ML20005A245
| ML20005A245 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/1981 |
| From: | Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20005A241 | List: |
| References | |
| REF-QA-99900524 NUDOCS 8106300097 | |
| Download: ML20005A245 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900524/81-02 Company:
Gibbs and Hill Incorporated 393 Seventh Avenue New York, New York 10001 Inspection Conducted:
April 27 - May 1, 1981 Inspector:
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D. F. Fox, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch
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Approved by:
C. dipl'e, Chief Qate ReactUr Systems Section Vendor Inspection Branch
,Ssmmary Inspection on April 27 - May 1,1981 (99900524/81-02)
Areas Inspected:
Implementation of Title 10 CFR Part 50, Appendix B, including design process management and action on previous inspection findings.
The inspection involved 39 inspector hours on site by one NRC inspector.
Results:
In the two areas inspected, one nonconformance and two follow up items were identified in one of the areas.
Nonconformance:
Design Process Management:
Fai'ure to suomit to NRC changes in the QA program and organization described in the Gibbs and Hill Topical Report (See Notice of Nonconformance, enclosure).
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OETAILS A.
Persons Contacted
- R. E. Ballard, Manager of Projects E. J. Bond, Supervising Engineer, Special Analysis
- B. Czarnogorski, Ergineer, Quality Assurance
- P. P. DeRienzo, Vice President, Quality Assurance
- R. A. DiMarino, Senior Engineer, Mechanical J. R. Isgro, Supervising Engineer, Electrical
- N. N. Keddis, Manager, Quality Assurance J. Khinda, Senior Engineer, Special Analysis
- S. M. Marano, Project Engineer
- M. S. Miller, Supervisor, Quality Assurance P. A. Totten, Assistant Chief Engineer, Mechanical
- J. E. Triolo, Supervisor, Quality Assurance T. R. Vardaro, Supervising Job Engineer G. D. Weatherford, Chief Engineer, Building Services
- E. J. Zadina, Supervisor, Quality Assurance
- Denotes those present at the Exit Interview.
B.
Action on Previous Inspection Findings 1.
(0 pen) Unresolved Item (Report 80-02,Section I.C.3.b(1)) The following two identified safety concerns did not aprear to be timely evaluated and reported in accordance with the intent of 10 CFR Part 21.
a.
HEPA filters and demisters did not appear to be seismically qualified prior to their installation at Fort Calhoun and the Comanche Peak nuclear power station.
b.
The post LOCA airborne radiation protection afforded control room operators at the Fort Calhoun and the Comanche Peak nuclear power stations did not appear to be adequate.
With respect to item a, the inspector determined that representa-l tive HEPA filters and demisters have successfully passed seismic qualification testing to the seismic spectra specified for the Comanche Peak nuclear power station in April of 1980 and March of 1981 respectively.
The tests were conducted by Wyle Laboratory under the direction of the Corporate Consulting 1
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and Development Company, Limited.
Gibbs and Hill accepted and approved the seismic qualification test report for the HEPA filters on August 20, 1980, and stated that since a Gibbs and Hill engineering representative physically witnessed the seismic qualification testing of the demisters, acceptance and approval of the resulting test report by Gibbs and Hill is anticipated by June 15, 1981.
The G&H Special Analysis Department concluded that, as a result of the successful Comanche Peak seismic qualifi-cation testing and the significantly reduced amplitude of the seismic spectra associated with the design basis earthquake for the Fort Calhoun nuclear power station, the HEPA filters and demisters can be considered to be seismically qualified for use at Fort Calhoun.
With respect to item b, the inspector determined that Gibbs and Hill executive managment advised the Omaha Public Power System of a safety concern related to post LOCA control room habitability on May 14, 1979.
The letter stated that Gibbs and Hill "...
consider it our duty to bring these concerns to your attention
... (however) we discounted these discoveries on the following basis:
(1) This is not an accident considered by the NRC and (2)... the ventilation system was designed to operate with the doors normally closed."
Subsequent correspondance from the Omaha Public Power District to Gibbs and Hill, dated September 25, 1979, states in part that, "... it was determined that the concerns raised do not constitute a r&l'ation hazard to the public or to the control room operators.'
TUSI (Texas Utilities Services, Inc.) subsequently conducted a review of the habitability of the control room cf the Comanche 3
Peak nuclear power station in accordance with the requirements of NUREG-0737 (Clarification of TMI Action Plan Requirements).
TUSI correspondance dated April 13, 1981, stated that, ".
the review revealed several items which need additional clarification or changes... (specifically) if a radio-active cloud leaked into the unsealed unit two control room (which is currently under construction), there may be a dose to the unit one operators due to " shine" through the barrier... (Furthermore) Ocor E-40B in the rear of the control room is not designated as a shield door."
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4 TUSI is planning to submit the responses to these and other related questions to NRC in accordance with Section III.D.3.4 of NUREG-0737.
These items are being held open pending NRC Headquarters action /
guidance.
2.
(Closed) Nonconformance (Report 81-01, item A) Design drawings were not identified in accordance with the project procedure.
The inspector verified the corrective action and preventive measures described in Gibbs and Hill letter of response dated March 13, 1981.
Specifically, Design Control Procedure DC-3 (Orawing Production Procedure) was revised in March of 1981 to bring practice and procedure into convergence, and the administrative Project Engineer issued a memo to all Job Engineers on March 5, 1981, advising them of the procedural change and emphasing the preferable manner of identifying drawings.
3.
(Closed) Nonconformance (Report 81-01, item C) An engineering training course was not conducted as scheduled.
The inspector verified the corrective action and preventive measures described in the Gibbs and Hill letter of response dated March 13, 1981.
Specifically, Procedure QA-5 (Procedure for Indoctrination and Training) was revised to assign the responsibility for scheduling, initiating, arranging, and documenting of all training courses to the Training and Development Department, and the Training and Development Department issued a memo in March of 1981 to all Chief Engineers, Department Managers, and the Design Manager requesting that they identify their personnel training needs for 1981 so that the appropriate courses could be scheduled for 1981.
4 (Closed) Followup Item (Report 81-01,Section II.C.3) The Personnel Department Policy and Procedure Manual. and implementing instructions, did not appear to reflect the current NRC guidelines for verifying the education and experience of new employees.
The inspector determined that Gibbs and Hill Personnel Department Policy and Procedure Manual was revised on March 21, 1981, to state that any misrepresentation or falsification of the employment application on a personal resume is grounds for immediate dismissal.
The department's implementing instructions were revised on March 23, 1981, to require written verification of the new employee's education by the educational institution, and experience by the previous I
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employers, within approximately the first six weeks of employment.
In the event a satisfactory response is not received, the employing Technical Manager must document the basis for not immediately dis-charging the employee.,
C.
Desian Process Managemen,t 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 defined, implemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups performing safety related design activities, b.
Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures, c.
Appropriate quality standards of items important to safety are identified, documented, and their selection reviewed and approved.
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 and auditing.
f.
Methods are prescribed for preparing design analyses, drawings, specifications, and other design documents so that they are planned, controlled, and correctly performed.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine if procedtres have been prepared, approved, and issued to prescribe a con-trolled system for the management of tne design process that is concistent with commitments to NRC and objectives a.
through f. above.
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6 (1) Sections 17.1.2, 17.1.3, 17.1.5 and 17.1.6 of the NRC accepted Gibbs and Hill (G&H) Topical Report GIBSAR-17-A and amend-ments thereto, to determine the G&H corporate commitments relative to management of the design process.
(2) Applicable G&H Quality Assurance Procedures and Instructions
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to determine if the G&H corporate commitments relative to management of the design process were corr,ectly translated into quality assurance policies, procedures, and instructions that provide control over activities affecting the quality of the design that are within the G&H scope of supply.
(3) Applicable Comanche Peak Design Control Procedures and Project Control Procedures to verify that procedures have been established to implement the committed quality assurance program and to prescribe design activities that are within the G&H scope of supply, b.
Review of Sections 9.4.6.3, 9.4.7.1, 9.4.7.2, 9.4.7.3, and Figure 9.4.-8 of the PSAR; Sections 9.4C.1, 9.4C.3, 9.4C.4, 9.4C.5, Table 1.3-2 and Table 9.4-1 of the FSAR for the Comanche Peak nuclear power station, to determine the regulatory require-ments, safety classifications, technical requirements, specific design inputs, and quality assurance requirements of the ventilation systems for the diesel generators, electrical safeguards, and the control building uncontrolled access areas including the "Uninterruptible Power Supply" inverter and battery rooms.
c.
Review of the Technical Descriptions for the Diesel Generator Room Heating and Ventilation System (TD-0302, Revisions 0 and 1) and the Uncontrolled Access Heating, Ventilation and Air Condition-Ing Systems (TD-0305A, Revisions 0 and 1), and associated flow diagrams and composite drawings, to determine if sources of design inputs, such as PSAR/FSAR commitments, regulatory / quality requirements, and others, were correctly and traceably translated into verified final design cocuments and to the ultimately procured heating, ventilation and air conditioaing systems.
The following related documents were reviewed to determine if the quality assurance program for the management of the design process was being effectively implemented by the current G&H activities affecting the cuality of the design that are within the G&H scope of supply.
B
7 (1) Calculations (five).
(2) Design verifications (five).
(3) Orawings (33 G&H and 13 vendor).
(4) Equipment Environmental Qualification Report (two).
(5) Quality Assurance Requirements Documents (two).
(6) Safety Concerns (three).
(7) Specifications (18 G&H and 1 vendor).
3.
Findings a.
Nanconfon.ences One nonconformance was identified in this area of the inspection, as (See Notice of Noncenformance enclosure).
7ne following nonexclusive list of differences between the in place QA program and the program described in the Gibbs and Hill Topical Report GIBSAR-17-A, through amendment 4 dated January 1979, were noted by the inspector, Organizational structures and titles are different.
The Vice President, Consulting Engineering, QA and New Technology, has additional responsibilities and no longer reports to the Senior Vice President, Power and Energy.
The position of " Assistant to Vice President" has been addea.
The actual in place Engineering organizations, functions and QA interfaces are different.
The revisions of the Regulatory Guides endorsed by the in-place QA Program are different.
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Review and approval of calculations and technical specifications by Engineering and Quality Assurance are not as described in the Topical Report.
b.
Unresolved Items None were identified.
c.
Followup Items Although no specific nonadherences to procedural requirements or design errors were found during the inspection, the inspector expressed concern that the G&H design control program may not be effectively implemented in the areas of design inter-face control and design change control.
The following two items will be examined during future inspections:
(1) The effectiveness of the intradisciplinary and interdisciplinary review of both G&H and vendor design documents will be evaluated.
(2) The basis for, and tracking of, design changes from PSAR commitments will be evaluated.
O.
Exit Interview An exit interview was held with management representatives on May 1, 1981.
In addition to those individuals indicated by an asterisk in para-graph A above, those in attendance were:
L. B. Coggan, Project Engineer J. A. Gaynor, QA Engineer H. R. Rock, Vice President of Projects The inspector discussed the scope of the inspection and the details of the findings identified during the inspection.
The inspector also discussed the identification and processing of significant safety concerns under the provisions of 10 CFR Part 21.
Except as noted herein, the inspector stated that the in place QA Program appears to be satisfactorily implemented in the areas irspected.
Management comments were generally for clarification only, or acknowledgement of the statements by the inspector.
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