ML20059L444
| ML20059L444 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20059L434 | List: |
| References | |
| REF-QA-99901101 99901101-88-01, 99901101-88-1, NUDOCS 9009260323 | |
| Download: ML20059L444 (3) | |
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i APPENDIX B 4
Planned Maintenance Systems EA 90-062 Docket No. 99901101/88-01 NOTICE OF NONCONFORMANCE j
During an inspection conducted May 9-12,(QA) program at the Planned Maintenan 1988, the NRC staff reviewed the implementation of the qualit Systems, Incorporated (PMS) y assurancefacility in Mount Vernon, Illinois.
The results of the inspection revealed that certtin of its activities were not conducted in accordance with NRC requirements.
These items have been classified as noncon-foi.uaces with the requirements of Appendix B to 10 CFR Part 50 and ANSI /ASME N45.2 that were contractually imposed on PMS through purchase orders with NRC licensees and within the PMS quality assurance manual.
1.
Criterion II, " Quality Assurance Program," of Appendix B to 10 CFR Part 50 requires, in part, that the quality assurance program will provide control over activities affecting the quality of systems and components. The program will take into account the need for special controls and skills to attain the required quality. The program will also provide for indoc-trination and training of personnel as necessary to assure that suitable proficiency is achieved and maintained.
Sections 2.2, 2.4'and 3.5 of ANSI /ASME N45.2.6-1978, " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants,"
requires, in part, that the capabilities of a candidate fu ;ertification will be initially determined by an evaluation of the candidate's education, experience, training, test results or capability demonstration. The qualification of personnel will be certified in writing, including:
(1) t the level of capa)ility; (2) activities certified to perform; (3) the basis used for certification, including:
(a) records of education, exper-ience and training; (b) test results, where applicable; and (c) results of capability demonstration; (4) results of periodic evaluations; and (5) l date of certification and date of certification expiration. Additionally, there are personnel education and experience requirements for each of the I
three capability levels, which delineate specific education and experience prerequisites.
ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants," requires, in part, that a prospective I
lead auditor will have participated in a minimum of five quality assurance l
audits within a period of time not to exceed three years prior to the date l
of qualification and that he will pass an examination to evaluate his comprehension and-ability of the requirements. Additionally, lead auditor proficiency records will be maintained and reviewed annually to maintain lead auditor qualification in accordance with the requirements.
Contrary to these requirements, PMS could not produce adequate documenta-tion to substantiate its qualification of its inspection and auditing i
I staff, specifically:
i a.
All of the records for the PMS technical staff Level II and Level III inspection personnel that were reviewed did not indicate 9009260323 nOO913 PDR OA999 ENVPLANN 99901101 PNU
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the activities employees were certified to perform nor the basis used for the certification of quslifications (88-01-04);
b.
Two of the three records for PMS technical staff level 11 and level III inspection persunnel that were reviewed did not contain objk-tive evidence to sutstantiate that the education and applicable experience requirements had been satisfied at the time they were certified (88-01-05);
c.
PMS could not provide objective evidence to substantiate that Mr.
Hanner had participated in a minimum of the required five audits i
during the three-year period before his certification as lead auditor forPMS(88-01-06);
d.
PMS could not provide objective evidence to indicate that Mr. Hanner's lead auditor qualifications had the required annual review performed since the initial July 1985 lead auditor certification (88-01-07);
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e.
An NRC telephone verification with the applicable colleges of two out of the three PMS technical staff revealed that a 2-year associate t-degree for one PMS person and a graduate (MBA) degree for the PMS president were not awarded to the personnel even though the respective i
resumes indicated that these persons had received the AA and NBA degrees (88-01-08).
2.
Criterion 111. " Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that the design basis for systems and components is correctly translated into specifications.
Section 4. " Design Control," of ANSI /ASME N45.2-1977 requires, in part, e
that all applicable design requirements, regulatory requirements, codes,
'i and standards be correctly translated into specifications, drawings, procedures or instructions, and that deviations from specific design requirements or quality sthndards be identified, documented and controlled.
Contrary to these requirements, PMS failed to correctly and fully translate specifications and purchase order requirements into seismic test procedure requirements for the Wyle test report for transformers in Fitzpatrick Purchase Order No. 86-5790, and failed to perform a material analysis for fuses ordered for Browns Ferry, PMS Job No. TV-1043 (88-01-09).
s 3.
Criterion VIII, " Identification and Control of Materials, Parts and Components," of Appendix B to 10 CFR Part 50 requires, in part, that measures will be established to tssure that identification of items is maintair;ed either on the item or on records traceable to the item.
i ANSI /ASME N45.2-1977 requires, in part, that measures will provide for l'
~ assuring that only correct and accepted items are used and installed, and the relation to an item (batch, lot, component, part) at any stage is maintained, from the initial receipt through fabrication, installation L
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or modification. When codes, standetds or specifications require trace-l ability of materials, parts or components to specific inspection or test records, the program will be designes to provide such traceability.
Section 6, of IEEE Standard 323-1974, as contractually imposed on PMS, requires, in part, that the qualification of Class 1E equipment will include the identification of the Class 1E equipment being qualified.
Contrary to these requirements, PMS could not verify the identification and subsequent record traceability of components tested by and procured by PMS for the New York Power Authority under its Fitzpatrick Purciase Order No.86-5790(88-01-10).
4.
Criterion XI, " Test Control," of Appendix B to.0 CFR Part 50 requires, in part, that a test program be established to assure that all testing required to demonstrate that systems and components will perform satis-r factorily in service.is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test results will be i
documented and evaluated to assure that test requirements have been satisfied.
ANSI /ASME N45.2-1977 requires, in part, that regardless of the degree of standardization or similarity to proven designs, the applicability of standardized or previously proven designs with respect to meeting per-tinent design requirements will be verified for each application.
Contrary to these requirements (88-01-11):
P a.
PMS issued certificates of compliance which indicated that some components, sue'; is electrical relays, vertical scale indicators for control rooa panels, transformers, and fuses, met various quali-fication standards without performing a verification that the basis ofcertification(e.g.,previousequipmentqualificationtesting).
was relevant, valid and, as a m 41 mum, enveloped the qualification requirements applicable to the current order; and L
b.
PMS could not provide objective evidence to ensure that each of the l
IEEE 323-1974 test sequence requirements were followed for the PMS L
environmental qualification testing performed for the contact assemblies on Public Service and Gas Purchase Order PI-127398 (PMS JobNo.P-1010).
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