ML19347D116
| ML19347D116 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/1980 |
| From: | Costello J, Hale C, Peranich M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19347D109 | List: |
| References | |
| REF-QA-99900509 NUDOCS 8103110090 | |
| Download: ML19347D116 (13) | |
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.,;. f.;,- ].. c.j - s;.irp:;...( :fSi: WCCEhR R Gdi.ATORY?COMtI5SIONl u1M 0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900509/80-06 Program No. 51200 Company:
Stone and Webster Engineering Corporatian P. O. Box 2325 Boston, Massachusetts Inspection at:
Boston, Massachusetts Inspection Conducted:
December 1-5, 1980 Inspector:
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~kO J. R. (oJs eflo, Principal jint ector Date Program Evaluation Sectio 5 Vendor Inspection Branch 0%i 0 No./
In-20-20 M. W. P(rjnicn,SeniorPropct, engineer Date Reactor Projects Section Division of Resident and Regional Reactor Inspector IE:HQ Approved by:
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C. J. Hatt, Chief Date Program Evaluation Section Vendor Inspection Branch Samarv
nspection on December 1-5, 1980 (99900509/80-06)
Areas Insoected:
Implementation of commitments to the NRC in the areas of followup on previous ir.spection findings from 79-05 and 80-03 inspections, followuo on a headquarters requ6ft, and followup on the special 79-03 inspec-tion.
The inspection involved fifty-six1(56) inspector hours on site by two (2) NRC inspectors.
Results:
In the three (3) areas inspected, one (1) deviation was identified.
There were no unresolved items.
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Deviation:
Followup on special 79-03 inspection - Noncomformance and Discosition Reports (N&D's) were identified that were not completed as required oy procedures.
(See Notice of Deviation enclosure).
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- %;A:(1 DETAILS SECTICN A.
Persons Contacted
- F. B. Baldwin, Assistant Quality Assurance Manager F. Belliveau, Engineer E. J. Brabazon, Project Engineer
- R. B. Bradbury, Chief Licensing Engineer J. A. Carota, Structural Engineer
- W. R. Curtis, Lead Engineer, Engineering Assurance
- E. P. Doherty, Supervisor, Engineering Assurance
- W. M. Eifert, Assistant Chief Engineer, Engineering Assurance
- E. F. Haslam, Jr., Vice President Senior Personnel Manager G. R. Heine, Coordinating Engineer
- S. L. Hunt, Supervisor, Engineering Assurance "J. W. Kelly, Quality Assurance Program Administrator
- G. S. Krall, Assistant to the Project Engir.eer E. McManus, Principal Mechanical Engineer S. Morss, Engineer, Engineering Assurance A. M. Mottola, Document Clark D. P. Richard Engineer J. B. Selden, Regulatory Advisor, Licensing Division
- D. C. Shelton, Chief Engineering, Engineering Assurance
- L. P. Walker, Head Licensing Technical Section
- P. A. Wild, Vice President, Director of Engineering
- Denotes those present at exit meeting.
B.
Followuo On Previous Insoection Findings 1.
(0 pen) Unresolved Item (79-05):
It is not apparent that adequate measures have been established to control humidity to specified requirements in the Records Retention Center.
l There is a major effort in effect to upgrade the records retention center which will replace the present air conditioning with a more sophisticated air conditioning system better able to control humidity.
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- This item will be reinspected during a subsequent Boston inspection.
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2.
(Closed) Deviation (80-03):
Surry project procedure STF-3 for IE l
Bulletin 79-14 related work was not adequate in addressing time frames and responsibilities for evaluating nonconformances with respect to system operability and prompt notification of the utility.
l Surry project procedure STF-3 has been revised (revision 3) as of l
9/30/80 to require that for the remaining Surry IE Sulletin 79-14 l.
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. ia e evaluations the following will take place:
The final issuance to VEPC0 of the Boston Task Force Project Engineer's (SPE) review snall take place witnin thirty (30) days after initiation of Attacnment 3 (Nonconformance/0verstress Condition Notification) icentifying possible overstress.
This revision to procedure STF-3 satisfies the requirement of IE Bulletin 79-14 that the analytical engineering evaluation be completed in 30 days and makes the BPE responsible for meeting the time frame.
C.
Followuo On Pre'ious Investigation This area of inspection is a followup of an investigation relating to an employee at Stone & Webster Engineering Corporation (S&W) misrepresenting employment records in order to secure emoloyment as a stress analyst.
The investigation was conducted at S&W offices on August 5-7, 1980.
The results of the investigation are centained in Report No. 99900509/80-04 dated August 21, 1980, and attachment thereto dated August 25, 1980.
In summary, allegations concerning qualifications of a stress analyst emoloyed by S&W were confirmed.
The S&W corrective action which had been initiated prior to our investigation included terminating the employee in question and initiating a verification program of the education and employment back-ground of all technical and professional contract design personnel employed by the Boston Office of S&W.
1.
Objectives a.
Determina if QA program requirements have been violated.
b.
Determine corrective and preventive actions.
c.
Determine present status of problem.
2.
hthodofAccomplishment The preceding objectives were accomplished by an examination of:
a.
Five (5) personnel records with discrepancies
~ b.
Three (3) new personnel forms for soliciting information regarding former employment, education and professional registration.
Three (3) followup form l'etters for the above personnel forms.
c.
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Findings a.
As indicated above and in Report 99900509/80-04, the allegations concerning qualifications were confirmed and the employee was terminated.
b.
In the 99900509/80-04 report a figure of approximately 85 contract employees was used.
The actual figure was 73.
c.
During the period that authorization forms for verifying education and experience background were being sent to each contract design employee, 9 of the 73 resigned on a voluntary basis.
Therefore, S&W did not obtain the necessary releases to check the background of this group.
d.
The education anc/or prior employment of 5 of the remaining 64 employees did not agree in all respects with their claimed credentials.
e.
Four (4) of the 5 with discrepancies in their credentials resigned voluntary; the other person was terminated on December 1, 1980.
f.
The work performed by the 5 individuals whose background check revealed discrepancies, as well as the work performed by the 9 individualswhosebackgroundswerenotchecked,wassubjected to independent verification in accordance with the provisions of the S&W Quality Assurance Program.
g.
To prevent recurrence of this problem, S&W has instituted a program whereby S&W verifies in writing the educational back-ground, employment record for the previous five (5) years and professional registration (if any) of all of its contract design employees. This same program has been instituted for all technical and professional employees hired directly by S&W.
The personnel practice for the last two (2) to three (3) years for employees hired directly by S&W was to verify employment and education by phone.
h.
No deviations or unresolved items were identified in this area of inspection; however, further review of the terminated employees work will be co.nducted during a subsequent inspection.
D.
Followuo on Soecial 79-03 Insoection An introductory meeting was held on December 2, 1980, at 9:00 AM to discuss the purpose of this inspection and to outline the general inspection plan.
The general inspection plan covered the steos to be taken by the inspectors to verify S&W's imolementation of corrective and preventive actions discussed in their September 6, 1979, and August 15, 1980 response letters to Special Inspection Report 99900509/79-03.
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Included in this plan were a review of S&W revised 10 CFR 21 procedures and tneir implementation.
1.
Objectives a.
Confirm S&W's implementation of corrective and preventive actions discussed in their September 6,1979; December id,1979; April 10, 1980; July 9, 1980; and August 15, 1980 letters, b.
Review S&W's reassessment of past deviations forwarded to NRC licensees for reporting under 10 CFR 50.55(e) to determine whether the NRC should have been so informed by S&W of these deviations pursuant to 10 CFR Part 21.
c.
Review content and implementation of all present procedures or other instructions established to assure compliance with 10 CFR 21.21(a) requirements for evaluation of identified " deviations" and informing a responsible officer of S&W of a matter that is reportable under 10 CFR Part 21.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of the following documents:
Ref. No.
S&W Document Date/Descriotion Quality Standards QS 1.
10/24/79 - QS 16.1, Rev. A,
Title:
S&W Problem Report System.
2.
10/31/79 - QS 16.2, Rev. A,
Title:
Noti-fying Clients of Potentially Reportable Deficiencies Under 10 CFR 50.55(e).
. 3.
5/19/80 - QS 16.3, Rev. A, Change 1,
Title:
Identifying and Reporting Defects and Failures To Comply Under 10 CFR 21.
Engineer 4-hAssuranceProcedures(EAP) 4.
7/15/80 - EAP 6.3, Rev. 3, Change 3,
Title:
Preparation, Review, Approval, and Control of E&DCR's (Engineering and Design Coordi-nation Reports).
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Ref. No.
S&W Occument Date/0escriotion 5.
9/28/79 - EAP 15.1, Rev. 3, Change 9,
Title:
Handling of Nonconformance and Dispo-sition Reports (N&D's) by Engineering -
Applies to Shoreham & North Anna only.
6.
8/12/80 - EAP 15.2, Rev. 1, Change 1,
Title:
Handling of Nonconformance and Dispo-sition Reports (N&D's) by Engineering.
7.
6/19/80 - EAP 16.2, Rev. 5, Change 1,
Title:
Problem Report System.
8.
10/31/79 - EAP 16.2, Rev. 2, Change 1,
Title:
Notifying Clients of Potentially Reportable Deficiencies Under 10 CFR 50.55(e).
9.
10/31/79 - EAP 16.3, Rev. O,
Title:
Identifying and Reporting Defects and Failures to Comply Under 10 CFR 21.
Ref. No.
Engineering Department Memorandums, WJL Kennedy, Vice President to Distribution 10.
4/30/79 - No. 79-7,
Subject:
Reporting of Significant Problems For Corrective and Preventive Action 11.
12/13/79 - No. 79-29,
Subject:
Evaluation of Past 10 CFR 50.55(e) Reports and Licensee Event Reports.
10 CFR 21 Notifications of Defect 12.
7/23/80 - GE 4 kv switchgear circuit breaker -
snap rings.
13.
7/23/80 - GE 4ky switchgear circuit breaker -
fuse holder.
14.
7/23/80 - GE 4kv switchgear circuit breaker -
closing latch.
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Ref. No.
S&W Occument Date/Descriction 15.
5/29/80 - Emergency Diesel Generator Exhaust Silencer Support System - Seismic Protection; Fairbanks Horse Engine Division.
16.
7/1/80 - Diesel Generator Battery Racks; Fairbanks Morse Engine Division.
17.
7/1/80 - Containment Electrical Penetration Fault Current Protection Devices; Stone & Webster Engineering Corporation 18.
8/27/80 - Use of fillet welds in place of full penetration welds for attachments to safety related piping; Stone & Webster Engineering Corporation.
19.
11/24/80 - Procurement and use of undocumented Safety Injection System (SIS) cable inside containment; Stone & Webster Engineering ~ Corporation 20.
12/2/80 - Square D Company 480V Motor Control Centers - NEMA Size 3 starters with catalog numbers 8536SE01, 8736SE02, 8502SE02.
Reports of a Problem 21.
6/5/79 - Pipe Stress Analysis - North Anna 1 22.
6/27/80 - Possible Defect, 480V Motor Control Centers, Type 3, Starters, Square 0 Company - Shoreham #1.
Problem Reoorts 23.
1/16/78 - PR-P-97, Motor Operated Butterfly Valve Insulation Deficiency, North Anna 3 & 4.
24.
6/26/79 - PR-P-18, Pipe Support Base Plate Designs Using Concrete Anchor Bolts n.
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Ref. No.
S&W Document Date/Descriotion Nanconformance And Discosition Recorts 25.
9/21/78 - N&D 1882, Stainless Steel Seismic Tube Supports 26.
3/2/79 - N&D 2113, Core Spray 27.
11/4/80 - N&D 0506, Gouges on Embedments 28.
5/29/79 - N&D 0169, Component Cooling Heat Exchanger Support Steel 29.
10/24/80- N&D 0497, Calibration of Load Cell 30.
7/3/80 - N&D 0406, Reactor Vessel Vertical Restraint Pad Indicator.
31.
5/29/79 - N&D 0498, Component Cooling Heat Exchanger Support Steel - Superceded N&D 0169 10 CFR 21 Evaluations - Licensing File EDM 79-29 32.
Containment Motor Operated Valves -
James A. Fitzpatrick.
33.
Control Cable - Nine Mile Pt. 2 34.
Diesel Generator Exhaust Silencer Support System (Tornado Protection) -
North Anna 1 and 2.
35.
Nonreportability of Silt Buildup -
Beaver Valley 1
- 36.
Pipe Rupture / Break Restraint -
North Anna 1.
37.
Pipe Stress Analysis - North Anna 1.
38.
Upper Support Embedment Plate - North Anna 1.
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Ref. No.
S&W Occument Date/Descriotion Deviations Evaluated For 10 CFR 21 - Not Part of EDM 79-29 39.
Reactor Containment Liner / Graver -
Beaver Valley 1.
40.
Rosemount Pressure Transmitters -
River Send.
41.
Rosemount Pressure Transmitters -
Nine Mile Point #2.
42.
Minimum Design Shielding Requirement -
River Bend.
43.
4kv Switchgear, G. E. Timing Relays -
Shoreham:
3.
Findings a.
In this area of inspection, o'e (1) deviation from commitment was identified (See Notice of.<viation).
There were no unresolved items.
b.
The item identified in inspection report 99900509/79-03 dated August 10, 1979, listed seven (7) procedural deficiencies con-tributing to the infraction.
The corrective actions and preven-tive measures taken to rectify these deficiencies are described in Stone & Websters letter of response to Victor Stello Jr.
IE:HQ's, USNRC, dated September 6,1979.
The corrective actions were completed by October 3{ 1979, and consisted of revisions toQS16.1,QS16.2,QS16.I,andtheapplicabilitymatrixof QS 16.3.
In additioa, EAP 16.3, Revision 0, was issued and all interim instructions and memorandum for the Engineering Depart-ment were formally cancelled.
The preventive measures included the use of the new procedures but in addition S&W sent a notice to all of its offices and facilities subject to 10 CFR 21 advising its personnel of the changes in internal procedures and directing them to review and follow the revised procedures.
All of the procedural def'iciencies identified in the infraction are considered adeouately resolved except for the deficiency concerning limited applicability of QC 16.3 to the evaluation of reportable deviations.
Resolution of this will be dependent upon S&W's response to the deviation identified in this inspection report.
This item will be reviewed during the next inspection.
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~s The infraction listed as item A in the 79-03 report is consicered closed.
c.
Corrective actions and preventive measures taken to rectify the two deficiencies Ifsted on items B & C in inspection report 99900509/79-03 were completed by October 31, 1979.
S&W measures are as follows:
(1) Revisions to QS 16.2 and 16.3 which (1) provided for sub-mittal to the designated responsible officer information required to determine if the Commission had been adequately informed and (2) provided separate notification and a report to the Commission when upon evaluation, it is determined that an item which has been reported under 10 CFR 50.55(e) is also a defect under 10 CFR 21.
(2) S&W initiated a review of all 10 CFR 50.55(e) reports and LER's published since 1/6/78 to determine if there are any 10 CFR 21 defects.
This review was completed by December 1, 1980.
(3) A revised Part 21 poster has been placed at all Stone and Webster offices and facilities where activities subject to Part 21 are conducted.
The revised poster includes the full text of Section 206 of the Energy Reorgainzation Act of 1974, the regulations cont d ed in 10 CFR 21, a descrip-tion of the Quality Standard (00 adopted pursuant to 10 CFR 21, a statement where the QS f.. available for examination, and the name of an individual to whcm notification can be made.
The deficiencies listed as items B&C in the 79-03 report are considered closed.
d.
Cor:ective actions and preventive measures taken relative to the deviation listed as item ', ir faspection report 99900509/79-03 were completed by October 31, 1979.
These
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measures included revisions to EAP 16.1 and QS 16.1 which required that justificac N.. for determinations not to issue a problem report be docmented.
However, the potential for inadequate documentation may exist in the present revised procedures when a " report of a problem" is returned to the originator by the Project Engineer or Engineering Assurance.
This area will be examined during future inspections to assure that adequate docmentation exists in those cases where reports of a problem are returned to the originator prior to the review conducted by the Engineering Division assigred reviewer.
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e.
In response to the request in the NRC letter dated August 10, 1979, S&W conducted an evaluation of past 10 CFR 50.55(e) anc Licensee Event Reports (LER) in accordance with Engineering Department Memorandum (EDM) No. 79-29.
our inspection of ECM 79-29 inn. ructions and implementation, i
relative to conducting a review of past 50.55(e) and LER reports initiated by S&W to determine whether the Commission was adequately informed under 10 CFR 21, identified two reports I
that had not been subject to these reviews.
These pertained to:
(1) Containment MOV's (Motor Operated Valves) - J. A. Fitzpatrick (2) Pipe Stress Analysis - North Anna 1 Before completion of the inspection S&W satisfactorily addressed the inspectors concerns by initiating a ECM 79-29 10 CFR 21 review of ecch of the above items.
This review will include evaluation cf each item unoer S&W Problem Report Procedures to assure that all generic consicerations under 10 CFR 21 have been closed out.
As a result of the EMD 79-29 review seven (7) 10 CFR 21 reportable items were identified and reported (see Method of Accomplishment Ref. Nos. 12 thru 18).
Further, as a result of the deviation identified in this report, a question arises concerning the revised procedures and their implementation.
Based on ooservations made during this inspection of S&W filling out N&D forms that, even though the inspector did not identify a specific deviation that had not been reviewed under Part 21 (EAP 16.3) procedures, the inspector could not conclude that the mechanism used by S&W,to identify whether the N&D is a 50.55(&) ites,will assure that all deviations identified by the QA program in delivered basic components would be subject to evaluation under EAP 16.3.
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We plan to review the S&W res;onse to the Notice of Deviation and conduct additional followup of t!.a S!.W mechanism established to assure that all deviations in deliveres basic components are properly considered under 13 CFR Part 21.
E.
Exit Meetina-1 4
A meeting was conducted with management representatives at the conclusion of the' inspection on December 5, 1980.
In addition to the individuals indicated by an asterisk in the Details Section those in attendance were:
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R. G. Burns, Assistant Quality Assurance Manager
'J. H. Fletcher, Project Engineer S. B. Jacobs, Assistant Engineering Manager R. B. Kelly, Vice President and Manager, Quality Assurance D. T. King, Engineering Manager S. C. Rossier, Assistant Engineering Manager R. J. Rudis, Engineer, Engineering Assurance R. C. Tappan, Project Engineer The two inspectors summarf7.ed the scope and findings of the inspection for those present at the meeting.
Management representatives acknowledged the comments of the inspectors relating to the results of the inspection.
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