ML19289E032
| ML19289E032 | |
| Person / Time | |
|---|---|
| Issue date: | 12/28/1978 |
| From: | Brickley R, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19289E022 | List: |
| References | |
| REF-QA-99900524 NUDOCS 7903210374 | |
| Download: ML19289E032 (13) | |
Text
U. S. ITUCLEAR REGULATORY COM:4ISSION OFFICE OF INSPECTICil Ai!D ENFORCEMENT REGION IV Report No.
99900524/73-02 Program No.
51200 Company:
Gibbs & Hili incorporated 393 Seventh Avenue New York, New York 1CC01 Inspection Conducted:
December 11-15, 1978 91'3
'/
Inspectors:
)
MC N bh'
/
[
R. H. 'SMckley, Princip'al (Inspector, Vendor Date Inspection Branch a
l h
~.3I, -5nu m
/ Ml v 2/ ? t' i
ti J,.j. Johns,on, Contractor Auditor, Vendor Date Inspect 1An Branch
.N Approved by:
Lv L
[,) UUV C. J. %14,' Chief, Program Evaluation Section, Date
~
Vendor Inspection Branch Summary Inspection on December 11-15, 1978 (99900524/78-02)
Areas Insoected:
Implementation of 10 CFR 50 Appendix B and Tcpical Report No. GISSAR-17-A including design inspection, implementation of the Quality Assurance Program on Gibbs & Hill Standard Safety Analysis Raport (GISBSSAR),
and action on previous inspection findings. This inspection involved 60 inspector-hours on site by two (2) NRC inspectors.
Results:
In the three (3) areas inspected there were no unresolved items identified in any of the areas.
The following deviations were identified.
Deviations:
Cesign Inspection:
- 1. Failure to identify the revisor and soprover of a revision to a design calculation as required (Enclosure, Item A), and 2.
Failure to obtain the approval of the structural discipline on a s;ecification as required (Enclosure, Item 3).
7903210 M 4 Implementation of the Quality Assurance Program on GISBSSAR: 1.
Failure to audit GIBBSSAR activities on a semi-annual basis as required (Enclosure, Item C.); 2.
Failure of five (S) personnel to attend the Technical Indoctrination Program as required (Enclosure, Item D.); and 3.
Failure to obtain satisfactory corrective action to audit findings and schedule re-audits of deficient ereas (Enclosure, Item E. ).
DETAILS SECTIOh I (Prepared by R. H. Erickley)
A.
Persons Contacted
A. 3eary, Manager, Quality Control J. Galperin, Senior Engineer
- N. Hyman, Manager, QA
- J. Jusco, Assistant QA Supervisor C. N. Yeh, Nuclear Engineer
- Denotes those present at the exit interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 78-01) Failure to reaudit four (4) conditionally approved suppliers within the past year that were performing work on issued purchase orders.
The inspector examined the corrective actions and preventive measures described in the letter of response dated May 4, 1978, and found the following:
a.
A master list of vendors with conditionally approved QA programs was prepared and transmitted to the G&H QC/ Vendor Surveillance Department and TUGC0 QA as committed.
b.
The Executive Vice President issued a directive to the QA and QC Departments with a copy to TUGC0 reemphasizing that a vendor must have an approved QA program prior to performing work.
c.
A Vendor Document & Drawing Status listing was issued by the G&H QC/ Vendor Surveillance Department as committed.
d.
Both the master list of vendors with conditionally approved QA program? and the Vendor Document & Drawing Status listing had been revised on a monthly rather than a bi-weekly basis as committed.
The inspector noted that the G&H QA Progress Report No. 2 to NRC Inspection Report 73-01 dated Novemcer 13, 1978, had identified this item and recommended that management notify NRC; however, no notification was made.
e.
The responsibility for performance of sucplier pre-award surveys, follow-up surveys and audits was assumed by TUGC0 QA as of August 15, 1977, as stated in a letter from the TUGC0 QA Manager to the GSH Project Manager dated Aoril 21, 1978.
f.
The master list of vendors with conditionally approved QA programs. Revision / issuod Novemt3er 1973, indicated that one vendor remained with pre-award restrictions
?.
(0 pen) Deviation (Report No. 78-01) Failure to conduct internal project audits.
The inspector exa:nined the corrective actions and preventive measures described in the letter of response dated May 4,1978, and found the following:
a.
A QA Department Master Audit Schedule and supplemental Audi t Schedule and Recor i Sheets have been issued as cc:nni tted.
b.
Additional QA personnel (approximately eleven) have been assigned to the project.
c.
The audits of the Print Department, Proiects, and Instrumentation and Controls were not perfonred until five (5) ranths af ter the G?di commitment date of June 15, 1978.
d.
The audits of Purchasing, Central Files, and Applied Mechanics have not been perfonned.
3.
(Closed) Deviation (Report No. 78-01) Failure to perform auJits on six (6) vendors.
The inspector examined the corrective actions and preventive measures described in the letters of response dated May 4, 1978, and June 30, 1973, and found the following:
a.
A Vendor QA Audit Schedule was issued on March 1973 as comnitted.
b.
The records of vendor audits are maintained by TUGC0 since they have assumed responsibility for these activities (see paragraph B. l.e above)', therefore, the only evidence of audit performance that was available for examination was in the documents referenced in paragraphs B. l.a and B. I.c above.
4.
(Closed) Unresolved item (Report No. 78-01) Project procedures were not clear with respect to design interf ace review requirements.
The inspector exa.ained Revision i to procedure DC-13 (Procedure for Identification Control of Design Interfaces, Both External and Internal) issued in August 1978, applicable revisions (Section III, page III-9) to the Project Guide issued April 14,1973, and the results of the specification and drawing reviews, and found that this item has been resolved.
C.
Design Inspection - Containment Soray 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 commitments, 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 folicw the guidance of Regulatory Guide 1.1.
Design analyses ec'3blish the capability of the system to c.
provide flow at.tes 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 them to be designed, fabricated, erected and tested in accordance with applicable ASME Section III and 10 CFR 50, Appendix B, requirements.
Provisions arid plans have been made for pre-operational and e.
operational testing consistent with SAR commitments and statements.
f.
The analysis (design) of system spray coverage supports SAR commitments and statements.
9 The system design for pH control including analyses of pH versus time af ter 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 analyse of the radio-logical consequences of a LOCA are consistent with item i.
above.
2.
fje_thod of Acccmplishment The preceding objectives were accomplished by an examination of:
a.
Sections 6.2.3 (Containment Air Purification and Cleanup System), 6.2.2 (Centainment Heat Removal System), and Table 6.2-11 (Containment Spray System Ccmponent Design Parameters) of the Comanche Peak Steam Electric Station (CPSES) FSAR; and Section 17.1.2 (Quality Assurance During Design and Construction (Gibbs & Hill)) of the CPSES PSAR to identify the technical and programmatic comitments for the Containment Spray System
(_C SS ).
b.
Procedure Nos. QA-1 (Design and Engineering Surveillence Procedure), DC-5 (Specification Production and Solicitation of Bids Procedure), DC-7 (Technical Calculation Procedure),
DC-9 (Design Review Procedure - Specifications), and DC-10 (Design Review Procedure - Calculations) of the CPSES Project Procedures Manual, and QAII-D (Engineering and Design Verification Procedure) of the G5H QA Manual to determine that they were consistent with SAR commitments.
c.
Calculation No. 232-1 (. Containment Spray NPSH) and associated records, e.g. Analysis & Calculation Control Sheet, I.O.M dated February 11, 1977 (Design Review Action), Design and Engineering Surveillance Record Sheet, Design Review -
Calculations - Record Form, and Mechanical Checklist -
Calculations to verify that it satisfied C.1.a and C.1.b above and was done in accordance with applicable procedures.
d.
Calculation No. NC-AA-13 (Containment Spray Iodine Removal) and associated records, e.g. IOM dated September 26, 1977, and Design Review - Calculation - Record Form to verify that it satisfied C.1.i above and was done in accordance with applicable procedures.
e.
Calculation No. 232-12 (Containment Spray System Orifice Sizing) and the associated Analysis & Calculation Control Sheet to verify that it satisfied C.1.a above and was done in accordance with applicable procedures.
f.
Specification No. MS-12 (Containment Spray Pump) Revision 2 dated April 29, 1975 and associated records, e.g. the Specification Review - Record Forms for Revisions 0,1, and 2 te verify that it satisfied C.1.a and C.1.d above, utilized the results of appli ?ble c acign analysis, and was done in accordance uith apglicauie procedures.
The objectives of paragraphs C.1.c, C.1.e, C.1.f, C.1.g, C.1.h and C.1.j above were not completed and will be scheduled for a future inspection.
3.
Findings a.
There were no unresolved items identified.
b.
Two (2) deviations were identified.
(See Enclosure, Items A and B).
D.
Exit Interview An exit interview was held with management representatives on December 15, 1978.
In additicn to those individuals indicated by an asterisk in each Details Section, those in attendance were:
P. P. DeRienzo, Vice President, Consultant Engineering and Quality Assurance R. H. Gordan, Senior Vice President, Power and Energy N. N. Keddis, QA Supervisor H. R. Rock, Project Manager i
The inspector summarized the scope and findings of the inspection.
Management representatives had no comments in response to each item discussed by the inspector.
DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Persons Contacted D. Conrade, Assistant Chief, Computer Services
- il. I. Hyman, Manager, Quality Assurance C. M. Jan, Assistant Chief Structural Engineer J. E. Triolo, Senior Engineer, Quality Assurance R. Prieto, Assistant Project Manager (GIS3SSAR)
C. it. Yeh, *;uclear Power Engineer
- Denotes those present at the exit meeting.
B.
Implementation of Quality Assurance Program on GIBBSSAR 1.
Objectives The objectives of this area of the inspection were to examine pertinent records associated with GIBBSSAR to assure that it is being developed under a controlled Qualtiy Assurance Program r.ad procedures meeting the requirements of the Gibbs and Hill Topical Report, GIBSAR-17.
The applicable areas in the GISBSSAR 3 cope of work include:
QA organization, QA program, training, design, procurement, QA records, audits and corrective action.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Gibbs and Hill Tooical Report, GIBSAR-17: Section 17.1.1 (Organization); 17.1.2 (QA Program); 17.1.J (Design Control);
17.1.4 (Procurement Document Control); 17.1.16 (Corrective Action); 17.1.17 (QA Records); 17.1.18 (Audits).
These establish program commitments.
b.
Quality Assurance Manual:
QAI-D-2 (Procedure for Indoctrination and Training); QAI-G (Procedure for Performance of Audits);
QAI-E (Procedure for Control of Ncnconformances and Corrective Action); QAI-F (Procedure for Control of QA Documents); QAII-C (Interface Control Procedure); QAII-D (Engineering and Design Verification Procedure); QAII-B.1. (Procedure for Preparation of Q-List); QAII-B.2. (. Technical Data Input Procedure);
QAII-B.4.1. (Analyses and Calculations Procedure - Pcwer Division); QAII-B.4.2. (Analyses and Calculations-Structural Division); QAII-B.7. (Safety Analysis Report Procedure).
These procedures provide detailed requirements to implement topical commi tmen ts.
c.
Gibbs and Hill Project Manual, including EDP-5 (Technical Calculations Procedure) and EDP-10 (Use and Control of Computer Programs). These procedures provide detailed requirements to implement topical commitments.
d.
Project Guide for GIBBSSAR, Revision 0 dated September 1, 1978, nich identifies applicable sections of the QA Manual and Project Manual above, any exceptions taken, and project unique requirements.
e.
Documents to verif y implementation of topical comitments and procedural requirements in the area of audits and corrective action:
(1) Audit of GISBSSAR activities issued May 2,1973. This is the only audit that has been performed, and consists of thirteen parts and attached deficiency forms covering the activities of:
(a) Nuclear Analyses and Calculations (b) Nuclear Engineering (c)
Project Administration (d) Applied Mechanics Engineering (e)
Structural Engineering (f)
Electrical Engineering (g)
Instrumentation and Control Engineering (h) Shielding Engineering (i )
Shielding Calculations (j ) Chemical Services Engineering (k) Chemical Services Calculations (1) Mechanical Calculations (m) Mechanical Engineering (2) Responses to audit findings; saluation (where available);
memo dated June 30, 1978 rejecting c. rtain responses; memo dated November 21, 1978 requesting response; and a memo dated December 13, 1973 accepting certain responses.
(3) Auditor qualifications for one auditor.
(4) Audit schedules of GIBBSSAR for 1978 and 1979.
No prior schedules were available.
(5 ) Scheduling of verification activities for above audit deficiences and responses. This schedule was issued December 13, 1978.
f.
Documents to verify implementation of topical commitments and procedural requirements in the area of training:
Training records for QA Seminar and Nuclear Engineering Course and/or Structural Engineering Course for seven (7)
GIBBSSAR project-assigned personnel.
g.
Documents to verify implementation of topical commitments and procedural requirements in the area of design:
(1) Safety Analysis Report Signoff Record (Form F 787) authorizing publication, signed by the originating discipline job engineer, supervisor (as applicable),
chief engineer, supporting (i.e. interfacing) disciplines (as applicable), project manager, and quality assurance; Verification Record (Form F 782) signed by independent reviewer, and applicable checklists, for the following GIBBSSAR Chapters / Sections:
(a) Section 3.9 - Mechanical Systems and Ccmponents:
Arrendment 2 and Amendment 4; Table 1.9-3 of Amendment 4; Table 3.9-2 of Amendmen. 7.
The current SAR (to Amendment 7) was also checked for inclusion of all approved revised sections and tables.
(b) Qualifications of independent reviewer for the above section.
(c) Section 3.8-Design of Category 1 Structures (Containment):
Subsection 3.8.1.6.e.1 of Amendment 3; Figures 3.8-1, 3.8-2, 3.8-3 and 3.8-4 of Amendment 3; Figures 3.8-1A, -1B, -1C,
-10, -1E, -1F, -1G, -1H 2 & 3 of Amendment 6.
(d) Section 6.3 - Emergency Core Cooling System (ECCS):
Original issue (showing this as ilSSS scope); Subsection 6.3.1 of Revision 5 (interface information).
(e)
Section 3.7 - Seismic Design: Original issue, Amendment 4, and A:rendment 5; Figure 3.7-18 of Amendment 5; Subsections 3.7.1.4, 3.7.2.1, 3.7.3.12b, and 3.7A, Revision 6. Text of the SAR was also checked for inclusion of approved revised sections.
(f) Chapter 7 - Instrumentation and Controls:
Original issue and Arrendment 1; Section 7.7 of Arendment 4.
(g) Spot check for above approval documents for original issue of Chapters 1, 2, 4, 8, and 12.
(2) Calculations examined for checker's initials, required approval, and check lists F870 and F769 (as applicable):
(a) Calculation t1C-AA Control Room Dose Analysis (input to TACT IV computer code program used for LOCA (Loss of Coolant Accident) analysis in Chapter 15, pages 15.6-15.12).
(b) Calculation t;C-AA-13 (input to TACT IV and graphs 15.6-5 through 15.6-18). Approvals were checked for Figures 15.6-7, 15.6-8, 15.6-14, 15.6-17, and 15.6-18 which were generated from input from flC-AA-13 fed into TACT IV program.
(c) Calculation t;C-AA Droplet Distribution and graph which became Figure 6.5-3 of A:rendment 5.
(3) Computer Codes used in GIBBSSAR checked for verification status and records (see also paragraph 3.h.(4) below for addition informatinn):
(a)
QUAKE:
verification done but not yet reviewed, approved and filed in house -(verified by STARDYNE and hand calculations).
(b) TIME:
verification done but not reviewed, approved and filed yet (STARDYliE used to verify).
(c) SCONV:
verification done but not reviewed, appoved, and filed yet (IBM program CSMT used to verify).
. (d) SPECTRA:
verification done but not yet reviewed, approved, and filed (Verification by comparison of computer output with spectrum curves).
(e) LCOL:
verification complete (by hand calculation).
(f) GALEGAS and GALELIQ:
source was NRC, modified in h
.se.
Verification is complete (verified by sample pragram in user's manual).
(g) AtilSN:
used for Fort Calhoun 1.
tio verification except standard use.
(h)
KALNINS:
used for Fort Calhoun 1, No verification except standard use.
(i) NASTRAN:
Public domain.
Used by NASA.
No verification except standard use.
3.
Findings a.
In this area of the inspection, three (3) deviations were identified (See Notice of Deviation Enclosure, Items C.,
D., and E.) No unresolved items were identified.
b.
Concerning Notice of Deviation Enclosure, Item E., prior to the conclusion of inspection, management obtained corrective action replies from three (3) departments / disciplines, and scheduled folicw up action dates for five (5) departments /
disciplines.
However, measures to prevent recurrence of this type of deviation have not yet been addressed by Gibbs and Hill.
c.
QA program requirements appear in GIBSAR-17 and in applicable procecures listed in paragraph B.2.b. above.
d.
The project organization is headed by a Project Manager and an Assistant Project Manager.
The QA function is being performed by the Gibbs and Hill QA Manager.
The project group includes Job Engineers / Supervisors assigned for each discipline to perform GIBBSSAR functions.
No consultants have been used, by report.
e.
No procurement activities have been perfor.ed for the GIBBSSAR project, by report.
f.
GISBSSAR records are considered preliminary by Gibbs and Hill until final acceptance by NRC.
Hence all GISBSSAR records are handled as " working documents" and have not come under the QA records procedures or controls
F requiring duplicate storage.
In general, they are maintained in working areas in single, non-fireproof files.
On this project, the documentation will be duplicated wnen NRC accepts GIBBSSAR, by report.
g.
The status of the project is that the original submittal was made to the NRC on October 15, 1976, and docketed on May 2, 1977.
Revision 7 has been generated and sent to NRC, and Revision 8 will be submitted approximately December 18, 1978.
First round questions frcm the NRC for Electrical and Power Systems are expected in January,1979, and the projected Preliminary Design Approval (PDA) by NRC is anticipated for January 15, 1980, issuance.
h.
All audit findings identified by Gibbs and Hill during their April audit of GIBBSSAR activities issus in May, 1978 are still open.
These have not been re-identified as new findings by the NRC inspector since they have already been identified by Gibbs and Hill.
However, they do appear to include significant items, such as:
(1)
Project Q-List not prepared or issued.
(2)
DDIRs (Design Data Input Records) not generated and/or not maintained properly by a number of disciplines.
(.3 ) Certain shielding calculations not submitted for design verification.
(4) Certain computer programs do not have verification records.
(The procedural requirement became effective May, 1977.
Prior programs generally did not have verification records, although some are being generated at present, as was verified by the NRC inspector).
(S)
Several calculations were identified that were not checked or not approved by job engineer.
An index of calcs had not been prepared by Chemical Services.
(6) No Project Guide had been issued.
(NRC inspector observed that it was subsequently issued on September 1, 1978).
Further review will be made during a subsequent inspection to assure that verification and closure have been performed by Gibbs and Hill for the deficiencies identified by Gibbs and Hill during their audit issued May 2,1978.