ML20009G653
| ML20009G653 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1981 |
| From: | Chamberlain D, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20009G642 | List: |
| References | |
| REF-QA-99900510 NUDOCS 8108040515 | |
| Download: ML20009G653 (9) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900510/81-02 Company:
United Engineers and Contructors, Incorporated 30 South 17th Street Philadelphia, Pennsylvania 19101 Inspection at: Philadelphia, Pennsylvania Inspection Conducted:
June 1-5, Inspectors:
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hb$f J. R.LGbstello, Coritt' acto'r Inspector Date Reactor Systems Section Vendor Inspection Branch L
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s D. D. Qhjiberlain, Contfart6f Inspector Date Reactor Systems Section' Vendor Inspection Branch Approved by:
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Date Reactor ystems Section Vendor Inspection Branch Summary Inspection on June 1-5, 1981 (99900510/81-02) i Areas Inspected:
Implementation of 10 CFR Part 50, Appendix B criteria in the areas of supplier nonconfo mance and corrective action, QA records, technical personnel background verification, and status of previous inspection findings.
The inspection involved 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> on site by two NRC inspectors.
Results:
In the four areas inspected, two unresolved items were identified in two areas. There were no nonconformances.
0108040515 810626 PDR GA999 EECONEC 99900510 PDR
2 Unresolved Items:
Supplier Nonconformance and Corrective Action.
It is not apparent to the inspector that the present WPPSS Nuclear Project Procedure No.
41 (Significant Project Change Proposals) represents desired operating practices (See DetailsSection I, paragraph D.3.b).
Records.
A long term storage area for the hard copy QA records on the Seabrook project does not appear to meet the requirements of ANSI N45.2.9 (See DetailsSection II, paragraph B.3.b).
3 DetailsSection I (Prepared by J. R. Costello)
A.
Persons Contacted E. H. Bamford, Director Industrial Relations
- R. H. Leonard, Assistant Manager, Reliability and Quality Assurance (R&QA)
- B. C. Low, Supervising Engineer Quality Systems W. N. MacIntyre, Assistant Supervising Engineer Vendor Surveillance R. H. Marsh, Manager Quality Assurance Audits W. R. Morrison, Supervising Engineer Vendor Surveillance
- T. G. Mudge, Supervising Engineer Project Quality J. H. York, Change Management Coordinator
- Indicates those present at the exit meeting.
B.
Stat s of Previous Inspection Findings 1.
(Closed) Deviation (81-01):
Contrary to precedures, some Vendor Surveillance Check Plans were not signed as required.
UE&C has changed the requirements in WPPSS Quality Assurance Proce-dure QA-7-2 to allow a stamp, initials or full signature rather than just a full signature. This change was approved May 29, 1981.
2.
(Closed) Deviation (81-01):
Contrary to procedures, some vendor surveillance files did not have a Vendor Surveillance Check Plans.
The vendor surveillance representatives involved have resubvitted the missing Vendor Surveillance Check Plans which are now on file.
The requirement to submit Vendor Surveillance Check Plans with the Vendor Surveillance Reports is being reemphssized in the ongoing training sessions conducted by the Supervising Engineer, Vendor Surveillance.
In addition, an audit was conducted of 373 Vendor 3
Surveillance Reports from the WPPSS and Seabrook projects.
This audit disclosed an additional 17 reports without the full check plans or a 4.5% noncompliance.
The full check plans for these 17 reports were reconstructed from the summaries in the inspection reports.
Due to the low incidence of noncompliance, and the ability to reconstruct any missing check plans from available reports, no further action is planned.
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4 3.
(Closed) Deviations (81-01):
UE&C did not complete on the date specified the committed actions relative to a previous inspection finding.
A UE&C memorandum dated April 15, 1981, has been issued to Project Managers and those personnel responsible for the ir..plementation of procedure GEDP-0034 (Response to Audits, Corrective Action Requests and Other Quality Assurance Reports).
This memorandum calls attention to the requirement for completing corrective action on the required date and insisting on full compliance.
Also, R&QA has conducted a verification audit of the file, log, and follow up records for audits, corrective action requests and other quality assurance reports with no further cases identified.
C.
Technical Personnel Background Verification 1.
Objectives To inspect further the system described in our 99900510/81-01 report for verifying employee educational and employment background.
2.
Method of Accomplishment Examined the implementation of Industrial Relations procedure, Procedure for Verification.
3.
Findings Since the 81-01 inspection, UE&C has modified and improved tn2ir method of verifying employee educational and employment background.
This is described in a new Industrial Relations organization proce-dure entitled " Procedure for Verification."
At the time of the 81-01 inspection, UE&C was not using a signed release from the prospective employee to obtain information regarding former experience and educational background. Without the signed release some difficulty was experienced in obtaining personnel information.
UE&C's Industrial Relations organization, utilizing the new procedure, obtains a signed release from the employee for obtaining background information.
This procedure is being used on all new employees and UE&C intends to go back and update records of employees hired within the last three years.
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i D.
Supplier Nonconformance and Co.'rective Action 1
1.
Objectives The objectives of this area of inspection were to verify that proce-dures have been established and implemented for:
a.
Disposition of nonconformances that provides for:
(1) Identification, control, and disposition of items or services that do not meet procurement documents requirements.
(2) Submittal of nonconformance notice by supplier for review, approval, and disposition by the purchaser.
b.
Corrective action that prov* des for:
(1) Identification of and timely corrective action of condi-tions adverse to quality.
(2) Review and evaluation of conditions adverse to quality.
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(3) Reporting these conditions and the corrective action to l
management.
(4) Assuring that corrective action is implemented and main-tained.
4 2.
Method of Accomplishment The prceeding objectives were accomplished by an examination of:
a.
Chapter 17.2 of the Preliminary Safety Analysis Report (PSAR)
I for Seabrook Station Units 1 and 2.
b.
Chapter 17.2 of the Preliminary Safety Analysis Report (PSAR) for WNP-1.
c.
Quality Assurance Standards VII-1, VII-2, XV, and XVII.
d.
General Engineering and Design Procedures GEDP-0034 and GEDP-0046.
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6 e.
WPPSS Quality Assurance Procedures QA-15, QA-16, and QA-16-1.
f.
Seabrook Quality Assurance Procedures QA-7-1, QA-7-2, QA-15, QA-16-1, and QA-16-2.
g.
WPPSS Project Procedures PP19, PP32, PP33, and PP41.
h.
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:
(1) Five Significant Project Change Proposals; PCP 14S0012A, PCP 14500001D, PCP 14S00079, PCP 145000120, and PCP 14X00016.
(2) Four Quality Control Vendor Surveillance Reports; Cives Steel Co., Crosby Valve and Gage Co., Gould Inc., and PX Engineering Co.
(3) Six Quality Assurance Audit Reports; PX Engineering Co., Cives Steel Co., Masoneilan International Inc.,
York Electro Panel Co. Inc., Gould Inc., and Barton Instruments.
(4) Five Stop Work Orders; Nos. 002, 003, 004, SS-03, and SS-04.
(5) Eight Corrective Action Reports; Nos. 024, 030, 031, 051, 053, SS017A, SS023, and 5S024.
(6) One Deficiency Report DR-1.
(7) Five Contract Waiver Requests; CWR 10, CWR 14, CWR W-3, CWR W-8, and CWR W013.
(8) Four Corrective Action Requests; Nos. H020, H021, H026-1, and H039-B.
(9) Thirteen Vendor Notification Reports; Nos. 15335, 14560, 15425, 16027, 16192, 15243, 15974, 6899, 15938, 18227, 17458, 15969, and 16374.
7 3.
Findings a.
No nonconformances were identified in this area of the inspec-tion.
b.
One unresolved item was identified.
WPPSS Nuclear Project Procedure No. 41 does not represent present practices and is in the process of being revised.
The Significant Project Change Proposal form now used is not the same as the one in the present WPPSS Nuclear Project Procedure No. 41. With the present Project Procedure No. 41, the inspector was not able to determine (1) if block 4 needed to be initialed by the Project Business Manager, (2) if the date authorization required in block 12 needs to be filled out, (3) how required discipline review is identified in block 17 and (4) why Project Change Proposal PCP 14500120, which required a PSAR/FSAR change and a licensing review, did not have a licensing signature and date.
E.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on June 5, 1981.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance were:
G. F. Cole, Manager Nuclear Projects H. C. Grau, Project Engineering Manager J. B. Silverwood, Manager Reliability and Quality Assurance G. L. Visco, Manager Department Management Services The inspector summarized the scope and findings of this inspection for those present at the meeting.
Management representatives acknowledged the statements of the inspector.
The inspector also notified those present that Mr. D. D. Chamberlain would be the assigned principal inspector for all future inspections at UE&C.
8 DetailsSection II (Prepared by D. D. Chamberlain)
A.
Persons Contacted E. H. Bamford, Director of Industrial Relations W. F. Bergan, Microfilm Supervisor A. W. Cole, Project Administrator M. I. Hill, Administrator R. A. Kirk, Head Nuclear /Mechtnical Design-K. G. Lingappan, Supervising Nuclear / Mechanical Engineer R. H. Marsh, Manager Quality Assurance Audits G. J. Neuberger, Administrator W. J. Valinote, Administrator J. H. York, Change Management Coordinator B.
QA Records 1.
Objectives The objectives of this area of the inspection were to examine the establishment and implementation of quality related procedures'for collecting, filing, storing, maintaining, and dispositioning of QA records to verify that:
a.
A QA records system is defined, implemented, and enforced for all groups performing safety related activities.
b.
QA records are legible, completely filled out, and adequatel' identifiable to the item involved.
c.
A specific submittal plan for QA records is established between the licensee and contractor, d.
A designated authority has been assigned to control the receipt and storage of QA records.
e.
The QA record system is periodically audited.
2.
Method of Accomplishment The preceeding objectives were accomplished by an examination of:
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a.
Commitments (1) Section 17.2.17 of the Preliminary Safety Analysis Report for Seabrook Station Units 1 and 2.
(2) Section 17.2.17 of the Preliminary Safety Analysis Report for WNP-1.
b.
Procedures (1) Quality Assurance Standard XVII.
1 (2) Seabrook Quality Assurance Procedure QA-17.
(3) Seabrook Administrative Procedure No. 2.
(4) WPPSS Project Procedure No. 34.
(5) General Administrative Procedures GAP-0011 and GAP-0014.
I c.
Documents i
(1) 3eabrook Project (a) UE&C Drawing Nos. 800157, 8001655, 805023, 805028, 805750, 805000, and 801821.
(b) Specification Nos. 201-1, 248-31, 255-1, 137-2, 137-1, 145-2, 113-1, 118-1, 119-3, and 238-3.
(c) Vendor Drawing Nos. 20588, 20616, 20704, 31349, l
31374, and 31396.
l (d) Audit Report Nos. NH-366, NH-293, NH-282, and NH-208.
(2) WPPSS Preject (a) UE&C Drawing Nos. 805295, 805307, 805328, 805447, j
805485, and 805503.
(b) Specification Nos. 38 and 47.
(c) Vendor Drawing Nos. 50248, 50490, 50500, 51248, 51618, and 52691.
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10 (d) Audit.:eport Nos. WP-275, WP-193, WP-107, WP-47, WP-25,81-173, and 80-165.
3.
Findings a.
No nonconformances were identified in this area of the inspection.
b.
One unresolved item was identified.
The long term storage area for the hard copy QA records on the Seabrook project does not appear to meet the requirements of ANSI N45.2.9 for protection of records from possible destruction or deterioration (i.e., the QA records are stored at the top level of a metal building within a few feet of the sheet metal roof.
No air conditioning is provided and the records would be subjected to extreme temperature and humidity variations).
However, UE&C has duplicate records storage in other locations and will provide the NRC inspector with information on the other locations during the next inspection.
The NRC inspector will evaluate the adequacy of the duplicate storage at that time.
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