ML19350A636
| ML19350A636 | |
| Person / Time | |
|---|---|
| Issue date: | 12/19/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19350A624 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8103160598 | |
| Download: ML19350A636 (2) | |
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Gilbert / Commonwealth'
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e-Docket No. 99900525/80-03 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on November 17-20, 1980, it appears that certain of your activities were not conducted in full compliance with your commitments as indicated below:
Criterion V of Appendix B ts 10 CFR 50, states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accompliahed." Deviations from these requirements are as follows:
A.
Sections 2.2 and 2.7 of the Gilbert / Commonwealth (G/C) Nuclear Quality Assurance Manual (NQAM) state in part that the " Major elements of the Quality Assurance Program provide for:...a.
Identification of structures, systems and components to which the Quality Assurance Program is applicable...
A list of the structures, systems and components controlled by this Quality Assurance Program shall be prepared for each nuclear project to which this Manual applies...."
Contrary to the above, a list identifying the structures, systems and components to which the G/C quality assurance program is applicable and that are to be controlled by the program, was not prepared nor in place for the restart tasks of the TMI-1 Continuing Services Project even though the NQAM applies to the project.
Corrective action and preventive measures have been completed by G/C therefore no further written response to this deviation is necessary.
See Section I.B.14 of report 999J0525/80-03 for details.
l B.
Paragraph 3.3 of the NQAM requires that the " Power Engineering Divisions
.. (h) Identify and control design interfaces...." Design Control Procedure DCP:1.30 provides specific instructions for these activities relative to drawings.
Contrary to the above, design ini.erfaces were not identified and controlled on piping drawings 4692-E-304-6041A, 4692-E-304-666IA, 4692-E-304-736IA, 4692-E-311-831IC, 4692-E-311-841IC 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 Project Management Manual of the TMI-1 Continuing Services Project), the Originator (the mechanical discipline) did not initiate l
l revisions four and five to piping drawing 4692-E-304-666IA, instead the instrumentation and control discipline of the TMI-1 Restart Task I
l initiated the changes.
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2.
Contrary to Paragraph 3.2.5.7 of DCP:1.30, organizations that interface with the mechanical discipline did not document their review of the identified or.' wings, and revisions thereto, that were originated by the mechanicai discipline to assure that the drawing properly presents their interface comments as indicated by their signing the drawing.
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