ML20056F236
| ML20056F236 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1993 |
| From: | Cwalina G, Robert Pettis Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20056F216 | List: |
| References | |
| REF-QA-99901265 99901265-93-01, 99901265-93-1, NUDOCS 9308260212 | |
| Download: ML20056F236 (12) | |
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ORGANIZATION:
CONTINUUM DYNAMICS, INC.
PRINCETON, NEW JERSEY REPORT N0.:
99901265/93-01 CORRESPONDENCE Dr. Alan J..Bilanin, President ADDRESS:
Continuum Dynamics, Inc.
P.O. Box 3073 Princeton, New Jersey 08543 ORGANIZATIONAL Barbara Hawk CONTACT:
Quality Assurance Manager (609) 734-9282 NJCLEAR INDUSTRY Professional consulting firm specializing in research ACTIVITY:
and development for government and industry.
INSPECTION M
t-5 and June 4, 1993 CCNDUCTED:
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TEAM LEADER:
Rbbert L. Pettis, Jr., P.E.
Dc i/
Reactive Inspection Section 1 Vendor Inspection Branch OTHER INSPECTORS:
K. Naidu, Senior Reactor Engineer R. Frahm, Jr., Reactor Engineer A. Cubbage, Reactor Systems Engineer U. Rohatg,i., Brookhaven National Laboratory,
/6 / f- /
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APPROVED:
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(N M u W/ /f 2 Gregory C. Cwalina, Chief Date Reactive Inspection Section 2 Vendor Inspection Branch INSPECTION BASES:
10 CFR Part 21 and 10 CFR Part 50, Appendix B INSPECTION SCOPE:
Review whether tests conducted by Continuum Dynamics, Inc., in support of the Boiling Water Reactors Owners Group Reactor Water Level Monitoring Long Term Program, were performed in accordance with its quality assurance program and applicable purchase order requirements.
PLANT SITE All Boiling Water Reactors APPLICABILITY:
i 9308260212 930701 PDR GA999 EECCONTD 99901265 PDR u
1 INSPECTION
SUMMARY
1.1 Violation i
1.1.1 Contrary to Section 21.21, " Notification of failure to comply or existence of a defect and its evaluation," of Title 10 of the Code of Federal Regulations, 10 CFR Part 21 (Part 21), the Continuum Dynamics, Inc. (CDI) procedure for implementing Part 21 was inadequate because it:
(1) had not been updated to address substantive changes in evaluation and reporting requirements of 10 CFR Part 21 that became effective on October 29, 1991; (2) was written in a way which could effectively preclude reporting of deviations by employees and which restricted the scope of failures to comply (as defined in Part 21) that would be reported, and contained provisions to report substantial safety hazards instead of requiring to report deviations for i
evaluation to determine if they were substantial safety hazards; and (3) did not contain provisions to ensure that all affected licensees or purchasers are informed of deviations which CDI is unable to evaluate.
(93-01-01) 1.2 Nonconformances 1.2.1 Contrary to Criterion III, " Design Control," and Criterion V,
" Instructions, Precedures, and Drawings," of Appendix B to 10 CFR Part 50 (Appendix B), the CD1 Quality Assurance (QA) Manual (Revision 10, dated December 1992) does not contain provisions for dedicating items purchased by CDI as commercial grade and used as part of a safety-related activity.
(93-01-02) 1.2.2 Contrary to Criterion III, " Design Control," and Criterion VII,
" Control of Purchased Material, Equipment, and Services," of Appendix B, inadequate measures were established for the selection and review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of systems and components.
Specifically:
CDI's evaluation checklist of American Electronics Laboratories' (AEL's) a commercial quality program and controls (performed by CDI on February 9, 1993) did not adequately address AEL's basis for notifying CDI of conditions "significantly out of tolerance" during the calibration process. Such basis may be critical since AEL's reporting threshold may not be consistent with that of CDI, thereby precluding reporting of such conditions which could have an adverse effect on CDI's evaluation of tests performed. Additionally, CDI's evaluation checklist did not document the training of AEL personnel involved in the calibration process.
In commercial grade purchase orders (P0s) 93044, 93060, and 93069 to
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AEL, CDI did not invoke or reference the observed commercial or quality controls for the items and services purchased.
CDI purchased commercial grade instruments, including calibration i
services, from Omega Engineering, Inc. and Test Equipment Service, Inc.,
without performing any assessments or surveys to verify that the suppliers' quality programs and controls were effectively being implemented for the types of instruments and services purchased. These instruments were used in tests conducted by CDI, in support of the Boiling Water Reactors Owners Group (BWROG) Reactor Water Level Monitoring (RWLM) long Term Program, for the Electric Power Research Institute (EPRI).
(93-01-03) 2 STATUS OF PREVIOUS INSPECTION FINDINGS There was no previous NRC inspection of this facility.
3 INSPECTION FINDINGS AND OTHER COMMENTS 3.I Intrance and Exit Meetinas During the entrance meeting in Princeton, New Jersey, on May 4, 1993, the NRC inspection team met with members of the CDI staff and other - epresentatives of the BWROG, discussed the scope of the inspection, and estabiisned working interfaces.
The inspection team observed activities, held discussions with CDI's staff, and reviewed records and procedures. The specific areas, documentation reviewed, and the team's findings are described in this report.
The persons who participated in and who were contacted during the inspection are listed in Section 4 of this report.
During the exit meeting on May 5, 1993, the inspection team summarized the inspection findings, observations, and recommendations with CDI's management and staff. On June 4, 1993, the inspection was continued at EPRI's Nondestructive Examination (NDE) Center, located in Charlotte, North Carolina. This was necessary since the actual test configurations tested by Continuum Dynamics, Inc. (CDI) were assembled at this facility. There was no formal exit meeting conducted during this part of the inspection.
3.2 Backaround According to the CDI scope of work reference document (RP 3665-01), prepared by the BWROG and CDI for EPRI, the purpose of the BWR0G RWLM Long Term Program is to simulate depressurization events using piping geometries representative of those found on operational boiling water reactors at various gas concentrations and depressurization rates. Work is to be performed under the
" Plan for Testing Prototypical Boiling Water Reactor Water Level Instrumentation Reference Leg Geometries During Rapid Depressurization Events," Revision 1, dated March 8, 1993, hereinafter referred to as the test plan, which was prepared by CDI under subcontract to EPRI through the support of the BWROG.
The program consists of the following work scopes:
reference leg de-gas test; plant specific data analysis; and the preparation of analytical models. Data from the tests are expected to provide both a bounding estimate on the severity of such an event on reactor pressure vessel water level error, and a unique data base for verifying and validating industry analysis codes to be used to predict the plant specific water level instrument errors during depressurization.
i Genera'l Electric Nuclear Energy (GENE), San Jose, California, acting as agent for the BWROG, issued P0s to EPRI for the total work scope to be performed.
CDI, under contract from EPRI, was selected by the BWROG to perform the work i
tasks and resolve the issues related to non-condensible gases in the RWLM system reference legs. According to the individual work scopes, all work is to be performed under CDI's Appendix B QA program, which includes 10 CFR 1
Part 21. Actual testing was performed by CDI at EPRI's NDE Center. Acting on i
behalf of the BWROG, GENE performed an implementation audit of CDI's Appendix B QA program on January 11, 1993, and approved them as a qualified supplier for engineering services.
The purpose of the NRC inspection was to determine whether tests conducted by CDI were performed in accordance with its approved Appendix B QA program and applicable PO requirements, including Part 21.
3.3 Review of 10 CFR Part 21 In order to evaluate the CDI program for evaluation and reporting of defects and noncompliance pursuant to Part 21 and its implementation, the team reviewed Section 1.2.1., " Applicable Codes," and Section 1.2.2., " Procedure for Reporting Defects (10 CFR Part 21)," of CDI's QA Manual, Revision 10, dated December 1992. The inspectors determined that the procedure was not adequate to effectively implement the provisions of Part 21. The team determined that the CDI procedure 1) did not address the timeliness requirements which first appeared in the July 1991 revision of Part 21, 2) placed the burden of determining if a significant safety hazard exists on employees who may not be able to make that determination, and 3) did not address informing customers of deviations which CDI is unable to evaluate.
These issues are discussed in detail below.
The procedure (Section 1.2.2) states:
When there is the recognition of a substantial safety hazard by l
any CDI employee performing his normal duties on a contract governed by Part 21, the employee shall provide written notice to the President of CDI immediately. This written notice shall include, as a minimum, the contract number and revision level, the date of recognition, a description of the contract requirements and a description of the expected substantial safety hazard.
The President shall provide written notice of the substantial safety hazard within two days as required by 21.21(b)(2) and to the Commission as defined in 21.3(b) of Part 21.
The inspectors determined that it is unlikely that "any" CDI employee performing the types of activities that CDI conducts (including constructing test equipment, conducting the tests, gathering test data, evaluating the data or evaluating instrument calibration services), as evidenced by the RWLM Long Term Program, would be in a position to determine whether a " substantial safety hazard" exists. The inspectors determined it unlikely that all employees would be aware of the potential safety impact of a deviation from or failure to comply with a customer P0. Most employees would pr ably not be i
l aware of the P0 requirements or the relationship between the tests and their nuclear safety-related application. Therefore, if the procedure were strictly interpreted, as written, the employees may not be able to evaluate a deviation to identify a substantial safety hazard and, therefore, would ~not be required to report the deviation to the President of CDI.
In addition,.the inspectors noted that the procedure does not co6tain I
provisions, as required by Section 21.21, to ensure that all affected licensees or purchasers are informed of deviations or failures to comply which CDI is unable to evaluate.
Finally, the current revision of Part 21 does not contain a Section 21.21(b)(2), as specified in the CDI procedure.
Section 21.21(b)(2) existed in a previous version that was superseded in July 1991. Consequently, it appears that CDI was unaware of the substantial' changes regarding evaluation and reporting requirements that first appeared in July 1991, and CDI,-
therefore, did not incorporate the new evaluation and reporting requirements into its procedure.
In a May 10, 1993 letter to the NRC, CDI provided further information regarding their interpretation of their procedure and other documents that CDI believes fulfills the intent of Part 21. These issues are discussed below:
Although CDI's QA manual requires that each CDI employee read and
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understand Part 21,-there is no objective evidence to assure that each employee really understands the meaning of substantial safety hazard, particularly as it-applies to CDI's scope of work.
CDI stated that some employees involved in testing may not be qualified to make a significant safety hazards determination and contends that
.i other conditions are imposed by procedure that' accounts'for that possibility. As a result, CDI provided QA Procedure No. 12.0,
" Guideline Procedure for Performing Testing," Revision 2, dated January 1982, in support of their statement. Section M, "Anamolous[ sic]/
Discrepant Test Data," states, in part, "The QA Manager will assure that.
the Nonconformance Reports describing data' anomalies or. discrepancies are clear and complete... Data conditions which the Principal Investigator (PI) judges more. significant will be analyzed to determine
-if procedures should be revised, equipment reworked, personnel-retrained, etc.
The PI shall direct appropriate changes, and if he i
deems necessary, the client's concurrence shall be required for the l
corrective action." The procedure again places _the burden of i
determining safety significance'upon the PI and does not require that i
the customer be made aware of deviations (or'even of defects).
l CDI states that all documents and practices found not to conform to customer requirements or the QA manual are required to be reported-i through the Nonconformance Report (NCR)' system described-in QA manual Section II.15., " Control of Nonconforming Items." Section 11.15. does j
require the documentation of items found not in conformance with the. QA l.
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manual but does not address specified customer requirements.
- Further, the Section only states that affected clients be notified "when appropriate." No guidance was found that discussed when notification would be appropriate.
CDI provided examples of NCRs that show a line item, "Related to 10CFR217" which is to be filled out. The inspectors could find no guidance as to how that determination was to be made.
Based upon the inspectors' review of all available guidance, it is assumed that box is the final determination as to whether a significant safety hazard exists.
Although CDI stated that these are reviewed by QA, there does not appear to be objective evidence that an evaluation was, in fact, done. A review of the NCRs provided by CDI indicated that the discrepancy, its cause, measures to prevent recurrence, and corrective actions were all identified, implemented and approved by the same person.
No CDI document requires the employee to specify how the significant safety hazards determination was made, nor does one exist requiring QA to verify the employee's determination. As a result, Violation 93-01-01 was identified during this part of the inspection.
3.4 Desian Control and Quality Assurance Review The inspection team reviewed the implementation of CDI's QA manual to accomplish the activities related to design control and overall quality assurance of the reference leg de-gas tests.
The BWROG provided CDI with plant-specific isometric drawings showing the geometries of the reference leg instrument piping.
CDI reduced this data using spreadsheet calculations to determine spatial orientations of end points in a Cartesian coordinate system. The president of CDI designated a PI who developed procedures to compensate for data on elevations, lengths, azimuths, and conflicting lengths and elevations, that were missing on plant-specific isometric drawings.
The PI then selected the configuration representing the bounding reference leg piping geometries and proposed to use it in the reference leg tests. The overall design of the tests were approved by the Model and Test Committee, a subcommittee of the BWROG.
CDI prepared sketches to represent configurations of the test specimens, provided them to Teledyne Engineering Services (TELEDYNE) and requested them to prepare fabrication drawings for the piping spool pieces. CDI requested TELEDYNE to send the drawings to Adroit Fabricators and Manufacturers, Inc.
(ADROIT) so that they could purchase the raw material necessary to fabricate the spool pieces and fittings of the reference legs and ship the fabricated hardware direct to EPRI's NDE Center in Charlotte, North Carolina.
J.A. Jones Applied Research (JAJ) assembled the fabricated hardware to the TELEDYNE drawings, while CDI physically verified that the installed piping configurations met the TELEDYNE drawings.
Since the activities performed by TELEDYNE, ADROIT and JAJ were c?assified in Table 6.1 of the test plan as not quality-related, they were not performed under CDI's QA program. However, CDI maintained quality on the fabricated piping and pressure vessel systems by l
establishing QA procedures in both the specification and approval of the design of these components, and in the verification of the as-fabricated -
components to assure they conform to standards specified in the design release. Documentation, instrumentation, data collection from the tests, and certain tasks related to the piping system itself, were classified as quality-related by CDJ.
The inspection team determined that the Sllowing CDI activities-appeared to l
be in compliance.
In accordance with the QA manual requirements, CDI management designated a PI to accomplish this task. The PI prepared Pre-Test Procedure F164-PT 01-RV0, " Plant Specific Piping Analysis Procedure," which outlined the scope for data reduction.
CDI prepared isometrics to represent the reference legs for ten nuclear power plants, including a full scale mock-up of the as-built installation of the Washington Public Power Supply System, Unit 2 (WNP-2),
"C" reference leg.
As a rule, CDI analyzed the shortest reference leg, per condensing chamber, per plant. All calculations were signed by the preparer and were independently verified.
CDI personnel used an engineering calculation sheet (Form 23, Revision 1 of August 20,1984), which is a cover page for any calculation generated
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in support of a quality-related contract to document all calculations for the de-gas tests. All cover sheets were signed by the preparer and independently verified.
CDI personnel used Form 23b to document the calculations. All the engineering calculations had been stored appropriately and were readily i
retrievable.
CDI personnel prepared a test plan which incorporated the appropriate work elements for the de-gas test. The procedure adequately defined the responsibilities of the individuals assigned to implement the test plan.
Appendix I to the procedure depicted a logic diagram indicating the various inputs and stages of the test from inception to the final analysis of the test data. Appendix II provided the minimum criteria that should appear on the test data sheet.
CDI personnel prepared procedure F164-02-RVO for calibrating the " Data Acquisition System."
3.5 Review of Instrument Calibration Services Provided to CDI Procurement of services is performed by CDI on a limited basis.
However, in order to perform safety-related tests for the de-gas test program, CDI contracted with several vendors for instrument calibration services.
Table 6.1 of the test plan classified the calibration of instrumentation used i
in the tests as quality-related. Therefore, all related activities are to be performed under CDI's QA Program.
Section 8 of the test plan, " Quality l
Assurance," states that quality-related activities are those which are I
t directly related to the planning, execution and objectives of the test, and are to be performed in accordance with CDI's QA Program which complies with Appendix B, and the reporting requirements of Part 21.
The inspectors reviewed the following quality-related P0s issued by CDI for various instruments and associated calibration services:
P0 No. 93010, dated January 6, 1993, was issued to Test Equipment Service, Inc. (TES) for calibration of a Micronta digital multimeter and a Tektronik oscilloscope, with certification to the National Institute of Standards and Technology (NIST).
P0 No. 93040, dated February 1, 1993, issued to Omega Engineering, Inc. (OMEGA) for the purchase of equipment.
P0 No. 93014, dated January 8, 1993, was issued to OMEGA for a thermometer with certification to NIST.
P0 No. 93060, dated February 9, 1993, was issued to American Electronic Laboratories (AEL) for four OMEGA pressure gages with certification demonstrating conformance to Military Standard (MIL-STD) MIL-STD-45662A.
P0 No. 93044, dated February 3, 1993, was issued to AEL for four OMEGA pressure gages, two Rosemount pressure transmitters, and a Fluke digital multimeter, with certification demonstrating conformance to MIL-STD-45662A.
P0 No. 93069, dated February 10, 1993, was issued to AEL for seven Rosemount and Sensotec pressure transducers and display conditioners.
Since these items and services were treated as commercial grade items (CGIs) by CDI, the inspectors reviewed the dedication process which would provide the assurance that the items and services are adequate to meet the requirements of Appendix B.
A review of CDI's QA manual identified that it did not contain any provisions for dedicating CGIs which are used as part of a safety-related activity.
As a result, Nonconformance 93-01-02 was identified during this part of the inspection.
The inspectors reviewed CDI's basis to support the purchasing of CGIs from the above suppliers.
CDI stated that they do not maintain an approved suppliers list of qualified suppliers, but produced a document titled, " Evaluation Checklist for Suppliers of Calibration Services," dated February 9,1993, which was used to document AEL's capability of performing calibration services in accordance with MIL-STD-45662A.
The checklist, supplied to CDI by GENE, was completed by a CDI staff member who received training as an auditor of calibration services on February 8,1993. A review of the checklist identified that AEL's commercial quality program and controls did not adequately address their basis for notifying CDI of conditions "significantly out of tolerance" during the calibration process, as required by Section 5.6 of MIL-STD-45662A.
CDI invoked the MIL-STD in some of their P0ssince it appeared to ultimately satisfy the reporting requirements of Part 21, and it was recommended by GENE to do so.
Such basis may be critical since AEL's reporting threshold may not be consistent with that of CDI, thereby precluding reporting of such conditions by AEL. The failure of AEL to report such conditions could have an adverse effect un tests performed by CDI. The checklist also did not address the training of AEL personnel invo.lved in the calibration process, the identification of the critical characteristics to be controlled by the supplier, and the verification of such supplier controls.
Also, CDI P0s 93044, 93060, and 93069 to AEL, did not invoke or reference the observed commercial or quality controls for the CGIs purchased. As a result, a portion of Nonconformance 93-01-03 was identified during this part of the inspection.
A review of CDI's basis for using OMEGA and TES identified that CDI did not perform any assessments or surveys to verify that the suppliers' quality programs and controls were effectively being implemented for the types of instruments and services purchased. CD1 stated that they requested and received a QA manual from TES which stated compliance with Appendix B and MIL-STD-45662A, for repair and calibration of measurement and test equipment, but did not perform any implementation reviews at the two suppliers. The instruments purchased / calibrated from OMEGA and TES were used in tests conducted by CDI, in support of the BWROG RWLM, for EPRI. As a result, a portion of Nanconformance 93-01-03 was identified during this part of the inspection.
3.6 Quality Assurance Review of WNP-2 Mock-up at EPRI The NRC inspectors visited EPRI's NDE Center on June 4, 1993. The purpose of the visit was to perform a QA review of the test apparatus used by CDI to mock-up the WNP-2 "C" reference leg. The WNP-2 mock-up was one of seven configurations tested by CDI from April 11, 1993 through May 23, 1993.
According to CDI, the important parameters involved in the de-gassing physics process included non-dimensional cumulative height versus cumulative volume, total vertical drop of the reference leg, and piping slopes and diameters. As a result, the inspectors verified that CDI had measured and verified the entire geometry of the mock-up on April 12, 1993. The original WNP-2 plant as-built piping isometric drawings, prepared by Johnson Controls, Inc. and supplied to EPRI by WNP-2, were used to accomplish this task. CDI Procedure F164-05-RV0, dated March 7, 1993, describes the methodology used by CDI to perform the verification which included verification of the geometry by recording end points of the piping segments in a Cartesian coordinate system relative to a point located inside the NDE Center. A plumb bob was then used along with a steel tape measure to record the measurements.
Nodal locations for the end points were then recorded on the piping isometric drawings.
Engineering calculations were also performed to reduce the plant-specific geometry to a non-dimensional plot.
The NRC inspectors verified that the calculations and other quality related documents used to record the data were signed and independently verified by CDI personnel.
The data was then entered into a spreadsheet format and I
reduced to provide plots of cumulative percent height from the output of the,
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tondensing chamber to a particular pipe location, versus cumulative percent volume contained in the reference leg to that same location.
Verification of the spreadsheet calculations was performed and documented using simple piping representations which were performed by CDI on January 8, 1993. The inspectors also verified that the instrumentation used during the test had valid calibration stickers covering the dates on which the tests were performed.
The instrumentation included a differential and absolute pressure transmitter and their associated indicators, two temperature indicators (one for ambie-+ and one for water), two pressure gauges used with a dual-chamber samplins evt.nder to measure dissolved gas concentrations, and a flow meter and its associated sensor. The two temperature sensing thermocouples, used by CDI during the actual tests, had been removed from the mock-up and were not available for inspection.
The inspectors concluded that the WNP-2 mock-up appeared to be an adequate representation of the actual reference leg used to measure reactor vessel water level at WNP-2, and that an appropriate level of QA had been applied.
3.7 Review of Nonconformance Reports (NCRs)
The control of nonconforming items is described in Section II.15, " Control of Nonconforming Items," of CDI's QA manual.
This section defines nonconformances as those documents and practices which do not conform to specified requirements of the manual.
It requires individuals to use Form QA9 to document nonconforming items.
The QA9 Form also has a line item question "Related to Part 217".
It was noted that " items nonconforming to the QA manual" are not usually considered defects or deviations.
Because information in NCRs is one source where deviations or defects are documented, it was recommended that CDI review the NCRs to determine if the items reported are defects or deviations. To accomplish this, CDI should revise the current QA manual to include appropriate text describing the use of NCRs as one of the sources which provide information on possible defects or deviations which will require an evaluation to determine if any of them constitute substantial safety hazard.
The inspection team reviewed the following NCRs:
NCR No. 024, dated April 30, 1993, documented that on March 24, 1993, the test operator did not document the reading on differential pressure (DP) transmitter No. I prior to blowdown. This was contrary to the requirement of Step 5.1 of De-Gas Test Procedure F 164-04, Revision 1.
Corrective action taken was to advise the operator to follow established procedures in the future.
NCR No. 023, dated April 23, 1993, documented that the sensor in the conductivity meter, which measured the conductivity of the demineralized water source, was not calibrated prior to the test.
CDI's corrective action was to provide a sample of the demineralized water to EPRI requesting verification and validation of the value that had been indicated by the conductivity meter.
NCR No. 022, dated April 23, 1993, documented that a CDI operator observed a transient that had been produced by a DP cell in the data acquisition system. CDI determined that high frequency welding equipment that was being operated in the vicinity of the DP cell was the j
cause of the spike.
Corrective action was to advise JAJ personnel who were welding the test configurations to refrain from welding when de-gas tests were being conducted.
NCR No. 009,. dated December 27, 1992, documented the QA manager's discovery that, even after a month had elapsed, a recently hired employee had not been indoctrinated in the CDI QA program.
The NCR was closed after the employee had been indoctrinated.
The review of the above NCRs indicated that the following provisions of the CDI QA manual had been implemented:
Form No. QA9 had been used to document nonconforming conditions.
The NCRs indicated the specific requirement and the nonconforming condition.
The NCRs contained information on the cause of the nonconforming condition and the measures taken to prevent recurrence.
A review of the NCR's indicated that appropriate corrective action had been taken.
3.8 Review of OualitY Assurance Audits The QA manager conducted annual internal audits in 1991 and 1993.
However, in 1992, quality related work was minimal at CDI and, therefore, the QA manager did not perform an internal audit of CDI's activities.
For the 1991 and 1993 audits, the QA manager used a check list, which reflected all the applicable Appendix B criteria, to document the results of the audit.
At the conclusion, the QA manager met with CDI's President and the PI, and discussed the results of the audit. The audits did not identify any adverse findings.
4 PERSONNEL CONTACTED Continuum Dynamics. Inc.
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A. Bilanin, President
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R. McKillip, Senior Associate
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- 0. Wachspress, Research Associate
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B. Hawk, Quality Assurance Manager
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U.S. Nuclear Reaulatory Commission G. Cwalina, Chief, Reactive Inspection Section 2, Verdor Inspection Branch Others
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J.. Munchausen, Program Manager, EPRI
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J. Morgan, Senior Engineer, Gulf States Utilities
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G. Beck, Senior Manager, Philadelphia Electric Company
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J. Cornell, Engineer, Philadelphia Electric Company
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Attended the entrance meeting at CDI on May 4, 1993 Attended the exit meeting at CDI on May 5, 1993 Note: There was no entrance or exit meeting held for the June 4,1993 i
inspection at EPRI.
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