ML20008G049
| ML20008G049 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1981 |
| From: | Chamberlain D, Costello J, Hale C, Henderson J, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20008G045 | List: |
| References | |
| REF-QA-99900507 NUDOCS 8107020029 | |
| Download: ML20008G049 (12) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99500507/81-02 Company:
Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 Inspection at:
Chicago, Illinois Inspection Conducted: March 17-20, 1981, and April 6-10, 1981 Inspectors:
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C. J. Itald, Chief N
Date Reactor Systems Section vendor Inspection Branch
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J. B. Wnoerson, beniAr Inspection Specialist Date IE:HQS
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J.)R. Costello, Contractor Inspector Date l
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't-O. D. Chamcerlain, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch i
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Approved by:
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Reactor Systems Section Vendor Inspection Branch l
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2 Performance - Objective evidence shall be examined to assure compliance with QA program requirements.
Audit sample size shall be that which is necessary to assure effective QA program implementation. When nonconformances are identified, the audited organization shall determine the cause and effect of the nonconformance and the extent of corrective action required, and then initiate actions appropriate to prevent recurrance.
Contrary to the above, the S&L internal audit system is deficient in a number of areas, resulting in a reduction in its comprehensiveness and effectiveness.
This is evidenced by the number and significance of non-conformances being identified by others, such as NRC and licensee audits and inspections and repeated failure to take effective generic corrective and preventive actions regarding identified nonconformances.
Specific examples are identified in paragraphs E. and I. of the Details Section.
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3 DETAILS A.
Persons Contacted A. F. Aschoff, Associate, Mechanical Department M. A. Atia, Project Engineer E. B. Brauch, Head, Engineering Mechanics Division R. E. Cotta, Senior Electrical Engineer P. M. De Blake, Senior Quality Assurance Engineer A. A. Deguermendjian, Supervising Engineer K. M. S. Farag, Section Leader, Component Support Group R. X. French, Associate and Assistant Manager Electrical Department O. P. Gupta, Assistant Chief, Structural Design Engineering R. C. Heider, Project Manager H. H. Hitzeman, Senior Structural Engineer R. W. Hooks, Supervising Design Engineer
- 0. A. Hrynewych, Mechanical Engineer M. L. Jacobs, Engineering Assistant T. G. Longlais, Chief, Stm etural Design Engineer R. R. McCluer, Assistant Chief, Structural Design Engineering J. R. Meister, Mechanical Engineer W. B. Paschal, Project Supervisor D. C. Patel, Supervising Design Engineer J. A. Patel, Supervising Structural Engineer R. J. Pruski, Project Manager R. D. Raheja, Project Engineer T. J. Ryan, Assistant Chief, Struc.aral Design Engineering D. K. Schopfer, Mechanical Project Engineer V. K. Singla, Senior Structural Engineer B. Surawski, Electrical Project Engineer T. Tella, Quality Assurance Auditor B. G. Treece, Associate and Senior Electrical Project Engineer P. L. Wattelet, Project Manager B.
Follow Up on Previous Inspection Findings (Closed) Deviation (Report No. 80-02, Item A):
Contrary to commitment there are no procedure / measures which require obsoleting, recalling or identifying non-current drawing prints.
Procedure GQ 3.07 was revised on February 28, 1981, to require that all obsolete or superseded drawings and aperture cards be appropriately l
identified to reflect their current status, or be destroyet id replaced i
with the latest revision.
C.
Inspection Scope The inspection described in the following paragraphs was conducted in two parts: (1) inspection dates of March 17-20, 1981, with one inspector from RIV and one from RIII; and (2) inspection dates of April 6-10, 1981, with l
two inspectors from RIV.
The remainde.r of this report documents the scope and results of both these inspections.
4 The scope of this inspection included an evaluation of S&L's performance and responsibility concerning several site related problems identified by Region III personnel, and the effectiveness of S&L's generic corrective and preventive actions in response to their internal inspection and audit f!ndings and those of others, i.e. the NRC and the licensees.
More speci-fically, the scope or objective of this inspection was to:
1.
Evaluate S&L's performance and responsibility concerning the following site identified problems.
a.
Inadequate review and approval of "as built" drawings submittad by IPC (Clinton).
b.
Issuance of snubber and hanger designs before calculations were performed, in some cases, and before calculations were reviewed and approved in others (Clinton).
c.
Nonconformances relating to the installation of guard pipe penetrations for the reactor water cleanup systems (Clinton).
No criteria for assessing weight loads on cable trays when specifying cable loadings (Zimmer).
e.
Maximum heat loads in cable trays being exceeded, known by S&L as early as 1978, and this nonconformance not being docu-t mented for correction and follow up (Zimmer).
2.
Evaluate each element in Item 1., first on the identified project, then for its generic applicability to other projects and the effec-tiveness of S&L's corrective and preventive actions on the other projects, as applicable.
3.
Assess the effectiveness of S&L's corrective and preventive actions relative to previously identified NRC inspection findings.
The following sections document the results of this inspection relative to those items noted above.
D.
Review and Approval of "As Built Orawings" (Clinton).
Based on a review of the Project Scope of Work (SL3021 and SL356),
S&L issues documents that define standed parts that are to be used for local supports. The design of each support is identified and located, and a specific parts list is assembled.
Instructions for the assembly and orientation of each support are given, including such things as required length and size of attachment welds.
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5 Baldwin Associates, under an IPC contract, converted the above documents into a series of assembly drawings.
These assembly drawings illustrated the parts in proper position, the size, length and location of attachment welds, and other pertinent information.
Crafts people assembled and installed the supports with the guidance of the assembly drawings.
IPC identified that certain of the installed supports did not conform to the
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S&L requirements, and so notified RIII under 10 CFR 50.55(e).
As corrective action, IPC revised the original scope of work to require thmt S&L review all Baldwin assembly drawings for conformance to S&L requirements.
For those installed supports identified as discrepant and those considered I
suspect, S&L was requested to determine whether they met S&L's design criteria, l
even though they may not meet the prescribed details.
If the design criteria was not met, S&L was to recommend corrective action, either modification or l
replacement.
As preventive measures, IPC required that all future instal-l 1ations were to be made only after receipt of S&L's concurrence with the assembly drawings and their release for construction without comment, or with l
defined corrections.
S&L is also providing site liaison engineers to assist Baldwin personnel in understanding drawing and specification requirements, j
processing field engineering change requests, etc.
This particular division in S&L's scope of work appears unique to the Clinton project, therefore the generic aspects of this problem would not be applicable to other S&L projects.
This problem appears to have
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occurred on site before S&L became involved in this particular area of work.
No nonconformances were identified that related to S&L per-formance.
E.
Snubber and Hanger Design Calcelations As a part of an IE team inspection of the Clinton project site during l
February and March 1981, a Region III inspector selected nine installed piping suspension system components including snubbers, variable spring hangers, sway struts, rigid supports, and rigid hangers to be reviewed l
at the S&L office to determine whether sufficient design censideration and documentation had been in place prior to issuance of design drawings for l
hardware fabrication and installation.
The review was performed in the S&L's Chicago office, on February 18, 1981.
The documentation reviewed l
showed a lack of approved design calculations prior to design issue.
During discussons with the S&L responsible personnel and review of docu-mentation, it was determined that this lack of design calculation documenta-tion was first identified on the Zimmer project in October 1978, by an S&L internal audit (this internal audit by S&L was in response to an earlier finding onsite by NRC inspectors concerning nonconformances in hanger calculations).
This internal audit finding on the Zimmer project resulted in a cencern that there was possibly a lack of adequate procedures to control safety related design processes.
A corrective action report (CAR) was issued to the Zimmer project and a departmental survey was initiated to evaluate the adequacy of procedures.
Some of the results of the CAR and the department survey were as follows:
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6 1.
The mechanical department issued a new standard (MOS 15.2) on January 10, 1979, to provide instructions for component support design.
2.
Each project eventually issued project instructions (PI).for
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the control of hanger design work.
3.
General Quality Assurance Procedure GQ 3.08, Design Calculations, was revised (Revision 4) on March 5, 1979, to add Paragraph 3.0.C.1 stating that " Calculation shall be approved prior to the start of fabrication or start of construction of affected item (s)."
During this inspection, S&L's generic corrective and preventive actions were evaluated concerning this problem on the Zimmer, Clinton, Marble Hill, La Salle, and Byron-Braidwood projects.
S&L's principal system for obtaining such actions is their internal audit system.
Several problems with the S&L internal audit system and generic corrective actions were identified and resulted in the issuance of an item of nonconformance (see Notice of Nonconformance enclosure, item B).
The internal audit reports from early 1979 to present were examined for the Clinton, La Salle, and Byron-Braidwood projects.
The NRC inspector noted that the lack of design calculation documentation continued to be identified on other projects after the original finding on the Zimmer project in late 1978.
Specific examples of similar findings and of the apparent ineffectiveness of the S&L internal audit system and j
generic corrective action resulting from the audit report examination are as follows:
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Scheduling Supplemental Audits - Procedure Development or Revision 1.
Implementation of MOS 15.2 has never been audited on the Clinton, La Salle, or Byron-Braidwood projects.
2.
Implementation of Clinton Project Instruction PI-CP-016 Revision 0 for hanger design was never audited.
3.
Implementation of GQ 3.08 Revision 4 issued March 5, 1979, was audited as indicated below:
a.
Clinton Project - August 1979 - The audit report did not indicate that the requirement for approval of design calcu-lations prior to release for fabrication or construction was audited.
The first audit where specific reference was made to checking that design calculations were approved prior to release was in December 1980.
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Byron-Braidwood Project - October 1979.
c.
La Salle Project - May 1979 - This audit was timely for the design calculation procedure revision.
Audit Performance and Corrective Acticn 1.
Audits conducted on the Clinton project in August 1979, October 1980, and November 1980, did not identify any problems relating to approval l
of design calculations prior to design release; however, hanger designs were released during this time frame without approved design calculations.
An audit conducted by S&L in December 1980 and January 1981 identified three nonconformances relating to approval of design calculations.
One nonconformance was in the hanger design area and the report stated that a similar finding had been identified in a recent client audit.
2.
Audit conducted on the Byron-Braidwood project in June 1980 identified a nonconformance where an electrical conduit support calculation was not approved, even after the support was released for construction.
The corrc:tive action did not include a review of other projects.
3.
Audit canducted on the La Salle project in May 1979 identified a noncon-formance where a structural design caiculation was not approved prior to drawing release. The sample size examined was two calculations and one of the two was nonconforming.
The corrective action only corrected the one calculation and did not initiate a review of other calculations on that project nor was ccrrective action expanded to other projects.
4.
Audit conducted on the La Salle project in April 1980 identified that "None of the calculations for nonstandard or standard piping support components used on the La Salle Coaty Station have been approved.
No drawings have been revised or reissued to the field.
The engineer in charge of this area,..., has indicated that calculations will be approved and affected drawings revised and released to the field by December 1980." However, another audit conducted in November 1980 iden-tified two nonconformances where drawings were issued to the field without design calculations being approved.
The corrective action for the two nonconformances did not result in a generic review of other projects.
Biweekly meetings are held in the engineering departments.
These meetings have in the past been one means of disseminating information of generic interest, including QA matters.
These meetings appear to have been inef-fective in obtaining corrective action concerning the snubber and hanger calculations problem.
This is ' apparent since the problem was first identi-fied on one project in October - 278, and was not under control on all projects until January 1981.
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8 F.
-Guard Pipe Penetration Design On February 26-27, 1981, a RIII inspector observed the installation of the second set of the seismic guides in the RWCU steam tunnel pipe penetration assembly.
In accordance with the S&L Drawing No. M06-1000, Sheet 6, " Guard Pipe Details," Revision H, dated May 21, 1981, the gap between all 'four seismic guides should be 0.010".
In actual measurement, it was found that all four guides were bound tight against the process pipe wall.
As a result,
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the contractor issued a Nonconformance Report (NCR) No. 4151 on March 2,1981, to document the pioblem including a detail mapping of the gap measurements on all four seismic guide shoes.
In addition, the licensee agreed that no further work on the steam tunnel penetration assemblies will be permitted prior to S&L's resolution and evaluation of this nonconformance, together with other possible nonconformances that might exist.
The inspector discussed this design issue with the S&L Project Manager, and the Head of Engineering Mechanics Division, and was told that S&L was in the process of evaluating the nonconforming conditions and will not be ready to discuss any generic or specific issues until early April 1981.
Although there was an apparent lack of contractor installation and QC inspection program procedures to assure that design gap requirements were met, the root cause of the problem may be that the S&L design engineer was insensitive to the installation difficulties.
This area will be a follow up item for further consideration during a subsequent inspection.
G.
Cable Tray Weight Load Criteria This item, as well as the one following (paragraph H.), was identified onsite.
Based on information that was available on the site, it appeared that weight loads on cable trays were not being considered consistent with SAR commitments.
As a result of this inspection, S&L's design approach to cable tray loadings (weight and heat) was clarified, and this item was resolved based on commitments by S&L, including a revision to the applicable Project Instruction.
Further details relating to this item are discussed in the following paragraphs.
H.
Cable Tray Design Criteria S&L has developed a system for continually monitoring the cable tray heat and weight loadings to be used for the duration of cable placement.
A simplified description of the system is as follows.
A " design index" number is established by taking the sum of the cross-sectional areas of all cables in a tray (for conservation, the diameter of a given cable is used to calculate the area of a square which is used as the cable cross-sectional area) divided by the cross-sactional area of the cable tray filled to the design level. -
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9 Periodically, and as work progresses, the " design index" for each cable tray is computed. When the " design index" for a tray exceeds 1.25, S&L must consider specifically the cables in the tray to assure that weight and heat load criteria are not violated before final approval of that tray loading. While cable placement activities are ongoing S&L performs sampling calculations of those trays with the larger " design index" numbers as a means of monitoring their compliance with tray loading criteria.
It was these interim calculations, that was the source of Region III's concern that S&L's calculations were not being formally reviewed and approved and all calcula-tions were not being performed.
l S&L uses this same design approach for cable trays on their other projects.
No nonconformances were identified during this inspection concerning S&L's design, approach and calculational methods relative to cable tray loadings.
S&L reaffirmed their commitment to perform formalized calculations, as required by their Project Instruction, before final approval of the cable tray loadings.
Region III identified several items that require correction / clarification during their site inspection which will be documented in the Region III report.
S&L has completed action on some of these. One nonconformance l
was identified concerning the tracking by S&L of an item not conforming l
to design.
(See Notice of Nonconformance enclosure, Item A).
This item, as well as the following, will be identified in the Region III inspection report of Zimmer site activities.
1.
A reference in the FSAR, Section 8.3.3.1, for cable ampacity in trays does not reflect that actually used for design.
2.
Procedures were not in place requiring (1) final weight calculations I
for cable trays exceeding a design index of 1.25; and (2) thermal l
calculations for power sleeves.
Our future inspections will assure that S&L has taken appropriate action on the specific project and generically. Accordingly, this will be i
considered a follow up item.
I.
Effectivness of Corrective and Preventive Actions Based on the concerns expressed by Region III relative to S&L, (paragraph G.
l above), there was an apparent lack of effective follow up by S&L on other projects of the inspection findings identified by the licensees or Region III on a specific project.
S&L's performance and responsibility relative to these project specific concerns was evaluated during this inspection and the results are documented in the preceeding paragraphs.
In addition to the Region III concerns, this inspection included S&L's generic consideration of inspection findings made during previous Region IV inspections.
In the Region IV inspection 99900507/80-01 conducted March 24-28, 1980, a deviation (nonconformance) was issued concerning the Byron /Braidwood project for not meeting the following requirements.
10 Sargent & Lundy General Quality Assurance Procedure GQ-3.07, Revision 4 (8/21/78) states in part: "If the Pre P ct Leader... determines that no interface exists the drawing shall u forwarded directly to the Reviewer.
The decision that no interface condition exists shall be documented...
The Project Leader shall maintain a log containing information as to whom i
and when the drawing was sent for coments and when the coments were
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received.
All coments and coment resolution documents shall be maintained in file for at least one year or until the next drawing revision has been issued."
In Sargent & Lundys' response to this finding they agreed to correct the items identified by the NRC inspector and to conduce an audit to further investigate this area. An audit covering the same type requirements was conducted on the Byron /Braidwood project and a report was issued on July 28, 1980.
As a result of this audit 7 corrective action reports (CAR's) were issued covering the same type of nonconformance.
The audit that was con-ducted was on one project only, therefo e did not consider the generic aspects on other projects.
During October and November of 1980, a similar type audit was conducted on the Clinton project and a report was issued on December 19, 1980.
This report contained 5 corrective action reports covering the same type of nonconformance identified by the NRC inspector in the 99900507/80-01 report dated April 17, 1980.
Had a generic audit been conducted at the time of the Byron /Braidwood audit, this would have been corrated sooner.
Further review by the inspector disclosed that S&L had conducted a similar type audit on the La Salle project on January 21-28, 1980, and a report was issued on February 20, 1980.
This report contained 6 corrective action reports cc.vering the same type of nonconformance identified by the NRC inspector in the 99900507/80-01 report.
Had a generic audit been conducted at that time covering this type of nonconformance, the NRC inspector would not have written the nonconformance in the 99900507/80-01 report.
In sumary, this nonconformance to the requirements of S&L procedure GQ-3.07 was originally identified by S&L on the La Salle project on January 21-28, 19E0; was identified again by the NRC inspector on March 24-28, 1980, on the Byron /Braidwood project; was confirmed by S&L on the Bryon/Braidwood project on June 23 - July 3, 1980; and was identified again by S&L on the Clinton project on October 14-18, and November 17-25, 1980.
Had timely and effective corrective actions and preventive measures been taken on a generic basis when this nonconformance was first identified, the whole problem would have been corrected early in 1980 rather than some 10 months later.
This is another example of the Item B in the Notice of Nonconformance enclosure.
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11 J.
Exit Interview Meetings were held with management representatives on March 20, 1981, and April 10, 1981.
Those in attendance at these meetings were:
Sargent & Lundy
- E. V. Abraham, Project Director L. E. Ackmann, Director of Services W. A. Chittenden, Director of Engineering R. X. French, Assistant Manager, Electrical Department A. P. Gillis, Administrative Assistant, QA Department W. G. Hegener, Manager, Mechanical Department
- R. C. Heider, Project Manager
- G. C. Kuhlman, Project Director
- J. C. LaVallee, Project Manager
- R. J. Mazza, Project Director P. C. McClintock, Manager, Electrical Department J. E. McFarland, Head, QA Division J. M. McLaughlin, Manager, Structural Department R. W. Patterson, Senior Partner
- R. J. Pruski, Project Manager R. F. Schaibel, Project Director H. M. Sroka, Project Director
- H. S. Taylor, Assistant Head, QA Division Cincinnati Gai & Electric Company
- R. P. Ehas, Senior QA Engineer
- 0. J. Frederick, Engineer
- R. J. Reiman, Senior Engineer NRC
- P.
A. Barrett, Reactor Inspector, RIII
- 0. D. Chamberlain, Contractor Inspector, RIV
- J. C. Costello, Contractor Inspector, RIV C. J. Hale, Section Chief, RIV
- R. F. Warnick, Section Chief, RIII
- I. T. Yin, Reactor Inspector, RIII
- Denotes March 20 meeting only.
- Denotes April 10 meeting only.
During the March 20 meeting the scope and preliainary findings were presented, and those present werc advised that the inspection would be continued the week of April 6,1981.
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2 12 The scope was restated during the April 10 meeting and the completed inspection findings were presented.
Management comments were generally for clarification only.
The content and expected management actions in response to all NRC inspection I
findings were reviewed with those present during the April 10 meeting.
These actions include:
1.
Correcting the specific nonconforming or deficient item or items identified; 2.
Identification and correction of similar nonconforming or deficient items in the same area or activity, as well as generically, i.e. in other areas, disciplines, departments, or projects that may be subject to the same problem; 3.
Based on the results of 1 and 2 above, initiate effective measures that will prevent recurrance of the identified nonconformanca or deficiency; and 4.
The date or dates when each of the above items will be completed.
Management representatives present acknowledged their understanding of these statements.
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