ML19259C505
| ML19259C505 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1979 |
| From: | Brown R, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19259C499 | List: |
| References | |
| REF-QA-99900507 99900507-79-1, NUDOCS 7906220222 | |
| Download: ML19259C505 (16) | |
Text
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U.S. NUCLEAR REGULATORY C0f01ISS10N OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900507/79-01 Program No. 51200 Company:
Sargent and Lundy Engineers 55 E st Monroe Street Chi o, Illinois 60603 Inspection at: Chicago, Illinois Ins ection Conducted: March 12-16, 1979 r
I Inspectors:
k SOh 3.R.(Cojtello,PrincfpalInspector, Date Vendof Inspection Branch stL dk h7h R. L. Brpwn, Principal /InApector, Date Vendor Inspection Branch t
Approved by:
h k.
~
C. J. Pglf, Vendor Inspection Branch Chief, Program Evaluation Date
- Secti6n, Summary Inspection on March 12-16, 1979 (99900507/79-01)
Areas Inspected:
Implementation of Sargent & Lundy Tcpical Report SL-TR-1A, Revision 5, including design input, procurement document control, records, and action on previous inspection findings. The inspection involved sixty-four (64) hours on site by two (2) USNRC inspectors.
Results:
In the four (4) areas inspected, two (2) deviations were identified in two (?) areas and one (1) unresolved item was identified in one of the other areas.
Deviations:
(1) Follow-up cn Previous Inspection Findings - Project In-struction covering project status reports does not meet the requirements of GO 3.12 on project 4391/4392/4633/4684 (see enclosure, " Notice of Devia-tion," item A).
(2) Records - Scme Project Managers are not dating their signatures en QA Record Submittal Schedules as required by S&L Procedure GQ 17.01 (see enclosure, " Notice of Deviation," item B).
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2 Unresolved Item:
Procurement Document Control - Project procedures for project 4536 do not assign responsibility for resolution and/or close out of supplier's QA program deficiencies identified by Sargent & Lundy Engi-neers (see DetailsSection II, paragraph C.3.b).
228116)
N.
-e s
_ DetailsSection I (Prepared by J. R. Costello)
A.
Persons Contacted W. C. Cleff, Mechanical Project Engineer M. E. Dickerman, Lead Record Technician G. Horb, Project Leader E. Kabot, Quality Assurance Controller M. A. Mensing, Electrical Engineer D. C. Patel, Supervising Design Engineer A. J. Skale, QA Coordinator
- H. S. Taylor, Assistant Head, Quality Assurance Division D. C. Treece, Senior Electrical Project Engineer
- Denotes those present at exit meeting B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 77-03):
Duplicate record storage practices and facilities are not being maintained as required.
Sargent and Lundy and the Quality Assurance Branch (QAB) of NRC have agreed to the use of a four (4) hour rated safe located in the present two (2) hour rated temperature and humidity controlled records storage facility.
This qualifies as a single records storage facility and is now in use.
2.
(Closed) Unresolved Item (Report No. 78-02):
Implementation of Procedure GQ 3.12 for issuing Project Status Reports does not appear to be meeting procedure requirements for date of issue.
Revision 7 was is ued one month late, but subsequent issues have been meeting issue dates.
Project Manager has been notified of the deviation and the requirement for meeting commitment dates.
During this review, the inspector noted that Project Instruction PI-BB-1, Revision 4, did not meet the requirements of GQ 3.12 (see enclosure, " Notice of Deviation," item A).
3.
(Closed) Deviation (Report No. 78-03):
Contrary to procedure GQ 18.01, the Head, Quality Assurance Division has not been dating his final approval signature on the audit schedules.
Procedure GQ 18.01 has been revised removing the requirement for the Head, Quality Assurance Division to date his signature.
4.
(Closed) Ceviation (Report No. 78-03):
Centrary to the letters of September 21, 1978, and November 1, 1978, all of the requested 228116%
comments had not been received and documented by November 1, 1978, and the audit results were not available by December 1,1978.
The inspector verified that all requested comments have been received and documented and Internal Audit Report No. 32, con-to detennine if this deviation existed in other areas, dur.e n was approved and issued December 21, 1978.
Internal Audit Report No. 32 identified nine (9) additional nonconformances in this area.
C.
QA Records 1.
Objectives The objective of this area of the inspection was to examine the establishment and implementation of quality related procedures for collecting, filing, storing, maintaining, and dispositioning of QA records to verify that:
a.
A QA records system is defined, implemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups perfonning safety re-lated activities including QA, design, procurement, admini-stration, and services.
(QA records generated after com-mercial operation are subject to the record control system.)
b.
QA records are legible, completely filled out, adequately identifiable to the item involved, validated, and listed in an index that indicates:
the record retention time, where the record is to be stored, and the location of the record in the storage area. Any changes or modifications to these records are controlled.
c.
A specific submittal plan for QA records is established between the licensee and contractor and records exist that acknowledge the licensee's receipt of QA records.
d.
A designated authority has been assigned to control tre receipt of QA records by a system which includes a list of QA records required, a record of QA records received, and an inspection of incoming records including a current assessment of the status of incoming records.
e.
A custodian has been designated to assure that QA records are in accordance with b. above and to enforce a QA record storage filing system which includes a system description of the filing technique and storage area, rules for access and centrol of record files, accountability of records removed from record files and security requirements.
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f.
The QA record storage facility is in compliance with appli-cable codes, standards, and regulations consistent with NRC Regulatory Guide 1.88.
g.
The QA record storage system is periodically audited to assure the record control system is implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Sargent & Lundy Topical Report SL-TR-1A, Revision 5, Section 17 (Quality Assurance Records) which establishes QA program commitments.
b.
Implementing procedures to satisfy topical commitments and satisfy items (a' through (g) of the Objectives section.
(1) General Quality Assurance Procedures l
GQ 17.01, Revision 3, Submittal Schedule For Quality Assurance Records GQ 17.02, Revision 3, Quality Assurance Records -
Collection, Storage, Retrieval and Disposition f
(.2 ) Quality Assurance Division Internal Procedures (Sec-i tion V - Records Section)
RSIP-3, Revision 1, Receipt and Verification of Quality Assurance Record Transmittals RSIP-4, Revision 1, Distribution, Review and File Main-tenance of the Quality Assurance Active Records Index RSIP-5, Revision 2, Processing Quality Assurance Records RSIP-6, Revision 2, Indexing Quality Assurance Records RSIP-7, Revision 2, Microfilming Quality Assurance Records RSIP-8, Revision 2, Processing Quality Assurance Record Input Data and Microfilm RSIP-9, Revision 1, Creating or updating the Quality Assurance Record File RSIP-10,,,evision 4, Retention / Retrieval of Quality Assurance Records 2281 16g c.
Documents to verify implementation of topical comitment and procedural requirements and to satisfy implementation of (a) through (g) of the objectives section.
(1) QA Record Submittal Schedule for nine (9) projects.
(2) Quality Assurance Active Records Index dated February 28, 1979.
(3) QA Records File Location Assignment Log.
(4) Two (2) sets of documents and two (2) sets of aperature cards submitted on Form GQ-17.02-1 (Transmittal of QA Records) for project 4391/4392.
(5) Record log of weekly readings of temperature, humidity and fire extinguisher pressure in the Quality Assurance Records Center facility.
(6) List of personnel who have access to QA Records Center Safe.
(7) Sample format of a Quality Assurance Inactive Records Index - There are no inactive records yet, as no records have been shipped to the client.
(8) Management audits of the S&L Quality Assurance Division -
These audits cover the records operation which is in the Quality Assurance Division.
(a) M2 Audit conducted July 20-November 3,1976 (b) M3 Audit conducted January 10-31, 1978 (c) M4 Audit conducted October 23-31, 1978 (91 Generic documents retrieved from Quality Assurance Records Center Safe.
File Index No.
, Title (a) 02AG01 Calculations - Column Lead Tabu-lations Reactor Building (b)
A4B External Audi. Schedule Index (c)
QCPS.2 Pre-Award Audit Centractors CA Program 2281 167
._ File Index t h Title (d)
QCP8.8 Source Inspection (e)
QCP8.1.1 Review Contractors OA Program (f}
1741 Standard Specification For Piping Supports (g) 010752 Seismic Qualification Procedure For Essential Service Water Pump Motors (h) 8.1 Calculation - Pressure Drop Sensitivity (10) Project documents retrieved from Quality Assurance Records Center Safe File Index No.
Title (a) 9.17 Calculations - Essential Service Water Systems (b) ECN 437 Engineering Change Notice 437 (c) ECft 210 Engineering Change Notice 210 (d). ECN 577 Engineering Change Notice 577 (e) 1.2.3 Field Change Request 1297 (f) 1.2.4(15178EGJD)
Nonconfonnance Report 1310 (g) DC-SD03 Containment Structural Design Criteria (h) 1.2.4(04379IJDB)
Nonconfonnar ce Report 1763 (11) Project drawings retrieved from Quality Assurance Records Center Safe.
Drawing No.
, Title (a)
IE-1-4321AE Internal / External Wiring Diagran Centainment A Electrical Penetra-tion 2281 168
_ Drawing No.
Title (b)
IE-1-4340AD Internal / External Wiring Diagram 6900V Switchgear (c) 6/20E-0-3021B Cable Pans, Piece Parts and Covers Auxiliary Building (d) M-42A Diagram of Essential Service Water Components (e) M-907 Turbine Building Piping in Sub-structure (f) M03-1119-05 Mechanical Piping Penetration Schedule Control Building (g) S-729 Auxiliary Building Foundation Section 2-2 (h) S-1017 Containment Building Pool Liner (i) S-757 Auxiliary Building Section and Details 3.
Findings a..
General Comments On Sargent & Lundy's Single Storage Record Facility (11 All records are treated as lifetime.
(21 No record submittal plans between client and S&L have been developed as of this date.
(31 All records in storage are microfilm reproductions of original hard copies.
(4) Records are stored in a four (4) hour fire rated safe which is located in a two (2) hour fire rated temperature and humidity controlled facility.
(51 S&L top management has decreed that ;M records must be ccmpletely legible for microf G
.g er they must be redrawn or redone so they 7.6 2281 169 b.
One deviation was identified in this area of inspection (see enclosure " Notice of Deviation," item B) and no unresolved items were identified.
D.
Exit Meeting A meeting was conducted with management representatives at the con-clusion of the inspection on March 16, 1979.
In addition to the indi-viduals indicated by an asterisk in the Details Sections, those in attendance were:
J. M. McLaughlin, Assistant Manager Structural Department D. C. McClintock, Manager Electrical Department A. D. Taylor, Administrative Assistant, Electrical Department S. A. Zych, Head Quality Control Division The inspector summarized the scope and findings of the inspection for those present at the meeting. Actions taken on the findings identi-fied in previous inspections were also discussed along with the reso-lutions of these findings. Management representatives acknowledged the statements of the inspector.
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- DetailsSection II (Prepared by Ross L. Brown)
A.
Persons Contacted S. L. Delmotte, Mechanical Engineer J. A. Dudeck, Senior QC Coordinator R. W. Evans, Mechanical Engineer
- A.
P. Gillis, Senior QA Coordinator R. C. Heider, Project Manager
- J. E. McFarland, Head, QA Division P. A. Nevins, Senior Engineer (Electrical)
A. Rahman, Electrical Engineer M. J. Shewski, Mechanical Engineer
- H. S. Taylor, Assistant Head, QA Division
- R. A. Witt, Senior Structural Project Engineer
- De iotes those present at the exit meeting.
B.
Design Inputs 1.
Objectives The objectives of this area of the inspection were to determine tnat:
a.
Procedures have been established and are being implemented that prescribe the system for control of those criteria, parameters, bases, or other design requirements upon which detailed final design is based.
b.
Design inputs are specified on a timely basis, their selec-tion reviewed and approved, incorporated into the design documents, and changes in input are justified, reviewed, and approved.
c.
Commitments are properly translated into design inputs, as applicable to the following:
(1) Basic functions (2)
Perfomance requirements (3)
Regulatory requirements, codes, and standards 2281 171
-- (4)
Design conditions (5)
Loads (6)
Environmental conditions.
d.
Ce >1gn requirements are specified, when applicable, relating to interfaces, materials, mechanical, structural, hydraulic, chemistry, electrical, instrumentation and control, redundancy, accessibility, fire protection, and other requirements that present undue risk to the health and safety of the public.
2.
Methods of Accomplishment The above objectives were accomplished by:
a.
Review of the Sargent & Lundy (S&L) Topical Report SL-TR-1A, Revision 5, dated October 31,1977, (topical report) Sec-tion 3.00 to determine the S&L commitments relative to design inputs.
b.
Review of the following General Quality Assurance Procedures
(.QAP) to determine if the QA program includes procedures that provide responsibilities and control of the design activities which affect the quality of safety-related items:
(11 GQ-3.04, Revision 4, dated September 20, 1978, which describes the requirements and responsibilities for the preparation, review and approval of the design criteria.
(2) GQ-3.06, Revision 1, dated July 30, 1976, describes the responsibilities and requirements for the prepara-tion, review, approval and distribution of S&L standards that pertain to safety-related items.
The procedure also identifies the typical design input for the stan-dard.
(3) GQ-3.07, Revision 4, dated August 21, 1978, that assigns the responsibility to provide and receive the design input, as required for the preparation and completion of S&L drawing, it also assigns the responsibility for review and approval of the drawing for technical ade-quacy.
(4)
GQ-3.08, Revision 3, dated May 27, 1977, which requires the preparation of calculations per the design input data and assigns the responsibility for their review and approval.
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~ _ _ (5) GQ-3.10, Revision 4, dated September 20, 1978, describes the requirements for planning and performing design reviews in accordance with the department standard (GQ-3.06).
(6) GQ-3.12, Revision 2, dated October 23, 1978, requires a project status report to be prepared to identify the current status of various design documents.
It also establishes the updating frequency of the report.
c.
Review of the following documents relative to Project No.
4536-00 to verify implementation of the program as described in B.2.a and B.2.b.
(1) Calculation No. 01RH1 related to the portions of the Residual Heat Removal System (RHRS) assigned to S&L.
This document references the design criteria furnished by the NSSS.
(2) One Piping & Instrumentation Diagram Drawing and one Single Line System drawing relative to the RHRS.
(3) Calculation No.19-D-1 for Battery Charges.
i (4) Specification K-2989, contract date August 29, 1977, appears to accurately reference the requirements of calculation No.19-D-1.
(5) Calculation No.19-D-2 for 125V-DC Batteries, reference the inputs from S&L Standard ESC-291 and project assigned industry standards.
(6) Specification K-2988, contract date September 30, 1977, references the requirements established in the Calcula-tion No. 19-D-2.
(7) Design Criteria for DC Power System (Class IE portion)
DC-DC-01-CP.
(8) One Single Line Diagram - ES-136, identifies the 125V-DC system ccmponents.
3.
Findincs No deviations from commitment or unresolved items were identified in this area of the inspection.
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_ C.
Procurement Document Control 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been prepared and are being implemented to assure that:
a.
The organizations involved in the execution of procurement activities have been identified and their responsibilities delineated.
b.
Procurement documents include the scope of work to be per-formed by the supplier, the technical requirements, material and equipment specifications, procedures and instructions, test and inspection requirements, acceptance requirements, and identification, packaging, handling and shipping require-ments.
c.
Procurement documents require that the supplier have a docu-mented quality assurance program consistent with 10 CFR 50, Appendix B, codes and applicable standards.
d.
The supplier is required to incorporate appropriate quality assurance program requirements in sub-vendor procurement documents.
e.
Procurement documents are reviewed by the QA organization before transmittal to the prospective suppliers and these reviews are documented.
f.
Changes to procurement documents undergo the same degree of review and controls as the original documents.
g.
Measures to control the release and distribution of procure-ment documents are being implemented.
2.
Methods of Accomolishment The above objectives were accomplished by:
a.
Review of the topical report Section 4.00 to determine that procedures are required to verify that regulatnry/ code re-quirements, design bases and technical / quality requirements are included or referenced in the procurements documents.
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. b.
Review of the following procedures to verify that the pro-gram exists to control the procurement activities.
(1) GQ-4.01, Revision 7, dated August 21, 1978, that re-quires the procurement specification to either include or reference the technical and quality requirements.
(2) GQ-4.02, Revision 4, dated July 30, 1976, that describes the requirements and responsibilities for the evaluation and recommendation of award for the purchase of safety-related items and services.
c.
Review of the owners Quality Assurance Manual for Project No. 4536-00, Chapter 7, to determine the S&L responsibility related to the purchase of Balance of Plant (BOP) material, equipment and services.
d.
Review of the Outline of Procedure, Reference No. 3356, Revision 13, dated June 17, 1978, for Project No. 4536-00, i
to determine the method is prescribed for the handling of administrative project matters between the owner, S&L and plant constructor (purchaser of 80P equipment).
e.
Review of the S&L Project (No. 4536-00) Monthly Progress I
Report.
f.
Review of the following documents related to the purchase of project equipment.
l Briefly the method of handling the procurement of safety-related Balance of Plant materials, equipment and services I
is as follows:
S&L prepares and obtains approvals, and distributes the procurement specification in accordance with the project's distribution list.
Project No. 4536-00 requires the approved specification to be transmitted to the Plant Constructor (purchaser) to obtain bids and place a purchase order with the acceptable vendor.
S&L is responsible to evaluate the bidder (s) submittals and transmit any coments to the purchaser.
(1) S&L Specification No. K-2315 that scecifies the applicable codes and standards related to the manu-facture of the Fuel Fool Cooling and Cleanup Heat 2281 175
_ Exchange, plant constructors (purchaser) internal memorandum dated May 18, 1976, placing the equip-ment supplier on the approved list and the owners letter to the purchaser authorizing the purchase of the equipment from the approved supplier.
(2)
S&L Specification No. K-2828A for Shutdown Service Water Pump (Large) that specified the technical and quality requirements, S&L-QC Coordinators -
bidders' program evaluation and recommended sup-plier report, purchasers letter to the owner stating resolution of the QC coments in the evaluation report.
(3) S&L Specification No. K-2841 for Shop Fabricated Tanks, ASME Section III, that identified the technical and quality requirements, S&L-QC's pro-gram evaluation and letter identifying the program deficiencies, purchasers letter stating satisfac-tory resolution of S&L QC comments.
(4) S&L Specification No. K-2978 for Electrical Pene-trations, that specifies the codes, standards and technical requirements for the fabrications, S&L-QC Coordinators evaluation of the suppliers QA Manual and S&L evaluation and recommendation of the preferred bidder.
(5) S&L Specification No. K-2957B for Reactor Pedestal Shield Wall Plate Work, which specifies the codes, standards, technical and quality program require-ments, also the S&L-QC Coordinators evaluation report relative to his review of the quality pro-gram of two (2) bidders for this specification.
(.6 ) S&L Specification No. K-2957A for Drywell Plate Work.
S&L management stated this equipment was origin-ally included in the specification that included the equipment noted in paragraph C.2.f.(5) and the specification was revised to cover this scope of work and the purchase order was placed with the present vendor and the requirements described in Specification No. K-2957A are applicable.
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3.
Findings a.
Deviation No deviations from comitments were identified in this area of the inspection.
b.
Unresolved Item The S&L project files do not contain evidence that the supplier of the Drywell Plate Work (Specification No. K-2957A) had an acceptable QA Program, which would resolve the program deficiencies identified by the S&L-Quality Control Coordin-ator during his program evaluation and fonvarded to the pur-chaser as comments on the Bid Evaluation Form. This evalu-ation was one of the reviews conducted and identified in paragraph C.2. f. (5).
Project management stated that the intent of the procedural requirements for Project No. 4536-00 is that the Plant Constructor (purchaser) is responsible to resolve the vendor quality assurance program deficiencies identified by S&L and reported as comments in the evaluation reports.
Project management further stated that the applicable pro-ject procedures will be reviewed and revised as necessary to clarify the intent as stated.
These revised procedures will be reviewed during a subse-quent NRC inspection.
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