IR 05000416/1984048

Insp Repts 50-416/84-48 & 50-417/84-07 on 841105-09. Violation Noted:Failure to Implement Adequate Corrective Action Re Procurement,Receipt & Storage

ML20133D528
Person / Time
Site:	Grand Gulf
Issue date:	12/12/1984
From:	Jackson L, Upright C, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133D444	List: IR 05000416/1984048 ML20133D441 ML20133D461
References
50-416-84-48, 50-417-84-07, 50-417-84-7, NUDOCS 8507220228
Download: ML20133D528 (12)

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UNITED STATES

[pitt 'o . NUCLEAR REGULATORY COMMISSION g .

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< ^ MARIETTA STREET, N f ATLANTA, GEORGI A 30323

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Report Nos.: 50-416/84-48 and 50-417/84-07 Licensee: Mississippi Power and Light Company Jackson, MS 39205

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Docket Nos.: '50-416 and 50-417 License Nos.: NPF-29 and CPPR-119

Facility Name: Grand Gulf I and 2

' Inspection Conducted: November 5-9, 1984 Inspectors: / Tf IT - d' 2 H.' Jacks n' V , I Da'te Signed R. W. Wrigh e $t ~

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h /L r Date Signed Approved byi '/ %

C. MLUpright, $s'ction 0'hief

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Date Signed Division of Reactor Safety 1 -

SUMMARY Scope: .This routine,- unannounced inspection entailed 64 inspector-hours at the

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~s ite during normal duty hours, in the areas of licensee action on previous enforcement matters; onsite design activities; and procurement, receiving, and storage activitie t Results: Of the three areas inspected, no violations or deviations were identi-fied in two areas; one violation was found in the area of procurement, receiving, and storage involving failure to implement adequate corrective action.

8507220228 841211 PDR ADOCK 05000416 G PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• J. D. Bailey, Compliance Coordinator

• K. E. Beatty, Training Superintendent

• J. E. Cross, General Manager

• L. F. Daughtery, Compliance Superintendent

• G. D. Lhamon, Operations Training Supervisor

• D. Little, QA Auditor

• F. Rogers, Manager Plant Operations

• Stewart, Unit 2 Construction Manager

• F. Tanner, Manager, Nuclear Site QA (Acting)

• M. Wright, (Acting) Manager, Plant Operations

• J.-W. Yelverton, Manager Plant Support Other -licensee employees contacted included construction, document control center, and QA personne Other Organizations L. L. Anderson, Bechtel Project Field Engineer P. S. Collins, Bechtel QA Auditor D. A. Lindsey, Lead Piping / Mechanical /QC receiving inspector K. Ellis, Bechtel Lead Clerical Administrator R. Gordon, Plant Design Supervisor

• J. F. Hudson, Project QA Manager T. D. Kinnebrew, QC Mechanical / Piping Inspector G. McClain, Lead Electrical / Mechanical Field Engineer

• C. F. O'Neil, Lead Resident Design Engineer J. A. Quinn, Contract Purchasing Agent L. Radideau, Lead Engineer, Civil R. Rogers, Deputy Group Supervisor, Hanger Supports B. Young, Lead Piping / Hanger Field Engineer NRC Resident Inspector .

• J. Caldwell

• Attended exit interview

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. Exit Interview The : inspection scope and findings were summarized on November 9, 1984, with those persons indicated in paragraph 1 above. The licensee acknowl-edged an unresolved item 50-416/84-48-0 Subsequent to this inspection, the licensee was notified that the unresolved item was being upgraded to violation 50-416/84-48-01; Failure to implement adequate corrective action, paragraph . Licensee Action on Previous Enforcement Matters (0 pen) Violation 50-417/84-01-01: Failure to Provide a Procedure to Control and Evaluate NRC Bulletins and Notices Affecting Unit The inspector examined Project Engineering Procedure (PEP)-5, R0, issued on March 7,1984. This procedure now specifies the requirements for the control and evaluation of NRC Bulletins and Notices for Unit 2. However, this item remains open pending satisfactory resolution of generic reviews being conducted by the licensee under CARS 827 and 84 . Unresolved Items

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Unresolved items were not identified during this inspectio . Onsite Design Activities (37055)

Inspection Objective This inspection was conducted to determined whether the licensee's, archi-tect engineer's, and contractor's onsite design activities, including controls for engineering and construction initiated field changes, is conducted in compliance with the quality assurance requirements described in the facility safety analysis repor Functional Responsibilities for Onsite Design Mississippi Power and Light Company (MP&L) has the ultimate design responsibility for the Grand Gulf Nuclear Station (GGNS) and has delegated this design authority to Bechtel Power Corporation (BPC), who is the A-E/ Constructor and to General Electric (GE), the Nuclear Steam System Supplier (NSSS). The design control programs incorporate measures for identification and control of design interfaces between BPC and G With the exception of_the NSSS, Bechtel's home office in Gaithersburg, ,

Md. initiates and approves the majority of the station desig The Project Engineer has assigned a resident-design group (RDG) to the site to facilitate technical conmunications and interface. This RDG (which

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is an extension of the home office)-is a multi-disciplined engineering group whose' work scope is. determined by the Project Engineer-and includes design activities which can be more efficiently performed at the sit .

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Currently, these design activities include Class I 2-inch and under piping, tubing layout and supports for small bore piping, tubing, instrumentation, seismic conduit, cable trays, and the HVAC syste The Lead Resident Design Engineer has the signature authority of the Project Engineer for the performance of these design activities.

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The BPC design control program commits to the applicable sections and elements of 10 CFR 50, Appendix B; Regulatory Guide 1.28, (Safety Guide 28,6/7/72); and ANSI N45.2-197 Design Procedure Review All activities-(including . control of the design process) of the RDG are governed. by the GGNS Unit 2, Project Engineering Procedures Manua .

The following procedures and instructions from the subject manual were reviewed to verify the adequacy of these documents and to query various

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onsite design staff personnel of their knowledge of pertinent design

! . control requirements contained therei !

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EDPI 2.14-12, R1, Project Engineering Resident Engineers

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EDPI 4.1-12, R0, Design Criteria

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EDPI 4.25-12, R1, Design Interface Control

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EDP 4.27, R0, Design Verification

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EDPI 4.37-12, R12, Design Calculations

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EDPI 4.46-12, R3, Project Drawings

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EDPI 4.47-12, R2, Drawing Change Notice

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EDPI 4.49-12, R2, Project Specifications

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EDPI 4.61-12, R2, Nonconformance Reports & Deficiency Reports '

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EDPI 4.62-12, R2, Change Request Notice Procedures reviewed and knowledge of individuals interviewed were verified to be adequat Design Process Review (1) New Design The inspector conducted discussions with Bechtel engineering personnel from the Resident Civil and Plant Design (small pipe &

pipe hanger) Groups to determine whether they understood their applicable design control procedures and to verify proper implementation of these procedure 'The following onsite Bechtel design criteria, sources of formulae, and references. utilized by the RDG for the design of Grand Gulf's

small pipe and various hanger supports were examined by the inspector:

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Project Design Criteria Manual, R15

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Grand. Gulf Frequency Response Spectra, Calc. C-T2695.0, Rev. 2

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Unitrust General Engineering ~ Catalog No. 10

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Formulas for Stress and Strain, Roark & Young 5th E , - , , - . ,

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Grand Gulf Hanger Engineering Standards, R0

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Design Specification M-300.2, R18, The Design of Pipe Hangers, Supports, Restraints & Anchors

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Design Specification M-18, R19, Office and Field Engineering Users Manual for Routing and Supporting Two Inch and Under Piping

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Design Specification M-1398, R15, Hanger Users Manual Specific to Grand Gulf

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Design Specification No. 9645-C-103.1, R12, Design and Installation of Concrete Expansion Anchors

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Design of Welder Structures

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AISC Manual, 7th E ME 101 Computer Analysis User's Manual Linear Elastic Analysis of Piping Systems (LEAP)

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ME 101 Theory Manual, LEAP The majority of onsite small pipe and hanger support design is accomplished manually; however, the RDG does have and utilizes the ME 101 and CE-901 (STRUDL) standard computer programs (SPCs)

for complicated pipe stress and hanger support analyses respec-tivel The RDG can only provide data input to these SCP Revisions to the SCPs are controlled by the home office and corresponding user and theoretical manuals are updated by home office transmittals to the RD The below listed design calculations and pertinent drawings were selected for examination by the inspecto Discussions were conducted with Civil and Plant Design engineers from the RDG concerning the subject calculations relative to design inputs employed, criteria used, review, approval, and home office inter-face. The applicable drawings were examined for proper identifi-cation, that they were properly reviewed and signed off by a checker (an individual other than the originator who has a level of design qualifications at least sufficient to perform the design work being checked), responsible engineer, group supervisor, interfacing disciplines as applicable, and that revisions to the drawings were processed in the same manner as the origina Calc. No. C-H 2672.2470 Drawing Nos'. HD-2468,-R0, HVAC. Duct Hanger. Locations s Q2T48G020H01 thru 06, RO, Hanger Drawings-Q2T42G004H01.thru 04, R0, Hanger Drawings

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Calc. No. C-H 2672.0154 Drawing No. HD-2453, R3, HVAC Duct-Hanger Locations

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Calc. No. C-H 2671.0, R0 and R2,-dated 6/19/83 Drawing Nos~. Q2T48G003H01, 02; R0, Hanger Drawings 03, 10, 13, 16, 23; R1, Hanger Drawings 15, 17; R2, Hanger Drawings 11, 14, 18; R3, Hanger Drawings

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Calc. No. C-H2686.219, R1, dated 10/17/84 Drawing Nos. 2A-119-0219, R1, Auxiliary Building Conduit Seismic Support

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Cal.'No. C-H2682.0993, R0, dated 12/30/83 Drawing Nos. 2A-121-0016, 0019, Hanger Drawings Hanger Installation and Inspection Records (WP & irs) for Subject Hangers

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Calc. No. Q2E126115C06, RA, dated 9/23/83 Drawing No. M-2548E, Isometric Drawing

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Calc. No. Q2E12C115R07 RA Drawing No. HL-2548E, R0, System Piping Isometric

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Calc. Problem 4004, R1 Drawing No. H-2555A, RA, System Piping Isometric Based on these discussions, review of design procedures and

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criteria utilized, examination of typical piping / support design calculations and drawing controls exercised, the inspector con-cluded that the RDG was performing its onsite design function-in accordance with their PSAR commitments and NRC requirement (2) Design Changes The inspector selected four field change notices (FCNs HM-2-0154, HM-2-0085, EC-2-1193, EC-2-0993) for review to determine the following:

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Reason /need for the change

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' Do the changes compromise the original design intent

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Did the changes receive a-DCN number which required the drawing to be changed

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Were the affected design drawings updated / revised to reflect new. design changes The inspector concluded the subject field change notices had been

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. properly. addressed and handled in' accordance with Bechtel's procedures and commitment Control.of Drawings

~The inspector interviewed personnel responsible for control and distri-

bution of-drawings and design change notices (DCNs) to confirm that the

. latest' revisions of these documents were being used in constructio The following drawings and DCNs were selected for review at contro_lled drawing stations D and AB:

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C-2017, R2' C-2020 N, R2 C-2020 A, R5 C-2020 P, R2 C-2020 8, R3, DCN 1 C-2020 Q, R4 C-2020 C, R3 C-2020 R, R1 C-2020 0, R3 C-2020 T, R2 C-2020 G, R3 C-2020 U, R1 C-2020 H, R2 C-2020 V, R3 C-2020 J, R1 C-2020 W, R2 C-2020 K, R1 Q 2E12G014A03, R0 M-2348 E, R11 M-2553J, R3 Based on the above sample, the inspector concluded that the facilities, control, and distribution of the above documents were satisfactor Design Control by Licensee The inspector interviewed BPC and MP&L QA personnel who are responsible for auditing onsite design activities to determine the following:

.- They were aware that each contractor who prepares and/or issues design documents must be audite Audits were conducted on Bechtel's RDG activities. The inspector examined Bechtel audit report Nos. 2-83-03, 01-84, and MP&L audit report No. MAR 83/2-006 to verify that:

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The audited organization received a copy of the audit repor Appropriate standards were referenced for measure of performanc Auditors were selected in accordance with QA Manual procedure Adverse findings received effective corrective action, were examined for significance, and reaudits were scheduled as necessar Within this area, no violations _or deviations we'er identifie . Procurement, Receiving, and Storage (35065)

This inspection was conducted to determine whether material and equipment .

procurement specifications. include applicable quality assurance (QA) and technical requirements identified in the safety analysis report (SAR) and whether receipt inspection and storage activities are in compliance with the QA progra .

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~ Site Procurement MP&L contracted to Bechtel Power Corporation, Gaithersburg, Md., the

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architect-engineer responsibilities for establishing measures for the preparation, review, approval, and control of procurement document '

The MP&L Unit 2 Project Manager exercises the prerogative to review certain contractor purchases prior to award, based on previously established agreements or on a case-by-case basis. Bechtel performs audits, maintains a Bechtel evaluated supplier list, prepares proposed supplier evaluation lists ard procurement bidders lists for MP&L, and

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provides engineering and quality assurance controls in procurement of safety-related items and service Onsite procurements are limited to those items which have an existing

. approved specificatic Procurement Action Review The inspector selected the following listed procurement item contracts to determine that the following elements had been included:

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Applicable regulatory, technical, and quality assurance require-ments

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Procurement documentation adequately reviewed

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Changes to technical and QA requirements adequately reviewed

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Purchaser notification points, hold points, and access rights incorporated in or provided for in the documentation

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10 CFR 21 reporting requirements appropriately addressed

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Documentation to confirm acceptability of the item required to be furnished

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QA requirements applicable to subcontractors

. Purchase Order Specification -Vendor 9645-2F-5176 9645-C-13 DuBose Steel 9645-2F-5872 9645-C-13 DuBose Steel 9645-2F-4465 9645-C-13 DuBose Steel 9645-2F-6573 9645-M-20 Hub Inc.,

.9645-2F-6019 9645-M-20 Cardinal Industries

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9645-2F-6487 9645-M-20 Guyon Alloys 9645-2F-3877 9645-C-13 ' Interstate Steel 9645-2F-2045- 9645-C-13 Mills Alloy 9645-2F-428- 9645-C-13 Interstate Steel 9645-2F-3095 9645-M-20 Guyon Alloys 8645-2F-3372 9645-M-20 Capitol' Pipe

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During the review of. the ' above listed procurement documents, it was noted that NCR 6606 had been issued on May 25, 1983. This NCR documented that ten penetration closure plates had been installed in Unit 2 containment without performing the prescribed charpy impact testing required by specification 9645-C-151.0. The disposition of NCR 6606 required the material to be impact tested. Subsequent testing of material with heat number 412T2781 met the required average of 20

- foot pounds or greater. The other two heats of material (7427189 and 41150811) did not meet the requirement of 20 foot pounds when tested at zero degrees Fahrenheit. Subsequent testing of heat number 7427189 at 40 degrees Fahrenheit was determined to be acceptable. However, the other penetrations fabricated from heat of material number 411S0811 was revised by DCN #7 to use thicker material and was scrapped. The inspector concluded that NCR 6606 had been dispositioned and handled properl Based on the above information, the inspector further requested to review objective evidence that the closure plates for Unit I had been evaluated. This review of records confirmed that NCR 6314 had been

. issued on January 19, 1982. NCR 6314 documented that containment i penetration closure plate number 73 on Unit I was fabricated from American Society for Testing and Materials (ASTM) A-36 material without charpy impact testing having been performed. ASTM A-36 is not listed in the certified design specification 9645-C-151 as an acceptable materiel for containment closure plate Four other containment closure plates identified on Material Noncon-formance Report (MNCR) number MNCR-00578-83 dated July 9, 1983, and MNCR-00706-83 dated August 3, 1983, have been installed on Unit I without having the required charpy impact test performe Bechtel letter dated June 20, 1983, concluded that the absence of impact tests on these plates did not constitute a safety issue. This con-clusion appears to be based on the lowest service metal temperature exceeding +30 F' and the Winter 1980 Addenda to the 1980 Edition of the ASME Code exempting impact test for normalized SA 516, Gr. 70, plate in (

thicknesses under 2 inches under qualified condition . Within this area, one violation was identified. The disposition of NCR 6314 for the ASTM A-36 material'to "use-as-is" is also based on the lowest sevice metal temperature and the fact that ASME Code Winter 1980 Addenda exempted . impact tests under qualified conditions. The licensee failed to comply with regulatory- requirements . in that the installed material does not comply _with the ASME B&PV Code, 1974 Edition, through Summer 1974 Addenda. The licensee further failed to establish measures to -assure implementation of adequate corrective action to preclude repetition. This failure to _ implement adequate corrective action is a violation'50-416/84-48-0 _

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. Source Selection Bechtel maintains an Evaluated Supplier List which is update monthly; the most. recent copy dated September 28, 1984, was reviewed by the inspector. This if 3t contains all Bechtel suppliers of Q-list safety-related engineering equipment or ASME Section III materials. The date, results, and type of most recent survey of the supplier is given. ASME i certification stamp number and date of expiration are shown and other infor: ration detailed to indicate the status of supplier qualit Audit schedules of suppliers for Grand Gulf Nuclear Station are prepared by Bechtel two months in advance of the date due to cover a three-month audit pla MP&L approves the audit list and Bechtel conducts the audit Supplier Performance Evaluation Bechtel performs supplier- profiles (annual evaluations of supplier quality programs) and biannual audits of these same suppliers. MP&L is

. responsible for concurring with the frequency of Bechtel evaluations cased on importance and status of the function being evaluate Unacceptable performers are uniquely identified on the evaluated supplier lis It was noted . that one supplier has been uniquely identified based .on an NRC inspection of the fabrications facilit Approval by Bechtel, Norwalk, CA is required prior to issuing a pur-chase order to this company, Receiving Inspection The inspector examined the system established for performing receiving inspection to verify the _following:

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Facilities were adequat QC procedure 2.0, revision 2, Receiving Inspection, was adequat QC procedure 10.0, revision 1, Personnel Certification, required the inspector to be qualified.

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Receiving records were available and identified discrepancies were properly dispositione Certified' material- test reports were reviewed and- approved by Bechtel Q Procurement documents required documentation to verify acceptance of-the ite Certificates of conformance identified the applicable purchase order _and were signed by an appropriate member of the supplier QA organizatio . . . .- . . - , = , , - .

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The inspector. reviewed receiving reports, certified material test reports, receiving inspector qualifications, certified design speci-fications, certificates of compliance, and nonconformance reports pertaining to the material received on the purchase orders listed in paragraph 6.b above. The receiving inspections were conducted in accordance with the QA progra Storage ,

The inspector reviewed QC procedure 4.0, revision 0, Material Handling-and Storage, and Work Plan Procedure WP/P-15, revision 4, Maintenance of Material ' and Equipment While . in Storage, to assure that these

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-procedures were in compliance.with ANSI N45. The inspector toured the warehouse, laydown areas, paint storage trailer, Unit 2 containment, reactor building, and auxiliary building ,

to determine the following:

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Storage facilities for Class A equipment had an environmentally

. control atmosphere and provisions to prevent animals from enterin Facilities for Class B, C, and D equipment storage were satisfie Protection from damage during storage was adequat Periodic inspection vf storage facilities was mad Warehouse access was controlle Stored items were ider;tifie Nonconforming items were segregated and/or controlled.

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Items in storage received the required preventive maintenanc Records of. inspections were maintaine +

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Equipment in the power blocks was adequately protected. Equipment received- periodic rotation and electric heaters in motors ' were energize The quality assurance program-and implementation of adequate storage  ;

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was found satisfactor .

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. Audits The inspector reviewed the following audits:

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MAR 84/2-008 Maintenance of Material While in Storage

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>%R 83/2-0018 Maintenance of Material While in Storage

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MAR 83/2-0014 Receipt. Inspection

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. MAR 84/2-0024 Procurement Document Control

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MAR 83/2-0014' Procurement Document Control

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MAR-83/2-0053 Receipt Inspection

.The above audits were selected to . verify that the licensee is imple-menting a programsto evaluate the adequacy of the Procurement, Receiving, and Storage Program against ANSI standards N45.2.2 and N45.2.13. These audits identified deficiencies and reaudits confirmed implementation of corrective action. The licensee audits of procurement, receiving and storage were found satisfactory.

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