ML20028F970

Responds to NRC 820202 Ltr Re Violations Noted in IE Insp Rept 50-508/82-20.Corrective Actions:Ebasco Site Support Engineering Considered in Compliance W/Procedural Requirements of E-76 & ANSI N45.2.11

ML20028F970
Person / Time
Site:	Satsop
Issue date:	01/17/1983
From:	Leddick R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20028F968	List: ML20028F970
References
GO3-83-49, NUDOCS 8302070255
Download: ML20028F970 (4)

Text

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f}yo Washington Public Power Supply System DJaff Box 1223 Elma, Washington 98541 (206)482-4428 /S N /h y' Docket No. 50-508 /,pg, January 17, 1983 G03-83-49 U. S. Nuclear Regulatory Commission, Region V Cffice of Inspection and Enforcement 1450 Maria Lane, Suite 260 Walnut Creek, California 94596-5368 Attention: Mr. D. M. Sternberg, Chief Reactor Projects Branch No. 1

Subject:

NRC INSPECTION AT WNP-3 IE REPORT NO. 50-508/82-20 NONCOMPLIANCES (50-508/82-20/01 AND 02)

Reference:

NRC Letter, Mr. D. M. Sternberg to Mr. R. S. Leddick, NRC Inspection at Washington Nuclear Project No. 3 (WNP-3),

dated December 2, 1982.

The referenced letter reported the results of the NRC inspections conducted by Mr. D. P. Haist on October 4-8 and November 1-3,1982, of activities author-ized by NRC Construction Permit No. CPPR-154. Two violations (Noncompliances) were identified as follows:

Violation A (Noncompliance 50-508/82-20/01), Safety-related design changes not verified by an individual independent of the individual who performed the original evaluation of the design changes.

Violation B (Noncompliance 50-508/82-20/02), Failure to perform design calculations in accordance with procedures.

Attached is the Supply System approved report detailing disagreement with Violation A as an Item of Noncompliance and the corrective / preventive actions taken for Violation B.

Should you have any questions or desire further information, please contact me directly.

'% i R.'S. Ledd ck (760)

Program Director, WNP-3 JAV:nj Attachments cc: J. Adams - NESCO D. Smithpeter - BPA Ebasco - New York WNP-3 Files - Richland 8302070255 830131 gDRADOCK 0500050s PDR

Attachment to

Letter, G03-83-49, dated January 17, 1983 l VIOLATION A (Noncompliance 50-508/82-20/01) 10CFR50, Appendix B, Criterion V states, in part, that: " Activities affecting j quality shall be... accomplished in accordance with... procedures..."

Section 17.1.3 of the Quality Assurance Program as documented in approved PSAR Deviation No. 26-WP states, in part, that: "The procurement documents specify that the contractors and vendors of Supply System Quality Class I items and activities develop and implement design and interface control procedures which assure: (d) Proper design verification...is performed...(e) Individuals or groups responsible for design verification or checking are other than those who performed the original design.

Ebasco Procedure No. E-76, " Guidelines for Design Verification," (January 20, 1982), Paragraph 11.0 states, in part, that: "A design change shall be verified

. using the same method by the same group or organizations as the original design

document." Paragraph 5.1.2 states that

" Qualified individuals meeting the definition of Independent Verifier as delineated in ANSI N45.2.ll-1974, Pars-graph 6.1 shall verify design outputs." Paragraph 4.4 states: " Independent Verifier - An engineer, designer or any competent individual, regardless of classification, who shall review, confirm or substantiate a specification, calculations, drawing or other valid technical comments and meet the following criteria of independence: (1) did not specify a singular design approach, (2) did not rule out certain design considerations, (3) did not establish the design inputs for the particular design being verified.

Contrary to the above requirements, safety-related design changes effected by Project Change Proposals Nos. 2464, 2497, 5884, 5897 and 8734 were not verified by an individual independent of the individual who performed the original evalu-ation of the design changes.

Object;;n to Item of Noncompliance The Supply System does not agree that Violation A is an Item of Noncompliance.

The Project Change Proposals (PCPs) referenced above were reviewed and technically accepted by Resident Engineers and subsequently verified by Ebasco Site Support Engineering (ESSE).

Design Change Quick Fix PCPs (QFPCPs) may be generated by centractors, Resident Engineers and/or ESSE. Each Design Change PCP receives review ar.d technical concurrence by Resident Engineering and verification by ESSE.

Resident Engineering's responsibility is chartered in Company Procedure, E-69,

" Design Change Notice, Field Change Notice," and delineated in PSP-RE-2-36.

" Initiation and Processing of Project Change Proposals." In accordance with PSP-RE-2-36, Resident Engineering reviews and provides technical concurrence with the design change and forwards the PCP to the ESSE LDE (Lead Discipline Engineer) for minor change concurrence and design verification. The design verification responsibility is chartered to the ESSE LDE and is performed in accordance with Frocedure E-76, " Guidelines for Design Verification."

All of the PCPs cited above were reviewed and technically accepted by ,

! Resident Engineering and verified by ESSE. This is in conformance with i

Ebasco Procedure E-76, Paragraph 4.4, and ANSI N45.2.ll-1974, Paragraph 6.0.

Attachment to: Letter, G03-83-49, dated January 17, 1983 f

VIOLATION A (Noncompliance 50-508/82-20/01) (Continued)

. Conclusion Design changes effected by PCPs are reviewed and technically accepted by Resident Engineering, then independently verified by ESSE. The Supply System believes that ESSE is in compliance with the procedural requirements of E-76 and ANSI N45.2.ll. Therefore, the Supply System does not agree with the NRC Item of Noncompliance (50-508/82-20/01).

As a result of recent Supply System audits in New York and at the site, Ebasco has revised the E procedures to clarify and emphasize the original intent of their implementing procedures. In addition, PSP-RE-2-36 is being revised to clearly establish and emphasize Resident Engineering's review and technical concurrence function. The revision to PSP-RE-2-36 is anticipated to be implemented by March 1, 1983.

VIOLATION B (Noncompliance 50-508/82-20/02) 10CFR50, Appendix B, Criterion V states, in part, that: " Activities affecting quality shall be... accomplished in accordance with... procedures..."

Section 17.1.3 of the Quality Assurance Program as documented in approved PSAR Deviation No. 26-WP states, in part, that: "The procurement documents specify that the contractors and vendors of Supply System Quality Class I items and activities develop and implement design and interface control procedures which assure:...(c) Application of design control measures."

Ebasco Procedure No. E-30, " Preparation of Calculations," (November 20,1979),

Paragraph 5.1.1 states, in part, that: "Each set of calculations should include some or all of the following items, depending on applicability: Cover sheet, table of contents, criteria, applicable codes and standards, assumptions...

summary of calculation results." Paragraph 5.1.2 states that: "Where detailed calculations are not warranted, a calculation sheet shall be completed to clearly state the basis of how the design data was developed." Paragraph 5.1.3 states, in part, that: "Each set of calculations shall have a cover sheet...The calcu-lation number may be a department-assigned number or a number assigned by the calculation originator." Paragraph 5.4 states that: " Assumptions and base data should be clearly stated, where they are introduced into the calculation, with justificatons and source." Paragraph 6.2 states, in part, that: "The checker is responsible for checking all of the originator's calculation package. The checker shall initial and date each page of the original calculations after they are completely checked..." Paragraph 8.1 states: "Each discipline, or depart-ment, shall maintain a record of all calculations they perform." Paragraph

8.2 states

"All calculations shall be kept in binders which are labeled as to the general subject..."

Contrary to the above requirements, a calculation prepared to justify a safety-related cable tray support detail design change (PCP No. 2464) was not assigned a calculation number, was not checked and was not filed in the department cal-

ulation binder. The calculation did not contain a cover sheet which clearly stated the basis of how the design data was developed and did not clearly state assumptions with justification and source of base data.

4ttachment to: Letter, G03-83-49, dated January 17, 1983 VIOLATION B (Noncompliance 50-508/82-20/02) (Continued)

Corrective Steps Taken And Results Achieved Ebasco Procedure E-30, " Preparation of Calculations," Paragraph 5.0 Celculations states in part:

"5.1.1 Each set of calculations should include some or all of the following items, depending on applicability: i a) Cover Sheet b) Table of Contents c) Criteria d) Applicable Codes and Standards e) Assumptions f) Calculations and/or Computer Printout Information g) Summary of Calculation Results" Calculations for QFPCP 2464 have been formalized per Ebasco Procedure E-30 and assigned Calculation No. 150. Calculation No.150 has been checked and filed in the ESSE Civil Department Calculation Binder and the PCP file.

Corrective Steps Taken To Avoid Further Items of Noncompliance The ESSE Civil Department is in the process of reviewing all PCPs previously processed by ESSE-Civil. This Item of Noncompliance is believed to be an isolated incident. However, any similar discrepancies revealed in ESSE-Civil's review will be corrected in accordance with Procedure E-30. To avoid future occurrences, all ESSE Civil Engineers and Designers, who are involved in pro-cessing PCPs, have been instructed on the requirements of E-30.

Date of Full Compliance The training on Procedure E-30 for ESSE Civil Engineers and Designers was com-pleted and documented on January 5, 1983. The completion of ESSE Civil Depart-ment's review of PCPs, previously processed by ESSE-Civil, is anticipated by June 30, 1983.

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