05000366/LER-1981-035, Forwards LER 81-035/03L-0
| ML19345H294 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/05/1981 |
| From: | Manry M GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345H295 | List: |
| References | |
| PM-81-392, NUDOCS 8105120377 | |
| Download: ML19345H294 (1) | |
| Event date: | |
|---|---|
| Report date: | |
| 3661981035R00 - NRC Website | |
text
.
h U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 95600503/80-02 Program No. 51200 Company:
Burns and Roe, Inc.
496 Kinderkamack Road Oradell, New Jersey 07649 Inspection at:
Oradell, New Jersey; Woodbury, New York; and Paramus, New Jersey Inspection Conducted:
September 15-19, 1980 Inspectors:
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- 0. F. Fox, Contractor Inspector Date Program Evaluation Section Vendor Inspection Branch 3 ir &
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- 0. G. Breaux, Inspector n /is /ro Date Program Evaluation Section k Vendor Inspection Branch I
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Approved by:
C. J.(HaJ e, Chief Date l
Progr W Evaluation Section Vendor Inspection Branch Summary Inspection conducted on September 15-19, 1980, (99900503/80-02)
Areas Insoected:
Implementation of Title 10 CFR 50 Appendix B, and Topical Report B& ROE-COMi-1-NP-1A, including 10 CFR Part 21 inspection, audits, training, follow-up on an NRC regional request, and action on previous inspection findings.
The inspection involved eighty-one (81) inspector hours on-site by two (2) USNRC inspectors.
Results:
During this inspection, one (1) violation of 10 CFR Part 21 and three (3) ceviations from commitments to NRC were identified.
One unresolved item was identified.
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2 10 CFi Part 21 Violation:
Failure to post 10 CFR Part 21 in the facilities where certain safety related activities are being conducted.
(See Notice of Violation)
Deviations:
Followup on previous inspection findings:
Corrective action
icentified in a Burns and Roe response to a previous deviation had not been completed as committed.
(See Notice of Deviation, Item A).
Followup on an NRC regional request:
Qualification records of source surveillance personnel were not maintained as required.
(See Notice of Deviation, Item B).
Audits:
Technical audits were not timely conducted nor closed out as required.
(See Notice of Deviation, Item C)
Unresolved Items:
Occumentation made available during the inspection did not appear to substan-tiate the Burns and Roe management position that an identified substantial safety hazard which existed at the interface between rigid conduit and safety related electrical switchgear installed in WNP-2 and another operating nuclear power plant was evaluated, documented, and reported in accordance with the requirements of 10 CFR Part 21 and Burns and Roe procedure PM-014.1.
(See DetailsSection I, paragraph 0.3.)
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DETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contacted
- J. M. Blas, Home Office QA Manager J. Cirilli, Manager, Vendor Surveillance
- J. W. DeLooper, Manager, Quality Audits J. J. Oriscoll, Project Manager, Operating Plant Services J. F. Freer, Group Supervisor, Electrical
- J. R. Ellwanger, Supervisor, Licensing L. Fischer, Sr. Civil Engineer I. Gabel, Deputy Director, Power Technology Division H. H. Khalaf, Mechanical Engineer J. F. C'Donnell, Group Supervisor, Civil Engineering C. Scarlett, Supervisor, Nuclear Engineering P. Shendy, Cooper Project Engineering R. E. Snaith, Senior Project Engineer 4
F. P. Secchia, Secretary and General Council J. Zalavadia, Group Superfisor, Heating Air Conditioning
- M. Zizza, Vice President, Engineering and Design
- Denotes those present at the exit interview.
B.
Followup on Previous Inspection Findings 1.
(0 pen) Jsviation A.1 (Report 80-01). WNP-2 PSAR commitments to design verification are not being implemented.
The inspector determined that the corrective and preventive measures described in Burns and Roe letter of response dated June 5, 1980 were not completed as committed.
Although the WNP-2 project specific and the corporate master procedure for Engineering Review and Approval of Project Drawings were revised by the scheduled date, the revisions did not specifically require that completed drawings, and all changes thereto, be design reviewed or design checked by a qualified engineer from the same discipline as the originator and who was not the preparer of the document.
- Further, the revised procedures do not exclude the individual performing the design review or check from having specified the design, or input to the design, as required by their commitments.
This constitutes a deviation from commitment.
See Notice of Deviation, Item A.
2.
(Closed) Deviation A.2 (Report 80-01). WNP-2 PSAR commitments to quality assurance records are not being implemented.
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The inspector verified the corrective actions and preventive measures described in Burns and Roe letters of response dated June 5,1980, and July 17, 1980.
Specifically, Burns and Roe prepared draft revisions to sections 0.1, 0.2, and 0.3 of the WPPSS PSAR for the WNP-2 nuclear power plant which identified changes in the Burns and Roe responsibility for construction management and quality assurance.
Burns and Roe transmitted the revised drafts to WPPSS by letter BRWP-80-396 dated July 18, 1980.
Followuo Item:
The Technical Division of the Washington Public Power System reportedly considers the Burns and Roe Quality Assurance Program "an acceptable and sufficient means for accomplishirg design verification as required by 10 CFR 50 Appendix B."
- dowever, the Burns and Roe quality assurance program did not in the past, nor does the proposed current proposed revision specifically require an indecendent design review or verification of design documents as described in Revision 2 of Regulatory Guide 1.64 (which however, has not been committed to by WPPSS).
Furthermore, the revised draft to the PSAR does not clearly delineate the specific responsibilities for design verification retained by Burns and Roe and those assumed by WPPSS for Burns and Roe designed structures, systems and components.
This item will be followup during future inspections.
3.
(Closed) Deviation B (Report 80-01).
Topical report organizational changes were not submitted to NRC.
The inspector verified the corrective action and preventive measures described in Burns and Roe letters of response dated June 5, 1980, and July 17, 1980.
Specifically, Burns and Roe submitted past organi-zational changes to NRC and reaffirmed their commitment to submit future changes to the Topical Report to NRC within thirty days and programmatic changes prior to their implementation.
4.
(Closed) Deviation C (Report 80-01).
Design calculations did not exhibit the required " checked" statement by the checker.
The inspector verified the corrective action and preventive measures described in the Burns and Roe letter of response dated June 5,1980.
Specifically, the required " checked" statement was added to the identi-fied deficient calculations and Burns and Roe Project Procedure WNP ED-010 (Calculations) was revised to state that "the checker's required signature and initials on the calculation indicate that the calculation was checked and found to be satisfactory" and the redundant " checked" statement eliminated from the procedure.
5.
(Closed) Deviation 0 (Report 80-01).
Audit files did not contain the required audit checklists and QA recommendations for corrective action.
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5 The inspector verified the corrective action and preventive measures desc-ibed in the Burns and Roe letter of response dated 5, 1980.
Specifically, checklists and QA recommendations were added to complete audit files cs appropriate and all auditors were instructed by formal memorandum to assure that all audit procedural requirements were accomplished.
6.
(Closed) Deviation E (Report 80-01).
Source Verification Plans were not included in Vendor Surveillance Project Plans.
The inspector ver'fied the corrective action and preventive measures described in the t 'ns and Roe letter w/ response dated June 5, 1980.
Specifically, the missing Source Verification Plan was reconstructed and inserted into the Vendor Surveillance Project Plan and Burns and Roe Quality Assurance Instruction 07-102 was revised to require a copy of the Source Verification Plan to be maintained in the Vendor Contract file.
C.
Followuo on Regional Recuest 1.
Objectives a.
Determine the following:
(1)
If the WNP-2 QA program at Burns and Roe is being fully implemented.
(2)
If issued drawings and specifications are being maintained current.
(3)
If the design of the hanger systems and the sacrificial shield wall were reviewed according to commitments.
(4)
If contractor requests for information and non-conformance reports are being reviewed and/or answered as per commitments.
(5)
If vendor surveillance at the Leckenby Company has been effectively implemented, in accordance with commitments, by qualified individuals, since defective pipe whip restraints and sacrificial shield wall components from Leckenby have been identified at the WNP-2 site.
b.
If a breakdown in the Burns and Roe QA Program has occurred, determined the cause and those specific requirements that may have been violated.
2.
Method of Accomolishment
- - The following documents were reviewed in accomplishing the above objectives.
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6 Sections 0.2 (WPPSS QA Program) and 0.3 (Burns & Roe QA Program) a.
of the PSAR for the WPPSS (Washington Public Power Supply System) to determine the QA Program commitments to tne NRC, relative to Hanford No. 2 (WNP-2) nuclear power plant.
b.
Burns & Roe prepared revision to Sections 0.2 and 0.3 of the PSAR for the WPPSS WNP-2 nuclear power plant, to determine if the revision accurately reflects the current Burns & Roe scope of supply to WPPSS.
c.
The appropriate sections o? the Burns & Roe WNP-2 Project Plan and the Project Quality Assurance Manual, to determine that the in place QA Program establishes the commitments contained in the Burns & Roe prepared revision to Sections 0.2 and 0.3 of the PSAR, and that the established program is being effectively implemented.
d.
The following "prepurchased equipment" contracts and changes thereto to determine the Burns & Roe responsibilities for design, desi p verification, vendor surveillance and installation of safety related pipe and conduit hangers and supports, pipe whip restraints, HVAC and plumbing, and the sacrificial shield wall.
2808-90; Leckenby Co; Awarded January 28, 1976 2808-215; B&C/B0 ECON /WSH; Awarded May 13, 1974 2808-216; Waldinger; Awarded May 10, 1974 2808-218; Fishback/ Lord; Awarded February 14, 1975 2808-220; Johnson Contro H; Awarded November 16, 1976 2808-233; 8. F. Shaw; Awarded September 13, 1977 e.
Applicable sections of the following procedures to determine the requirements with respect to design review, contractor requests for information, and nonconformance control.
WNP-2-ED-001; Engineering Review and Approval of Project Drawings.
WNP-2-ED-009; Review, Certification and Approval of Tech. Specs.
WNP-2-ED-010; Calculations.
WNP-2-ED-012; Request for Information.
WNP-2-ED-013; Special Design Review.
WNP-2-ED-043; Technical Audits of Project Engineering.
WNP-2-PM-016; Review and Approval Signature Requirements for System Descriptions, Tech. Specs, and SAR/ER.
WNP-2-PMI-4-5; Project Control of Nonconformances.
f.
Twenty five (25) Nonconfomance Repor*s, six (6) Contract Waver Requests, twenty (20) Contractor Requests for Information and thirty (30) contractor submittals of drawings and specifications for review and comment / approval, to determ e if Burns and Roe L
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completed their review and disposition of the documents in accor-dance with commitments.
g.
Qualification records of six Vendor Surveillance Personnel, seven Vender Survey and Trip Reports, seven B& ROE letters to contractors, and two internal memoranda, to determine if vendor surveillance was in accordance with commitments, performed by qualified individuals, and would assure that defective material was not released to the WNP-2 site.
3.
Findings a.
Deviations One deviation was identified in this area of the inspection.
See Notice of Deviation, Item 8.
b.
Followuo Items None were identified on this area of the inspection, however see related item in paragraph B.2. above, i.e, neither the approved, nor the proposed revision of the WPPSS PSAR for WNP-2 clearly delineate the responsibilities for desigr verification retained by Burns and Roe and those assumed by WPPSS for B& ROE designed structures, systems and components.
c.
Comments (1) With respect to objective a.(1) above, B& ROE was not imple-menting the overall Quality Assurance / Quality Control Program for the WNP-2 Project that was described in Appendix 0 of the WNP-2 PSAR.
The program that was being implemented differed from that described in the PSAR in areas such as construction management, organization, QA Program, design control, design verification, procurement, and site related activities.
As a result of Deviation A identified in inspection report 80-01, B& ROE prepared a revision to Appendix 0 of the PSAR which, except in the area of design verification, appears to define the QA Program being implemented on the WNP-2 Project.
B& ROE transmitted the re' i;ed draft of Appendix 0 to WPPSS on July 18,1980, via B;/P-80-396 transmittal letter. WPPSS in turn committed to BAR0E, "... to fi'e a PSAR deviation by approximately August 29, 1980, and an FSAR amendment by approximately October 17, 1980,... " via Memo F-80-aZ58 dated August 5, 1980.
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8 (2) With respect to objective a.(2) above, B& ROE apparently has been systematically shifting all design and technical support functions for WNP-2 from the Home Office (New York and New Jersey) to the WNP-2 site and to the recently organized (per B& ROE letter BRWP-80-472 dated August 21, 1980) Richland Office since early 1979.
B& ROE management stated that the on-site B& ROE Engineering group did much of the design work and changes thereto for WNP-2 especially in the area of pipe hanger design, civil and structural engineering, instrumentation and control, and heating and ventilating.
The Burns and Roe site and Richland Office groups will handle essentially all changes to existing designs and will provide new designs and technical support to WPPSS construction management as needed.
Revisions to drawings and specifications issued and maintained by the Burns and Roe Home Office that were examined by the inspector were processed timely, however the inspector could not verify, at the Home Office, that revisions to drawings and specifications made by the site group were responded to and controlled in accordance with commitments.
This item will be followed up in future inspections as part of the previously identified followup item.
(3) Wi'5 respect to objective a.(3) above, B& ROE records indicate that the Home Office prepared the design specifications and some design drawings for pipe hanger systems, pipe whip restraints, and the sacrificial shield wall, but did not, except for a few isolated pipe hangers, that were not com-pleted by one of the subcontractors, perform the detailed design of these items.
First and second Tier subcontractors did the actual detailed design work and generated the fabri-cation and/or shop drawings.
The B& ROE Home Office reviewed most of the contractor submitted drawings and specifications for conformance to the design specifications, but did not conduct design reviews on any contractor designed / supplied items (except for a few recent isolated cases).
Tha question of whether the B& ROE review and approval of calculations, drawings, and specifications meet the intent of " independent design verification" as described in Reg.
Guide 1.64 has not been fully resolved.
However, the inspector found no evidence to indicate that review or checking of the adequacy of the design was not an inherent part of the manage-ment review and approval cycle of such design documents prior b
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Past issues of procedures used to control the generation and issue of such documents did not specifically require that all such documents be reviewed by a qualified engineer who was not the originator of the design.
Current revisions of the procedures do, or will, contain this requirement.
B& ROE instituted a Technical Audit Program (WNP-2-043 " Tech-nical Audits of Project Engineering") for calender year 1979 to provide additional assurance of the adequacy of the WNP-2 design.
Approximately seventy two (72) technical audits of the seven major functional engineering areas were conducted by qualified engineers who did not perform or specify the original design (i.e., not assigned to the WNP-2 Project).
Although the followup and close out of ti.ese technical audits were not always in compliance with procedural requirements (See Notice of Deviation, item C), review of selected reports by the inspector indicated that, for the designs audited, certain arrects of the design were subjected to an independ-ent check or review by the technical auditors.
With respect to independent design verification of B& ROE designs, WPPSS letter to B& ROE, WPBR-80-101 dated March 10, 1980, states in part that, "... procedures have not been employed to assure that activities related to Design Veri-fication are carried out in a planned, controlled, orderly and co rect manner...."
B& ROE letter to UPPSS, BRWP-80-225 dated April 24, 1980, responded by stating:
.)
The B& ROE procedures are adecuate and meet the require-ments committe.d to ano agreed with by WPPSS.
(b) The B& ROE proposal for developing an independent Design Verification Plan for WNP-2 was not approved by WPPSS.
(c) Although WPPSS indicated that 8& ROE should continue indepenaant design verification in accordance with the PSAR commitments, "... B& ROE is not performing inde-pendent design verification on the WNP-2 Project as defined by Regulatory Guide 1.6.4, Revision 2...."
(WPPSS committed to Revision 0 of Reg. Guide 1.64)
WPPSS letter to B& ROE, WPSR 186 dated May 22, 1980, essentially rejected the previous B& ROE response and stated that, "... the results of the verif# cation efforts shall be clearly documented with the identification of the verifier clearly indicated tnereon and filed...."
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10 B& ROE in their letter BRWP 362 dated July 2,1980, reiterated their position on design verification and further stated that ".
WPPSS is committed to performing design reviews of B& ROE prepared procurement documents (design specifications) and drawings, and B& ROE is committed to a verifying or checking process... and that current procedures implemented on~the WNP-2 Project are adequate and sufficient to meet the requirements of the PSAR...."
This item will be followed up in future inspections as part of the previously identified followup item.
ss (4) With respect to objective a.(4) above, review of Contractor Requests for Information and Non-conformance Reports that were received by the B& ROE home office and indicated that they were adequately reviewed and returned to the originator within one to two weeks except for a few isolated cases where additional information was needed from the vendor, or from the WNP-2 site QC Inspection Group, to properly disposition the request and/or nonconformance.
However, all recently submitted Contractor Requests for Information and Non-conformance Reports are received and processed by the B& ROE WNP-2 Site Engineering Group and only referred to the home office when the site group cannot adequately respond to the item.
Thus, the inspector could not determine that recent requests or reports were reviewed and answered or dispositioned in accordance with commitments.
Review of this item will continue in future inspections.
(5) With respect to objective a.(5) above, three of six examined vendor survllance personnel qualification records were incomplete or otherwise not available for examination by the inspector (See Notice of Deviation, item B).
Review of available records, interviews with other vendor surveil-lance personnel, and review of related letters and reports indicate that the B& ROE home office vendor surveillance per-sonnel are experienced in the required surveillance activities and have conducted the requisite surveillance visits.
Records of site personnel were not available for examination at the home office.
B& ROE management stated that, to the best of their knowledge, no B& ROE home office vendor surveillance personnel were ever used to perform a vendor surveillance, audit or inspection at any vendor, including the Leckenby Company where the sacrificial shield wall, pipe hangers and pipe whip restraints were being fabricated, except on contract 3808-90 with the me
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Surveillance on this contract (-3808-90 for pipe whip restraints) resulted in seven vendor survey and trip reports, seven B& ROE letters to the vendor, two internal memorandums, and six Contract Waver Requests being generated during the contract period from February 3,1976, through October 20, 1976.
Review of the home office verdor surveillance records in-dicate that one pipe whip restraint and several sets of nuts and bolts were shipped to the WNP-2 site by Leckenby without prior B& ROE authorization, and that field welding of the base weld of four other restraints, not completed by Leckenby, was required.
All other pipe whip restraints fabricated by Leckenby met the purchase order requirements and were " final accepted for shipping" by B& ROE vendor surveillance personnel prior to shipment to the WNP-2 site.
D.
10 CFR Part 21 Inspection 1.
Objectives The objectives of this area of inspection were to examine the establish-ment and implementation of related 10 CFR Part 21 procedures to verify that:
a.
10 CFR Part 21 is posted in accordance with the requirements.
b.
Deviations and nonconformances are evaluated and adequate records are maintained and properly dispositioned by the responsible organizations or persons.
c.
Methods of analysis for a defect, deviation or failure to comply are clearly described and responsibilities assigned to organizations or persons in each related phase of analysis, d.
A Director or responsible officer has been appointed to notify the commission of evaluated defects, deviations or failures to comply.
e.
Procurement documents for safety-related items specify that 10 CFR Part 21 requirements apply.
f.
Evaluation of deviations were timely and appropriate.
g.
Items determined to be substantial safety hazards were timely and appropriately reported to the NRC.
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12 2.
Method of Accomolishment The followi.1g documents were reviewed to accomplish the above objectives.
The following Burns and Roe facilities were inspected to verify a.
that 10 CFR Dart 21 notices were posted which described the Regulations and Burns and Roe procedures, identified the loca-tion where copies of the regulations and procedures are available, and identified the name of the individual to whom reports may be mace.
185 Crossways Park Dr., Woodbury, N.Y.
496 Kinderkamack, Rd., Oradell, N.J.
550 Kinderkamack Rd., Oradell, N.J.
800 Kinderkamack Rd., Oradell, N.J.
633 Industrial Ave., Paramus, N.J.
b.
_JROE Project Procedure PM-014.1 Revision 3, dated March 1, 1978,
" Reportable Defects and Non-Compliances (Nuclear Projects);"
B& ROE Purchase Order BR-2808-502; StatL3/ Summary of B& ROE (Safety Concern) Evaluation Reports 77-1 thru 77-6, 78-1 thru 78-17, 79-1 thru 79-26, and 80-1 thru 80-12; Evaluation Reports 79-4, 79-8, 79-17, 80-2 and 80-8; B& ROE Letters to WPPSS BRWP-79-273, BRWP-79-348 BRWP-79-378, BRWP-79-561, BRWP-80-325, and BRWP-80-348; B& ROE memorandum dated April 21, 1980, concerning B& ROE Audit BR80-1-AT1; and B& ROE letters to Wyle Laboratories dated January 4,1980, and February 12, 1980.
3.
Findings a.
Violations One violation was identified in this area of the inspection.
See Notice of Violation, enclosure.
10 CFR Part 21 posting requirements were met at the following B& ROE facilities.
185 Crossways Park G33 Industrial Avenue 10 CFR Part 21 posting was not accomplished at:
496 Kinderkamack Rd.
550 Kinderkamack Rd.
800 Kinderkamack Rd.
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13 b.
Unresolved Item Documentation made available during the inspection did not appear to substantiate the Burns and Roe management position that an identified substantial safety hazard, which existed at the inter-face between rigid conduit and safety related electrical switch-gear installed in WNP-2 and an operating nuclear power plant, was evaluated, documented, and repcrted in accordance with the require-ments of 10 CFR Part 21 and Burns and Roe procedure PM-014.1.
This item is currently undergoing technical review in NRC Head-quarters.
Based on the results of that review, the VIB will take enforcement action, as aporopriate.
E.
Exit Interview An exit interview was held with management representatives on September 19, 1980.
In addition to these individuals indicated by an asterisk in para-graph A of the Details Section, the meeting was attended by:
H. R. Canter, Director, Project Operations T. A. Hendrickson, Assistant to the President F. J. Patti, Chief Nuclear Engineer W. P. Rausch, Director of Project Support and QA C. J. Satir, Project Engineer E. J. Wagner, Department Director of Engineering and Design Ths inspector discussed the scope and findings of the inspection in detail.
Management comments were generally for clarification only, or acknowledge-ment of statements by the inspector.
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14 DETAILS SECTION II (Prepared by D. G. Breaux)
A.
Persons Contacted
- J. W. Delooper, Manager, Quality Audits F. Hess, Engineer A. G. Karg, QA Engineer
- F. J. Patti, Chief Nuclear Engineer C. E. Roemer, Senior QA Engineer
- Denotes those present at the exit interview.
B.
Audits 1.
Objectives The objectivc3 of this area of the inspection were to verify that:
a.
Audit system is established which has organizational independence, authority, and is documented in procedures and/or instructions in accordance with commitments.
b.
Audit records include a written audit plan, team selection, audit schedule, and audit notification to the person or organization to be audited.
c.
Members of the audit team are independent of arv direct respons-ibility for the activities being audited.
d.
Provisions exist for the eporting of the effectiveness of the quality assurance program to responsible management.
e.
The audit includes the use of checklists or procedures, detailed audit reports, and timely identification, acknow-ledgement, documentation of nonconformances, and subsecuent corrective action and verification.
f.
Audit reports contain the audit scope, identification of auditors, persons or organizations contacted, summary of the results of the audit, the details of any nonconformances noted, the recommenda-tions for correction, and distribution of the report to respons-ible management.
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Method of Accomplishment Review of the following documents to determine that the preceding objectives were accomplished:
a.
The audit program framework was identified in Burns and Roe Inc.
Nuclear Quality Assurance Manual (B& ROE - COM4-1-NP), Revision lA dated February 15, 1978, Chapter XVIII entitled " Audits".
This chapter describes the general requirements for a system of planned and documented audits to verify compliance with all aspects of the quality assurance program and to verify the ef fectiveness of the program.
b.
Burns and Roe Inc. Washington Public Power Supply System Nuclear Project No. 2 Quality Assurance Program, Volume II, Section 21.0, titled " Audits" defines the framework for the audit function with respect to the specific project inspected.
c.
To assure the proper identification of organizational responsibil-ities and proper identification of documents to be used in per-forming the audit function with respect to the WPPS$ Nuclear Pro-ject No. 2 the following procedures were reviewed:
(1) WNP-2-043, " Technical Audits of Project Engineering", Rev. O dated September 3,1980.
(2) 2808-Q-4.8, " Technical Audit of Project Engineering", Rev. I dated January 20, 1974.
(3) WNP-2-QA-001, " Audits of Project Quality Assurance Program (Nuclear Projects)," Rev. 4 dated May 25, 1979.
d.
To assure that procedural requirements are being properly and effectively performed in the area of audits the following were reviewed:
(1) The Technical Engineering Audit Status Log, kept by WPPSS Project Quality Assurance, was found to have proper inputs and all disposition information reflected current status.
(2) The WPPSS Project Quality Assurance "Open Audit Finding Status Report" for technical audits was reviewed and found to show proper Open Item status of audits.
(3) Technical audits of the following disciplines, 76-6(HVAC) 76-6 (Nuclear), 76-9 (Stress), 77-15 (Stress), 78-13 (Mechanical), 78-14 (Mechanical), 79-14 (Mechanical), 79-13 4
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(Mechanical), 79-13 (Nuclear), 76-12 (Stress), 76-9 (Nuclear), 78-14 (Stress), 76-9 (Nuclear), and 78-14 (Nuclear) were reviewed to assure proper and timely initiation, reporting, and audit finding close out and followup were being dispositioned according to prescribed project procedures.
(4) Burns and Roe Inc. quality assurance audits, BR79-10 (Vendor Surveillance Activity), BR 79-8 (Project Engineering), and BR 80-4 (Project Quality Assurance) for WPPSS Nuclear Pro-ject No. 2, were reviewed and found to have proper audit content, timely initiation and followup of audit findings.
(5) The following client quality assurance audits,80-145, 79-104, and 80-159 for the WPPSS Nuclear Project No. 2, were reviewed to assure proper and timely interface betweer Burns and Roe and the client (WPPSS).
(6) Burns and Roe Inc. generated document entitled " Corporate Audit Program Status Summary of Open Audit Findings" dated September 2,1980, was reviewed and found to show proper status of audit findings as reflected by an audit file inspection.
(7) The WPPSS Project audit schedules for 1978, 1979, and 1980 were reviewed.
3.
Findings In this area of the inspection one (1) deviation from commitment was identified.
(See Notice of Deviation, Item C).
During this inspection it was observed that WPPSS Project Engineering Technical Audits were not being processed in a timely manner.
An audit was requested by Quality Assurance on Novemoer 20, 1978, but the audit (Technical Audit 78-14 (Stress)), was not completed by engineering until March 25, 1980.
In similar example an audit was requested on August 3,1976, but completion of the audit by Engineering (76-9 (Nuclear)) was not until March 25, 1977.
Once technical audit findings have been corrected by the affected engineering disciplines, there is to be a verification by Project Quality Assurance (PQA) that corrective actions in all disciplines of an audit have been completed before a request for reaudi'. is init-fated.
Reaudit of corrective action on technical audit findings were not being processed in a timely manner.
PQA initiated a request for a reaudit of 76-9 (Stress) on March 16, 1978, but the reaudit was not completed until August 14, 1980.
Reaudit request of 76-9 (Nuclear) was initiated by PQA on August 3,1976, but the reaudit was not completed until March 25, 1977.
It was also noted that this effort on 76-9 I
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17 (Nuclear) is on its third reaudit because of unsatisfactory corrective action as of September 19, 1980.
C.
Training 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented that provide for:
a.
Formal indoctrination and training or retraining programs for new employees and reassigned employees.
b.
Training of inspection, examination and testing personnel that provide for:
(1)
Indoctrination with the technical objectives of the project, the codes and standards to be used, and the quality assur-ance elements that are to be employed.
(2) On the job participation through actual performance of processes, tests, examinations and inspections.
(3) Testing the capability and proficiency of personnel who perform nondestructive examinations.
(4) Retraining and recertification if evaluation of performance shows individual capabilities are not in accordance with specified qualifications.
(5) Records of training received by each person including appli-cable certification of qualification and results of tests.
c.
Training of audit personnel, including technical specialists, that provide for:
(1) Orientation with applicable standards and procedures.
(2) General training in audit performance including funda-mentals, objectives, characteristics, organization, perform-ance and results.
(3) Specialized training in methods of examining, questioning, evaluating, documenting specific audit items, and methods of closing out audit findings.
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18 (4) On the job training, guidance, and counseling under direct supervision of an experienced, qualified auditor to include planning and performing audits; reporting and followup action; and review and study of codes, standards, procedures, instructions, and other documents related to QA and QA program auditing.
d.
Training programs for other personnel performing quality related activities that include:
(1) A description of quality assurance material to be presented and method of presentation.
(2) Schedules for conducting the training sessions.
(3)
Identification of individuals by job description or titles or groups required to attend sessions.
e.
Occumentation of attendance and retention of other applicable records for all formalized training accomplished.
2.
Method of Accomolishment Review of the following documents to determine that the preceding objectives were accomplished:
a.
The indoctrination and training program framework was identified in Burns and Roe Inc. Nuclear Quality Assurance Manual (B& ROE-COM4-1-NP, Revision 1A dated February 15, 1978, Chapter II entitled
" Quality Assurance Program." This chapter states that "Indoctrin-ation and training procedures are established for those personnel performing quality related activities."
b.
In Burns and Roe, Inc. Washington Public Power Supply System Nuclear Project No. 2 Quality Assurance Program, Volume II, Section 5.0 titled " Quality Assurance Program" states that Quality Assurance will " assist in quality assurance training of project personnel."
c.
To assure the proper identification of organizational responsibil-ities and proper identification of documents to be used in per-forming the indoctrination and training function with respect to the WPPSS Nuclear Project No. 2 the following procedures were reviewed:
(1) WNP-2-005, "WNP-2 Indoctrination and Training Plan",
Rev. 3 dated September 5, 1980.
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19 (2) WNP-2-PM-013, " Indoctrination and Training of Project Personnel (Nuclear Projects), Rev. O dated September 5, 1980.
d.
To assure that procedural requirements are being properly and effectively performed in the area of indoctrination and training the following was reviewed:
(1) The discipline indoctrination and training matrix log kept by the Project Training Coordinator (Project Quality Assurance Manager) was found to contain latest listing of project documents, procedures, and instructions.
Initiation of training requirements upon receipt of a change of project documents affecting quality was reviewed and found consistent with prescribed procedures.
(2)
Internally initiated PC's (Project Connitments)88-286, BB-292,88-298, BB-203, and BB-173 reflected training commitments by the Functional Discipline Group Supervisors in the area of new or revised documents reflecting quality.
(3) Proper status of the previous PC's were listed on a Project Administration generated document titled " Burns & Roe WPPSS Commitment Status Report on Action Items Owed By Burns and Roe," which is updated and printed on a weekly basiJ.
The file of all PC's (Project Commitment) kept by Project Admin-istration was reviewed and found to reflect the Commitment Status Report.
(4) Six (6) training session records in the Civil, Mechanical, and Nuclear disciplines conducted by the Discipline Group Supervisors in a subtraining session to the Discipline i
Engineers care reviewed and found to be properly cond" ted and documented in accordance with procedures.
(5) Corporate Quality Assurance Qualification and Training files of seven (7) individuals were reviewed for proper training documentation.
3.
Findings a.
In this area of the inspection no deviations from commitments, unresolved items or followup item were identified.
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