ML19351E713
| ML19351E713 | |
| Person / Time | |
|---|---|
| Issue date: | 10/17/1980 |
| From: | Agee J, Brickley R, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351E701 | List: |
| References | |
| REF-QA-99900521 NUDOCS 8012190080 | |
| Download: ML19351E713 (11) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900521/80-03 Program No. 51200 Company:
Bechtel Power Corporation Los Angeles Power Division P. O. Box 60860 Terminal Annex Los Angeles, California 90060 Inspection Conducted:
September 22-25, 1980 Inspectors:
EN3 y
/c!/4/70 R. H. Brickley, IS;;incipal Inspector I) ate Program Evaluation Section Vendor Inspection Branch
~77 N 73n.abAs <
iabe/ro g J. R. Agee, Contrac @ Inspector
'Date ComponentsSection II Vendor Inspection Branch Approved by-
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Date
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C. J.
Chief Progr '
aluation Section Vendor Inspection Branch Summarv Inspection on September 22-25, 1980 (99900521/80-03)
Areas Inspected:
10 CFR 21 and 10 CFR 50, Appendix B in the areas of design document control, design verification, and follow-up on one 10 CFR 50.55(e) and one 10 CFR 21 report. The inspection involved fifty-six (56) inspector hours on site by two (2) NRC inspectors.
Results: There were no items of noncompliance, or unresolved items identified in any of the areas.
The following deviations were identified in three (3) of the areas:
Deviations:
10 CFR 50.55(e) follow-up - failure to check a drawing for com-pliance with applicable codes and standards as required by procedures (Notice of Deviation, Item A), design verification - failure to require the evaluation 80121900%
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of the effect of revised calculations on those calculations that were based on results of the original calculation (Notice of Deviation, Item B); design document control - a calculation had not been approved within sixty (60) days following completion of the calculation (Notice of Deviation, Item C.),
calculation revision numbers identified in the Calculation Control Log and the CEBUS were not consistent (Notice of Deviation, Item D), a specific calculation could not be found (Notice of Deviation, Item E).
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DETAILS SECTION I (Prepared by R. H. Brickley)
A.
Persons Contacted D. R. Chauhan, Engineering Group Leader (EGL), Pipe.' tress and Supports (PS&S)
D. J. Freeland, Staff Member, Chief of Plant Design J. B. Hosmer, Assistant Project Engineer D. S. Jagahnathan, EGL, Civil / Structural (C/S)
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Z. Jeric, Project Engineer M. P. Ljubicic, Engineering Group Supervisor (EGS, PS&S)
V. Najarian, Assistant Project Engineer C. A. Palmquist, Engineer, C/S D. S. Parker, Manager, Materials & Quality Services (M&QS)
J. B. Roberts, Mechanical NSS Grcup Leader N. J. Thakur, M&QS Coordinator
- Denotes those in attendance at the exit interview.
B.
Inadequate Weld Inspection Procedure This item is a follow-up to a 10 CFR 50.55(e) report by the Licensee (Arizona Public Service Company - Palo Verde Units 1 & 2).
During an ANI review of welding documentation at the site, it was revealed that drawing 13-P-ZZG-011 (Form 84) required that all Class III welds 4 inch or less be visual inspected only, in noncompliance with the Winter 1975 Code Addenda-ND-5222 (applicable to Palo Verde).
1.
Objectives The objectives of this area of the inspection were to:
i s.
Examine the results of the evaluation of this item to determine that a proper evaluatics was performed.
b.
Determine whether this item is generic or plant unique, c.
Determine if the QA program requirement. were followed.
d.
Verifyt$attheapplicablereportingrequirementswerefollowed.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of the records maintained on Deficiency Evaluatica Report (DER) No. 30-5
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consisting of DER 80-5 Final Report, letters to the Licensee, QA Bulletin and response, and Licensee letter to NRC.
In addition the inspector examined applicable procedures from the Engineering Depart-ment Procedures Manual and the Project Internal Procedures Manual.
3.
Findings a.
General (1) The examination of the records on drawing 13-P-ZZG-011 revealed that Revision 2 to the drawing required that piping cless HBCB meer the requirements of the Winter 1975 Addeadt i.e.
Paragraph ND5222 requires that circum-ferential weld joints larger than 2 inch be examined by either magnetic particle, liquid penetrant, or radiographic methods. On Revision 3 to the drawing the requirements for this piping class was changed to require only a visual exam-ination for those welds between 2 and 4 inches. This change existed through Revision 11 of the drawing.
(2) The inspector verified that the drawing was revised via Drawing Change Notice No. 52 to bring it into conformance with the code.
(3) Of the 201 welds affected 3 were found defective'and were repaired.
In all cases minimum wall thichaess requirements were met.
(4) A QA Bulletin was sent to all projects alerting them of this
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problem. The projects response to the bulletin revealed that this problem existed only at Palo Verde.
(5) The inspector concluded that a proper evaluation had been sade and concurred in their decision that it was only Leport-able under 10 CTR 50.55(r.).
b.
Items of Noncompliance, Deviations. and Unresolved Items One deviation was identified (See Enclosure, Notice of Deviation, Item A).
C.
Deficient Pioe Suoport Design This item is a follow-up to a 10 CFR 21 report by Bechtel-LAPD regarding a defect in the design of pipe supports for Vogtle 1 & 2.
The load capacity tables for embed plates had been determined on the % sis of full engagement 3
area and no lateral loads on the weak axis of the embed. The use of these 3
tables in the design of supports had been based cut partial" engagement and
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- g. 3 allowed lateral loads in some cases. This situation could result in a pipe support design that exceeded the allowable embed loads.
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.
3.
Determine whether this item is generic or plant unique.
c.
Determine if the QA program requirements were followed.
d.
Verify that the applicable reporting requirements were followed.
2, Method of Accomplishment The preceding objectives were accomplished by an examination of Bechtel letters to NRC/RIV, internal memos, DER No. 004, Licensee letter to NRC/RII, Bechtel Problem Alert TPM-P-005, and applicable calenlations.
3.
Findings a.
General (1) This defect was found to affect 5763 ASME Section III and ANSI B31.1 pipe supports issued for constructiv_ as of January 18, 1980. Of these, 1306 (23%) were redesigned as a result of the Bechtel review.
(2) This defect was found to be the result of the project mis-interpretation of the requirements established in TPO Civil Design Guide C-2.36.
The response to the Problem Alert issued to all Bechtel projects revealed no other case where this misinterpretation occurred therefore this defect is project unique.
(3) The inspector concluded, from the records examined, that QA program and reporting requirements were followed, and that a proper evaluation was performed.
b.
Items of Noncompliance. Deviations. and Unresolved Items None identified.
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3.
.o D.
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:
Identify individuals or groups who aie authorized to perform a.
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 l
prc<en designs, known problems and their effects, and changes to previously verified designs.
d.
Identif: and document the method by which design verification is to be performed.
Identify the items to be considered during design verification e.
by reviews including selection and incorporation of inputs, necessary assumptions, quality and QA requirements, codes, standards,_ regulations, construction and operation experience, interfaces, design method used, comparison of output with input, item application suitability, material compatibility, and main-tenance features (see Section 6.3.1, N45.2.11).
f.
Prescribe the requirements for performing design verification by alternate calculations which shall include performance by a person or persons other than those who perfor=ed 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
~.I modes. Where the test is only intended to verify a specific design feature, the other features of the design shall be verified by other 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 preceding objectives were accomplished by an examination of applicable procedures contained in the Engineering Department and Project Internal Procedures Manuals and; selected drawings, System Descriptions, Calculations, and the Heat Exchanger Specification applicable to the Component Cooling Water System (CCWS).
3.
Findings s.
General (1) The examination of Engineering Department and Project Internal Procedures revealed that procedures had been established governing the items identified in D.1 above, however, a weakness was identified in the procedures for calculations as discussed in the following paragraph.
(2)
The examination of Calculation No. M26.7 (Desigt. Tempera-tures and Pressures of the CCW and SW Cooling Systems)
Revision 0 dated November 3, 1975, revealed that it was based on data obtained from Calculation M26.1 (CCW Heat Exchanger) Revision'0.
An examinatica of Calculation M26.1 revealed that it had undergone two (2) revisions since the initial issue.
No evidence could be found to
S indicate that the effect of these revisions on the validity of Calculation M26.7 or other calculations utilizing these data had been evaluated. Since none of the procedures governing calculations addressed this issue it is considered a procedural weakness (See Enclosure, Notice of Deviation, Item B).
(3) The examination of Calculation M26.53 (Pipe Rupture in Safe.y Equipment Building Tunnel) Revisica O dated December 16, 1975 revealed that they had determined that a rupture of the 10 inch Auxiliary Steam Line could result in a tunnel pressure of 8.5 psig (4 psig is the maximum allowed) and a thrust force of 15,235 lbs. The inspector verified that an 8 inch flow restrictor had been placed in this line to reduce the pressure in the tunnel below the maximum allowed.
(4) No cases were identified wherein existing procedural requirements were not isolemented.
b.
Deviations and Unresolved Items One deviation was identified (See Enclosure, Notice of Deviation, Item 3).
E.
Exit I terview An exit interview was held with management representatives on September 25, 1980.
In addition to those individuals indicated by an asterisk in Para-graph A of each Details Section those in attendance were:
J. E. Bashore, Project Manager A. G. Coutoumanos, QA Staff P. Dragolovich, Project Manager L. G. Hinkelman, Vice President and Deputy General Manager W. A. Homer, Manager of Engineering J. V. Morowski, Vice President and General Manager R. L. Patterson, QA Manager D. B. Wood, Assistant Project Manager The inspector summarized the scope and findings of the inspection. Manage-ment comments were generally for clarification only or acknowledgement of the statements by the inspector.
- 9 DETAILS SECTION II (Prepared by J. R. Agee)
A.
Persons Contacted S. H. Freid - Licensing Coordinator J. B. Hosmer - Assistant Project Engineer S. A. Lelever - Nuclear Systems Group Leader C. E. Michhart - Project Quality Engineer J. B. Roberts - NSSS Group Leader
- A. W. Stenerson - Project Quality Assurance Engineer K. R. Walvekar - Mechanical Engineering Group Supervisor C. Wreath - Project Control Center
- Attended the exit interview.
B.
Design Document Control 1.
The objectives of this area of the inspection were to determine that approved procedures have been established and are being implemented for the cont ol and distribution of design documents that provide for:
a.
Identification of personnel positions or organizations respons-ible for preparing, reviewing, approving, and issuing design documents.
b.
Identification of the proper documents to be used in performing the design.
c.
Coordination and control of design (internal and external) interface documents.
d.
Ascertaining that proper documents, and revisions thereto, are l
accessible and are being used.
I e.
Establishing distribution lists which are updated and maintained
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current.
2.
dethod of Accomplishment The preceding objectives were accomplished by review and examination of the following documents and areas:
I a.
Project Quality Assurance Manual Procedures; l
(1) Section 1.0 Division Organization and Responsibilities, Revision 5, November 15, 1977.
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10 (2) Section 1.1 Project Organization and Responsibilities, Revision 6, March 17, 1980.
b.
Project Internal Procedures Manual:
Engineering Sections; (1) 8.0, Drawing Preparation, Revision 20, August 2, 1980.
(2) 9.0, Drawing Control, Revision 5, March 29, 1978.
(3) 11.0, Specifications, Revision 13, March 14, 1980.
(4) 13.0, Specification Control, Revision 3, August 2, 1977.
(5) 14.0, Calculations, Revision 9, January 30, 1980.
(6) 22.0, Design Change Package and Startup Problem Report, Revision 5, January 30, 1980.
(7) 31.0, Pecords Management, Revision 4, June 7, 1980.
c.
Engineering Department Procedures (EDP);
(1) 4.2, Generic Engineering Documents, Revision 1, December 13, 1977.
(2) 4.65, Design Deficiency Processing, Revision 0, April 1, 1974.
(3) 4.47, Drawing Change Notice, Revision 2 LAPD, February 20, 1979.
(4) 3.7, Design Change Control, Revision 2, December 3, 1975.
(5) 6.3, Supplier and Subcontractor Design Document Control, Revision 1, August 13, 1975.
d.
Combustion Engineering, Inc., 3alance-of-Plant Criteria, 3410 MWT Plant, November 1971, Section 3.0, Chemical & Volume Control System (CVCS).
e.
Bechtel Transmittal Nos. 10722 dated October 24, 1979, and 14968 dated June 13, 1980, to Combustion Engineering with enclosed microfilm of contract drawings submitted for comment or con-currence.
f.
Ccabustion Engineering letter S-CE-5636 dated July 23,1979, and Bechtel letter Log BC-1515, dated November 29, 1979, concerning comments and approvals in the traasmittal and exchange of contract drawings.
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Findings a.
General Examination was made of CVCS documentation from the receipt of system initial criteria (item 2.d) to the generation and approval of system and equipment drawings, specifications, and calculations to storage, microfilming and distribution of the documents. The documents selected for examination were appropriately filed and/or accounted for except as identified in item b, below.
b.
Deviations Three (3) deviations were identified (See Notice of Deviation, Items C. D, and E).
c.
Unresolved Items None.
d.
Followup Items None.
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