ML19290E575
| ML19290E575 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/1980 |
| From: | Costello J, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19290E544 | List: |
| References | |
| REF-QA-99900510 99900510-79-4, NUDOCS 8003140227 | |
| Download: ML19290E575 (15) | |
Text
.
U.S. NUCLEAR REGUI.ATORY COTIISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900510/79-04 Program No. 51200 Company: United Engineers & Constructors, Inc.
30 South 17th Street Philadelphia, Pennsyl-mia 19101 Inspection Conducted:
December 10-14, 1979 Inspectors:
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J./. Costello, Principal Inspector Date Prhgram Evaluation Section Vendor Inspection Branch
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' Date Program Evtluation Section Vendor Inspection Branch f
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Approved by:
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C. J' Q e," Chief Date Program Evaluation Section Vendor Inspect. ion Branch Summary Inspection on December 10-14, 1979 (99900510/79-04)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria in the areas of training, followup on previous inspection findings and followup on regional requests.
The inspection involved sixty-two (62) hours oa site by two (2) USNRC inspectors.
Results:
In the three (3) areas inspected five (5) deviations were identified in one (1) area. There were ao deviations in the cther two (2) areas and no unresolved items in any of the areas.
Deviations: Training:
(1) Contrary to procedural requirements, no records of attendance or completion were maintained of mandatory indoctrination sessions I and II for four project engineering personnel.
(2) Contrary 8003140 2.1%
2 to procedural requirements, a controlled manual was not updated (although change package receipts had been returned), procedures were missing, and it was not returned when the holder left the project.
(3) Contrary to procedural requirements, one person certified and acting as Level III (to ASME III, Division II) had not been re-evaluated during the required two year interval and his certificate showed an expired date.
(4) Contrary to the project pro-cedure, QA 2-2, QA Manual - Corporate Standard II-3 does not meet ANSI N45.2.6 and Regulatory Guide 1.58 requirements in that it does not require an annual reexamination of near-vision acuity of certified personnel. (5) Contrary to procedural requirements, one person certified to ANSI N45.2.6 requirements was not re-evaluated for recertification during the required two year period.
3 DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted D. D. Boyle, Assistant Project Engineering Manager, Seabrook
- G. F. Cole, Project Manager, Seabrook A. J. Hulshizer, Supervising Structural Engineer R. C. Lesnefsky, Project Quality Assurance Engineer D. C. Marr, Supervising Engineer, Quality Planning Z. B. Olszewski, Supervising Engineer, Stress Analysis J. J. Parisano, Supervising Engineer, Piping R. F. Perry, Manager Mechanical Analysis
- D. J. Stride, Project Administrator
- S. Timmaraju, Manager Quality Engineering
- R. J. Vurpilla t, Assistant Department Manager Quality Services
- Denotes those present at the exit meeting.
B.
Followup on Previous Inspection Findings 1.
(0 pen) Deviation (Report No. 78-04):
Contrary to 10 CFR 50, Appendix B, Criterion XVII, and WKP-1 PSAR, some vendor drawings were not reviewed by the UE&C Reliability and Quality Assurance Department.
This method of not reviewing all drawings for inclu-sion of quality requirements appears to be inconsistent with NRC requirements and has been forwarded to NRR/QAB as an item for further consideration.
2.
(0 pen) Leviation (Report No. 79-02):
Contrary to Chapter 17.1.3 (Design Control) of the WPPSS-PSAR, a specification for the Borated Water Storage Tank (BWST) and the Demineralized Water Storage Tank contained seismic response spectra which had been superseded.
UE&C has issued a contract modification to the vendor (Welk Brothers) which requires them to submit revised calculations for the BWST and Demineralized Water Storage Tank that will meet the revised response spectra.
3.
(Closed) Deviation (Report No. 79-03):
Contrary to WPPSS Project Procedures 5 and 33, no record copy of the Specification Approval Form for revision 2 of Specification 9779-113 was filed with Docu-ment Control, and Material Requisition No. 228928 was not signed by Project Engineering Management.
A copy of the Specification Approval Form for Revision No. 2 is now on file.
In addition the Material Requisition No. 228928 for revision 2 of Contract 40 A
A has been signed by the Project Engineering Manager.
To prevent re-currence a memo dated 9/6/79 has been sent to each discipline re-minding them of the requirement of Project Procedure No. 5 that a record copy of the Specification Approval Form must be filed with the Document Control Center.
Also a memo has been written by the Project Administration dated 11/5/79 to contract Administration reminding them that the Project Engineering Manager's signature is required on a Material Requisition.
4.
(Closed) Deviation (Feport No. 79-03):
Contrary to UE&C Procedure QA-17, Vendor Nonconformance Reports for Seabrook Station are not retained as part of Vendor Manufacturing Records stored in the Site Construction Office Building.
List C of Appendix A to QA-17, in listing all "nor.conformance reports" as permanent documentation, was not precise and has been revised to read "nonconformances to Procurement Documents," which was the original intent.
This complies with the intent of Regulatory Guides 1.88 and 1.123 and the NRC Pro-duct Acceptance Criteria, and is being implemented on all procure-ments by the use of generic procurement QA document QAS-1.
To pre-vent recurrence QA-17 has been revised to clarify the vendor docu-mentation submittal requirements some of which go to the site and some to the home office.
C.
Followup on Two 10 CFR 50.55(e) Reports Covering Significant Design Errors in the Seabrook Station 1.
Objectives The objectives of this area of the inspection were to accomplish the following concerning a design error in the structural drawings for the control building and an error in the seismic de-sign of the containment supports.
a.
Has design corrective action been taken?
b.
Have items been corrected?
c.
Could other plants have the same problem?
d.
Has 10 CFR Part 21 evaluation been considered?
2.
Method of Accomplishment The preceding objectives were accomplished by discussions with cognizant UE&C personnel and an examination of the following documents:
5 Letter from G. F. Cole, UE&C Project Manager Seabrech to a.
John De Vincentis, Project Manager Yankee Atomic Electric Company dated November 6,1979,
Subject:
Discrepancy in the Seismic ?-
in the Containment Annular Area.
This letter reports a v,;;n discrepancy.
b.
Letter form G. F. Cole, UE&C Project Manager Seabrook to John De Vincentis, Project Manager Yankee Atomic Electric Company dated November 6, 1979,
Subject:
Discrepancy in the Reinforcing Bar for the Control Building.
This letter reports a design discrepancy.
Memorandum from John De Vincentis to Distribution dated November c.
7, 1979,
Subject:
Reporting 10 CFR 50.55(e) Design Deficiencies.
In this memo it stated that on Tuesday November 6, 1979, De Vincentis called Joseph Mattia, NRC Region I Inspector for Seabrook Station to report two significant design defi-ciencies under 10 CFR 50.55(e).
d.
Letter from John De Vincentis, Project Manager Yankee Atomic Electric Company to G. F. Cole, UE&C Project Manager Seabrook dated November 9,1979,
Subject:
Reporting 10 CFR 50.55(e)
Design Deficiencies.
This letter stated that the two design deficiencies received from UE&C via 5BU - 31426 (letter dated 11/6/79) and 5BU - 31428 (letter dated 11/6/79) had been re-ported to the NRC under 10 CFR 50.55(e).
Appendix to SD-66, General Procedures for Re-evaluation of e.
Containment Annulus Structural Steel Framing dated November 29, 1979.
f.
Letter from G. F. Cole, UE&C Project Manager Seabrook to John De Vicentis, Project Manager Yankee Atomic Electric Company dated December 5, 1979,
Subject:
Discrepancy in the Seismic Design in the Containment Annular Area.
This letter transmits an interim report on the design discrepancy.
g.
Letter from G. F. Cole, UE&C Project Manager Seabrook to John De Vincentis, Project Manager Yankee Atomic Electric Company dated December 5, 1979,
Subject:
Discrepancy in the Reinforcing Bar for the Control Building.
This letter trans-mits the final report on the subject discrepancy.
h.
UE&C Corporate Procedure entitled " Reporting of Defects and Noncompliances to the Nuclear Regulatory Commission."
6 i.
UE&C General Engineering & Design Procedure GEDP-0012, revision 1 dated 2/20/75 entitled " Development and Use of Amplified Response Spectra For Seismic Design of Structures and Systems."
j.
Work Order WR 272, Issue 5, dated 11/15/78 - provide loads for class 1 piping and remainder of analysis for class 2 piping inside containment.
k.
Drawing 9763-F-800273 - Isometric Piping Safety Injection System Line No. 273.
Also drawings 800272 and 800274 cover-ing lines 272 and 274.
1.
Final Report entitled, " Seismic Analysis of Containment Structure" dated March 19, 1976.
3.
Findings Design Error in Structural Drawings for the Control Building a.
1.
As a result of a site inquiry regarding the rearrange-ment of reinforcing bars in one of the walls of the Control and Diesel Generator Building a review of the design calculations was made.
At this time it was die-covered four (4) drawings had been issued that did not contain all the reinforcing bars required by the calcu-lations.
2.
At the time the error in the drawings were discovered no concrete had been placed that would be affected by lack of reinforcing bars in these drawings.
3.
Immediate steps were taken to notify construction forces of the need to modify the reinforcement and appropriate Engineering Change Authorizations were issued directly to the field to install the required additional reinforce-ment.
4.
Investigation of the cause of this error disclosed that calculations for the Cont; ol and Diesel Generator Building were performed in two phases.
The first phase did not con-tain the reinforcement which was ultimately left off the drawings.
5.
When the drawings were prepared the checker did not in-struct the draftsman to correct the drawings to the latest revised calculations as he felt the original calculation provided adequate conservatism.
7 6.
The checker signed the drawings as being in a;reement with revision 1 instead of revision 0 of the calculations.
The action taken by the checker was in violation of UE&C'e procedures as he did not have proper authorization to disregard the calculations and further he certified wrong info rmation.
7.
UE&C has conducted a special QA training session for the entire Seabrook Structural Engineering-Design group to review the procedural errors involved, to assure proper compliance with pertinent project procedures and to in-still the seriousness of certifying to only correct information.
8.
A comparison of all Seabrook concrete design drawings and calculations was conducted to assure no design defi-ciencies existed with respect to calculated requirements for any of the other structures.
This comparison has not revealed any findings that would indicate a deorgn deficiency in any of the other structures.
9.
This design error in the structural drawings for the control building appears to be an isolated case caused by a failure to follow procedures.
10.
As soon as this design problem was known the UE&C Pro-ject Manager for Seabrook notified the Project Manager at Yankee Atomic Electric Company who in turn reported the incident to the USNRC.
If no action had been taken by Yankee Atomic Electric Company then UE&C would have considered reporting the incident under 10 CFR Part 21.
b.
Error in the Seismic Design of the Containment Supports 1.
In September 1979 a UE&C employee was assigned the task of performing a seismic response analysis of Safety Class 2 and 3 piping in the containment building.
He discovered a document entitled " Seismic Analysis of the Annular Steel" dated 10/7/77.
Utilizing this document he determined that portions of the annular structural steel had considerably higher "g" values than those used to input to previous analyses of Safety Class 2 and 3 piping supported by the same annular steel.
2.
Further investigation revealed that the seismic analyses of Safety Class 2 and 3 lines in the same area performed at that time used as input Amplified Response Spectra (ARS) extracted from a document entitled, " Seismic Analysis
8 of Containment Structure," dated 3/19/76.
Note that this date was approximately one and one half years earlier.
3.
The March 19, 1976 document presented the ARS for the reinforced concrete containment outer shell and the interior concrete structure including the secondary shield walls.
The ARS values contained in this document are lower than in the October 7, 1977 document because by their nature concrete structures in general
-e stiffer than structural steel structures.
4.
Therefore, a design deficiency existed because the piping systems were analyzed using incorrect low values of ARS with the possibility that one or more piping systems in question would be overstressed under maximum seismic and operating loadings.
5.
The planned design corrective action is to redesign the containment annular steel frame by providing additional bracing.
The design of all components located in this area will then be :hecked against the redesigned containment annular steel frame and its resulting amplified response spectra.
6.
The containment steel annular frame has not yet been re-leased for fabrication and will be held until additional bracing is designed.
7.
" Hold" has been placed on the design and analysis of piping systems located in the containment annulus.
8.
UE&C is currently reviewing the seismic design require-ments of all other components supported by the contain-meat annular steel frame.
9.
UE&C had just completed a short term audit of selected seismic Category I systems and components to assure use of correct amplified response spectra in their seismic design.
The audit report was not published at the time of this in-spection, but discussions with the Project Manager indicate that this problem may exist in some other systems.
10.
The inspector reviewed General Engineering & Design Pro-cedure GEDP-002 (Development and Use of Amplified Response Spectra for Seismic Design of Structures and Systems) and finds that it needs to be more specific.
In tracking why Seismic Analysis of the Annular Steel was not used as
9 an input to the piping system design, there was no specific guidance and no indication that this was going to follow the Seismic Analysis of Containment Structure.
Also the time between preparation of a document and review appears excessive, i.e. I to 1\\ years.
11.
This error in the seismic design of the containment sup-ports has not been closed out and will be further in-spected during the next regular inspection. This follow-up inspection will consider the seismic design requirements of Seabrook as well as other UE&C designed nuclear plants.
12.
This design error would have been considered as a 10 CFR Part 21 had not the Project Manager at Yankee Atomic Electric Company notified the USNRC.
D.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on December 14, 1979.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance were:
R. J. Curnane, Vice President Project Support Operations E. C. House, Assistant Engineering Manager G. E. Sarsten, Manager Power Engineering J. B. Silverwood, Manager Reliability and Quality Assurance G. L. Visco, Supervisor Project Control System The inspector summarized the scope and findings of this inspection for those present at the meeting.
Management representatives acknowledged the statements of the inspector.
10 DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Persons Contacted J. M. Feil, NDE Level III Test Examiner and Welding Engineer J. L. Fisher, Quality Assurance Engineer G. S. Korin, Manager, Field Quality Assurance R. C. Lesnefsky, Project Quality Assurance Engineer
- R. H. Leonard, Assistant Department Manager R&QA (Quality Engineering)
D. C. Marr, Supervising Engineer, Quality Planning R. H. Marsh, Manager, Services
- D.
J. Stride, Project Administrator
- R. J. Vurpillat, Assistant Department Manager, R&QA (Quality Services)
A. Zarevics, Administrator
- Denotes those present at exit meeting.
B.
Training 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented that provide for:
Formal indoctrination and training or retraining programs a.
for new employees and reassigned employees.
b.
Training of inspection, examination and testing personnel that provide for:
(1)
Indoctrination with the techincal objectives of the project, the codes and standards to be used, and the quality assurance elements that are to be employed.
(2) On the job participation through actual performance of processes, tests, examinations and inspections.
(3) Testing the capability and proficiency of personnel who perform nondestructive examinations.
(4) Retraining and recertification if evaluation of per-formance shows individual capabilities are not in ac-cordance with specified qualifications.
11 (5) Records of training received by each person including applicable certification of qualification and results of tests.
Training of audit persoanel, including technical specialists, c.
that provide for:
(1) Orientation with applicable standards and procedures.
(?'
General training in audit performance including funda-mentals, objectives, characteristics, organization, per-formance and results.
(3) Specialized training in methods of examining, questioning, evaluating, documenting specific audit items, and methods of closing out audit findings.
(4) On the job training, guidance, and counseling under direct supervision of an experienced, qualified auditor to include planning and performing audits; reporting and followup action; and review and study of codes, standards, procedures, instructions, and other documents related to QA and QA program auditing.
d.
Training programs for other personnel performing quality re-lated activities that include:
(1) A description of quality assurance material to be pre-sented and method of presentation.
(2)
Schedules for conducting the training sessions.
(3)
Identification of individuals by job description or titles or groups required to attend sessions.
Documentation of attendance and retention of other applicable e.
records for all formalized training accomplished.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
UE&C Topical Report No. UEC-TR-011-5A Section 17.1.2.5 (Program a.
Training) and Appendix II, Figure V (Applicable Standards and Regulatory Guides), to determine company program commitments (as applicable).
12 b.
UE&C Quality Assurance Manual - Corporate Standards, Standard Nos. II-2 (Indoctrination and Training), II-3 (Qualification and Certification of Inspection, Testing and Surveillance Personnel), II-4 (Qualification and Certification of Concrete Inspection and Testing Personnel), and XVIII-2 (Selection, Qualification and Certification of Auditing Personnel).
These standards were examined to determine the procedural requirements for company-oriented functions, and to determine the basic requirements which project procedures incorporate or adapt to meet project unique requirements.
c.
UE&C Nuclear Quality Assurance Manual (ASME Code Section III, Division 2), Section 5, Proc edure 5-B to determine procedural requirements for training, testing, certifying and reevaluating Levels I, II, and III concre:e inspection personnel.
d.
UE&C yA Manual for WPPSS Projects 1 and 4, Procedure QA-2-1 (Indoctrination and Training) for project program and pro-cedural requirements.
UE&C Manual of Procedures for WPPSS Projects 1 and 4, Project e.
Procedure No. PP-9, concerning document and manual control.
This was examined to determine project procedural requirements.
f.
UE&C Project QA Procedures for Seabrook Station, Procedure No. QA2-2 (Indoctrination, Training, Qualification, and Certification) to determine project procedural requirements.
g.
Reliability and QA (R&QA) Training records examined:
(1) Completion of Indoctrination and Training Sessions I and II by twelve (12) selected QA Personnel, plus six (6) quality-affecting persons assigned to the WPPSS project (primarily site personnel).
(2) Schedule of R&QA Training Sessions for 1979.
(3) Review of information concerning R&QA Training Session held October 19, 1979.
The subject was vendor _ surveil-lance and an attendance list was available.
h.
Qualification and certification records for Nondestructive examination (NDE) personnel and personnel qualified to N45.2.6:
(1) Ultrasonic testing (UT) certifications and recertifications (as applicable) for three (3) Level II personnel.
13 (2)
UT tests for two (2) Level II persons.
(3) Qualification and cettification to Radiographic Testing (RT), Ultrasonic Testing (UT), Liquid Penetrant Testing (PT), Leak Testing (LT), Eddy Current Testing (ET),
Magnetic Particle Testing (MT) and Visual Testing (UT),
and ANSI N45.2.6 for one (1) Level III person.
(4) NDE test for above Level III person.
(5) Qualification and certification files for three (3) per-sons with LP, MP, RT, VT and N45.2.6 certifications.
i.
Records of qualification and certification of six (6) Lead Auditors and evaluation of maintenance of gaalification, as applicable.
j.
Records of qualification and certification of one (1) Level III, ASME Section III, Division 2, person.
k.
UE&C training records for project personnel (Philadelphia based) for WPPSS Projects 1 and 4.
These were examined for completion of QA Indoctrination and Training Sessions I and II by Engineers, design supervisors and other supervisory personnel.
1.
UE&C project training records for project personnel (Philadelphia based) for WPPSS Projects 1 and 4 included training or specific procedures, changes and designated areas as follows:
(1) Three (3) project training session records for 1977 examined.
(2) Two (2) project training session records for 1978 examined.
(3) One (1) project training session record for 1979 examined.
m.
Three (3) UE&C manuals of Procedure for WPPSS 1 and 4 were reviewed for control, completeness, and currency (after one manual being used during the inspection was found deficient).
3.
Findings In this area of the inspection, five (5) deviations were a.
identified (See Notice of Deviation, Items A, B, C, D, and E).
No unresolved items were identified.
14 b.
Concerning the deviation identified as item A in the enclosure, the following actions were taken by UE&C before the conclusion of the inspection and no further written response to this de-viation is necessary:
(1) UE&C engineering personnel on WPPSS project identified as not having documented completion of Indoctrination and Training Sessions 1 and 2 did so, and project records were corrected to reflect completion.
No additional per-sonnel were identified as deficient.
(2) Memo No. AA90831 from D.C. Stride dated December 12, 1979 provided preventive action by requiring a periodic review of training records (minimum time:
every three (3) months) and a reminder to Supervising Discipline Engineers to co-ordinate with Project Administration to assure trainind of new personnel, Concerning the deviation identified as item B in the enclosure, c.
the following actions were taken by UE&C before the conclusion of the inspection and no further written response to this de-viation is necessary:
(1) Manuals Nos. 24 and 57 were updated and missing procedures inserted.
(2) Manual No. 24 was returned to the originator and reassigned to the new PQAE.
Note that this provides preventive action also, since the change packages will now be sent to the proper person.
d.
Concerning the de iation identified as item C in the enclosure, the following actions were taken by UE&C before the conclusion of the inspection and no further written response to this de-viation is necessary:
(1) Reevaluation of the Level III person was accomplished and documented on Form 4514, and a new form 7010 was issued certifying this individual.
(2) A memo from R. J. Vurpillat to R. H. Marsh dated December 14, 1979 was issued to perform an audit (as soon as schedule permits) of the computer printout against a sampling of hard copy certification records, and to perform subsequent yearly audits.
This provides preventive action, since the computer printout is used to determine need and dates for recertifications and appeared to be the source of the errors identified.
15 e.
Concerning the deviation idantified as item D in the enclosure, please note the following.
Company practice has included annual re-examination of near-vision acuity for certified personnel (as was verified by the inspector), despite the fact that QA Manual - Corporate Standard II-3 fails to delineate this re-quirement.
f.
Concerning the deviation identified as item E in the enclosure, the following actions were taken by UE&C before the conclusion of the inspection and no further written response to this devi-ation is necessary:
(1) This person was reevaluated and recercified.
(2) The same memo discussed above in B.3.d(2) provides preventive action, since an omission on the computer printout appeared to cause this deviation also.
I