ML19262A837
| ML19262A837 | |
| Person / Time | |
|---|---|
| Issue date: | 09/12/1979 |
| From: | Donna Anderson, Brown R, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19262A826 | List: |
| References | |
| REF-QA-99900502 99900502-79-3, NUDOCS 7912110133 | |
| Download: ML19262A837 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTICN AND ENFORCEMENT REGION IV Report No.
99900502/79-03 Program No. 51200 Company:
Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3 Houston, Texas 77001 Inspection Conducted: August 27-31, 1979 Inspecto :
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- D. G. Anderson, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch L[yp w
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. t, R. L. Brown, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch O
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%t3-77 C. J. Male,' Chief Date Program Evaluation Section Vendor Inspection Branch Approved by:
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~/3~79 C. J. H W, Chief Date Program Evaluation Section Vendor Inspection Branch Summary Inspection on August 27-31, 1979 (99'300502/79-03)
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2 Areas Inspected:
Implementation of Title 10 CFR 50, Appendix B, including Design Input, QA Records, and Action on Previous Inspection Findings. The inspection involved sixty-two (62) inspector hours on site by two (2) USNRC inspectors.
Results:
In the three (3) areas inspected there were no unresolved items identified in any of the areas, no deviations were identified in two (2) of the areas, and the following deviation was identified in the remaining area.
Deviation: Design Input-references for design input parameters were not identified in the text of a System Design Description with a superscript numeral indicating a footnote (See Notice of Deviation enclosure).
1 5 3 0 1 8r7"
3 DETAILS SECTION (Prepared by D. G. Anderson)
A.
Persons Contacted
- J. E. Paden, Project Quality Engineer
- R. W. Peverley, Assistant Engineering Project Manager
- J. C. Shuckrow, Project Quality Engineer G. W. Smith, Mechanical Discipline Project Engineer M. D. Withrow, Engineer
- Indicates those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Unresolved Item (Report No. 79-01): Response spectra for the reactor containment structure, as identified in a B&R report, appears to differ from that reported in the FSAR for the South Texas Project. The Mechanical Engineering Branch, USNRC/NRR/ DSS, reviewed the following design calculations that had been impacted by use of incorrect response spectra: 2C0/SC044-1A, 2C011SC 037-3C, 20011SC037-2B, 2C011SC044-6B, 2C011SC044-Subpart 12, 2C091SC014 B/DCN.
Their review indicated that the seismic load factors were conservative or lower than those used in the calculations, therefore the design based upon these calculationc is considered adequate.
C.
Design Inputs 1.
Objectives The objectives of this area of the inspection were to determine that:
a.
Procedures have been established and are being implemented that prescribe the system for control of those criteria, parameters, bases, or other design requirements upon which detailed final design is based.
b.
Design inputs are specified on a timely basis, their selection reviewed and approved, incorporated into the design documents, and changes in input are justified, reviewed and approved.
c.
Commitments are properly translated into design inputs, as applicable to the following:
(1) Basic functions (2) Performance requirements 1530 188
4 (3) Regulatory requirements, codes, and standards (4) Design conditions (5) Loads (6) Environmental conditions d.
Design requirements are specified, when applicable, relating to interfaces, materials, mechanical, structural, hydraulic, chemistry, electrical, instrumentation and control, redundancy, accessibility, fire protection, and o %er requirements that prevent undue risk to the health and safety of the public.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
A review of the Brown and Root Quality Assurance Manual, Section 3.0, Design Control, which summarizes the methods used by Brown and Root, Power Engineering Group, to describe their activities related to the design process. The design process for the South Texas Project is defined, implemented, and enforced according to the following Engineering Procedures:
STP-DC-002-I, Engineering Procedure for Drawing Control, May 15, 1978.
STP-DC-005-H, Preparation and Control of Specifica-tions, February 7,1978.
STP-PM-005-F, Interface Control, November 4, 1977.
STP-DC-007-G, Preparation and Control of System Design Descriptions (SDD), August 22, 1978.
STP-DC-008-G, Calculations, February 3, 1978.
STP-DC-009-G, File and File Storage, February 14, 1978.
STP-DC-012-G, Final Safety Analysis Report (FSAR)
Change Control, June 14, 1978.
STP-DC-013-C, Document Change Notice Control, January 24, 1978.
STP-DC-019-D, Technical Reference Control, February 3,1978.
b.
Review of the following documents:
(1) System Design Description List for the South Texas Project, CR-0241, June 28, 1979.
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5 (2) System Design Descriptions:
5R349ND016, Reactor Head Degassing System, July 9, 1979.
7C019SD010, Containment Structure, March 27, 1979.
2V219SD017, Reactor Containment Fan Coolers Duct and Support Structure, April 11, 1979.
SV140VD006, Reactor Containment HVAC, September 15, 1978 2Z3912D003, Seismic Monitoring System, June 21, 1979.
3Z149ZD007, Radiation Monitoring System, March 28, 1979.
4C019SD006, Containment Internal Structure, March 29, 1979.
(3) Specifications:
7R349NS057-C, Reacter Head Degassing System Package, July 13, 1978, 7Q239NS027-C, Shop Fabricated Pressure Vessels, March 22, 1977.
3Z1492S001-E, Radiation Monitoring System, June 2, 1978.
(4) Change Notices:
7R349NS057-C/DCN/7/31/78, RHDS Package Specification Change Notices, August 10, 1978.
321492S001-E/DCN/10/25/78, Radiation Monitoring System.
(5) Drawings:
SK0241F224, Reactor Head Degassing System Gas Storage Tanks.
1-F-5046-C, STP Units 1 and 2, Piping Diagram Reactor Head Degassing System, January 4, 1979.
1-F-5055-C, STP Units 1 and 2, Piping Diagram Gaseous Waste Processing System, April 13, 1979.
c.
Review of design input commitments in the following documents:
(1) Reports:
ST-NS-0239, South T:xas Project Gaseous Waste ?rocessing System Conceptual Design Supporting Documentation and Backup Material, Volume 2, March 1975. This document is a consultant's report which provides heat and fission product source terms for the reactor vessel head and volume control tank.
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6 (2) Calculations:
7R349NC195A, RHL3 Nitrogen Requirements, April 8, 1977.
7R349NC184A, RHDS Degassing Package Sizing, September 16, 1977.
7R319NC073, "i.illed Water Requirements for RHDS, suly II, 1975.
7P.349NC238A, RHDS Design Pressure and Temperature, March 9, 1978.
7R319NC159A, RHDS Source Strengths, February 11, 1977.
A479NC118-C, Radiation Exposure to Equipment, April 27, 1979.
d.
Review of the identification of design requirements in the following documents:
Technical Reference Documents 6Z019ZQ002-D, System and Equipment Monitoring General Design Criteria, May 22, 1979.
3V279RQ009-B, HVAC Ductwork Structural Design Data, December 12, 1977.
Review of the Final Safety Analysis Report for the South Texas e.
Project to assure that design input had been translated correctly into the following sections:
(1) Volume 13, Chapter 11.3, Gaseous Waste Management System.
(2) Volume 8, Chapter 6.2.1, Containment Functional Design.
(3) Volume 14, Chapter 12.3, Radiation Protection Design Features.
3.
Findings In this area of the inspection, no unresolved items were identified.
The following deviation from commitment was identified (See Notice of Deviation, enclosure):
During the review of System Design Descriptions (SDD) for input to the design process, the inspector noted that design input parameters used in the text of the SDD were not traceable to the references listed in the appropriate appendix in the rear of the SDD. For the applicable SDD, STP-DC-007-G requires that superscript numerals identify the references to design input. A later revision of this procedure, STP-DC-007-H requires that the number of the reference be placed in parenthesis adjacent to the design input parameter. Brown and Root 0.uality Assurance Personnel followed up on this item during the 1530.191
7 inspection and identified several other SDD which did not have the appropriate identification of references to design input.
D.
Exit Meeting An exit meeting was conducted with Brown and Root management personnel at the conclusion of the inspection on August 31, 1979. Those individuals indicated by an asterisk in Section A of the Details Sections of this report were in attendance.
In addition, the following were present:
R. W. Bass, Manager, QA Audit Section J. R. Childers, Assistant Houston QA Coordinator J. L. Hawks, Engineering Project Manager G. S. Millas, Assistant Engineering Project Manager B. F. Mitchell, Project Quality Engineer T. D. Stanley, Project QA Supervisor K. A. Swarts, Senior Engineering Manager R. W. Vincent, Project QA Manager The inspector discussed the scope of this inspection and the deteils of the finding identified during the inspection. Management representatives of Brown and Root acknowledged the statements by the inspector with respect to the one (1) deviation presented.
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8 DETAILS SECTION II (Prepared by Ross L. Brown)
A.
Persons Contacted C. H. Brister, Material Control Supervisor P. G. Bruen, Document Administration Supervisor M. N. Kimball, Project Veudor Surveillance Coordinator
- J. T. Moore, Manager Quality Systems
- H. Paperno, Assistant QA Manager
- J. C. Shuckrow, Project Quality Engineer P. A. Stidham, FREA & Telecopy Supervisor R. M. Witte, Process Support Group Supervisor
- Denotes those present at the Exit Meeting B.
QA Records 1.
Objectives The objectives of this area of the inspection were to examine the establishment and implementation of quality related procedures for collecting, filing, storing, maintaining, and dispositioning of QA records to verify that:
a.
A QA records system is defined, implemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups performing safety related activities including QA, design, procurement, administration, and services,
b.
QA records are legible, completely filled out, adequately identifiable to the item involved, validated, and listed in an index that indicates: the record retention time, where the record is to be stored, and the location of the rec >rd in the storage area. Any changes or modifications to t iese records are controlled.
c.
A specific submittal plan for QA records is established between the licensee and contractor and records exist that acknouledge the licensee's receipt of QA records.
d.
A designated authority has been assigned to control the receipt of QA records by a system which includes a list of QA records required, a record of QA records received, and an 1530 193
9 inspection of incoming records including a current assessment of the status of incoming records.
e.
A custodian has been designated to assure that QA records are in ac.ordance with b. above and to enforce a QA record storage filing system which includes a system description of the filing technique and storage area, rules for access and control of record files, accountability of records removed from record files and security requirements.
f.
The QA record storage facility is in compliance with applicable codes, standards, and regulations consistent with NRC Regulatory Guide 1.88.
g.
The QA record storage system is periodically audited to assure the record control system is implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of B&R, Quality Assurance Manual (QMI) Section 17.0, Quality Assurance Records, that describes the method to be used for the receipt, handling, filing storage and disposition of lifetime and nonpermanent QA records.
It also requires project procedures in which records are listed, organizational and retention responsibilities are defined.
b.
Review of the following procedures to determine that engineering has a program to control the quality records received by or originated by the Engineering Department:
(1) STP-DC-002-I/DCN/3-16-79, Engineering Procedure for Drawing Control, that states, all South Texas Project (STP) drawings (except those for information only) shall be registered and issued through Engineering Document Control Center (EDCC) and shall be distributed in accordance with STP-DC-011.
The procedure also requires all controlled drawings to be issued by EDCC using a Document Transmittal Order form. (DTO)
(2) STP-DC-004-E/DCN/6-15-79, Foreign Document Processing and Control, requires EDCC to number each foreign document with a unique multi positioned Total Plant Number System (TPNS) identifier as described in l
STP-DC-010.
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10 (3) STP-DC-005-H/DCN/5-15-79, Engineering Procedure for Preparation and Control of Specifications, which assign the responsibilities to initiate or upgrade document register in accordance with the requirements of STP-DC-010 and implementation of distribution as required 'oy TP-DC-011.
(4) STP-DC-007-H/DCN/8-14-79, Engineering Procedure for System Design Descriptions that raquires EDCC to:
maintain document register of System Design Descrip-tions (SDD), maintain a current copy of STP Design Manual, maintain a file of SDD's in issue sequence which includes copies of all revisions of the SDD, provide controlled distribution of the SDD's and provide a bi-monthly listing of current SDD revisions.
(5) STP-DC-008-G/DCN/1-25-79 Engineering Procedure for Calculations that requires EDCC to:
codify and issue oppropriate TPNS file designations for each calculation, maintain document register, and publish bi-monthly a listing of those calculations, and register calculations into the Control Data System.
(6) STP-DC-009-G/DCN/4-24-79, Engineering "rocedure for Filing and Storage, which establishes the bases, guidelines, and requirements for filing of records and records retention system to be used on the project.
It defines the manner in which project records shall be identified, collected, filed, microfilmed, stored ano maintained. This procedure lists only those records for which engineering has retention respon-sibility until the record turnover.
(7) STP-DC-010-F/DCN/4-27-79, Engineering Procedure for Codification, that describes the method for codifying design documents and correspondence on the project that are maintained or filed by EDCC including those documents which are designated as quality assurance records.
(8) STP-DC-011-C/DCN/5-7-79, Engineering Procedure for Document Distribution, that describes the process of selecting the distribution of STP documents and assigns the responsibilities for the activities.
(9) STP-DC-020-A Engineering Procedure for Record Turnover, which establishes the requirements and methods for transfer of records for which engineering has the 153J l95 L
...%e-
11 retention responsibility (STP-DC-009) to the site QA for final turnover to the client. The procedure also assigns the organizational responsibility for these activities.
c.
Review of Quality Assurance Procedure ST-QAP-2.3, Document 2-tion Administration, that establishes the minimum require-ments and assigns the responsibilities for the receipt, distribution and storage of project related documents received by or originated by the QA Department.
d.
Review of the following project records to verify con-formance with the requirements, methods and responsibil-ities defined and/or assigned in paragraphs B.2.b.(1) through B.2.b.(9) and B.2.c. above.
(1) Specifications:
(a) 3E269ES029, Revision A and Revision E Electric Penetration Assembly.
(b) 8S139MS017, Revision D S.G-FW Pumps.
(c) 3R2S9NS012, Revision A and Revision D Essential Cooling, Water Pump.
(d) ZA901PS106, Revision A ASME III, Pipe 2.5 inch and larger.
(e)
IL360PS102, Revision A, B and E ASME III, Pipe Hangers and Supports.
The specifications had a DT0 attached, DCNs were referenced and the documents were approved by the appropriate organi-Nt'ons including QA.
(2) Drawings:
(a) 2C021C1032-8 (b) 6C151N5002-0 (c) C011S1559-2.
The Title Block identified the Title, Document Number and Revision Number. The Revision Blocks noted each revision and had the approval of applicable disciplines for all revisions.
(3) Calculations:
(a) SS109MC274, Revision A dain Steam Line, Safety Relief Valve (b) R289NC008, Revision A Essential Cooliig Water Pu:np.
I9b 1
12 The file for these calculations included the design verification sheets, checklist, approval sheet and design input requirements.
(4) Management Audit Reports for audits conducted in June 1978 and June 1979.
(5) Four (4) Internal Audit Reports:
BR-37, BR-38, BR-43 and ST-22.
(6) Two (2) External Audit Reports and one Vendor Surveillance Report that closed the audit findings in one audit report.
(7) The Field Request for Engineering Action (FREA) Log. These requests are usually for clarification, but if a design change is required the DCN is referenced on the FREA and the DCN is controlled.
(8) The QA Document Administrations Log book that identifies the QA Records transferred to the project site for turn-over to the client.
3.
Findings No deviations from commitment or unresolved items were identified in this area of the inspection.
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