ML19345G041
| ML19345G041 | |
| Person / Time | |
|---|---|
| Issue date: | 12/17/1980 |
| From: | Breaux D, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345G032 | List: |
| References | |
| REF-QA-99900510 NUDOCS 8102190803 | |
| Download: ML19345G041 (14) | |
Text
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O U.S. NUCLEAR REGULATORY CCMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900510/80-03 Company:
United Engineers & Constructors, Inc.
30 South 17th Street Philadelphia, Pennsylvania 19101 Inspection Conducted:
November 17-21, 1980 Inspectors:
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- bkg, 12.//4 /r0 J.
. Costello, Principal Inspector
'0afe P
ram Evaluation Section Vendor Inspection Branch CV O 6.hti L S. Sua n.hs lec 0.
eaux, inspector)
Date P
ram Evaluation Section Ve or Inspection Branen Approved by:
h' / 7- [O C. J.(H@ e, Chief Oate ProgranTEvaluation Section Vendor Inspection Branch Summary Inspection on November 17-21, 1980 (99900510/80-03)
Areas Insoected:
Implementation of 10 CFR 50, Appendix 3, criteria in the areas of cesign corrective action, procurement document control, procurement source selection and follow-up previous inspection findings.
The inspection involved sixty-two (62) hours on site by two (2) USNRC inspectors.
Results:
In the four (4) areas inspected, one (1) deviation was identified in one (1) area.
There were no deviations in the other areas and no unresolved items were identified in any of the areas inspected.
Deviation:
Procurement Document Control:
Contrary to procedural requirements, some imoortant procurement correspondence was not marked to indicate wnether a response by the client was required (See Notice of Deviation).
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l DETAILS SECTICN I (Prepared oy J. R. Costello)
A.
Persons Contactec J. E. Hill, Control Engineer, Instrumentation & Control P. C. Lahoti, Supervising Engineer, Quality Planning
- R. H. Leonard, Assistant Manager, Reliability and Quality Assurance R. C. Lesnefsky, Supervising Engineer Project Quality (WPPSS)
D. E. McGarrigan, Manager Quality Assurance (Seabrook)
'W. S. Stevens, Senior Attorney, Corporate Legal Department
" Denotes those present at the exit meeting.
l 3.
Follow-uo on Previous Inscection Findings 1.
(0 pen) Deviation 3 (Report No. 30-01):
Contrary to procedures, issued drawings were not properly identified as safety-related (3.1), were not certified (3.2), or were not marked void or destroyed when superseded (3.3).
Corrective and preventive actions concerning 3.1 and 3.3 were comoleted by properly identifying drawings as safety-related and marking or destroying superseced drawings.
This is described in Report 80-01, plus UE&C letter of response dated July 2, 1980.
In a revised response to 3.2 dated August 20, 1980, UE&C stated it wants its drawings certified per the requirements of GEDP-0013.
The backfit of certifying tne drawings is scheduled to be complete by December 31, 1980.
Copies will be reissued only when the drawing is revised.
Verification of :nese actions will be made during a future inspection.
2.
(Closed) Deviation E (Recort No. 80-01):
Contrary to PSAR commitment IEEE Standard 382 was not invoked in a procurement document for the Containment Atmospheric Monitoring Systems.
t UE&C stated that PSAR Table 7.1-1 was in error in scecifying IEEE-382 and planned to revise this taole as part of the FSAR effort.
The new FSAR dated 9/2/80 has corrected the requirements shown in PSAR Table 7.1-1 and no longer requires IEEE Standard 382 for Containment Atmospheric Monitoring Systems.
Note:
See DetailsSection II for other additional folicwuo on previous inspection findings.
C.
Design Corrective Acticn f
1.
{b,iectives The objectives of this area of the inspection were to examine and verify
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a.
Procedures have been established and implemented for identifying deficiencies of a significant or recurring nature, determining the cause of the deficiencies, and initiating corrective action to prevent recurrence.
b.
Deficiencies and their corrective action are reported to appropriate levels of management.
c.
Followup action is taken to assure timely completion of corrective action of a deficiency when resolution is not completed immediately.
d.
The design process and verification procedures are reviewed and modified as necessary where a significant design change is necessary due to incorrect design, or in the case of recurring deficiencies.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Chapter 17.2 of the Preliminary Safety Analysis Report (PSAR) for Seabrook Station Unit 1 and 2 (UE&C Quality Assurance).
b.
Chapter 17.2 of the PSAR for WNP-1 (UE&C Quality Assurance).
c.
Implementing procedures to satisfy PSAR quality assurance program commitments and to satisfy the intent of the objectives section.
These procedures are:
(1) General Engineering & Design Procedure GEDP-0032, Revision 3, Control, Evaluation and Implemention of Design Changes.
(2) General Engineering & Design Procedure GEDP-0034, Revision 1, Response to Audits, Corrective Action Requests and Other Quality Assurance Reports.
(3) General Engineering & Design Procedure GEDP-0046, Revision 0, Response To Potential Significant Deficiencies as Defined In 10 CFR 50 Paragraph 50.55(e).
(4) Quality Assurance Procedure QA-5, Revision 6, Instructions, Procedures and Drawings For WPPSS Nuclear Project No. 1 and No. 4.
(5) Quality Assurance Standard XVI, Revision 5,. Corrective Action.
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4 (6) Corporate Procecure, Reporting of Defects and Noncompliance to the Nuclear Regulatory Commission.
Revised Novemcer ic80.
(7) Public Service Company of New Hampshire, Seacrook Station Unit 1 and 2 Acministrative Procedure No. 15, Changes to Project Occuments.
(8) General Er.gineering & Design Procedure GEDP-0015, Revision 3, Preparation of Specifications.
d.
Documents to verify implementation of PSAR quality assurance program commitments and to satisfy the intent of tne ocjectives section.
The documents are as follows:
(1) 10 CFR Part 21 Reports (a) UE-NRC-21 Report dated 4/10/79.
This report covered the failure of Rosemount Model 510 DU Trip Calibration Units.
These units have a tendency to malfunction by unexpected and uncalled for unlatching of the gross output signal caused by voltage transients nhich affect tne silicon controlled rectifier.
The Rosemount failures were determined by the 10 CFR 21 committee to not be a defect or noncompliance on 4/20/79.
This was done on the basis no essential safety feature was compromised by this type of failure.
(b) UE-NRC-21 Report dated 11/13/79.
This report covered the lack of proper calibration of the M/P Power Source used in the magnetic particle examination of the wciding performed on structural portions of beams used in polar cranes fabricated in Harnescr.feger's facility.
l The above recorted failure was determined not to be a defect or noncomoliance on 12/5/79.
l (c) UE-NRC-21 Report datea 5/15/80.
This report covered the results of a UE&C review of NRC Sulletin No. 79-02 whicn showed additional unrelated deficiencies in the design of various pipe suoports.
l This was not reported as a 10 CFR 21 defect.
(d) UE-NRC-21 Report dated 5/19/80.
This report covered the use of incorrect amolified response spectra (ARS) l for the design of Atmospneric Clean-Up Trains, Fan and j
Fan Housing for WNP 1/4.
5 The above discrepancy was determined to be a defect or noncompliance and NRC headquarters was notified by letter dated 8/8/80.
(e) Notification to NRC of a potential 10 CFR 21 defect dated May 13, 1980.
This potential defect was first reported in USNRC Report No. 99900510/79-02 dated June 14, 1979, and was reported again on May 13, 1980, when a responsible officer of UE&C was made aware of the problem.
This noti-fication covered the use of an earlier revision of amplified response spectra in the design of two safety related tanks for WNP-1.
Evaluation of the deviation revealed that a defect, as defined in 10 CFR 21, did not exist as the design of the tanks did not have to be modified when analyzed with the new response spectra.
(f) Notification to NRC of a potential 10 CFR 21 defect dated May 15, 1980.
This potential defect was first reported as a 10 CFR 50.55(e) ceficiency and was discussed in USNRC Report No. 99900510/79-04.
It was reported as a 10 CFR 21 item when a responsible officer of UE&C was made aware of the problem.
This notification covered the use of invalid seismic amplified response spectra in the design of the containment annular ring for the Seabrook project.
(2) 10 CFR Part 50.55(e) Notifications (a) Notification to Region V dated 1/24/80.
This notifi-cation covered pipe support base plate designs using concrete expansion bolts (WNP-1/4).
Original design calculations did not account for the effects of base plate flexibility to the extent specified in item 1 of IE Bulletin 79-02.
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(b) Notification to Region V dated 2/24/77.
This notifica-tion covered design of General Services Building (WNP-1/4).
l Original calculations assumed floor slabs acted as rigid diaphrams.
Later improvements in analysis using three dimensional finite element analysis showed the design was not conservative enough.
(c) Notification to Region V dated 11/30/79.
This notifi-cation covered instances of partial or comolete lack of fusion of spotwelds on the steel struts used to support electrical raceway systems for WNP-1/4.
All of these deficiencies were traced to one manufacturer.
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(d) Notification to Region V dated 1/23/78.
This notification covered voics discovered in the nortn face of placement No. 28 of concrete 'aNP-1/4 The voids were attributed to improper consolidations of concrete in an area of extensive rebar congestion.
(e) Notification to Region I dated 9/27/78.
This notification covered the undersizing of the refueling water storage tank (RWST) for the Seabrook project.
The RWST was increased from 375,000 to 475,000 gallons.
(f) Notification to Region I dated 11/6/79.
This notification covered a deficiency in four crawings which did not show all of the reinforcing bar called for in the calculations.
(g) Notification to Region I, oated 10/8/80.
This notification covered a deficiency wnere a slotted hole had been cut with a torch and the oxide layer on the hole surface had not been removed.
(h) Notification to Region I dated 11/6/80.
This notification covered a deficiency in the cooling tower concrete beams where the reinforcing stirrups were closer to the concrete surface than permitted by code.
(3) Engineering Change Authorizations (ECAs)
(a) ECA 0110037A - Revise Anchor Plate Si:e (b) ECA 01055A - Correct Rebar Detailing Error (c) ECA 011750A - Weld Correction Angle to Emoedded Plate (d) ECA 011536A - Revise Pressuri er Slab (4) Design Change Notices (DCNs)
(a) DCN 011560A - Revise Design Calculations (b) DCN 030529A - Revise Reactor Coolant Schematic (c) DCN 020070A - Revise Emergency Feecwater Pipe Manifold (c) OCN 030088A - Revise Design of Fuel Pool Receptacle (e) DCN 080031A - Revise Containment spray System Description
7 (5) Specifications (a) 9779-58, Revision 1, Division 15, Section 15A, local Instrument Racks ASME Section III WPPSS Quality Class I.
(b) 9779-53, Revision 13, Diesel Generators (c) 9779-155, Revision 6, Control Valves and Regulators 3.
Findings No deviations from commitment or unresolved items were identified in this area of inspection.
D.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on November 21, 1980.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance were:
G. F. Cole, Project Manager R. A. Curnane, Vice President, Project Support Operations D. H. Rhoads, Project Engineering Manager J. B. Silserwood, Manager Reliability and Quality Assurance D. J. Stride, Project Administrator 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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8 DETAILS SECTION II (Prepared by D. G. Breaux)
A.
Persons Contacted O. C. Goodrich, Project Planning Engineer R. C. Lesnefsky, Project QA Engineer, WPPSS Project
- 8. C. Low, Quality Engineer, Seabrook Project R. A. Mabry, Supervising Mechanical Engineer, Seabrook Project R. H. Marsh, Manager QA Audits D. E. McGarrigan, Quality Engineer, Seabrook Project J. A. Wilmer, Purchasing; Seabrook Project S.
Action on Previous Insoection Findings 1.
(Closed) Deviation (Report 80-02,) The Engineering Purchasing Schedule (EPS) for the WPPSS Project did not reflect current revision status of specifications, as required by procedures.
The ir.spector verified the corrective action described in the UE&C letter of response dated October 27, 1980, i.e., the latest applicable revision,for the specifications in question will be identified and recorded on the latest issue of the Engineering Purchasing Schedule (EPS).
To verify that preventive action was taken, the inspector interviewed the Planning Engineer that is assigned to review the Home Office controlled specification revision numbers with each Discipline Supervising Engineer and reflect this on the EPS update.
f 2.
(Closed) Follow-up Item (Paragraph III.B.3.c.3 of Report 80-01):
The objectives of the followup were to assure that the vendor for Purchase Order No. 9763-006-248-65, for the Main Steam Isolation Valves (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 3 and ANSI N45.2.
The inspector verified this by reviewing UE&C QA Audit NH-369 dated October 7, 1980, of the Flow Control Division, Rockwell International, Raleigh N. C.
The scope in the area of this audit was the QA program relative to Purchase Order 9763-006-248-65.
Upon resolution of several findings listed in the audit report, Rockwell's QA plan will be approved and they will be released for manufacturing.
3.
(0 pen) Followup Item (Paragraph III.S.3.c.4 of Report 80-01):
The objectives of this follow-up item were to assure that the System Design Description No. S00-3 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 S00-3 until they have received all documented submittals from the vendur, Rockwell.
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The status of this follow-up is open until UE&C receives all document submittals and changes tne 500-3 to reflect these vendor design document inouts.
This inspection revealed that most supplier document submittals had been received and were in-house for review, but that 500-3 would not be changed until these reviews were satisfactory.
C.
Procurement Source Selection 1.
Objectives The objectives of this area of the inspection were to verify that pro-cedures have been established and implemented for the selection of qualified suppliers or services, materials, parts and components that provide for:
Requirements for evaluation of the potential supplier's capability a.
to provide items or services in accordance with the technical and quality assurance specifications of the procurement documents.
b.
Methods of evaluating potential suppliers that are consistent with applicable regulatory, code and contract requirements and should include source evaluation audits, review of historical performance, and/or review and evaluation of the supplier's QA program, manual and procedures.
Consideration of the complexity, inspectability and safety signifi-c.
cance of purchased items or services when selecting the method of source evaluaton.
d.
Performance acurce evaluaticn audits that include appropriate checklists or instructions for systematic review of the prospective supplier's QA system.
e.
Qualification requirements for personnel performing source evalu-ation audits.
f.
Source selection being based on historical product performance that includes review of past procurement and operating experience with identical or similar items and is limited to relatively simple i
services or off-the-shelf items.
l g.
Periodic re evaluation of suppliers and that an up-to-date listing of the evaluation status is being maintainea.
h.
Distribution of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to companies designated in these documents.
i 10 i.
Measures to assure that the stoolier's Did conforms to the procure-ment document requirements and that resolution of unaccectable conditions identified during Did evaluation are corrected before the contract award.
2.
Method of Accomolishment The preceeding objectives were accomplished by review of the following documents.
a.
United Engineers and Constructors Topical Recort UEC-TR-001, Amendment 5, dated March 21, 1978, Section 17.1.7, " Control of Purchased Material, Equipment, and Services." The organi:ations involved in the area of procurement selection are identified in this section.
b.
In the UE&C Power Division General Engineering and Design Procedures (GEDP) Manual, the following procedures were reviewed for organizational responsibilities:
(1) GEDP 0038 " Procurement of Equipment, Material, and Services" Ruvision 1, dated February 19, 1975.
(2) GE P 0039 " Technical Bid Evaluation" Revision 2, dated December 10, 1978.
c.
In the Power Division Operations Manual - Section VII - General Administration Procedure GAP-001 dated Novemoer 25, 1974, "Corre-spondence Control" departmental responsibilities were identified.
d.
In the UE&C Quality Assurance Manual Corporate Standard the contents in the area of procurement source selection were reviewed for positive reflection of Topical Report commitments.
To assure that procedural requirements are being properly and l
e.
l effectively performed the following were reviewed:
(1) Procurement files for the following Seabrook project purchase orders were reviewed to assure that source selections activ-ities such as bidders lists, commercial and technical evalu-l ations, and UE&C recommendation to client on evaluation of supplier were being properly generated:
(a)
P.O. #9763.006-248-31, Steam Generator Safety Vaives.
(b)
P.O. #9763.006-248-?6, Feedwater Isolation Valves.
(c)
P.O. #9763.506-248-65, Main Steam Isolation Valves.
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P.O. #9763.006-246-1, Refueling Water Storage Tank (RWST).
(e) P 0. #9763.006-238-1, Containment Spray Pump.
(f)
P.O. #9763.006-248-9, Containment Spray Noz:les.
(g)
P.O. #9763.006-248-29, Plug Valves.
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(h)
P.O. #9763.006-248-30, Diaphragm Type Valves.
(i)
P.O. #9763.006-248-34, Containment Penetration.
f.
The following re-audit evaluations of suppliers were selected from a QA generated document, UE&C External Audit Schedule, to assure proper procedural implementions:
(1) Bethlehem Steel (Albany); Last audit 7/78 (#NH211) evaluated and reaudit referral to 7/80.
(2) Crosby Valve; Last aidut 9/78 (#223) evaluated and reaudit referral to 9/80.
(3)
Irwin Steel; Last audit 8/78, (#215) evaluated and reaudit referral to 8/80.
g.
The following pre-award facility surveys were reviewed for proper implementation of procedures:
(1) Audit #357, Consip Custom Line, (2) Audit #363, System Control Inc.,
(3) Audit #31, Sprayco, i
(4) Audit #18, Bingham Williamette, and i
(5) Audit #321, Bethlehem Steel.
3.
Findings a.
In this area of the inspection no deviations from commitment were identified.
b.
Unresolved Items or Follow-uo Items None were identified.
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12 3.
Procurement Document Control 4
1.
Obiectives The ocjectives of this area of the inspection were to verify that procedures have been prepared and er 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 tne supplier, the tecnnical 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 3.
4 d.
The supplier is required to incorporate appropriate quality assurance program requirements in sub-vendor procurement documents.
I e.
Procurement documents provide rights of access to the supplier's plant facilities and records, identification of manufacturing hold points, witness points and notification of the time of these events, documentation recuirements, records requirements, and requirements for reporting and approving of the disposition of nonconformances.
f.
Procurement documents are reviewed by the QA organization before transmittal to the prospective suppliers and these reviews are documented.
g.
Changes to procurement documents undergo the same degree of review and controls as tne original documents.
h.
Measures to control the release and distribution of procure-ment documents are being implemented.
l 2.
Method of Accomolisnment The preceding objectives were accomplished by review of the following documents.
13 3.
lited Engineers and Constructors Topical Report UEC-TR-001 (mencment 5 catec March 21, 1978, Section 17.1.4, Procurement Document Control.
The organi::ations involvec in tne area of procurement document control are identified in this section.
b.
The Quality Assurance Manual, Corporate Standard, was reviewed to see that a system of controlling procurement documents was set up as outlined in the Topical Report UEC-TF-001.
c.
In the Power Division Oceration Manual,Section VII, General Acministrative Procedures, the following were reviewed for specific instructions:
(1) GAP-001 dated November 25, 1974, Correspondence Control.
(2) GAP-0014 dated Septemcer 17, 1975, Document Control Center.
d.
To assure that procedural requirements are being properly and effectively performed, the following were reviewed:
(1) Seabrook project procurement specifications and their associated revisions with their initiating change orders were reviewed for content and procedural requirements.
Specifications 248-31, 248-36, 248-65, 246-1, 238-1, 248-9, 248-9, 248-29, 248-30, and 248-34 (2) The following Seacrook Project Purcnase Orders were reviewed for proper procedural requirement execution:
(a)
P.O. 9763.006-248-31 (b)
P.O. 9763.006-248-36 i
l (c)
P.O. 9763.006-248-65 (d)
P.O. 9763.006-238-3 (e)
P.O. 9763.006-248-9 (f)
P.O. 9763.006-248-29 (g)
P.O. 9763.006-248-30 (h)
P.O. 9763.006-248-34 e.
From a Seabrook project document titled Client Correscondence System Report, the following corresconcence letters were reviewec.
i 14 (1) Five (5) UE&C suggested procurement bid lists to client.
(2) Eight (8) UE&C commercial and tecnnical bid evaluations to the client in area of procurement.
I (3) Twelve (12) UE&C final supplier recommendations to clienc for procurement approval.
3.
Findinos a.
In this area of the inspection one (1) deviation from commitment was identified.
(See Notice of Deviation).
b.
Unresoived Items or Follow-uo It?ms None were identified.
c.
Comments With respect to the deviation from commitment in the area of client response to UE&C generated procurement documents, there is a basic underlying, concern.
This concern is that the UE&C Client Correspondence System Report, which is a definitive document control listing identifying all outgoing corresponcence from UE&C to the client, is not reflecting proper response status.
Without accurate and complete information in this Client Correspondence System Report, concerning the need for client response to each document, possible unresponded important pro-curement correspondence could go unnoticed.
A listing of all correspondence requiring client response is extracted from this Client Correspondence System Report.
This listing is sent to project management for expediting these resconses.
It is the responsibility of the responsibile engineer that initiates the client correspondence to clearly mark for document control whether a response is required.
Without this information from the esponsible engineer, follow-up on out-standing client responses is ineffective or impossible.
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