ML20031G587
| ML20031G587 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031G586 | List: |
| References | |
| REF-QA-99900510 NUDOCS 8110230308 | |
| Download: ML20031G587 (2) | |
Text
-
United Engineers and Constructors, Inc.
Docket No. 99900510/81-03 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on September 14-18, 1981, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
A.
Criterion V of Appendix B to 10 CFR Part 50 states:
" Activities affecting quality shall be precribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantita-tive or qualitative acceptance criteria for detemining that important activities have been satisfactorily accomplished."
Contrary to the above, the storage of QA records is not being accomplished in accordance with approved procedures QA-17 and QA-18.
Specific examples of the above nonconformance are:
1.
Hard copy QA records at the Folcroft facility are not t:1ng stored in steel file cabinets as required by Section IV.E.1.b. of Quality Assurance Procedure QA-17.
2.
Records of design reviews are not being maintained as QA records (duplicate storage) as required by Appendix A of QA-17.
3.
Periodic audits (yearly) of record storage system and areas are not being conducted as required by Section 5.7 of ANSI N45.2.9. (imposed by Section II.A.1 of QA-17) and Section IV. A.4. of QA-18. The last audit of the Folcroft facility was on May 22, 1979, and the last audit of the Boston office storage was on May 9,1979.
B.
Section 17.2.2.2. of the Washington Public Power Supply System Unit 1 PSAR states in part: "... Design and specification changes will be subject to the same design control measures as are the original speci-
- ication requirements...."
Contrary to the above, design changes are not being subjected to the same design control measures as the original design.
Project Change Proposal (PCP)14500139 received four revisions after the original discipline / tech-nical review and none of the revisions were reviewed by the affected groups prior to final approval. An example is a change made in the in-strument and control technical area (containment isolation) which received no review from the instrument and control group. The present project procedure (PP-41) for PCPs does not describe how revisions to PCPs are to be handled.
8110230308 811006 PDR GA999 EECUNEe.
99900510 FDR
i,
C.
United Engineers and Constructors, Inc., Preliminary Safety Analysis Report for the Seabrook Project states, in 17.2.1.2., that vendor surveillance representatives witness shop tests and inspect equip-i l
ment to the extent designated on the Vendor Surveillance Check Plan, prepared by the Home Office Quality Assurance Engineer.
Paragraph 17.2.10 also states that UE&C defines mandatory hold points as noted in 17.2.7., for witnessing of inspections or tests by UE&C Vendor Surveillance Representatives. Vendors may not proceed beyond mandatory hold points until the inspection or test has been witnessed or written i
consent has been obtained.
t Contrr.sy to the above, based on inspection of the vendor surveillance 4
check plan, fabrication of Feedwater Isolation Valves by Borg Warner NVD (Contract 248-36) proceeded past the first mandatory hold point designated without a UE&C Vendor Surveillance Representative witness of the inspection or test, or written consent by UE&C to waive this hold point.
The hold point in question was the witness of Liquid Penetrant testing of the first valve body to neck weld and a subsequent
~
review of the vendor's welder qualifications and NDE personnel qualifi-cations by the UE&C surveillance representative.
L i
l i
i r
t i
l f
1 i
i i
i
- - -,. - - -...., -,- --,.,. - -, ___. - - -. _.- _. ~.- _.,.... -.. - J... -
.... - - -,.