ML20010A371
| ML20010A371 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1981 |
| From: | Chamberlain D, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010A367 | List: |
| References | |
| REF-QA-99900509 NUDOCS 8108110366 | |
| Download: ML20010A371 (14) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900509/81-02 Company:
Stone & Webster Engineering Corp.
Post Office Box 2325 Boston, Massachusetts, 02107 Inspection at: Cherry Hill Operations Center Inspection Conducted:
May 4-7, 1981 Inspectors:
h h _ h,Jr/fL 4/f/r/
J A,. Costello, Contractor Inspector Date R aStor SystemsSection V Kdor Inspection Branch hA G<oA /dn th/r, 7.)D.Chamberlaid,ContractorInspector Date Meactor Systems Section Vendor Inspection Branch f
b
/
Approved by:
Date C. ( Ohle, Chief Reactor Systems Section Vendor Inspection Branch Summary Inspection May 4-7, 1981 (99900509/81-02)
Areas Inspected:
Implementation of 10 CFR Part 50, Appendix 8 and Topical Report SWSQAP 1-74A in the areas of design verification, design change control, design corrective action and follow up on regional requests.
The inspection involved 56 inspector hours on site by two NRC inspectors.
Results:
In the four areas inspected no deviations or unresolved items were identified.
8108110366 810617 PDR GA999 EECSWE 99900509 PDR
2 DetailsSection I (Prepared by J. R. Costello)
A.
Persons Contacted J. A. Burgess, Project Quality Assurance Supervisor
- D. M. Campagna, Project Engineering Assurance Engineer P. J. Chomentowski, Assistant to the Project Engineer
- A. D. Coleman, Assistant to the Project Manager
- M. E. Gilman, Quality Assurance Department Representative L. 8. Hirst, Assistant Project Engineer
- J. M. Lord, Manager-Engineering Assurance P. J. McQuaid, Principal, Structural Mechanics 4
- H. G. Pace, Project Quality Assurance Manager R. H. Pinney, Lead Licensing Engineer J. T. Plant, Quality Assurance Engineer
- R. B. Weaver, Supervisor Engineering Assurance Administrative Services
- Indicates those present at exit meeting.
B.
Follow Up On Regional Requests In this area of inspection two regional requests relating to deficiencies or potential deficiencies were reviewed and evaluated by the inspector.
The regional requests included the following:
(1) undetected rejectable indications in flued head welds, (2) biological shield wall welding defects, and (3) inadequate NDE of containment liner welds.
The deficiencies or potential deficiencies covered in these two regional requests had been inspected and reported in Inspection Reports 99900509/79-04, 99900509/80-02 and 99900509/80-05; however, the subject matter of these two regional requests had not been closed out.
1.
Objectives a.
Determine present status of problem.
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l b.
Determine if procurement and procurement quality control processes were adequate.
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c.
Evaluate the generic implications of this problem.
2.
Method of Accomplishment The preceding objectives were accomplished by a review of the following documents:
a.
NMP2-P2838, Specification for Shop Fabrication and Field Erection of Primary Containment Steel Plate Liner and Drywell
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Floor Liners.
b.
NMP2-S204G, Specification for Biological Shield Wall.
c.
Letter from Niagara Mohawk to Region I, USNRC dated 6/28/79, concerning welding of flued head forging and penetration sleeve.
This letter provided rationale for using UT or MT in place of RT for NDE of welds.
d.
Final Report from Niagara Mohawk Power Corporation, dated 9/6/79, i
" Report of Investigation into Significant Deficiency Concerning Inadequate Nondestructive i~<aminations Performed on the Nine Mile Point Unit 2 Containment Liner Welds."
e.
Interim Report from Niagara Mohawk Power Corporation, dated 4/15/80, " Biological Shield Wall Interim Report."
f.
Final Report from Niagara Mohawk Power Corporation dated 8/1/81,
" Biological Shield Wall."
g.
Problem Report PR-QA-1, Revision 1, Vendor and Subvendor Ultrasonic i
Test Techniques and Performance for Liner Examination," dated 12/31/80.
h.
Quality Assurance Inspection Plan No. 020N091A00001, Shop Fabricated / Field Erection of Containment Liner.
i.
Quality Control Instruction, QCI No. HQ4-57.10-050, PQA Inspection 1
of Sellers Nondestructive Test Examinations NMP2 only, dated q
8/22/80.
j.
Procedure 59-UT-079 (UT-4A), Ultrasonic Examination of Pipe and
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Safe 191 Welos.
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Engineering and Design Change Request E&DCR No. F10063 which covered instructions to Graver for performing UT on welds.
1.
Regulatory Guide 1.19, August 11, 1972, Nondestructive Examina-tion of Primary Containment Liner Welds.
m.
Paragraphs NB-5260, Structural Attachment Welds,~and NB-5330, Ultrasonic Acceptance Standards from Section III, Division I, ASME Code 1971 thru Summer 1973.
n.
Quality Assurance Audit Report, Graver Tank and Manufacturing Company, NMP2 Site and East Chicago, Indiana, dated 10/20/78.
3.
Findings a.
Of the t N ee deficiencies or potential deficiencies described in the two regional requests for follow up action, S&Ws final analyses of their safety implications were as follows:
(1) Undetected rejectable indications in flued head welds.
This condition could have been a safety haz.ird if left undetected.
(2) Biological shield wall welding defects.
The condition of the biological shield wall welds could not have adversely affected the safety of operations of the plant had it remained-undiscovered.
(3) Inadequate NDE of containment liner welds.
This condition could have been a safety hazard if left undetected.
b.
Of the three deficiencies or potential deficiencies listed abc e, two were identified by S&W personnel and one (Undetected rejectable' indications in flued head welds) was identified during an NRC inspection at NMP2 on March 20-23, 1979, when the use of UT versus RT was questioned.
UT was originally specified because Regulatory Guide 1.19, Revision 1, dated August 11, 1972, required all welds in pene-trations, airlocks and access openings that are not backed by concrete, such as welds between penetrations and flued fittings, and flued fittings and pipelines, to be fully examined in accordance with the examination methods of Article NE of Section III of the ASME Code.
Sub paragraph NE 3231.1 of the 4
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5 Winter 1972 Addendum identifies this joint. configuration as a special exception where ultrasonic examination may be performed in lieu of radiography.
Due to anticipated difficulty in using RT instead of UT because of flued head forging geometry, UT was specified for this joint configuration.
When the welds were reexamined using RT~some welds found to be acceptable using UT were found to be unacceptable.
As a result of this, IE Bulletin 80-08 was issued so all flued head designs would be checked, and S&W reradiographed and repaired all NMP2 flued head welds.
c.
In reviewing the cause of the above deficiencies or potential deficiencies, S&W noted there was a definite breakdown in the welding and NDE programs of Graver and Conam, and these suppliers were replaced.
d.
In the contracts for the Biological Shield Walls and the Containment Liner (includes flued head) one item stands out, nd that is the breakdown of NDE namely UT.
This involved the use of inadequate ultrasonic testing methods, and impro-perly implemented ultrasonic testing techniques.
Thus many weld defects were not identified,and therefore not repaired until they were identified by S&W.
e.
Action has been taken by S&W to reexamine all welds (some on a samp!ing basis and some 100%) on the Biological Shield Wall and the Containment Liner. The reexamination was done utilizing adequate ultrasonic testing met bds and techniques with the exception of the flued head welds whict used RT.
All welds not meeting specification were repaired.
This work is essentially completed now.
f.
A review of the procurement and procurement quality control for NMP2 in the time frav.e in which the above weld deficiencies were reportea showed a need for improvement.
However, the majority of the weld defects were identified by the S&W NMP2 QA program with the exception of the flued head welds.
g.
As a result of welding and NDE defects identified at vendor shops in early and mid 1978, S&W initiated, in late 1978 a Quality Enhancement Program, structured to reduce the possi-bility of similar occurrences in the future.
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6 The Quality Enhancement Program is a continuing S&W effort, still being refined.
Some of the significant modifications put into effect since August 1978 are as follows:
(1) S&W PQA inspector training, qualification, and certi-fication in NDE disciplines were intensified.
This was implemented in August 1978.
(2) S&W PQA implemented a formal PQA inspection planning activity in April 1979.
(3) S&W inspection reporting system, which allows centralized data analysis and input, has been modified to provide a variety of inspection report forms.
These forms are geared to specific inspection actions such as hardware inspection, process surveillance, and systems surveillance.
This was implemanted in February 1980.
(4) The S&W procedurai system has been restructured to provide flexibility in accomodating ur.ique project requirements.
Thit was implemented in June 1980.
h.
Regarding the problem encountered with the Biological Shield Wall and the Containment Liner welds, the Quality Enhancement Program provides the following features designed to eliminate any future recurrences of this type of weld defect:
(1) For future and selected existing Category I orders where ultrasonic testing (UT) is utilized, the specification will establish hold points at which, prior to performance of any UT, the S&W PQA inspector, aided by Nondestructive Testing (NDT) Division engineers, will evaluate the effectiveness of the seller's UT techniques, operators, and g0neral implementation of the test parameters.
All UT procedure qualifications (techniques) will be approved by the S&W Nondestructive Testing (NDT) Division engineers at the preestablished hold point, as required by specification for each different configuration.
(2) For future and selected existing Category I specifications, S&W QA will establish notification points for application of all NDE methods other than UT.
The NDT Division Engineer will verify NDE applications on a random basis after coordinating the activity with the S&W PQA inspector.
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7 (3) Require sellers to notify S&W Project Management of any changes in their quality assurance management.
i.
In the reexamination and rework of the Biological Shield Wall and the Containment Liner (includes flued head), S&W considered the generic aspects as it affects S&W.
This is described in the Final Reports from Niagara Mohawk Power Corporation on the Cor.tainment Liner and Biological Shield Wall referenced in B.2.d. and f. above.
The problem was a breakdown in UT at the supplier and subsupplier level and would probably be different for each AE and NSSS depending on the controls exercised on NDE at the supplier and subsupplier level.
j.
No nonconformances or unresolved items were identified in this area of the inspection.
C.
Design Corrective Action 1.
Objectives The objectives of this area of the inspection were to examine and verify that:
a.
Procedures have been established and implemented for identify-ing deficiencies in the design process of a significant or recurring nature, determining the cause of the deficiencies, and initiating corrective action to prevent iecurrence.
b.
Deficiencies in the design process and the corrective action are rg arted to appropriate levels of management.
c.
Follow up action is taken to assure timely completion of corrective action of a deficiency in the design process when resolution is not completed immediately.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Section's 1, 3, and 16 of SWSQAP 1-74A, Standard Nuclear Quality Assurance Program Manual.
b.
Engineering Assurance Procedures EAP 2.12 (Control of Licensing Commitments), EAP 4.13 (Processing of Project Specifications),
EAP 5.4 (Review and Approval of Project Production Drawings),
EAP 6.3 (Preparation, Review, Approval, and Control Of E A -
Engineering and Design Coordination Reports), EAP 15.2 (f,#
'g of Nonconformance and Disposition Reports - N&Ds - By Enginet.
ing), and EAP 16.1 (Problem Report System).
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c.
Quality Standards QS 6.1 (Document and Document Change Control),
QS 14.2 (Inspection Report System), QS 15.1 (Nonconformance and Disposition Report), and QS 16.1 (S&W Problem Report System).
d.
Quality Assurance Directives QAD 6.8 (PQA Use of Engineering and Design Reports), QAD 14.1 (Inspection _ Report System),
QAD 15.1 (PQA N&D Report Preparation and Processing), and QAD 15.2 (Field Nonconformance and Disposition Report Status Reporting and Data Analysis).
9.
Nine Mile Point - Unit 2 Project Procedures, SWPP2 (Processing of Problem Reports) SWPP16 (Engineering and Design Coordination Reports - E&DCR), and SWPP24 (Handling of Nonconformance and Disposition Reports - N&D).
f.
Documents to verify implementation of quality assurance program commitments, procedural requirements,.and to satisfy the intent of the objectives section.
These doucments are as fol'.,ws:
(1) Nonconformance and Disposition (N&D) Report Log, Nine l
Mile Point 2 Project.
(2) Ten N&D Reports numbered 1020, 1359, 1718, 1761, 1861, 1858, 1966, 1977, 2010 and 2063.
(3) Four Problem Reports numbered S-12,.CS-25, P-114 and P-107.
L (4) E&DCR and N&D Drawing Change Record, NMP2 (Piping, Concrete, and Electrical groups).
(5) E&DCR and N&D Specification Change Record, NMP2.
(6) L:g of PSAR changes generated as a result of E&DC'ts.
(7) Monthly Project Reports (NMP2) for January and February 1
1981.
(8) Management Actior 'eports (NMP2), January, February, and March 1981.
(9) Six Initial Problem Reports (IPRs) numbered 50b24, 50634, i
50681, 50672. 50698 and 50696.
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9 (10) Five E&DCRs requiring PSAR/FSAR acti3n numbered P00259, C0030, P00199, P11187, and P40340.
(11) Eight In:pection Reports numbered X1000465, S1013468, l
S1012054, W1008685, M100032, $100u287, N2P30300015, and l
N2P301U001.
(12) Inspection System Handbook.
(13) Three drawings and revisions thereto numbered 12177-EB-50A-6, 12177-EC-15K-3, and 12177-EC-38F-4.
(14) Three specifications and changes thereto numbered NMP2-P3030, Addendum 5, NMP2-M070A, Revision 8, and NMP2-P413H, Addendum 4.
3.
Findings a.
Nonconforniance and Unresolved Items In this area of inspection, no nonconformances or unresolved items were identified.
i b.
Follow Up Items Two follow up items were identified in this area of inspection which would have been listed as nonconformances if S&W had not already identified them and were taking action to correct j
them.
These follow up items are as follows:
(1) Some problem reports are being closed out before all the necessary actions are completed.
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(a) Problem Report E-20 (GE Magne-Blast Circuit Breakers Type AM-4.16-250-9, 1200 and 2000 Amp Frame with ML-13 Mechanisms) was closed after receiving a reply from GE covering their corrective and preven-tive actions.
Yet, the problem report had also recommended an upgraded S&W PQA inspection plan for this equipment which had not yet been instituted.
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l 10 (b) Problem Report CS-25 (Engineered Safety Features -
ESF - Reset Controls, NRC IE Bulletin 80-06) was closed on the basis that copies of this report were issued to the Systems Group and a lecture was to be given to the Systems Engineers during the first quarter of 1981.
However, another part of the p oblem was a redeste to be completed by December 1, 1981, which would prevent the isolation valves on the Containment Atomsphere Moni aring System sensing lines from reopening and the sampling pemps restarting upon a reset of the LOCA signal.
(2) NMP2 Project Procedure SWPP24 rcquires that procurement specifications shall be amended and reissued within 4 months of N&D and/or E&DCR change No. 5.
The 5th E&DCR for procurement specification M070A was issued on October 10, 1980, which meant that specification M070A should have been revised on February 10, 1981, but it was not.
The present method of tracking N&D and E&DCR changes needs some refinement to prevent this recurrence and S&W is now working on a better system.
D.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on May 7, 1981.
In addition to the individuals indicated by an asterisk in the Details Sections those in attendance were:
W. H. Chamberlain, Assistant Engineering Manager M. L. Fasnacht, Structural Engineering Supervisor R. Howley, Lead Power Engineer J. A. Kirkebo, Project Engineer H. Raese, Pioject Manager, NMP2 B. G. Schultz, Project Manager L. S. S. Smith, Deputy Director, Construction J. C. ThoF9 son, Quality Assurance Supervisor R. A. Zanetti, Vice President and Assistant Manager Cherry Hill Operations Center The inspector summarized the scope and findings of the inspection for those rrezent at the meeting. Management representatives acknowledged the statements of the inspector.
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DetailsSection II (Prepared by D. D. Chamberlain)
A.
Persons Contacted i
- E. B. Burg, Assistant Engineering Assurance Engineer j
- D. M. Campagna, Engineering Assurance Engineer
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- W. R. Curtis, Lead Engineering Assurance Engineer i
- J. W. Kelly, QA Program Administrator i
- R. J. McMorland, Engineering Assurance Engineer i
W. Whittemore, Structural Design Coordinator l
- Indicates those present at exit meeting.
B.
Design Change Control i
1.
Oojectives l
The objectives of this area of the inspection were to verify that:
a.
Procedures have been established and implemented for controlling changes to approved design documents.
i b.
Design changes are:
(1) reviewed for the impact of the change; (2) documented as to the action taken; and (3) transmitted to all affected persons and organizations.
c.
The design changes are justified and subjected to review and approval by the same groups or orgcnizations as for the original design.
d.
When responsibility has been changed, the designated organiza-i tion shall have access to the pertinent information,- com-j j-petence in the specific area of design, and an understanding of the requirements and intent of the original design.
1 2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
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12 a.
SWSQAP 1-74A, Standard Nuclear Quality Assurance Program Manual, Sections 1, 2, 3 and 5.
b.
Engineering Assurance Prcredures:
EAP 4.13 (Processing of Project Specifications), EAP 5.4 (Review and Approval of Project Production Drawings), EAP 5.10 (Preparation Review, and Approval of Logic Diagrams and Logic Descriptions), EAP 5.13 (Preparation, Review, and Approval of One Line Diagrams), EAP 5.16 (Preparation, Review, and Approval of Flow Ciagrams), and EAP 6.3 (Preparation, Review, Approval, and Control of E&DCR's).
c.
River Bend Project Procedures:
RBP 12.0-10 (Engineering & Design Coordination Report (E&DCR) Procedure), and RBP 18.3-0 (Interface Between the Site Engineering Group and Project Headquarters).
d.
Design change documents for River Bend Project:
(1) 16 Engineering and Design Coordination Reports.
(2) Three revised specifications.
(3) Three revised flow diagrams.
(4) Three revised logic diagrams.
(5) Three revised one line diagrams.
e.
E&DCR and N&D Specification Change Record (River Bend Project) 3.
Findings In this area of the inspection, no nonconformances or unresolved items were identified.
C.
Design Verification 1.
Objectives The abjectives of this area of the inspection were to determine that procedures have been established and are being implemented that:
a.
Identify individuals or groups who are authorized to perform design verification reviews.
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i b.
Require the results of the design verification effort to be clearly documented, with the identification of the verifier clearly indicated, and filed so they are identifiable to the doucment reviewed and can readily be retrieved.
c.
Require that the extent of design verification take into consideration the importance to safety, complexity,_ degree of standardization, state of the art, similarity with previously proven designs, applicability of standardized or previously proven designs, known problems and their effects, and changes to previously verified designs.
d.
Identify and document the method by which design verification is to be performed.
e.
Identify the items to be considered during design verification by the design review method.
f.
Prescribe the requirements for performing design verification by the alternate calculations method.
g.
Prescribe the requirements for performing design verification by the qualification testing method.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
SWSQAP 1-74A, Standard Nuclear Quality Assurance Program Manual, Sections 3 and 5.
b.
Engineering Assurance Procedures:
EAP 3.1 (Verification of Nuclear Power Plant Designs), EAP 5.3 (Preparation and Control of Manual and Computerized Calculations), EAP 5.19 (Preparation, Review, and Control of Structural Design Criteria), EAP_5.21, (Preparation, Review and Control of,QA Category I Electrical Design Criteria),
c.
River Bend Project Procedure, RBP 6.4-2 (Procedure for Prepara-tion and Processing of Calculations).
d.
Ten design calculations for River Bend Project (three structural, four electrical and three power).
e.
Two Structural Department design calculations for Nine Mile Point Project.
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Three design criteria for River Bend Project (two electrical and one structural).
g.
Engineering Assurance Audit Observation, A0 No. 12210-117.
3.
Findings a.
Nonconformances and Unresolved Items In this area of the inspection, no nonconformances or unresolved items were identified.
b.
Follow Up Item During the examination of structural design calculations for the River Bend Project, certain problem areas were identified by the NRC inspector. The areas noted were as follows:
(1) Revision was made without the reason for the revision being stated.
(2) Revision was not clearly identified in some cases.
(3) Revision was made without clear evidence that independent review of the revision had been performed.
When the problems were brought to the attention of Stone and Webster Engineering Assurance Personnel, they informed the NRC inspector that similar observations had been documented by an internal Engineering Assurance Audit Observation. The NRC inspector examined the Engineering Assurance Audit Observa-tion documentation and determined that corrective and preven-tive action had been initiated in the structural calculation area.
One portion of the corrective action initiated was a commitment that "All calculations will be reviewed to ensure that no truely unchecked revisions exist.
If any are found they will be properly reviewed and this review documented in the -calc. per EAP 5.3."
This corrective action is to be completed ~by December 1, 1981.
The NRC inspector will cenduct a follow up inspection in this area to determine the effectiveness of the corrective and preventive action taken by Stone and Webster.
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