ML20003G628
| ML20003G628 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1981 |
| From: | Breaux D, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003G622 | List: |
| References | |
| REF-QA-99900524 NUDOCS 8104300295 | |
| Download: ML20003G628 (13) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900524/81-01 Program No. 51200 Company:
Gibbs and Hill Incorporated 393 Seventh Avenue New York, New York 10001 Inspection Conducted:
January 26-30, 1981 Inspector:
k 5I
- 0. F. Fox, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch MG 3M 2/66/
- 0. G. Breaux, Inspector Program Evaluation Section/
'Date Vendor Inspection Branch f
Approved by:
k h /b C. J. Ha]3,/ Chief Oate
~
Program Evaluation Section Vendor Inspection Branch Summary l
Inspection on January 26-30, 1981 (99900524/81-01) l Areas Inspected:
Implementation of Title 10 CFR Part 50, Appendix B, including l
Design Document Control, Training, and action on previous inspection findings.
l The inspection involved seventy-five (75) inspector hours on site by two (2) i NRC inspectors.
Results:
In the three (3) areas inspected, there were four (4) nonconform-l ances and one follow up item identified in two (2) of the areas.
l Nonconformances:
Design Document Control:
Design Drawings were not identified l
ir. accordance with project procedure; (See Notice of Nonconformance, Item A.)
l Management Evaluation of the Engineering Department was not performed as scheduled.
(See Notice of Nonconformance, Item B.).
Training:
An Engineering Training course was not conducted as committed.
(See Notice of Nanconformance, Item C.).
Action on Previous Inspection Findings:
Failure to follow the G&H Part 21 procedure in the areas of posting and " safety concern evaluation board" performance.
(See Notice of Nonconformance, Item 0.).
810.4300295*
2 DETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contacted
- R. E. Ballard, Manager of Projects E. L. Bezkor, Job Engineer, Structural E. J. Bond, Supervising Engineer, Special Analysis A. V. J. Burzi, Job Engineer, I&C
- 0. M. Campbell, Administrative Assistant M. Chiruvolu, Supervising Engineer, Chemical L. B. Coggan, Project Engineer, Administration "B. Czarnogorski, Engineer, Quality Assurance
- P. P. DeRienzo, Vice President, Quality Assurance P. B. Ferrara, Supervising Engineer, Design F. W. Gettler, Vice President, Power Generation G. J. Gisonda, Senior Engineer, Licensing / Nuclear E. Horovitz, Asst. Chief Engineer, Mechanical J. Irons, Job Engineer, Mechanical
- N. N. Keddis, Manager, Quality Assurance P. Laurence, Supervising Engineer Structural K. Mittal, Project Engineer, Nuclear P. R. Rajan, Project Engineer, Structural A. Rutkowski, Supervising Engineer, Applied Mechanics
- J. E. Triolo, Supervisor, Quality Assurance T. M. Vardaro, Asst. Chief Engineer, Electrical
- E. J. Zadina, Supervisor, Quality Assurance
- Denotes those present at the Exit Interview.
B.
Action on Previous Insoection Findings 1.
(Closed) Followup (Report 80-01,Section II.C.3.b).
A complete inspection of the FMEA (Failure Mode and Effects Analysis) tech-nique was not possible due to time limitations.
The inspector verified that a draft procedure (Procedure For Pipe Rupture Damage Study) was being used to perform preliminary FMEA pipe rupture damage studies.
Gibbs & Hill Management stated that the procecure is currently being reviseo and will be issued for official use by March 31, 1981.
2.
(Closed) Unresolved Item (Report 30-02,Section I.S.1).
Apparent inconsistencies between the CPSES PSAR commitments, the January 22, 1980 " interface document," the committed vendor audit interface instruction (QA-2), the vendor audit interface instruction (QAI-6),
and the vendor aucit program actually being implemented by G&H could not be resolved during the inspection.
The inspector verified that G&H management has uniquely identified the G&H responsibilities with respect to the vendor audit program and revised procedures QA-2, QAI-4, and QAI ti accordingly.
j 3
3.
(Closed) Violation (Report 80-02) Gibbs and Hill failed to meet the posting requirements for 10 CFR 21 in facilities where safety related activities were being performed.
The inspector verified the corrective actions and preventive measures described in Gibbs and Hill letter of response dated December 19, 1980.
Specifically:
a.
Copies of Section 206 and the 10 CFR Part 21 Regulations and implementing procedures in their entirety were posted in all Gibbs and Hill facilities where safety related activities were being conducted.
b.
Gibbs and Hill developed an abbreviated notice containing Section 206 and describing the content and location of the Regulations and procedures, and the name of the individual to whom reports may be made which will be posed at all locations in lieu of the above by March 31, 1981.
c.
Gibbs and Hill procedure for reporting safety related defects and noncompliances pursuant to 10 CFR Part 21 was revised as committed.
4.
(Closed) Followup (Report 80-02,Section I.C.3.c.(1)).
Existing procedures do not appear to permit an individual with a valid safety concern to ultimately express it to the responsible officer.
The inspector verified that Gibbs and Hill procedure OPO-1 (Reporting Safety-Related Defects and Noncompliance Pursuant to 10 CFR 21) was revised, which improves communication to the responsible officer.
5.
(Closed) Followup (Report 80-02,Section I.C.3.c.(2)).
The timeliness of reporting significant safety related defects and noncompliances to NRC will be evaluated.
Review of the nine (9) Gibbs & Hill 10 CFR Part 21 safety concerns identified and evaluated by Gibbs & Hill to date indicated no untime-liness in reporting to NRC those items deemed to be reportable by the Gibbs and Hill responsible officer.
6.
(Closed) Followup (Report 80-02,Section II.B.3) Maintenance of adequate storage conditions of all QA records will be evaluated.
The inspector determined that of the seven hundred and fifty (750) plus documents that were missing from the QA records at the time of inspection 80-02, all but twenty (20) have been located and incorpor-ated into the QA record file.
Gibbs and Hill management stated that these remaining documents will be incorporated into the QA records by March 31, 1981.
Records relating to the current effort to complete the over fifty thousand backlog of design changes will be completed by September 30, 1981.
9 4
Gibbs and Hill management stated that one set of QA records is being maintained by TUSI on the Commanche Peak Steam Electric Station ~ site, including all microffims and apperature cards.
The other set of QA records, except for microfilms and apperature cards, is being-maintained in the Gibbs and Hill New York offices.
Procedure QA-9 (Quality Assurance Records Retention) was revised.
7.
(Closed) Followup (Report 80-02,Section II.C.3.b).
The status and effect of the freeze instituted by TUSI on incorporating changes into the Gibbs and Hill Flow Diagrams and Composite Piping Drawings could not be determined.
Gibbs & Hill management stated that:
a.
All structural and mechanical drawings have been revised to reflect all changes made to date.
b.
All Flow Diagrams, Electrical One-Line and Three-Line Drawings, Elementary Wiring & Connection Diagrams, and Cable and Raceway Schedules will be revised to reflect all changes by July 31, 1981.
c.
Updating of General Arrangement Drawings, Instrument and Control Diagrams, and Cable Raceway Details will be on an as needed basis.
8.
(Closed) Unresolved Item (Report 80-02,Section I.C.3.a.).
Gibbs and Hill failed to follow their 10 CFR Part 21 implementing procedure, Specifically:
a.
Contrary to the requirements of Section 5.2 of procedure OPD-1, the following information was not posted in-toto on any office building floor where safety related activities were in progress on G&H or domestic nuclear projects:
(1) " Copy of Section 206 of the Energy Reorganization Act of 1974."
(2) " Copy of 10 CFR 21."
(3) " Notice of referring to this document (OPO-1) as detailir.g reporting criteria and procedures and stating the name of the individual to whom reports may be made, and where such reports may be examined."
b.
Contrary to the requirements in the first paragraph of section 6.3 of procedure OPD-1, the QA Manager did not convene, within two regular working days of initial notification (3-5-80), the
" safety concern evaluation board" to evaluate and determine the reportability of identified potential safety hazard 80-01 (Lack of
5 Seismic Qualification of HEPA Filters and Demisters).
The board was convened for consideration of this item on 3-26-80.
Other such examples exist.
c.
Contrary to the requirements in the second paragraph of section 6.3 of procedure OPD-1, the " safety concern evaluation board" did not document the results of all meetings held to evaluate the reportability of potential safety hazard 80-01.
d.
Contrary to the requirements in the third paragraph of section 6.3 of procedure OPD-1, the " safety concern evaluation board" did not complete and sign the required concurrence /nonconcur-rence forms which document the conclusions of the board convened to evaluate the reportability of potential safety hazard 79-03 (Control Room Non-Habitability).
This unresolved item was forwarded to NRC:HQS for enforcement guidance.
That guidance has been provided and this unresolved item has been closed and reissued as an item of nonconformancu.
The inspector verified that appropriate corrective actions were taken by Gibbs and Hill (proper posting and stressing the importance of following procedures), and as further preventive measures 10 CFR Part 21 implementing procedure OPD-1 was revised to more precisely implement the requirements of 10 CFR Part 21.
C.
Design Document Control 1.
Objectives To determine if 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 organizations respons-ible 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 (internal and external) inter-face documents.
d.
Ascertaining that proper documents, and revisions thereto, are accessible and are being used.
e.
Establishing distribution lists which are updated and maintained current.
6 2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine if procedures have been established to control design document generation, review, approval, and distribution in the areas identified in objectives
- a. through e. above:
(1) Sections 17.1.3, 17.1.5, and 17.1.6 of the NRC accepted G&H (Gibbs and Hill) Topical Report GIBSAR-17-A dated June 1976, to determine the G&H corporate programmatic commitments relative to the control of design documents.
(2) Sections 2, 3, and 5 of the G&H CPSES (Commanche Peak Steam Electric Station) Project Procedures Manual and Sections III, V, VIII, and IX of the CPSES Project Guide, to determine if the corporate commitments relat'.ve to control of design documents were correctly translated into quality assurance requirements and procedurec.
b.
The following documents were reviewed to determine if the quality assurance program for control of design documents was being effectively implemented for current design activities affecting quality by the G&H engineering organizations:
(1) Two (2) Audit Reports, (2) Thirty (30) Calculations, (3)
Eight (8) Design Change Inquiry / Authorizations, (4) Three (3) Design / Analysis Procedures, (5)
Fifty-five (55) Design Drawings, G&H Internal, (6)
Five (5) Design Sketches, (7) Nine (9) Drawings, Vendor Field Change / Authorizations and transmittals thereof, (8)
Six (6) Design Verification Documents, (9) Three (3) Failure Mode and Effects Analysis, (10) Twelve (12) Field Change / Authorizations and transmittals
- thereof,
7 (11) One (1) Procurement Authorization, and (12) Seventeen (17) Specifications.
3.
Findings Nonconformances Two (2) nonconformances were identified in this area of the inspection.
See Notice of Nonconformance.
With respect to Nonconformance; Item A:
The sheet number of three (3) of four (4) examined instrumentation and control drawings (2323-M1-2206-03, 2323-M1-2210-10 and 2323-M1-2210-09) was not indicated by the numerical suffix to the drawing number.
The sheet number of thirty-two (32) out of thirty five (35) examined structural drawings (2323-S1-0595-04, 2323-S1-0589-01, 2323-S1-0585-01, and others) was not indicated by the numerical suffix to the drawing number.
The sheet number of seven (7) and of eight (8) examined mechanical drawings (2323-M1-0233, 2323-M1-0234, 2323-M1-0231, and others was not indicated by the numerical suffix to the drawing number.
D.
Exit Interview An exit interview was held with management representatives on January 30, 1981.
In addition to those individuals indicated by an asterisk in para-graph A of each Details Section, those in attendance were:
L. Mesick, Administration Specialist H. R. Rock, Vice President of Projects The inspector summarized the scope and findings of the inspection and the form and content of contractor letters of response to NRC inspection reports.
Management comments were generally for clarification only, or acknowledge-ment of the statements by the inspector.
8 DETAILS SECTION II (Prepared by D. G. Breaux)
A.
Persons Contacted J. C. Alberti - Manager, Employment E. L. Bezkor - Supervising Engineer, Structural
- B. Czarnogorski - Engineer, Quality Assurance J. L. Eichler - Chief, Engineer Structural
- J. A. Gaynor - Engineer, Quality Assurance
- N. N. Keddis - Manager, Quality Assurance
- L. T. Mesick - Administrative Specialist
- M. S. Miller - Supervisor, Quality Assurance
- G. J. Steidle - Employee Relations Supervisor
- J. E. Triolo - Supervisor, Quality Assurance
- E. J. Zadina - Supervisor, Quality Assurance
- Denotes those present at the Exit Interview.
B.
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 assurance elements that are to be employed.
(2) On the job participation through actual performance of pro-cesses, 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 inoividual capabilities are not in accordance with specified qualif. cations.
9 (5) Records of training received by each person including applicable 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 fundamcatals, objectives, characteristics, organization, performance and results.
(3) Specialized training in methods of examining, questioning, evaluating, documenting specific audit items, ard methods of closing out audit findings.
(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 pro-gram 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.
Documentation of attendance and retention of other applicable records for all formalized training accomplished.
2.
Mothod of Accomolishment i
The preceding objectives were acccmplished by reviewing the following documents relative to the Gibbs & Hill Quality Assurance Program.
a.
The appropriate sections of Chapter Seventeen (17) entitled
" Quality Assurance" for the Commanche Peak Steam Electric Station Final Safety Analysis Report were reviewed for reference of the establishing of a formal indoctrination and training or re-training program.
This program and its responsibilities l
were to be formalized in subsequent Gibbs & Hill Quality Assur-ance Procedures.
10 b.
In the Gibbs & Hill Quality Assurance Procedures Manual, QA-5 was reviewed to assure that a procedure was in place estab-lishing the guidelines for the indoctrination and program designed to achieve and maintain proficiency of Gibbs and Hill personnel in knowledge, understanding and application of the Gibbs and Hill Quality Program and Procedures.
This procedure (QA-5 " Procedure for Indoctrination and Training" Revision 3 dated November 3, 1979) describes certain indoctrination and training program descriptions for different personnel performing certain safety-related activities.
This procedure also defines certain management responsibilities in the area of program development.
c.
The Comanche Peak Steam Electric Station Project Procedures Manual and Project Guide were reviewed for definition of Gibbs and Hills quality related activities during the construction phasr, of this project.
This formulation was to assist the inspector in concluding that all indoctrination and training of personnel performing safety related activities were identified in the guidelines of Quality Assurance Procedure QA-5.
d.
The following Quality Control Precedures were reviewed for evidence of the formation and implementation of an indoctrina-tion and training program for QC personnel.
This is to assure that if Gibbs and Hill QC inspectors assist in safety-ralated vendor shop surveillances in the future; the training program is formed and functioning properly.
All shop surveillances are at this time under the direction of TUGC0 (Texas Utilities Generating Company).
(1) QCP-1 " Quality Control Personnel Certification" Revision 1 May 29, 1979.
(2) QCP-7 " Procedures for Training and Indoctrination of Quality Control Personnel" Revision 1, August 1, 1979.
e.
To assure that procedural requirements are being properly and effectively performed the following were reviewed:
(1) Quality Assurance file of QA training seminars for QA Personnel.
This file included attendance request memos which contained an outline of the training seminar to be given.
An attendance sheet was also included in the file of ten (10) QA training seminars conducted from January 12, 1979 - June 27, 1980.
11 (2) Ten (10) QA Auditor training qualification files were reviewed for proper content and procedural implementation.
(3) Reviewed the QA Indoctrination Seminar file with respect to personnel performing safety related actifities.
(4) File documenting the training program presented to engineer-ing and design personnel in the area of design review.
Reviewed four (4) seminars given.
(5)
In the Structural Engineering Design Department the following training was reviewed:
(a)
In-House Technical Structural Course consisting of 16 sessions over a four (4) month period.
(b) Structural Department Information Workshops which included such subjects as:
Removal of Drawings and Calculations from files.
Preparation and checking of Structural Calculations.
(6) The following Quality Assurance Department Technical Development Training File was reviewed and included such specified training as:
(a) Nuclear Waste Management and Technology (b)
Lead Auditor Training Course; given by General Atomic, San Diego (7) Ten (10) Quality Control Inspectors Training and Qualifi-cation files were reviewed for proper content and complete-ness of NOE certifications.
(8) Quality Control Training Session files were reviewed and contained six (6) sessions dating from September 7, 1976 to July 8, 1980.
3.
Findings a.
In this area of the inspection, one (1) nonconformance was identified.
(See Notice of Nonconformance, Item C).
C.
Technical Personnel Background Verification 1.
Objectives
12 To verify that measures have been established and are being effec-tively implemented that assure:
a.
The education and work experience information contained in employee job applications are being verified by the employing organization.
b.
There is objective documented evidence / records that attest to the employee's education and experience.
2.
Method of Accomolishment The preceding objectives were accomplished by reviewing the~ following documents relative to Gibbs and Hill Personnel activities, a.
The appropriate sections of Gibbs and Hill Personnel Policies and Procedures Manual were reviewed for evidence that personnel background verification is established.
(1)
Policy Statement A-1 " Employment" dated February 1977 states; "The personnel department reserves the right to verify any and all statements contained in a company employment application or personal resume before and after employment.
Any misrepresentation may be cause for dismissal."
(2)
Policy Statement A-4 "Part-Time Enployees" dated February 1977 states; "Part-Time applicants are subject to same recruiting procedures as full-time employees."
(3) Policy Statement B-5 " Employee Records" dated February 1977 states; " Personnel department responsibility for coordinating accurate reference verification to outside inquiries.
These include:
Academic Degrees earned, Professional Registration acquired."
b.
Two (2) inter-office memos dated October 6, 1980, and October 29, 1980, " Employment Procedures," were reviewed and provided evidence that a concerted effort in response to the NRC Inspection and Enforcement Circular on personnel background veri-fication was in process.
c.
To assure that procedural requirements are being properly and effectively performed, the following were reviewed.
(1) Ten (10) Technical Personnel files were reviewed for content of education and past employment verification documentation.
i
-l 13 (2) Five (5) Employment Applications.
(3) Five (5) telephone reference check forms.
(4) Ten (10) Educational Verification forms.
3.
Findings General In the review of personnel files there was sufficient documentation of background verification.
In response to the NRC Inspection and Enforcement Circular on background verification, the personnel department is revising policies and procedures to address this concern.
In an attempt to standardize this verification process, there is a commitment to formulate personnel office instructions in the area of verification processes.
Nonconformances and Unresolved Items None were identified.
Followuo Item Ouring subsequent inspections the previously described verification policies and procedures will be reviewed to assure that the concerns expressed in NRC Inspection and Enforcement Circular on background veri-fication are addressed.
Further, verification will be made that the Personnel Department background verification activities are described in a departmental instruction formulated by the Gibbs and Hill Personnel Manager.
..