ML18186A573
| ML18186A573 | |
| Person / Time | |
|---|---|
| Site: | 99901409 |
| Issue date: | 07/06/2018 |
| From: | Andrea Keim NRC/NRO/DCIP/QVIB2 |
| To: | Kerri Kavanagh NRC/NRO/DCIP/QVIB2 |
| Keim A | |
| References | |
| IR 2011201 | |
| Download: ML18186A573 (5) | |
Text
July 6, 2018 MEMORANDUM TO: Kerri A. Kavanagh, Chief Quality Assurance Vendor Inspection Branch-2 Division of Construction Inspection and Operational Programs Office of New Reactors FROM: Andrea T. Keim, Reactor Operations Engineer /RA/
Quality Assurance Vendor Inspection Branch-2 Division of Construction Inspection and Operational Programs Office of New Reactors
SUBJECT:
CLOSURE OF INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA RELATED-FINDING FOR OBAYASHI INSPECTION REPORT NO. 99901409/2011-201 The purpose of this memorandum is to document the U.S. Nuclear Regulatory Commission (NRC) staffs closure of the Notice of Nonconformance (NON) documented in Obayashi Corporation (hereafter referred to as Obayashi) Inspection Report No. 99901409/2011-201, dated November 3, 2011 (Agencywide Document Access and Management System (ADAMS)
Accession No. ML11286A106).
On September 12-16, 2011, the NRC staff completed an inspection at the Obayashi facility in Tokyo, Japan. The purpose of the technically-focused, limited-scope inspection was to evaluate Obayashis implementation of quality activities affecting current and future design analyses, calculations, and drawings that Obayashi supplies to Westinghouse Electric Company (WEC) in support of the AP1000 design.
In Inspection Report No. 99901409/2011-201, the NRC staff issued Notice of Nonconformance (NON) 99901409/2011-201-03, which the NRC staff determined that the examples documented in this NON were material to the acceptance criteria of inspections, tests, analyses, and acceptance criteria (ITAAC) No. 3.3.00.02a.i.a (760), 3.3.00.02a.i.b (761), 3.3.00.02a.i.c (762),
and 3.3.00.02a.i.d (763) from Revision 19 of the certified AP1000 Design Control Document.
NON 99901409/2011-201-03 documents a finding against Criterion III, Design Control, of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Processing Plants, to Title to 10 of the Code of Federal Regulations Part 50, Domestic Licensing of Production and Utilization Facilities, for Obayashis failure to: 1) correctly implement the CONTACT: Andrea Keim, NRO/DCIP 301-415-1671
K. Kavanagh provisions of the American Concrete Institute (ACI) 349, Code Requirements for Nuclear Safety-Related Concrete Structures & Commentary; 2) implement measures to identify and implement organizational interfaces between Obayashi and WEC for design control, design changes and technical directions; and 3) ensure that design changes were reviewed and verified with the same rigor as the original design.
In letters dated December 12, 2011 (ADAMS Accession No. ML113460990), February 2, 2012 (ADAMS Accession No. ML12097A145), and April 5, 2012 (ADAMS Accession No. ML12102A349), Obayashi described their corrective actions to address the issues identified in NON 99901409/2011-201-03. Specifically, in letter dated December 12, 2011, Obayashi discussed that WEC issued a stop work order on Obayashi and that Obayashi AP1000 design work will be performed under the WEC quality assurance program and procedures. The NRC staff reviewed Obayashis corrective actions taken to address the issues identified in NON 99901409/2012-201-03. The NRC staff also performed an inspection at WEC from May 21-25, 2018. During the inspection, the staff reviewed WECs corrective actions and oversight of Obayashi. As part of WECs corrective actions, WEC performed an extent of condition of work performed by Obayashi. The results of the review found no errors but did make recommendations for reconciliation of ongoing structural design changes. The WEC review is documented in Review of Obayashi Technical Analyses, dated October 28, 2011 and Review Supplement of Obayashi Technical Analyses, dated November 23, 2011.
Based on the documentation reviewed, the NRC staff has determined that the corrective actions taken by Obayashi and WEC are adequate to address the identified nonconformance.
NON 99901409/2011-201-03 is closed and no additional inspection follow-up is required to verify completion/adequacy of the corrective actions.
Enclosure:
Summary of NRC Inspection at Westinghouse Electric Company related to Obayashi Affecting ITAAC
ML18186A573 NRO-002 OFFICE NRO/DCIP/QVIB-2 NRO/DCIP/QVIB-2 NAME AKeim KKavanagh (PPrescott for)
DATE 07/06/2018 07/06/2018 Summary of NRC Inspection Westinghouse Electric Company Related to Findings at Obayashi Affecting ITAAC
- 1. AFFECTED INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA The U.S. Nuclear Regulatory Commission (NRC) inspectors identified the following inspection, test, analysis, and acceptance criteria (ITAAC) related to components being fabricated by Obayashi Corporation (here after referred to as Obayashi). For the ITAAC listed below, the NRC staff reviewed Obayashis corrective actions and Westinghouse Electric Companys (WECs) oversight in response to Notice of Nonconformance (NON) 99901409/2011-201-03. The ITAACs design commitments referenced below are for future use by the NRC staff during the ITAAC closure process; the listing of these ITAAC design commitments does not constitute that they have been met and closed. The NRC staff identified one finding with three examples associated with the ITAACs identified below.
Source Document ITAAC Index No. ITAAC Acceptance Criteria i.a) A report exists which reconciles deviations during construction and concludes that the as-built Appendix C from the containment internal structures, Combined License including the critical sections, for Vogtle Electric No. 760 3.3.00.02a.i.a conform to the approved design and Generating Plant will withstand the design basis loads Units 3 and 4 specified in the Design Description without loss of structural integrity or the safety-related functions.
i.b) A report exists which reconciles deviations during construction and concludes that the as-built shield Appendix C from the building structures, including the Combined License critical sections, conform to the for Vogtle Electric No. 761 3.3.00.02a.i.b approved design and will withstand Generating Plant the design basis loads specified in Units 3 and 4 the Design Description without loss of structural integrity or the safety-related functions.
i.c) A report exists which reconciles deviations during construction and concludes that the as-built structures in the non-radiologically Appendix C from the controlled area of the auxiliary Combined License building, including the critical for Vogtle Electric No. 762 3.3.00.02a.i.c sections, conform to the approved Generating Plant design and will withstand the design Units 3 and 4 basis loads specified in the Design Description without loss of structural integrity or the safety-related functions.
Enclosure
i.d) A report exists which reconciles deviations during construction and concludes that the as-built structures in the radiologically Appendix C from the controlled area of the auxiliary Combined License building, including the critical for Vogtle Electric No. 763 3.3.00.02a.i.d sections, conform to the approved Generating Plant design and will withstand the design Units 3 and 4 basis loads specified in the Design Description without loss of structural integrity or the safety-related functions.
- 2. FINDINGS AND OBSERVATIONS During an inspection at WEC from May 21 - 25, 2018, the NRC staff reviewed the corrective actions that WEC performed. WEC reviewed all work performed by Obayashi. WEC also had Obayashi work under the WECs quality assurance program as documented in APP-GW-GAH-032, AP1000 Plant Engineering Obayashi Scope Project Quality Plan. The NRC finds that the corrective actions taken by Obayashi and WEC in response to NON 99901409/2011-201-03 are adequate to address the identified nonconformance.
NON 99901419/2011-201-03 is closed and no additional inspection follow-up is required to verify completion/adequacy of the corrective actions.
- 3. ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description Applicable ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.b, 99901409/2011-201-03 CLOSED NON Criterion III 3.3.00.02a.i.c, and 3.3.00.02a.i.d 2