ML20147D499
| ML20147D499 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1978 |
| From: | Costello J, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20147D412 | List: |
| References | |
| REF-QA-99900507 NUDOCS 7812200020 | |
| Download: ML20147D499 (18) | |
Text
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9:
VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900507/78-02 Program No.
44090 Company:
Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 Inspection at:
Chicago, Illinois Inspection Conducted: August 7-11, 1978 Inspectors: D.k.hAl f/M/7f J. jR. CosteTlo, Principal Inspector Date ~
. ddor Inspection Branch Vq 4 s %+
c/Whv J. 44. Joyfr son, Contractor Auditor Ddte '
Vendor 7nspection Branch Other Personnel:
D. k. hnT;M L 2/2Sh?
J. Rf fair, Applied fjechanics Engineer Dat'e DiWsion of Operating Reactors Approved by:
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C. J.'Mle, Chief, Projects Section Date Vendor Inspection Branch Summary Inspection on August 7-11,1978(99900507/78-02).
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, including specifications for pipe support base plate anchor bolts, design 781220002o
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verification, evaluation of supplier performance, supplier nonconformance and corrective action, and action on previous inspection findings.
The
. inspection involved sixty (60) hours on site by two (2) USNRC inspectors.
Results:
In the five (5) areas inspected two (2) deviations and one (1) unresolved item were identified in two (2) areas.
In the other three (3) areas no deviations or unresolved items were identified.
Deviations:
(1) Design Verification - Contrary to 10 CFR 50, Appendix B, Criterion V, comments on engineering drawings and design criteria doc-uments were not obtained and/or documented from all those making comments (enclosure, " Notice of Deviation," item A).
(2) Supplier Nonconformance and Corrective Action - Contrary to 10 CFR 50, Appendix B, Criterion'XV, Sargent & Lundy does not have procedures for review and acceptance, rejec-tion, or other disposition of vendor NCRs (nonconformance rep (orts) whe they are submitted directly by the vendor to Sargent & Lundy enclosure,
" Notice of Deviation," item B).
Unresolved Items:
(1) Desi tion of procedure GQ-3.12 (gn Verification - Sargent & Lundy's implementa-Project Status Reports) does not appear to be meeting the intent of the procedure (DetailsSection I, paragraph D.3.b.).
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. DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted W. C. Cleff, Mechanical Project Engineer B. A. Erler, Head, Structural Design and Drafting Division
- 0. P. Gupta, Assistant Chief, Structural Design Engineering S. M. Kasmi, Supervising Design Engineer K. T. Kostal, Senior Structural Engineer J. C. LaVallee, Project Manager J. R. Lazowski, Project Leader, Mechanical Design and Drafting Division G. C. Logan, Mechanical Project Engineer L. N. Ma, Supervising Design Engineer
- J. E. McFarland, Head, Qua'iity Assurance Division R. J. Netzel, Assistant Chief, Structural Design Engineering R. Rabin, Quality Assurance Coordinator R. E. Reimer, Quality Assurance Coordinator
- H. S. Taylor, Assistant Head, Quality Assurance Division B. C. Treece, Senior Electrical Project Engineer
- Denotes those present at exit meeting.
B.
Action on Previous Inspection Findings 1.
(0 pen) Deviation '(Report No. 77-03):
Duplicate record storage practices and facilities are not being maintained as required.
Sargent and Lundy (S&L) has proposed to the Quality Assurance Branch (QAB) of NRC an alternate method for complying with the l
regulations.
This matter has not been completely resolved between S&L and the QAB and will remain an open item until resolved.
C.
Pipe Support Base Plate Anchor Bolts 1.
Objectives a.
The design techniques used to obtain anchor bolt pull-out loads including whether plate flexibility was considered in the analysis, b.
The load rating techniques used to obtain anchor bolt pull-out loads including the factor of safety between bolt pull-out loads and design loads.
c.
Installation requirements for anchor bolts including torque requirements and test requirements.
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2.
Method of Accomplishment The following design specifications and calculations were reviewed:
a.
Proposed Standard Specification for Concrete Expansion Anchors, Safety and Non-Safety Related Applications, dated April 16,1976.
b.
, Form 1738 of S&L Standard Specifications, dated July 25, 1977.
c.
Inter-office memorandum, " Design Aids for Selection of Hanger Supports," dated October 14, 1976.
d.
Conauit Support Standard Drawings IE-0-3093 and IE-0-3093H.
e.
Conduit Support Design Verification Calculations for Standard Base Plate Designs.
f.
Piping Support Design Verification Calculations for Standard Base Plate Designs.
3.
Findings The base plate flexibility was not considered in obtaining a.
bolt loads for standard base plate designs.
Anchor bolt loads were determined by hand calculations considering both shear and tension loads on the plate to be reacted to by all bolts equally.
b.
The design specification for anchor bolts gives a table of minimum lift-off loads (the load required to overcome the bolt pre-torque) which are used as design allowable loads and a table for ultimate capacity loads.
The specification requires field tests to be performed on each bolt size to verify the levels listed in the tables.
The current stand-ard specification has a factor of safety of 3.5 for design loads.
The design specification requires field testing of minimum c.
lift-off loads and ultimate capacity loads for each size bolt used.
The specification also requires torque of the bolts after installation.
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The design allowable loads for bolts used with the standard base plates (which did not consider plate flexibility for calculating bolt loads) are a factor of two (2) to three (3) lower than the current allowable loads given in the standard specification, e.
There were no deviations or unresolved items identified in this area of inspection.
D.
Design Verification 1.
Objectives The objectives of this area of the inspection were to determine that procedures have been established and are being implemented that:
I a.
Identify individuals or groups who are authorized to perform design verification reviews.
b.
Require the results of the design verification effort to be clearly documented, with the identification of the verifier clearly indicated, and filed so they are identifiable to the document reviewed and can readily be retrievec.
c.
Require that the extent of design verification take into consideration the importance to safety, complexity, degree of standardization, state of the art, similarity with previously proven designs, applicability of standardized or previously proven designs, known problems and their effects, and changes to previously verified designs.
d.
Identify and document the method by which design verifica-tion is to be performed.
e.
Identify the items to be considered during design verifica-tion by review including selection and incorporation of inputs, necessary assumptions, quality and QA requirements, codes, standards, regulations, construction and operating experience, interfaces, design method used, comparison of output with input, item application suitability, material compatibility, and maintenance features.
f.
Prescribe the requirements for performing design verifica-tion by alternate calculations which shall include perform-ance by a person or persons other than those who performed w
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the original calculation, the review of appropriateness of assumptions, input data, and code or other calculation method used.
The selection of method shall provide results consistent with the original calculation.
g.
Prescribe the requirements for performing design verifica-tion by qualification testing.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Sargent & Lundy Topical Report SL-TR-1A, Revision 5, which establishes QA Program commitments including:
(1)
Design verification covering the use of design review, alternate or simplified calculations, or a qualifica-tion testing program.
This is described in Section 3, Design Control.
(Note: S&L does not use qualification testing as a means of design verification, (item g. of the Objectives) testing is imposed on 3;ppliers through purchase documents, as necessary.)
(2)
Identification of applicable procedures and instructions used to implement the program commitments which are described in Section 2, Quality Assurance Program.
b.
Implementing Procedures to satisfy topical connitments and satisfy items (a) through (f) of the Objectives section above including:
(1)
General Quality Assurance Procedures GQ-3.02 Project Scope of Work GQ-3.03 Classification Criteria GQ-3.04 Design Criteria GQ-3.06 Sargent & Lundy Standards GQ-3.07 Sargent & Lundy Drawings GQ-3.08 Design Calculations GQ-3.09 Foreign Design Documents GQ-3.10 System and Structure Design Reviews GQ-3.11 Design Reports GQ-3.12 Project Status Reports GQ-3.13 Engineering Change Notices I
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. GQ-4.01 Procurement Specifications GQ-5.01 Project Instructions (2) Project Instructions PI-BB-1 Preparation of Project Monthly Engineering Progress Report PI-MH-001 Preparation and Maintenance of the Project Monthly Engineering Progress. Report and Status Report (3) General, Drafting Standards GDS-4.1.1 Processing of Comments on Sargent & Lundy Design Drawings c.
Documents to verify implementation of topical commitments and procedural requirements and to satisfy implementation of (a) through (.f) of the Objectives section.
These doc-uments'are as follows:
(1)
Standard Specification for Concrete Expansion Anchor Work (Standard Form 1738, Revision 7-25-77).
(2) Civil / Structural Inspection Report No.1244 -
- Baldwin Associates.
(3) Wedge Anchor Load Verification, K-2944, Amendment 12, Form 1730, dated July 12, 1978.
(4)
PL 8X23WDF500X6, Containment Spray (CS) Pump Parts List.
(5)
C-8X23WDF500X6A, CS Pump Section Assy.
(6)
C-8X23WDF86X7A, CS Pump General Arrangement.
(7)
Specification F/L-2758A, Miscellaneous Pumps (Safety Category I).
(8)
S-1040, Reactor Pressure Vessel Shield Wall Section and Details Units 1 and 2, (Revision F, March 20,1978).
(9)
S-1067, Containment Building Foundations, Sectional Plan at El. 350'-6".
. (10) S-876, Containment Building Structural Arrangement.
(11) M-906-Sheet 3, Essential Service Water Make up, (Revision A, June 27,1978).
(12) M-532-Sheet 12, Diagram of Essential Service Water.
(13) M-900-Sheet 2, Outdoor Piping Arrangement.
(14) M-2066, P&ID/Ctd, Diagram Component Cooling System Units 1,and 2.
t (15)6E-2-4030VX12,SchematicDiagram,EssentialServkce Cooling Towers Sub Ventilation Fan Dampers (Revision 0, December 19,1977),
(16) 6E-0-3201, Cable Pans, Essential Service Water Cooling Tower Substation (Revision A, June 1, 1977).
(17) 6E-0-40305X03, Schematic Diagram, Essential Service Water Cooling Tower.
(18) 6/20E-1-305HL, Cable Tray Hangers, Auxiliary Building.
f (19) Foreign Drawing Status Program, Complete List of Mechanical Drawings - Project No. 4391/4392/4683/
4684 (July 24, 1978).
(20) Status of Project Specifications - Project Nos. 4391/
4392/4683/4684 - Period Ending June 15, 1978.
(21) System and Structure Design Review Status Report -
Project Nos. 4266/4267 - Period Ending July 21, 1978.
(22) Design Criteria Status Report - Project Nos. 4391/
4392/4683/4684 - Period Ending April 28, 1978.
(23) DC-EF-01-BB, Design Criteria, Engineered Safety Features, Revision 2, August 20, 1977.
(24) System and Structure Design Review Status Report -
Project Nos. 4391/4392/4683/4684 - Revision 6,
-January 31, 1978.
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Findings In this area of inspection one deviation from commitment and one unresolved item were identified.
a.
Deviation (enclosure, " Notice of Deviation," item A):
Sargent & Lundy procedures which implement 10 CFR 50, Appendix B, requirements state in part the following:
GQ-3.04 (Design Criteria)
"The Preparer shall distribute the design criteria to interfacing departments and divisions for. comment....
The Preparer shall maintain a copy of all comments, their resolution and documentations of dif-ferences from the PSAR in file."
GQ-3.07 (Sargent & Lundy Drawings)
"The Project Leader /
Supervisor / Supervising Design Engineer shall distribute the drawing along with a drawing transmittal sheet to interfacing departments and divisions for review and comments....
The Project Leader / Supervisor / Supervising Design Engineer shall maintain a log containing information as to whom and when the drawing was sent for comments and when the comments were received....
The Project Leader /Supervi-sor/ Supervising Design Engineer shall maintain a copy of all comments and their resolution in the file for the project.... "
Contrary to the above requirements, connents were not obtained and/or documented on the following items even-though the documents had been issued.
(1)
C-8X23WDF86X7A, Containment Spray Pumps (Revision 1, February 1, 1978) - No response from two requested to comment.
_(2)
S1617, Auxiliary Building Plan Elevations, 463-4, request for comments transmitted December 16, 1977, on I-130; no response from two requested to comment.
(3) 6E-2-4030VX12,' Schematic Diagram, Essential Service Cooling Tower Sub Ventilation Fan Dampers (Revision 0, December 19, 1977) - No documentation to show transmit-tal for, or receipt of, comments.
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(4)
DC-EF-01-BB, Design Criteria Engineered Safety Features
- No response from four requested to comment.
b.
Unresolved Item Sargent & Lundy Procedure GQ-3.12 (Project Status Reports) states in part:
"In the event that no changes have occurred since its previous issue a revision to a Project Status Report will not be required.
However, if a periodic revision is not prepared... all recipients... shall be notified in wri ting. '...
The following Project Status Report shall be issued....
System and Structure Design ~ Review Status Report (issued quarterly)."
Procedure GQ-3.12 also states in part, "Page numbers shall either indicate the number of the page and the total number of pages or each page shall be numbered and the last page shall be identified as the final page."
The last issue of System and Structure Design Review Status Report for project Nos. 4391/4392/4683/4684 was issued on January 31, 1978. The periodic revision would be due on March 31, 1978, or a written notice would be issued to all recipients; time did not permit a full investigation of
'this matter to determine if a written notice had been issued, or if there were other procedures or instructions with dif-ferent requirements.
Also, the last issue of Project Specifications Status Report for project Nos. 4308/4923 (datedJuly 12,1978) did not clearly identify the last page.
j These items will be further investigated and evaluated during the next inspection.
E.
Exit Meeting A meeting was conducted with management representatives at the conclu-sion of the inspection on August 11, 1978.
In addition to the individ-uals indicated by an asterisk in paragraph A of the Details Sections,
.those in attendance were:
L. E. Ackmann, Director of Services W. A. Chittenden, Director of Engineering R. X. French, Assistant Manager, Electrical Department J. M. McLaughlin, Assistant Manager, Structural Department S. A. Zych, Head Quality Control Division
- S The inspector-summarized the scope and findings of the inspection for those present at the meeting.
Management representatives acknowledged the statements of the inspector and made the following comment relative to the special inspection on pipe support base plate j
anchor bolts.
Sargent & Lundy personnel would like more advance notice of special engineering oriented inspections so they could have the necessary material available and avoid hurried searches for documentation.
Sargent & Lundy management representatives were advised that these comments would be considered in future inspections.
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DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Persons Contacted J. Dudeck, Project Quality Control Coordinator J. Florek, Electrical Engineer -
- A. P. Gillis, Senior Quality Assurance Coordinator D. C. Haan, Project Manager R. Kurtz, Quality C.ontrol Coordinator A. Marcos, Structural Project Engineer S. E. Quinn, Mechanical Project Engineer R. E. Rabin, Quality Assurance Coordinator R. Reimer, Quality Assurance Coordinator M. E. Schuster, Quality Control Coordinator P. Wattelet, Project Manager
- Denotes those present at the exit meeting.
.B.
Supplier Nonconformance and Corrective Action I f
1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for:
a.
Disposition of nonconformances that provide for:
(1)
Measures by the purchaser and supplier for identifica-tion, control, review, and disposition of items or services that do not meet procurement document require-ments.
(2)
Submittal of nonconformance notice to purchaser by supplier which shall include recommended disposition and technical justification.
(3)
Submittal to the purchaser for approval of dispositions containing one or more of the following nonconformances:
(a). Technical or material requirement violated.
(b)
Violated requirement in supplier document approved
.by purchaser.
(c)
Nonconformance cannot be corrected by continua-tion of the original process or by rework.
(d)
Original requirement is not met but the item can be restored so that its function is unimpaired.
(4)
Purchaser disposition of supplier recommendations, verification of disposition, and maintenance of records of nonconformance.
b.
Corrective action that provides for:
(1)
Iden'tification of and timely corrective action for conditions adverse to quality which occur during the procurement process that are the responsiblity of the purchaser.
(2)
Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
(3)
Reporting these conditions and the corrective action to management.
(4) Assuring that corrective action is implemented and maintained.
(5)
Verification of supplier's corrective action system.
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Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Sargent and Lundy Topical Report Number SL-TR-1A, Revision 5:
Section 03.00 (Design Control); 05.00 (Instructions, Procedures and Drawings); and 15.00 (Nonconforming Materials, PartsorComponents).
b.
PSAR (Preliminary Safety Analysis Report), Attachment A (S&L QA Program) for Projects 4808 and 4923:
Sections 17.A.1.5 and 17.A.1.15.
c.
Implementing procedures to assure that procedural controls have been provided to satisfy topical commitments and items
- a. = through b. of the Objectives _ section above:
(1)
S&L QA Procedures:
GQ-2.03 (Review of Client Quality Assurance Program Requirements); GQ-5.01 (Project Instructions).
(2)
S&L Quality Control Procedures Manual:
QCPs 7.5, 5.1, and Notes.
(3)
Project Instruction PI-LS-09 for Projects 4266 and 4267 (Processing of Client Field Change Requests, Nonconform-ance Reports and Sargent and Lundy Engineering Change Notices),
d.
Additional documents related to requirements and S&L' activities:
(1)
Design Criteria for Replication applicable to Projects 4808 and 4923, Section 5.11.7 (Vendor and Contractor Requested Changes, which appears to address design changes and material substitutions which result in drawing or specification revision).
(2) Article 111.8 to Specification Y2797 indicating nonconformances to be submitted to S&L.
e.
Documents examined to verify implementation of above pro-gram and procedural requirements, and to satisfy im-plementation of a. through b. of Objectives section:
(1)
ITT Grinnnell NCR (nonconformance report) Number 1 to Specification Y2741 and approval of proposed corrective action on June 29, 1978, with additional requirements added by Sargent and Lundy Mechanical Engineer.
(2)
Client memo regarding NCR from RCI (Reactor Control Incorporated) for Specification I2922 and S&L memo from Mechanical Engineer to client (licensee) recommending disposition.
(3)
Client memo regarding NCR to Specification J2961.
(4)
Client NCR number 222 for Projects 47.66 and 4267 requiring S&L review and recommendation.
(5)
Nonconformances to Specification H2235 to Tube Turns and approval of proposed corrective action by S&L Mechanical Engineer, l
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. 3.
Findings a.
In this area of the inspection, no unresolved items were identified. One (1) deviation was identified.
(See Notice of Deviation enclosure, item B.)-
b.
Related to this deviation, the Sargent'and Lundy scope of work usually does not require vendors to send nonconformances to specification requirements directly to S&L for review i
and resolution.
Generally, these are sent to the client (licensee), who may request S&L review.
However, on at least one project, S&L scope does include primary responsibil-ity for the review and evaluation of vendor NCRs and proposed corrective action.
The applicable PSAR Section 17.A'.1.15 states that, " Requirements are established in procurement specifications that vendors shall furnish. documentation of any nonconformance.
Sargent and Lundy reviews documented instances of nonconforming parts and components where such nonconformance affects the design...
S&L reviews and makes recommendation... for accepting of nonconformances, discrepancies, deviations or conditions adverse to quality requiring "use as is" or proposed rework or repair techniques."
Also Section 05.01 of the S&L Topical SL-TR-1A requires that, " Activities affecting quality... are. prescribed in documented' procedures which clearly assign responsibility and describe the required sequence of actions.
project Instructions are prepared to provide for... client requirements not addressed in a Quality Assurance procedure."
' No Quality Assurance procedure exists and no Project Instruc-tion has been generated for this project to cover review and recommendation of disposition of vendor NCRs or transmittal to client (licensee) for verification of correc-tive action.
To date, it appears that only one vendor NCR has been received and proposed corrective action made by S&L Mechanical Engineer (See item 2.3.(1) in Method of Accomplishment above).
- c..
S&L scope of work for the projects examined did not include verificatien of implementation 'of corrective action or of sup(4)'and (5) of the Objectives section above). plier's cor b.
Although the specification is generated by S&L, the purchase order and subsequent vendor surveillance activities are not usually within S&L scope.
They are generally handled by the client (licensee).
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C.
Evaluation of Supplier Performance 1.
Objectives The objectives of this area 'of the inspection were to verify that procedures have been ~ established and implemented that provide for:
a.
Establishing that the purchaser and supplier understand the provisions and specifications of the procurement documents.
b.
Requiring,the supplier to identify planning technique.s. and processes to be utilized in fulfilling procurement require-ments.
c.
Reviewing documents which are generated or processed during activities fulfilling procurement requirements.
d.
Identifying and processing necessary change information.
e.
Establishing exchange method of document information between purchaser and supplier, f.
Initiation of pre-and post-award activities, as necessary.
g.
Control, handling, and approval of supplier generated doc-uments.
h.
Control of changes in items or services.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Sargent and Lundy Topical Report Number SL-TR-1A, Revision 5:
Section 03.00 (Design Control); and 07.00 (Control of Purchased Material, Equipment and Services).
b.
PSAR (Preliminary Safety Analysis Report), Attachment A (S&L QA Program) for Projects 4808 and 4923:
Section
- 17. A.1.3.1 (Design of Purchased Equipment).
c.
Implementing procedures to assure that procedural controls have been provided to satisfy topical commitments and items (a) through (h) of the Objectives section above:
GQ-3.09 (Foreign Design Documents).
(1)
S&L QA Procedures:
QCPs titled:
[I S&L Quality Control Procedures Manual:
p (2)
" Review of NDE (Non-Destructive Examination) Proce-L dures"; " Review of Welding Procedures"; " Review of Contract Test and Inspection Documentation"; " Review (ij -
of Contractor's QA Program"; " Evaluation of Fabrication
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and QC Procedures"; and Notes.
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Additional documents related to requirements and S&L b
d.
activities:
Sections 111.1, 111.3, and Specification J 2552-1:111.4 regarding vendor drawing su
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Documents examined to verify implementation of above program and procedural requirements, and to satisfy implementation e.
of (a) through (h) of the Objectives _ section above:
(1)
Vendor Drawings and S&L Status indication:
Crosby Specification J 2941 (Relief Valves):
(a) drawings 05-C-60739, Revisions B, C, and 0; and DS-C-60740, Revisions B and C.
Specification J 2552-part 2 (Electrical Penetra-C (b) tions):
Sams drawing 50014216, Revision C.
ITT Specification Y 2741 (Nuclear Piping):
(c)
Grinnell spool drawings MH 10-1x; MH 10-2x; MH 10-5x; and MH 02-80x, Revision 1.
Lakeside (d)
Specification Y 2797 (NSSS Supports):
9182-23 BE, Revisions 0 and 1; Bridge drawingsAE, Revisions 0 and 1; 9182-2AB, Revision 9182-23 2; and 9182-28, Revision 2.
s Vendor weld procedures and S&L status indication:
49-B-U3b; Revision 0 and 1; 30-B-U3-GF; and 14B-U3b-S.
(2)
Inspection Point Program recommendation to client (3)
Y 2364 (Condensate based on vendor submittal for:
Booster Pumps from Bingham-Willamette); K 2806 (Reactor Feed Pump Turbine Drives from GE).
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(4)
Vendor Surveillance Activities performed for Main Steam Flued Heads from Tube Turns (Purchase Order 2099):
Post-award audit, Quality Control Plan, test reports, and final inspection report.
Note that this type of activity is not in S&L usual scope of wcrk, but was. performed per request of the client (licensee).
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Findings a.
-There were no deviations or unresolved items identified in.
this area of the. inspection.
b.
S&L's scope of-work for the projects examined did not
. include initiation of pre-and post-award activities nor establishing that suppliers understand provisions of the procurement documents (Items (a) and (f) of Objectives section above).
These areas are handled by the client (licensee).
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