ML20076C992
| ML20076C992 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, LaSalle, 05000000 |
| Issue date: | 07/06/1982 |
| From: | Curran R, Ferguson R, Harris R AFFILIATION NOT ASSIGNED, ENERGY, INC., FERGUSON, INC. |
| To: | |
| Shared Package | |
| ML20076C924 | List: |
| References | |
| NUDOCS 8305200637 | |
| Download: ML20076C992 (65) | |
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, AUDIT REPORT
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ENERGY INCORPORATED /FERGUSON INCORPORATED AUDIT REPORT OF SARGENT & LUNDY FOR COMMONWEALTH EDISON COMPANY JULY 6,1982 L
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ENERGY INCORPORATED f
R. N. CURRAN _
o-- DATE 7[6[8z.
R. J. HARRIS '
2M hM_ DATE //6 /8T-
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FERGUSON INCORPORATED R. N. FERGUS0 62 vfg6r.Jv t - -EATE 7//, 92 3 /
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I, TABLE OF CONTENTS b PAGE SCOPE,
SUMMARY
, AND ASSESSMENT 1 I.
1.0 Scope 1 2.0 Summary and Assessment 2 a.
5 I II. MANAGEMENT AREA - R. N. FERGUSON - TEAM LEADER 1.0 Introduction 5 5
, 2.0 Assessment
.; 3.0 Findings, Observations, and Comments 6 7
III. MECHANICAL-STRUCTURAL AREA (R. J. KARRIS AUDITOR) 1.0 Introduction 7
~ 7 2.0 Assessment
' 3.0 Findings, Observations, and Comments 9 lll 11 is I V. ELECTRICAL AREA (R. N. CURRAN AUDITOR) 11 1.0 Introduction 11 2.0 Assessment 3.0 Findings, Observations, and Comments 12 a
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ATTACRMENTS A - Audit Checklist Questions and Responses - R. N. Ferguson I
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B - Audit Checklist Questions and Responses - R. J. Harris C - Audit Checklist Questions and Responses - R. N. Curran D - Assessment of the Commonwealth Edison Company Audit Team
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I. SCOPE,
SUMMARY
, AND ASSESSMENT h 1.0 SCOPE r-Energy. Incorpor&ted/Ferguson Incorporated (EI/FI) have completed an audit
[ for Commonwealth Edison Company (CECO) of the Sargent & Lundy (S&C) Engi-neers Quality Assurance Program as implemented on the Byron /Braidwood.and g
r LaSalle Projects. The audit was conducted in conjunction with but inde-
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pendent of the regularly scheduled CECO. QA Department audit. The audit was Lh perfonned at the S&L offices in Chicago, Illinois on June 7 through 11, 1982.
The areas audited by the EI/FI team were: QA administration; QA program; design control, including: Engineering Document Control, Engineering Procedure Control, Computer Program Verification, Analysis Control, Inter-face Control, including S&L and NSSS interfaces,1E equipment qualification program, and 1E equipment design control.
% The purpose of the audit was to provide CECO with an independent assessment of the S&L QA prcgram from both a management and technical point of view and to assess the adequacy of the CECO audit team. The EI/FI audit team i consisted of the following individuals:
R. N. Ferguson (Team Leader, Management) - Ferguson Incorporated R. J. Harris (Mechanical / Structural disciplines) - Energy Incorporated R. N. Curran (Electrical / Instrumentation disciplines) - Energy Incorporated Mr. George Marcus, Director, Quality Assurance-Engineering / Construction, CECO, coordinated the overall activities of the S&L audit.
In preparation for the audit, the EI/FI and CECO audit team held a two-day meeting to discuss the audit checklist questions. This meeting was under the direction of Mr. W. J. Shewski, Ceco Manager of Quality Assurance, and
- l. Mr. George Marcus.
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During the meeting each auditor's questions were reviewed to assure that all important areas were covered. This resulted in a final comprehensive set of questions for the audit.
During the audit the complete audit team met daily with Mr. Shewski to review the audit progress and discuss all preliminary findings, observa-tions, and comments. At the conclusion of the audit, the EI/FI tea:n reviewed and concurred with the Ceco audit team's findings, observations, and comments.
2.0
SUMMARY
AND ASSESSMENf The results of the EI/FI audit are as noted below. .
The details of the Observations and Comments are provided in subsequent sections of this report for each auditor. The audit checklist questions l and the responses for each team member are included in Attachments A, B, anu C to this report. Attachment D contains the assessment of the Ceco i audit team.
2.1 Findings
l All findings are included in the CECO audit report.
2.2 Observations l (1) Section 7.0 of the QA Program (SL-TR-1A), Control of Purchased ;
Material, Equipnent, and Services, does not have a corresponding GQ, specifically for the control of purchased services. It is g
recommended that procedures be generated to guide the procurement B of services. .
(2) The c'o ntrol of the design interface between the NSSS vendor and S&L does not appear to be under a written department standard or {
project instruction which would require the formal tracking of
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7 this design' interface. This interface should be fomally L tracked. It is suggested that this interface be controlled by GQ 3.09, Foreign Design Documents.
P 2.3 Comments I
t (1) Documented training in the QA Coordination Section consists f solely of the Friday meetings. Attention should be placed in r this area to strengthen the training program. This could consist of documenting the training performed covering QA Codes and L Standards, etc. The training documentation for this section h appears weak in contrast to some of the other sections within the
[ division.
) In the General Office Procedures there are two procedures that
[ (2)
These two appear to be safety related in some applications.
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procedures are B.14 (Part 21 Reporting) and 4.1 (Computer Code h Veri fication). It is suggested that these procedures be removed
- k. from the GOPs and placed in the safety-related procedure control system.
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(3) The General Office Procedure, 4.1, which governs the verification
[ of computer programs, establishes the need for docunentation but l does not address the details of documenting the verification.
F y This has resulted in verification documentation which is incon-sistent in format and very difficult to trace through the compu-h
- ter programs' development history. GOP 4.1 should be more h explicit regarding the verification documentation.
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[ 2.4 Assessment It is the assessment of the EI/FI audit team that the S&L QA program as impler.ented, on the Byron /Braidwood and LaSalle Projects, is definitely f -
adequate in scope and is being effectively implemented. The Quality Control Program procedures and instructions reviewed were very thorough and d -
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well underscood by S&L's staff. These procedures and instructions comply with the appropriate criteria of 10CFR50 Appendix B and Section III of the ASME Code. A detailed assessment is provided for by each audit team member in sub' sequent sections of this report.
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- II. ' MANAGEMENT AREA (R. N. FERGUSON - TEAM LEADER) v
1.0 INTRODUCTION
The management area was divided into two sections: QA Administration and QA Program. This area was primarily audited by Mr. M. Stannish, CECO, and Mr. R. N. Ferguson, Ferguson Incorporated. In e.ddition, a portion of Mr.
] B. Harl's and Mr. E. Martin's questions covered the management area. Each auditor had a separate checklist and independently evaluated the areas
} being audited. The audit results of all team members were evaluated by Mr.
Ferguson on a daily basis. -
l This section of the audit report covers the results of Mr. Ferguson's audit. Mr. Ferguson's audit questions and responses are contained in Attachment A of this report. .
2.0 ASSESSMENT It is'Mr. Ferguson's assessment'after investigating many areas of the S&L QA management and program implementation that its status and adequacy are satisfactory. The S&L management is intimately involved in and supportive lt.
of the program. The QA Division leadership is committed to not only implementing but improving the program. An example of this involvement is h
the QA Task Force (established by Management), the Trend Review Committee, and the QA Coordinating Committee. The results of these functioning groups are reported to upper management and acted upon appropriately. This commitment by management is vital to the continued success of not only the QA Program but S&L as an A/E firm in the commercial nuclear power industry.
j All of the S&L staff interviewed are knowledgeable of the QA program and procedures. There appears to be good coordination of the QA requirements F in the interface between the project organizations and the S&L departments and divisions.
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3.0 FINDINGS, OBSERVATIONS, AND COMMENTS l
3.1 Findings
None.
3.2 Observations h
f Section 7.0 of the QA Program (SL-TR-1A) - Control of Purchased Material, Equipment, and Services - does not have a corresponding GQ, specifically
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for Control of Purchased Services. GQs 4.01 and 4.02 have some information .
on the procurement specifications and bid evaluations but do not apply to However, the control of Service Consultants after award of contract.
It is recomended that' procedures neither GQ is referenced in Section 7.
be generated to guide the procurement of Service Consultants.
E 3.3 Comments -
(1) Documented training in the QA Coordination Section consists solely of the Friday meetings. Attention should be placed in this area to strengthen the training program. This could consist of documenting the training perfonned covering QA Codes and l Standards, etc. The training documentation for this section appears weak in contrast to some of the other sections within the division.
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(2) In the General Office Procedures there are at least two proce-dures that appear to be safety related in some applications.
These two procedures are B-14 (Part 21 Reporting) and 4-1 (Computer Code Verification). It is suggested that these proce-dures be removed from the GOPs and placed in the safety-related procedure control system.
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0' III. MECHANICAL-STRUCTURAL AREA (R. J. HARRIS AUDITOR) w J
1.0 INTRODUCTION
! The mechanical and structural area of the audit was conducted by Mr. Mike Gorski of CECO and Mr. Robert Harris of Energy Incorporated. Mr. 'Gorski's portion of the audit dealt with explicit FSAR requirements where Mr. Har-h ris's dealt with assessing the effectiveness of S&L's Quality Assurance Program,in the design and analysis area. Mr. Gorski and Mr. Harris worked together for the portion of the audit concerning computer program verifica-tion and documentation. The remainder of the time tioth auditors worked g
W independently but in the same areas.
This section of the audit report covers the results of Mr. Harris' audit.
Mr. Harris' audit questions and responses are contained in Attachnent B of this report.
2.0 ASSESSMENT I
Mr. Harris' audit approach was to review the S&L's Quality Assurance Proce-dures, Department Standards, and Project Instructions covering design and analysis activities to determine if these procedures, standards, and in-structions are sufficient. Specific design and analysis activities were then checked to detennine if the existing procedures and instructions were being effectively applied. Except for the two conditions noted in Section t
3.0, Findings, Observations, and Comments, it was found that S&L's program is very thorough, well understood by the engineering staff, and effectively g
lU impl emented. During the audit, all S&L staff members contacted not only I understood the required procedural steps involved in their work but were knowledgeable of the procedures themselves. Although staff training was not covered as a specific audit question by Mr. Harris, it was apparent S&L's staff has been well trained in both the use of the procedures and the total integration of the Quality Assurance program.
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t S&L's Quality Assurance Manual gives the uverall direction for the quality program. This manual contains the GQ Procedures which give additional l direction to the staff concerning implementation of the quality program.
GQ-5.01, Project Instructions', requires the development of Project Instruc-tions for additional direction to the staff members assigned to the proj-l l
ect. These instructions contained most of the design interface requirements and contained tracking requirement to assure the various interfaces have occurred. It should be noted that all the project instruc-tions reviewed during the audit did contain the level of detail necessary to assure continuity throughout the program. Again during the audit it was l
found that the staff was very familiar with these instructions.
In addition to the GQs and Project Instructions , each department within S&L g has its own department standards. These standards contain ins'tructions a covering the engineering work completed by the given department. Again,
! the department standards reviewed during the course of the audit were found to be excellent training and instructional documents well understood by the l
l department staffs.
The engineering documents (drawings, specifications, analysis reports, and g E
l criteria) were all well done and cross referenced. Specifically, the
) stress analysis reports thoroughly referenced the drawings and criteria documents by both number and revision. This thoroughness seemed to be h l consistent in all documents reviewed.
To aid the staff members in applying the correct design criteria, the projects had developed general project design criteria documents (see re- ]
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1 sponse to audit question Y-1 discussing seismic loading). These documents were not necessarily a program requirement but were generated to aid the
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5 staff during the design and analysis activities. These documents are excellent reference documents and will be invaluable during the life of the h plant for future reference. $
1 l At the conclusion of the audit, it was Mr. Harris' opinion that S&L has a g very thorough Quality Assurance Program. The program is well documented 28-7 '
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and understood by the, staff. It appears to also be well applied. Even in the areas where explicit instructions did not exist, such as the distribu-tion of the NSSS design data (see Observation III-3.2), the staff was
" following good engineering practices and was initiating the proper design 5
i interfaces.
3.0 FINDINGS, OBSERVATIONS, AND C0!EENTS
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3.1 Findings
None.
3.2 Observations _
The control of the design interface between the NSSS vendor and S&L does not appear to be under a written department standard or project instruction which would require the formal tracking of this interface (see response to l
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- audit question IV-3).
It Discession: The NSSS design interface should be fomally tracked.
would appear that the control of this interface should come under GQ 3.09. GQ 3.09, Foreign Design Document, requires the project manager by project instructions or the department manager by department standard to establish a system for monitoring receipt of contractors' technical docu-ments. This monitoring is to include maintaining a list of docunents If these PIs or dss I received with the review status of each document.
exist, they were not made available. However, in tracing a G.E. pipe g hanger loads report through the system, it was apparent that the reviews U
are being completed and loads the infomation is being included in the design cf the structures.
h 3.3 Comments The General Of fice Procedure, 4.1, which governs the verification of compu-ter programs establishes the need for docunentation but does not address f 28-7
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!;l the details of documenting the verification (see response to audit question II-5). This has resulted in the verification documentation which is inconsistent in format and very difficult to trace through the computer programs' development history.
Di scussion: GOP 4.1 requires each computer program to have a unique pro-gram number, a completed verification certification form, the Computer Library to maintain a listing of all documented computer programs, and the verification to be documented. The explicit requirements in GOP 4.1 are being applied. However, the documentation of the verification process is not explicitly defined in 4.01. This has resulted in the documentation being inconsistent with poor traceability between the earlier and current versions of the progrens. The fonnat and information included. in the g verification report are left to the auditor's discretion. In reviewing the u documentation for the PIPSYS computer program, this problem was apparent.
In addition, the program version and user's manual are not tied together as .
a unique set.
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IV. ' ELECTRICAL AREA (R. N. CURRAN AUDITOR)
1.0 INTRODUCTION
The electrical area of the audit was conducted by Mr. Tom Sommerfield of Mr. Sommerfiel'd pre-Ceco and Mr. Robert Curran of Energy Incorporated.
pared his questions based on requirements of the FSAR while Mr. Cu l questions dealt with assessing the areas of equipment qualification, con-trol of plant design changes, NSSS supplier interfaces, and the effective-ness of S&L in applying their Quality Assurance programs in these areas.
Mr. Sommerfield and Mr. Curran worked together whele their questions g The remainder of the time the two U covered a common area of documentation.
auditors worked independently.
B 2.0 ASSESSMENT B Mr. Curran's audit approach was to review the S&L procedures, design criteria, and drawings to detemine if these documents are sufficient to I control interfaces with the NSSS suppliers, provide and maintain required separation of IE equipment and cable, and to ensure the qualificat 1 equipment.
' At the conclusion of the audit it was the opinion of Mr. Curran that S&L engineering staff contacted had a thorough knowledge of the Quality A Changes, resulting from ance program and were implementing said program.
kSSS design changes, which were reviewed, were found to be completely The establishment of 1E equipment and cable separation and the documented. In maintenance of these separations was found to be well documented.
l particular, he found the documentation of IE equipment qualificat very thorough, both by the engineering staff for Byron /Braidwood an for LaSalle County.
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3.0 FINDINGS', OBSERVATIONS, AND COMMENTS
3.1 Findings
None.
3.2 Observations None. l 3.3 Comments None.
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h AUDIT CHECKLIST QUESTIONS AND RESPONSES
- R. N. FERGUSON :
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RESPONSE TO AUDIT CHECKLIST QUESTIONS h
Checkli st r Item Number Questions / Responses k
- 1. QA Administration 1 -
[ a., Organization charts identify the "on-site" and "off-site" j
r organizational elements which function under the cognizance of the QA program and the lines of authority. Ref. NUREG-75/087, Item 1A5 (SL-TR-1A, Fig. 01.01-I and 01.02-1).
NOTE: Is the QA department involvement with the project (on-site and off-site) effective?
l l . b. The QA responsibilities 'of each of the organizational elements noted on the organization charts are described.
Ref. NUREG-75/087, Item 1A6, ie.d., examine difference between organization charts in SL-TR-1, Rev. 5 and those in QA 1.02 (SL-TR-1A, Section 01.00).
Response
The organization charts in the GQ are up to date and do identify the corporate and project interfaces. The topical report has not been updated since 1977 so the organization charts in it are out of date. Draft 7 was submitted to the NRC on September 29, 1980 and 22 comments were received on October 24, 1980. No formal reply has been made by S&L. Draft 9 is to be submitted in about -
three months. This item is adequately covered in the CECO portion
! of the audit. The QA Division involvement with the S&L on-site activities consists of a QA coordinator making an on-site visit
] (surveillance) on a one day every two or three weeks basis plus scheduled audits which involve the on-site activities (six sched-f E uled for 1982). The surveillance activities of the on-site work A-1
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is minimal and this area should be carefully observed by S&L QA management to assure its effectiveness.
Considerable time was spent individually with Mr. H. S. Taylor (Director of QA), Mr. D. L. Leone (Byron /Braidwood Project, Director), and Mr. R. Mazza (LaSalle Project Director) discussing g the S&L QA Program and the involvement by management. The company u management appears to have extensive knowledge of the program and is involved in formulating QA policy and implementing the program. l
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- 2. QA Program 2-a. Management Audit performed annually and the corrective action is identified and tracked. Ref. NUREG-75/087, Item 2C.1b.
Re sponse_
The internal S&L management audit for 1981 is scheduled to begin on June 28. The femal assessment for the year 1980 was not done. This was an audit finding by Cincinnati Gas & Electric so was not further pursued by this auditor. The management audits are infomally tracked by the QA Division, but this is the responsibility of the Director of Services. An integral part of the management audit process is the QA Task Force which was appointed by management.
This task force issued a report on 1 82 which was reviewed by this auditor and found to be very comprehensive and well done.
2-b. Management regularly assesses the scope, status, adequacy, and compliance of the QA program to 10CFR50, Appendix B by receiving Ref. NUREG 75/087, Item 2.C.la.
copias of the audit reports, etc.
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Response
Management regularly receives copies of the audit reports in accordance with the distribution requirements as stated in GQ f- 18.01. Also, management regularly attends the audit exit
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meetings.
b Committed to the development, control, and use of computer code
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2-c.
programs conducted in accordance with the QA program and a
- description of how the QA program will be applied is in the
- program. Ref. NUREG 75/087, item 2. A.lc. -
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Response
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This item was covered in-depth by Mr. R. J. Harris 'in Item III of his audit checklist. The SL-TR-1A Section 03.03 provides the f~ commitment to apply QA to the control of computer programs and the actual procedures are covered in the department procedures.
k-u 2-d. QA manuals are issued to the proper personnel and the revisions are controlled.
Re sponse T
QA manuals are issued to the key personnel and the revisions are
_ controlled. Specifically checked the following: Leone (Manual
- 28), Gallagher (#189), Keinosky (f432), Raef (#181), C. B. Martin
(#149), and Treece (#106).
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Section 7 of SL-TR-1A does not have an implementing GQ which would
}" apply to the control of purchased services. Some infomation is in GQ 4.02, but it is not sufficient. This is reported as an observation.
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3 The General Office Procedures were stated to be "non-safety-re-
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lated" and therefore not subject to the same controls as "
QA-related procedures would be.
There are at least two proce-dures.- B-14 (Part 21 Reporting) and 4-1 (Computer Code Verifica- -
tion) - that appear to affect safety-related work and as such should be subject to the same controls as the other safety-related procedures. This is reported as a comment.
Audit 2-e. QA audit program (internal and external) is effective? i reports are distributed to management and appropriate actions are taken.
Response
The QA audit program (both internal and external) appears to be
- comprehensive and effective under the direction of Mr. Bob Martin. Several audit reports (including audit 60 (BLM) dated 6-This area was audited in-depth by M. Stanish 3-82) were reviewed.
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2-f. QA staffing is adequate to accomplish program objectives.
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The QA Division staff consists of approximately 40 people with 11 of them as auditors and 5 coordinators. This appears to be an
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2-g. QA training program is described in a written document and implemented and effective.
Re sponse A considerable amount of time was spent evaluating the S&L train-ing program. All company QA training except that of the QA i
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{i Department is coordinated by the QA Division in the Training Group
- headed by Pat DeBlake'. Tests are given every two years primarily on the GQs. The problem with this is that unless it was decided 1 by the training group that special training was necessary, the h person to be trained could be two years out of date on being trained in the GQ revisions. The method for detennining if all
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applicable people are on the training schedule is the Quarterly
] Update issued by the oepartment heads. This method may allow some r-people to be missed since there is not an independent check
/J against personnel records to assure that all people (both S&L and L contract people) are indeed on the schedule _.
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ment Training Group. This training is covered by department procedures GDIP 7 and 8 and requires each group to maintain their own training records. Some groups do better than others in this e area. For example, training in the QA Coordination Section is not ~
L well documented with the exception of the Friday meetings. This is reported as a coment.
Department technical training is being performed in accordance I with procedures ESI-230, MAS-8, and SAS-24. This program is set
- up and performing reasonably well. For example, they have a power
' plant design course 16 weeks long (1.5 hrs /wk) which is required of everyone down to designer-2 level. This course is required to be completed within two years after entering the company and they hold a new course every year to 1.5 years. Randomly checked
! S. G. H. Ashrafti and J. S. Steele and others and they had re-ceived training. Project instruction training is being performed on both the Byron /Braidwood and LaSalle projects. Project train-ing records are required to be maintained in a project instruction training file by the project manager per GQ 2.07, page 3, and this I is being done.
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2-h. Nonconformances are evaluated and corrected on a timely basis.
Response
I The timeliness of evaluating nonconformances is good and they are being evaluated.
I 2-i. Nonconformances are trended and corrective action taken as a result of these trends and reported to management for review and assessment, Ref. NUREG 75/087, Item 15.5.
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Response
S&L has established a Trend Review Committee which trends not only S&L detected nonconformances but also those nonconforming condi-tions identified by companies who audit S&L. Reviewed the Trend Review Committee Report dated 2-12-82. This infomation is pre-sented to management through routine status reports from the QA Director.
2-j. Nonconformance control program applies to computer codes also (and services). Ref. NUREG 75/087, Item 15.1.
I Re sponse l
Nonconformance control of computer codes and services is primarily I
i done on the basis of audit and the resulting CARS. lhey have audited these functions. Some thought should be given to estab-lishing a formal nonconfomance system associated with computer l codes.
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AUDIT CHECKLIST g ,7g ann 7 turn 11
. ENERGY INCORPORATED 1 3 PAGE: OF ORGANIZATION TO BE AUDITED: AUDIT NO: AUDITOR:
Sargent & Lundy RNFerguson
- CHARACTERISTIC REFERENCE DISP' COMMENTS
- 1. QA Administration
, a. Organization charts identify the "on- ACC See response to audit questions following this audi', checklist.
site" and "offsite" organizational elements which function under the cognizance of the QA program and the i lines of authority. Ref. NUREG-75/087, Item lAS (SL-TR-1A, Fig.
01.01-1 and 01.02-1).
NOTE: Is the QA department involvement lT" with the project (onsite and offsite) l effective?
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- b. The QA responsibilities of each of ACC the organizational elements noted on the organization charts are described.
Ref. NUREG-75/087, Item 1A6, i.e.,
examine difference between organi-zation charts in SL-TR-1, Rev. 5 and thoac in GQ 1.02. (SL-TR-1A, Section 01.00). ,
- 2. QA Program
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- a. Management Audit performed annually (SL-TR-1 A) ACC and the corrective action is identi- (02.07) fled and tracked. Ref. NUREC-75/087, Item 2C.lb.
- DISPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY rORM OA-014 (REV. 2, 4 82) CHECKLIST APPROVED B Aeh M4-#2
2 AUDIT CHECKLIST onre: aune 7 thru 11 CONTINUATION SHEET
'h' ENERGY INCORPORATED
' PAGE:
2 OF 3 CHARACTERISTIC REFERENCE D'ISP* COMMENTS
- 2. QA Program - (Con't)
Management regularly assess the scope, (SL-TR-IA) ACC b.
status, adequacy, and compliance of (02.07) the QA program to 10CFR50, Appendix E by receiving copies of the audit reports and etc. Ref. NUREG 75/087, Item 2.C.la.
Committed to the development, control, (SL-TR-1A) ACC c.
and use of computer code programs (03.03) .
conducted in accordance with the QA program and a description of how the QA program will be applied is in the y;(n program. Ref. NUREG 75/087, Item 2-. A . l c .
02.01 ACC
- d. QA manuals are issued to the proper with personnel and the revisions are OBS.
controlled.
18.01 and. ACC ,
- c. QA audit program (internal and external) is effective? Audit 18.02 reports are distributed to management ,
and appropriate actions are taken.
ACC I
- f. QA staffing is adequate to accomplish l program objectives, 02.05 ACC
- g. QA training program is described in a W1th written document and implemented Commtnts and cffcctive.
f OBS.= OBSERVATION DEE = DEFICIENCY l
- DISPOSITION: ACC.= ACCEPTABLE l
FORM OA-Ol4 (REV. 2, 4-82) i M M M M M M M
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AUDIT CHECKLIST .gg7g; done 7. turo 11 CONTINUATION SHEET ENERGY INCORPORATED 3 PAGE: 3 OF 4
CHARACTERISTIC REFERENCE DISR* COMMENTS
- 2. QA Program - (Con't) 16.01 ACC
- h. Nonconformances are evaluated and corrected on a timely basis. GQ 16.01 3.0C.2 l
l ACC l ,
- 1. Nonconformances are trended and corrective action taken as a result of these trends and reported to management for review and assessment.
Ref. NUREG 75/087, Item 15.5.
ACC
- j. Nonconformance control program applies T to computer codes also (and services).
Ref. NUREG 75/087, Item 15.1.
OBS.= OBSERVATION DEE = DEFICIENCY
- DISPOSITION: ACC.= ACCEPTABLE FORM OA-Ot4 (REV. 2, 4 82)
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. . ATTACHMENT B l .
u AUDIT CHECKLIST QUESTIONS AND RESPONSES R. J. HARRIS g -
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P RESPONSE TO AUDIT CHECKLIST QUESTIONS c
Checklist Item Number Question / Response h
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- 1. Document Control i
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I-1. Are the following engineering documents controlled (distribution, traceability, and revision)?
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- a. Procedures f
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- b. Specifications k
[ c. Drawings r~ Response h
The engineering documents (specifications and drawings) are I basically controlled (filed, distributed, a,nd revision con-trolled) by the department that generates the docunent on the i
! given project. There is not a central document control for the entire company or for each project. This type of system re-I suits in document files throughout the company; however, the !
control of documents appears to be very good. Company proce- l dures for the control process are contained in S&L's Quality ;
Assurance Manual, under the GQ procedures, GQ 3.07 and 4.01 for l g
tJ drawings and specifications, respectively. In addition, these l procedures contain instructions for the preparation of these documents. It does not appear that S&L's work involves the l preparation of procedures. Therefore, instructions for the preparation, issuance, and control of procedures was not audited. 1 F .
i L l 121-8 3_1 -
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- J -- - _ _ _
L 1-2. Are the following engineering analysis reports controlled (maintained revised)?
- a. Stress analysis
- b. Transient analysis H
l c. Shielding and criticality E
Response
GQ-3.08, Design Calculations, gives the preparation and issu-ance instructions for design calculations. Again, the control of analysis reports is the responsibility of the department on the given project that generates the analysis.
I-3. Are revisions at the analysis, specification, or drawing level I
fed back through the system to determine the effects of all i levels (analysis, specification, design) in the design?
Response
As.noted in the response to audit questions I-1 and I-2, procedures which control the preparation of specifications, drawings, and design calculations do exist. These instructions also cover revisions. However, a different department may be responsible for the design calculations than is responsible for the drawings and specifications. Therefore, the control and carrythrough of a design change from the specification to the drawing or analysis becomes an interface problem between departments. These interfaces are specified by the project instructions required by GQ 5.01 of the Quality Assurance Manual and by department standards. {
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B-2 121-8
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" l k I r II. Engineering P'rocedures L
9 L 11-1. Do procedures exist that control design reviews from a require- l
- . ments scheduling and documentation standpoint (by system, by I
plant area, etc.)?
e L
Respons2
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F l
' The S&L Quality Assurance manual, Section 3.03, line 98 gives e
i the requirements for the design reviews and the direction to u consult the specific department standardt and project instruc-tions for further instruction covering design reviews carried out by the given department. An example of the department standards and project instructions for design reviews was:
)
E " Structural Standard Document", Standard SAS-2, Rev. 2, and L
i - Project Instruction for LaSalle County Station; PI-LS-06, b " Mechanical System Design Reviews", and PI-LS-08, "Overall y Design Review".
1 L Per these standards, the structural department at LaSalle was h.. required to maintain a design review status list " System and Structural Design Review Status Report". From this list, the
{ design review report for the Containment Embedment Plates, DRR-
~
l SD-062-LS, Rev. O, 7/23/76, was reviewed for completeness. The review report was short but did contain all the pertinent data, including the drawing and analysis reports.
II-2. Do the procedures governing second level reviews identify by who and how the reviews are to be completed and are the reviews
) documented?
Re sponse_
As noted in the response to audit questions I-1 and I-2, GQs q
d 3.07, 3.08, 3.12.1, and 4.01 give the instructions for the l
1 .
121-8
I preparation and cohtrol of drawings, calculations, and These procedures do give thorough design specifications.
review requirements.
Do the procedures governing design groups cover the II-3.
interfaces? .
I
- a. Civil / Mechanical
- b. Mechanical / Electrical .
- c. System Response / Mechanical
- d. Shielding / Civil ,
Response _
disci-Design interface control between the various depart- engine
/
plines is controlled by project instructio d ment standards.
[
interface control is PI-LS-27,An"Docunentation example of department of Ha and Final Loads Check of Structures". i l standards covering the design interface between th t Standard and electrical discipline is the Mechanical l Departmen ctuator which requires the mechanical staff to request Data va ve a information from the electrical staff by the Sheet MES 5.5.1 and 5.6.1. in that they the S&L design interfaces are very thorough i i line.
require documented responses from each affected The containment spray system containment in isolat checked and it was determined that thes use for valve M0 ICS 007A-1, B-5000.
B-4 121-8 ,
II-4. Do the engineering procedures specify the signatures approval requirements and are they adequate to assure proper design I interface control?
Response
Signature approval requirements are covered by project instruc-l tions. On Byron and Braidwood PI-BB-10, Rev.1, dated 1-10-79, l
gives the level of signature and in addition references the GQs and department standards which govern signature requirements.
II-5. Is the computer program verification procedure adequate and implemented?
Response
The computer program verification procedure is part ,of the S&L General Office Procedures, number 4.1, " Checking and Validation I Requirements for Engineering Applications and Programs", dated 1-19-77. This procedure requires the validation of each com-puter program to be doctanented and a " Validation Certification Form" be completed for each program. It also required a listing of all verified computer programs to be maintained by the Computer Library on the " Program Library List". Documenta-tion of the verification was required, but the instructions for the verification report or packages were not detailed. In addition, there were no explicit instructions requiring the user's manual and a given version (update) of the computer l
program to be tied together. As a result of these limited instructions, the verification documentation for the computer programs reviewed varied considerably. The format and information included were inconsistent, and a clear corre-spondence between the program version and the user's manual was not evident.
I B-5 121-8
(l The verif ation reports were reviewed for the PIPSYS computer program.
Several verification reports were reviewed, starting with the report designated as TASK / PROGRAM #095-065-5.3 date 11/10/81. The explicit requirements stated in 4.1 were included in the report. However, the correspondence between the user manual revision and the revision nunber of the program S&L's s'taff stated that this correspondence was was not clear.
traced through the release dates of the manual and computer
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That is, the revision of the manual in program revisions.
force when the program is released 1s the appropriate manual.
However, the lack They felt very comfortable with this system.
of specific documentation made it very difficult to trace the This correspondence between program versions and manuals.
difficulty was noted as an audit comment in Section III-3,0 of this report.
t III. Computer Program Verification, e j Is there a list of properly verified computer programs which III-1.
can be used on the project and does it contain the programs used?
Response _
As noted. in the response to audit question II-5, a computer program listing of properly verified program is maintaine the engineering staff only has access to programs on this list.
All programs on this list can be used per Alfred Pebler and John Gary, staff members on the Byron and Braidwood project.
Is the documentation for the computer programs such that e III-2.
program and program version is?
- a. Uniquely identified.
B-6 121-6 ,
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- b. Manuals specify version / revision traceability.
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- c. Computer output identifies which version of the program the runs were made on.
Response
As noted in response to audit question II-5, GOP 4.1 does require a unique program number but the manuals can only be related back to a version of the program by the release dates. Two piping stress analyses were reviewed to determine if the program version and release date were printed on the computer output. It was found in both cases that the runs did l!
have this infonnation printed out by the computer. Analyses checked were:
- 1. Auxiliary feedwater system, Byron and Braidwood Unit #1, j 1AF-01, Rev. 03F0, dated 2/18/81. Analysis was completed on PIPSYS program 9.5-065.5.3 dated 2/6/81.
a 2. High pressure core spray, LaSalle County Unit #1, EMD-033718, Rev. 4, dated 1/13/82. Analysis was completed on PIPSYS program 9.5-065-5.1 dated 9/11/80.
Again, the appropriate manuals must be traced by the dates.
III-3. Does the project assure that only programs on the approved verified computer program list get used on the project?
Response
As noted in response to audit question 11-5, the only programs available to the engineering staff are the programs on the
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" Program Library List" and all these programs.are verified.
Therefore, per this system, it appears only verified programs 121-8 B-7
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can be used. Department standards give the instructions for the use of verified programs. l III-4. Do computer programs which are not on a verified computer program list get approved by the project prior to use?
Response
As noted in response to audit question II-5, only verified computer programs which are on the " Program Library List" can be used by the engineering staff for analysis. Therefore, if a new program was to be used, it would first have to be verified then included on the computer program list, and at that time, g it could be used for analysis on the project. E I I I-5. How is computer program verification documented?
Response
Computer program verification is documented. See response to audit question 11-5.
IV. Design Control Does the project criteria specified for a project include j IV-1.
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requirements from the following?
f
- a. Regulatory Requirements.
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- b. Codes and Standards.
- c. Client Imposed Requirements.
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B-8 121-8
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d Response s
a Yes - these criteria are imposed at several levels starting with the PSAR/FSAR, the S&L Quality Assurance Manual, the department standards, system design specifications, and project design criteria reports. These documents are well written and 5 are very complete. Examples are:
a
- 1. QA Manual, Section 3.03, line 85, and GQ 3.08 impose the requirements of Regulatory Guide 1.64.,
- 2. Byron and Braidwood criteria, Structural Project Design Criteria, DC-ST-03-BY/BR, Rev. 8, Section 10. This section contained the NRC Standard Review Plan load combinations and stress limits to be used for the analysis of structures on the project.
y IV-2. Do the criteria get imposed at the engineering design level on 5 the project and are they effective?
Response
Yes - The department standards and project design criteria manuals were well distributed. In literally all work areas I which were visited during the audit, these manuals were visu-U ally available. During the course of the audit many sets of design calculations were reviewed for various reasons by both q
a myself and Mike Gorski. In review of these analyes, the design criteria were well documented. Specific analysis reviewed for this purpose was:
LaSalle County Station high pressure core spray. The system Design Specification, DS-HP-01-LS, Rev. 2, dated m 11/16/81, imposes the 1974 edition of the ASME Code, no s addenda. The specification gave the piping class and the 0 -
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e load conditions. The design analysis for this system for Unit 2 referenced the Unit 1 analysis, EMD-033718, Rev. 3, dated 1/13/82. The analysis was completed to the 1974 edition of the ASME Code, no addenda.
Does the design information (loadings, configuration, opera- q IV-3. j tional controls, and revis' ions to same) from the NSSS vendor i get into S&L design process and is it effective?
Response
l b
No fomal project instructions or department standards exist f for tracing the integration of the NSSS design information into 3
, i the S&L design. We lack of fomal tracking was noted as an However, audit observation in Section 111-3.0 of this report.
on both the Byron and Braidwood and LaSalle Projects the design (
information is distributed to the proper staff members and the For example, on current NSSS design infomation is being used.
Byron and Braidwood, Westinghouse submitted containment hanger loads smanary sheets, for use, in letter nunber S.O EMXP-1000, MNTC-1048, SMD-BY1-10615. These loads would affect the design of the structure. This infomation was properly dis'tributed to D. C. Patal, Structural Design Engineer, for action.
In addition, a detailed check of this interface was made on the LaSalle project. The Project Management Department document I control file was checked for the latest GE hanger loads submitted to Sargent & Lundy. They were GE report number The Structure Engineering Staff
- 22A7429, 30,31,32, Revision 2.
under S. Kazmi had completed the structural design using the The structural drawing associated revision 0 and 1 GE reports.
This with the pipe hangers was HLS-373 Rev.16, dated 1/18/82.
drawing was in the process of being revised to incorporate the revision two design data, i
B-10 121-8 ,
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A IV-4. Are the design interfaces between the following design groups adequately identified and controlled?
r L a. Mechanical / Civil
- b. Nuclear / Mechanical L
b r c. Civil /El ectrical L
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[ d. He'chanical/ Electrical L -
h Response T
- L As noted in response to audit question II-3, project instruc-h E tions do exist for these interfaces. These procedures and instructions are very thorough and are being effectively f applied. Response to audit questions IV-5, IV-6, and IV-7 E
L addresses the mechanical / structural interface in detail.
L IV-5. Do the results of the analysis (such as piping support loca-
[ tions, nozzle loads, structural steel sizing, component support loads, etc.) get' factored into the design process (design
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drawings or equipment specifications)?
IV-6. Does a change at the design (drawing) level get reverified by analysis if an analysis was involved in the original design?
IV-7. Are field change requests acted on and approved by the same engineering organizations that approved the original design and is that action timely?
n a
n.
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-11 121-8
-p_ - - e . . , . _ _ . - . . - . . . , , . _ . . ,.m y _ . _..,_ . _ . y_,.r _. . . __, _ _ - . . _ . - . - _ _ . _
L Response to Questions IV-5, 6, and 7 It was determined that the detailed effectiveness of the design interfaces (the analysis results and the drawing revision / anal-ysis followthrough) was very effective. This was determined by !
the following check on the Byron and Braidwood projecti The project instruction, PI-BB-14, requires that the civil /struc-tures staff must review and act on all changes to the piping support loads resulting from analysis or design revisions by g official transmittal. This process was checked for the
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Auxiliary Building Subsystem 2S x 17 containing 25 supports.
The revised design was transmitted by Mechanical Design and Drafting on transmittal F-158 dated 12/31/81 by an interoffice memo dated 12/31/81 with all supports defined. Structural l design and drafting did document the review by interoffice memo dated 1/8/82 returning the original transmittal. The trans-mittal was very thorough, w' ell documented, and acted on very timely. Similar project instruction exists for other inter-faces. Field changes which result in a design change follow the same change and review process.
I IY-8. Are the safety-related system structures and components protected (separated) from the non-safety-related equipnent?
What procedures exist to identify safety-related systems from non-safety-related systems on the plant composite drawings?
l e l Response g
The safety-related systems are protected from the non-safety-related systems by designing all supports for the non-safety j, T
systems to withstand all seismic loadings without failure.
This design approach is not covered by Project Instructions f*
according to Mr. Rakowski and Mr. Green, but on the Byron and Braidwood project, this commitment has been made to the NRC in response to NRC questions on this subject. It' appears this d B-12 -
121-8 a
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- issue is' being addressed; however, no S&L procedures addressed this issue. In the discussion with the project staff it was
- pointed out that all areas in a safety-related building are designated as safety-related areas. Then, if through a review
] of the composite drawing 'for a given area of the plant, it can be detennined that no safety-related equipment exists l the l eqJipment/ system supports Will not be designed to resist
} seismic loads. However, if any safety-related equipment is !
- located in the area, all supports will be designed for seismic a . loads.
1 j y IV-9. What procedures or documentation exist to assure the plant environmental conditions (sprays, radiation, temperature, j 2 pressure, and pipe break loadings) get factored into the design
" of the safety-related equipment?
m J Response l
' )
See Attachment C, Audit Checklist Questions and Responses, R. ,
.,3 !
N. Curran, Audit, question 5A.
k IV-10. What action has S&L initiated to assure that the plant design considered the NRC concerns noted in IE Bulletin 79-027
}
Re sponse p
L.
An installation specification was written covering the instal-lation of concrete expansion anchors: Standard Specification for Concrete Expansion Anchor Work, Aug.1976. Tnis specifica-I tion is imposed on all contractors involved in the installation of concrete anchors. It requires the contractor to develop an
- installation procedure, including the use of a traveler for a each anchor documenting the installation and inspection.
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B-13 121-8 O
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h, To determine the flexibility of the base plate, an extensive test program was carried out to determine the allowable load-ings without overstressing the expansion anchors. This program was reported in " Static, Dynamic and Relaxation Testing of Expansion Anchors in Response to NRC IE Bulletin 79-02",
7/20/81.
The results of this testing formed the basis for the design loading on the standard configuration base plates. This report is currently under review by the NRC.
l E
V. . Analysis Control V-1. Are the seismic loading criteria imposed into the stress analysis and testing of the systems, structures, and components?
Response
To assure that the proper seismic loading is used for design analysis and testing, a seismic design criteria docunent containing the seismic loading throughout the plant has been generated. This docunent is for use by the project design staff. On the Byron and Braidwood project this document is
" Development of Seismic Subsystem Design Criteria .and Response l
Spectra", DE-ST-04-BB, Rev. O, 3/23/82. This document was used to determine the seismic loading for subsystem analysis and testing. It has been updated periodically aad on 3/23/82 it was changed from an engineering report to a controlled doctrnent j
and released as Revision 0. This type of document should aid l
l in getting the proper seismic loading used in both test speci-1 fication and in stress analysis. y Are the system loadings (pressure, temperature,, and fluid y l
V-2.
' momentum) factored into the stress analysis for the system? J B-14 121-8 -
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Response
Yes - The ASME design specifications for the systems do specify the loading conditions. These loads are being used in the stress analysis. The design specification, stress analysis,
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and drawing correlations were checked in detail on the LaSalle County project and found to be in agreement. The high pressure
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core spray line was checked. The Design Specification DS-NP-01-LS, Revision 2,11/16/81, defined the ASME Code as the' 1974 edition, no addenda, and gave both the design and operating I conditions. The stress analysis report for the high pressure
- line on Unit 2 was Subsystem 2HP-01, Vol 45, Quad 1-98-937, EMD
- 035336, Rev.1, 2/8/82, referenced in response to audit question III-2. The analysis referenced the design speci-fication and used the design conditions as stated.
l On the Byron and Braidwood project the analysis checked (see analysis for the auxiliary feedwater system referenced in the response to audit checklist question III-2) did not thoroughly i
reference the ASME design specification. In checking further it was found that the design specification was not in existence j
when the analysis was completed (the original analysis was dated 9/8/75 and the design specification was dated 3/15/82).
- A. review of the design specification and the analysis indicated j
that the design conditions used were as specified. It was S&L a staff's opinion that the ASME Code did not require the design specification to be completed before the design effort for the
- system was initiated. It is the auditor's understanding that J -
this issue has been addressed in an earlier CECO audit.
r L V-3. Are the piping system supports and component support loadings factored into the design of the structures (concrete and P
a steel)? .
1 121-8 B-15 4
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Response
$^
The interface between the piping analysis (support loadings) and the design of the structures was very good. As noted in g response to audit questions IV-5, IV-6, and IV-7, the applica- E i tion of the project instruction which governed this interface
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i being very effectively applied. In addition, in response to
's h audit question IV-3, it was detennined that integration of the NSSS vendor piping support loadings into the design of the
' structures was also effective even though no fonnal procedures or instructions governed this interface.' ;
Y -4.* Do procedures / specifications governing the loading case combinations for the system, structures, and components exist?
Response
l Procedures do exist and were found to be very thorough. See response to audit question IY-1.
Y - 5. Are the loading conditions and combinations generated and specified in the component / systems design specification and are they imposed on the analysis process?
Response
Yes - As noted in response to audit question Y-2.
Y-6. Are analysis reports identified back to the ;ystem configura-tion by drawing nunber and revision?
Resoonse i
In the analysis reviewed during the audit, it was found that i the analyses referenced applicable docunents (drawings, B-16 121-8
4 specifications, and ASME Code) giving the revision numbers and or addenda. The correctness of these references was documented I when reviewing the high pressure core spray analysis referenced in response to audit questions IV-2 and V-2. In this check, the design specification, DS-HP-01-LS, imposed the 1974 edition, no addenda, of the ASME Code. The analysis was then checked to determine if the analysis used the proper l
references. Both the Unit 2 and 1 analyses were checked because the HP line Unit 2 was not analyzed in detail but I referenced the Unit 1 analysis and made a geometry comparison between Units 1 and 2 to determine if- the Unit 1 analysis was l
appropriate. (The comparison concluded that Unit 1 analysis was appropriate.)
! The Unit 2 analysis (subsystem 2HP-01, Vol. 45, QUAD 1-81-937, Rev.1, 2/8/82) referenced the M-938 SH1, Rev. L, 4/10/81 Unit f 2 drawing and the M-1040-01, Rev. J, 4/21/81 Unit i drawing.
I Both were the drawing revision in effect during the analysis.
In checking Unit 1 stress report, it'was determined that the proper 1974 ASME Code was used. Later revisions of the above l
drawings have been released since the above analyses were l
completed. These design changes are currently in progress.
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3-17 121-8 E
AUDIT CHECKLIST gg7g June 7 thru 12 ENERGY INCORPORATED 10 PAGE: 1 OF ORGANIZATION TO BE AUDITED: AUDIT NO: AUDITOR:
Sargent & Lundy RJ11arris CHARACTERISTIC REFERENCE DISP
- COMMENTS
- 1. Document Co' n trol See response to audit questions following this audit checklist.
- 1. Are the following engineering documents GQ 3.07, 4.01, ACC controlled (distribution, traceability, 5.01 & 3.12 and revision)? John Wojeik/
Drafting Supv.
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- a. Procedures c. Reebel -
D.C. - LaSalle
- b. Specifications DJ
,L c. Drawings l
- 2. Are the following engineering Bruce Rarduhn ACC analysis reports controlled (maintained , Mechanical Project l revised)? Engineer ,
i
- n. Stress analysis .
- b. Transient analysis
- c. Shielding and critica.1.ity
- DISPOSIT;UN: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY FORM OA-Ol4 (REV. 2, 4-82) CHECKLIST APPROVED B i fd / ANW T-X-N w a gn::3 m m m m m m m M M m " M m M M C
AUDIT CHECKLIST g ,7g aune 7 thru 11 CONTINUATION SHEET 2
f{] ENERGY INCORPORATED PAGE: OF 10 CHARACTERISTIC REFERENCE DISR' . COMMENTS .
I. Document Control - (Con' t) GQ 5.01 ACC
+
- 3. Are revisions at the analysis, -
specification, or drawing level fed ~
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back through the system to determine the effects of all levels (analysis, .
specification, design) in the design.
II. Engineering Procedures QA Hanual Section ACC o, 3.03
,'. 1. Do procedures exist that control design Dept. Standard
'* reviews from a requirements, SAS-2, Rev. 2 scheduling and documentation stand- Proj. Instruction point - (by system, by plant area, PI-LS-06 etc.) PI-LS-08 Hr. S. Kazmi Struct. Eng. Div.
- 2. Do the procedures governing second GQ 3.07, 3.08, ACC
- Icvel reviews identify by who and how 3.12.1 & 4'.01 the reviews are to be completed and nre the reviews documented? .
- 3. Do the procedures governing design Proj . Instruction ACC groups cover the following inter- PI-LS-27 and
- faces? Dept. Standards HES 5.5.1 & 5.6.1
- DISPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION D E = DEFICIENCY FORM OA Ol4 (REV. 2, 4-82)
AUDIT CHECKLIST g ,7g;aune 7 thru 11 CONTINUATION SHEET (S)'
'L
' ENERGY INCORPORATED PAGE:
3 OF to CHARACTERISTIC REFERENCE DISR* COMMENTS II. Engineering Procedures - (Con't)
- a. Civil / Mechanical
- b. Mechanical / Electrical
- c. System Response / Mechanical
- d. Shielding / Civil m 4. Do the engineering procedures specify Proj . Instructiona ACC 4 the signatures approval requirements PI-BB-10, Rev. I c and are they adequate to assure Ron Rakowski proper design interface control? Mech. Proj . Eng.
- 5. Is the computer program verification GPO 4.1 ACC procedure adequate and implemented? Judy Yamamota With Nancy llolmen Commen :
- DISPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY FORM OA-ol4 (REv. 2, 4 02)
MI ** M M M M M ^
M M M M M M M M M M M___
. :. :. La t_a c2::r e r m m usar w m=r,m - 1er,a nm - s r,w r AUDIT CHECKLIST g,7g;aune7.th,,[i CONTINUATION SHEET ENERGY INCOHPORATED 4 OF 10 l
. PAGE:
CHARACTERISTIC REFERENCE DISR' COMMENTS.
III. Computer Program Verification John Gray ACC Alfred Pebler I
- 1. Is there a list of properly B&B Project verified computer programs which j
can be used on the project and does j it contaisi the programs used7 i
l Piping Analysis ACC
! 2. Is the documentation for the
! computer programs such that each IAF-01, B&B and With .
program and program version is? EMD-033718, LC I:ommenL See I::-5
'us .
j a. Uniquely identified.
- b. Manuals specify version / revision traceability.
- c. Computer output identifies which version of the program the runs were made on.- ,
- 3. Does the project assure that only John Gray B/B programs on the approved verified Alfred Pebble B/B computer program list get used on Guy Deboo/LaSalle -
the project? Std. EMD TP-1, Rev. 0
- DISPOSITION: ACC.: ACCEPTABLE OBS.= OBSERVATION DER = DEFICIENCY FORM OA OI4 (REv 2. 4 62)
AUDIT CHECKLIST g,7 g aune 7 thru ti CONTINUATION SHEET -
(A') ENERGY INCORPORATED PAGE: 5 op to L
CHARACTERISTIC REFERENCE DISR* COMMENTS III. Computer Program Verification - (Con't) Judy Yamamota ACC Nancy llolmen -
- 4. Do computer programs which are not on a verified computer program list get approved by the project prior to use? .
- 5. Ilow.is computer program verification See response to ACC documented? audit questions With ,
11-5 :ommen t Per m
II-5 h
IV. Design Control QA Manual, ACC Dept. Standards,
- 1. Does the design criteria specified FSAR, Project for a project include requirements Design Criteria from the following? R. J. Hetzel Ron Rakowski Bruce Parduhn '
- n. Regulatory Requirements.
- b. Codes and Standards. .
- c. Client Imposed Requirements. .
- DISPOSITION ACC.: ACCEPTABLE OBS.= OBSERVATION . DEE = DEFICIENCY ronM OA-oi4 (nEV. 2, 4 82)
J oc~> W R M M M M M M --
M M " m m W m M c
AUDIT CHECKLIST g ,7g; aone 7 esto 11 CONTINUATION SHEET Q'p' ENERGY INCORPORATED . PAGE: 6 op to CHARACTERISTIC REFERENCE DISR' COMMENTS IV. Design Control '- (Con' t) Bruce Parduhn ACC
- Design Spec.
- 2. Doest'he criteria get imposed at the US-IIP-01-LS engineering design level on the pro- Piping Analysis .
AMD-033718 Ject and is it effective?
Does the design information (loadings, Ron Rakowski OBS 3.
configuration, operational controls D. C. Patel
- and revisions to same) from the NSSS S. Kazmi vendor get into Sargent and Lundy GE and Westing-design' process and is it effective? house hanger ,
w load reports e' > Dwg. IILS-373 Are the design interfaces between Project ACC 4.
the following design groups adequately Instructions identified and controlled?
9
- a. Mechanical / Civil
- b. Nuclear / Mechanical
- c. Civil / Electrical .
- d. Mechanical / Electrical 08S.= OBSERVATION D$E = DEFICIENCY ,
- DISPOSITION: ACC.= ACCEPTABLE FORM OA-Ol4 (REv. 2, 4 82)
AUDIT CHECKLIST DATE. aune 7 thro it es CONTINUATION SHEET
() ENERGY INCORPORATED PAGE:
7
_ OF 10 CHARACTERISTIC REFERENCE DISP
- COMMENTS IV. Design Control - (Con't) Ron Rakowski ACC PI-BB-14
- 5. Does the results of the analysis Transmittal F-150 (such as piping support locations, nozzle loads, structural steel sizing, component support loads, etc.) get . ,
factored into the design process (design drawings or equipment. specifi-cations)?
- 6. Does a change at the design (drawing) level get re-verified by analysis if an analysis was involved in the original design?
- 7. Are field change requests acted on and approved by the same engineering organizations that approved the original design and is that action timely?
- DISPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY FORM OA-014 (REV. 2, 4 82)
M M M M M M M w. e*
- M C E W Q l +2 > L__M Q M wew
AUDIT CHECKLIST DATE. aune 7 thru it e
(* CONTINUATION SHEET ENERGY INCORPORATED 8 OF 10 2 . PAGE:
CHARACTERISTIC REFERENCE DISR' COMMENTS lV. Design Control - (Con' t) Ron Rakowski ACC Ken Green
. 8. Are the safety related system B/B Project structures, and component protected ,
(separated) from the non-safety related equipment? What procedures .
exist to identify safety related systems from non-safety related system on the plant composite drawings?
Y U 9. What procedures or documentation - R. N. Curran ACC exist to assure the plant environ-mental conditions (sprays, radiation, temperature, pressure, and pipe break loadings) get factored into the design of the safety related equipment? ,
- 10. What action has Sargent & Lundy R. J. Netzel ACC, initiated to assure that the plant Sr. Proj . Eng. B&B design considered the NRC concerns Reports Std. Spec .
noted in IE Bulletin 79-027 for Concrete Ex-pansion Anchors Statis Dynamic &
Relaxation Testiog
..w..........~.,vi ... ,tesi.casc to "hC IE-nullctias 7" 02
- DISPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY FOnu OA.ol4 (REY. 2. 4 82)
AUDIT CHECKLlST DATE:
June 7thruti CONTINUATION SHEET f[b) ENERGY INCORPORATED PAGE: 9 OF 10 CHARACTERISTIC REFERENCE DISP' COMMENTS V. Analysis Control Ron Rakowski ACC B&B Seismic
- 1. Are the seismic loadings criteria Criteria imposed into the stress analysis and Development of
- testing of the systems, structures, Seismic Subsysten and components? Design Criteria and Response .
Spectra DE-ST-04-BB
- 2. Are the system loadings (pressure, Bruce Parduhn ACC ,
temperature and fluid momentum) y factored into the stress analysis L
a for the system?
- 3. Are the piping system supports and S. Kazmi ACC component supports loadings factored Ron Rakowski into the design of the structures (concrete and steel)?
R. J. Netzel ACC
- 4. Do procedure / specification governing the loading case combinations for the Structural system,'struetures, and components Project Design .
Criteria B&B, exist?
DC-ST-03-BY/BR Rev. 8 Section 10
- OlSPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY ronM oA-oli (nEV. 2, 4 82)
M M M M g g M
C @ @ M M J- M M .v ,~ - ...-
AUDIT CHECKLIST 037g: aune 7.thru it i
CONTINUATION SHEET 10
]O{ ENERGY INCORPORATED ,
PAGE: 10 OF CHARACTERISTIC REFERENCE DISR* COMMENTS.
V. Analysis Control - (Con' t) ACC
- 5. Are the loading conditions and combinations generated and specified in the component / systems design specification and are they imposed on the analysis process?
h
- 6. Are analysis reports identified ACC
, back to the system configuration by *
.y drawing number and revision?
. !j l
I l
- DISPOSITION: ACC.: ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY FORM OA Ol4 (REv. 2, 4 82)
v I
4
- ATTACHMENT C AUDIT CHECKLIST QUESTIONS AND RESPONSES
" R. N. CURRAN h
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- 46-18 1
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AUDIT CHECKLIST QUESTIONS AND RESPONSES 0-Checklist Item Number Question / Response i'
Q
- 1. Are the NSSS and S&L design interface controls, procedures, I and lines of communications established and implemented for review, approval, release, distribution, and revision of documents involving the following?
- a. Reactivity control
~
L b. Reactor shutdown mechanisms 6
- c. Reactor safety systems 3 .
I Response L
d
$ Design interfaces between the NSSS supplier and S&L occur in only the area of actuation of ESF equipment. Specifications for these actuation circuits are provided by the NSSS sup-plier. Reactivity control, reactor shutdown mechanisms, and f reactor safety systems, other than ESF equipments, are the responsibility of and are supplied by the NSSS supplier.
l l
Changes in NSSS design are transmitted to S&L as a Field Change Notice in the case of Westinghouse and Field Devia-tion Dispositions Request in the case of General Electric.
In reviewing Field Deviation Disposition Request HAI-1511 for LaSalle County and Field Change Notice CAEM-10585 for
' Byron /Braidwood, it was found that review, approval, revi-sion of documents, release, and distribution of documents h were in accordance with the provisions of S&L QA manual i GQ.07 Section 4, Revisions.
a c-1 45-18 3
3 -
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- 2. Do the ' engineering analysis personnel interface, for j
example, in establishing safety system configurations and in establishing instrument accuracies, stability, and response j
time and is this effort documented?
Response _
All interfaces between analysis and engineering personnel occur within the NSSS supplier organization. There is no direct contact with S&L unless a change occurs which impacts S&L design in which case it is hand 1ed as a field change described in question 1.
The subject, therefore, was not pursued.
Does S&L have a documented basis for providing separation of (
3.
1E equipment and cables? In the event of field changes, is there documented verification that the required separation .
is being maintained? '
Response
f i
Separation of 1E equipment and cables is specified in the FSAR.
Minimum requirements are described in S&L specifica-tion F/L-2788, including reference to the requirements of IEEE-420-1973.
Separation of cables, conduits, and trays is specified in Separation design criteria DC-EE-01-BB Revision 8, 9/1/81.
of IE equipment is specified by the design criteria for the 1E system on a case-by-case basis.
Computer codes, Electrical Design and Drafting Procedure for Cable Information System CIS-4 Input, EDSB-127, and Elec-trical Design and Drafting Procedure CIS-4 Output Reports c-2 46-13
g,
}..
and Cable Tabulation EDSB-128 are used to route cables or to
[ verify routing' for the purpose of maintaining separation of Byron /Braidwood. Similar codes designated CIS-3 are used f for LaSalle County.
Verification of separation and isolation is documented in j the Safe Shutdown Analysis for Byron /Braidwood. This docu-ment will become part of the Fire Protection Report in the -
FSAR.
Does S&L have a 1E grounding and shieTding policy? Is any
{
4.
specific recommended practice followed, e.g., IEEE or Air Force Rocket Propulsion Lab manual? Is adherence to the
( grounding and shielding policy controlled?
7 Response y
Grounding and shielding standards are defined in EA-216 f~ which includes seven shielded cable standards and 39 ,
grounding standards. Control of grounding and shielding is provided by installation drawings such as 6/20 E-0-3301A.
Revisions of these drawings are given the same level of h- ,
review and approval as the original drawing.
u Is qualification of IE equipment controlled with respect to
[ 5.
the following?
{
I a. What design document specifies the environmental r
conditions under which 1E equipment must operate?
- b. Is certification of qualification required from vendors of IE equipment and are the certification requirements in accordance with the design document specifications?
3 .
3 j .
46-18 c-3
)
. h
- c. What procedures govern review of vendor qualification reports and are these reports reviewed for adequacy by qualified S&L personnel?
Response
The FSAR specifies environmental conditions under which IE equipment must operate. Qualification reports are required of vendors of IE equipment. These reports are reviewed by engineering personnel for Byron /Braidwood and by the CQD l
~
personnel for Lass 11e County.
Each qualification is documented and includes S&L specifica- g tions, vendor's qualification report, and engineering's or El CQD's evaluation documents and acceptance reports. Reviewed were qualification documentation for Okonite and Rockbestos 600-volt' cable, S&L specification F/L 2823; Okonite 5 and 8 KV cable, S&L specification F/L 2851; .and Samual Moore instrument cables, S&L specification F/L 2852 for Byron /
Braidwood.
Also reviewed for LaSalle County were qualification reports
.for Kerite SKY cable, CQD No. 001978, and Limitorque SMB-3 operator, CQD No. 001667.
- 6. In cable spreading rroms shared by more than one 1E train, is separation provided meeting the fire protection guidelines of Regulatory Guide 1.120?
Response
Separation requirements are specified by the FSAR. Separa-tion of cables is provided by separation of cable trays and conduits. Separation is controlled by the electrical in-sta11ation drawings. Separation of cables is verified by I
46-18
l 4
- g. co5puter codes CIS-3 and CIS-4 as discussed in question 3.
Reviewed were the Fire Safety Report, Safe Shutdown Analy-I sis, and cable spreading room drawings for Byron /Braidwood.
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-- 46-18 c-5 1*
e AUDIT CHECKLIST DATE: June 7 thru 11 ENERGY INCORPORATED PAGE: 1 OF 3 ORGANIZ ATION TO BE AUDITED: AUDIT NO: AUDITOR:
Sargent and Lundy RNCurran CHARACTERISTIC REFERENCE DISP
- COMMENTS
- 1. Are the NSSS and S&L design interface GQ .07 ACC. See response to' audit questions following controls, procedures and lines of IIAl-1511 this audit checklist.
communications established and imple- CAEM-10585 mented for review, approval, release, J. Esterman distribution and revision of documents T. Thorsell involving the following? V. Naschansky
- a. Reactivity control
- b. Reactor shutdown mechanisms
?
@ c. Reactor safety systems ,
- 2. Do the engineering analysis personnel N/A interface, for example, in establishing T. Thorsell safety system configurations and in V. Naschansky establishing instrument accuracies, stability and response time and is this c[ fort documented? ,
- DISPOSITION: ACC.= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY ronu ca.oi4 intv. 2, 4.sa CHECKLIST APPROVED 'Adda m 3 N.P-
- - - - - ~
- - - - r. - - ==
- m e u.a e a w -
AUDIT CHECKLIST . gg7g June 7 thru 11 CONTINUATION SHEET f( '
ENERGY INCORPORATED PAGE:
2 OF 3
i CHARACTERISTIC REFERENCE DISP
- COMMENTS
- 3. Does S&L have a documented basis for GQ .07 ACC.
providing separation of IE equipment FSAR and cables? In the event of field F/L-2788 l changes is there documented verification
~
CIS-3 and 4 -
l i
l that the required-separation is being IIAI-1511 maintained? CAEM-10585 l R. Schiavoni J. Esterman T. Thorsell V. Naschansky M. Murskyj T. Eisenbart K. Green ,
9 Does S&L have a IE grounding and EA-216 ACC.
4.
shielding policy? Is any specific 6/20 E-0-3301A recommended practice followed, e.g.,
J. Esterman IEEE or Air Force Rocket Propulsion 18 adherence to the V. Nashsh Lab Manual?
grounding and shielding policy controlled 1 Is qualification of IE equipment CQD #001978 ACC.
5.
controlled with respect to the CQD #001667 following? F/L 2823 F/L 2851
- a. What design document specifies F/L 2852 the environmental conditions FSAR app. M under which IE equipment must IPS-364 ,
operr.te? rlUREG OJ88 Reg. Guide 1-60 085.= OBSERVATION DEE = DEFICIENCY
- DISPOSITION: ACC.= ACCEPTABLE FORM OA-Ol4 (REV. 2, 4 82)
AUDIT CHECKLIST g37g; June 7 thro il ENERGY INCORPORATED 3 3 PAGE: OF CHARACTERISTIC REFERENCE DISe* COMMENTS
- b. Is certification of qualification J. Sinnappan required from vendors of IE V. Naschansky equipment and are the certification T. Eisenbart requirements in accordance with the M. Hurskyj design document specifications?
- c. What procedures govern review of vendor qualification reports and are these reports reviewed for adequacy by qualified S&L personnel? ,
? 6. In cable spreading rooms shared by more Fire Safety ACC. .
O' than one IE train is separation pro- Report Safe vided meeting the fire protection Shutdown Analysis guidelines of Regulatory Guide 1.1207 6E-0-3390 et.al.
6E-1-3361 6E-1-3362 CIS-3 and 4 J. Esterman, ,
V. Naschansky
- DISPOSITION: ACC= ACCEPTABLE OBS.= OBSERVATION DEE = DEFICIENCY FORM QA-Ol4 (REV. 2, 4-82)
M M M e n.' M M M ~~w M M M M M M M M M M U
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ATTACHMENT D E ,
- ASSESSMENT OF THE COMMONWEALTH EDISON COMPANY AUDIT TEAM I
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1.0 INTRODUCTION
- The unique approach of two independent audit teams preparing for the audit and auditing at .the same time provided several benefits:
L (1) The opportunity for the EI/FI team to assess the performance of h the CECO audit team.
L (2) Less disruption to the organization being audited than if the E audits were being conducted at different times.
- (3) Allowed the EI/FI team members to benefit from the CECO team
- members' intimate knowledge of the way Ceco and S&L functioned.
] Therefore, the EI/FI personnel were able to function efficiently much sooner than would normally be the case.
L -
~7 Provided the opportunity for the EI/FI team to review the CECO (4) audit questions prior to conducting the audit and thereby being assured that the audit was comprehensive.
This attachment contains the EI/FI assessment of the Ceco audit team's L performance. This assessment is provided to give CECO Quality Assurance
- Management an independent evaluation of their audit team's effectiveness.
2.0 ASSESSMENT R. N. Ferguson (Team Leader) q a
It is this auditor's assessment that the two independent teams approach utilized by CECO for the 1982 S&L audit is very effective. Mr. G. Marcus' extensive experience in both QA and as a team leader was apparent in all phases of the audit. The audit was well organized and managed. The audi-tors I worked with were: Mr. M. Stanish, Mr. B. Harl, and Mr. E. Martin.
All three of these individuals are senior personnel with considerable
- ]5 experience in the audit areas they were assigned, as well as the process of 46-20 D-1
l
- how to audit and, as would be e'xpected, perfomed in a professional and thorough manner.
R. J. Harris (Auditor)
During the audit preparation and the audit I worked with Mr. Mike Gorski and Mr. Al Montalto. Both auditors prepared well for the audit and had obviously been through the audit process before. Mr. Gorski's technical background qualified him to audit both the Quality Assurance program and the technical work completed by S&L. Mike was able to review the FSAR comitments and translate them into thorough audit qu'estions. During the audit he knew where to look for the infomation and was able to assess the information given. When required he was able to ask additional questions necessary to determine if S&L was effectively meeting the FSAR comit-ments. Mr. Montalto did an excellent job in preparing the audit checklist and was well aware of the design requirements for the pipe hangers. Hi s audit approach was good and he definitely knows his way around the S&L organization. However, his limited educational background effected his
~
ability to interpret other analytical methods used by the analyst to design the hanger supports. ,
R. N. Curran ( Auditor)
- During preparation for the audit and during the audit I worked with Mr. Tom Sommerfiel d. Both during preparation and the audit it was obvious that Mr.
l Sommerfield had previous audit experience. Mr. Sommerfield's engineering background and quality assurance experience qualified him to audit the technical aspects of the S&L engineering work as well as the Quality Assur-1
- ance program.
Mr. Sommerfield prepared his audit questions from a review of the FSAR.
During the audit he knew what questions to ask to gain access to the infor-l mation necessary. to determine if S&L were effectively meeting their FSAR requirements. During the audit Mr. Sommerfield exhibited considerable d I competence in assessing the technical information provided him.
1 J
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46-20
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