ML19263D198
| ML19263D198 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1979 |
| From: | Brickley R, Brown R, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263D197 | List: |
| References | |
| REF-QA-99900519 NUDOCS 7903260057 | |
| Download: ML19263D198 (12) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900519/79-01 Program No.
51200 Company:
Bechtel Power Corporation Gaithersburg Power Division 15740 Shady Grove Road Gaithersburg, Maryland 20760 Inspection Conducted: January 23-26, 1979.
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Inspec tors :
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b i 7h R. H. Brickley, PrincifU Inspector, Vendor Date Inspection Branch
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.s R. L. Brown,) Principal Ins;/ector, Vendor Date Inspection Branch c3~G~7 Approved by:
Td v-C. J. Ha{e,) Chief, Program Evaluation Section, Date Vendor Inspection Branch Summary Inspection on January 23-26, 1979 (99900519/79-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, including design inspection - containment spray system, action on previous inspection findings, and verification activities.
The inspection involved fifty-six (56) inspector-hours on-site by two (2) inspectors.
Resul ts :
In the three (3) areas inspected there were no deviations or unresolved items identified.
79032600 6 7
. DETAILS SECTION I (Prepared by R. H. Brickley)
A.
Persons Contacted S. R. Blazo, Group Leader, Dose Assessment Group
- L. Bonn, QA Supervisor, Audits S. Z. Dubow, Mechanical Supervisor B. H. Dunbar, Quality Engineer H. E. Filacchione, Senior Engineer P. J. Kochis, Mechanical Licensing Engineer F. J. Lolli, Group Leader, Plant Design Group A. Menendez, Mechanical Group Supervisor H. W. Osgood, Supervisor, Radiation Analysis J. K. Parikh, Supervisor, Plant Design Group
- Denotes those in attendance at the exit interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 77-01); QA management audits not performed on the QA records system of the two (2) projects reviewed.
The inspector verified that QA management audits have been performed on the QA records system of the two (2) projects one on February 21.-24, 1978, and the other on October 16-24, 1978.
2.
(Closed) Deviation (Report No. 78-02); Three (3) examples of a failure to follow procedures in the area of design control.
The inspector verified the corrective actions and preventive measures committed by Bechtel in their letter of response dated June 30, 1978.
This was accomplished by a review of the records maintained on these activities ie:
a.
QE Surveillance Report No. 78 Reports the results of a 100% review of all drawings issued during the forty-five (45) days prior to June 30, 1978.
b.
QE Surveillance Report No.78-103 - Reports the results of a check of two (2) drawing control stations for proper identification of superseded drawings and currentness of drawing revisions.
c.
QE Surveillance Follow-up Report - Reports surveillance follow-up to Report No.78-103 to verify completion of a 100% check of all drawings by Project Engineering.
. 3.
(Closed) Unresolved Item (Report No. 78-03); Pipe support fillet welds for the Grand Gulf project do not meet the size requirements of Subparagraph XVII-2452.1 of Appendix XVII to Section III of the ASME Code.
Bechtel's evaluation and recommendations on this matter (paragraph I.B.2.c, Report No. 99900519/78-03) have been evaluated by the licensee and found acceptable.
(Reference NRC:
II Report Nos. 50-416/78-18 and 50-417/78-18, paragraph re IFI 416/417/78-10-01).
4.
(Closed) Unresolved Item (Report No. 78-03); Bechtel had not completed an analysis to verify that the spray pattern from each spray header arrangement of the Containment Spray System gives a minimum of 90% area coverage at the operating deck as committed in Subsection 6.2.2 of the SNUPPS PSAR.
The inspector examined calculation EN-39 and Attachment A (Print of the Spray Coverage) which indicated that 93.2% of the total area would be covered.
C.
Design Inspection - Containment Spray System 1.
Objectives The objectives of this area of the inspection were to verify for the containment spray system that:
a.
Design criteria, requirements and comnitments, as listed in the SAR, were utilized in design input during system and component design.
b.
Analyses of containment spray pump net positive suction head (NPSH) during all phases of operation.
c.
Design analyses establish the capability of the system to provide flow at ratas and temperature which result in heat removal rates consistent with those utilized in the LOCA and/or main steam line break analyses.
d.
Specifications and/or procurement documents for system components require they be designed, fabricated, erected and tested in accordance with applicable ASME Section III and 10 CFR 50, Appendix B, requirements.
e.
Provisions and plans have been made for pre-operational and operational testing consistent with SAR commitments aad statements.
o f.
The analysis (design) of system spray coverage supports SAR commitments and statements.
g.
The system design for pH control including analyses of pH versus time after system actuation supports SAR commitments and statements.
h.
Provisions to prevent trapping of chemical additives imple-ment SAR commitments.
i.
Calculations of iodine removal constants, use parameters, and system characteristics are consistent with those in items a-h above.
j.
Iodine removal constants used in the analyses of the radio-logical consequences of a LOCA are consistent with item i.
above.
2.
Method of Accomplishment a.
Project No. 7597 The preceding objectives were accomplished bj an examination of:
(1)
Sections 6.2.2 (Containment Heat Removal System), 6.2.3 (Containment Air Purification and Cleanup System) and Appendix 178 (Bechtel Power Corporation Quality Assurance Program) of the project FSAR for the technical and programmatic commitments.
(2) Sections 8.0 (Design Criteria - Engineered Safeguards),
8.2 (Containment Spray and Additive System) and 8.2.5 (Mechanical Design) of the Project Mechanical Design Criteria Manual; and Subsections 5.4 (Bechtel Prepared Drawings and Sketches), 5.8 (Quality Assurance Program),
and 5.10 (Design Calculations) to Chapter 5 (Engineering and Startup); and Chapter 6 (Specifications) of the Project Procedures Manual to determine that they were consistent with SAR commitments.
(3)
Specifications No. SS-1102-40 (Small Steel Gate, Globe, Needle and Check Valves) Revision 6, and SS-1109-1 (Shop Fabricated Piping) Revision 11 to verify that they satisfied C.1.d above and were done in accordance with applicable procedures.
(4)
Drawing Nos. D-175038 (P&ID Safety Injection System -
Containment Spray) R-6, D-175376 (CSS - Plan Auxiliary Building at El. 77'-0") R-7, D-175377 (CSS - Plan Auxiliary Building at El. 100'-0") R-5, D-175378 (CSS Plan -
Containment) R-7, D-175379 (CSS Plan - Containment) R-4, D-175380 (CSS - Sections and Details) R-6, D-175381 (CSS - Sections and Details) R-7, and D-175491 (CSS -
Details) R-1 to verify that they satisified the requirements of the applicable documents listed in C.2.a.(2) above.
(5) Mechanical Calculations Nos. 5.2 (Containment Pump Pressure Drop) R-2, 5.7 (Containment Spray Pumps -
Available NPSH) R-1, 5.8 (Containment Spray Pumps NPSH-Available and Required, worst case during the injection phase) R-0, 5.11 (Containment Spray Pump Pressure Drop)
R-1, and 5.12 (CSS Eductors) R-0 to verify that they satisfied C.I.a, C.1.b and the requirements of the applicable documents listed in C.2.a.(2) above.
b.
Project No. 9645 The preceding objectives were accomplished by an examination of:
(1) Section 6.5.2 (Containment Spray System) of the project FSAR and Section 17.1.3.2 (Bechtel Design Control) of the project PSAR for the technical and programmatic commitments.
(2) Section B (System Description and Design Criteria) -
Subsection I.1.7 (RHR System of the Project Design Criteria Manual), and procedures 4.3.1 (Bechtel Prepared Drawings), 4.4 (Calculations) and 4.5 (Specifications) of the Project Engineering Procedures Manual to determine that they were consistent with SAR commitments.
(3) Calculation Nos. 1.1.1C (NPSH Calculations - RHR Pumps)
Revision C, and Q1.1.6B (RHR System SFD Calculations)
Revision B to verify that they satisfied C.1.a, C.1.b and the requirements of the applicable documents of C.2.b.(2) above.
(4)
Calculation Nos. PD-M-10-4 (Directly Sprayed Volume in CTMT), Revision A to verify that they satisfied C.1.a, C.1.f and the requirements of the applicable documents of C.2.b. (2) above.
(5)
Calculation No. 5.3.25-N (LOCA - Post LOCA Off-site and Control Room Operator Doses with Containment Sprays),
Revision 0 to verify that it satisfied C.1.i, C.I.j and the requirements of the applicable documents of C.2.b.(2) above.
(6) Specification M-201.0 (Design Specification for Shop Fabricated Piping - Nuclear Service - 2h Inches and Larger) R-23 to verify that it satisfied C.1.d and the requirements of the applicable documents of C.2.b.(2) abcve.
(7)
Specification No. M-1550 (Technical Specification for Containment Spray Nozzles), Revision 8 and Drawing No.
SK-M-1530 (Containment Spray Coverage Study) to verify that they satisfied C.1.f and the requirements of the applicable documents of C.2.b.(2) above.
3.
Findings a.
There were no deviations or unresolved items identified in this area of the inspection.
b.
Bechtel's responsibility for the Containment Spray System on Project 7597 was found to limited to the detail design of valves 2 inches and smaller, piping, and hangers, based on a system configuration established by Westinghouse.
The inspection of-this project was therefore limited to those activities.
The examination of Calculation No. 5.3.25-1 (paragraph C.2.b.
c.
(5)) used on Project 9645 revealed that they used an iodine partition coefficient (H) of 422.9 to calculate the decontamination factor (DF) of 53.86.
For conservatism they selected a DF of 50 corresponding to an H of 392 for their analysis of off-site thyroid doses following a LOCA.
Section 8.3.4 of ANSI N581 (PWR and BWR Containment Spray System Design Criteria) Draft 7, June,1977, allows use of an H of 100 when no chemical additives are utilized as in this case.
With this restriction (H=100) the inspector calculated a DF of 13.5 for this project.
Refering to Section 6.5.2.3.2.1 of the project FSAR the inspector verified that the use of a DF of 50 based on an H of 392 to determine off-site thyroid doses was identified to NRR. The FSAR is presently under review by NRR therefore no further action by NRC:IV is contemplated.
d.
The examination of Calculation No. Q1.1.6B (paragraph C.2.b.
(3)) used on project 9645 revealed an error in the calculation of item 17 (pressurg drop per 100 ft.) on page 55.when it should have Th listed was 1.24X10-c.
Discussions with Bechtel engineers indicated that this error did not significantly effect the final results.
In addition a random check by Bechtel engineers of approximately six (6) similar calculations revealed no further errors.
D.
Exit Interview An exit interview was held with management representatives on January 26, 1979.
In addition to those individuals indicated by an asterisk in each Details Section, those in attendance were:
J. M. Amaral, QA Manager I. Arbaiza, Quality Engineer C. E. Bald, Vice President and Division Manager W. M. Mendis, Chief Quality Engineer J. Mutzberg, QA Program Supervisor R. H. Stone, Manager, Division Engineering W. M. Turner, Project Quality Engineer A. A. Vizzi, Project Engineer A. Zaccaria, Project Engineer The inspector summarized the scope and findings of the inspection.
Management connents were generally for clarification only, or acknowledgement of the statements by the inspector.
DETAILS SECTION II (Prepared by Ross L. Brown)
A.
Persons Contacted
- D. E. Trapold, Division Supplier Quality Manager J. L. Smith, Division Technical Services Representative
- Attended the exit interview.
B.
Verification Activities 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for verification activities that provide for:
Qualified personnel to be assigned to check, inspect, audit a.
or witness the activities of suppliers as early as applicable.
b.
The planning of verification activities including identification of the inspection sequence, hold and witness points, acceptance criteria, documentation required by the procurement document, and receiving inspection plans.
Implementing source surveillance including activities at c.
supplier's facilities (i.e. inspections, audits) and receiving inspection dispositioning.
d.
Reporting results of source surveillance activities and evaluation of reports.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following sections of the Projer'. Procurement Procedures Manual, Revision 0, dated August,1978, to verify that the procurement documents are required to include or reference the applicable codes, standards or regulatory requirements.
(1)
Section 2.0., Bidding Program, requires approved bidders and bid analyses / evaluations prior to contract award.
_9 (2)
Section 3.0. Procurement Department Responsibilities /
Functions, requires the " Procurement Suppliers Quality Department (PSQD) to perform supplier surveys, quality program evaluation, supplier quality program audits, and surveillance inspec tion services in accordance with the Procurement Supplier Quality Manual."
b.
Review of the following sections of the Project Engineering Procedures Manual to determine that the engineering functions relative to the procurement activities have been described:
(1)
Section 2.1.4. Purchases (including Subsections 2.1.4.1.
Revision 2, 2.1.4.3, Revision 1, and 2.1.4.4. Revision 0.).
These describe the engineering functions and responsibilities relative to procurement activities, e.g. preparation of bid package, analysis of bids and recommendation of suppliers and insurance of purchase order reference and/or documents.
(2) Subsection 4.2.17, Revision 1, dated July,1977, Suppliers Deviation Disposition Request, provides the method for processing supplier / subcontractor requests for deviations from procurement requirements.
(3) Subsection 4.5.1.2, Revision 3, dated December, 1978, Coordination Review and Approval of Design Specification, provides-for the review and approval by the Project Quality Engineer of all "Q" safety related speci fications, material requisition and changes thereto.
(4) Subsection 4.3.2, Revision 2, dated June,1977, Drawing and Documents by Vendor / Subcontractors, describes the..c+ hod for receiving, distribution, review, documentation and control of vendor drawing / documents.
(5)
Subsect'on 6.10, Revision 2, dated April,1978, Review of Suppliers and Subcontractors Quality Assurance Manual, requires the supplier to submit a quality manual for engineering quality review and approval prior to start of work.
c.
Review of the following sections of the Procurement Supplier Quality Manual, Revision 1, dated April 1,1978, to determine if the organizational structure of the Procurement Supplier Quality Department (PSQD) has been described and that the responsibilities and authorities of PSQD personnel have been delineated relative to planning, directing, and implementing the quality surveillance activities:
(1)
Section 1.0, Subsection 1.1, and Subsection 2.3, Responsibilities, assigns the responsibilities for the following functions :
(a) Directing the selection, qualification, and assignment of SQD personnel.
(b) Planning, development and implementation of the SQD's indoctrination, training and personnel qualification program.
(c)
Describes the SQ-Representatives duties and responsibilities relative to progran implementation, surveillance of supplier activities and reporting of findings.
(2)
Section 2.0, Subsection 2.1, Supplier Surveys, describes the procedure applicable to supplier evaluation activities performed by PSQD personnel to assess the manufacturing and/ quality capabilities of suppliers.
(3) Section 2.0, Subsection 2.3, Supplier Quality Program Audits, defines the procedures that apply to audits performed by PSQD personnel to examine the implementation of the supplier's quality program.
(4) Section.2.0, Subsection 2.4, Suppliers Performance Evaluation, describes the requirements and procedures applicable to suppliers evaluation activities performed by PSQD personnel to provide infonnation on the supplier's performance.
(5) Section 3.0, Subsection 3.2, Surveillance Inspection, describes the requirements and procedures for the conduct of inspection activities performed by the SQ Representatives such as; review of supplier personnel qualifications (welder and NDE), review with the vendor the Bechtel assigned witness and/or hold points, and review with the vendor the other procurement document requirements, d.
Review of the following documents pertinent to the procurement activities for four (4) projects:
(1) Purchase Order No. 9645-M-011.0 for Reactor Feed Pumps and Revisions 1-13 with the associated documents relative to this P.O. Purchase Memorandum which
.. authorized the P.0., applicable Material Requisition that describes or references the technical requirements and quality plan.
(2)
Supplier Survey Report, Supplier Quality Program Audit Report, and Supplier Quality Program Evaluation Report relative to P.O.10467-P-193Q for Central Service Water Pipin.
u (3)
Supplier Quality Program Audit Report and Reaudit Report for P.O. 9.695-M201.0, which included the audit summary, corrective action, close out distribution and preaudit memo.
(4)
SQ Representative reports related to PO 9645-M-242.0, Supplier Performance Report, fifteen (15) Quality Surveillance Reports (QSR) and three (3) Quality Surveillance Deficiency Reports (QSDR) and their resolutions.
(5)
One Supplier Deviation Disposition Request against P.O. No. 9645-F-32183, requesting acceptance of a condition relative to the specification.
The recom-mendation was accepted by Bechtel Engineering, Responsible Engineer, Project Engineer, Project Quality Engineer and other disciplines.
(6) SQ Repr sentative reports relative to P.O. No. 7597-FNP2-29, twenty (20) Quality Surveillance Reports and five (5) QSDR's. All deviations were closed.
(7)
SQ Representative reports related to P.O. No. 6511-PEHZ-263, QSR's Nos.1 through 31, dated Seotember 17, 1973-December 21, 1978.
All open items have been closed.
(e)
Review of the following general type documents:
(1) Supplier Quality Program Audit Schedule for December, 1978, through April,1979, which identifies the vendor to be audited, contract No., product, tentative date of audit, assigned auditors, and scope of audit.
(2) Personnel Qualifications / Certifications for one SQ Representative Level II/ Auditor and one SQ Representative Level III/ Auditor.
. (3)
Personnel Status Roster, that identifies all SQ Representatives and Auditors, their latest date of qualification and level of qualification.
The " level of qualification" is Bechtel assigned levels and are not comparable to SNT-TC-1A level s.
(4)
Evaluated Supplier List (ESL).
Bechtel management stated this ESL is not an approved vendor list, but it represents a list of suppliers that have been evaluated relative to a given program and it does give sufficient information for contract award, but the specification that is part of the P.O. requires the supplier to submit a program for Bechtel review and approval prior to starting component manufacture.
3.
Findings During the inspection of this area no deviations from commitment or unresolved items were identified.
.