ML20148H305

Notice of Nonconformance from Insp on 871207-11. Nonconformance Noted:Failure to Establish Adequate QA Program to Control safety-related Activities Re Fire Damper Design & QA Monitoring Design Areas

ML20148H305
Person / Time
Issue date:	03/22/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20148H281	List: ML20148H275 ML20148H305 ML20148H326
References
REF-QA-99900853 NUDOCS 8803290386
Download: ML20148H305 (2)

Text

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APPENDIX A Pullman Construction Industries Docket' No. 99900853/87-01 l

NOTICE OF NONCONFORMANCE l

1 Based on the results of an NRC inspection conducted on December 7-11,1987, it '

appears that certain of your activities were not conducted in accordance with the NRC requirements. These items are set forth below and have been identified and classified in accordance with Appendix B to 10 CFR Part 50.

1. Criterion I, "Organization," of Appendix B to 10 CFR Part 50 requires, in <

part, that the authority and duties of persons and organizations performing l activities affecting the safety-related functions of components and '

systems be clearly established and delineated in writing. These activities include both the performing functions of attaining quality objectives and the quality assurance functions.

Criterion II, "Quality Assurance Program," of Appendix B to 10 CFR Part 50 ,

requires, in part, that a quality assurance (QA) program which complies '

with the applicable requirements of this appendix be established. This program shall be documented by written policies, procedures, or instruc- )

tions. The QA program shall provide control over activities affecting the quality of the systems and components, to an extent consistent with their importance to safety.

Criterion III, "Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that measures shall be established to assure that the design basis for systems and components are correctly translated into specifications, l drawings, procedures and instructions. These measures shall include  !

provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Measures shall also be established for the selection and review for suitability of application of equipment that is essential to the safety-related functions of the systems. Design control measures shall provide for verifying or checking the adequacy of design, such as by performance of design reviews.

Section II, "Quality Assurance Program," of the Pullman Construction Industries, Incorporated (PCI) quality assurance manual, revision 2, dated January 28, 1986, requires, in part, that PCI will assure that activities affecting quality are documented and accomplished in accordance with written instructions. -,

Section III, "Design Control," of the PCI QA Manual, states, in part

...PCI shall control design documents and changes thereto in accordance l with procedures established to meet the requirements of the individual project specifications...PCI accepts the design control responsibility for the PCI fire damper models FD-100, FD-200 and FD-400....No calculations or engineering determinations are made by PCI personnel. Product design i is based on actual test or analysis." ,

88032 % 336 680322 PDR Op999 ENVPULLM ,

99900BDS PDR

Contrary to the above, PCI has failed to establish an adequate QA program to control its safety-related activities in regard to the fire damper design and QA monitoring of design areas. Examples of this are noted as follows:

a. Objective evidence could not be provided that would indicate that PCI had performed an independent review for technical adequacy of the fire dwper "suitability for application" evaluations that it has performed for several NRC licensees;

b. Objective evidence could not be provided that would indicate that PCI had performed an independent review for technical adequacy of its fire damper performance qualification curves;

c. PCI has not adequately delineated the authority and duties of its design engineers who perfonn activities affecting the functions of safety-related fire dampers, nor has it delineated associated monitoring. duties for its QA engineers;

d. PCI has not established adequate engineering procedures or instructions to provide control over its activities affecting safety-related fire dampers;

e. It could not be determined by a review of objective evidence whether or not PCI has correctly translated its ir.-house fire damper raw test data into PCI design parameters or instructions; and

f. Calculations and engineering determinations for safety-related fire dampers are typically perfonned by PCI engineering personnel without benefit of procedures, instructions or QA monitoring activitics.