tion Change Requests were issued without a Quality Assurance review signature (See Notice of Deviation, Item G).
Unresolved Item: The existance of the requisite list of safety related struc-tures, systems and c aponents that come under the TMI-1 Continuing Services -
l (Restart) Project could not be verified.
(See DetailsSection I, peragraph j
C.3.b.).
d i
T 4
6 i
1 4
..,,... ~
3 DETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contacted
- N. R. Barker, General Manager, Quality Assurance Division D. J. Bode, Engineering Specialist, V. C. Summer Project J. H. Brendlen, Project Engineer, TMI-1 Continuing Services Project
- R. F. Ely, Staff Engineer, TMI-1 Continuing Services Project R. :1. Gifford, Assistant Manager, Structural Engineering, Perry Project H. N. Goldstein, Project Engineer, TMI-1 Continuing Services Project
- J. R. Helwig, Assistant Project Manager, V. C. Summer Project
- R. C. Holzwarth, Manager,. Corporate QA Programs
- N. C. Kazanas, Manager, Quality Assurance, GPUNC G. M. Kowal, Manager, Applied Engineering Analysis
- W. E. Meek, Mana'ger, Engineering Department
- J. M. Pratt, QA Program Manager, TMI-1 Continuing Services Project
- F. R. Ricci, Manager, Design Control
- R. M. Rogers, Project Manager, TMI-1 Continuing Services Project P. J. Shipper, Project Engineer, TMI-1 Continuing Services Project
- J. G. Shollenberger, Project Engineer, TMI-1 Continuing Services Project A. F. Smith, President and Chief Executive Officer J. M. Smith, Project Electrical Engineer, Perry Project W. A. Steidle, Supervising Engineer,' TMI-1 Continuing Services Project C. C. Strempke, Project I&C Engineer, TMI-2 Continuing Services Project D. P. White, Manager, Mechanical - Nuclear Department
- H. E. Yocum, Project Manager, V. C. Summer Project
- Denotes those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) 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.
The inspector verified the corrective action described in the G/C letters of response dated June 12, 1979, and March 27, 1980, ie, copies of Engineering QA records have been forwarded to the records retention center.
The transfer of QA Division records, generic considerations and committed preventive measures were previously w--r
+- -
4 4
verified and documented in Nhc inspection reports 79-04 and 80-01.
2.
(Closed) Deviation (Report 79-04): A purchase order for a nuclear safety related item did not contain, nor reference, all of the technical requirements fer the item, i.e. the design orawing numbers for safety related pipe rupture restraints were not included nor referenced in the purchasing documents.
The inspector verified the corrective action described in the G/C letters of response dated January 28, 1980, and April 29, 1980, ie, a listing of the identification numbers of all drawings applicable to the purchase order was inserted in the procurement records for the purchase otJer. However, the preventive measures were not completed as committed. This constitutes a deviation from commitment.
See Notice of Deviation, item A.2.
3.
(open) Deviation (Report 80-01, Deviation A).
The NQAM does not specifically reflect the commitment to perform an annual management audit to evaluate the QA Program nor does an implementing procedure exist.
The inspector verified that annual management audits of the QA Program were performed and documented.
The corrective action and preventive measures described in the G/C letters of response dated May 20, 1980 and June 26, 1980, are committed for completion by August 30, 1980, and although underway, were not completed as of this inspection.
See Sections III.B.1 for additional details..
4.
(0 pen) Deviation (Report 80-01, Deviation B.1).
The checker did not initial nor date issued Perry Project System flow diagrams.
The inspector verified the preventive measures described in the G/C letter of response dated May 20, 1980, ie, an engineering management memo was issued on April 3,1980, which strongly emphasized the importance of following procedures.
The corrective action described in the G/C letter is committed for completion by October.1, 1980, and although underway, was not com-pleted as of this inspection.
5.
(0 pen) Deviation (Report 80-01, Deviation B.2).
Cover pages of specifications for TMI-1 Restart Project safety related items were not imprinted with the phrase " SAFETY RELATED" nor were they printed on salmon colored paper.
The preventive measures described in the G/C letters of response dated May 20, 1980, and June 26, 1980, are committed for completion by August 30, 1980.
The G/C response to the NRC request for additional
5 information with respect to corrective action is.due August 15, 1980.
Although both the corrective action and preventive measures are underway,.and were discussed in detail during the inspection, neither were completed as of this inspection.
6.
(0 pen) Deviation (Report 80-01, Deviation B.3) Drawings depicting
. safety class items for the TMI-1 Restart Project did not exhibit the requisite " Nuclear Safety Related" notice.
The preventive measures described in the G/C letters of response dated May 20, 1980, and June 26, 1980, are committed for completion e
by August 30, 1980. The G/C response to the NRC request for addi-tional information with respect to corrective action is due August 15, 1980. Although both the corrective action and preventing'neasures are underway, and were discussed in detail during the inspection, neither were completed as of this inspection.
7.
(Closed) Deviation (Report 80-01, Deviation B.4) Drawings depicting.
safety class items for the Perry Project did not exhibit the required i
documentation that the design review of the drawing was completed prior to their issue.
The inspector verified the preventive measures descrioed in the G/C letter of response dated May 20, 1980, ie, an engineering management memo was issued on April 8, 1980, which strongly emphasized the importance of following procedures. However, the corrective action described in the G/C letter was'not completed as committed. This constitutes a deviation from commitment.
See Notice of Deviation item A.2.
8.
(Closed)' Deviation (Report 80-01, Deviation B.5) See Section 4
III.B.2 for details.
4 9.
(0 pen) Deviation (Report 80-01, Deviation C.1) Responses to audit SA 79-1 had not been received nor has corrective action been com-pleted as delineated in audit IA 79-1.
'The inspector verified the preventive measures described in G/C letter of response dated May 20, 1980, ie, the issue, and review by the QA Policy and QA Advisory Committees, of a monthly report on the status of responses, and completion of corrective actions, for-internal audits findings..The corrective action described in G/C letters of response dated May 20, 1980, and June 26, 1980 is com-mitted for completion by July 31, 1980, and although underway, was
]
not completed-as of-this inspection.
^
- +. -
.----c
~
l 5
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) t 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 as 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 (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 approximately the past 4 years.
G.
Section 9.9.1.1 of the Gilbert Associates Project Management Manual for the V. C. Summers Nuclear Station Unit 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 components 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 designee 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.
f
F 6
10.
(Closed) Deviation (Report 30-01, Deviation C.2) Audits performed tu 1979 did not cover indoctrination and training of personnel and con-trol of internal.and external design interfaces.
The inspector verified the corrective action and preventive measures described in the G/C letter of response dated May 20,.1980, ie, a QA review was performed to determine areas not previously covered j
and a revised internal audit schedule was issued to adequately l
cover those areas, and the first monthly internal audit status report l
was issued as committed.
i 11.
(Closed) Deviation (Report 80-01, Deviation C.3) Follow-up action was not scheduled to correspond with committed implementation dates for corrective action with respect to internal audit findings.
The inspector verified the corrective action and preventive measures described in the G/C letter of response dated May 20, 1980, ie, an i
internal audit was performed to determine status of current audit l
findings and items found open were closed or identified for close follow by the InternL1 Audit Coordinator, and the first monthly status report of internal audits was issued as committed.
12.
(Closed) Deviation (Report 80-01, Deviation C.4) Formal overdue audit response notices were not transmitted for audit findings with overdue responses.
The inspector verified the corrective action and preventive measures described in the G/C letters of response dated May 20, 1980, and June :26,1980, ie, formal overdue notices were transmitted to those organizations whose responses were overdue and responses were received from them. Furthermore, an Internal Audit Coordinator was appointed to provide assurance against repeated violations, and, the first monthly internal audit status report was issued as committed.
13.
(Closed) Deviation (Report 80-01, Deviation C.5) See Section III.B.3 for details.
14.
(Closed) Unresolved Item (Report 80-01). The Quality Assurance Program for the TMI-1 Continuing Services (Restart) Project required by the G/C NQAM and the DCP. Manual was not defined in the' Project i
Management Manual nor in a Project Quality Assurance Plan as required.
This item was elevated to a deviation from commitment.
See Notice of Deviation, item B.1 and additional details in Section III.B.4.
l 15.
(Closed) Follow-up Item (Report 80-01, I.C.3.b.(1)).
The Safety Classification of Itens are not permanently identified on the " Design
-Input" form as required by DCP:1.05.
7 The inspector verified that the " Design Input Form" (Appendix C to DCP:1.05) has been revised to include provisions for entering and recording the safety classification of the structure, system or component as required.
16.
(Closed) Follow-up Item (Report 80-01, paragraph I.C.3.b.(2)).
The basis for the G/C Topical Report endorsing the 1977 issues of certain ANSI standards, in tintrast to the 1971 issues that are endorsed by NQAM, could not be determined during this inspec-tion.
The inspector verified that the NQAM is being revised to reflect the commitment to the ANSI standards delineated in the recently revised (February 1980) Topical Report GAI-TR-106, Revision 2A.
The revision of the NQAM is scheduled for completion by August 30, 1980.
17.
(Closed) Follow-up Item (Report 80-01, paragraph I.D.3.c(1)).
The relative frequency of occurance of drawings with duplicate drawing or revision numbers, and drawings with inaccurate refer-ences, will be evaluated during a future inspection.
The inspector verified that the previously identified drawing with a duplicate number had been voided and that the drawings with duplicate revision numbers and inaccurate references were corrected.
These appeared to be isolated events.
No recurrance was observed on the thirty one (31) drawings examined during this inspection.
18.
(Closed) Follow-up Item (Report 80-01, paragraph I.D.3.c.(2)).
The relative frequency of calculations that did not reference the source of design inputs, and calculations that were not signed as being Design Reviewed / Verified, will be evaluated in a future inspection.
The inspector verified that the previously identified calculations that did not reference the source of design inputs, or that were not signed as being Design Reviewed / Verified, had been corrected.
This appeared to be an isolated situation related to one originator who was appraised of the ommissions and corrected the deficiencies.
No recurrance was observed in the six (6) calculations examined during this inspection.
19.
(Closed) Follow-up Items (Report 80-01, paragraph I.D.3.c.(3)).
It could not be determined during this inspection that all devi.a tions (exceptions or variances) from NQAM requiremer.*s
8 or approved Divisional Procedures that were taken in the individual Project Management Manuals were approved in advance of their implementation by both the Division General Manager and the Quality Assurance Division General Manager as required by procedures.
This item was elevated to a deviation from commitment.
See Notice of Deviation, item B.2.
20.
(Closed) Follow-up Item (Report 80-01, paragraph II.B.3.b.(1)).
Neither the NQAM, nor the QAPM appears to require a documented yearly evaluation of vendors with active contracts to determine the need for an audit, or to require that a minimum G/C QA audit fre-quency of three years be imposed for active vendors.
The inspector verified that the NQAM is being revised to reflect the above requirements.
The revision of the NQAM is scheduled for completion by August 30, 1980.
21.
(Closed) Follow-up Item (Report 80-01, paragraph II.B.3.b.(2)).
All requirements which appear in the Topical Report are not reflected in the NQAM, and certain ones do aot appear in subtier manuals. Hence, the NQAM appears to be less definitive and less restrictive than the Topical Report in certain areas.
The inspector verified that all of the requirements in the recently revised G/C Topical Report (February 1980) that were more restric-tive than those contained in the NQAM were identified in a May 24, 1980 memorandum to R. C. Holsworth and that the NQAM is being revised in accordance with the memorandum to reflect the more restrictive requirements contained in the Topical Report.
The revision of the NQAM is scheduled for completion by August 30, 1980.
22.
(Closed) Follow-up Item (Report 80-01, paragraph II.B.3.b(3)).
Regulatory Guide (R.G.) requirements in the NQAM appear to be different from, and less restrictive than, those in the Topical Report, for example, R.G. 1.54 which endorses ANSI N101.4, is committed to in the Topical Report, however it is not committed to in the NQAM.
The inspector verified that the NQAM is being revised to include all of the R.G. commitments contained in the recently revised Topical Report.
The revisions of the NQAM are scheduled or completion by August 30, 1980.
23.
(Closed) Follow-up Item (Report 80-01, paragraph II.C.3.(1)).
4 9
The Records Management Manual Procedure 3.4 allows checkout of boxes of QA records from the Record Storage Retention facility.
A review of the log of records checked out indicated their retention at other locations for long periods of time (2 years and.more) raises concern that ~
practice may negate the dual storage requirements.
The inspector verified that the Records Retentions Center has developed, and is using, a new records control form which requires that "all checked out QA Records be returned within one month in accordance with Records Management Procedures."
24.
(Closed) Follow-up Item (Report 80-01, paragraph II.C.3.c.(3)).
4 Certain calculations do not~ appear to have been reviewed and/or verified, although the system had been designed and procured.
The inspector verified that the previously identified calculations 3
that were not' reviewed and/or verified had been corrected. This appeared to be isolated to-calculations that were completed prior l
to the requirement being clearly defined in QAAC bulletin 79-2 dated i
11/20/79. No recurrance was observed in the six (6) recent calcu-lations examined during this inspection.
25.
(Closed) Follow-up Item (Report 80-01, paragraph II.C.3.c.(3)).
Manuals do not appear to be controlled. Manuals had procedures I
missing, memos missing and were. unnumbered or unassigned.
The inspector verified that the deficiencies in the identified manuals had been corrected. They appeared to isolated events.
The QA Document and Record Control Coordinator issued memoranda i
to all holders 'of NQAM and Quality Assurance Procedures Manuals requesting verification of the contents of their assigned manual (s).
Responses received indicate that all manuals are current or.are in the process of being updated in compliance with the aforesaid memos.
26.
(Open) Follow-up Item (Report 80-01, paragraph II.C.3.c.(4)).
It was L apparent that all applicable ANSI Daughter Standard Requirements were imposed on the PUMP manufacturer (BWC) for the Perry Project.
While-it appears that all applicable ANSI Daughter. Standard Require-ments may not have been imposed on BWC via SP-506-4549-00 or.
SP-702-4549-00, the inspector could not determine the specific commitments for imposing certain ANSI Daughter-Standards during.
this inspection.
9 The item will be further evaluated during a future inspection.
4
1 10 27.
(Closed) Follow-up Item (Report 80-01, paragraph II.C.3.c.(5)).
During inspection 80-01, it was noted that one calculation was not
-dual stored.' Specifically calculation number 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.
No recurrance of lack of duplicate storage of calculations was observed during inspection 80-02.
28.
(Closed) Follow-up Item (Report 80-01, paragraph IV.B.1.d)
See paragraph III.B.S. for details.
29.
(Closed)-Follow-up Item (Report 80-01, paragraph IV.B.2.d)
See paragraph III.B.6. for details.
C.
Design Interfaces 1.
Objectives The objectives of this inspection for control of both internal and external design interfaces were to determine that procedures have been established and implemented that:
Require that design organizations identify, in writing, their a.
interfaces for managing the flow of design information.
b.
Define and document the responsibilities of each organizational unit for the preparation, review, approval, distribution, and revision of documents involving design interfaces.
Establish methods-for systematically communicating needed c.
design information, including changes thereto, across design interfaces as work progresses.
d.
Require documentation of information transmitted between organizations which identified the status of the design information or documents incomplete items which require further evaluation, review or approval.
Require that design information transmitted orally or by other e.
informal means is promptly documented, and the documentation confirmed and controlled.
~f.
Identify the external organizations providing criteria, designs, specifications,-and technical direction.
g.
Identify the positions and titles of key personnel in the l
u
4 11 communication channel and their responsibilities for decision making, problem resolution, and providing and reviewing information.
l 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine if the above objectives were accomplished relative to control of design interfaces:
(1) Sections 17.2,17.3,17.15,17.16 and 17.17 of the GAI (Gilbert Associates Incorporated) Topical Report GAI-TR-106 (Gilbert / Commonwealth Quality Assurance Prograr for Nuclear Power Plants), Revision 2A, dated February 1980, to deter-mina the corporate QA programmatic commitments relative j
to control of internal and external design interfaces:
j (2) Sections 2.0, 3.0, 15.0, 16.0 and 17.0 of the G/C NQAM (Nuclear Quality Assurance Manual) and the following docu-ments to determine that the corporate commitments relative to control of internal and external design interfaces, eval-l uating and reporting significant safety deficiencies and management assessment of.the approved Quality Assurance Program.
Appendix E, Procedure for Processing of Reportable Events,
' Revision 0, dated December 15, 1977.
. (Management Review of the G/C Quality Assurance Program, Revision 0 dated June 22, 1980.)
to the. charter of the Quality Assurance Policy Com-mittee.
3 (3) Sections (policies and procedures) of the following Project Management Manuals and Project Quality Assurance Plans to determine that the corporate commitments relative to con-trol of internal and external design interfaces are reflected in the approved in place Quality Assurance Programs.for the individual nuclear projects consistent with the G/C scope of supply for the project:
TMI-1 Continuing Services Project Management Manual dated April 30, 1980.
GPUNC (General Public Utilities Nuclear Corporation).
Operational Quality Assurance Plan and TMI' Recovery I
f 4
g --
g-
.. ~..
.c 12 QA Plan - Unit II for Three Mile Island and applied to Units.1 and 2.
GPUNC TMI-1 Restart Report GPU Service Standard No. ES-011 (Classification of i
TMI-1 Systems and Components) dated July 17, 1979.
GPUNC Procedure 1000.001 (Three Mile Island Unit I Quality Assurance Systems List).
Perry Project Management Manual dated January 15, 1980.
Perry Project Quality Assurance Plan Dated January 15, 1980.
V. C. Summers Project Management Manaal dated November 19, 1979.
V. C. Summers Quality Assurance Plan dated July 5, 1978.
(4) G/C Procurement Control Procedure dated October 26,~1978, 1
to determine that the Quality Assurance Program commitments i
relative to control of internal and external design inter-i faces were accurately translated into procedures which control vendor initiated, as well as G/C initiated, design changes (including field changes), in procured structures, systems and components (5) The following sections of the GAI Design Control Procedures Manual dated February 14, 1980, to determine that the Quality Assurance Program commitments for the control of internal and external design interfaces were correctly translated j
into timely and effective design control procedures 1.10, Design Input j
1.15, Layout Design 1.25, Fluid System Diagrams 1.30, GAI Drawings 1.35, Piping Design 2.05,. Design Verification 2.10, Review and Approval 5.10, Project Management Manual (6) Sections 2.5, 2.13, 2.14 and 3.0-C of the comprehensive identification (GAI) systems manual, to determine the require-ments for identifying and formatting external design documents:
3 13 b.
Review of the following design documents to determine if the inplace procedures for control of internal and external design interfaces are being effectively implemented consistent with corporate and project commitments in those design related activities affecting quality (consistent with the scope of supply for the project).
Change Notice - One (1)
Calculations - Six (6)
Design Verification Records - Three (3)
Document Review Form - One (1)
~ Drawings - Thirty-one (31)
Drawing List - One (1)
Engineering Change Notices - Four (4)
Equipment Specifications - Four (4) l External (Vendor & NSSS) Documents - Eight (8)
External Document Comment Record - One (1)
Purchase Orders - Five (5)
Record Transfer Forms - One (1)
Reporting Requirement 10 CFR 21 Posters - Three (3)
Safety Related Equipment Lists - Seven (7)
System Design Descriptions - Three (3) 3.
Findings
.I a.
Deviations from Commitm at i
Three deviations from commitment were identified in this area of the inspection.
(See Notice of Deviation, Items C, D and E.)
{
b.
Unresolved Item
\\
The G/C NQAM states in Section 2.2 that the " Major elements of-the Quality Assurance Program provide for:
.. a.
Identifi-cation of structures, systems and components to which the Quality Assurance Program is applicable.
." Section 2.7 of the NQAM further requires that "A list of the structures, f
i
(
14 systems and components controlled by this Quality Assurance Program shall be prepared for each nuclear project to which this Manual applies.
." Section 3.2 additionally requires that " Procedures shall be established to implement the following requirements Identifying the structures, systems and components to a.
which the Quality Assurance Program is applicable.
A list of structures, systems and components controlled by the G/C Quality Assurance Program was prepared by G/C for the Perry Project and the V. C. Summer Project, however, the existance of an equivalent list (s) for the TMI-1 Restart Project could net be located and verified by the inspector during this inspection even though G/C personnel stated that such a list had been prepared.
This item will be further examined during a future inspection.
c.
Follow-up Items (1) The existing G/C procedure for processing of reportable events established (in 1977) o uniform method for reporting, processing, evaluating, and documenting reportable events.
However, the procedure may not permit an individual with a safety concern to ultimately express the concern to the responsible reporting officer of G/C.
This item will be further evaluated during a future inspection.
(2) Existing documents and procedures may not provide suffi-cient assurance that commitments contained in the NRC accepted TMI-1 Restart Report (which is equivalent to a Safety Analysis Report and thus identifies " inputs to the design") are identified, documented, and traceable to design output documents, such as System Specifications and Equipment Specifications.
This item will be further evaluated during a future inspection.
(3) The recently revised and approved Project Management Manual for the TMI-1 Continuing Services Project endorses t
the quality assurance program as defined in the G/C NQAM.
The NQAM is scheduled for revision by August 30, 1980.
It could not be established that the Regulatory Guides and ANSI Standards (including daughter standards) that will be l
endorsed by the revised NQAM are identical to, or more restrictive than in turn those committed to by GPU in the l
TMI-1 Restart Report and in turn by G/C in the TMI-1 Con-tinuing Services Project Management Manual.
-G l
15 This item will be further evaluated during a future inspection.
d.
Comments (1) With respect to Notice of Deviation item C, the practice of not identifying incoming vendor documents with a G/C identification number, modifying them to incorporate G/C-design data, and subsequently issuing them without applying-the G/C name or identification number to the document, appeared to be limited to the instrument and control dis-cipline of the TMI-1 Restart (tasks) Project.
Vendor draw-ings and specifications haadled by the mechanical discioline that were examined by the inspector were fully identified in accordance with DCP procedural requirements.
DCP:2.4 appears to permit Project Managers to define a non-standard drawing identification system that would be compatible ~with both G/C and client needs, however, no such identification system other than the prescribed " standard DCP system" was defined in the TMI-1 Continuing Services Project Manual.
Furthermore, even though all such deviations from DCP pro-cedural requirements by a project requires (per'G/C policy and the approved NQAM) approval of the Engineering and Quality Assurance Management prior to their implementation, no evidence of the requisite approval could be established during the inspection.
(2) Except as'noted in Section I.B and paragraphs a through c above, the inspector concluded that, with respect to control of design interfaces:
(1) the commitments contained in the Topical Report and/or the NQAM appear to be correctly trans-lated into a viable quality assurance program;-(2) the-defined quality assurance program for control of both' inter-nal and external design interfaces appears to be implemented within the contractual _ scope of work for the TMI-1 Continuing Services - (Restart Tasks) - Project.
D.
Exit Meeting An exit meeting was conducted with Gilbert / Commonwealth personnel at the conclusion of the inspection on July 25, 1980.
In addition to those individuals indicated by.an asterisk in the Details Sectious of this report, the meeting was attended by:
R. B. Archibald, Manager of Projects A. J. Bullock, Jr., Assistant Project Manager, Perry Project n
16 L. B. Eiland, Records Coordinator, Perry Project G. J. Gibson, Project Quality Coordinator, Perry Project S. K. Gross, Project Administrator, TMI-1 Project P. B. Guidikunst, Project Manager, Perry Project J. F. Hilbish, Manager, Licensing and Regulatory Support J. L. Kamphouse, Project Engineer, TMI-1 Project A. G. Maino, Manager, Quality Engineering P. C. Patton, Assistant Project Manager, Perry Project S. W. Reid, Manager, Building Services W. F. Sailer, Manager of Projects D. E. Sanford, Manager, Quality Systems T. A. Schlegel, Supervisory Engineer, Electrical Department F. W. Symons, Manager, Technical Support E. B. Toll, Manager, Instrumentation and Control S. J. Torma, Manager, Inspection / Material Services S. S. Urbaniak, Supervisor, QA Audit Program The inspector discussed the scope of the inspection and the details of the findings that were identified during the inspection. Management requested additional details of the findings and information on the specific intent and scope of 10 CFR Part 21 reporting requirements.
The inspector also discussed the form and content of Letters of Response to ifRC Inspection Reports and emphasized the importance of timeliness in their submission and in execution of the action committed therein.
The int,pector advised G/C management that any repetition of corrective ar. tion or preventive measures for previous inspection findings not being completed as committed could result in escalated enforcement action.
The management was requested to specifically identify what steps have been, or will be taken by G/C to prevent recurrance of this situation in their letter of response to this inspection report.
The management stated that they would comply with our request and take positive action to assure that G/C will timely define and complete a:.1 corrective actions, generic considerations and preventive measures far deviations from commitment identified in this and all future NRC Anspections.
l l
17 DETAILS SECTION II i
(Prepared by D. G. Breaux)
~A.
Persons Contacted C. D. Grim, Manager Expediting J. R. Helurg, Assist Project-Manager; V. C. Sunmer R. J. Hoffert,- Q. A. Project _ Manager; V. C. Summer -
R. C. -Holswarth, Corporate-QA Program Manager.
D. L. Mellinger, Proj ect T~.,1cian, V. C. Summer P. D. Osborne, Director Procurement Services W. S. Piper, Purchasing Agent C. M. Reynolds, Chief Expediting R. A. Wilkinson, Q. A. Document and Records Control d
B.
Procurement Document Control-i 1.
Objectives The objectives of this area of the inspection were to verify that procedures have-been prepared and are being implemented to assure that:
The organizations involved in the execution of procurement a.
activities have been identified and their responsibilities-delineated.
e b.
Procurement documents include the scope of work to be per-formed by the supplier, the technical requirements, material and equipment specifications, procedures and instructions, test and inspection requirements, acceptance requirements, and. identification, packaging, handling and shipping require-
)
ments.
j Procurement documents require that the supplier have a documented c.
quality assurance. program consistent with 10 CFR 50, Appendix B.
i d.
The supplier is required to incorporate appropriate quality assurance program requirements in sub-vendor procurement documents.
Procurement documents provide rights of access to the supplier's e.
plant facilities and records, identification of manufacturing hold points, witness points and notification.of the time of-these events, documentation requirements, records requirements, i
i-
~
18 and requirements for reporting and approving of the disposition of nonconformances.
f.
Procurement documents are reviewed by the QA organization before transmittal to the prospective suppliers and these reviews are documented.
g.
Changes to procurement documents undergo the same degree of review and controls as the original documents.
h.
Measures to control the release and distribution of procure-ment documents are being implemented.
2.
Method of Accomplishment Review of the following documents to determine if the preceeding objectives were accomplished relative to Procurement Document Control:
Procurement document control was identified in Gilbert / Common-a.
wealth Topical Report gal-TR-106 Revision 2A dated February 1980, Section 17.4, Procurement Docuuent Control.
The organi-zations involved in the execution of procurement activities have been identified in this Section.
b.
In the Gilbert Associates Procurement Control Procedures Manual, Construction Services Division, the following sections were reviewed for organizational responsibilities and procedures:
(1) Part A-5, " Quality Assurance Records Control Program" (2) Part II.1.2., " Developing and Maintaining Standard Project Contractual Documents" (3) Part II.1.4., " Technical Specifications and Drawings for Contract Documents" (4)
Part V.1.1.,
" Processing Specifications and Bills of Materials" The following procurement packages were reviewed to assure that document control procedures were being followed properly, Purchase Orders SN-10168-SR, SN-10223-SR, and SN-10240-SR.
c.
Procurement procedures were reviewed to assure that supplier commitments and activities were being monitored.
Procurement Control Procedures Manual Part IV titled " Expediting," defines the system of keeping status of open purchase orders.
Selected purchase orders were reviewed to verify proper functioning of l
1 19
'the system. _These selected Purchase Orders were, SN-10168-SR (168-056),_SN-10423-SR (223-016), and SN-10240-SR (240-928).
d.
.To assure the procedures outlined in the ". C. Summers Nuclear Station Unit 1 Quality Assurance Manual and the concurring-Project Management Manual were -being properly implemented in the area.of-Quality Assurance Procurement Document Control, the following documents were reviewed:
4 (1) ' Twenty-five (25) safety related Deviation / Change Requests (D/CR) were reviewed to determine that the Quality Assurance department was receiving these documents and was dispositioning them in accordance with designated procedures.
(2). The' Quality Assurance Project Manager's D/CR Log Book was i
reviewed to assure that the D/CRs had been entered and dis-positioned to reflect current status.
(3) The Corrective Action Report (CAR) Log, kept by the Project Quality Assurance Manager for the V. C. Summer project, was reviewed for_ required content, and three (3) CARS were chosen from Quality Assurance document files to assure dispositioning was consistent with the information in the CAR Log.
(4) A document was selected that was an example of one of the final activities in the area of procurement. The. document selected was the Certificate of Inspection which is a GAI/QA generated document that identifies any outstanding Deviation /
Change Request (D/CR) or Inspection Hold and the Accompanying j
disposition information.
Three (3) examples of Certificate of Inspections on different supplier contracts were reviewed for procedure implementation.
1 (5) Three (3) Bills of Material were reviewed to assure that preparation and content of the document was-in agreement with preparatory procedures.
Subsequent revisions of the Bills of Material were reviewed for proper distribution
-and acceptance signatures.
The Project Management-Manual for the V. C. Summer Project was e.
reviewed.for procedural information dealing with Engineering
. Change Notice (ECNs).
To assure that these procedures were 3
being implemented, the following-documents were reviewed.
(1) South Carolina Electric and Gas Company Virgil C. Summer Nuclear Station Unit 1 ECN Status Report, wnich is a document kept, and updated by, the Project Manager as required by a
~-
20 procedures.
This ECN Status Report was reviewed to assure that the-contents of this report have been properly entered and that the disposition reflects document file contents.
(2).To assure proper distribution to GAI/QA for concurrence and control of ECN's.
Six (6)'ECN's were examined for content.
(3) South Carolina Electric and Gas Company Virgil C. Summer-ECN Exception Report was reviewed for content.and status.
This report-is used in conjunction with the ECN Status
. Report as a comprehensive list of ECNs that are not closed.
out to date.
3.
Findings In this area of the inspection two (2) deviations from a.
commitment were identified (See Notice of Deviation, Items F. and G.)'
b.
Unresolved Item or Follow-up Items None were identified.
I e
n
~_
21 DETAILS SECTION III (Prepared by L. W. Gage)
A.
Persons Contacted
- J. C. Daly, TMI-1 Senior QA Program Manager
- R. C. Holzwarth, Manager, Corporate QA Programs
- M. Pratt, :TMI-1 QA Project Manager
- R. M. Rogers, Project Manager, TMI-1 Continuing Services (Restart) Program
- Denotes those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
Follow-up on Deviation A of Report 80-01 a.
Objective The objective of this area of inspection was to verify the action taken by G/C as delineated in their letter of May 20, 1980.
b.
Method of Accomplishment The inspector reviewed the G/C procedure draft procedure " Manage-ment Review of the G/C Quality Assurance Program," Revision 0, dated June 22, 1980. This document provides a written procedure for conducting a management review (by audit) of the status and adequacy of the QA Program.
G/C stated that this procedure will be issued, and referenced as an Amendment to the Charter of their QA Policy Committee.
The inspector also reviewed G/C memo (Holzwarth to Lanza) dated May 21, 1980, which documents the preventive measures committed to in the G/C letter of May 20, 1980: namely, the review of the Topical Report and Standard Review Plan, to determine if there were any other requirements in them that are not covered in their Nuclear Quality Assurance Manual.
Several requirement differences were found and identified in the memo.
The resulting additions to the NQAM will be incorporated by August 30, 1980.
c.
Findings Since G/C committed completion date for this deviation is August 30, 1980, and their effort is continuing, this item will remain open until the next inspection.
The reference to the Management Review procedure and the cor-rection of requirement differences in the NQAM were identified by the-inspector as a follow-up item.
~~-
r 22 2.
Follow-up on Deviation B.5 of Report 80-01 a.
Objective.
The objective of this areasof inspection was to verify the action-taken by G/C as delineated in their letter of May 20, 1980.
b.
Method of Accomplishment The inspector reviewed the design verification records for Structural Design, as well as design verification records for Instrumentaticn and Control, _and for Mechanical Design. - The records included:
1.
June 27, 1980, Structural, review by J. Herr 2.
June 23, 1980, I&C review by V. Willems 3.
June 19, 1980, Mechanical review by W. Brannen The inspector determined that G/C had carried out their commitment to review structural design verifications, per their letter of day 20.
He also determined that they had performed quarterly reviews, since the last NRC inspection, in the instrumentation and control and in~the mechanical areas.
c.
Findings This item is considered closed.
3.
Follow-up on Deviation C.5 cf Report 80-01 a.
Objective The objective-of this-area of inspection was to verify the action taken by G/C as delineated in their letter of May 20, 1980.
b.
Method of Accomplishment The inspector reviewed the file on audit SA-79-1, including theLclose-out action _ documentation dated May 21, 1980.
c.
Findings-The inspector determined that_ G/C correctly responded to the
-deviation identified in report 80-01.
However,-the concern of'the inspector related to the audit report " area of concern No. J1,7 and not -to audit report finding No.
1.
The G/C close-out
~
action applied to Audit finding No. 1.
The two were not related.
- -. = = - -
.n
. _7 23 The response to the " area of concern No. 1" in Audit report SA-79-1 was identified.by the inspector as a follow-up item and will be reviewed again during a future inspection.
4.
, Follow-up on Unresolved Item I.D.3.b of Report No. 80-01 a.
Objective To determine if.the QA Program for the TMI-1 Continuing Services (Restarc) Project has been defined in G/C manuals.
b.
Method of Accomplishment The-inspector reviewed the April 30, 1980 revision of the G/C Project Management Manual (PMM) for the TMI-1 Continuing Services (Restart) Project.
Paragraph 8.01.1 of the PMM states:
"The GAI Quality Assurance Program for the project as described in this plan and its -
referenced documents meets the requirements of the GPUNC-Operational Quality Assurance Plan and TMI Recovery QA Plan -
Unit II for Three Mile Island and applied to Units 1 and 2."
The inspector noted that G/C possessed controlled copies of the GPUNC "TMI-GPU Operational Quality Assurance Plan for Three Mile Island Nuclear Station Unit 1" (Revision 8, dated April 18, 1980).
c.
Findings This unresolved item is considered closed, being escalated to a devi-ation from commitment.
(See Notice of Deviation, Item B.1.)
5.
Follow-up on Follow-up Item IV.B.I.d of Report 80-01 a.
Objective e
l The objective of this area of inspection was to resolve the inconsistency between-(1) the purchase requisition quality requirement for a Barton Model 288 Switch,'and (2) the QA
. requirements on the ECM sign-off page.
4 b.
Method of Accomplishment The inspector interviewed the cognizant G/C Design and Quality i
Engineers and reviewed the memo of explanation, dated July 25, 1980,. entitled "Justifica. tion for the classification of ECM-017."
~
x i
24 The inspector _ determined that the justification of the ECM classification was satisfactory and the memo verified the explanations provided by the personnel interviewed.
c.
Findings This item is considered closed.
6.
Follow-up on' Follow-up Items'IV.B.2.d of Report' 80-01 i
a.
Objective i
The objective of this area of inspection was to follow-up on the exclusion of the TMI Restart Report from the list of design verification bases in the TMI-1 Continuing Services PMM of October 23-,
1978.
b.
Method of Accomplishment The_ inspector reviewed the revised (April 30, 1980) issue of the l
TMI-I Continuing Services PMM.
G/C, in paragraph V.05 of the PMM states:
"The Project Engineer ensures that all GAI work
[
is in accordance with the TMI technical specifications and commitments in the.
Restart Report."
c.
Findings The G/C Project Manager stated that G/C will document how they are ensuring that their (G/C) work is in accordance with those commitments in the Restart Report that are neither the G/C scope of supply for _the TMI-1 Restart Project.
G/C intends to provide a document that will identify each commitment and identify the G/C task (s) that satisfy the commitment.
G/C will provide this document to GPUSC for their review and concurrence, both initially, and on a periodic basis as it is
. updated.
i While these actions close the subject followup item, this matter will be reviewed and evaluated by the NRC inspector during a future inspection.
)
i 1
r
,.