ML20003G293
| ML20003G293 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1981 |
| From: | Chamberlain D, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003G288 | List: |
| References | |
| REF-QA-99900505 NUDOCS 8104280697 | |
| Download: ML20003G293 (12) | |
Text
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m0 V. S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900505/81-01 Program No. 51200 Company:
EBASCO Services, Incorporated Two World Trade Center New York, New York 10048 Inspection at:
New York, New York Inspection Conducted:
February 2-6, 1981 q
Inspectors:
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J. R. 'Castello, Principp Knspector Cate Program Evaluation Section Vendor Inspection Branch b
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- 0. 0 @ amberlain, Co p rfctor Inspector Date Program Evaluation Section Vendor Inspection Branch Approved by:
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C. J. Hal V Chi'ef, Program Evaluation Section Date Vendor Inspection Branch Summary Inspection on February 2-6, 1981 (99900505/81-01)
Areas Inspected:
Implementation of Ebasco Topical Report No. ETR-1001 in the areas of design process management, audits, action on previous inspection findings and technical personnel background verification.
The inspection involved sixty-two (62) inspector-hours on-site by two (2) USNRC inspectors.
Results:
In the four (4) areas inspected, three (3) nonconformances were identified in one (1) area and one (1) unresolved item plus one (1) follow up item were identified in another area.
There were no findings in two (2) areas.
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2 Nonconformances:
Audits:
Activities affecting quality which were formerly per-formed by the Senior Vice President Nuclear have not been reassigned in procedures QA-II-9, QC-7 and A-45, (See Notice of Nonconformance, Item A).
The records of audits performed by two (2) auditors were not being documented and maintained (See Notice of Nonconformance, Item B).
The internal audits required for St. Lucie No. 2 for calendar year 1980 were not performed (See Notice of Non-conformance, Item C).
Unresolved Item:
It is not apparent that all the written criteria had been prepared and signed for the development of a WPN 3/5 logic diagram (See DetailsSection II, paragraph B.3.b).
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3 DetailsSection I (Prepared by J. R. Costello)
A.
Persons Contacted J. E. Buckley, Manager Corporate Employment A. M. Contino, Education Specialist F. F. Ford, Quality Program Coordinator
- J. M. Gushue, Principal Engineer C. B. Hickey, Assistant Engineer, Quality Assurance M. A. Kerin, Principal Engineer D. M. Manion, Manager Professional and Technical Employment J. H. Northfield, Lead Engineer, Procedures J. M. Riffle, Personnel Supervisor
- S. Sparacino, Superviscr, Quality Assurance Engineering
- R. F. Williams, Supervisor, Quality Assurance Engineering S. V. Wright, Supervisor, Document Control
- Indicates those present at exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Unresolved Item (80-01):
It is not clear whether the PSAR commitments to ANSI daughter standards and/or the Gray Book for two (2) projects requires passing these commitments on to vendors either by incorporation or reference in the purchase order, when applicable to the vendor's scope of work.
All of the purchase orders:
(1) issued prior to issue of Ebasco Specification 860-75 (Quality Control Requirements For Suppliers of Equipment and Services), and 860-W-RCV.2 (Contractor Quality Assurance Requirements for WPPSS) which imposed the daughter standards and; (2) issued after the PSAR commitments to the Gray and Green Books, were reviewed.
In those cases where material had not been delivered to the site, the daughter standards are being imposed.
In those cases where material has been delivered, the Supplier Quality Program Evaluation checklists used at that time have been reviewed and these reviews show that the essential require-ments of the daughter standards have been covered.
2.
(0 pen) Follow up Item (80-01):
Determine the status and final disposition of PSAR Change Requests Nos. 083 and 084 for WPPSS
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which indicate adoption of a new QA Program to replace ETR-1001 (which was adopted on PSAR Change Request No. 50) and the original QA Program described in the PSAR.
SAR Change Requests No. 083 and 084 (actually No. 085) were made to adjust the QA program to changing responsibilities at the site.
SAR Change Request No. 085 was rejected by Ebasco licensing on the l
basis it would not be acceptable to NRC.
SAR Change Request No. 092 has now been issued to supersede No. 085 and has been approved by Ebasco licensing, but not by WPPSS or NRC.
Review of this SAR Change I
4 Request by the inspector shows that it does not represent present QA practices, appears to have conflicting requirements, and is negating present Regulatory Guide commitments in favor of Gray and Green Book commitments.
Our future inspections will continue to follow this item.
3.
(Closed) Follow up Item (80-01):
Determine why procedure E-77 titled "Section Identification and Documentation of Design Inputs" is not listed in the Topical as a quality affecting implementing procedure.
Also, why procedure E-77 does not reference E-52 titled
" Coordination of NSSS Interfaces" or list codes, standards and regulatory requirements (including applicable issue and/or addenda) per ANSI N45.2.11, Section 3.2.
The aforementioned deficiency in procedures has been recognized by Ebasco and is being corrected.
Procedure E-76 and E-77 are being combined and will be reissued as E-76 about mid-March.
E-76 is listed in the Topical Report ETR-1001 as a quality affecting pro-cedure and the revised E-76 procedure will reference procedure E-52.
C.
Technical Personnel Background Verification 1.
Objectives To verify that measures have been established and are effectively implemented that assure:
a.
The education and work experience information contained in employee's job applications are being verified by the employing organization.
b.
There is objective and documented evidence / records that attest to the employee's education and experience.
2.
Method of Accomolishment The preceding objectives were accomplished by examination of:
(a) " Personnel Practices Manual - Employment Practices," dated October 1976.
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(b) "Information Release Statement," dated May 2, 1980.
(c) Personnel files of six (6) employees.
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Findings Ebasco verifies education and experience in writing.
Employees are asked to sign a release to obtain this information.
The personnel department normally check the last three (3) places of employment unless the employee has worked for a long period of time in either of his last two (2) jobs.
If an empicyee falsifies his employment application, he is dismissed.
Ebasco, as a matter of policy, makes a telephone check with the employee's last supervisor.
Agencies furnishing contract employees are asked to certify that they have verified their employees' background.
Recently, Ebasco has instituted a follow up on contract employee backgrounds through an independent agency.
In cases where the employee's education and/or experience are in a foreign country, Ebasco's efforts include obtaining copies of certi-ficates showing completion of a course of study plus attempts to verify employment in the foreign country.
No nonconformances or unresolved items were identified in this area of inspection.
D.
Audits 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
An 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 of the person or organization to be audited.
c.
Members of the audit team are independent of any direct responsibility for the activities being audited.
6 d.
Provisions exist for the reporting of the effectiveness of the Quality Assurance Program to responsible managemert.
e.
The audit includes the use of checklists or procedures, detailed audit reports, timely identification, acknowledge-ment, documentation of nonconformances, subsequent 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 recommendations for correction, and distribution of the report to responsible management.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Nuclear Quality Assurance Program Manual ETR-1001, Revision 8, Sections QA-I-3, QA-I-5, QA-I-6, and QA-II-9.
b.
Nuclear Licensing Department Procedure L-3, Revision 1 (Pro-cessing SAR Change Requests).
c.
Quality Assurance Engineering Procedures QA-0.5, Revision 7 (Internal Audits); QA-G.3, Revision 5 (QLalification of QA Audit Personnel).
d.
Quality Program Procedure QC-7, dated February 2, 1977 (Quality Assurance Audits).
e.
Administrative Procedure A-45, dated December 20, 1976 (Ebasco Management QA Audit Committee Procedure).
f.
Ebasco Quality Program for Florida Power and Light, St. Lucie No. 2, Procedure QC-7/PSL-2, Revision C (Quality Assurance Audits).
I g.
Documents to verify implementation of quality assurance pro-gram commitments, procedural requirements, and to satisfy the intent of the objectives section.
These documents are as follows:
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7 (1) Ebasco Management Quality Assurance Annual Audit Report No. 2-80, June 27, 1980.
'(2) Monthly schuule and report of internal audits (a) January thru December 1980, St. Lucie (b) January thru December 1980, Waterford (3) Six month schedule matrix of internal audits (a) January 1980 - June 1980 (b) July 1980 - December 1980 (4) Engineering Audit Plan for Engineering and Design Audit No. AP-4, Revision 5.
(5) Internal audits of St. Lucie No. 2:
(a) No. 1295, Instrumentation and Control Engineering, July 16, 1980 (b) No. 1189, Mechanical Nuclear Engineering, February 6,1980 (c) No. 1271, Purchasing Department, June 18, 1980 (d) No. 1290, Applied Physics-Radiation Monitoring, July 30, 1980 (e) No. 1326, Licensing, September 30, 1980 (f) No. 1334, HVAC Engineering, October 9, 1980 (6)
Internal Audits of St. Lucie No. 1:
(a) No.1272, Mechanical Nuclear Engineering, June 4,1980 (b) No. 1273, HVAC Engineering, June 19, 1980 (c) No. 1274, Electrical Engineering, June 19, 1980 (d) No. 1275, Instrument and Control Engineering, June 19, 1980 (7) Audits of three different vendors.
8 (8)
Reports of internal audits for the 1st and 2nd quarter of 1980, all dated August 18, 1980.
(9) Reports of audits for the 3rd and 4th quarters of 1980, for St. Lucie No. 2, dated January 31, 1981.
(10) Facility audit status reports for December 1980 and January 1981.
(11) Quality Assurance Trend Analysis Report 010 covering the 1st and 2nd quarters of 1980.
(12) Training, qualification and experience records of eleven randomly selected auditors.
3.
Findings a.
Nonconformances See Notice of Nonconformance enclosure, Items A, B and C.
b.
Unresolved Items and Follow Up Items None were identified.
E.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on February 6, 1981.
In addition to the individuals indicated by an asterisk in the Detail Sections, those in attendance were:
R. B. Kosinski, Quality Assurance Engineer B. R. Mazo, Chief, Quality Assurance Engineer B. E. Tenzer, Vice President, Materials Engineering and Quality Assurance H. Worchel, WPPSS Project Engineer The inspector summarized the scope and findings of the inspection for those present at the meeting.
Management representatives acknowledged the statements of the inspector.
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9 DetailsSection II (Prepared by D. D. Chamberlain)
A.
Persons Contacted A. L. Castelli, Lead Instrumentation Engineer K. P. Chang, Supervising Design Engineer F. X. Ciulla, Project Designer J. Das, Lead Control Engineer W. Fong, Associate Engineer R. J. Gaudio, Lead Systems Engineer J. T. Grillo, Lead Electrical Engineer C. B. Hickey, QA Engineer Y. C. Jain, Lead Engineer A. C. Jugo, Design Supervisor Instrumentation
- R. Kosinski, QA Engineer M. G. Landa, Senior Associate Engineer T. P. Morales, Assistant Project Engineer
- 8. R. Parry, Design Supervisor (Acting)
C. A. Peart, Assistant Engineer T. Rock, Design Group Supervisor
- H. Worchel, Project Engineer M. K. Yates, Project Manager
- Denotes those present at exit meeting.
B.
Deisgn Process Management 1.
Objectives The objectives of this area of inspection were to examine the establishment and implementation of quality related procedures for the design process to verify that:
a.
The design process system is defined, implemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups performing safety-related activities.
b.
Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures.
c.
Appropriate quality standards for items important to safety are identified, documented, and their selection reviewed and approved.
d.
Final design can be related to the design input with this traceability documented, including the steps performed from design input to final design.
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10 e.
Design activities are documented in sufficient detail to permit design verification and auditing.
f.
The methods are prescribed for preparing design analyses, drawings, specifications, and other design documents so that they are planned, controlled, and correctly performed.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
ETR-1001, Ebasco Nuclear Quality Assurance Program Manual for Washington Public Power Supply System (WPPSS) Nuclear Projects Nos. 3 and 5:
(1) Section QA-I-1, Revision 5, Quality Assurance Program; and (2) Section QA-I-4, Revision 1, Design Control b.
Engineering Procedures:
(1)
E-1, November 20, 1979, Review of Vendor Drawings.
(2)
E-7, April 2, 1979, Processing Drawings for Review and Approval.
(3)
E-9, November 20, 1979, Processing Conceptual Design Documents for Review and Approval.
(4)
E-15, July 20, 1980, Preparation of Ebasco Standard 4
Specifications.
(5)
E-19, November 20, 1979, Docur.entation, Processing and Resolution of Specification Technical Questions from Bidders.
(6)
E-21, November 20, 1980, Processing Project Equipment Specifications for Review and Approval.
(7)
E-30, November 20, 1979, Preparation of Calculations.
c.
Eleven design drawings for WPPSS Nuclear Projects Nos. 3 and 5.
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Five procurement specifications for WPPSS Nuclear Projects Nos. 3 and 5.
e.
Seven design calculations for WPPSS Nuclear Projects Nos. 3 and S.
f.
WPPSS Nuclear Projects 3 and 5, documentation review requirements for drawings and specifications, dated March 1980 and respectively.
3.
Findings a.
Nonconformances In this area of the inspection, no nonconformances were identified.
b.
Unresolved Item In this area of the inspection, one unresolved item was identified as follows:
Engineering procedure E-7 states in part:
The criteria shall be put in writing, or in the form of sketches, schematics, one line diagrams, calculations, etc., signed by the Lead Discipline Engineer and signed where required by the Design Group Supervisor (Electrical Mechanical-Nuclear, HVAC and I&C Departments) acknowledging understanding, and approved by the Supervising Engineer prior to verification (checking) of the design.
During this !nspection, documentation was not made available to the inspector to verify that written criteria had been prepared and signed for the development of the Diesel Logic Diagram G-6055 on WPPSS Nuclear Projects 3 and 5.
The inspector was advised that a sketch had been prepared and used for the development of G-6055 to meet the requirements of procedure E-7.
However, the sketch could not be located during the inspection, therefore; this item will remain unresolved until the next inspection.
c.
Follow Uo Item The WPPSS Nuclear Projects 3 and 5 Documentation Review Requirements for Design Drawings Revision 6 dated March 1980, was issued for review and comment on March 13, 1980.
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12 Engineering procedure E-7 requires resolution of comments on updated lists anG then the signing of a cover sheet by the Project Enginear, Quality Assurance Engineer, Project Licensing Engineer and Manager of Construction Services.
This resolution of comments nd sign-off has not been completed for Revision 6 as of February 5, 1981.
Although there is no time limit specified in procedure E-7 for resolution of comments and sign-off, sufficient time has elapsed for resolution of Revision 6 of this list.
A follow up of this item will be conducted during the next inspection to determine the timeliness of comment resolution and sign-off.
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