ML19350A652
| ML19350A652 | |
| Person / Time | |
|---|---|
| Issue date: | 12/19/1980 |
| From: | Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19350A624 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8103160605 | |
| Download: ML19350A652 (12) | |
Text
-
O w.
m.a y
- g. 5. NUCLEAR ~ REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900525/80-03 Program No. 51200 Company: Gilbert / Commonwealth P. O. Box 1498 Reading, Pennsylvania 19603 Inspection Conducted:
November 17-20, 1980 1
y b-[f-[d Inspectors:
,D. F. Ffx) Contractor Tr#4ctor Date e
Program'E9aluation Sectfon Vendor Inspection Branch Approved by:
C/
-/7-T([]
C. J.(70ple, Chief Date ~~
ProgrWEvaluation Section Vendor Inspection Branch Summary Inspection on November 17-20, 1980 (99900525/80-03)
Areas Inspected:
Implementation of Title 10 CFR 50 Appendix B and Topical Report GAI-TR-106 in the areas of design document control, 10 CFR Part 21 inspection, and action on previous inspection findings.
The inspection involved thirty-two (32) inspector hours on site by one (1) USNRC inspector.
Results:
In the three (3) areas inspected, two (2) deviations from commitment were identified in two (2) of the areas.
Two unresolved items were identified.
Deviations: Actions on Previous Inspection Findings:
The requisite list of safety " elated structures, systems and components for the TMI-1 Continuing Services (Restart) Project was not in place. (See Notice of Deviation, Item A).
Design Document Control:
Drawings were. revised and issued by other than the originating organization and without documented comments of interface review (See Notice of Deviation, Item B.)
Unresolved Items:
(1) Safety related activities provi' ed to NRC licensees may d
l not be concucted in accordance with the appropriate quality assurance program.
(Details Section B.8).
(2) Gilbert / Commonwealth did not follow their approved 10 CFR Part 21 implementing procedure.
NRC Headquarters has been requested to review the enforcement action to be taken.
(Details Section C.3.b.).
i
.1o.1.o w r
......- -. p.-
....,n..
_.., g.
OETAILS SECTION A.
Persons Contacted R. W. Alley, Project Engineer, Perry Project
- N. R. Barker, General Manager, Quality Assurance Division R. D. Boyer, Project Civil Engineer R. L. Dail, Manager, Materials and Special Processes
- J. C. Daly, Senior QA Program Manager
- R. C. Holzwarth, Manager, Corporate QA Programs
- A. G. Maino, Manager, Quality Engineering T. M. McMahon, Manager, Electrical Engineering Department
- W. E. Meek, Manager, Engineering Department W. S. Piper, Client Purchasing Agent
- J. M. Pratt, QA Program Manager, TMI-1 Continuing Services Project
- F. C. Prawldck 1, Supervisor, QA Audits
- F. R. Ricci, Manager, Design Control
- R. M. Rogers, Project Manager, TMI-1 Continuing Services Project W. J. Santamour, Manager, Site Investigation and Analysis J. G. Shollenberger, Project Engineer, TMI-1 Continuing Sersices Project
- 0. P. White, Manager, Mechanical - Nuclear Department R. A. Wilkinson, Quality Assurance Engineer
- 0enotes those present at the exit meeting.
B.
Action on Previous Insoection Findings 1.
(Closed) Deviation A (Report 80-01)." The NQAM does not specifically reflect the commitment to perform an annual management audit to evalu.te the QA Program nor does an implementing procedure exist.
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.
Specifically, a procedure for Management Review of the G/C Quality Assurance Program was issued on July 22, 1980, and the l
NQAM was revised on August 29, 1980, to include the requirement for annual I
management review of the QA Program.
2.
(Closed) Deviation B.1 (Report 80-01).
The checker did not initial nor date issued Perry Project System flow diagrams.
The inspector verified the corrective action and preventive measures i
described in the G/C letter of response dated May 20, 1980.
Specifically, all affected drawings exhibited the required checker's signature and a
2
-w-
--.-e
- -* -=~
r+ - - - - - - - - " ~ * ~ *
- - ~ ' - " - ' ' ' - ~ ~ ' " - -
n ~-
- _o.
... m,,....
w.
the Engineering Department Manager issued a memo on April 8, 1980, which strongly emphasized the importance of following procedures with respect to design control.
3.
(Closed) Deviation B.2 (Report 80-01).
Cover pages of specifications for TMI-1 Restart Project safety related items were not imprinted with the phrase " Nuclear Safety Related" nor were they printed on salmon colored paper.
The inspector verified the corrective action and preventive measures described in the G/C lettars of response dated May 20, 1980, June 26, 1980, and August 4, 1980.
Specifically, a list of affected specifications has been prepared and specifications issued or revised after May 1, 1980, cre properly imprinted with the phrase " Nuclear Safety Related" on the salmon colored cover page.
Preventive measures were as described in item 2. above.
4.
(Closed) Deviation B.3 (Report 80-01).
Drawings depicting safety class items for the TMI-1 Restart Project did not exhibit the requisite
" Nuclear Safety Related" notice.
The inspector verified the corrective action and preventive measures described in the August 4, 1980.
Specifically, a list of all affected drawings has been prepared and drawings issued or revised after April 1, l
1980, that depict safety related items are imprinted witn the words
" Nuclear Safety Related." Preventive measures were as described in item 2. above.
OCP 4.15 (Procurement Documents) was revised on August 12, 1980, to include the requirement to properly identify safety related specifications.
5.
(Closed) Deviation C.1 (Report 80-01).
Responses to audit SA 79-1 had not been received nor had corrective action been completed as dalineated in audit IA 79-1.
The inspector verified the corrective action and preventive measures
. described in G/C letters of response dated May 20, 1980, and June 26, 1980.
Specifically, an internal audit was performed to determine the status of responses and corrective actions for internal audits performed in 1979.
All responses were received and corrective actions for 1979 audits were completed as committed.
A supervisory position, Supervisor of QA Audit Program,' was established and the format and distribution of the monthly audit status report was revised to clearly identify the individual responsible for assuring timely and adequate corrective action for audit findings, including those identified in NRC inspection reports, to all G/C management and the QA Policy and QA Advisory committee members.
6.
(0 pen) Follow-up Item (Report No. 80-01, paragraph II.C.3.c.(4)):
It was not apparent that all applicable ANSI Daughter Standard Rec,uirements were inposed on a pump manufacturer (BWC) for the Perry Project.
d
4 The appropriate inclusion of applicable ANSI Daughter Standards in procurement documents will be further evaluated during future inspec-tions.
7.
(Closed) Deviation A (Report 80-02):
Corrective action committed in a G/C response to previous deviations had not been completed as committed.
The inspector verified the corrective action and preventive measures described in G/C letter of response dated October 2, 1980.
Specifically, the Project Management Manual for the V.C. Summer project was submitted to (but not yet approved by) South Carolina Electric and Gas, and the Perry Project safety-related electrical discipline drawings have been revised to indicate completion of design verification.
The Engineering Department Manager issued a series of five letters strongly emphasing assignment of management responsibility for responding to audit findings, engineering total commitment to quality, and the importance of completing corrective action as committed.
Further preventive measures are as described in item 5 above.
8.
(Closed) Deviation B (Report 80-02):
An approved QA Program Plan was not in place and approval for a variation (deviation) from a DCP procedural requirement was not obtained, for the TMI-1 Continuing Services (CS) (Restart) Project.
The inspector verified the corrective action and preventive measures described in G/C letter of response dated October 2, 1980.
Specifically:
(a) The Project Management Manual (PMM) for the TMI-1 CS Project was revised and approved by General Public Utilities (GPU) on May 1, 1980, to include the QA Program and again on November 11, 1980, to reflect commitments in the referenced G/C letter; (b) the G/C procedure for l
processing variances, changes or additions (in PMMs) was revised to conform to the corresponding NQAM requirements on June 20, 1980; (c) DCP 5.10 (Project Management Manual) was revised to describe the correct procedure for obtaining approvals of variances and to require review of all project management manuals to determine if any variances are needed; and (d) a memorandum was transmitted to project management emphasing the requirement that a QA Plan must be in place prior to start of work on any nuclear project regardless of size.
Unresolved Item
(
l G/C has entered into individualized contracts with NRC licensees such l
as Florida Power Corporation, Houston Lightir.g and Power, Pennsylvania l
Power Corporation, South Carolina Electric and Gas, Washington Public
~
Power System and others to provide G/C empicyees on a " loan" basis as well as to provide certain safety related services to them such as design verification, auditing, and QA program effectiveness evaluation.
m.
J Based on the documentation available during the inspection and on personal interviews with responsible G/C management, the inspector could not determine that:
(1) Safety related activities conducted in the licensees facilities are done so under the jurisdiction of the licensee's approved QA Program.
(2) Safety related activities not conducted in the licensees' facilities are done so under the jurisdiction of the G/C QA Program.
9.
(Closed) Deviation C (Report 80-02):
Certain vendor drawings relating to TMI-1 (Restart) were revised by G/C and subsequently issued without the drawing bearing G/C identification.
The inspector verified the corrective action and preventive measures described in the G/C letters of response dated October 2, 1980, and November 10, 1980. Specifically, a list of affected drawings has been prepared, and drawings issued or revised after November 21, 1980, are properly identified with a G/C control identification number and the TMI-1 CS PMM was revised to include Exhibit 5:11 (Procedure for Control of GAI Revisions of Vendor Orawings) and approved by GPU on November 7, 1980.
10.
(Closed) Deviation 0 (Report 80-02):
Certain fluid system diagrams relating to TMI-1 Restart were not design verified in accordance with DCP: 2.05 (Design Verification).
The inspector verified the corrective action and preventive measures described in G/C letters of response dated October 2, 1980, and November 19, 1980.
Specifically:
(a) a list of affected drawings was prepared; (b) design verification of all fluid system diagrams issued or revised after May 1,1979, have been design verified i
and the design verification documents entered into the record; and (c) a full time project mechanical engineer was assigned to l
_ the TMI-1 CS (Restart) project.
11.
(Closed) Deviation E (Report 80-02):
TMI-1 CS (Restart) drawings were revised and issued by other than the originating organization and without interface review.
The inspector verified the corrective action and preventive measures described in the G/C letters of response dated October 2, 1980, and November 10, 1980.
Specifically:
(a) a list of affected fluid system diagrams was prepared and, where appropriate, drawings issued or revised after May 1, 1979, were interface reviewed and revised to a
1 4
g
/ -
reflect the initials of the reviewer; (b) a full time project mechanical engineer was assigned to the TMI-1 CS (Restart) Project; and (c) the Manager of Engineering issued a memorandum on November 10, 1980, stating that the Section Manager shall assure that the responsi-bilities of the project engineer are fulfilled.
12.
(Closed) Deviation F (Report 80-02):
A Corrective Action Request (CAR) log was not maintained.
The inspector verified the corrective action and preventive measures described in G/C letter of response dated October 2,1980.
Specifically, the CAR log was updated, removed from the file room and maintained in the office of the QA Engineering Aide.
Project QA personnel were appraised of the purpose of the log and the necessity for maintaining it.
13.
(Closed) Deviation G (Report No. 80-02):
Approximately fifty percent of the Deviation / Change Requests (DCR) issued for one purchase order were without QA comments or QA program manager signature.
The inspector verified the corrective action and preventive measures described in G/C letter of response dated October 2,1980.
Specifi-cally:
(a) A list of affected DCRs was prepared and those DCRs, not otherwise incorporated into the order by a QA reviewed document, were evaluated by QA for impact on the hardware; and (b) Project QA Engineers were reminded if the requirement for QA review / signature during a project meeting held November 17, 1980.
14.
(Closed) Unresolved Item (Report 80-02, paragraph I.C.3.b):
The existance of the required list of safety related items to which the TMI-1 CS (Restart) Project quality assurance plan is applicable could not be verified.
The inspector reviewed the action described in the G/C letter of response dated October 2, 1980, and determined that the TMI-1 CS (Restart) Project obtained the required list of safety related structures, systems and components (TMI-1 Quality Classification List) to which the QA plan is applicable from GPU on September 11, 1980, and subsequently released it for use by all project engineers.
This item was elevated to a deviation from commitment. See Notice l
of Deviation, Item A.
Since the corrective action described above was completed and a letter was issued by the QA Division General Manager on November 20, 1980, to project management emphasing that such a list must exist for all nuclear projects regardless of project size, no further written response to this deviation is necessary.
2 i
15.
(Closed) Follow up Item (Report No. 80-02, paragraph I.C.3.c(1)):
The G/C procedure for processing reportable events may not permit an individual with a safety concern to ultimately express his concern to the responsible G/C reporting officer.
The inspector reviewed the action described with G/C letter of response dated October 2,1980, and determined that the G/C procedure for processing safety concerns was revised and issued as Appendix E to the G/C NQAM on October 2, 1980.
This revised procedure requires that copies of the originator's safety concern and the Cognizant Manager's evaluations of the potential reportaoility thereof, be transmitted directly 'o the Quality Assurance Divisions General Manager who has bey aesignated as the responsible G/C reporting officer.
16.
(Closed) Follow-up Item (Report 80-02, paragraph 1.C.3.c(2)).
Commitments contained in the GPU TMI-1 Restart Report may not be traceable to design output documents.
The inspector reviewed the action described in the G/C letter of response dated October 2, 1980, and determined that the TMI-1 CS (Restart) Project prepared a list of all tasks / commitments contained in the Restart Report that are within the G/C scope of supply and transmitted the list to the GPU TMI-1 Project Engineering Manager on September 22, 1980.
The list identifies the G/C task number and the responsible engineer associated with each of the tasks and is revisea t
as needed to reflect reassignment of personnel and additional tasks i
as defined by GPU.
17.
(Closed) Follow-uo Item (Report 80-02, paragraph I.C.3.c(3)).
Inconsistances between the commitments to ANSI standards and Regulatory Guides contained in the NQAR GPU TMI-1 Restart and the G/C TMI-1 CS (Restart) Project Management Manual could not be l
resolved.
t l
The inspector reviewed the action described in the G/C letter of response l
- dated October 2, 1980, and determined that no apparent conflicts with respect to the commitments to ANSI Standards and Regulatory Guides exist between Revision 8 of the GPU Operations QA Plan, the latest revision (August 29, 1980) of the NQAM, and the latest revision (November 7, 1980) of the TMI-1 CS (Restart) Project Management Manual.
C.
10 CFR Part 21 Insoection l
1.
Objectives The objectives of this area of inspection were to examine the establish-ment and implementation of procedures related 10 CFR Part 21 and to l
verify that:
l 1
.' 8 ~
~
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 analyses 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 appropriate.
g.
Items determined to be substantial safety hazards were appropriately reported to the NRC.
2.
Method of Accomplishment Review of the following to accomplish the above objectives:
a.
Assured proper posting of Part 21 requirements in all Gilbert /
Commonwealth facilities where safety related activities were being conducted.
b.
Revisions 0 and 1 of G/C QA procedure " Procedure for Processing of Reportable Events:"
c.
GAI/SCE&G purchase orders Q254155, Q259983, Q261333 and Q265446, I
and changes thereto.
d.
G/C identified potentially reportable events (safety concerns) that were processed to Revision 1 of the above procedure:
SN-001 l
(Caoles Supplying Power to Class 1E Battery Charges-10/29/80);
l SN-002 (Containment Vessel, Drywell Structure, Reactor Building Floor liner Plate-11/4/80); and SN-003 (Hilti KWIK-130LTS, Poten-tially all Safety Related Structures-11/4/80) e.
G/C identified potential significant deficiencies that were l
processed in accordance with Revision 0 of the above procedure:
Potential FSAR Violation - Crystal River Unit 3 - 12/27/79; Spacing Between Anchors Below Specifications - V.C. Summers; four G/C specifications; one deviation analysis report; three Possible Reportable Event reports; five letters; five memos; i
and four telecon memoranda.
g 3.
Findings a.
Violations and Deviations There were no violations of 10 CFR Part 21 regulations nor deviations from commitment identified in this area of the inspection.
b.
Unresolved Item G/C did not follow their implementing 10 CFR Part 21 procedure with respect to procedurally unauthorized individuals con-ducting preliminary evaluations of possible reportable events.
This matter has been forwarded to NRC Headquarters for enforcement policy guidance.
c.
Follow-up Item; (1) Training of G/C personnel who conduct safety related activities in the application of the G/C Procedure for Processing of Reportable Events will be followed during future inspections.
(2) Maintenance of records which are required to assure com-pliance with 10 CFR Part 21 requirements will be followed during future inspections.
D.
Design Occument Control 1.
Objectives To determine that approved procedures have been established and are being implemented for the control and distribution of design documents that provide for:
a.
Identification of personnel positions or organiztions responsible for preparing, reviewing, approving, and issuing design documents.
b.
Identification of the proper documents to be used in performing the design.
c.
Coordination and control of design interface documents.
4 gi)4%
4h
$+$
%*4 TEST TARGET (MT-3)
'u E IB 625
.g,3 1.1
['S OllE gI.8 1.25 U l.4 i.6 in e
6"
+%
+ sp
- k k>
'8$h.;k
.g
c,/a e+h.g) k,
/Nff
\\ / Y I ((#
ifg,NNYj
/)e[gh q
NNV\\//jff
/
y e, s v +g,
's <,,
4 4
io e. ev ///;/
^
^
4
%s
~
T
~
~ 10 d.
Ascertaining that proper documents, and revisions thereto, are accessible and are being used.
I e.
Establishing distribution lists whicn are updated and maintained current.
2.
Method of Accomplishment The preceding objectives were accomplished by review of the following documents.
a.
Sections 17.3, 17.5, and 17.6 of the GAI (Gilbert Associates Incorporated) Topical Report GAI-TR-106 (Gilbert / Commonwealth Quality Assurance Program for Nuclear Power Plants), Revision 2A, dated February 1980, to determine the corporate QA programmatic commitments relative to control of design documents.
b.
Sections 3.0, 5.0, and 6.0 of the G/C NQAM (Nuclear Quality Assurance Manual) to determine that the corporate commitments relative to control of design documents were correctly translated into an approved Quality Assurance Program.
c.
Sections (policies and procedures) of the following TMI-1 CS (Restart) Project Management Manuals and Quality Assurance Plans to determine that the corporate commitments relative to control of design documents are accurately reflected in the approved in place Quality Assurance Programs consistent with the G/C scope of supply.
(1) TMI-1 Continuing Services Project Management Manual dated November 11, 1980.
(2) GPUNC (General Public Utilities Nuclear Corporation)
Operational Quality Assurance Plan and TMI Recovery
~
QA Plan - Unit II for Three Mile Island and applied to Units 1 and 2.
(3) GPUNC TMI-1 Restart Report.
(4) GPU Service Standard,No. ES-011 (Classification of TMI-1 Systems and Components) dated July 17, 1979, and TMI-1 Quality Classification List dated September 11, 1980.
a
.,e_.__.
c _. -.. _.
_m
.,_,..,_,,,,,y..
.-y..
11 d.
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 design documents were correctly translated into effective design control procedures.
1.10, Design Input 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 4.15, Procurement Occuments 5.10, Project Management Manual e.
Review of the following design documents to determine if the inplace precedures 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).
Three (3) Design Verification Records.
Thirty-two (32) Drawings.
Five (5) Engineering Change Notices.
Five (5) Specifications.
Three (3) External (Vendor & NSSS) Documents.
One (1) Record Transfer Form.
One (1) Safety Related Equipment List.
3.
Findings a.
Deviations from Commitment One dev'ation from commitment was identified in this area of the "nspection.
(See Notice of Deviation Item 8).
b.
Comment Time did not permit the inspector to complete this area of the inspection.
Objectives b, d, and e above will be pursued during a future inspection.
D.
Exit Meeting An exit meeting vas conducted with Gilbert /Commoonwealth personnel at the conclusion of the inspection on November 20, 1980.
In additon to those 4
33 individuals indicated by an asterisk in paragraph A. above, the meeting was attended by:
R. B. Archibald, Manager of Projects M. Plica, Assistant Project Manager A. W. Grammes, Project Quality Coordinator R. J. Hoffert, Project Quality Coordinator J. W. Foster, Assistant Project Manager F. L. Moreadith, Manager, Structural Department J. C. Weldon, Assistant General Counsel J. B. Muldoon, Manager, Specialty Engineering G. J. Gibson, Project Quality Coordinator, Perry Project P.C. Patton, Assistant Project "anager, Perry Project D. E. Sar. ford, Manager, Quality Systems 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 infomation on the specific intent and scope of 10 CFR Part 21 reporting requirements.
The inspector also discussed Letters of Response to NRC Inspection Reports and emphasized the importance of timeliness in their submission i
and in execution of the action committed therein.
~
l
.