ML20054J361
| ML20054J361 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20054J359 | List: |
| References | |
| REF-QA-99900510 NUDOCS 8206280536 | |
| Download: ML20054J361 (2) | |
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t APPENDIX A United Engineers & Constructors, Inc.
Docket No. 99900510/82-02 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on April 5-8, and April 19-23, 1982, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
A.
Appendix II, Figure V of Topical Report UEC-TR-001-5A, APPLICABLE STANDARDS AND REGULATORY GUIDES, lists Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants, which endorses N45.2.11.
ANSI N45.2.11, Section 8.2, states in part:
... the procedures for effecting design changes shall require that the documents which reflect the design change be reviewed and approved by the same groups or organizations which reviewed and approved the original design documents."
Contrary to the above, Administrative Procedure No.15, Revision 14, Changes to Project Documents, ECA/RFI FORM INSTRUCTIONS AND DISTRI-BUTION, allows " minor" design changes to be reviewed and approved by the responsible site engineer (RSE), only, and the list which' identifies " minor changes," has no review and approval requirements.
B.
Section 17.1.3.1 of Topical Report UEC-TR-001-5A, states in part:
" Applicable Regulatory requirements and design bases for safety related structures, systems, and components are translated into specifications, drawings, procedures, and instructions.
Measures which assure correct translation of the requirements are documented in QA Procedures and General Engineering and Design Procedures (GEDP's). The GEDP's establish provisions for the preparation, review, and approval of engineering documents including the Systems Design Description and Structural Design Criteria."
Contrary to the above, the applicable GEDP provisions of Sections III and V of GEDP-5, Preparation, Documentation and Control of Calculations, were not being implemented for the preparation, review, and approval of a calculation on conduit and cable tray support weld adequacy (Conduit Support Calculation, dated April 25, 1980) in that:
(1) the calculation had approximately six pages that were not checked; (2) no i
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B2044290536 EN20608 ptNt GW4999 EECtN4EC 99900510 PDR
United Engineers & Constructors, Inc.
calculation number was assigned; (3) the calculation was not marked as preliminary or final; and (4) no cover sheets were included with the calculation.
C.
Criterion V of Appendix B to 10 CFR Part 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, proce-dures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for deter-mining that important activities have been satisfactorily accomplished."
Section 4.12.3 of Project Procedures No. 34, Project QA Records, for WPPSS Nuclear Project No. 1 states in part: "The DDC shall maintain a file of... PCR's.
The file shall be microfilmed periodically and a diazo microfilm sent to the Field Document Control Center."
l Contrary to the above requirements, records and information made available to the inspector indicate that the last Project Change Request (PCR) was microfilmed in January 1978.
Project Change Proposal (PCP's) superseded PCR's in October 1980.
There was no evidence that any PCP had been microfilmed with a copy sent to the Field Document Control Center.
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