ML17139B042

Suppl to Investigation of Unit 1 Small Piping Sys Design Installation & Insp Program Adequacy & Implementation. Viewgraphs Encl

ML17139B042
Person / Time
Site:	Susquehanna
Issue date:	08/24/1982
From:	Gulliver W, Shovlin R, Swoyer B PENNSYLVANIA POWER & LIGHT CO.
To:
Shared Package
ML17139B041	List: ML17139B040 ML17139B042 ML18031A396
References
NUDOCS 8209240294
Download: ML17139B042 (38)

Text

SUSQUEHANNA STEAM ELECTRIC STATION SUPPLEMENT TO INVESTIGATION OF UNIT ONE SMALL PIPING SYSTEM DESIGN INSTALLATION AND INSPECTION PROGRAM ADEQUACY AND IMPLEMENTATION PPSL AND BECHTZL QA COVERAGE Id) 8-Mez W. H. Gulliver B. 'C. o Investigation Team Leader Inveetigatiin Td m Leader g 2+T~

R. J. Shovlin Investigation Manager e

820924029'4 820908 PDR ADOCK 05000387 8 PDR

l~

I. OBJECTIVE The objective was to determine whether PPSL and Bechtel Q.A. Programs covered the areas of concern identified during the PPSL Investigation of Small Pipe Design/Installation.

II. SCOPE The scope was to review the documentation compiled by the PP&L and Bechtel Q.A. site organizations. This documentation was to reflect the site Q.A. activities conducted from January, 1981, through July, 1982, relating to small pipe design program. This investigation was conducted from August 19 to August 23, 1982.

Generally, the audits performed by Bechtel were of enough detail and depth to indicate that there was sufficient review of the particular aspect of the system being audited. Bechtel MCAR's (Management Corrective Action Report) and QAR's (Quality Action Report) aze written for'any particular discrepancy (outside an audit scope) that requires corrective action and follow-up. The following are examples of audit findings and QAR's that indicated problem areas related to those found during the PPSL Investigation:

l. Audit f/24-4-10, February, 1982, contained a finding that noted a non-compliance with the procedure for "voiding" drawings. (Another finding in this audit, although not related to the Investigation Report, reported that supervisor's signature (initials) being misused.)

2. Audit f/'s 30-3-4, 30-3-5, 30-3-6, and 30-9-2, dated March, 1981, August, 1981, April, 1982, and May, 1982, respectively, discovered various instances of lack of controls for procedural implementation and engineering interfaces.

3. Audit Pr24-4-9, June', 1981, contained findings that indicated various areas in which the "as-built" configuration of the piping did not agree with the drawings.

4. QAR 8859, July 30, 1982, dealt with Field Engineering not revewing SPA Drawings in a timely manner.

~

Page 1 of 3

5. QAR 8856, July 22, 1982, deals with the deficiency identified in the design of "SPA 600" hanger.

B. PP&L (P.A.

During the period under review, there were seven (7) formal and seven (7) unannounced audits relating to the small pipe program.

These audits covered such areas as document control, Q.C.

Inspection, and design control (related to interface control and the use of the latest information for design verification).

Numerous findings were identified during these audits and several of these still remain open. Some of the audits in which the findings were similar to those of the PPSL Investigation are:

1. Audit ftC-82-14 (joint audit with Bechtel), April, 1982, in which some procedural control were lacking in the Resident Engineering Group.

2. Audit /!C-81-06, January, 1982, identified problem areas in the Field Engineering locating hanger deficiencies in this

'alkdo~w.

3. Unannounced Audit 8111, September, 1981, discovered'various areas of procedural and implementation problems in the, design portion of the small pipe program.

B

4. N-5 Package Review Audit 8's CL-48, $ fay, 1982, CL-34, Hay, 1982, and CL-34, June, 1982, indicated areas in which there were drafting errors.

IV. CONCLUSIONS A. PPSL and Bechtel audits covered the programatic/procedural aspects of the small pipe design/installation program, but did not include a technical review of these aspects.

B. The Investigation Team had the benefit of technical sup'port.,

The majority of the concerns identified during the Investigat'ion were a result of the technical review. As a consequence of PP8L and Bechtel audits not having technical support, it cannot be expected that they would raise the same concerns that the Investigation Teams did.

C. The reviewing of PP8L and Bechtel audits reveal that their frequency d'id not increase in porportion to work being accomplished during the "final hectic period" (April-June 1982).

But both Bechtel and PPKL QA coverage of small pipe program existed in the forms of Bechtel QA surveillance of hanger Page 2 of 3

0 's-built installation (from Oct. 1981) and PP8L N-5 Package Review, which occurred from September, 1981, through July, 1982.

These activities increased in proportion to the work being accomplished during the "final hectic period." These activities and any discrepancies were formally documented.

V. 'GENERAL INFORMATION A. Persons Contacted Gene Glorvigen Bechtel QAE Jitendra Khandhar Bechtel QAE Ross Beckley PPBL Q.A.

Ted Newman PP&L Q.A.

Ron Matthews PPGL Q.A.

B'. Documents Referenced

1. Bechtel Audits No's 30-3-4, March, 1981, 30-3-5, August, 1981, 30-3-6, April, 1982, 30-9-2, May, 1982, 24-4-10, February, 1982, 24-4-9, June, 1981, and 24-4-11, April, 1982..

.2. PPSL Formal Audit No's C-81-06, January, 1982, C-82-09, March, 1982, C-82-13, June, 1982, C-82-14, April, 1982, 115, October, 1981 and 109, July, 1981.

0

3. PPSL Unannounced Audit No's. CL-4, August, 1981, CL-4, June, 1981, CL-4, June, 1982, CL-33, December, 1981, CL-4, December, 1981, CL-26, June, 1982, CL-26, January, 1981, CL-48, May, 1982, CL-34, May, 1982, and CL-34, June, 1982.

4. Bechtel QAR No's. 859, July 30, 1982, 856, July 22, 1982, 855, July 15, 1982, 841, May 28, 1981, 784, February 21, 1981, 744, October 5, 1981, 736, September, 11, 1981, and 678, March 1981.

5. Bechtel MCAR No's. 1-77, October 27, 1981, 1-73, July 2, 1981, 1-72, June 10, 1981, and 1-67, February 11, 1981.

6. Bechtel Management Audit conducted on 10/27-31/81.

BMS: lm S-25

'age 3 of 3

SHALL PIPING ACTION PLAN RESULTS INTRODUCTION BACKGROUND NRC CONF I RNATORY ACTION LETTER 82-21 SPECIFIC ISSUES ALLEGATIONS A".iD NRC CONCEPTS DISPOSITION CORRECTIVE ACTIONS OTHER QUESTIONS SNALL PIPING PROGRAN INVESTIGATION FINDINGS DISPOSITION CORRECTIVE ACTIONS CONCLUSIONS

PARALLEL PROGRAN GENERIC ISSUES CONCERNS DISPOSITION CORRECTIVE ACTIONS SUNNARY AND CONCLUSIONS SNALI P I P I NG PROGRAN SNALL P I P I NG ADEQUACY PARALLEL DESIGN PROGRAN ADEQUACY RENAINING ACTION (CORRECTIVE AND PREVENTIVE)

SCHEDULE

t!

l 0

\

INTRODUCTION NRC CONFIRMATORY ACTION LETTER 82-21 1,'ENNSYLVAflIA POWER AND LIGHT COMPANY WILL CONDUCT AN INVESTIGATION TO ASSURE THAT DESIGN CRITERIA AND ASSUMPTIONS WERE PROPERLY TRANSLATED, If"TO DESIGN DOCUMENTS AND IMPLEMENTED DURING CONSTRUCT I 0< AND INSPECTION. THE INVESTIGATION WILL EXAMINE THE SMALL BORE I PE DESIGN PROGRAM AS WELL AS OTHER SIGNIFICANT PROGRAMS.

2, IDENTIFIED DEFICIENCIES OR WEAKNESSES WILL BE EVALUATED CORRECTIVE ACTIONS IMPLEMENTED, AND MEASURES ESTABLISHED TO PRECLUDE RECURRENCE,

~ 3, THE LIST OF TECHNICAL ISSUES IDENT IF I ED BY THE NRC AT THE JULY 28 AND 30, 1982, MEETING WILL BE EVALUATED, DISPOSITIOf'lED, AND CORRECTED, RESOLUTION OF THESE ITEMS WILL BE PRESENTED TO THE NRC f'lOT LATER THAN AUGUST 25, 1982, 4, THE SMALL BORE PIPE PROGRAM WILL BE EXAMINED FOR PROGRAM ADEQUACY AND SAMPLED FOR DETAILED IMPLEMENTATIOf'j, 5, THE FINDINGS IDENTIFIED BY THE NRC AND THOSE SUBSEQUENTLY IDENTIFIED BY THE PPL REVIEW WILL BE EVALUATED, THE EVALUATION WILL COMPARE SIf'"'lILARITIES IN THE SMALL'ORE PIPE PROGRAM, WITH OTHER PARALLEL PROCRAMS FOR GENERIC DEFICIENCIES AND WEAKNESSES,

SMALL PI PE INVESTIGATION NRC QUESTIONS AUGUST t8, I982 QC ACCEPTANCE OF INACCESSIBLE ATTRIBUTES 0 SIGNATURE DENOTES CLAMP LOCATION OR I ENTAT I ON g ETC c 0 BOLTS NOT REQUIRED TO BE INSPECTED BY QC IN INSTALLED POSITION 0 BOLTS RECEIPT INSPECTED BY QC 0 OTHER SPECIFIED BUT INACCESSIBLE ATTRIBUTES, NCR 0 CONCLUSIONS ALL REQUIRED ATTRIBUTES'NSPECTED S I( NATURE LEG IT IMATE

I' SMALL PIPE INVESTIGATION NRC QUESTIONS AUGUST L8, 1982.

RESIDENT E FIELD ENGINEERS WORKING TOGETHER SAME SUPERVISION e WORKED IN SAME LOCATION 0 IMPROVED COORDINATION AND EFFICIENCY 0 WORKED UNDER SEPARATE MANAGEMENT 0 LENT ENGINEERS APPLIES TO UNIT 2 SAME CALCULATOR/VERIFIER BACKED UP BY CHECKER AND SUPERVISOR 0 CONCLUSIONS ORGANIZATION LEGITIMATE VERIFICATION PROCESS ASSURES SATISFACTORY DESIGN

SMALL PIPE INVESTIGATION NRC QUESTIONS AUGUST t8, 1982 ADEAUACY OF BECHTEL 8 PP~L QA COVERAGE 0 BECHTEL

38. FORMAL AUDITS MCAR R QAR PROCESS PROVIDED ADDITIONAL COVERAGE 0

FINDINGS INCLUDED INSTALLATION/DRAWINGDISCREPANCIES IMPROPER S IGNATURES CLARITY OF INSPECTION ATTRIBUTES CALCULATION PROCESSING

0 SMALL PIPE INVESTIAATION NRC QUESTIONS AUGUST 18, 1982 ADEQUACY OF BECHTEL R PPRL QA COVERAGE 0 PPRL (JANUARY'982 JULY'982)

FORMAL AUDITS j.00Ã REVIEW N-5 OF PACKAGES AUD.I T F I ND I NGS INCLUDED PROCEDURAL CONTROL IN RE IDENTIFICATION OF DEFICIENCY BY FE PROCEDURAL'ROBLEMS DRAFTING ERRORS 0 CONCLUSIONS BECHTEL R PPRL QA COVERAGE ADEQUATE MANHOURS INCREASED DURING APRIL JULY, L982 PROBLEMS TYPICAL PROCESS NOT OUT OF CONTROL

SMALL PIPE INVESTIGATION OBJECTIVES

. 1 ASSURE SAFE OPERATION 0 ASSESS ADEQUACY OF DESIGN/INSTALLATION/

INSPECTION 6 SUGGEST GENERIC DUPLICATIONS 0 ASSESS ADEQUACY OF QA COVERAGE CONDUCT 0 TWO TEAMS 0 PROGRAM REVIEW INTERVIEWS 0 WALKDOWNS I COMPARE NOTES e FEEDBACK TO PLANT SUPERINTENDENT REVIEW COMMITTEE 0 REPORT

SMALL PIPE INVESTIGATION FINDINGS INFORMAL CHANGES TO DESIGN CRITERIA 0 FIELD CONDITIONS NECESSITATED MODIFICATIONS. TO DESIGN 0 COVERED SPAN LENGTHS'VERHANGS GEOMETRY ADJUSTMENT 0 SHOULD HAVE BEEN FORMALIZED k

0 NOT USING MEMOS RESULTS IN MORE CONSERVATIVE DESIGN

0 BECHTEL REVIEWED MEMOS I

INCORPORATED INTO DESIGN CRITERIA

%WL'L "-P I PE I NVESTI GATI ON FINDINGS

. QS =BUILT DRAWING DISCREPANCIES (0 .VAR I OUS 'F I ND I NGS REGARD I NG VO I D I NG g

ORI.ENTATIONp USE OF REVISIONS (0

I'ND I.CAT I VE OF CONTROL/PROCESSING PROBLEMS (0 ..BECHTEL

-- .ASSESSES AS ISOLATED INSTANCES AFTER REVIEW AS BU I LT/RECONC I LIATI ON PROCESS RESOLVES REVIEW PROCESS FOR 'NIT 2 (0:PPRL CONCURS

SMALL PIPE INVESTIGATION FINDING FAILURE TO, FORWARD DESIGN DETAILS 0 DRAWINGS HELD BY FIELD ENGINEERING 0 DRAWINGS NEVER GOT TO RESIDENT ENGINEERING 0 BECHTEL RE RECEIVED DRAWINGS FROM SAN FRANCISCO FORMALLY RE USE CORRECT. DESIGN INFORMATION IN RECONCILIATION PROCESS FIELD PROCEDURES REVIEW AND REVISE I

PPRL CONCURS

SMALL PIPE INVESTIGATION FINDINGS USE OF ENGINEERING JUDGEMENT IN AS BUILT RECONCILIATION 9 LIMITS NOT DEFINED 6 INCONS I STENT APPLICATION BECHTEL QUALI FIED ENGINEERS (R i E GROUP)

CONCURRENCE BY CHECKER AND SUPERVISOR REVIEW AREA AND PROVIDE DIRECTION 0 PPRL CONCURS

SMALL PIPE INVESTIGATION FINDINGS

. USE OF LATEST DRAWING REVISION IN THERMAL WALKDOWN 0 FORMAT NOT DESCRIBED IN PROCEDURE 6 BECHTEL DRAWING USED FOR ORIENTATION REVIEW BASED ON FIELD CONDITIONS FsEi SUBSEQUENT REVIEW IF CHANGES OCCURRED PPRL CONCURS

i' SMALL PIPE INVESTIGATION FINDINGS DESIGN CONTROL MEASURES 0 SUMMARIZES SEVERAL FINDINGS/OBSERVATIONS ISSUANCE OF DESIGN DIRECTION INFORMAL TRANSMITTAL OF DRAWINGS DISTRIBUTION/CONTROL OF DOCUMENTS USE OF AS BUILTS 0 BECHTEL MOST INSTANCES CITED WERE EXPLAINED AFTER FURTHER INVESTIGATION REVIEW AND REVISE CONTROL PROCEDURES QA VERIFIED COMPLIANCE WITH MINOR PROBLEMS 9 PPRL CONCURS

SMALL PIPE INVESTIGATION F INDI NAS INSPECTION OF DETAIL 600 CLAMPS 0 NO CRITERIA FOR EAR GAP MEASUREMENT 0 WERE OTHER ATTRIBUTES MISSED IN ENGINEERING DEFINITION 0 BECHTEL SPA REVISED REVI EW AND REVISE SPECIFICATION O PPRL 100'~ INSPECT I ON COMPLETE CONCUR WITH BECHTEL ACTION

(y a SMALL PIPE INVESTIGATION FINDINGS INSPECTION CRITERIA FOR PRE-FABRICATED

-COMPONENTS 0 NO INSPECTION REQUIREMENTS 0 EXAMPLES

- DETAILS 600 GAPS SWAY STRUT JAM NUTS 0 BECHTEL t

IDENTIFY ATTRIBUTES ON DESIGN DRAWINGS UPGRADE INSPECTION REQUIREMENTS GENERIC REVIEW I PPRL CONCURS

SMALL PIPE INVESTIGATION CONCLUSIONS SMALL PIPE PROGRAM 0 REVIEW OTHER SMALL PIPE SYSTEMS EVALUATE UNIT 2 PROGRAM 6 RE-DEFINE INTERFACE RESPONSIBILITIES O REViEW PROGRAMMATIC TRAINiNG 0 EVALUATE QUALITY ASSURANCE COVERAGE 6 STRONG WALKDOWN PROGRAM I

9 AS-BUILT PROGRAM ADEQUATE i1 QC PROGRAM ADEQUATE'FFECTIVE I

GENERIC IMPLICATIONS

' REVIEW PROGRAMS WITH SPLIT DESIGN RESPON SIBILITY REVIEW DOCUMENTATION CONTROL PROGRAM I INCREASE MANAGEMENT ATTENTION

~

i ~ ~

PARALLEL PROCRAN GENERIC ISSUES DESIGN CONTROL o CONTROL OF SPECIFICATION CHANGES (G-1-1) i o ENGINEERING JUDGEMENT (F-1-3) (F-1-12) o QUALITY RELATED ACTIVITIES PERFORNED TO CURRENT DESIGN DOCUNENTS (F-1-0)

DESIGN INTERFACE CONTROL o DESIGN DIRECTION PROCESSING (F-2-1)

DESIGN CHANGE CONTROL o POST NALKDONN CHANGES (F-1-15)

'NSTALLATION AND INS, ECTION o CRITERIA ADEQUACY DOCUNENT CONTROL o CONTROL OF SPECIFICATION CHANGES (F-1-1) o CONTROL OF "RED LINE" DRAMINGS (F-1-2)

DOCUMENT CONTROL (CONTINUED) o CURRENT DOCUMENTS FOR QUALITY RELATED ACTIVITIES (F-1-I4) o DOCUMENT TRANSMITTAL (F-1-6) o DRAWING CHECKI NG/APPROVI f ~6

~

SNALL PIPING PROGRAN o EVOLUTION o UNIQUE o DEF I C I ENCI ES o CONPLETE DETAILED AS BUILTS o RESULTS-

SMALL PIPE ADEQUACY o DESIGN APPROACH (M241) IS VALID AND CONSERVATIVE 0 ALL SMALL P I P I NG DESIGNED US I NC M2 41 OR DETAILED ANALYSI S o AS BUILT PROCESS GOOD, r,E. GOOD CORRELATION o THERMAL INTERFERENCE AND STPESS !AALKDOPINS MERE EFFFCTIVE o RECONCILIATION EFFORT PROVIDES HIGH DEGREE OF CONFIDENCE THAT SMALL PIPING, AS INSTALLED. MEETS THE DESIGN INTENT o IDENTIFIED DISCREPANCIES IN THE RECONCILIATION PROCESS HAVE BEEN CONSISTENTLY SHOWN TO BE ISOLATED IMPLEMENTATION PROBLEMS , (NOT PROGRAM BREAKDOMNS)

AND NOT SIGNIFICANT TO SYSTEM DESIGN ADEQUACY

~ ~

CORRECTIVE ACTIONS TO BE ACCOMPLISHED ACTION ITEM CORRECTIVE ACTION FROM DATE DUE Perform a 100% inspection on NRC Question //15 Prior to heat. up 35 snubbers and a 10% inspection all'ize exceeding 150'F on the balance of Unit //1 snubbers to ensure clearance between the snubber end and clamp ear.

Review all Field Procedures involving NRC Question //19 September 30, 1982 Field Design for lack of clear direc-tion concerning the review/checking and approval functions for design draw-ings and instruct the appropriate per-

~sonnel as to the importance of adhering to the requirements in this area.

Bechtel Project Management will re- Finding l-l September 30, 1982 emphasize that project procedures Generic Concern l-l must be used to change design docu-ments and that greater caution must be excercised by engineering super-visors in deciding what constitutes a design change as opposed to en-gineering guidance.

Field procedures will be revised as Finding 1-5 September 30, 1982 applicable to indicate time constraints Finding 2-1 on field engineering review of engineer- Generic Concern 2-1 ing designs and how to provide documenta-tion of this review. Also Bechtel's computerized logs will be used to reconcile differences between engineering issued and field issued P.S.'details. Q.C. will verify if~re is any peP%frmed.

impact on the inspection

0 ACTION ITEM CORRECTIVE ACTION FROM DATE DUE Bechtel Project Management will re Finding 1-5 September 30, 1982 emphasize with all supervision the need to comply with document control procedures and the requirements to verify that all quality related activities are being done with the current document revision.

Bechtel will reemphasize that all attributes Finding 2-4 September 30, 1982 absolutely necessary for design intent to be Finding 2-4 met, will be identified on the design drawings.

Pipe Support fabrication, installation,. and inspection Specification M-213 (including Appendix F) will be revised to (1) amplify the need to inspect'or vendor specified uirements and (2) identify all critical ~

ibutes on hanger design detail drawings t us establishing the need to inspect for these attributes.

Project Engineering will .review and provide input to QC on hanger QCI's functional require-ments and design intent. QC will revise QCI's as necessary.

0 r ~ >

MAJOR AREAS OF CONCERN o ADEQUATE INSPECTION AND INSTALLATION OF PREFABRICATED COMPONENTS o DESIGN DELEGATION SPLIT RESPONSIBILITY o SENSITIVITY TO SCHEDULE PRESSURE o DOCUMENT CONTROL IMPLEMENTATION o DESIGN CONTROL SENSITIVITY 0 LACK OF REAL TIi lE PROGRAM REVIEW