ML19296D855
| ML19296D855 | |
| Person / Time | |
|---|---|
| Issue date: | 12/28/1979 |
| From: | Mcfarland C, Vallish E, Webster E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19296D840 | List: |
| References | |
| REF-QA-99900509 NUDOCS 8003130366 | |
| Download: ML19296D855 (22) | |
Text
e U. S. NUCI. EAR REGUI.ATORY CO.tISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900509/79-05 Program No. 51200 Company:
Stone and Webster Engineering Corporation P. O. Box 2325 Boston, Massachusetts Inspection at:
Boston, Massachusetts Inspection Conducted: November 26-30, 1979 Inspectors:
k' Q
-+/
[)-)b '7f J. R. (oftEllo, Principsy Inspector, Region IV Date Program Evaluation Section Vendor Inspection Branch "h
v
/d/
Q-3T-79 J. M. fq on, Contraf Q Auditor, Region IV Date Program W aluation Sectidn Vendor Inspection Branch Qdu L3 ^6 79 Reactor h }struction and Engineering Support Branch C.R.Mcf2lahd.Principj^1laspector,RegionII Date 0
@-v I
E. L l' A ish, Mech'iii9 / Engineer, Region II Date a
M Reactor onstruction ahd Engineering Support Branch V
E. H. 'w'e tis r ', InspEctoY, fekion II Date Reactor ations and Nullear Support Branch y
8003130 % $
2 Approved by:
.s 1 Q_-
f-
'~
C. J. Hgl4, Chief Date Program'W aluation Section Vendor Inspection Branch Summary Inspection on November 26-30, 1979 (99900509/79-05)
Areas Inspected:
Implementation of the requirements of Title 10 CFR 50, Appendix 3, in the areas of QA records, follow-up on previous inspection findings, and follow-up on four (4) regional requests.
The inspection involved one hundred forty four (144) inspector hours on-site by five (5)
NRC inspectors.
Results:
In the six (6) areas inspected one (1) deviation and four (4) unresolved items were identified.
Findings pertaining to the four (4) regional requests will require further follow-up either through NRC Headquarters or Region II.
Deviation: QA Records - Contrary to procedural requirements, Project Manage-ment Department has not established all of the written procedures for the operation of the Record Retention Center (See Notice of Deviation).
Unresolved Items:
(1) Follow-up on regional requests - It is not apparent that a timely and complete generic review of amplified response spectra curves for all S&W projects is being conducted (DetailsSection II.B.3).
(2) Follow-up on regional requests - It is not apparent that a timely and complete generic review of the seismic requirement for safeguards area exhaust system ducting for all S&W projects is being conducted (DetailsSection II.B.4).
(3) Follow-up on regional requests - It is not apparent that adequate controls exist between the licensees and S&W to meet FSAR design commitments (DetailsSection III.B.3.e).
(4) Follow-up on regional requests - It is not apparent that the errors existing between the North Anna PSAR Supplementary Comment 7.4 and the actual installed design have been satisfactorily resolved (DetailsSection III.B.3.e).
(5) QA Records - It is not apparent that adequate measures have been established to control humidity to specified requirements in the Record Retention Center (DetailsSection IV.C.3.b).
9
3 DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted E. J. Adamson, Engineer R. P. Arsenault, Support Engineer J. W. Bonanno, Control Engineer
- L. S. Bright, Assistant Project Engineer
- W. R. Curtis, Engineering Assurance Engineer
- W. B. Dodson, Project Engineer
- V. C. Drotleff, Chief Power Engineer R. J. Faubert, Engineer
- E. B. Fleming, Senior QA Program Administrator J. F. Harkins, Senior Control Engineer G. A. Helm, Supervisor Quality Assurance Engineering, VEPC0 R. S. Hurford, Control Engineer
- B. F. Jones, Lead Engineer Power Division K. C. Knell., Engineer
- D. L. Mal-
- 3. Supervisor Engineering Assurance (Project Audits)
T. A. Mai..
Principal Engineer J. J. Morau, Licensing Engineer T. C. O'Connor, Project Engineer
- D. A. Piccione, Assistant Project Engineer C. G. Robertson, Supervisor Engineering Safeguards E. A. Warman, Assistant Chief Power Engineer H. B. Wessenger, Assistant Project Engineer
- C. H. Wilbur, Assistant Project Engineer
- Denotes those present at exit meeting.
B.
Follow-up on Previous Inspection Findings (Closed) Unresolved Item (Report No. 79-02):
It does not appear that Stone and Webster is imposing adequate requirements on their vendors in the case of significant conditions adverse to quality for assuring in a timely manner that the cause of the condition is determined and that corrective action is taken to preclude repetition.
The Manager Procurement Quality Assurance issued a directive to all procurement quality assurance personnel dated July 25, 1979, instructing them to tighten their enforcement of vendor corrective and preventive actions.
The Chief Engineer, Engineering Assurance, issued a letter to distribution dated August 13, 1979, instructing all cognizant personnel to rcport any instances of vendor failures to take prompt corrective and preventive action.
4 Also on November 29, 1979 a memo was issued by the assistant QA Manager's office asking that shop inspectors be reminded that vendors are required to identify nonconformances in their own nonconformance systems and, where required by specification, obtain approval of the disposition from S&W Engineering. All of these requested actions will be verified on future audits.
Note:
See DetailsSection IV for other follow-up on previous inspection findings.
C.
Follow-un on Reactor Containment Overpressurization. North Anna Units 3 and 4 1.
Objectives The objectives of this area of inspection were to answer the questions listed below.
These question were raised by an identified deficiency in the original analysis of containment pressurination resulting from a postulated main steam line break in the North Anna Power Station Units 3 and 4.
What is the present status of corrective action?
a.
b.
Did a weakness in the Quality Assurance Program permit this deficiency to occur and if so has it been corrected?
Is the problem generic and has 10 CFR Part 21 been properly c.
considered?
2.
Method of Accomplishment The preceding objectives were accomplished by (1) attending a Stone and Webster presentation covering the analysis of containment pressurization following a postulated main steam line break nd (2) an examination and discussion of the following documents:
a.
Section 14.2.2.1.5 of the North Anna 3 and 4 Preliminary Safety Analysis Report (PSAR) dated September 15, 1971.
this section covered the containment pressure evaluation in case of a steam line rupture.
The evaluation concerned itself only with the instantaneous release of mass energy and did not consider long term bl.Jown.
3 w
5 b.
Letter from E. H. McCallig, Project Engineer S&W to W. L.
Proffitt, Senior Vice President VEPC0 dated January 13, 1977.
The subject of this letter was " Auxiliary Feedwater System North Anna Units 3 and 4" and discusses various possibilities of limiting auxiliary feedwater flow to prevent over-pressurization.
Letter from James McFarland, Senior Project Manager B&W to c.
V. A. Hoffman, Project F.ngineer S&W dated November 29, 1978.
The subject of this letter was " Steam Line Break" and discusses the first two (2) of seven (7) special steam line break cases which B&W agreed to analyze.
d.
Letter from James McFarland, Senior Project Manager B&W to V. A. Hoffman, Project Engineer S&W dated May 3,1979. The subject of this letter was " Main Steam Line Break" and discusses the April 25, 1979, meeting held in Lynchburg, Virginia, to discuss the parameters for the remaining 3 through 7 special steam line break cases. This letter discusses the B&W proposed F0GG (Feed Only Good Generator) system.
Letter from James McFarland, Senior Project Manager B&W to V. A.
e.
Hoffman, Project Engineer S&W dated July 30, 1979.
The subject of this letter was "St' m Line Break" and discussed the analysis of steam line break cases 6.1, 6.2 and 6.a.
In this letter B&W recommended that S&W re-evaluate the auxiliary feedwater design to consider limiting flow during a steam line break.
f.
IE Information Notice No. 79-24 dated October 1, 1979. The subject of this notice was "Overpressurization of Containment of a PWR Plant after a Main Steam Line Break." This information notice pointed out that in a reanalysis of containment pressure following a main steam line break, if the auxiliary feedwater system continued to supply feedwater at runout conditions to the steam generator that had experienced the steam line break, containment design pressure would be exceeded in approx-imately 10 minutes.
g.
Letter from Sam C. Brown Jr., Senior Vice President VEPC0 to James P. O'Reilly, Director Office of Inspection and Enforcement USNRC dated October 4, 1979.
This was an interim report as the first report was made on September 4, 1979, under the provisions of 10 CFR 50.55(e) concerning the overpressurization of the containment from a Main Steam Line Break (MSLB) inside the containment.
This report stated that the PSAR containment M
6 pressure analysis did not consider the long term blowdown effects from a MSL3.
Preliminary calculations taking the long term blowdown into account, show that the containment design pressure will be exceeded in approximately 9 minutes due to the unabated auxiliary feedwater (AFW) flow feeding a MSLB inside the containment.
The long term addition of AFW results in the equivalent of a 177. sustained return to power which provides the energy necessary to support the " boil off" of the AFW.
This report also stated that VEPC0 is still evaluating modifications to limit AFW flow to the affected steam generator in the event of a MSLB.
h.
Initial Problem Report IPR 50503 entitled " Reactor Containment overpressurization" dated October IS,1979.
This initial problem report has wide distribution in Stone and Webster and is their method for obtaining corrective and preventive action.
In this report B. Jones of the Power Division was assigned responsibility for coordinating the investigation.
3.
Findings At the present time there is an extended construction delay a.
on North Anna Units 3 and 4.
As a result, the final solution to overpressurization of the reactor containment from a main steam line break is not being actively pursued.
b.
Stone and Webster was asked to do an analysis on Beaver Valley 1, Surry 1 and 2 and North Anna 1 and 2 to determine whether overpressurization of the reactor containment would occur from a main steam line break.
This analysis showed that it would not and that the problem was project unique to North Anna 3 and 4, which uses a B&k nuclear steam supply system.
North' Anna 3 and 4 is the only contract that S&W is presently involved in that uses a B&W nuclear steam supply system.
In the North Anna 3 and 4 design the requirement for auxiliary c.
feedwater for normal transients is 820 gpm to the two steam generators.
When a steam line break occurs, the pumps no longer have to pump against a pressure head and their flowrate increases to 2620 gpm. All of this flow goes to the bad generator and causes a lowering of the reactor coolcat temperature. This in turn results in a 17 percent sustained return to power transient which provides the energy necessary to support the " boil-off" of the continued auxiliary feedwater flow.
This is the problem that has to be corrected.
7 d.
Present studies of this problem are directed toward either developing flow limiting devices that would limit auxiliary feedwater flow in case of a main steam line break or developing a system that would send the auxiliary feedwater to the good generator only.
This latter system is called F0GG (Feed Only Good Generator).
e.
In reference to the question stated in C.1.b it must be remembered that much of this design was done in the 1971-1974 time frame. At that time the requirement for an independent design review was implemented considerally different than it is today. Also the state-of-the-art as reflected in the requirements of the North Anna PSAR (which assumed an instantaneous release of mass and energy in the case of a steam line break) is not as representative cf actual conditions as are today's requirements.
Stone and Webster's Quality Assurance Program has improved considerally since the 1971-74 time period.
The current S&W QA Program has well documented procedures which are being implemented and which should assure that future deficiencies of this kind would be lessened.
f.
In reference to the question stated in C.1.c the problem does not appear to be generic to other Stone & Webster plants.
- However, this problem should be considered on plants designed by other architect engineers which utilize B&W nuclear steam supply systems.
D.
Exit Meeting A meeting was conducted with mangement representatives at the conclusion of the inspection on November 30, 1979.
In addition to the individuals indicated by an asterisk in the Details Sections those in attendance were:
A. Banerjee, Assistant Project Engineer L. D. Barnes, Assistant Chief Engieer, Engineering Assurance N. B. Cleveland, Vice President, Quality Assurance G. D. Gowdy, Assistant Chief Engineer S. B. Jacobs, Chief Licensing Engineer J. W. Kelly, Quality Assurance Program Administrator R. B. Kelly, Manager Quality Assurance W. J. L. Kennedy, Director of Engineering L. D. Nace, Chief Engineer, Engineering Assurance H. L. Vener, Assistant Chief Engineering Mechanics
8 R. P. Wessel, Chief Engineer Engineering Mechanics P. A. Wild, Engineering Manager The inspector summarized the scope and findings of the inspection for those present at the meeting. Management representatives acknowledged the statements of the inspector.
g
9 DETAILS SECTION II (Prepared by C. R. McFarland and E. J. Vallish)
A.
Persons Contacted Stone and Webster Engineering Corporation (S&W)
- G. P. Milley, Lead and Principal Engineer, Pipe Stress Analysis, Engineering Mechanics Division (EMD)
K. E. Peterson, Principal Engineer, Structural Mechanics, EMD K. A. Condon, Supervisor, Structural Mechanics, EMD R. E. Foley, Assistant to Chief Engineer, EMD
- W. M. Eifert, Assistant Chief Engineer, Engineering Assurance Division (EAD)
- F. J. Mulligan, Supervisor Problem Reports, EAD
- D. L. Malone, Supervisor, Project Audits, EAD
- W. C. Drotieft, Chief Power Engineer E. A. Warmen, Assistant Chief Power Engineer
- R. B. Bradbury, Project Engineer, North Anna 1 and 2 H. B. Wessenger, Assistant Project Engineer, North Anna 3 and 4 M. Salvi, Assistant Project Engineer, North Anna 1 and 2
- B. F. Jones, Lead Engineer, Power Division C. J. Robertson, Supervisor, Engineering, Safeguards Virginia Electric and Power Company (VEPCO)
G. A. Helm, Supervisor, Quality Assurance Engineering
- Denotes those present at exit meeting.
B.
Licensee Identified Items, (Licensee Event Reports, 10 CFR 21 and 10 CFR 50.55(e) Items) 1.
Objectives The objectives of this area of the inspection were to review the status of items B3 and B4 (Amplified Response Spectrum (ARS) Curve Error and Safeguards Area Exhaust System), discuss with S&W staff the project and generic implicaticas of the identified problems; and review the schedule of work required to meet the required reporting requirements.
2.
Method of Acccmulishment The preceding objectives were accomplished by obtaining extensive briefings of the problems from the S&W staff; review of applicable procedures, internal office correspondence, Quality Assurance (QA)
10 and Quality Evaluation (QE) documentation; and the review of completed work of selected representative samples of comparable complexity.
3.
Amplified Response Spectrum (ARS) Curve Error VEPC0 notified Region II on November 5,1979, of an error found by S&W in their analysis of piping system seismic criteria as a Licensee Event Report for Unit 1 and under 10 CFR 21 and 10 CFR 50.55(e) for Unit 2.
As stated in the VEPC0 letter to Region II dated November 9, 1979, the error concerned the ARS curves applied to pipe stress analysis for safety related systems in the auxiliary building and other structures outside the containment building.
This error could yield unconservative pipe stresses, pipe support loads and equipment loads.
This error was found to apply to 44 isometric pipe drawings (MSKs) for Unit 1 (six Class 2 and 38 Class 3 lines; no Class 1) and eighteen MSKs for Unit 2 on shared systems.
Reanalysis of all affected drawings identified two pipes in Unit 1 and one pipe in Unit 2 which would have been overstressed during accident conditions as a result of this error.
Redesign work has been initiated and is scheduled to be completed by November 30, 1979.
After a comprehensive briefing on this subject ly S&W, the following documents relating to the old procedures and their revisions to preclude future occurrences of this nature, were reviewed:
Engineering Assurance Procedure (EAP) 5.3, Control of Computerized a.
and Manual Calculations.
b.
EAP 16.1, Problem Report System (a section of Chapter 16.0, Corrective Action).
c.
EAP 18.1, Engineering Assurauce (EA) Internal Audit Program.
d.
Engineering Mechanics Division Administrative Guideline (EMAG) 32, Control of Amplified Response Spectra (ARS) Data-Structural Mechanics, EMAG-50, Use of ARS by the Pipe Stress and Supports Section e.
(PSAS).
f.
EMAG-41, Preparation, Review and Control of Manual and Computerized Calculations.
11 g.
EA Audit Report 39-4, Manual Calculations and Computerized Calculation Summaries.
Audit dated September 20, 1979, North Anna 2 Pipe Stress Design Calculations.
h.
S&W letter VEPCO, II-7, November 13, 1979, ARS Curves Used in Pipe Stress Analysis, North Anna 1 and 2.
i.
Reportable Problems Log (of EA's Initial Problem Reports, IPRs).
j.
EA Task file 472, Hydraulic Snubbers, North Anna 1 and 2.
k.
EA Task file 514, Trunions on Category 1 Lines as Pipe Supports, North Anna 1.
1.
EA Task file 622, Pipe Support Base Plates, IEB 79-02, Generic.
EA Task file 603, Supplementary Neutron Shielding, North Anna 1.
m.
EA Task file 706, Containment Overpressurization, North Anna 3 n.
and 4.
The inspectors' review of the above documents included discussions with S&W management and technical staff responsible for the work associated with the content, implementation, and the monitoring of the work by Quality Assurance, Quality Engineering, and VEPCO.
Interoffice correspondence and the indices of the ARS for the piping systems in the affected structures were also reviewed by the inspectors.
The procedures reviewed provide for technical and administrative guidance, and instructions for the control of computerized and manual calculations have been routinely audited.
Samples of representative completed task files indicate that the IFR system has worked on problems that are comparable to the ARS problem.
The review of the task files indicate that the procedures are followed, the content of the IPRs is adequate, the reporting requirements are being met, the generic evaluations are being made routinely, and the timeliness of reports was adequate for the problems reviewed.
It was evident that requirements for documentation of the imple-mentation of relevant procedures have improved since the time of the initial design calculations and the earlier design review requirements in the 1971 through 1974 time period.
S&W action on the IPR's for the evaluation of the ARS curves used on other S&W projects such as Shoreham and Beaver Valley has not been ccmpleted to date. The need for a timely and complete generic review of this subject (Amplified Response Spri tra Curves) for all S&W projects is identified as an unresolved item.
12 4.
Safeguards Area Exhaust Svstem On November 1, 1979, the licensee notified the RII Office that the Safeguards Area Exhaust System which provides post LOCA ambient cooling for the recirculation spray and low head safety injection pumps was not entirely seismically designed as stated in FSAR Section 9.4.6.1 for North Anna, Unit 1 (LER 79-149/0IT-0); and as a 10 CFR 21 and 10 CFR 50.55(e) item for Unit 2 (VEPCO letter to Region II, November 9,1979).
Although the system from the Safe-guards area through the exhaust fans is a seismic Category 1 installation, the fan discharge ducting up to and including the discharge ventilation stack is not seismic Category 1; hence a seismic event coincident with a LOCA could cause the non-seismic discharge portion of the system to fail in such a manner as to prevent the exhaust system from performing its intended function.
Unit 2 has the same design and installation and is similarly affected.
During this inspection S&W briefed the inspectors on the general conditions pertaining to the safeguard areas exhaust fans, 1 RV-F-40A and 40B for Unit 1 and 2-HV-F-40A and 40B for Unic 2.
The S&W representative stated that an engineering evaluation is presently underway La determine what modifications are required to correct the possible design problem; and that if required, modifications
- o the systems will be made as determined necessary.
An interim 10 CFR 50.55(e) report is to be made on this item December 1, 1979. The final reports will be made after evaluating the options being studied.
S&W action on the IFR's for the evaluation of the safeguards area exhaust ducting on other S&W projects such as Shoreham and Beaver Valley has not been completed to date.
The need for a timely and complete generic review of this subject (Seismic Requirements for Safeguards Area Exhaust System Ducting) for all S&W projects is identified as an unresolved item.
5.
Findings Final reports for both of the above items, B.4 and 3.5, are to be submitted by VEPC0 to Region II as required for North Anna Unit I by Technical Specification 6.9.1.3; and for North Anna Unit 2 under 10 CFR 50.55(e). The review of these items and the reporting of subsequent inspections will be by Region II.
In this area of inspection, no deviations from commitments were identified, two (2) unresolved items were identified.
13 DETAILS SECTION III (Prepared by E. H. Webster)
A.
Persons Contacted Stone and Webster
- V. R Curtis, Senior Engineering Assurance Associate
- W. 3. Dodson, Project Engineer, North Anna 1 E. J. Adamson, Engineer, North Anna 1 R. P. Arsenault, Support Engineer, North Anna 1
- C. H. Wilber, Assistant Project Engineer, North Anna 1 K. C. Knell, Engineer, Surry T. A. Maynes, Principal Engineer, Surry T. C. O'Connor, Project Engineer, Surry
- D. A. Piccione, Assistant Project Engineer, Surry J. W. Bonanno, Control Engineer, Beaver Valley R. S. Hurford, Control Engineer, Beaver Valley R. J. Faubert, Engineer, Beaver Valley J. F. Harkins, Senior Control Engineer, Beaver Valley
- L. S. Bright, Assistant Project Engineer, Beaver Valley J. J. Moran, Licensing Engineer, Operating Plants Virginia Electric and Power Company G. A. Helm, Supervisor QA Engineering
- Denotes those present at exit meeting.
B.
Eneineered Safety Feature Reset Design 1.
Concern:
Operation of Containment Isolation or Safety Injection Reset resulting in equipment changing from the emergency operation mode.
Based on North Anna 1 LER 73-141/0IT-0, seven (7) ccmponent areas are affected:
Control room ventilation isolation dampers a.
b.
Safeguards areas exhaust ventilation emergency filter isolation dampers Inside and outside recirculation spray pump motors c.
d.
Containment recirculation cooling fans
14 Control rod drive mechanism cooling fans e.
f.
Service water isolation valves to the containment recirculation cooling fans g.
Turbine condenser air ejector exhaust isolation valves to the containment.
2.
References:
a.
IEEE Standard 279-1971 Sections 4.12, 4.13, and 4.16 b.
IEEE Standard 279-1968 (proposed) Sections 4.12, 4.13, and 4.16 c.
North Anna 1 and 2 FSAR Section 7 d.
Surry 1 and 2 FSAR Section 7.2.1.1 Beaver Valley FSAR Section 7.1.2.2 e.
f.
ESK, RE, and KSK prints of North Anna, Surry and Beaver Valley as held at Stone and Webster Corporate Offices, Boston, Massachusetts.
3.
Findings:
The design problem reported by the North Anna facility concerning a.
the recirculation spray pump motors not starting in the event that
" Containment Depressurization Reset" is used (and the actuation signal is gone for Surry) prior to completing the time delay (185 to 225 seconds after initiation to start the motor), is also true of the design in the recirculation spray pump motors (inside and outside) at Beaver Valley 1 and Surry 1.
The motor control circuits are so similar that it appears all Stone and Webster applications may be the same and therefore have this design.
This appears ta be inconsistent with IEEE Standard 279-1971 and 1968 (proposed) Section 4.16, which all three facilities have committed to.
References:
North Anna FSAR Sections 7.1.2. 3. 3, 7. 3.1. 3.5 (i) and FSAR Supplementary Comment 7.4 Surry FSAR Section 7.2.1.7 North Anna print 11715-ESK-5AW Surry print 11448-ESK-6AB
15 IEEE Std 279-1971 (North Anna and Beaver Valley)
IEEE Std 279-1968 (proposed) (Surry) b.
The Safeguards Area exhaust ventilation filter isolation damper at both North Anna and Surry shifts from the open (safety function) position to shut upon depressing the CDA (Containment Depressurization Actuation) reset push buttons (after the actuating signal is gone for Surry).
This feature may be inconsistent with IEEE Standard 279 Section 4.12, but may be mitigated by licensee administrative controls at Surry.
References:
North Anna and Surry FSAR Sections as stated in 3.a.
above.
IEEE Standard 279-1971 and 1968 (proposed)
North Anna print 11715-ESK-6PU Surry print 11448-ESK-6BH The control circuit design at Beaver Valley for the containment c.
recirculation cooling fans and the control rod drive mechanism fans is such that these fans may restart in one sequence of events after being secured by a containment Isolation Phase B (CIB) actuation.
Specifically, these fans are tripped from the INI electric bus when the feeder breaker to the bus trips on a CIB actuation.
After the CIB is reset and the INI bus is reenergized by the operator, a subsequent blackout would result in these fans being restarted when the emergency diesels restored power.
This feature may be inconsistent with IEEE 279-1971 Section 4.12, but may be mitigated by licensee administrative controls.
References:
Beaver Valley Section 7.1.2.3 IEEE Standard 279-1971 Beaver Valley 1 prints 11700-RE-21MF-1 11700-RE-21CZ-1 11700-RE-1K-8 d.
The containment isolation valves on the main condenser air ejector discharge piping to the containment could shift from their safety function condition (closed) upon Engineered Safety Function (ESF), reset at North Anna and Beaver Valley. At North Anna, should the main condenser air radiation monitor
16 indication reach its setpoint, the containment isolation valves would open to route the radioactive discharge to the containment.
If a Safety Injection (SI) actuation then occurred, these valves would shut on Phase A containment isolation.
If the air ejector discharge radiation monitors continued to read above set point, when the SI is reset, these containment isolation valves will reopen.
Beaver Valley's situation is similar, except that the CI3 signal shuts the one valve involved, which would subsequently reopen upon reset of the CIB.
These functions may be inconsistent with IEEE 279-1071 Section 4.12, but may be mitigated, in Beaver Valley's case, by administrative controls.
References:
North Anna FSAR as stated in 3.a. above Beaver Valley FSAR as stated in 3.c. above IEEE Standard 279-1971 North Anna 1 print 11715-ESK-6MN Beaver Valley 1 print 11700-RE-21KS The items identified by North Anna in LER 79-141/0IT-0 as notad e.
in the " concern" and the four above items all indicate inadequate controls existed between the licensees and Stone and Webster to meet FSAR design commitments, specifically regarding the controls for ESF reset at the North Anna facility requiring two deliberate operator actions (FSAR Section 7.3.1.3.5(i) and FSAR Comment 7.4) and to IEEE Standard 279 for Beaver Valley (FSAR Section 7.1.2.3) and Surry (FSAR Section 7.2.1. 7).
Pending NRC resolution of IEEE 279 Section 4.12 and 4.16 and Architect-Engineer evaluation of ESF reset functions at all of their projects, this item is unresolved.
It was noted that the Architect-Engineer promulgated Problem Reports on November 27, 1979, to investigate the scope of the EST reset problem with all of their projects.
Further action by NRC is being considered to communicate this area of concern to all licensees and to resolve similar problems that are found to exist at all other nuclear power plants.
The errors existing between the North Anna FSAR Supplementary Comment 7.4 and the actual installed design will remain unresolved pending further NRC evaluation of this area.
17 DETAILS SECTION IV (Prepared by J. M. Johnson)
A.
Persons Contacted
- W. R. Curtis, Engineer, Engineering Assurance (EA)
P. W. Day, Lead Engineer and Auditor, EA
- W.
Eifert, Assistant Chief, EA
- E. Fleming, Senior QA Engineer M. Godfrey, Computer Tape Librarian A. Isherwood, Supervisor, Computer Applications J. Jennings, Computer Program Librarian O. London, System Analyst
'A. J. Martino, Assistant Manager, Computer Department
- D. M. Oman, Assistant Manager, Records Management Division R. Schichter, Supervisor, Records Retention Center (RRC)
C. Stella, Computer Program Librarian K. Trumbore, Supervisor, Computer Production and Library W. White, Jr., Manager, Engineering Systems Department F. P. Whittaa, Manager, Computer Department H. Zassenhaus, Manager, Records Management Division
- Denotes those present at exit meeting.
B.
Follow-up on Previous Inscection Findings 1.
(Closed) Deviation (Report No. 79-02). Copies of certain documents listed on division QA records of general applicability were not at tne Record Retention Center (RRC). The documents listed on the deviation as missing are now available in the RRC. Also, a compre-hensive audit of record retention was performed, and training was conducted for appropriate personnel.
2.
(Closed) Unresolved Item (Report No. 79-02):
Procedures prepared by the Project Management Department for the operation of the RRC are in draft form and have not been issued.
Procedures RMG (Records Management Guideline) 2.1, Records Retention Facility Requirements, RMG 2.3, Transferring Records to the RRC, and RMG 2.4, Receiving Records at the RRC, were issued July 23, 1979, and September 1, 1979.
Because procedure RMG 2.6, Retrieval of Records frca Records Retention Center is still in draft form, and current practice permits check out and temporary retention for use by employees of QA records, a devi-ation was issued (See Notice of De tiation).
18 C.
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 QA records system is defined, implemented, and anforced in a.
accordance with approved procedures, instructions. or other documentation for all groups performing safety related activities including QA, design, procurement, administration, and services.
(QA records generated after commercial operation are subject to the record ccatrol system.)
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 record in the storage area. Any changes or modifications to these records are controlled.
A specific submittal plan for QA records is established between c.
the licensee and contractor and records exist that acknowledge 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 inspection of incoming records including a current assessment of the status of incoming records.
A custodian has been designated to assure that QA records are e.
in accordance 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 regulaticas consistent with NRC Regulatory -
Guide 1.88.
g.
The QA record storage system is periodically audited to assure the record control system is implemented.
19 2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
Topical Report SWSQAP1-74A, Revision C, Section 17, Quality a.
Assurance Records, to determine program commitments.
b.
Quality Standards QS-17.1, Quality Assurance Records System, and QS-17.2, Forms Control, to determine procedural requirements.
Quality Assurance Directive QAD-17.1, QA Site File, and QAD 17.4, c.
Processing of QA Department Documents for Permanent File Storage, to determine procedural requirements.
d.
Engineering Assurance Prc EAP 17. 1, Collection and Retention of Quality Assurat.-
cords, EAP 17.2, Quality Assurance Records, and EAP 5.2, Preparation and Control of Division Guidelines, to determine procedural requirements.
Records Management Guidelines RMG 2.1, Records Retention e.
Facility Requirements, RMG 2.3, fransferring Ru ords to the RRC, and RMG 2.4, Receiving Records at the RRC; these were examined to determine procedural requirements.
f.
Draft version of Records Management Guideline RMG 2.6, Retrieval of Records from the RRC (not issued yet) to determine proposed requirements.
g.
ANSI PH 1.43, invoked by RMG 2.1, concerning storage of microforms.
h.
Memos issued by W. Glass, Supervisor of Office Facilities Department, covering procedural requirements for operation of RRC.
Records Management System RMS-1, General Instruction for the use of the Corporate Master Records Type List, including attachment 3, Master Records Type List, showing Record Descrip-tion and Retention Requirements.
j.
Records of training conducted to assure familiarity with QA Record requirements which included dates of training, list of attendees and format of training session.
k.
EA Audit issued September 28, 1979, concerning dual storage of QA records, including two (2-) audit observations, EA-045 and Power 022, and their status.
The scope of the audit was also examined.
1.
QA Department Special Study (Audit) of QA Record Retention issued June 1,1979, and incorporated recommendations.
(No specific re-sponses to these recommendations were required.)
20 QA Records examined for duplicate retention (i.e. in departmental m.
files and in RRC):
(1) Records listed in Notice of Deviation Enclosure to Inspection Report 79-02 as missing from RRC:
(a) EAG-XXVII-12-1, Electrical Design Criteria.
(b) EMAG-37, Revision 0, Conceptual Design Review.
(c) EMTR-400, Revision A, Material Properties for Pipe Rupture Analysis.
(d) ME-023-022:. Seismic Analysis of Piping Systems (SHOCK 3).
(e) Weld Procedure W53M.
(2) EA Audit No. 77/071: EA Corrective Action Status Report dated January 12, 1979.
(3) EA Audit No. 79/026: EA Audit Report of QA and Audit Division performed December, 1978, through January, 1979.
(4) EA Audit No. 79/0669: EA Audit Report of Shoreham Project (Audit No. 24)
(5) EA Auditor Qualifications for two (2) auditors.
(6) Problem Reports Nos..
PR-5-o, PR-5-8, PR-5-13, PR-EM-1, PR-E-9, and PR-E-13, Revision 0 and Revision 1.
(7) Computer Codes Nos: ME-023-0501 (Seismic Analysis o#
a Piping System - SHOCK 3) and ME-018-0301 (Pipe Stress Analysis -P Stress).
(8) Computer Code User's Manuals for: ME-023-0303 (Draf t);
ME-023-0501 (Draf t), ME-018-0301 (Draf t); ME-095-0302 (Pipe Lug Stress Analysis - PI Lug); ME-110-0310 (NUPIPE_
SW); ME-155-0103 (Pipe Bearing Stress Analysis - SEARST);
St-306-0101 (QUAKE): ST-312-0001 (QUAKE 2); and ST-235-0101 (Nodal Forces Due to Pressure Load for STRUDL - Hatch -
PLOAD).
n.
L.D. Nace Interoffice Memorandum No. 79/376 dated April 2, 1979 approving deviation from EAP 5.25 requirements to consider draf t versions of User's Manuals for ME-023, ME-018, ME-095, and other listed computer codes, to be complete when required revisions have been completed and documented.
21 Com) uter Program Documentation Review and Approval forms for o.
ME-018 and ME-023.
p.
Inspection of RRC storage facility, including microform storage area and microforms in Treasury area, to assure that procedural requirements of RRG 2.1 are met.
q.
Examination of temperature / humidity recorder in the microform storage area, which read 70 degrees Fahrenheit and 527. rh (relative humidity).
Review of RRC Log Book, which indicates records (some QA and r.
some non-QA) checked out by Stone and Webster personnel.
3.
Findings In this area of the inspection, one (1) deviation was identified.
a.
(See Notice of Deviation).
b.
In this area of the inspection, one (1) unresolved item was identified, as follows:
Procedure RMG 2.1, Revis' a 0, issued July 23, 1979, requires storage of film in the RRC to comply with the environmental con-dition requirements of ANSI PH 1.43, which recommends that hum-idity be maintained between 15 percent and 40 percent relative humidity in an archival, long-term storage environment.
It is not clear what measures Stone and Webster is taking to provide assurance that the humidity within the RRC microform storage area remains within this range and avoids extreme changes in humidity. No control device was in operation during the in-spection, and the humidity indicator was observed at a reading of 52 percent relative humidity.
Also, the condition of microforms which have already been stored for several years appears indeterminate because no inspection for possible deterioration has been conducted.
Procedure RRG 2.1, which requires such an inspection for condition every two (2) years, was issued July 23, 1979.
c.
(1) Concerning the Notice of Deviation, please note that draft procedure RRG 2.6, not yet approved and issued, appears to cover this area adequately to assure safety of the records.
This draft indicates that a copy will be maintained in RRC of any QA records checked out for use.
(2) Meantime, however, QA records have been checked out (with-out a copy maintained in RRC) in accordance with memos issued by Office Facilities Department which provide
22 instructions for withdrawal for use of QA records by Stone and Webster employees. These memos require a log-ging system to indicate the person who checked the record out, his location, the date checked out, and the date of return. There is also a form to be used at the discretion of the Supervisor, RRC, to request the person who has a QA record in his possession to indicate the proposed date of return of the record.
(3) The authorization of these memos issued by Office Facilities Department is unclear, since no RRG has yet been issued to delineate controlling requirements for the retrieval, check out, use and return of QA records stored in the RRC.
d.
There is no reader for microforms in the RRC. Therefore, the inspector was able to verify that the microform listing the record as contained thereen was available at RRC, but was unable to verify condition, legibility or completeness of the QA record contained on the microform, since there was no way to read the microform.
.