ML19340E703
| ML19340E703 | |
| Person / Time | |
|---|---|
| Issue date: | 11/03/1980 |
| From: | Agee J, Donna Anderson, Brickley R, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19340E697 | List: |
| References | |
| REF-QA-99900501 NUDOCS 8101150460 | |
| Download: ML19340E703 (16) | |
Text
(N U.S. NUCLEAR REGULATORY CCMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT REGICN IV Report No. 99900501/80-01 Program No. 51200 Ccmpany:
Bechtel Power Corporation Ann Arbor Power Division 777 East Eisenhower Parkway Ann Arbor, Michigan 48106 Inspection Conducted: October 7-10, 1980 Inspectors: 'Id. N /
be ID/ye/fo R. H. Brickley, P @ cipal Inspector Date Program Evaluation Section Vendor Inpsection Branch
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D. G. Anderson, Principal Inspector Date '
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Oh J. V Agee, Cdftractor Inspector Date Program Evaluation Section Vendor Inspection 3 ranch h
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J.' 3dle, Chief Date
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Program Evaluation Section l
Vendor Inspection Branch l
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[ ' 3 ' 7/O Approved by:
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C. J. Ralje, Chief
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l Vendoc Inspection Branch 8101150Y(pO
2 Sumary Inspection conducted October 7-10, 1980 (99900501/80-01)
Areas Inspected:
10 CFR 50, Appendix B in the areas of design inspection design verification, design interfaces, and action on previous inspection findings. The inspection involved one hundred eleven (111) inspector-hours on site by four (4) NRC inspectors.
Results:
In the four (4) areas inspected there were no items of noncompliance or unresolved items identified. The following three (3) deviations were iden-tified:
Deviations: Design inspection microfilm (QA record) of two (2) calculations were not legible (See Notice of Deviation, Item A), design verification the procedure governing calculations does not require the identification of computer program number, name, or version used in design analysis (See Notice of Deviation, Item B), design interfaces, the Design Interface Control Log is not being maintained in the Control Systems Design Group as required.
(See Notice of Deviation, Ites C).
3 DETAIIS SECTION I (Prepared by R. H. Brickley)
A.
Persons Contacted D. D. Kopinski, Special Studies Sub Group Leader
- V. J. Manta, Project Quality Engineer A. Patel, Stress Group Leader, Plant Design L. H. Schroeder, Ecgineering Group Leader R. F. Tulloch, Plant Design Group Supervisor
- Denotes attendance at the exit interview.
B.
Initial Management Meeting 1.
Objectives A recent Bechtel Power Corporation organizational change established the Ann Arbor effice as a new Power Division.
The Ann Arbor office had previously been an Area Office of the San Francisco Power Division.
The objectives of this meeting were to acquaint management of this Power Division with the following:
a.
The Licensee Contractor Vendor Inspection Program (LCVIP).
b.
NRC organization relative to the Vendor Inspection Branch.
c.
Implementation of the LCVIP.
d.
Types of documents generated and processed in implementing the LCVIP.
2.
Meeting Results The preceding objectives were accomplished during a meeting on October 7, 1980. Those individuals present at that meeting, in addition to the inspection team, were:
Bechtel Ann Arbor Power Division (AAPD)
R. C. Ash, Project Procurement Manager, Midland
- R. Z. Baltazar, Project Quality Engineer (PQE), Duane Arnold L. M. Christian, Project Manager, Duane Arnold F. R. Culhane, Engineer, Business Development
4
- L.
H. Curtis, Project Engineer, Midland J. I. Dotson, Project Manager, Palisades
- L. A. Dreisbach, Project Quality Assurance Engineer
- L. J. Grant, Quality Assurance (QA)
- P. L. Gray, Project Supplier Quality, Midland J. L. Hurley, Project Engineer, Duane Arnold
- V. J. Manta, PQE, Midland
- J. R. McBride, Quality Engineer
- J. Milandin, QA Manager
- W. Moring, QA Engineer
- M. G. O'Mara, QE Supervisor
- G. L. Richardson, QA Supervisor E. A. Rumbaugh, Manager of Engineering
- J. A. Rutgers, Project Manager, Midland C. A. St. Onge, Project Engineer, Palisades C. F. Smith, Procurement
- R. K. Vassar, Project Operations & Service Manager
- H. W. Wahl, Vice President and General Manager
- K. Wiedner, Engineering Manager Consumer Power Company W. A. Bird, Project QA, Midland
- G. R. Eagle, Project QA, Midland
- Denotes those in attendance at the exit interview.
The following is a summary of the presentation made during this meeting. The presentation was made by Mr. C. J. Hale.
a.
The general LCVIP was described and how the Vendor Inspection Branch organizationally interfaces with the Office of Inspection and Enforcement and Region IV.
b.
The three phases of our inspectica program were described and the three components of our inspections i.e. programmatic, technical, and reactive.
The basis of our inspections was identified as 10 CFR Part 50, Appendix B, as implemented by topical QA programs or SARs and 10 CFR Part 21.
c.
The documentation and records generated and processed by our program were described, and include:
Reports-resulting from each inspection and issued within 30 days following the inspection.
Responses - due from the inspected organization within 30 days of receipt of Inspection Report and contain the results of their proprietary review and responses to the inspection findings
5 (deviations and violations) that include (1) actions taken to correct the identified problem (including the generic assessment of the problem); (2) action taken to prevent recurrence of the problem; (3) the dates the corrective and preventive actions were or will be completed.
Public Document Room (PER) - all reports and correspondence will be placed in the PER.
White Book - this publication is issued quarterly and summarizes the previous quarter's activities of the VIB.
Bulletins, Circulars, and Information Notices - these documents will be distributed to AAPD as they are issued by IE.
d.
Mr. R. H. Brickley, was identified as the principal contract and inspector for AAPD; however, begining in 1981 Mr. D. G.
Anderson would be assuming this responsibility.
C.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 99900522/79-03) A calculation on the containment spray system had not been checked as required.
The inspector verified the corrective actions and preventive measures committed in their letter of response dated July 11, 1979, i.e. Calcu-lation No. F-M-3720-33 was checked and approved, the survey for other unchecked calculations was completed and corrective action taken, and EDP 4.37 had been revised.
2.
(Closed) Deviation (Report No. 99900522/79-03) Solution - anneal heat treatment procedures were not submitted by a valve vendor for Bechtel approval prior to use as required by the procurement specification.
The inspector verified the corrective actions and preventive measures committed in their letter of response dated July 11, 1979, i.e. the Specification Change Notice and Supplier Quality Department Project Memorandum were issued.
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Note: The Ann Arbor Power Division was formerly part of the San Francisco Power Division (SFPD - Docket No. 99900522), therefore the preceding findings were issued against SFPD.
i D.
Design Inspection (Protection Against High Energy Line Ruptures in Fluid l
Systems Outside Containment) t 1.
Objectives The objectives of this area of the inspection were to select one or i
more high energy line systems and determine:
I I
I
6 a.
The assential systems that are proximate to any portion of the selected high energy line system.
b.
That the design analysis report combined with the composite drawing and stress isometric confirm that the integrity of the essential system would not be degraded in the event of a rupture at any location.
c.
That break point locations are in accordance with NRC guide-lines and have been indicated on the drawings.
d.
That, for high energy line fluid systems located in contain-sent penetration areas, the drawings and design basis provide confirmation that NRC criteria have been met, e.
That, for those essential systems that are not protected by either the separation or protective enclosure design methods, the applicable drawings identify the break point locations and the physical design features to protect the essential systems.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of documents applicable to this area of inspection i.e. the Midland FSAR (including questions and answers), Engineering Department Pro-cedures (EDP) Topical Report BN-TOP-2, stress isometrics, calculations, computer run (ME-101 program), P& ids, Bechtel/NRC Meeting Minutes, and training records.
3.
Findings a.
General (1) Personnel performing the High Energy Line Break Analysis (HELBA) were found to be utilizing Section 3.6 of the FSAR, NRC Branch Technical Positions APCSB 3-1 and MEB 3-1, and Topical Report BN-TOP-2 (Design for Pipe Break Effects) to govern the technical aspects of the HELBA.
These were supplemented by bi-weekly training sessions that were documented. The programmatic aspects were found to be governed by EDPs.
(2) The inspector selected the auxiliary feedwater system for examination and was able to verify that the break point locations were selected in accordance with NRC guidelines.
7 (3) The examination of the jet impingement analysis for Units 1 and 2 (Calculation Nos. AFW-7 and AFW-3) identified several target areas that required evaluation by other disciplines (civil, electrical, etc.) to determine that they could withstand the impingement forces.
The inspector verified that in one case (AFV-7/ Civil) the target areas and forces had been transmitted; however, due to other higher priority work, they had not been evaluated.
b.
Items of Noncompliance and Deviations (1) There were no items of noncompliance identified.
(2) During the examination of calculation No. AFW-1 (HEI.BA Break Point Selection for the Auxiliary Feedwater Discharge System, H633 Sh 4-7, Unit 1) the inspector noticed that J
several sheets of data from the associated computer run were not legible. The examination of the microfilm (QA record) revealed that it also was not legible.
A check of the microfilm en one additional calculation No. AFV-3 (HEI.BA Break Point Selection for the Auxilary Feedwater l
Discharge System, H634 Sh 5-8) revealed the same deficiency.
(See Enclosure, Notice of Deviation, Item A).
c.
Unresolved Items None identified.
d.
Follow-up Items (1) Verification that all target areas identified in AFW-1 and AFV-3 have been evaluated and resolved will be obesined during a future inspection.
1 E.
Exit Interview An exit interview was held with management representatives on October 10, 1980.
In addition to those individuals indicated by an asterisk in Psra-graph A of each Details Section (also Paragraph B of DetailsSection I) those in attendance were:
C. J. Buhl. Supplier Quality Manager R. R. Ploger, Manager, Administrative Services P. J. Presley, Quality Engineer J. B. Sullivan, Principal Engineer The inspector summarized the scope and findings of the inspection. The i
inspector also reminded them that the response to an inspection report commits them to completion of the identified actions by a specified date and should contain, as a minimum, the following:
L
8 1.
Corrective Actions A description of the steps that have been or will be taken to correct the item, the steps that have been or will be taken to assure that similar items do not exist, and the date these actions were or will be completed.
2.
Preventive Measures A description of the steps that have been or will be taken to pre-vent recurrence of this type deviation and the date these preventive measures were or will be completed.
In both cases the corrective and preventive actions must be documented and capable of being verified by the NRC inspector during a subsequent inspec-tion.
In addition, the inspector recommended that they give serious consideration to informing the NRC of the deficiencies that they had identified in the control of their computer programs as potentially reportable under 10 CFR 21.
(See DetailsSection II, paragraph B.3).
Management comments were generally for clarification only, or acknowledge-ment of the statements by the inspector.
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9 DETAILS SECTION II (Prepared by D. G. Anderson)
A.
Persons Contacted
- D. R. Anderson, Mechanical Group Supervisos J. A.. Clements, Nuclear Group Supervisor
- L. J. Grant, Quality Assurance Supervisor E. W. Hunt, Jr., Nuclear Systems Engineer
- M. G. O'Mara, Quality Engineering Supervisor
- Indicates attendance at the exit interview.
B.
Design Verification 1.
Objectives The objectives of, this area of the inspection were to determine that procedures have been established and are being implemented that:
a.
Identify individuals or groups who are authorized to perform design verification reviews.
b.
Require the results of the design verification effort to be clearly documented, with the identification of the verifier clearly indicated, and filed so they are identifiable to the document reviewed and can readily be retrieved.
c.
Require that the extent of design verification take into con-sideration the importance to safety, complexity, degree of standardization, state of the art, similarity with previously proven designs, applicability of standardized or previously proven designs, known problems and their effects, and changes to previously verified designs.
d.
Identify and document the method by which design verification is to be performed.
e.
Identify the items to be considered during design verification l
by reviews including selection and incorporation of inputs, necessary assumptions, quality and QA requirements, codes,
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standards, regulations, construction and operation experience, interfaces, design method used, comparison of output with input, item application suitability, material compatibility, and main-tenance features.
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10 f.
Prescribe the requirements for performing design verification by alternate calculations which shall include performance by a person or persons other than those who performed the original calculation, the review of appropriateness of assumptions, input data, and code or other calculation method used.
The selection of method shall provide results consistent with the original calculation.
g.
Prescribe the requirements for performing design verification by qualification testing which shall include requirements:
(1) For the identification, documentation, a demonstration of the adequacy of performance under the most adverse con-ditions, and consideration of all pertinent operating modes. Where the test is only intended to verify a specific design feature, the other features of the design shall be verified by :P.her means.
(2) That testing be performed in accordance with written test procedures which incorporate or reference the test require-ments, acceptance criteria limits and include provisions for assuring that prerequisities for the given test have been met, adequate instrumentation of the required range and accuracy is used, and that necessary monitoring is performed.
(3) That test results be documented and evaluated by the respons-ible designer and, if test results indicate that modifications to the item are needed, these modifications shall be docu-mented and the item modified, retested, or otherwise verified.
(4) That scaling laws be established and verified for tests performed on models or mock-ups and the test configurations clearly defined and documented.
(5) That the results of model test work be subject to error analysis, where applicable, prior to use in final design.
2.
Method of Accomplishment The inspector selected Midland Plant, Units.1 and 2, for evaluation of the inspection objectives in the area of design verification.
The Midland Plant is commited to Topical Report BQ-TOP-1, Revision 1, May 20, 1975, for compliance to the requirements of 10 CFR 50, Appendix B.
The following procedures implement the requirements of the Topical Report in the area of design verification.
11 EDP-4.46, Project Drawings, May 27, 1976.
EDP-4.37, Design Calculations, May 27, 1976.
EDP-4.36, Standard Computer Program, May 13, 1977.
EDP-4.49, Project Specifications, May 27, 1976.
EDP-4.58, Specifying and Reviewing Supplier Engineering and Quality Verification Documentation, May 22, 1978.
The inspector reviewed the following documents to assure that the above noted procedures are being implemented:
a.
Specifications / Purchase Orders:
7220-M-55-AC, Purch?se Order, Fuel Pool Cooling Heat Exchangers, 10/30/78.
7220-M-55(Q), Technical Specification for Fuel Fool Cooling Heat Exchangers for the Consumers Power Company Midland Plant, Units 1 and 2, March 31, 1977.
7220-M-54-AC, Purchase Order, Reactor Building Spray Pumps, July 12, 1977.
7220-M-54, Design Specification for Purchase of Reactor Building Spray Pumps for the Consumers Power Company Midland Plant Units.
1 and 2, June 30, 1977.
b.
Drawings:
7220-M-407, Liquid Waste Unit I and 2, Piping and Instrument Diagram, sheet la and IB, 2A and 23, 3A and 3B, 4/10/80 throug'a 8/15/80.
7220-M-410, Decay Heat Removal and Core Flooding, Unit 1, Piping and Instrument Diagram, June 27, 1980.
7220-M-413, Reactor BuildP.1 Spray, Unit 2, Piping and Instrument Diagram, Sheets A and B, 3/3/80 and 7/8/80.
7220-M-414, Fuel Pool Cooling and Purification, Piping and Instru-ment Diagram, Sheets A and B, 9/20/79 and 8/12/80.
7220-M-416, Component Cooling Water, Unit 1, Piping and Instrument Diagram, Sheets 1A, IB, 2A, and 2B 9/9/80.
c.
System Descriptions:
7220-SD-M-07, Liquid Waste System, 8/1/80, 7220-SD-M-10, Decay Heat Removal and Core Flooding System, 10/4/77.
7220-SD-M-12,_ Reactor Building Spray System, 5/9/77.
7220-SD-M-14, Spent Fuel Pool Cooling and Purification System, 6/17/77.
7220-SD-M-16, Component Cooling Water System, 10/17/78.
d.
Calculations:
Volume 20, FM 3715-1 through FM 3720, Final Midland Mechanical Calculations-Reactor Building Spray System.
n v
12 Volume 21, FM 3721-FM 3724, Final Midland Mechanical Calculations-Decay Heat Removal System.
Volume 22, FM 3725-FM 3740, Final Midland Mechanical Calculations-Reactor Building Spray System.
Volume 25B, FM 3820-3830, Final Midland Mechanical Calculations-Fuel Pool Cooling and Purification System.
Volume 25C, FM 3830-3860, Final Midland Mechanical Calculations-Component Cooling Water System.
e.
Computer Programs:
LINEDROP D7P103, Liquid Line Size Calculation, ME 499 User and Theoretical Manual, 4/25/79, ME 499 Verification Report, 4/30/79.
f.
Qualification Tests:
7220-M-54-70-3, Performance Test Report Reactor Building Spray through 73-2, Pumps, S/N 72240.through 72243, 8/15/77 through 10/28/77.
7220-M-54-75-1 Thermal Transient Test Report for Reactor Building through 77-1, Spray Pumps, S/N 72241 through 72243.
g.
Safety Analysis Reports:
Final Safety Analysis Report, Midland Plant, Units 1 and 2, Volume 11, Section 5.4.7, Decay Heat Removal System; Volume 13, Section 6.5.2, Containment Spray Pumps; Volume 15, Section 9.1.3, Fuel Pool Cooling and Purification System, and Volume 15, Section 9.2.2, Component Cooling Water System.
Volume 1, Appendix 4A, Responses to NRC Questions, Question 232.14, Fuel Storage Rack Criticality, including the following verification documentation:
Calculation 7220-C42-6-1, Criticality Analysis for the Midland Nuclear Plant Fuel Storage Racks, December 1978; and Babcock and Wilcox Report 1227, Fuel Storage Rack critically Analysis, 1/26/79.
3.
Findings In this area of the inspection, no unresolved items were identified.
The following deviation was identified (See Enclosure, Notice of Deviation, Item 3).
Topical Report BQ-TOP-1, Revision 1 is the quality assurance program-that Midland Units 1 and 2 are commited to, and in turn BQ-TOP-1 commits to meeting the requirements of ANSI N.45.2.11, Quality
13 Assurance Requirements for the Design of Nuclear Power Plants.
Section 4.2, Design Analyses, of this Standard, states in part,
" Analyses shall be sufficiently detailed as to purpose, method, assumptions, design input, references and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without recourse to the originator.
. Procedures shall include requirements for:
- 6. Identification of Computer calculations, including computer type, code or programming, inputs and outputs."
The inspector identified two (2) calculations, 7220-FM-3830-21 and-24, Component Cooling Water System, which did not reference the computer program name, number, or version used.
Since EDP 4.36 or 4.37, do not specifically address the information to be referenced when using computer programs for design analyses, this item was iden-tified as a deviation from commitment to ANSI N45.2.11.
Further discussions with Bechtel management resulted in the inspector being appraised that Bechtel had identified this itea in the internal audit program.
In particular, of 340 calculations audited, approximately 266 showed no indication of verification, 51 did not indicate either the program name, number, or version used, and in the final analysis, 212 calculations did not meet EDP 4.36 procedural requirements. The following corrective action has already been taken by Bechtel: All calculations and computer programs will be verified to meet program requirements. This action for all disciplines and projects involved will be completed by July 1, 1981. The following is action to prevent recurrence: Requirements for computer program documentation will be included in a revision (Manager of Engineering Dicective) to EDP 4.37 and the cover sheet for calculations. This action will be completed by December 15, 1980. Followup action by Bechtel resulted in a deter-mination that of the calculations which indicated no evidence of verification, approximately 70% have, as of the date of the inspection, been determined to have documentation of verification.
Since Bechtel has already instituted a program of corrective action and action to prevent recurrence, their management was notified that these items did not need to be addressed in their letter of response, however, since this ites appears to be a breakdown of the Bechtel Quality Assurance Program with regard to computer programs us-d in safety-related analyses, Bechtel was encouraged to consider the reporting of this item under the reporting requirements of 10 CFR Part 21.
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14 DETAILS SECTION III (Prepared by J. R. Agee)
A.
Persons Contacted J. M. Anderson - Control System Group Supervisor S. W. Emerson - Group Leader, Mechanical P. Presley - Quality Engineer C. A. Rixford - Document Control Supervisor D. D. Saqueton - Control System Engineer G. S. Singh - Control System Group Leader B.
Design Interfaces 1.
Objectives The objectives of this area of the inspection for both internal and external interfaces were to determine that procedures have been established and implemented that:
a.
Require that design organizations identify, in writing, their interfaces for managing the flow of design information.
b.
Define and document the responsibilities of each organizational unit for the preparation, review, approval, distribution, and revision of documents involving design interfaces.
c.
Establish methods for systematically communicating needed design information, including changes thereto, across design interfaces as work progresses.
d.
Require documentation of information transmitted between organi-zations which identified the status of the design information or documents and incomplete items which require further evalua-tion, review, or approval.
Require that design information transmitted orally or by other e.
informal means is promptly documented, and the documentation confirmed and controlled.
f.
Identify the external organizations providing criteria, designs, specifications, and technical direction.
g.
Identify the positions and titles of key personnel in the communi-cations channel and their responsibilities for decision making, problem resolution, providing and reviewing information.
15 2.
Method of Accomplishment The preceding objectives were accomplished by an examination of documents applicable to this area of the inspection, i.e., the Midland FSAR (including system descriptions); Engineering De? art-ment Procedures (EDPs); Engineering Department Procedure Instruc-tions (EDPIs); equipment specifications; P& ids; client, NSSS, and supplier interface correspondence and documentation; and Design Interface Control Logs.
In addition to the examination of interface documentation, an examination was made of the project administration files and verification made that interface documents are controlled.
3.
Findings a.
General The inspector selected the Main Control Room Control panel for examination and was able to verify that the related equipment specification had been initially reviewed and approved and that subsequent changes had been reviewed and approved by interface design groups in compliance with EDPI 4.49.1. Subsequent Design Change Requests (DCRs), Design Change Notices (DCNs), Design Change Packages (DCPs) had been distributed to interfacing design groups with appropriate routing stamps. Each interfacing design group supervisor had initialed and provided ccaments, as appropriate, in compliance with EDPI 4.25.1.
Correspondence transmitting the revised drawings, to the panel supplier with subsequent supplier response had been completed and documented in compliance with EDPs 4.58 and 5.16.
b.
Deviations arr.
resolved Items (1) Unresolve
,s None identi.
(2) Deviations l
See Notice of Deviation, Ites C.
i The Control System's Design Interface Control Log is a loose leaf notebook that was in the custody of the Control Systems Group Supervisor. Exhibit A of EDP 3.13 indicates that Project Administration is responsible for the specification control log while the Group Supervisor is responsible for accuracy. Frequency i
of control log issue is monthly. While the inspector did not verify the complete accuracy of the Control System Log, it is recognized the possibility exists that a page is not missing
16 and that, through personnel error, the interface control of one (1) specification (J-202) was omitted from this specific log.
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