ML20041F167
| ML20041F167 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1982 |
| From: | Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20041F157 | List: |
| References | |
| REF-QA-99900531 NUDOCS 8203160251 | |
| Download: ML20041F167 (14) | |
Text
ORGANIZATION:
NUCLEAR POWER SERVICES, TNC.
SECAUCUS, NEW JERSEY REPORT INSPECTION INSPECTION NO.-
99900531/81-01 DATE(S) 11/17-20/81 ON-SITE HOURS: 82 CORRESPONDENCE ADDRESS:
Nuclear Power Services, Inc.
ATTN:
Albert J. Moellenbeck President One Harmon Plaza Secaucus, NJ 07094 ORGANIZATIONAL CONTACT:
Mr. Joel Grabie, QA Manager TELEPHONE NUMBER:
(201) 865-6550 PRINCIPAL PRODUCT: Engineering and Design Services NUCLEAR INDUSTRY ACTIVITY: Engineering and design of component supports and other equipment.
Currently about 70% of the work involves domestic nuclear facilities.
The total engineering staff consists of approximately 500 engineers, designers, and draftsmen.
About 2/3 of the engineering staff is located at field sites and 1/3 at the Secaucus, New Jersey facilities.
Major projects include Byron, Comanche Peak, McGuire, Oconee, South Texas Project, and Zimmer.
1 ASSIGNED INSPECTOR:
(7
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M-/bb D.F.efg, React'or$yAtemsSection(RSS)
Date OTHER INSPECTOR (S): L. E. Ellershaw, Reactive Inspection Section J. I. Tapia, Engineering and Materials Section APPROVED BY:
w O
3 '/(' i V C. J. (tfjle,' Chidf 7 R5F Date INSPECTION BASES AND SCOPE:
(
A.
BASES:
10 CFR Part 21 and 10 CFR Part 50, Appendix B.
B.
SCOPE:
This inspection was made in concert with an inspection of NPS Industries, Inc., as a result of concerns expressed to the NRC pertaining to possible errors and deficiencies in the design of component supports g
which could result in the failure of supports being provided to the Texas Electric Generating Company's Comanche Peak Steam Electric Station, Units 1
)
and 2.
In addition to the specific identified concerns the inspection also included a manaoement meetina.
PLANT SITE APPLICABILITY:
While the activities of this organization relate to numerous plant sites, this inspection was limited to the activities concerning the following Docket Nos. 50-445 and 50-446.
j DESIG"A y ORIGINAL s
d id ha-E 99900531 PDR
~
ORGANIZATION:
NUCLEAR POWER SERVICES, INC.
SECAUCUS, NEW JERSEY
~
REPORI IN5 pet,iiON NO.-
99900531/81-01 RESULTS:
PAGE 2 of 8 A.
VIOLATION:
Contrary to paragraph 21.6 of 10 CFR Part 21, posting of either 10 CFR Part 21, Section 206 of the Energy Reorganization Act of 1974 and adopted procedures, or Section 206 and an appropriate notice, had not been accomplished.
B.
NONCONFORMANCES:
1.
Contrary to Criterion II of Appendix B to 10 CFR Part 50, the NPS quality assurance program did not take into account the need for special skills to attain the required quality, nor provide assurance that all prerequisites for design activities have been satisfied, in that the NPS Personnel Qualification and Verification Program procedure (EPP-2) does not provide sufficient assurance that personnel hired to perform nuclear safety-related design analyses actually possess the special skills and technical qualifications (education, training and experience) needed to perform the analyses in a planned, controlled and correct manr.er.
2.
Contrary to Criterion XVII of Appendix B to 10 CFR Part 50 and Section 17.0.4 of the NPS QA Manual, QA records of indoctrination and training, needed to furnish evidence of activities af fecting quality, were not stored either in separate and secure storage locations or in a single fire and water proof area.
3.
Contrary to Section 7.0 of ANSI N45.2.11, dated May 1973, documented procedures did not assure that changes t odrawing 2S-8748 and.
calculations SC-111-2-31 and SC-265-2E-709 were reviewed for adequacy by authorized personnel, as evidenced by the signatories of unauthorized or unknown individuals on the documents.
4.
Contrary to Sections 7.0 and 8.0 of ANSI N45.2.11, drawing 25-510-R1 was changed on December 26, 1979, without justification and pages 154, 155, 174 and 175 of calculation package SC-265-2E-709 were changed on l
April 18, 1981, without being reviewed and approved by the same organizations that performed the original review and approval.
5.
Contrary to Section 4.2 of ANSI N45.2.11, design analyses were not l
sufficiently detailed as to purpose, method, and assumptions, in that l
the basis for sizing the fillet welds used in six examined structural calculations could not be determined by an appropriately qualified NRC inspector, without recourse to the originator.
l
ORGANIZAT10N:
NUCLEAR POWER SERVICES, INC.
SECAUCUS, NEW JERSEY REPORT INSPECTION NO.-
99900531/81-01 RESULTS:
PAGE 3 of 8 6.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 1.0 and 3.3 of NPS procedure EPP-2, the Personnel Verification Supervisor did not implement, nor cause to be implemented, all of the established measures to assure that personnel engaged in quality-related activities were qualified to perform the duties to which they are assigned, in that records contained in 16 examined personnel folders were incomplete, inaccurate, noncurrent and were not brought to the attention of the Vice President of Engineering when anomalies in the applicants education or experience qualifications were identified.
7.
Contrary to Criterion V of Appendix B to 10 CFR part 50 and QA Manual Section 15.0.4, an NCR was not initiated by the responsible NPS structural group supervisor after the identification and documentation in an inter-office memo dated April 28, 1980, that fillet welds in components supports were undersized with respect to ASME Code require-ments.
As a result, action was not initiated to correct existing drawing aad calculation deficiencies or preclude their recurrence as required by Section 9.0 of ANSI N45.2.11.
8Property "ANSI code" (as page type) with input value "ANSI N45.2.11.</br></br>8" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 17.0.4 of the NPS QA Manual, the TUSI Project QA Record Index did not identify, nor incorporate, NCRs, CARS, Procurement Documents and QA Package Review Checklists as generic project records, even though they were identified as such on the Master List of NPS QA Records.
9.
Contrary to Criterion V of Appendix 8 to 10 CFR Part 50 and Section 3.0.5 of the NPS QA Manual, the design verification of pipe support No. CT-2-00/-404-522R did not assure that the design met the specific design criteria, in that the design verification did not disclose that the tensile and shear force design inputs to the NPS baseplate analysis computer program were transposed.
10.
Contrary to Criterion V of Appendix 8 to 10 CFR Part 50 and Subsection NF of Section III of the ASME Code, 15 examined component support drawings specified fillet welds, to be welded at the CPSES Unit 2 site, that were not in accordance with ASME code requirements.
All such fillet welds g
were specified to be h", whereas the material was up to 2" thick which requires the use of fillet welds of up to and including 3/8".
C.
UNRESOLVED ITEMS:
None
ORGANIZATION:
NUCLEAR POWER SERVICES, INC.
SECAUCUS, NEW JERSEY REPORT INSPECTION NO.-
99900531/81-01 RESULTS:
PAGE 4 of 8 0.
OTHER FINDINGS OR COMMENTS:
1.
Management Meeting - The purpose, scope and nature of the Licensee, Contractor and Vendor Incaection Program were reviewed with the President of NPS and key management personnel at the beginning of the inspection.
The concerns expressed to NRC with respect to possible errors and deficiencies in the design of component supports were outlined and the bases for the inspection were enumerated.
The format, content, dissemination and publication of NRC inspection reports, and NPS responses thereto, were discussed in detail.
2.
A special inspection was conducted to determine the validity and safety significance of concerns expressed to the NRC that possible errors and deficiencies in the design of component supports could result in failure of the supports at the CPSES Units 1 and 2.
Review of available documentation and interviews with cognizant personnel, indicate that NPS was contracted by NPS Industries, Inc.
(NPSI), a separate entity of the NPS Corporation, via NPSI purchase order 30-086 dated September 11, 1978, to design hangers and supports for CPSES Units 1 and 2.
Safety and nonsafety-related hangers and supports were to be designed in accordance with Gibbs and Hill Inc.
(G&H) specifications 2323-MS-46A and 2323-MS-46B.
All final design drawings were to be generated by NPS using NPSI identification and logo on the drawings.
The concern was that undetected errors and deficiencies in NPS design calculations and drawings could result in failure of pipe hangers, supports, or whip restraints under accident conditions.
The inspectors reviewed applicable NPS contracts, procedures, and available documentation, to determine:
(1) if errors and deficiencies did in fact exist in final design documents; (2) their cause, (3) the extent of their proliferation into drawings that have been issued for construction, and (4) their safety significance.
Errors and deficiencies were found in final design calculations and drawings.
Specifically:
(1) the tensile and shear forces on the e
baseplate of pipe support CT-2-007-404-522R were interchanged in the k
computer input data to the design analysis of the supports; and (2) certain fillet welds identified on a significant number of component supports for CPSES Unit 2 were not sufficiently sized to meet the n.inimum requirements of Subsection NF of the ASME Code.
ORGANIZAT10N:
NUCLEAR POWER SERVICES, INC.
SECAUCUS, NEW JERSEY REPORT INSPECTION NO.
99900531/81-01 RESULTS:
PAGE 5 of 8 The inspection did not establish that errors and deficiencies were related to a single specific cause.
However, the inspectors noted certain programmatic deficiencies in the areas of personnel qualifi-cation, design control, design corrective action, QA internal audits and QA Record retention that could have contributed individually, or collectively, to the generation and lack of detection of the errors and deficiencies.
With respect to personnel qualifications, Nonconformances B.1 and B.6 indicate that the procedure for verifying the education and experience of new employees (EPP-2) does not provide sufficient assurance that design personnel actually possess the special skills and technical qualifications (education, training and experience) needed to perform safety-related design analyses in that:
a.
Section 6.1 permits the substitution of non-relevent experience for the required Bachelor's or Master's degree.
b.
Section 4.3 permits the promulgation of an error, or exaggerated education or experience, when the information obtained from previous employers personnel records is used as the sole basis for confirming that an applicant possesses the minimum qualifications needed to perform a specific design activity.
c.
Section 4.9 permits the verification of an applicant's education or experience solely through " personnel knowledge" of an NPS supervisory employee without supporting documentation.
(
d.
Sections 4.3, 4.6 and 4.7 were not being implemented, in that even l
though the records contained in 16 examined personnel folders l
indicated the. 4 applicants exaggerated their education and experience qualifications, and that the qualifications of 4 others could not be verified, this information was not brought to the attention of the Vice President of Engineering as required.
e.
Sections 3.4 and 4.11 were not being implemented, in that the Vice President of Engineering or his designee did not certify one of the applicants as qualified by completing the Technical I
l Review Form, and there were no current Technical Review Forms, g
for the current job position activities in which 10 of the
(
employees were engaged.
l 1
ORGANIZATION:
NUCLEAR POWER SERVICES, TNC.
SECAUCUS, NEW JERSEY REPORT INSPECTION N0.:
99900531/81-01 RESULTS:
PAGE 6 of 8 f.
Section 6.0 was not being implemented in that the following required records were missing from the 16 examined personnel folders:
one authorization for release of information; one request for verification of education; and one request for verification of employment.
Furthermore, there were no responses from previous employers to the NPS request for verification of employment of three applicants and the response to another request was not signed by the previous employer.
NPS management stated that their intent was to hire only those individuals that were capable of doing satisfactory work and that in the past several months alone, at least five individuals whose work was not satisfactory were discharged or resigned.
3.
With respect to design control, nonconformances identified during the inspection indicate that existing procedures are either not sufficiently definitive, or are not being implemented, in the areas of:
(1) accuracy and completeness of calculations; (2) verification of calculations and drawings; (3) design change control; (4) design document review and approval; and (5) security of QA Records.
a.
The inspector noted that the initials (BT) of the reviewer of Revision 2 to drawing 25-8748, dated October 29, 1981, did not correspond to that of any known past or present employee of NPS, and that the initials (TB) of the reviewer of Revision 1 to page 104 of calculation SC-111-2-31, dated December 26, 1979, did not correspond to the initials of TB contained in the approved list of personnel authorized to review and approve design documents, b.
With respect to nonconformance 8.9, the transposition of the l
tensile and shear force design inputs to the calculation did not i
result in a significant reduction of the structural capacity of the belted connection of the pipe hanger to the concrete wall.
l This is due to the fact that the allowable loads for the specified expansion anchors in tension, and in shear, are similar.
Nevertheless, the subject nonconformance represents a failure of the design verification process to detect and correct errors in design calculations.
c.
With respect to nonconformance B.5, the practice of specifying 1/4" fillet welds was based on the designer's visual inspection I
l
ORGANIZATION:
NUCLEAR POWER SERVICE 3, INC.
SECAUCUS, NEW JERSEY REPORT INSPECTION NO.:
9900531/81-01 RESULTS.
PAGE 7 of 8 of the loads involved and did not result in a significant safety concern in that for all cases reviewed, the resultant stresses in the welds were found to be relatively low.
However, lack of detail in design calculations was exemplified by:
(1) the nonexistence of a statement of justification for the adequacy of the welds; and (2) in one case, by a statement that "a one quarter-inch fillet weld would be inadequate" without any statement of corrective action that was needed or taken.
Due to the lack of detail, the NRC inspector had to resort to the structural engineering department originators of the calculation for an explanation of the statement.
The originators stated that the ctatement was only meant to apply to a weld of one inch length whereas sixteen inches of weld was provided in the support design.
d.
With respect to nonconformance B.10, 20 drawings were reviewed to assure that ASME Code requirements were properly translated into the drawings.
Review of 15 drawings pertaining to component supports for CPSES Unit 2 revealed that some of the specified h" field fillet welds are undersized, in that the material thickness required fillet welds up to and including 3/8".
A brief review of five component support drawings for CPSES Unit 1 did not reveal any evidence of this same discrepancy.
The NRC inspector noted that the Unit 2 drawings that were reviewed had loadings of up to 1000 lbs. specified.
e.
With respect to design corrective action, nonconformance B.7 identified that the existing procedure did not provide sufficient assurance that significant or recurring design deficiencies or errors were identified to the responsible management, nor that appropriate changes were made in the design process and the quality assurance program to prevent their recurrence, as required by Section 9.0 of committed ANSI N45.2.11.
With respect to QA audits, the inspector noted that most of the deficiencies identified during this inspection, existed since 1979 and should have been identified by an effectively g
implemented NPS internal audit program.
f ORGANIZATION:
NUCLEAR POSER SERVICES, INC.
SECAUCUS, NEW JERSEY REPORI INSPECIiON NO..
99900531/81-01 RESULTS:
PAGE 8 of 8 f.
With respect to QA record retention, nonconformances B.2, B.6 and B.8 identified that certain records, needed to furnish evidence of activities affecting quality, or of the important steps which led to the final design, are not being accumulated and maintained with the status of a Q* Record.
4.
Time did not permit the NRC inspectors to make an accuracte assessment of the extent of th' errors and deficiencies in the design process and drawings that were issued for construction.
However, the fact that:
(1) numerous safety-related component support drawings for CPSES Unit 2 specified undersized fillet welds; (2) six examined safety-related component support calculations were not sufficiently detailed to permit review and verification without recourse to the originator; and (3) approximately 20% of examined calculations were either not checked, not properly revised, or not reviewed ana processed as a QA record; is indicative that the errors and deficiencies could e.<ist in other design documents that were not examined by the NRC inspectors.
The specific errors and deficiencies identified by the NRC inspectors did not constitute a safety concern, in that the loadings and resulting stresses on the affected component supports were within the allowables of the ASME Code.
However, the fact is that these examples of calculational errors and violations of ASME Code requirements did escape detection and correction by the current NPS design control process and the QA program.
Accordingly, the programmatic deficiencies identified during the inspection are of considerable concern to the NRC.
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