ML19345B915
| ML19345B915 | |
| Person / Time | |
|---|---|
| Issue date: | 09/19/1980 |
| From: | Breaux D, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345B907 | List: |
| References | |
| REF-QA-99900510 NUDOCS 8012020733 | |
| Download: ML19345B915 (14) | |
Text
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' U. 7S.' NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.. 99900510/80-02 Company: United Engineers & Constructors, Inc.
30 South 17th' Street Philadelphia, Pennsylvania 19101 Inspection Conducted: August 25-29,-1980 Inspectors:
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J. R.(Coftello, Principj(14 Inspector Date Program Evaluation'Section Vendor Inspection Brznch
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D. B @n valuation Sdetionpaux,InternJnfpector Date-Progra-Vendor-Inspection Branch
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Approved:
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kb C. J. H(le). Chidf Date Program Tvaluation Section Vendor Inspection Branch Summary Inspection on August 25-29, 1980 (99900510/80-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria in the areas of design document control, follow up on previous inspection findings, and follow up on regional requests..The-inspection involved fifty-eight (58) hours on site by two (2) USNRC inspectors.
Results:
In the three-(3) areas inspected, one (1) deviation was identified in one (1) area.
There were no deviations in the other areas and no unresolved items identified in any of.the areas inspected.
Deviations:
Design Document Control:
Contrary to procedural requirements, Engineering Purchasing Schedule ~ dated' July 25, 1980, did not reflect current.
. revision status of specifications. -(See Notice of Deviation).
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DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted D. D. Boyle, Assistant Project Engineering Manager H. E. Flora, Supervising Nuclear Engineer H. C. Grau, Assistant Project Engineering Manager J..E. Hill, Instrumentation Control Engineer
- H. G. Kreider, Manager Power Engineering
- D. H. Rhoads, Project Engineering Manager A. P. Ricci, Design Supervisor G. Rigamonti, Chief, Power Engineering W. S. Stevens, Senior Attorney, Corporate Legal Department G. Valentenyi, Supervising Structural Engineer
- Indicates those present at the exit meeting.
B.
Follow Up on Previous Inspection Findings 1.
(Closed) Deviation F (Report No. 78-04):
Contrary to WNP-1 PSAR, some vendor drawings were not reviewed by the UE&C Reliability and Quality Assurance Department.
A deviation request to WPPSS was processed and approved to amend the PSAR to allow forwarding vendor drawings to R&QA on a selective basis at the discretion of the responsible engineer.
UE&C has taken the necessary action to clarify the wording in the FSAR to. include this selective review policy which is detailed in the Project Manual of Procedure.
This matter was identified to NRC/NRR on January 23, 1979, for their consideration during the FSAR review of the project.
2.
(Closed) Deviation D (Report No. 79-04):
Contrary to the project proce4tre QA 2-2, QA Manual - Corporate Standar? II-3 does not meet ANSI N45.2.6 and. Regulatory Guide 1.58 requirements of near-vision acuity of certified personnel.
The inspector reviewed the corrective and preventive actions described in UE&C's letter of response dated February 8, 1980.
Corporate Standard II-3 has been revised to require an annual eye test for correct color vision and near-vision acuity.
All other certification sections in corporate procedures.were checked-and found satisfactory.
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'3.
(Closed) Deviation A (Report No. 80-01):
Procedures for implementa-tion of the-reporting requirements of 10 CFR 50.55(e) did not exist.
Corrective action was completed prior to completion of the 80-01 inspection whereby UE&C' generated a new procedure-GEDP-0046.
Pre-ventive action was completed on June 30, 1980, with a. management training session covering the reporting requirements required by 10 CFR 50.55(e).
3 4.
(Open) Deviation-B'(Report No. 80-01):
Contrary to procedures, issued drawings were not properly identified as safety-related (B.1), were not certified (B.2), or were not marked void or destroyed when superseded (B.3).
Corrective and preventive actions-were completed by properly identifying drawings as safety-related and marking or destroying superseded drawings.
This is described in Report 80-01, Sections II.B.3.a.1 and-II.B.3.a.3 and UE&C letter of response dated July 2, 1980. ;In a revised response dated August 20, 1980, UE&C stated it wants its drawings certified per the requirements of GEDP-0013. The backfit of certifying the uracings is scheduled to be complete-by
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December 31, 1980.
Copies will be reissued only when the drawing
-is revised.
Verification of these actions will be made during a future inspection.
5.
(Closed) Deviation C (Report No. 80-01):
Contrary to proce,dures, specifications were not issued with purchase orders, were not project level design reviewed, were not submitted to the checker for internal review and revision,. or were not noted "For Construction."
Corrective actions were completed prior to the completion of the 80-01 inspection and are described in report 80-01.
Preventive actions were completed by June 27,-1980, and were accomplished by means of revising company procedures and a training session..These are described in UE&C lettet of response dated July 2, 1980.
6.
(Closed) Deviation.D (Report No. 80-01):
Contrary to procedural requirements, outdated drawings were not physically separated from current drawings in a stick file (D.1) and systems descriptions'did not reference codes and standards (D.2).
Corrective and preventive actions were taken prior to completion of the 80-01 inspection for deviation D.I.
These actions are described in Report 80-01.
Correc-tive and preventive actions for deviation D.2 are described in UE&C letter of response dated July 2, 1980, and consisted of a revision to procedure QA-3.
These actions were completed August 15, 1980.
7.
(Open) Deviation E (Report No. 80-01):
Contrary to PSAR commitment, IEEE Standard 382 was not invoked in a procurement document.
UE&C states that PSAR Table 7.1-1 is in error in specifying IEEE-382 and-plans to revise.this table as part of the FSAR effort.
Completion-of this effort is scheduled-for Septenber 15, 1980.
Note:
See DetailsSection II for other additional follow up on pre-vious inspection findings.
4 C.
10 CFR 21 Report Follow Up Concerning the Use of Incorrect Response Data in the Design of Two Safety-Related Tanks for the WPPSS Project 1.
Objectives The objectives of this area of inspection were to accomplish the following concerning an error in the seismic design of two safety-related tanks:
a.
Determination of how :he item was identified.
b.
Generic applicability of the item to other systems, components, or to other vendors, suppliers or domestic plants.
Verification that the cause of the safety concern was properly c.
identified.
d.
Detern.ination of the status of corrective action and preventive action to assure that this item has been satisfactorily resolved.
e.
Detennination of notification of affected utilities or customers.
f.
Determination of the accuracy and timeliness of reporting to the NRC.
2.
Method of Accomplishment The preceding objectives were accomplished by discussions with cognizant UE&C personnel and an examinatica of the following documents:
Telex from G. E. Sarsten, Vice President, Power Division UE&C a.
to Director, Office of Inspection and Enforcement dated May 9, 1980.
This telex concerned two situations which might be report-able under 10 CFR 21.
b.
Letter from G. E. Sarsten, Vice President, Power Division UE&C to Director, Office of Inspection and Enforcement dated May 13, 1980.
Subject:
10 CFR 21 Report of Situation related to Washington Public Power Supply System - The situation involved the use of an earlier revision of amplified response spectra in the design of two safety-related tanks.
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- Letter from'G. E..Sa'rsten, Vice President, Power Division UE&C to-Director,.0ffice of Inspection and inforcement dated May 13, 1980.
Subject:
10 CFR 21, Report of Situation. Related to Public Service' Company of New Hampshire - Seabrook Project.
This-situation involved ~a discrepancy in the-seismic design in the containment annular area.
d.
Letter from G. E. Sarsten,.Vice President, Power Division UE&C to Director, Office of Inspection and Enforcement dated-August 8, i
1980.
Subject:
10 CFR.21 Report of Defect Related_to Washington Public Power Supply' System Units WNP-1.and WNP-4._ Defect con-cerned a discrepancy in the response spectra which had been released for design and manufacture of HVAC equipment.
UE&C' Corporate Procedure entitled, " Reporting of Defects and e.
Noncompliances to the Nuclear Regulatory Commission." Revised June 1980.
f.
. UE&C General. Engineering and Design Procedure GEDP-0046 entitled,.
" Response to Potential Significant Deficiencies as Defined.In 10 CFR 50.55(e), Revision 0, May 9,1980.
g.
Seabrook Administrative Procedure No. 36 entitled, " Control of Seismic Design," Revision 1, May 20, 1980.
' h.
GEDP-0012, Development and Use'of Amplified Response Spectra
- For Seismic Design of Structures and Systems, Revision 1, dated February 20, 1975.
i.
GEDP-0013, Preparation of Drawings, Revision 2, March 28,1977.
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- GEDP-0014, Preparation of Design Specifications for Nuclear Power Plant Components (ASME B&PV,Section III, Division 1),
Revision 3, May 9, 1980.
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GEDP-0015, Preparation of Specifications, Revision 3, May 9, 1980.
1.
- Letter-from G. Valentenyi to G. Mani, Engineering Power-Division, dated March 18, 1980.
Subject:
WPSSS Nuclear Projects Nos. 1
- & 4, Change Order FB (Specification 9779-22, Revision 11, December 5, 1979). This letter contained twenty-four (24) recommendations concerning ARS ranging from clarification of ARS, to correct ARS, to requesting new ARS-be generated.
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Specification 11779-22, Fans and Air Handling Units WPSS Quality Classes I&G.
Internal' Audit Report NH-14 conducted November 15 - December 13,
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1979.
This audit covered engineering compliance with GEDP-0012 for the Development and Use of Amplified Response Spectra. The report lists eleven (11) findings.
4 Internal Audit Report NH-350 conducted February 4 - March 25,1980.
o.
Same subject as above.
This audit used two hundred sixty-one (261) checklists covering various line numbers and systems.
There were one hundred sixty-six (166) findings.
p.
Internal Audit Report NH-351 conducted January 31 - February 25',
1980.
Same subject as above.
This audit used 116 checklists.
There were 75 findings.
3.
Findings-The use of incorrect amplified response spectra on two safety a.
related tanks was discovered during the 79-02 USNRC inspection conducted on May 21-25, 1979. This error could potentially have resulted in a loss of safety function of the tanks.
This error was not reported at the time as either a.10 CFR 50.55(e) or a 10.CFR 21 item. The reason for not reporting according to cognizant UE&C personnel was that they assumed publication in the 79-02 report was adequate notification to the NRC. As a result of the USNRC 80-01 inspection where concern was expressed about not reporting this error as either a deficiency or potential defect, UE&C issued a 10 CFR 21 report on May 13, 1980.
b.
When the 10 CFR 21 report was issued on the use of incorrect-amplified response spectra on May 13, 1980, all of the correc-tive and preventive actions-had been completed, so the report became: a record of an accomplished fact requiring no further action.
The analysis showed this error did not have a generic
' application, as the potential defect concerned the unique appli-cation of seismic response spectra to a unique set of components.
Evaluation of the potential defect showed that when the proper-seismic response spectra were incorporated no changes were required to the tank design, fabrication or erection, therefore no defect existed.
Preventive action was taken regarding report-ing by. reissuing the 10 CFR 21 procedure and issueing a new pro-cedure on 10 CFR 50.55(e) reporting.
As the result of UE&C audi,s of amplified response spectra (ARS) c.
for equipment and structura.. design conducted on the WPPSS pro-
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. ject another case _of' wrong use of ARS was discovered on 5VAC equipment which was reported as a 10 CFR 21.on August 8, 1980.
This 10'C]lt 21 report has committed to generic corrective action on all'~ARS values used on WPSS equipment.
d.
-In' reviewing the. action taken on amplified response spectra for both the WPPSS and Seabrook projects it appears that'UE&C's
. treatment _of the errors as' individual cases did not get to the-root'of the matter. - The real problem was discovered from the follow up audits on amplified response spectra which showed a more generic problem. -Actions are.under way on both the WPPSS.
and Seabrook projects for follow up evaluation and verification-i of all ARS; values.
In regard to the accuracy and timeliness of reporting to-the e.
NRC there are some questions about past practices.
Th" assump-l tion by UE&C that publication of the deviation in regard to the use.of incorrect amplified response in the USNRC 79-02 report was' adequate notification was-suspect.
During the USNRC 80-01 post inspection ~ conference this matter was discussed with UE&C management which included two responsible officers.
At
.this point in time more information was available on UE&C errors in application of amplified response spectra at WPPSS and at Sea- -
treok as a result of followup audits.
One of the errors had been re"trted.under 10 CFR 50.55(e) and one had been reported in.the 79 02 report.
Follow up audits on amplified response' spectra indicated more problems might exist. With this information in.
hand, UE&C decided it was best to. report' both of these under 10 CFR 21 because two responsible officers were now aware of the potential defects.
f.
The three UE&C audits conducted to date on amplified response data-for the Seabrook Project-(see Method of Accomplishment items n, o, p) disclosed a total of two hundred fifty-two (252) findings.
The inspect'or will followup on these findings in a. future inspec-tion.
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There,were no deviations or unresolved items identified at this
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- time, t
D.
Exit. Meeting A' meeting was conducted with management representatives at the conclusion of.the inspection on August-29, 1980.
In addition to the individuals indicated by an arterisk in the Details Sections, those in attendance were:
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R.'J.LCurnane',-Vice President,' Project Support Operations
. R. H. Leonard, Assistant-Manager Reliability and Quality Assurance J. B. Silverwood,-Manager Reliability and Quality Assurance
- 13. Timmaraju,- Manager-Quality Engineering The inspector summarized the scope and findings of this inspection for those.present at the meeting.
Management representatives acknowledged the statements of the inspector.
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9 DETAILS SECTION II (Prepared by D. G. Breaux)
A.
Persons Contacted E. J. Baraniak, Piping Engineer,.WPPSS Project C. J. Chambers, Administrator, Document Control Center M. L. Hill, Administrator, Document Control Center J. J. Hobinstein, Support Planning
- R. C. Lesnefsky, Project QA Engineet, WPPSS Project B. C. Low, Quality Engineer, Seabrook Project R. A. Mabry, Supervising Mechanical Engineer, Seabrook Project R. W. Peters, Nuclear Engineer, WPPSS Project
- Indicates those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Follow up Item (Paragraph III. B.3.c.1 of Report 80-01):
During a previous inspection it was noted that an isoloated drawing listed in the Drawing Tracking System (DTS) for the WPPSS project reflected an incorrect status on the current revision of the draw-ing.
To assure that the status had been corrected, DTS report dated July 30, 1980, was reviewed.
Drawing 9779-S-503001 titled " General Arrangement, Control Room Complex" was found to have the proper revision status listed in the current DTS printout, thus correcting the item in question.
2.
(Closed) Follow up Item (Paragraph III. B.3.c.2 of Report 80-01):
The objectives of this follow up were to assure that specification (9763-006-248-65) for Seabrook Main Steam Isolation Valves (MSIV's) properly reflects the FSAR commitments.
To assure that the FSAR reflections were consistent, the current reviewed, accepted, and incorporated specification (9763-006-248-65) was reviewed.
The area of question; Section 1.3 titled " Service Conditions," was reviewed and evidenced that the integr9ted gamma radiation design life condition was changed to 1.3 x 10 rads to reflect the FSAR conditions.
With respect to the inclusion of Specification 9763-006-248-13 pertaining to actuators for valves of the Seabrook Project which includes IEEE 382 titled " Type-Test of Class 1 Electric Valve Operators for Nuclear Powet Generating Stations, the imposition of these standards are not required since the MSIV's are not limitorque motor operated valves, as defined in the actuator specification 9763-006-248-13. The isolation valves are actuated by a nitrogen pressurizied hydraulic accumulator system.
The proper information was reviewed with satisfaction; thus closing this follow-up item.
10 3.
(0 pen) Follow up Item.(Paragraph III. B.3.c.3 of Report 80-01): The objectives of this follow up were to assure that the vendor for Purchase Order No. 9763-006-248-65 for the Main Steam Isolation Valvec (MSIV's) for the Seabrook Project submitted a QA plan to supplement their own QA manual which was to meet the intent of 10 CFR 50, Appendix B and ANSI N45.2.
United Engineers and Constructors Quality Assurance approved Rockwell (valve vendor) Quality Assurance Program manual on August 21, 1980.
UE&C plans a subsequent audit of Rockwell's supplementary QA plan which will detail specific Seabrook Project Speci.fic QA requirements.
Rockwell has been released for Engineering Activities, but until this QA plan submittal has been approved release for manufacture processes cannot-commence.
The Rockwell QA plan has not been revicwed, so the status of this follow up item will be open until the proper UE&C review has taken place.
4.
(Open) Follow Up Item ( Paragraph III. B.3.c.4 of Report 80-01):
The objectives of this follow up item were to assure that the System Design Description No. SDD-3 was revised to show the new vendor of the Main Steam Isolation Valves (MSIV's) and all the changes that have occurred on design information supplied by the new vendor.
UE&C commented that they will not commence changing SDD-3 until they have received all document submittals from the vendor; Rockwell.
The status of this follow up is open until UE&C receives all document submittals and changes the SDD-3 to reflect these vendor design document inputs.
C.
Design Document Control 1.
Objectives To determine that approved procedures have been established and are being implemented.for the control and distribution of design documents that provide for; Identification of personnel positions or organizations respons-a.
ible for preparing, reviewing, approving, and issuing design documents.
b.
Identification of the proper documents to be used in performing the design.
c.
Coordination and control of design (internal and external) inter-face documents, d.
Ascertaining that proper documents, and revisions thereto, are-accessible and are being used.
11 Establishing distribution lists-which are updated and maintained e.
current.
2.
Method of Accomplishment Review of the following-documents to determine that the preceding objectives were accomplished relative to Design Document Control:
a.
Design control program framework was identified in United Engineers and Constructors Topical Report UEC-TR-001-5A Ammendment 5 dated March 21, 1978, Section 17.1.3 entilted
" Design Control." The organizations or personnel responsible for preparing, reviewing, approving, and issuing design documents are defined in this section.
b.
In United Engineers and Constructors Power Division General Engineering and Design Procedures Manual the following pro-cedures were reviewed for organizational responsibilities and procedures:
(1) GEDP-0013, " Preparation of Drawings," Rev. 2 dated March 28, 1977.
(2) GEDP-0014, " Preparation of Design Specifications for Structures, Systems, and Components," Rev. 2, dated April 4, 1975.
(3) GEDP-0015, " Preparation of Specification," Rev. 2 dated April 28, 1975.
(4) GEDP-0032, " Control, Evaluation and Implementation of Design Changes," Rev. 3 dated October 29, 1976.
(5) GEDP-0033, " Control, Evaluation and Implementation of Review Comments on Design Documents," Rev. 2 dated November 20, 1978.
(6)
GEDP-0035, " Engineering and Design Interface Control,"
Rev. I' dated March 17, 1975.
c.
To assure the proper identification of documents to be used in performing the design of the Washington Public Power Supply System, projects 1 and'4, the following procedures in the UE&C manual of Project Procedures were reviewed:
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12 (1)' PP-7, " Project Files," Rev. O dated March 26, 1979 (2)
PP-15, "Use of Review of Document Form," Rev. O dated April 11, 1979.
(3)
PP-19, " Administering Contractor Waiver Requests," Rev. 3 dated August 16, 1978.
(4)
PP-21, " Drawing Practices and Approvals," Rev. 5 dated August 14, 1978.
(5)
PP-18, " Project Change Request" Rev. 2, dated May 13, 19.78.
(6) PP-37, " Request for Engineering Information," Rev. 3 dated October 12, 1979.
d, To assure that procedural requirements are being properly and effectively performed in the area of Design Document Control the following was reviewed:
(1)
In the WPPSS project Document Control Center the " Client Correspondence System Report," dated August 15, 1980, the following System Design Descriptions (SDD) transmittal letters UWA0328, WU60053, UW81226, UW81198 were properly filed and retrieved upon request.
(2) The Client Correspondence System Report dated August 15, 1980, Contractor Waiver Requests (CWR's) transmittal letter MW0001, WW0004, WW0006 were retrieved and proper distribution evidenced.
(3) Engineering Purchasing Schedule'(EPS), latest revision dated July 25,1980, was' reviewed and the following specifications were picked to assure that proper status is reflected on the document:
023, 027A, 053, 137, 154, 062, 087, 257, 40A, 148, 124 (All WPPSS Project Specifications).
These specifications were traced back to their initiating design discipline to find if they have been transferred to the construction site.
Evidence that the following speci-fications were transmitted to the site was found in the falla=ing memos (a) Specification 23 transmitted"to site by memo 3249;-(b) Specification 27A transferred by memo AM-90063; (c) Specification 62 transferred by memo AM90034; and (d) Specification 87 transferred by memo AM90090.4
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(4) The Drawing Task Tracking System (DTS) was reviewed and the following drawings were traced back to the Design Disciplines to assure proper status of revisions:
- 412336, 411921, 411359, 202525, 202552, 202733.
(5) Selected Engineering Change Notices (ECN's) were reviewed to assure that proper procedural steps were taken in the area of initiation, acceptance, review, and distribution of this change document. The tracking system incorporated by UE&C for these changes is the Project Change Notice Tracking System (PCTS). This particular data run was for-WPPSS Nuclear Project Nos. 1 and 4, Report No. 2, dated August 8,.1980, Job No. 6702.
The following Engineering Change Notices were selected from this data print out,- and specific information was compared with the originating discipline copy to assure that proper input and status update has been performed through this tracking system:
ECN 3087, ECN 3091, ECN 3068, ECN 3079.
(6) To assure that Foreign Vendor Prints of Drawings, are being received and that proper distribution of the draw-ings to the involved Discipline Design Groups, the Document, Control Center specifically was observed in this area of activity. A vendor document entry system called the
" Foreign Print System Weekly Report" which lists the foreign-prints for a specific Purchase Order, its current drawing issue number, and the transmittal letter numbers that dis-tributed the drawing was reviewed.
The following Foreign Prints reviewed were:
F.P. No. 20260, No. 20490, No. 40050, No. 40191.
(7) Another design document entitled " Request for Engineering Information," (RFI) was reviewed to assure that the entry was current on the Project Change Notice Tracking System (PCTS) and that the interface with other vrganizations within UE&C was functioning properly. The RFIs reviewed were origi-nated in the Piping Design Discipline No. 018, No. 027, No.-036.)
3.
Findings a.
In this area of'the inspection one (1). deviation from commitment was identified.
(See Notice of Deviation)
1 14.
2 b.
During the inspection it was observed.that WPPSS Project Quality Assurance keeps copies of specifications.
Though QA receives revisions with the accompanying transmittal notice, there is no UE&C commitment for Project Quality Assurance to keep an updated file of project specifications. Specification 9779-137 was found to contain only revisions to Rev. 10, whereas the definitive design discipline copy reflected a Rev. 15 status.
It was discovered that the incoming specification revisions were being mistakingly filed in the procurement file with the attached transmittal letter instead of properly inserting the attached revision to the Project Quality Assurance specification copy.
The specification in question was revised and the proper revisions were inserted into the Quality A=surance copy of the specification.
This area will be considered further during a subsequent inspection to determine compliance with program commitments.
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