IR 05000410/1985018
| ML17054B730 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/14/1985 |
| From: | Lewis G, Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17054B729 | List: |
| References | |
| 50-410-85-18, NUDOCS 8506260722 | |
| Download: ML17054B730 (22) | |
Text
U.S.
NUCLEAR REGUl ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Division of equality Assurance, Vendor, and Technical Training Center Programs equality Assurance Branch Report No.:
Docket No.:
Licensee:
Facility Name:
Inspection At:
Inspection Conducted:
Inspection Team Members:
Team Leader:
Mechanical Systems:
50-410/85-18 50-410 Niagara Mohawk Power Corporation Nine Mile Point
Stone and Mebster Engineering Corporation, Cherry Hill, N.J.
May 21-24, 1985 G.
S.
Lewis, Inspection Specialist, IE T.
Del Gaizo, Consultant, MESTEC Services S. Klein, Consultant, MESTEC Services Mechanical Components:
J.
Blackman, Consultant, MESTEC Services Civi1/Structural:
Electrical/I8C:
A. Unsal, Consultant, MESTEC Services J.
Kaucher, Consultant, MESTEC Services Present at exit meeting:
J.
L. Milhoan, Section Chief, IE S.
Ebneter, Director, Division of Reactor Safety, Region I G adstone S.
Lewis, Jr.
Team Leader, IE
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'ate Approved by:
James
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hoan Section hi f
~ equality A s rance nch gqgggeo7ZZ 8~o PDR ADOCK 0500041 PDR
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Background Nine Mile Point - 2 Engineering Assurance In-Depth Technical Audit Implementation Inspection Report May 21 through 24, 1985 In a letter dated April 3, 1985, Niagara Mohawk Power Corporation forwarded to the NRC program plans for completion of the Engineering Assurance In-Depth Technical Audits of the Nine Mile Point 2 (NMP-2) Project and an Overall Audit Plan, guality Assurance Auditing Division, for an audit of the as-constructed condition of the Reactor Core Isolation Cooling System and associated structures at Nine Mile Point 2.
These plans were subsequently revised; viz.,
EA In-Depth Technical Audit Revision I dated April 18, 1985 Overall Audit Plan, guality Assurance Auditing Division, Revision
dated April 15, 1985.
NRC inspection activities of the NMP-2 audits are being conducted in three phases:
Inspection of program approach (review plans and procedures)
Inspection of program implementation Inspection of audit results and corrective actions.
The NRC's inspection of the program approach was conducted az Stone 5 Webster Engineering Corporation headquarters in Boston, MA on April 22 and 23, 1985.
That inspection addressed both the In-Depth Technical Audit and the Overall A d't e
NRC s report of that ~nspection was forwarded to Niagara Mohawk Power era u i Corporation on May 10, 1985 (NRC letter from B. K. Grimes to C.
V. Mangan).
This present inspection report addresses the second phase of NRC inspection, implementation of the program plan and supporting procedures relative to conduct of the In-Depth Technical Audit of the Reactor Core Isolation Cooling System.
The NRC's inspection of implementation of the program plan and procedures for the In-Depth Technical Audit was conducted at the site of the audit at the Stone 5 Webster Engineering Corporation's Cherry Hill Operations Center in Cherry Hi11, N.J..
2.
Purpose The purpose of this inspection was twofold:
'a ~
b.
To ensure that the In-Depth Technical Audit was being conducted in accordance with the approved program plan and supporting procedures.
To ensure that the In-Depth Technical Audit was being conducted in sufficient technical depth and detail to achieve NRC objectives of measuring the adequacy of the design and the effectiveness of the design process at NMP- ~
~
3.
NRC Inspection Team The inspection was conducted by NRC personnel, with the support of contractor personnel as follows:
~Assi nment Team Leader mechanical Systems Electri ca 1/I8 C Hechanical Components Civi1/Structural 4.
Personnel Contacted Name/Position G.
Lewis, Inspection Specialist, IE T.
Del Gaizo, Consultant, WESTEC Services S. Klein, Consultant, MESTEC Services J.
Kaucher, Consultant, MESTEC Services J.
Blackman, Consultant, WESTEC Services A. Unsal, Consultant, Harstead Engineering A large number of Niagara Mohawk Power Corporation (NNPC) and Stone and Webster Engineering Corporation (SWEC) personnel were contacted during the four day inspection.
The following is brief list of key personnel involved in the inspection:
Name J.
Lord C. Terry R.
Twigg W. Curtis R. Fortier H. Mooncai W. Nowicki R.
Heine W.
Pananos G. Bushnell 5.
General Conclusions Or anization SWEC NMPC SMEC SMEC SMEC SWEC NMPC SWEC SMEC SWEC Position Manager of Engineering Assurance Manager of Nuclear Engineering Audit Team Leader Audit Coordinator Power Systems Auditor Electrical Auditor Electrical Auditor Controls Auditor Structural Auditor Engineering Mechanics Auditor The following general conclusions are provided relative to implementation of the program plan and the depth of review observed by the NRC Inspection Team during the course of the inspection.
-2"
'
a.
The NRC team noted that in some instances the review was not conducted in a sufficiently comprehensive manner.
In some instances, corporate procedures, design guides, and computer codes were accepted by the auditors without verification against regulatory design requirements or commitments.
In some instances, auditors were making conclusions as to design adequacy without sufficiently investigating the design process of the project.
In several calculation reviews, the question of assumptions which require further verification were not being identified by the auditor and evaluated for adequate control or tracking by the project.
In several cases, calculation reviews did not evaluate the validity and appropriateness of'omputer codes used in the calculation.
Several disciplines were not reviewing Advance Change Notices (ACN's),
which are in general use as design control documents.
The audit was not verifying that field changes are being developed and subsequently approved consistent with the original design basis for the system.
C.
In some instances, potential action items were informally presented to project personnel for comment prior to formally preparing an action item which is not in accordance with audit procedures.
II There was a concern relative to the potential auditability of the documentation such as the auditor's review supporting the final report of the EA team.
Specifically, where an attribute on a review plan was indicated as SATISFACTORY, there was inadequate documentation of the auditor's basis for the conclusion.
(Note:
where an attribute was identified as UNSATISFACTORY, sufficient documentation was usually provided.)
6.
Specific Comments Specific comments of individual NRC discipline reviewers are provided in Attachment 1.
These comments elaborate on the general comments of section
above, and in some cases provide additional comments not considered to be of a general nature.
7.
Previous Inspection Concerns During the course of this inspection, the NRC review team evaluated action taken in response to NRC concerns raised during the previous inspection of the program approach as detailed in the NRC letter of May 10, 1985.
Mhere some concerns were not yet fully resolved, these concerns were reiterated during the exit meeting on May 24, 1985.
Formal responses to either these remaining concerns or the implementation concerns identified in this inspection report are not required.
The final audit report will be reviewed to determine whether resolution of these concerns has been accomplished.
Attachment:
Nine Mile Point 2 Engineering Assurance Program Specific Discipline Comments
f-
Attachment
NINE NILE POINT 2 ENGINEERING ASSURANCE PROGRAM Specific Discipline Comments
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DISCIPLINE:
MECHANICAL SYSTEMS Obs.
No.
1. 1.
Control of Desi n Chan es In most of the ten Engineering Change Notices/Engineering and Design Coordination Reports (ECN's/ELDCR's) reviewed by this discipline, the auditor has researched the condition and made a judgment as to the technical justification of the change, Although this answers the question of design adequacy, it does not address design process effectiveness.
The audit should be examining the project's compliance with its commitments to Regulatory Guide 1.64 (ANSI N45 2. 11) regarding justification of design changes."
Obs.
No. 1.2.
Review of ACN's ECN's
E8DCR's The EA Technical Audit review procedure called for selecting 10 ACN/ECN/E8DCR's which are "substantive design changes."
Two problems were identified by the inspection team:
1.
No ACN's were reviewed.
2.
Several ECN's were less than substantive.
Obs.
No. 1.3.
RCIC Steam Line Dose Rate Calculation The computer code used to derive the output of the calculation (gADMOD) was not verified as being benchmarked or otherwise certified. If the code is not valid, the results of the calculation would be unsupported.
Also, the allowable dose rate upon which the conclusion was drawn (e.g.,
20 mrem/hr allowable)
was not verified by the reviewer to some reference design document.
Obs.
No. 1.4.
HELB/MELB/Floodin There was insufficient documentation available to permit an evaluation of the audit performed in the HELB/MELB/Flooding analysis area by the EA Audit Team.
Obs.
1.5.
Inade uate Substantiation of Review Calculation Review Sheets used in this review plan do not provide adequate substantiation of items which are indicated as acceptable other than a "YES" response to the stated question.
This does not provide sufficient information to assess whether the audit included a review of appropriate documents to support the response.
Obs.
1. 6.
Verification of Assum tions Calculation A10.1H4 Rev.
2 (10/5/83) indicates an assumed pool strainer pressure drop of 0.5 psi.
The cover sheet shows a column to indicate whether such assumptions require later confirmation.
The entry for both Rev.
0 and Rev.
is "NO."
This is not consistent with the assumption made concerning verification of the pressure drop used for this strainer after it was purchased.
Purchase of a strainer which exhibited large pressure drops could affect the results of the calculation.
The calculation review sheet used by the SWEC audit team does not provide for ensuring that assumptions requiring later verification are, in fact, verified, and this was not picked up by the SWEC audit.
While no other occurrence of this type of observation was found in this discipline, since it is not part of the review sheet, it may be generi Obs.
No.
1. 7.
Incorrect Audit Action Item Engineering Assurance Action Item E-P25-0 is incorrect.
Calculation A10.1H7 established the Reactor Core Isolation Cooling System (RCICS)
d h
line size b
d y
eterminsng the pump discharge pressure and accounting for line pump ssc arge losses.
Pump total dynamic head (TDH) is added to minimum required net positive with the use o
suction head (NPSH),
and line losses are deducted.
The EA d t t
k e
au l or oo issue e use of minimum NPSH in establishing pump discharge pressure and issued Action Item E-P25-0 directing that maximum static head should be added to TDH to establish discharge pressure.
This is not correct.
Minimum static head should be used to determine line size (or, conservatively, minimum NPSH required).
(Note:
Action Item E-P25-0 has been revised by SMEC subsequent to this observation to correct maximum to minimum static head. )
S
DISCIPLINE:
MECHANICAL COMPONENTS Obs.
No. 2.1.
Pi e
Su ort Stiffness Check The calculation review plan 1903 calls for checking support stiffness to see if they are within a range acceptable to the piping group.
To see if the interface with piping is adequately reviewed in this area, as per review plan 1909, it is necessary that the effects of supports that do not meet stiffness requirements be checked in the pipe stress area.
Plans weren't developed to do this; however, calculations reviewed showed some evidence of this review.
Obs.
No. 2.2.
Verification of Assum tion guite often, calculations are developed based on information that requires confirmation.
Several calculations were reviewed which have items which require confirmation.
The EA auditor accepted justification for not having these resolved by referencing a
SMEC procedure (PP-93) which was developed after the codes were completed.
This doesn't appear to test the design process used in the original design.
Obs.
No. 2.3.
Field Desi n Chan es There appeared to be inadequate plans to review the technical adequacy of the field change system at the site to assure that the site engineers are technically cognizant of all aspects of the design that are implemented by design changes.
For example, it was not clear whethr the cumulative effects of piping schedule changes were being reflected in the NPSH calculations.
Obs.
No. 2.4.
Calculation U date Re uirements Pipe stress analysis calculations are affected by various input parameters developed from references and other calculations.
If the input sources change, some systematic method must be used to check which calculations are affected.
The EA auditor did not review this aspect of the design process.
Obs.
No. 2.5.
Ade uac of Audit Review Documentation In some instances, the review documentation did not contain sufficient information to adequately portray how the EA auditor arrived at his conclusions.
The extent of meaningful notes varied from none to reasonable.
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DISCIPLINE:
CIVIL/STRUCTURAL Obs.
No.
3. 1.
Limited De th of Technical Audit In the reinforced concrete design area, the EA audit team inspected the design of the Control Building and the RCICs Cubicle.
Both structures are simple in configuration and loadings.
If the inspection is limited to only these two structures, it may be difficult to reach a conclusion on the adequacy of design of concrete structures.
Ob
.
N
. 3.2. S~ii A
A major portion of the seismic analysis is performed using computer programs.
However, the EA auditor did not check the input and output of the various computer programs involved in the seismic analysis of the Control Building.
Obs.
No. 3.3.
Stiffness of Conduit Su orts The EA auditor noted various instances where the stiffness of the conduit supports were not addressed in the SWEC calculation.
The EA auditor did not write an action item on this matter but instead was trying to determine whether it would affect the design.
Design adequacy of the conduit supports are in question.
The NRC team believes the EA auditor should have written an action item on this finding to require a response the SWEC Nine Mile project.
Obs.
No. 3.4.
Plate Flexibilit The EA auditor, in the review plan, checked that the appropriate methods were used for the design of the conduit support.
Next to the check mark, the EA auditor noted that plate flexibility was not considered in calculating anchor tension loads.
The auditor had not made this an action item.
The NRC inspection team believes that this should have been an action item, to be responded to by the SWEC Nine Mile Point 2 projec I
DISCIPLINE'LECTRIC POWER Obs.
No. 4. 1.
Review of Desi n Process Based on inspection of the EA audit of two electrical E&DCR's; viz., P12209
"Electrical Penetrations",
and P50875 Breaker Replacement" it appeared that the EA auditor did not evaluate the impact of the design changes on the complete design process.
Obs.
No. 4.2.
Potential Action Items Not Formall Identified Potential action items have been identified by EA auditors during the conduct of the electrical review without being properly written up as audit action items.
The EA auditors indicated that these items were informally pr esented to project personnel for initial review and comment.
Two specific examples of this are given:
1)
E&DCR C01871 which concerned the subject of material compatability had listed the materials engineer as "review not required" yet the auditor did not initiate an action item; 2)
E&DCR C43806 "Addition of Top Hat to Safety Related Switchgear" was marked "seismic review required" but no engineering review signature for such a review was on the E&DCR.
Again the auditor did not initiate an action'tem.
Obs.
No. 4.3.
EA Review Re uirement on E&DCR's It appears that prior to the latest revision of PP-94 (E&DCR procedure)
dated August 31, 1985, no formal method or requirement existed for marking E&DCR's for an Eg review.
However, it appeared that the design process prior to this latest revision to PP-94 had not been questioned with regard to Eg review.
Obs.
No 4.4.
FSAR Commitments for Safet -Related Overload Heater Selection In the case of calculations to select heater overloads for safety-related HOVs, a simple calculation and a table are used.
The only input to using this method is the SWEC design guide.
The NRC inspection team was informed that it was assumed that the guide is correct and was not reviewed for compliance with FSAR commitments.
Obs.
No. 4. 5.
Use of Manufacturer's Data in Diesel Load Profile Calculation Calculation EC-32, "Diesel Generator Load Profile", establishes the loads'equencing for DG loading for LOOP and sequential LOOP/LOCA.
The assumptions stated in this calculation seem to indicate that assumed data were used in the calculation instead of actual manufacturer's data.
The team was informed that the auditors had not determined to what extent assumed data were used in the calculation.
When evaluating the adequacy of a calculation, it is necessary to validate assumptions and to ensure that open assumptions are tracked.
The DG Load Profile Calculation in its present form cannot be evaluated for the extent to which assumed data vs. actual manufacturer's data were use I C
DISCIPLINE:
INSTRUMENTATION 8 CONTROL Obs.
No.
5. l.
Auditable Review Plans In some instances, there was lack of sufficient detail to allow the NRC reviewer to fully understand the depth of review.
For example, documentation of reviews did not give an adequate basis for satisfactory findings and thereby cannot be used to judge depth of review or validity of audit findings.
Obs.
No. 5.2.
Calculation Assum tion Setpoint calculation for containment Drywell High Pressure Alarm assumed a
calibration accuracy of 0.25K.
No determination was made to see that this calibration assumption was verified.
Obs.
No. 5.3.
I8C Calculations Only two calculations were reviewed in Plan 1903.
This appears to be too small a sample to get a reasonable judgment on the quality of the design process in I8C calculations.
Obs.
No. 5.4.
Advanced Chan e Notices ACN The I8C EA auditor did not include a review of ACN's within Plan 81910,
"E8DCR's," although they have become a recognized mechanism for accomplishing design change controls.
It is necessary that a sample of ACNs be audited.
Obs.
No. 5.5.
Se aration 8 Isolation Re uirements The IRC audit did not appear to include a review of physical separation and electric isolation aspects of the design and design process to ensure compatabi lity with regulatory commitments.
Obs.
No. 5.6.
E8DCR's There appeared to be an insufficient sample of E8DCR's selected for review; however, the inspection team was informed by the EA audit team management that additional I8C E8DCR's were being selected for review.
Ob.N.5.7.
~P" b1 R
The EA technical audit of I8C problem reports had not progressed sufficiently for the NRC Inspection Team to conduct a meaningful implementation evaluation.
This area will be further reviewed during NRC evaluation of the final EA Technical Audit Repor ~,
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