ML20010J202
| ML20010J202 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010J175 | List: |
| References | |
| REF-QA-99900502 NUDOCS 8109290701 | |
| Download: ML20010J202 (3) | |
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Brown and Root, Inc.
Docket No. 99900502/81-02 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted April 13-17, 1981, it appears that certain of your activities were not conducted in accordance with NRC require-ments.
A.
Criterion V of Appendix B to 10 CFR Part 50 states that activities affecting quality shall be accomplished in accordance with instructions and procedures.
Sections 3.0 and 2.5 of Brown and Root procedure STP-PM0-022 (Procedure for Evaluating and Reporting of Defects, Noncompliances and Deficiencies) respectively state ir. part that, "Each defect, noncompliance or deficiency evaluated by the Incident Review Committee will be recorded on an NCR (or ADR, if appropriate).
All subsequent documentation related to such defect, noncompliance or deficiency shall reference the governing NCR (or ADR).
The NCR (or ADR) in turn will have an attachment listing all related documents to effect a cross referencing mechanism....
The total docu-mentation package shall be filed under the NCR (or ADR) and stored with the classification of a permanent QA record.
Therefore, all documentation relating to a possibly reportable or reportable incident including correspondence, meeting minutes, telephone-minutes, evaluation reports and written reports will be identified for file copy by the NCR (or ADR) number and transmitted to the Quality Assurance Record Center....
"A written report is required to be submitted to the NRC... on each defect, noncompliance or deficiency reported to the NRC per 10 CFR 21 or 10 CFR 53.55(e)....
An outline for these written reports is provided in Attach-ment C to this procedure."
Contrary to the above, safety concerns 9, 22, 23, 26, 45, 46, 53, 66, 69, and 20 others evaluated by the Incident Review Committee were not recorded on an NCR or ADR, nor did all subsequent documentation related to these safety concerns reference a governing NCR or ADR.
In addition, the total documentation pauages for these concerns (1) were not stored with the classification of a QA record; and (2) were not transmitted to the Quality Assurance Record Center.
Furthermore, the written report submitted to NRC regarding safety concern 81 (Cable Tray Hanger Design Deficiency), and others, did not contain all the information required by Attachment C to the Brown and Root procedure.
8109290701 810812 PDR GA999 EECBRRT 99900502 PDR;.
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2 B.
The NRC Letter of' Acceptance of the Brown and Root Topical Report B&R-002A (revision 3, September 1977) states in part that, " Programmatic changes by Brown and Root to this topical report are to be submitted to NRC for review prior to implementation.
Organizational changes which do not affect the program are to be submitted no later than 30 days after announcement."
Contrary to the above, programmatic and organizational changes made to the program by Brown and Root during the past year were not submitted to NRC as required.
Refer to Details Section paragraph C.3. for details.
C.
Criterion V of Appendix B to 10 CFR Part 50 states that activities affecting quality shall be accomplished in accordance with instructions and procedures.
Brown and Root South Texas Project Proc.edure STP-PM-006 (Personnel Training) states that, "Each personnel qualification file shall include... Pro-jected or completed Procedural Reading List (Form 200.81)... Projected or completed Training Requirements Checklist (Form 200.129)... Evidence of completion of QA Introductory Series."
Contrary to the above, the qualification files of four employees hired since February 12, 1981, did not include Form 200.81 (two of the employees), Form 200.129 (three of the employees), nor evidence of completion of QA Introductory Series (all four employees).
D.
Sections 6.2.1.1.3.8 and 3.11.5.2 of the FSAR for the South Texas Project nuclear power generation station state that, " Mechanical and electrical components of safety-related equipment were qualified for their potential normal operational environment and worst-case accident (DBA) environment.
The two general categories of postulated accidents considered in equipment qualification were LOCA and MSLB... For in-containment equipment, the DBA LOCA source term is an equivalent 100% core meltdown."
Contrary to the above, the material used for the inflatable seals of-the containment personnel and auxiliary air locks was not fully qualified for the worst-case accident (DBA) environment in that the Beta radia-tion resistance of the seal material had not been determined to date, norwastherequirementforqualifyingthesealmaterialtowithstand Beta radiation (1.4 x 10 Rad, per NUREG-0588) included in the pro-curement documents for the air lock.
E.
Criterion V of Appendix B to 10 CFR Part 50 states that activities affect-ing quality shall be accomplished in accordance with instructions and procedures.
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3-e Grown and Root procedure DL 035 (Power Personnel Services Procedure for l
l Verification of Education and Experience) states in part that, "The i
applicant shall provide'docusented evidence of completion of high school j
or college attendance, as applicable. -Documented evidence-is understood to j
mean an original transcript or diploma which may then be xeroxed by a
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Personnel Services Specialist if additional copies are required. The copies
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shall be initialed and dated by the Personnel Services Specialist to verify.
l authenticity."
i Contrary to the above, a Perconnel Services Specialist did not authenticate t
i by initialing and dating copies of transcripts or, diplomas that were l
contained in the personnel department record files of four of the eight examined files of newly hired employees.
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