ML19281A784
| ML19281A784 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/1979 |
| From: | Hale C, Jerrica Johnson, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19281A768 | List: |
| References | |
| REF-QA-99900505 NUDOCS 7904040291 | |
| Download: ML19281A784 (15) | |
Text
O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900505/79-01 Program No. 51200 Company:
Ebasco Services, Incorporated Two Rector Street New York, New York 10006 Inspection Conducted:
January 15-19, 1979 O
/
Md9 Inspectors:
L. E. @_1pp,' Senior Meyhatfical Engineer, Date IE:HQ O./h O 4,.~.w 4/ /71 J/M. John; son, Contractor Auditor, Date Iendor'inspectionBranch
\\{
Approved by:
b Dh79 C. J. Ha,le), Chief, Program Evaluation Date e
Section, Vendor Inspection Branch' Summary Inspection on January 15-19, 1979 (99900505/79-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B and/or Topical Report ETR-1001 including design inspection, audits, and action on six (6) previous inspection findings.
This inspection involved 61 inspector-hours on site by two (2) NRC inspectors.
Results:
In the three (3) areas inspected, there were no unresolved items identified. The following deviations were identified.
Deviations: Audits:
- 1. Failure to enter internal and management audit reports and associated records in QA Records system.
- 2. Failure to maintain retrievable management audit records for 1976, perform follow-up and closure for 1977, and maintain current status of outstanding deficien-cies in deficiency log per procedural requirements.
- 3. Failure to perform audit follow-up for external audits to assure written reply to nonconfor-mances and to assure corrective action is accomplished. Action on Previous Inspection Findings: Failure to implement committed corrective and prevent-ative actions relative to previously identified deviations.
5 0404 0291 DETAILS SECTION I (Prepared by L. E. Tripp)
A.
Persons Contacted
- T. A. Cotter, Quality Assurance Engineer E. Kashanian, System Engineer W. J. Krotiuk, Acting Supervisor, Applied Physics B. R. Mazo, Chief Quality Assurance Engineer C. Murphy, Supervisor, Project Files J. Phalen, Assistant Quality Assurance Engineer M. Pietrantoni, Lead System Engineer R. Salcedo, Equipment Engineer R. J. Simonetti, Project Coordinator
- S. Sparacino, Supervising QA Engineer
- R. T. Vickers, Project Engineer
- R. F. Williams, Supervising QA Engineer
- Denotes those present at exit meeting.
B.
Action on Previous Inscection Findings 1.
(0 pen) Deviation (Report 77-03): A significant number of Q designated project documents had not as y3t reached the dupli-cate controlled file.
In Ebasco's letter of response dated April 28, 1978, the estimated completion date for this effort was stated as August, 1978.
A review of this item indicated that approximately one half of the project files for one pro-ject are not in the duplicate files and are not scheduled for inclusion until late 1979.
2.
(0 pen) Deviation (Report No. 78-01): A backup file for inter-disciplinary review of drawings was not being maintained on a project.
In Ebasco's letters of response dated April 28, 1978, and May 23, 1978, a log-in, log-out, system for drawings was described along with a special study on drawings and revision of procedure E-71.
Ebasco management indicated that revision to E-71 and corrective action associated with the special study were to be completed by October 1, 1978.
Review by the inspector indicated that although a special study had been performed, agreement between project personnel and QA engineering on study results had not been reached and corrective action had not Deen scheduled.
Procedure E-71 (new Procedure E-7) was in the process of being revised but had not yet been issued.
3.
(0 pen) Deviation (Report No. 78-0)): A document review list for specifications issued on a project was rejected and then issued without resolution.
In Ebasco's letters of response dated April 28, 1978, and May 23, 1978, corrective action was described which indicated that the Interdisciplinary Review List on the project would be revised by June 1,1978, and re-issuance of specifications to those disciplines not previously incl:Med would be completed by November 1,1978.
Review of the revised review lists issued June 1,1978, and July 1,1978, showed that they did not totally reconcile QA comments.
Revi-sion 2 of this distribution list dated January 4,1979, and currently being circulated for final comment and concurrence provides for review by a wider range of disciplines.
Reissu-ance of specifications for review to those disciplines not previously included has not been completed.
4.
(Closed) Deviation (Report No. 78-01):
On two projects, docu-mentation of review of specifications by the same individuals or organizations who reviewed the original specification was not being maintained.
In Ebasco's letters of response dated April 28, 1978, and May 23, 1978, an evaluation was to be conducted which would determine the extent of review on speci-fications and provide corrective actions if discrcpancies were iound.
The evaluation and corrective action, if any, was to be completed by October 1, 1978. A review by the inspector estab-lished that the example cited for one project (Revision 2 of Specification 3240-54 for Containment Penetrations not being reviewed by Construction) involved only changes which did not affect Construction.
The Ebasco evaluation was performed for the other project covering a total of 220 specifications or revisions. The Ebasco review of specifications found them to be satisfactory with no corrective action required.
Inte rdis-ciplinary review of specifications by the other project is still the subject of another finding (See Item 3 above).
5.
(0 pen) Deviation (Report No. 78-02): Thirty-three (33) E-proce-dures, revised by their application in project unique procedures for the WPPSS project, had not been approved by the Manager of Standards and Procedures.
In the Ebasco letter of response dated August 10, 1978, it was stated thi.t the WPPSS Project unique proced' ires would be approved and issued to all project personnel by October 1, 1978.
Review of this area by the inspector indi-cated that further Ebasco review of these procedures had reduced the number of project unique procedures to only a few. These few procedures which are to be modified so as to make them pro-ject unique are in the process of final review and approval.
6.
(0 pen) Deviation (Report No. 78-02):
Several calculations by the Applied Physics Department for one project did not have calcula-tion cover sheets, calculation numbers, a department index for the project, or tables of content for binders containing calcu-lations.
In the Ebasco letter of response dated August 10, 1978, it was stated that the Applied Physics Department was currently engaged in a program of upgrading departmental calculation docu-ments to meet the applicable portions of E-61.
This program was to be completed by December 31, 1978.
The inspector's review of this area covering three projects showed that department indexes, calculation cover sheets and calculation numbers are being used and that documentation of calculations has been improved.
The three calculations cited in Inspection Report No. 78-02 were found to still be deficient.
These books (now numbered 3Al-005, 3Al-006 and 3Al-007) have no tables of contents. They.antain various reference material and pages of other calculations not covered by the calculation cover sheets.
For example, a page at the beginning of calculation 3Al-005 refers to the attached ref-erences for assumptions and inputs from various disciplines.
These references are contained in the loose leaf binders, but are not called out by date, number, etc. so that it is not pos-sible to establish the exact documents and sources of informa-tion used in the calculation.
7.
(0 pen) Deviation (Report No. 78-02):
Revisions to controlled copies of the Company Procedures Manual - administrative, certain E-proced;res, and the Purchasing Department Procedures Manual had not been distributed and/or the superseded documents destroyed or clearly marked as superseded or designated void.
The Ebasco corrective acticns and the status of this item were not reviewed in this inspection.
(See Notice of Deviation, enclosure, item D., relative to paragraphs B.l.,
B.2., B.3., B.S., and B.6. above.)
C.
Design Inspection - Auxiliary Feedwater System 1.
Objectives The objectives of this area of the inspection were to verify for the auxiliary feedwater system (AFS) that:
a.
Design criteria, requirements and commitments, as listed in the SAR, were utilized in the design input during system and component design.
b.
Interface locations between the AFS and other systems or components have design interface requirements to assure that they are compatible.
c.
Analyses used for determining flow requirements and making pump selection are consistent with system performance require-
- ments, d.
The AFS design meets diversity requirements and commitments.
e.
The AFS design analyses demonstrate that the AFS is capable of cooling the reactor coolant system down to temperatures and pressures at which the residual heat removal system can be operated.
2.
_ Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Design criteria and requirements to be utilized in system and individual component design were found to be listed in the following design related documents:
.WPPSS-PE-975, " List of Drawings Requiring Inter-disciplinary Review," January 27, 1978.
.G-1078, " Auxiliary Feedwater System Flow Diagram," Revision 3, December 12, 1978.
.SYS80-PE-IR15, "f1SSS Interface Requirements for Main Steam and Feedwater Systems for Standard System 80," Revision 4, October 20, 1977.
. Specification 3240-116, " Miscellaneous Centrifugal Pumps and Accessories," May 18, 1976.
. Letter from R. Ferrari to J. McCarthy, "WPPSS fluclear Project flo. 3, Applicable Criteria for Design Development of General Arrangement and Flow Diagram Drawings.
. Mechanical Nuclear Sketch for Auxiliary Feedwater System, January 23, 1974.
. Specification 3240-21, " Control Valves and Accessories,"
July 14,1978. The criteria and requirements specified and used in these documents were found to be consistent with SAR commitments.
b.
Compatibility of the AFS with other interfacing systems was inspected through examination of the above documents. This included interfaces with the main steam system (steam for the turbine driven pumps), the main feedwater system, the condensate storage system, and the Class IE power sources.
No discrepancies were noted.
c.
It was found that AFS flow requirements for the inspected project were set by the Nuclear Steam System Supplier rather than Ebasco.
It was verified through inspection of the pump specification and the AFS flow diagram that:
. Pump flows were consistent with the NSSS supplied require-ments.
. Pump and system design assure that the pumps do not trip (e.g., due to motor overload) or will not be damaged by run out such that there is a loss of system function 1.hrough the use of a minimum pressure retaining device at pump discharge.
. Allowance is made in the pump specification and AFS design for recirculation flow, pump water, and testing.
.Long term makeup requirements are supplied from the deminer-alized water storage tank through the condensate tran.'fer (make-up) pumps.
d.
AFS design diversity requirements were verified by inspec-tion of the AFS flow diagram plus the following:
. Preliminary Drawing D-6080, Sheets 377 A to C, " Instrument Schematic-Logic Diagrams - Motor and Steam Turbine Driven Auxiliary Feedwater Pumps."
. Preliminary Drawing D-6080, Sheets 379 A to C, " Instrument Schematic-Logic Diagram - Auxiliary Feedwater to Steam Generators No.1 and 2."
. Drawing G-1317, Sheets 1 to 6, " Auxiliary Feedwater Piping,"
Revision 1, June 20, 1978.
e.
It was found that design analyses of AFS cool down capa-bilities are performed by the Nuclear Steam System Supplier for the project inspected.
3.
Findings In this area of the inspection, no unresolved items or deviations were identified.
D.
Exit Meeting An exit meeting was conducted with management representatives at the conclusion of the inspection on January 19, 1979.
In addition to those individuals indicated by the asterisk in each Details Section of this report, the following were in attendance:
W. L. Sheehan, Project Manager B. Tenzer, Director, Materials Engineering and Quality Assurance The inspectors summarized the outstanding items and corrective actions that were reviewed during this inspection.
The in';ectors discussed the scope and findings identified during this inspection. Management representatives acknowledged the statements made by the inspectors with respect tc the three (3) deviations presented.
Subsequent to this exit meeting, and upon re-evaluation of the inspec-tion findings, Ebasco management was notified of an additional deviation (Item D in the Notice of Deviation Enclosure) by telecon on February 1, 1979, to Mr. S. Sparacino.
DETAILS Sr.CTION II (Prepared by J. M. Johnson)
A.
Persons Contacted
- T. A. Cotter, Quality Assurance Engineer (Internal Audits)
K. K. Khanna, Manager, Standards and Procedures Department.
R. B. Kosinski, Quality Assurance Audit Coordinator D. Krobetzky, Quality Assurance Engineering Specialist
- B. R. Mazo, Chief Quality Assurance Engineer
- S. Sparacino, Supervising Quality Assurance Engineer J. Tompeck, Project Quality Assurance Engineer
- R. F. Williams, Supervising Quality Assurance Engineer, Audits
- Denotes those present at exit meeting.
B.
Audits 1.
Objectives The objectives of this area of the inspection were to examine pertinent records associated with Ebasco internal, external and management audits to assure that topical commitments and proce-dural requirements are being implemented.
Records examined included auditor qualifications, audit schedules, audit plans and/or checklists, documentation of audits, distribution and retention of audit reports, records of proposed corrective action and verification of corrective action (where required).
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Ebasco Topical Report, ETR-1001: Section II-9 (QA Audits);
QA I-S (QA Evaluation of Suppliers / Contractors); QA I-6 (QA Records); QA I-2 (Organization and Responsibilities);
QA I-1, Table I-1.3 (Principal Implementing Procedures);
Appendix II (Ebasco Positions on USNRC Regulatory Guides).
Note that this topical is also Ebasco's Nuclear QA Manual.
b.
Louisiana Power and Light Preliminary Safety Analysis Report (PSAR) for Waterford Unit No. 3: Section 1.8 (QA Program).
c.
Ebasco Quality Program Quality Assurance Manual (Nuclear) for Louisiana Power and Light - Waterford Unit 3:
QC-7 (QA Audits - Internal and External).
_g.
d.
Implementing procedure A-45 (previously designated E-58)
(Ebasco Management QA Audit Committee Procedure).
e.
Implementing procedure QA-D.5 (Internal Audits); QA-D.5-1 (Audits of Vendors); QA-D.5-2 (Audits of Sites); QA-G.3 (Qualification of QA Audit Personnel); QA-P.9 (QA Vendor Evaluation); QA-G.4 (QA Engineering Records).
f.
Prior implementing procedures (applicable at the time certain work examined was perforred):
ME-QC-P.14 (QA Supplier / Contractor Audits).
9 Documents to verify implementation of topical commitments and procedural requirements in the area of Management Audits:
(1) Management Audit Report 1-78, including four (4) deficiency findings, response letters, evaluation letters, Reaudit #1, and Reaudit #2, closing this audit.
(2) Management Audit 1-77 including findings, response letters and evaluation letters.
(3) Log of Management Audit findings (available for 1978 only).
(4) Personnel qualifications for four management personnel who performed the above audits.
(5) Management audits in 1975 of OA Personnel Training and NDE (Non-destructive Examination).
h.
Documents to verify implementation of topical commitments and procedural requirements in the area of Internal Audits:
(1) Quarterly Internal Audit Reports of Ebasco QA Program (summaries of results of audits conducted during the quarter in given areas) for the Second Quarter of 1978, and their distribution.
(2)
Six (6) Month Audit Schedule for 1979 by Projects and Disciplines (on magnetic planning board).
(3) QA Engineering Audit Finding Log and status of findir.gs from audits listed below.
(4)
Engineering and Design Audit No. 0829 dated May 22, 1978, and associated records including notification, plan, items examined and one (1) finding, response, and internal memo dated January 10, 1978, from Supervising QA Engineer (Audits) to Internal Auditors deferring corrective action until the company direction has been determined by the Chief Engineers.
(5) Mechanical / Nuclear Engineering - Stress Analysis Audit No. 0930 dated November 30, 1978, and associated records including notification, audit plan, items examined, one (1) infraction and its closure dated September 5,1978.
(6) Mechanical / Nuclear Engineering - Piping and Valves Audit No. 0939 dated November 30, 1978, and associated records (no findings).
(7) Engineering and Design - Seismic Stress Analysis Audit No. 0681 dated January 10, 1978, associated records and record of implementation of satisfactory corrective action for four (4) findings on February 23, 1978.
(8) Mechanical / Nuclear Engineering - Piping and Valves Audit No. 0811 dated May 3,1978, associated records, and record of satisfactory implementation of correc-tive action for one (1) finding.
(9) Materials Engineering Audit (across projects) dated January 12-13, 1978.
The audit report consists only of the notation:
" Procedures not auditable; no docu-mented records that allow audit are retained by the department."
(10) QA Audit Report No. SA-2-VT-2 issued December 28, 1978, including 21 findings.
This was a comprehensive general project audit with emphasis on programmatic aspects of site activities of contractors as well as Ebasco's construction management functions.
(11) QA Audit Report No. SA-2-WAT-1 issued July 24, 1978, including 19 findings.
Corrective action audit issued December 28, 1978, closed 11 findings; 8 CARS were issued for items still open. This was a comprehensive project audit of the program and per-formance of the site piping contractor.
. (12) QA Auditor Qualification and Participation Records for four (4) internal auditors.
i.
Documents to verify imple. mentation of 10 CFR 50, Appendix B, PSAR, and procedural requirements in the area of External Audits:
(1) Ebasco Approved Vendor List (AVL) dated December 28, 1978.
This list, issued quarterly, shows the date of the pre-vious audit and the proposed date for the next periodic audit, which is generally on a three year cycle.
(2) Approved Vendor List applicable to one project (supplementary to the Ebasco AVL).
(3) Supplier Manufacturing / Service Facility QA Audit dated August 17, 1977, of a contractor providing site installation of nuclear piping and fabrication of 2" and under piping for one project, and follow-up of findings dated December 2,1977.
(4) Facility audits of Associated Piping (Temflex Division) dated November 30, 1972, March 11, 1975, and April 13, 1978, (P.O. 403422 for Containment Piping Penetrations-Mechanical).
Status on all audits was " Satisfactory."
(.5 ) Facility audits of Lunkenheimer (P. O. 403469 for Stainless Steel Valves 2h" and larger): August 23, 1973; November 24-25,1975 (Status was " Unsatisfactory."
Associated documents include the audit transmittal letter dated December 12, 1975, and vendor response dated January 20, 1976, with proposed corrective action.
There is no record, however, of reaudit or closure of findings by Ebasco); February 14, 1978, (Status was " Conditional Satisfactory." Associated records include the audit transmittal letter which requests a vendor response within 20 days. There are no records of vendor response or of further action by Ebasco).
For additional information, see para-graph 3.d below.
(6) Facility audits of ACF Industries-WDi (P.O. 403546 for Main Steam Isolation Valves and P.O. 403484 for Control Valves (Level Pressure and Flow)):
March 25, 1974, (Status is " Satisfactory"); July 26-27,1976, (Status is " Conditional Satisfactory." Associated documents include audit transmittal letter dated August 13, 1976, requesting response within 30 days, telecon dated March 28, 1977, of conversation with new QA Manager for WKM which requested corrective action response to above July 1976 audit findings, and which indicated that WKM could not find the audit and requested another copy sent. Another telecon dated November 15, 1977, documents a discussion wi'5 a member of the WKM QA department about the March %d, 1977, telecon and the failure by WKM to respond to the July, 1976 audit findings. WKM indicated that they would call back the r. ext day. There are no further records. WKM was removed from the Ebasco AVL on March 31,1977).
For additional information, see paragraph 3.d. below.
(7) QA Auditor Qualification and Participation Records for three (3) external auditors.
It was noted that qualification points were mis-added in several cases, but correct addition would have resulted in more than the required number of points in each case. Also, there is no record of yearly re-evaluation, but Ebasco is aware of this and a new form has been designed to correct the problem.
In no case examined had an auditor failed to perform enough audits to keep his qualifica-tion current, and hence no finding was issued in this area.
3.
Findings a.
In this area of the inspection, three (3) deviations were identi fied.
(See Notice of Deviation Enclosure, Items A.,
B., and C.).
No unresolved items were identified.
b.
Concerning Notice of Deviation Enclosure, Item A, please note the following:
(1) Audit records, including audit plans, audit reports, written replies, the record of completion of corrective actions, and associated documents, are identified as required QA records to be retained per ANSI N 45.2.9 requirements by ANSI N 45.4.12, paragraph 5.1 and 5.2.
Both of these ANSI Standards are committed to in Ebasco Topical ETR-1001, Appendix II, Ebasco Positions on USNRC Regulatory Guides.
Currently these records are retained in Ebasco departmental files, but are not entered into the QA record system which would provide protection from deterioration or loss. Quarterly
. Summaries, which do not include the above required detailed records, but do provide valuable summary information to management, are entered into the QA record system.
(2) Note also that procedure QA-G.4 (QA Engineering Records), Paragraph 6.1(c) requires Quarterly Summaries to be entered into the QA record system.
c.
Concerning Notice of Deviation Enclosure, Item B, the Management Audit Committee determination of the need to perform foli a-up and closure for the 1977 audit is docu-mented in two places:
(1) July 1,1977 memo from Consulting QA Engineer to Chief QA Engineer states in part:
"The following items are not closed and will require follow-up action by the Management Audit Committee:
- 1 (Audit 0222)
- 4 (Audit 0316)
- 6 (Audit 0226)
- 7 (Audit 0373)
"In addition to the above items, follow-up action will be required to verify actions taken by QA Engineering in response to the recommendations made."
(2) July 7,1977, memo from the Consulting QA Engineer to the Chief QA Engineer states; "A follow-up audit by the Management Audit Committee will be made at a later date to determine the effectiveness of your action."
d.
Concerning Notice of Deviation Enclosure, Item C, please note the following:
(1) Records indicate that both Lunkenheimer and WKM still have active work on these contracts in their manufac-turing facilities, although both are scheduled for completion soon.
Both contracts include components designed Safety Class 1 and 2 and Seismic I and II.
(2) Open audit findings include:
(a) Lunkenheimer audit - November 24-25, 1975:
". No independent authority (QA)
.. Welding procedures not being implemented.
It is essential that a reaudit of welding area be sched-uled if any welding of nuclear class valves is performed
. Control of nonconforming articles is inadequate" (b)
Lunkenheimer audit - February 14, 1978:
. Need to document QA design review
. Update AVL
.QA should sign P.O.s
. Segregate nonconforming materials
. Complete NCRs (nonconformance reports)
.Make calibration records traceable to NBS (National Bureau of Standards)
. Prepare storage and handling procedures
. Prepare weld control procedures" (c) WKM audit - July 26-27, 1976:
". No real QA on Non-Nuclear parts; QA program for
' Pressure retaining parts only'
. Welding controls not strictly enforced
. Procedures needed for receiving inspection, dimensional inspection, etc.
. Calibration records must indicate traceability to NBS
. Material certs must be signed off
. Weld rods lying around
. Weld rod storage cage has junk, debris, electrical parts, etc. in it
...Some weld material " Controlled;" some not. Vendor had trouble telling which was which
. Welder Qualification Records traceability weak
.No master list of welders
.No delta ferrite testing
. Designate a nuclear weld area, or control all areas" (3) Vendor surveillance has also been performed on these contracts, but appeared to consist primarily of observing witness and hold points.
There was no evidence of cross-communication of audit findings for closure.
(4) NRC concern includes whether the identified failures to perform audit follow-up and closure are isolated, or whether this is a generic problem, since in the records examined of external audits of four (4) vendors, follow-up problems were identified in two (2).
For additional information, see also Report DetailsSection II, paragraph B.2.i. (5) and (6).
.