ML20010J209
| ML20010J209 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/1981 |
| From: | Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010J175 | List: |
| References | |
| REF-QA-99900502 NUDOCS 8109290707 | |
| Download: ML20010J209 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND W ORCEMENT REGION IV Report No. 99900502/61-02 Company:
Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3 Houston, Texas 77001 Inspection Conducted:
April 13-17, 1981 U
Inspector:
D. F. Fox, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch Approved by:
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C. JC Hale, Chief Date React 3'r Systems Section Vendor Inspection Branch Summary Inspection on April 13-17, 1981 (99900502/81-02)
Areas Inspected:
Implementation of Title 10 CFR Part 50, Appendix B, and Topical Report B&R-002A, including follow up on previous inspection findings, design l
process management, and technical personnel background verification. The inspec-l tion involved 46 inspector-hours on site by one NRC inspector.
Results:
In the three areas inspected, one violation and five nonconformances were identified.
No unresolved or follow up items were identified.
Violation:
Follow up on Previous Inspec. ion Findings:
Failure to submit a written report of a significiant defect in piping supports within the time required by 10 CFR Part 21.
(See Notice of Violation) l Nonconformances:
Follow up on Previous Inspection Findings:
Failure to adhere to the requirements in the Brown and Root 10 CFR Part 21 implementing procedure (See Notice of Nonconformance, Item A).
Design Process Management:
Failure to submit to NRC changes in the QA program and organization described in the Brown and Root Topical Report (See Notice of Nonconformance, Item B); Failure to include Beta radiation resistance requirements in the specification for personnel and auxiliary air lock inflatable seal material (See Notice of 4
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Nonconformance, Item C); Failure to maintain required training records (See Notice of Nonconformance, Item D).
Technical Personnel Background Verifica-i tion:
Failure to follow procedure for authenticating copies of educational l-diplomas or transcripts of new employees (See Notice of Nonconformance, Item E).
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3 DETAILS A.
Persons Contacted
- R. J. Vurpillat, Manager, Quality Assurance
- H. T. Faulkner, Project Coordinator H. L. Bell, Project Staff Manager G. C. Priddy, Manager, Personnel
- P. A. Padden, Manager, Engineering Documentation R. W. Peverley, Assistant Engineering Progject Manager
- J. R. Childers, Houston Quality Assurance Coordinator
- B. F. Mitchell, Manager, Design Quality Engineering
- P. S. Jordan, Manager, Nuclear Licensing Staff
- K. R. Cook, Project Deputy General Manager
- S. J. Kelly, Training Coordinator M. Weintraub, Subcontracts General Manager
- J. A. Signorrelli, Manager, Technical Staff J. F. Halsey, Manager, Special Problems Group
- A. H. Geisler, Manager, Nuclear Licensing
- Denotes those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
(0 pen) Follow up Item (Report 80-02,Section II.C.3.e).
The status of the Brown and Root Vendor Control Evaluation and Correction Program will be evaluated.
The program consists of seven phases which implement the Brown and Root management commitment to NRC to define (and subsequently execute) a program that provides for a complete and thorough review and audit of the procurement documents, vendor control and surveillance activities, and release of safety related equipment and material to the site that is in full compliance with all Brown and Root commitments to NP.C.
The phases, approximate status, and initiation and completion dates provided to, or determined by, the inspector are as follows:
a.
Establish Priorities and Schedule - June 15, 1980, through January 31, 1981; 100% Completed as of March 15, 1981.
One hundred and sixty procurement actions were identified, prioritized and scheduled for review.
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4 b.
Generate "P0 Baseline Requirements" - November 3, 1980, through July 17, 1981; 8% Complete versus 56% projected.
c.
Independent NUS Audit - September 1,1980, through September 8, 1981; 2% Complete versus 62% projected.
d.
Resolution of Audit Findings - February 15, 1981, through October 9, 1981; 0% Complete versus 25% projected.
i e.
Update Purchase Orders - March 1, 1981, through November 6, 1981; 0% Complete versus 17% projected.
f.
Correct Vendor Deficiencies - March 15, 1981, through December 4, 1981; 0% Complete versus 11% projected.
g.
Release of Equipment and Materials - February 15, 1981, through December 4, 1981; 0% Complete versus 20% projected.
Procurement of safety related equipment and materials will continue to be ciasely monitored by NRC during future inspections.
2.
(Closed) Deviation (Report 80-03, deviation D).
Superseded QA procedures were not destroyed nor stamped void.
The inspector verified the corrective action and preventive measures described in Brown and Root letters dated December 16, 1980, January 20, 1981, and March 18, 1981.
Specifically:
a.
Quality assurance reviewed the QA Manual for procedures with non-unique identification and for reference to voided or superseded documents.
b.
A list of non-unique QA procedures and inappropriately referenced i
documents in QA procedures was generated and distributed to j
holders of QA Manuals.
c.
A draf+ revision of the QA Manual was issued for internal review and comment.
d.
The revised QA Manual is committed for issue prior to the ASME nesurvey which is currently scheduled for August 1981.
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3.
(Closed) Unresolved Item (Report 80-03,Section I.D.3.b.(2).
An apparent violation exists in that Brown and Root was not adhering to their procedure for implementing 10 CFR Part 21 requirements.
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This item was elevated to a violation as well as a nonconformance.
See Notice of Violation enclosure and Notice of Nonconformance enclosure, Item A.
4.
(Closed) Follow up Item (Report 80-03,Section I.B.4).
Verify imple-mentation of a management plan to assure that commitments to NRC will be performed as stated and be effectively implemented.
The inspector verified that Brown and Root developed a system and a form (NRC Action Item Commitment List) which was implemented for inspection 81-01 findings.
The system and form require the following:
a.
Each NRC identified deviation, unresolved item, or other out-standing item be listed (as well as the individual responsible for action thereon) and distributed accordingly.
b.
An internal commitment date be established that is earlier (generally two weeks) than the date committed to NRC.
c.
Quality Assurance is responsible for following the implementation and completion of corrective actions.
d.
Prior to the commitment date to NRC, Quality Assurance is to independently verify, by review of objective evidence, that the corrective actions have been completed.
The Senior Vice President is to be notified for each specific failure to complete corrective action by the internal commitment date.
e.
The status of open B&R commitments to NRC be routinely reported t
at the STP - Quality Assurance Management Review Board meetings.
The effectiveness of the system will be followed during future inspections.
5.
(Closed) Nonconformance (Report 81-01, Item A).
Corrective action committed in a Brown and Root response to a previous finding had not been completed as scheduled.
The inspector verified the corrective action and preventive measures described in Brown and Root letter of response dated February 16, l
1981.
Specifically:
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a.
Brown and Root developed and implemented a system to identify and assure completion of commitments made to the NRC.
See related Item B.4 above for details.
b.
An "NRC Action Item Commitment List" was transmitted to appro-priate management personnel for action / followup on-January 15, 1981.
c.
A management meeting was held and documented on January 13, 1981, at which the importance of meeting commitments to NRC was stressed to all South Texas Project management by Brown and Root executive management.
j Brown and Root completed the corrective ection during inspection 81-01.
6.
(Closed) Nonconformance (Report 81-01, Item B).
Unapproved Technical Reference Documents were contained in the South Texas Project Design
- Manual, i
l-The inspector _ verified the corrective. action and preventive measures 1
described in Brown and Root letters dated February 16, 1981, and j-March 18, 1981.- Specifically:
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a.
All STP Design Manuals were reviewed and brought into conformance L
with the procedural requirements for.the content and control l
thereof.
b.
Procedure STP-DC-007 was cancelled in its entirety on April 17, 1981, and was replaced by three new procedures, issued on the same day.
STP-SD-001-B (STP Design Manual), STP-SD-002-B (System Design Description), and STP-SD-003-B (Technical Reference Documents) collectively contain the germane j
requirements of STP-DC-007 and all committed changes thereto.
k c.
Nine additional STP procedures have'been revised to date.
d.
Training on the new and revised procedures was completed or-committed.
7.
(Closed) Nonconformance (Report 81-01, Item C). The Engineering Document Control Center did not publish a document status list as required.
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The inspector verified the corrective action and preventive measures described in Brown and Root lettets dated February 16, 1981, and March 18, 1981.
specifically:
a.
A current document status list was issued as committed.
The list consisted of two separate issues, one of which (Brown and Root Document Status List) identified the current status of Brown and Root generated design documents.
The second list, (Vendor Document Status List) identified the current status of vt.r/ior design documents received by Brown and Root.
b.
A new organization was formed on February 16, 1981, the EDC (Engineering Document Control), and assigned the responsibility for control and bi-monthly issue of both document status lists.
c.
Procedure STP-DC-028-B was revised to reflect the new Engineer-ing Document Control organization.
d.
The design document control system was' revised and upgraded to provide additional control over the generation, revision, verification, issue, and distribution of design documents.
e.
All affected STP procedures are to be revised to reflect the new organization and document control system by May 1, 1981.
C.
Design Process Management 1.
Objectives The objectives of this area of inspection were to examine the estab-lishment and implementation of quality related procedures for the design process to verify that:
a.
The design process system is defined, implemented, and enforced in accordance with approved procedures, instructions, or otter l
documentation for all groups performing safety related design activities.
b.
Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures.
c.
Appropriate quality standards for items important to safety are identified, documented, and their selection reviewed and approved.
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d.
Final design can be related to the design input with this traceability documented, including the steps performed from design input to final design.
e.
Design activities are documented in sufficient detail to permit design verification and auditing.
f.
The methods are prescribed for preparing design analyses, draw-ings, specifications, and other design documents so they are planned, controlled, and correctly performed.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine if procedures have been prepared, approved, and issued to prescribe a con-trolled system for the management of the design process that is consistent with commitments to NRC and objectives a.
through f. above.
(1) Sections 17.2, 17.3, 17.5, and 17.6 of the NRC accepted Brown and Root (B&R) Topical Report, B&R-002A Revision 3, and amendements thereto, to determine the B&R corporate commitments relative to managment of the design process.
't (2) Sections 2, 3, 5, and 6 of the B&R South Texas Project (STP) QA Manual, to determine if the B&R corporate commitments relativc to managment of the design process were correctly translated into quality assurance policies and prt,:edures that provide control over activities affecting the quality of design within the B&R scope of supply.
(3) Thirteen STP applicable design control procedures that are contained in the STP Engineering Procedures Manual, to verify that procedures have been established to implement the committed quality assurance program and to prescribe design activities that are within the B&R scope of supply, j
b.
Review of Secticn 3.8 of the PSAR, Sections 3.6, 3.11, 6.1, and 6.2 of the FSAR, and Section 3/4.6 of the Technical Spec-ifications for the South Texas Project, to determine the regulatory requirements, safety classification, technical requirements, specific design inputs, and quality assurance requirements of the three containment air locks and other containment penetrations.
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Review of the design specifications 1C15-501 and 2C2695S006 (both titled " Steel Liner Work for Reactor Containment Structures"),
subcontract procurement files (35-1197-0011 with the Pittsburg -
DeMoines Steel Company), three B&R and 33 Woolley drawings, and the Executive Design Review of the South Texas Project Personnel Air Lock, to determine if sources of design input, such as PSAR/FSAR commitments and regulatory / quality requirements, were correctly and traceably translated into verified final design documents and the ultimately procured personnel air lock.
d.
The following additional documents were reviewed to determine if the quality assurance program for the management of the design process was being effectively implemented for the current B&R activities affecting the quality of the design within the B&R scope of supply:
(1) Calculations (four),
(2) 9esign verifications (five),
(3) Drawings (twenty-two),
(4) Personnel training records-(four),
(5) Safety concerns (seventy-seven),
(6) Specifications (five),
t (7) System Design Descriptions (eleven), and (8) Technical Reference Documents (eleven),
3.
Findings a.
Nonconformances Three nonconformances were identified in this area of the inspec-tion.
See Notice of Nonconformance enclosure, Items B., C.,
and D.
(1) With respect to nonconformance B.
The following nonexclusive list of differences between the in place QA Program and the program described in the Brown i
and Root Topical Report B&R-002A (Revision 3, September 1977, l
including amendments dated October 17, 1978, and March 24, 1980) were identified by the inspector:
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10 Some organizational structures and titles are different from those described in the Topical Report.
The QA Manager does not report to the Power Division Group Vice President.
The position of " Assistant Quality Assurance Manager" has been added to the QA organization.
The actual in place QA and Engineering organizations, interfaces, and functions are not as describec: in the Topical Report.
The revisions of the Regul'atory Guides endorsed by the in place QA Program are different from those identified in the Topical Report.
Review and approval of procurement documents by Engineering, Quality Assurance, and Purchasing is not as described in the Topical Report.
The responsibility for, and execution of, the QA Audit and Vendor Surveillance activities are not as described in the Topical Report.
(2) With respect to the inflatable seal personnel air lock:
(a) Section 3.8.1.1.6 of the South Texas Project PSAR states in part that:
... Access into the Containment Building is provided j
by an equipment hatch, a personnel airlock and an j
auxiliary airlock.
The personnel airlock is an approxi-mately 10-feet diameter welded steel assembly with l
double doors.
The auxiliary airlock is a 5-1/2 feet diameter welded steel assembly with double doors.
Each l
door is hinged and furnished with double 0-ring gaskets, l
with leakage test taps between the gaskets...."
i (b) Subsequently, the design evolved to use inflatable seals, rather than compression seals, reportedly to facilitate access for heavy equipment.
Section 3.8.2.1.2 of the South Texas Project FSAR states in part that "The personnel and auxiliary air locks are double, inflatable seal airlocks with pressure bar-riers..."
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11 The appropriateness of the inflatable seal design was independently questioned by a B&R reviewer and NRC inspectors.
Specifically, the ability to assure long-term sealing without having access to the inner seals for maintenance, and the dependence upon active non-fail-safe systems to maintain seal tightness and thus containment integrity, were questioned.
A subsequent independent " Executive (Design) Review" was conducted by a consulting organization for Brown and Root. The review concluded that "... the inflat-able seal concept planned for STP should provide adequate safety.
Details of the STP personnel air lock door sealing systems need further review and analysis as described herein to insure acceptable performance under accident conditions..."
The Brown and Root Senior Vice President of Engineer-ing stated that the design of the personnel and auxiliary air locks would be reevaluated within the next month and a decision made to either conduct the failure mode and effects analyses and qualifica-tion program recommended by the independent reviewers or to re-engineer the doors to deploy compressive 0-ring seals.
b.
Unresolved and Follow Up Items None were identified.
D.
Technical Personnel Background Verification 1.
Objectives To verify that measures have been established and are being effectively implemented that assure:
a.
The education and work experience information contained in employees' job applications are being verified by the employing i
organization.
b.
There is objective, documented evidence or records that attest to the employees' education ~and experience.
2.
Method of Accomplishment l
The preceeding objectives were accomplished by an examination of:
a.
Brown and Root Procedure DL-035, Revision 0 dated May 21, 1980, (Procedure for Verification of Education and Experience).
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12 b.
Personnel department record files for the following individuals:
(1) Six individuals who were extended an offer of employment, but have not yet reported for work.
(2) Eight employees who started to work during the first quarter of 1981.
(3) Three employees who started to work prior to 1981.
3.
Findings One nonconformance was identified in this area of the inspection.
(See Notice of Nonconformance enclosure, Item E).
The Personnel Manager stated that procedure DL-035 would be revised by June 10, 1981, to include specific requirements for verification and documentation of the alleged education and experience of newly hired or transferred employee who are engaged in nuclear safety related activities.
Subsequently, the personnel files of all such employees will be reviewed and retrofitted by June 30, 1981.
Specific actions will be taken on a case-by-case basis for those individuals whose alleged education or experience can not be verified or was falsified.
E.
Exit Meeting An exit meeting was conducted with Brown and Root management personnel at the conclusion of the inspection on January 8, 1981.
In addition to those individuals indicated by an asterisk in paragraph A. of this report, the meeting was attended by:
J. R. Ayres, Manager, Materials K. M. Broom, Senior Vice President S. M. Dew, Assistant Engineering Project Manager T. L. Porfilio, Discipline Quality Engineer W. M. Rice, Group Vice President, P u er Group E. A. Saltarelli, Senior Vice President The inspector discussed the scope of the inspection and the details of the findings identified during the inspection, including the processing of identified safety concerns.
Management comments were generally for information only or for acknowledgement of the statements of the inspector with respect to the nonconformances presented.
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