ML19350A669

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QA Program Insp Rept 99900519/80-03 on 801103-06. Noncompliance Noted:Failure to Initiate Mgt Corrective Action Rept as Required by Internal Procedures
ML19350A669
Person / Time
Issue date: 12/15/1980
From: Agee J, Donna Anderson, Bennett A, Brickley R, Hale C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19350A658 List:
References
REF-QA-99900519 NUDOCS 8103160624
Download: ML19350A669 (16)


Text

O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900519/80-03 Company:

Bechtel Power Corporation Gaithersburg Power Division 15740 Shady Grove Rd.

Gaithersburg, Maryland 20706 Inspection Conducted:

November 3-6, 1980 Inspectors:

7 2 N.~8 izfer/r4 R. H. Brickley, ffincipal Inspector Date Program Evaluation Section Vendor Inspection Branch Oc/Lv msen Ch

, Princigal'fInspector

0. Si. Jncerson Date Pro fam Evaluation Sectio 6 Vendor Inspection Branch 7. N Td N is//-5/x pJ.R.Agee,Contdl3ctorInspector Program Evaluation Section Vendor Inspection branch HNS Y

/1//flTo

. B. Bennett, Sr. f ectrical Engineer, IE/HQS

'Dath Approved by:

b C. J. HMF, )Cttief

-IC40 Date l

Program E Wluation Section Vendor Inspection Branch Summary i

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Inspection on November 3-6, 1980 (99900519/80-03) 8108160 hM,

2 Areas Inscected:

10 CFR 50, Appendix B in the areas of control of comcuter programs, oesign process management, design inspection - safe shutdown systems, follow-up on two (2) 10 CFR 50.55(e) reports, and action on previous inspection findings.

The inspection involved one hundred four (104) inspector hours on site by four (4) NRC inspectors.

Results:

There were two (2) deviations and no unresolved items identified.

Deviations:

Failure to initiate a Management Corrective Action Report (MCAR) as required by internal procedures (See Notice of Deviation, enclosure item A).

It could not be determined that the evaluation of a design change made to the Component Cooling Water System for the SNUPPS project was documented (See Notice of Deviation, enclosure item B).

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DETAILS SECTION I (Prepared by R. H. Brickley)

A.

Persons Contacted "J. Arbaiza, Quality Engineer M. D. Archdeacon, Assistant Project Engineer S. Blazo, Nuclear Engineer D. V. Denison, Mechanical Engineer E. C. Fratz, Lead QA Engineer L. Jha, Plant Design Engineer J. C. Judd, Chief Nuclear Engineer

  • H. W. Osgood, Supervisor of Radiation Analysis
  • C. R. Reid, Assistant Chief Nuclear Engineer
  • W. M. Turner, Project Quality Engineer D. S. Williams, Nuclear Engineer
  • Denotes attendance a* the exit interview.

B.

Action on Previous inscection findings (Closed) Deviation (Report No. 99S00519/80-02) Failure to follow procedures during evaluation of as-built configuration of nuclear safety related piping

mponents.

The inspector verified the corrective actions and preventive measures committed in their letter of response dated September 24, 1980, i.e. all applicable procedures were revised to include provisions to allow use of material test report values in determining system operability.

I C.

Piping Exoosed Outside Missile Barrier This item is a follow-up to a 10 CFR 50.55(e) report by the Licensee (Mississippi Power & Light Company - Grand Gulf Units 1 and 2) which reported that oil indicator piping for the two standby service water system cooling towers for Units 1 and 2 protrudes approximately two (2) feet past the cooling water missile barrier.

1.

Objectives The objectives of this area of the inspection were to:

l a.

Examine the results of the evaluation of this item to determine j

that a proper evaluation was performed.

b.

Determine whether this item is generic or plant unique.

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4 c.

Determine if tne QA progrsm requirements nere folicwed.

d.

Verify that the applicable recorting requirements were folicwed.

2.

Method of Acccmolishment The preceding objectives were accomolished by an examination of the records saintained on the Bechtel-GPD Quality Action Request No. F-227 consisting of Bechtel correspondence with MP&L and the designer (Ceramic Cooling Tower Co. ), Bechtel - GPD Specification 9645-M-015.1, and the designers drawings.

3.

Findings a.

General (1) The examination of the records revealed that if the oil line was broken, a loss of oil frcm the fan gear box could occur causing the gears to seize and disable the far.

Upon loss of the fans, a loss of cooling to the water in the SSW basins would occur preventing the SSW system frer. performing its function of cooling safety related equipment.

(2) The cooling towers were designed by the Ceramic Cooling Tower Company, Fort Worth, Texas, under the requirements of Bechtel - GPD Specification 9645-M-015.1.

Section 5 of this specification requires that the cooling t::wer structure be designed to prevent tornado missiles frca damaging the equipment.

(3) This item was determined to be unique to the Grand Gulf Station.

Paragraph 9.2.1.1.1.f of Section 9 of the FSAR states in part "The Standby Service Water (SSW) System is protected from extreme natural phenomena, missiles,...."

Since this ites relates to the SSW 5ystem and meets the criteria of Section 3.3 of Quality Assurance Department Procedure 16.1-1, an NCAR should have been issued.

(4) Applicable reporting recuirements were followed.

b.

ItemsofNancemoliance,beviations.andUnresolvedItems (1) There were no items of noncompliance or unresolved items identified.

(2) One deviation, was identified (See Notice of Deviation, Enclosure Item A).

All QA program requirements were not folicwed.

This item snould have been tracked by Bechtel via their Management

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'5 Corrective Action Report (MCAR) system, rather than by the Quality Action Request (QAR) system.

The MCAR system requires more management involvement and process control than the QAR system.

Paragraph 9.2.1.1.1.f of Section 9 of the FSAR states in part, "The Standby Service Water (SSW) System is protected frem extreme natural phenomenal, missiles,...." Since this item relates to the SSW system and meets the criteria of Section 3.3 of QADP 16.1-1, an MCAR should have been issued.

D.

HVAC Air Extractors Structurally Inadeouate This item is a followup to a PRD reported by the Licensee (Mississippi Power & Light Cor.pany - Grand Gulf Unit 1). When HVAC air extractors are installed to direct air flow vertically downward to air registers in the bottom of the duct, the weight of the assembly bears on a single vane,' causing it to bend, allowing the vanes to shut, and closing off air flow to the register.

In applicctions for horizontal air flow, the vane assemblies have a tendency to sag.

1.

Objectives The objectives of this area of the inspection were to:

a.

Examine the results of the evaluation of this item to determine that a proper evaluation was performed.

b.

Determine whether this item is gener'c or plant unique.

c.

Determine if the QA program requiremsnts were followed.

d.

Verify that the applicable reporting requirements were followed.

r 2.

Method of Accomplishment l

l The preceding oPlectives were accomplished by an examination of the records mainta'aed on the Bechtel-GPD Quality Action Request No. F-249

' consisting o' dechtel correspondence with the supplier (Tuttle & Bailey, New Britais, Ct), Bechtel Deficiency Report No. 0689, and Mf&L PRD No. 80foJ.

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3.

Findings a.

General (1) This item was identified on a Non "Q" system however this condition may exist on "Q" systems since those items are of the same or similar construction.

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6 (2) Investigation of this item by Bechtel and the supplier was still in progress at the time of this inspection there-fore no conclusions could be made with respect to the objectives identified in paragraph D.l. aoove.

b.

Items of Noncomoliance. Deviations, and Unresolved Items.

None were identified.

c.

Follow-up Items This item will be further examined during a future inspection.

'E.

Control of Comouter programs 1.

Objectives The objectives of this area of the inspection were to determine that:

a.

Computer programs have been developed, verified, qualified, and are being used in accordance with procedures which have been prepared, reviewed, and approved by authorized management.

b.

A computer program custodian has been designated and the responsibility for maintaining the recurity of the program.

c.

Each computer program that has been authorized for use has been qualified, has an appropriate users manual, and this manual (or another manual) provides a detailed description of the mathematical model(s), empirical data (if any),

assumptions used, and applicable references.

d.

The computer program has beal verified / qualified and that documentation exists which includes:

(1).. description of the program version and option (s) validated, (2) A detailed description of the test (benchmark) problem (s),

including boundary conditions, mathematical model, and all key parameters.

(3) A listing of the tes't (benchmark) problem input data checks and a reprint of the program input and output, or reference to the location where this is stored.

(4) The comparison of c'"tions, evaluation of the program validity, and an ana.y,is of any identified errors.

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Technically qualified individuals have reviewed and approved e.

the verification / qualification of each computer program prior to 'its use in safety related applications.

f.

Revisions and modifications have bsen subjected to the same review and approval as the original vartion of tne program.

g.

Errors identified in computer programs are promptly corrected and appropriately verified prior to use.

h.

Errors which could result in significant deficiencies in nuclear plant design are reported to the NRC under the requirements of 10 CFR 21, 10 CFR 50.55(e), and 10 CFR 50, Appendix K, as apprcpriate.

2.

Method of Accomolishment The preceding objectives were accor.plished by an examination of the Users Manual, Theoretical Manual, Verification Report, and the master file for computer program NE007.

In addition, the inspector examined applicable procedures from the Engineering Department Procedures Manual.

3.

Findings a.

General (1) The QAD series of computer programs are point-kernal general purpose shield 1g programs.

The program QAD-P5A, used both ror neutron anc gamma-ray shielding calculations, was converted to Combinatoria: Geometry (CG) input on the Univac 1100.

The CG subroutines from MORSE (a multigroup neutron and gamma-ray reate carlo transport program) ware substituted into QAD-P5A'to replace the guadratic surface input.

Other changes that were made to the program were the replacement of the aluminum energy absorption buildup factor with the concrete dose buildup factor, corrections to the Albert-Welton Kernal cons ants, and an. expansion of the blank common mesh to a 100 X 100 array.

(2) Engineering Department Procedure 4.36 (Standard Computer Programs) was found to define the requirements for verifi-cation, documentation and control of Standard Computer Programs (SCP) used by engineering for calculations and analysis.

Revision 1 of this procedure was found to impose the applicable requirements identified in paragraph E.1 above.

(3) Bechtel SCPs are controlled by a Program Sponsor assigned by Engineering Management who is responsible for overall direc-tion of program activities.

A Technical Specialist is i

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8 assigned by the Program Sponsor and is responsible for the technical integrity of the program, i.e. theoretical basis, accuracy of results, adequacy and completeness of documenta-tion, and recommendations for modifications.

In addition, a programmer is assigned to maintain and make changes to the program as required.

(4) Data Processing was found to be the custodian of the program with responsiblity for document control, distribution, certification of the computer operating system, release of an SCP into production status.

(5) The examination of the manuals identified in paragraph E.2 above revealed that they contained the applicable elements described in paragraphs E.1.c. through E.1.g. above.

b.

Items of Noncompliance, Deviations, and Unresolved Items None were identified.

F.

Exit Interview An exit interview was held with management representatives on November 6, 1980.

In addition to those individuals indicated by an asterisk in para-

--aph A of each Details Section, those in attendance were:

J. M. Amaral, Manager, Corporate QA N. P. Gael, Project Engineer B. K. Kanga, Manager of Engineering D. C. Kansal, Manager, Division QA J. Kroehler, Project QA Manager W. M. Mendus, Chief, Quality Engineer B. L. Meyers, Project Manager A. Zaccaria, Project Engineer l

The inspector discussed the scope and findings of the inspection. Manage-ment comments were generally for clarification only, or acknowledgement of the statements by the inspector.

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9 OETAILS SECTION II (Prepared by D. G. Anderson)

A.

Persons Contacted

  • R. H. Flugrath, Quality Assurance Manager-Audits C. M. Herbst, Assistant Group Supervisor-Mechanical
  • J. J. Milos, Project Quality Engineer J. C. Oleinik, Seismic Group Member E. W. Thomas, Civil Group Supervisor
  • Indicate t attendance at the exit interview.

B.

Design Process Management 1.

Objectives The objectives of this area of inspection were to examine the establish-ment and implementation of quality related procedures for the design process to verify that:

a.

The design process system is de. fined, implemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups perfcrming safety related design activities.

b.

Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures.

l c.

Appropriate quality standards for items important to safety i

are identified, documented, and their selection reviewed and l

approved.

l d.

Final design can be related to the design input with this traceability documented, including the steps performed from design input to final design.

e.

Design activities are documented in sufficient detail to permit design verification ana auditing.

f.

The methods are prescribed for preparing design analysis, drawings, specifications,'and other design documents so that they are planned, controlled, and correctly performed.

2.

Method of Accomolishment i

The preceding objectives were accomplished by an examination of tne following:

10 a.

Bechtel Power Corporation, Topical Report, SQ-TOP-1.

b.

Final Safety Analysis Report, Standardized Nuclear Unit Power Plant System (SNUPPS), Chapter 17A.1.3, Design Control.

c.

Appli able Engineering Department Procedures.

d.

Design criteria 10466-M-000Q, Mechanical / Nuclear Design Criteria for the Standardized Nucic., Unit Power Plant System, 8/30/77.

System description 10466-M-00EG(Q), System Description-Component e.

Cooling Water System, 9/9/77.

f.

Drawing numbers:

10466-M-01EG01 and 01EG02, SNUPPS System flow Diagram-Component Cooling Water System, 9/9/77.

10466-M-02EG01, 02, and 03, SNUPPS Piping and Instrument Diagrams, Component Cooling Water System, Revision 6, 8, and 10.

g.

Document Control Log 10466-AE010, Standardized Nuclear Unit Power Plant System, 8/26/80.

.h.

Calculations:

10466-MECH-80P-EG-7, Component Ceoling Water System, 1/9/78.

10466-13-05-CP, Auxiliary / Control Building " LUC 0" Program input Parameters, 0.25g SSE and 0.13 OBE, 5/12/75.

10466-13-01-CP, Auxiliary / Control Building Mathematical Models, Reference Drawings, and Material Properties, 5/12/75.

10466-13-02-CP, Auxiliary / Control Building, Section Properties and Mass Properties, 9/18/74.

i.

Computer program runs LUCO-Wolf Creek, 0.25 SSE(E-W),12/20/73; and FOSIN, Wolf Creek, 0.25 SSE(N-5), 12/4/74.

j.

Design Specifications:

10466-M-072 (Q), Design Specification for Component Cooling Water Heat Exchangers for SNUPPS, 12/27/79.

11 10466-M-082 (Q), Design Specification for Component Cooling Water Pumps for SNUPPS, 12/27/79.

10466-M-105A (Q), Design Specification for Shop Fabricated Tank ASME III for SNUPPS, 12/27/79.

10466-M-1018, Technical Specification for Pressure Vessels ASME VIII for SNUPPS, 9/5/78.

10466-M-201A (Q), Design Specification for Shop Fabricated Piping to ASME Section III for SNUPPS, 12/27/79.

l 10466-M-2318 (Q), Design Specification for 600 through 2500 pound Check, Gate and Globe Valves 2 inches and smaller Carbon and Stainless Steel to ASME Section III for Sf"JPPS, 8/22/80.

10466-M-223C (Q), Design Specification for 150 and 300 pound Check, Gate and Globe Valves 2 inches and Larger-Carbon Steel to ASME Section III for SNUPPS, 6/20/80.

k.

Floor sifsmic response spectra 10466-C-04A105, -04A015, -04A05s, and -04A035; Auxiliary / Control Building Mass Points 1, 3, 5, and 10; and 0.25g accelleration for the SSE, 10/29/76.

3.

Findings In this area of the inspection no unresolved items were identified.

The following deviation as identified:

In comparing Figure 9.2-3 (sheet 2) of the SNUPPS/FSAP with drawing 10466-M-02EG02(Q), the inspector noted that a two-way solenoid valve l

l and associated vent line had been deleted from the component cooling l

water system in both redundant trains of the bypass line for the CCWS heat exchangers.

Valves TV 29 and TV 30 control flow through the bypass line, and thus the CCWS heat exchangers, during normal operation.

During a LOCA, air to the operators for these valves is

_ vented through valves TY 298 and TY 308 and valves TV 29 and TV 30 close directing all flow through the CCWS heat exchangers.

Valves 298 and TY 308 are actuated by a SIS signal.

Drawing Change Notice, DCN 10466-M-02EG02 (Q), noted the deletion of these lines and valves; however, a safety evaluation of the effect l

of this design change was not documented.

Since ANSI N45.2.11 requires that design changes be evaluated for impact on other systems, and that these evaluations be documented, this item appears to indicate an inacequacy of procedures to address documentation of evaluations for design change control.

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C.

Action on Previous Inscection Fincines (Closed) Unresolved Item (Report No. 80-01):

Acditional examination of EDP instructions are r.eeded to cetermine that the requirements of EDP l-1.10 (EDP Instructions) are being followed.

The inspector reviewed EDPI 4.49-01 to assure that the requirements for review and approval of revisions and addenda meet the requirements of review and approval of project specifications as required by EDP 4.49.

The inspector also assured that the control, preparation and sign-off of key documents receives interdisciplinary review and sign-off and the process is described in EDPI 4.46-01.

The requirement will be reviewed during future inspections to assure that all changes and revisions to documents receive the same interdisciplinary review as is accorded the original document.

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DETAILS SECTICN III (Prepared by J. R. Agee and A. B. Bennett)

A.

Persons Contacted A. J. Diperna - Assistant Group Supervisor, Control Systems D. C. Gasda - Electrical Supervisor A. Hassan - Electrical Engineer C. M. Herbst - Assistant Group Supervisor, Mechanical H. F. Moate - Group Supervisor, Control Systems P. J. Rebstock - Group Leader, Control Systems B.

Design Insoection (Safe Shutdown Systems) 1.

Objectives The objectives of this area of the inspection were to verify that:

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a.

Adequate approved engineering documentation has been implemented to fulfill the Safety Analysis Report (SAR) requirements for safe shutdown systems in compliance with applicable regulatory guides and general design criteria.

b.

Approved analyses indicate that safe shutdown can be acccmplished for postulated single failures and/or failure of auxiliary systems.

c.

Adequata independence (separation) of equipment, cont"ols and instrumentation and circuits of redundant systems hac been pro-vided and that periodic testing can be accomplished without interruption of plant normal operation.

d.

Safe shutdown can be acccmplished from the main control rocm and from an auxiliary control roca or panel.

e.

Approved quality assurance procedures have been implemented regarding documentation of design information including drawing control, equipment and procurement specifications, and operating j

procedures for the safe shutdown systems.

2.

Method of Accomolishment The preceding objectives were accomplished by an examination of:

a.

SNUPPS FSAR sections that describe:

(1) Balance of Plant (BOP) Safe Shutdown Systems.

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l 14 (2) Auxilary Feedwater System (APA)

(3) Appendix 5.4A Safe Shutdown b.

P& ids M-02AL01(Q), AFW Control, Revision 6; M-02AB01(Q), Main Steam, Revision 6; and M-02KA05(Q), Compressed Air System, Revision 2.

Electrical drawing numbers E-03A608(Q), Condensate Storage Tank c.

(CSI) Isolation Valves, Instrumentation and Alarms, Revision 4; E-03ALO4(Q), Safety Circuits for CST Isolation Valves, Revision 4; E-03AB06(Q), Main Steam Atmospheric Vent Valves, Revision 3; E-03AL01(Q), Motor Driven Auxiliary Pumps, Revision 4; and J-05001(Q) Local Control Pand, RP118 Auxiliary Shutdown Panel, Revision 2.

d.

Technical specification numbers 10466-M-021(Q), AFW Pumps and Turbine Drive, Revision 12, December 27, 1979; 10466-E-009(Q),

Metal Clad Switchgear, December 12, 1978; 10466-J-200(Q), Main Control Panels, Revision 10, April 22,1980; 10466-J-201(Q),

Auxiliary Control Panels, Revision 6, July 27,1979; and 10466-J-104(Q), Engineered Safety Features Actuation System, Revision 11, June 13, 1980.

s 3.

Findinal a.

General (1) The determination was made that Bechtel is responsible for the design and procurement for BOP systems for the SNUPPS projects.

Bechtel is not responsible for construction or providing the system operating procedures.

Only equipment operating procedures furnished by tn equipment supplier are provided.

(2) The inspector selected the Ayxiliary Feedwater System for examination since it is a major system employed to achieve and maintain safe shutdown.

From the review of this system, the detennination was made that the system design, equipment specifications, and related controls had been completed in compliance with design criteria outlined in the FSAR and approved engineering. documentation.

(3) No separate analyses indicating that safe shutdown can be accomplished for postulated single failures have been compiled for the BOP systems except those analyses in the FSAR.

Failure Mode and Effects Analyses (FMEA) are in the applicable FSAR chapters, for example, Chapter 10 (Section 10.4.9 addresses Auxiliary Feedwater System design basis and Table 10.4.13 lists the single active failure analysis of the components in the system).

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FSAR Appendix 5.4A Safe Shutdown, Revision 1, dated October 1980 and table 5.4A-1 commit to compliance to General Design Criteria 1 through 5, 44, and 45, and to Regulatory Guides 1.25 and 1.29.

(5) P& ids and electrical schematic diagrams have been compiled to provide independence (separation) of equipment, controls and instrument circuits of redundant systems.

Examples include:

(a) P&ID M-02AL01(Q), Revision 5, Auxiliary Feedwater System, (AFS) displays the valve line-up for automatic transfer of AFS from the Condensate Storage Tank (CST) to a water source from the Essential Service Water.

(b) P&ID M-02KA05(Q), Compressed Air System, Revision 2, August 14, 1980, displays the redundant air supolies available for operation of the Automatic Steam Relief Valves and the corresponding AFS control valves.

(c) Electrical drawing i-03ALO4(Q), Safety Circuits for CST Isolation Valve,, Revision 4, displays redundant safety circuits fer the valve line-up shown on P&ID M-02ALO1(Q), item (a), above. This electrical drawing also displayed separation of circuits for manual and automatic operation of these valves from both the Main Control Board and the 30P Auxiliary Shutdcwn Panel.

(d) Electrical drawing E-03ALO1(Q), Motor Auxiliary Pumps, Revision 4, April 4,1980, displays circuits paralleled with control switch in the control room (control can be accomplished from either location without use of a transfer switch; the equipment responds to the last connand from either location).

(e) The SNUPPS sealed model was used to trace circuits and instrunent lines associated with the AFS. The related P& ids and electrical drawings referenced above were used for comparative data. The following tracings were made:

-instrument air lines from power operated steam valves to redundant air supplies.

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-power circuits (cable trays and conduit) from AFS pumps to distribution cubicles.

-control circuits (cable trays and conduit) from AFS pumps to main control room and to auxiliary shutdown panels.

3.

Findings 4

Deviations and Unresolved Items None were identified.

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