ML20011A396
| ML20011A396 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/1981 |
| From: | Chamberlain D, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20011A373 | List: |
| References | |
| REF-QA-99900505 NUDOCS 8110090389 | |
| Download: ML20011A396 (11) | |
Text
- m.
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report:
99900505/81-02 Company:
EBASCO Services, Incorporated Two World Trade Center New York, New York 10048 Inspection at: New York, New York Inspection Conducted:
April 21-24, 1981 Inspectors:
h.O
@d. lle s'// /f/
J.(R) Costello, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch A
4 A
%AkvtN 5 / 3 / 91
- 0. D. Chamberlain, Contractor Inspector Date Reactors Systems Section Vendor Inspection Branch Approved by:
Q bl
/
C. K Male, Chief Oate
~
Reactor Systems Section Vendor Inspection Branch Summary Inspection on April 21-24, 1981 (99900505/81-02)
Areas Insoected:
Implementation of Ebasco Topical Report No. ETR-1001 in the areas of follow up on previous inspection findings, evaluation of supplier performance, and training.
The inspection involved 56 inspector-hours onsite by two NRC inspectors.
Results:
In the three areas inspected, two nonconformances were identified in one area and one follow up item was identified in another area.
i 91100903s9 810626 PDR GA999 EECEBAS l
99900505 PDR l
A
2 Nonconformances:
Follow up on Previous Inspection Findings:
Contrary to proce-dures, tne Instrument-and Control Departments on two projects did not document and/or sign the-design inputs as required for the development of control logic diagrams (See Notice of Nonconformance, item A).
Contrary to procedures, the Project Engineer for WPPSS 3/5 signed the document review list prior to the receipt of all Lead Engineer's signatures, and comments from one department were not fully incorporated (See Notice of Nonconformance, item B).
3 DETAILS SECTION !
(Prepared by J. R. Costello)
A.
Persons Contacted A. M. Contino, Education Specialist R. F. DeTommaso, Supervisor NDE Group L. E. Ellison, Chief, Vendor Quality Assurance Representative
- F. F. Ford, Supervising Quality Assurance Enginear J. C. Hoops, Manager, Site Quality Assurance
- 0. Krobetsky, Quality Assurance Training Specialist J. F. Marek, Quality Assurance Auditor K. A. McCarthy, Training Specialist T. J. Mormilo, Assistant Chief, Vendor Quality Assurance Reprosentatives W. Sawicky, Assistant Chief Engineer, Quality Assurance
- Indicates those present at exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Nonconformance (81-01 item B):
Contrary to procedures two auditors were certified as lead auditors with no backup records to support this certification.
The backup records have been reconstructed from the relevant audit reports in the Internal Audit Record files and are now in place.
Further review of the records did not disclose any additional cases.
2.
(Closed) Nonconformance (81-01 item C):
Contrary to procedures all of the internal audits required for St. Lucie No. 2 for calendar year 1980 were not performed.
Procedure QA-0-5 was revised Msrch 31, 1981, removing the mandatory minimum requirement of auditing each departmental operation twice in a calendar year.
The procedure has been revised to read "Each departmental operation (audit area) shall be reviewed during the six month interval and audited to an extent commensurate with the level of activity for each project."
See Details II.B for additional information on previous inspection findings.
C.
Training 1.
Objectives
T 4
To verify that procedures have been established and implemented that provide for:
a.
Formal indoctrination and training for new employees.and l
reassigned employees.
b.
Training of-inspection, examination and testing personnel.
c.
Training of audit personnel, including technical specialists.
d.
Training programs for other personnel performing quality related activities, e.
Documentation of training activities and retention of these docu-ments for all formalized training accomplished.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Section QA-I-1 (Quality Assurance Program) and QA-I-3 (Personnel Indoctrination and Training Program in Quality Assurance) of Nuclear Quality Assurance Program Manual ETR-1001.
b.
Quality Assurance Engineering Procedures QA-G.3 (Qualification of QA Audit Personnel), QA-G.3.1 (Requirements for the Qualification /
Experience Review and Certification of Designated Level III QC Individuals), QA-G.3.2 (Qualification of QA/QC Personnel to ANSI N45.2.6 Requirements), QA-G.4 (Quality Assurance Engineering Records) and NDE-1 (Training, Examination & Certification of Nondestructive Examination Personnel).
c.
Construction Department Procedure QS-3 (Indoctrination and Training).
d.
Vendor Quality Assurance Department Procedure VQAD-19 (Qualification of Inspection, Examination and Testing Personnel for Nuclear Facilities).
e.
Documents to verify implementation of quality assurance program ccm-mitments, precedural requirements, and to satisfy the intent of the objectives section.
These documents are as follows:
(1) Quality Assurance Engineering and Design Audit No. 1370.
Audit was conducted on December 18, 1980, and covered the training activity of Electrical Engineering personnel on the WPPSS 3/5 project.
This audit was the only audit on training for 1980 and it did not cover the Shearon Harris, St. Lucie and Waterford projects, nor did it cover the
y 5
Mechanical Nuclear, Civil, Instrumentation and Control, Con-struction, Projects, Procurement, Nuclear Licensing and Quality Assurance organizations.
(2) Quality Assurance Engineering and Desi'gn Audit No. 1431.
This audit was conducted on March 24-25, 1981, and was a follow up on Audit No. 1370.
(3)- Quality Assurance Engineering and Design Audit No. 1377.
This audit was conducted on January 7, 1981, and covered Nuclear Licensing on the WPPSS 3/5 project.
The audit did not cover training in the Nuclear Licensing organization.
(4) Quality Assurance Engineering Audit Plan AP-15, Rev_ision 1.
(5) Training courses for vendor quality assurance representatives.
(6) Three training and certification records from Vendor Quality Assurance Representative Training File.
(7) Seven training and qualification records from Quality Assurance Engineering Personnel Training File.
(8) -Quality Training Course Catalog for Quality Assurance Engineering personnel.
(9) Manpower Planning and Development Training History File.
(10) Eight training experience and certification records of nondestructive examination personnel (RT, PT, MT, UT, VT, EC & LT).
(11) Two training seminars u3ed by Nuclear Licensing.
(12) Three training courses (called units of instruction) used by Manpower Planning and Development Department and three training courses used by the Quality Assurance Engineering Department.
3.
Findings a.
No nonconformances or unresolved items were identified.
b.
Ebasco has developed a comprehensive training program covering both self study courses and instructor presented courses.
The content, format, and illustrations used in the courses reviewed by the inspector were readily understandable.
r l
l t
6 c.
Some of the procedural requirements of the training program were not being strictly adhered to.
The following problems were noted and will-be followed up by the inspector on the next scheduled inspection.
(1) Records of many Quality Assurance Representatives were not up-to-date in the NDE files at Lyndhurst, New Jersey.
This covered recertification of NDE personnel and eye examinations.
The NDE certifications are maintained at Lyndhurst and the inspector did not have time after finding this lack of recertification to determine whether these personnel were acting in an NDE capacity.
The eye examinat'ons were on file in New York, but had not been transferred to the official files in Lyndhurst.
(2) Contrary to procedures, training cequirenents of Nuclear Licensing personnel were not specified by the Quality Assurance Engineering Department.
Nuclear Licensing has Jpecified their own program.
(3) Manpower Planning and Development Department show many people in the engir.eering disciplines performing quality related work who have not had the 31 specified courses of training.
There is no procedural requirement that anyone take any of these courses, but they are recommended by the Quality Assurance Engineering Department.
(4) Pro;edural requirements state that appilcable elements of the training program be audited.
At the present time only a narrow area of training is being audited and is limited to a project basis.
(5) The format of tne present internal audits does not entirely satisfy the commitments in Ebasco Topical Report ETR-1001.
(6) The training of Quality Assurance Engineers is under the jurisdiction of the Quality Assurance Program Administration organization who are now respor.sible for all Quality Assurance training audits.
This creates a Fituation where an organization is auditing its own functicns.
D.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on April 24, 1981.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance were:
+
.~
7 B.'R. Mazo, Chief, Quality Assurance Engineer S. Sparacino, Supervising Quaiity Assurance Engineer B. E. Tenzer, Vice President, Materials Engineering and Quality Assurance R. F. Williams, Supervisor, Audits The inspector summarized the scope and findings of the inspection for those present at the meeting.
Management representatives acknowledged the statements of the-inspector.
t t
),
e DETAILS SECTION II (Prepared by D. D. Chamberlain)
A.
P_ersons Contacted F. X. Ciulla, Project Designer
'.. G. Das, Lead Control Engineer "F. F. Ford, Supervising QA Engineer G. Ganguly, Senior Electrical Engineer
- X. D. Pique, Project Quality Assurance Engineer
- D. G. Price, Assistant Chief Instrument and Control Engineer W. Szablowski, Project Engineer
- Indicates those present at exit meeting.
B.
Action on Previous Inspection Findings 1.
(Upen) Nonconformance Item A (81-01):
Activities affecting quality which were formerly performed by the Senior Vice President Nuclear have not been reassigned in procedures QA-II-9, QC-7 and A-45.
Procedure QA-II-9 has been revised (Revision 3) to show the Vice President Materials Engineering and Quality Assurance assuming the responsibilities of activities affecting quality that were formerly performed by the Senior Vice President Nuclear.
Ia response to this nonconformance, Ebacco committed to issuing Revision 3 of QA-II-9 to NRC headquarters for approval no later than May 1, 1981.
During this inspection, the NRC inspector also obtained the following commitments for the revision of procedures QC-7 and A-45:
a.
QC-7 will be revised within 30 days after receipt of approval of Revision 3 of QA-II-9.
b.
A-45 will be revised by June 15, 1981.
This item will remain open until applicable procedures are revised, approved and verified.
2.
(Closed) Unresolved Item (81-01):
It is not apparent that all the written criteria had been prepared and signed for the development of a WPPSS (Washington Public Power Supply System) 3/5 logic diagram.
This item has been elevated to a nonconformance (See Notice of Nonconformance, Item A).
Examples of this nonconformance relating to the development of control logic diagrams are as follows:
a.
The sketch that was used by the Instrumentation and Control (I&C)
Department on the Wasnington Public Power Suoply System (WPPS5)
a i
9 D
3/5 project to develop the diesel generator logic diagram was not signed by the Design Group Supervisor and approved by the Supervising Engineer as required.
Also, various changes had been marked with a pencil on the sketch with no justification and approval, b.
The I&C Department for e.he WPPSS 3/5 project did not document design inputs on a form as required.
c.
The I&C Department for the Shearon Harris project did not have signed sketches and/or documented design inputs as required.
3.
(Closed) Follow Up Item (81-01):
A follow up was to be conducted regarding the timeliness of comment resolution and sign-off of the WPPSS 3/5 Project Documentation Review Requirements for Design Drawings list.
Follow up of this item resulted in an item of nonconformance (See Notice of Nonconformance, Item B).
WPPSS 3/5 Project failed to follow the signature requirements of precedure E-7 during the recent epdate of the document review list.
Also, a spot check of the review list by the NRC inspector identified two drawings where a department (Corrosion Department) was not added to the review as requested.
WPPSS 3/5 Projcct took immediate corrective action by a total review of the list for omissions and typographical errors.
All pages that were in error were revised and reissued as revision 6A.
Also, all of the required Lead Discipline Engineer signatures were obtained.
C.
Evaluation of Supplier Performance 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented that provide for:
a.
Establishing that the purchaser and supplier understand the provisions and specifications of the procurement documents.
b.
Requiring the supplier to identify planning techniques and processes to be uti'ized in fulfilling procurement requirements.
c.
Reviewing documents which are generated or processed during activities fulfilling procurement requirements.
d.
Identifying and processing necessary change information.
f 10 e.
Establishing exchange method of document information between purchaser and supplier.
f.
Initiation of pre-and post-award activities, as necessary.
g.
Control, handling, and approval of supplier generated documents.
h.
Control of changes in items or services.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
ETR-1001, Ebasco Nuclear Quality Assurance Program Manual, Shearon Harris Project:
(1) Section QA-II"4, Purchasing (2) Section QA-II-5, Supplier Surveillance b.
Purchasing Department Procedures:
(1)
PD-3, Development of Project Bidders List (2)
PD-5, Preparation of Inquiry and Supplements, and Distribution of Quotations (3) PD-ll, Preparation of Purchase Orders and Supplements c.
Quality Assurance Procedures:
(1) QA P.1, Review of Vendor Procedures (2)
QA-P.5, Requirements for Preparation, Implementation and Control of QA Plans (3)
QA-P.9, Quality Assurance Vendor Evaluations d.
Vendor Quality Assurance Procedures:
(1) VQAD-1, Procedure for Assignment of Purchase Orders and Sub-Orders for Examination Nuclear Safety Related Equipment and Designated Equipment.
11 (2) VQAD-3, Procedure for Transmittal, Distribution and Use of Quality Assurance Plan for Vendors, Manufacturers or Contractors and Associated Quality Assurance Forme.
(3) VQAD-13, Review of Documentation, e.
Nine Vendor Quality Assurance Engineering Procurement Files (Shearon Harris Project) containing the following sections:
(1) Purchase Order and Specification, (2) QC Documentation, (3) QC Representative and Expediting Report, (4) Correspondence and Meetings, and (5) Deviation Report.
3.
Findings In this area of the inspection, no nonconformances or unresolved items were identifed.
_.