ML20031C939
| ML20031C939 | |
| Person / Time | |
|---|---|
| Issue date: | 05/26/1981 |
| From: | Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031C901 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8110090144 | |
| Download: ML20031C939 (17) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900525/81-01 Company:
Gilbert / Commonwealth P. O. Box 1498 Reading, Pennsylvania 19603 Inspection Conducted:
March 31 - April 2, 1981 Inspectors:
%b 80bi/
- 0. F.sFJx, Contractor Ifs'pector Date f
Reactor Systems Section Vendor Inspection Branch Approved by:
O hM<N C. J.(Ha)e,' Chief " ~
Date Reacto'r-Systems Section Vendor Inspection Branch i
Summary Inspection on March 31 - April 2, 1981 (99900525/81-01) i Areas Inspected:
Implementation of Title 10 CFR Part 50, Appendix B, and l
Topical Report GAI-TR-106 in the areas of design document control, follow up on NRC regional requests, technical personnel background verification, and action on previous inspection findings.
The inspection involved 30 inspector hours on site by one NRC inspector.
Results:
In the four areas inspected, two nonconformances were identified in l
one of the areas.
One unresolved item was identified.
Nonconformances:
Actions on Previous Inspection Findings:
Gilbert /Commonwealtn did not follow their approved 10 CFR Part 21 finplementing procedure.
(See Notice of Nonconformance enclosure, item A.) Errors and deficiencies were not detected during the design verification cycle nor oy QA audits.
(See Notice of Nonconformance enclosure, item B.)
Unresolved Item:
Gilbert / Commonwealth did not appear to fully evaluate and document the generic impact of identified substantial safety hazards.
(See Details, paragraph B.5.)
8110090144 810629 PDR GA999 EECGDAS 99900525 PDR
2 DETAILS SECTION A.
Persons Contacted R. P. Cronk, Project Engineer, V. C. Summer Project R. F. Ely, Staff Engineer, Applied Engineering Analysis
- R. J. Hoffert, QA Coordinator, V. C. Summer Project
- R. C. Holzwarth, Manager, Corporate QA Programs D. K. Kelly, Electrical Engineer, V. C. Summer Project
- G. M. Kowal, Manager, Computer Applications
- A. G. Maino, Senior QA Program Manager
- F. W. Maryniak, Manager, Personnel
- W. E. Meek, Vice Preisdent, Engineering Department W. F. Olsen, Supervisor, Standards and Procedures
- F. C. Prawlocki, Supervisor, QA Audits
- F. R. Ricci, Manager, Design Control
- R. M. Rogers, Project Manager, TMI-1 Continuing Services Project R. J. Sheldon, Project Engineer, V. C. Summer Project
- Denotes those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation B (Report 80-03).
Drawings were revised and issued by other than the originating organization and without documented evidence of interface review.
The inspector verified the corrective action and preventive measures described in the G/C (Gilbert / Commonwealth) letter of response dated January 21, 1981.
- pecifically
An f ?.erface review was conducted and documented on the piping a.
drawings identified by the inspector, b.
Four QA audits for documentation of drawing interface review were conducted of selected project engineering organizations.
c.
The Vice President of Engineering issued two memoranda to all engineering department managers reaffi ming that all revisions to a drawing must be intiated by the discipline that originated the drawing and that all such revisions must be interface-reviewed by all affected disciplines.
d.
Design Control Procedure OCP 1.30 (GAI Drawings) was revised to require sign-off, on the drawing itself, by affected interfacing organizations.
Drawing title blocks are being revised accord-ingly.
.s 3
G/C Quality Assurance audited the mechanical and the instrumentation and control (I&C) disciplines of the TMI-2 Continuing Services (Restart)
Project during this inspection and determined that additional drawings, beyond those identified by the inspector during inspection 80-03, were revised by an interfacing discipline (I&C) and not by the discipline that orginated the drawing (mechanical).
All such drawings were subsequently reviewed by the originating organization and signed off accordingly.
The Vice President of Engineering and the Manager of Projects co-issued a memorandum to all Project Managers stating that all revisions to drawings will henceforth be approved and issued by the discipline that originated the drawing as required by DCP 2.20 (Change Notices) and DCP 1.30 (GAI Drawings).
2.
(Closed) Unresolved Item (Report 80-03,Section I.B.8).
Safety related services provided to licensees may not be conducted in
~
accordance with an approved quality assurance program.
G/C management stated that G/C provides personnel and services under an approved G/C QA Program as well as providing personnel to clients who work under the clients' quality assurance program.
The Reading Office provides personnel and services to three licensees under the direct control of G/C management, and personnel to eight licensees who work under the direction of the licensee.
The Jackson Office provides personnel and services to four licensees under the direct control of G/C management, and personnel to two licensees who work i
under the direction of the licensee.
3 The inspector verified that G/C has inplace QA Programs governing the safety related activities administrated by the Reading Office.
G/C management stated that those safety related activities administrated by the Jackson Office were also governed by approved QA Programs.
1 The relationship for " loaned employees" (ie, those who work under the direction of non G/C management) was not clearly stated in all " loaned employee" agreements with all clients.
G/C has formally requested of applicable clients that they confirm, in writing, that all G/C employees " loaned" to them conduct safety related activities in strict accordance with the client's procedures, including the report-ing of significant safety hazards.
Confirmation of the above has been received from three clients to date.
4 I
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4 3.
(Closed) Unresolved Item (Report 80-03,Section I.C.3.b).
G/C did not follow their implementing 10 CFR Part 21 procedure with respect to procedurally unathorized individuals cunducting preliminary evaluations of possible reportable events.
This item has been elevated to a nonconformance.
See Notice of Nonconformance enclosure, item A.
The inspector verified that G/C took corrective action and implemented preventive measures during this inspection, therefore no further written response to this nonconformance is required.
Specifically, (1) the 12 safety concerns that were not processed in accordance with the 10 CFR Part 21 implementing procedure in effect at the time were reviewed and signed by individuals procedurally authorized to do so; (2) the 10 CFR Part 21 implementing procedure (Procedure For Processing Reportable Events) was revised on February,27, 1981, to clarify the requirements for identifying, evaluating, documenting, and reporting of substantial safety hazards; and (3) training classes on the pro-cessing of reportable events were conducted by G/C Quality Assurance.
4.
(Closed) Follow up Item (Report 80-03,Section I.C.3.c(11)).
Training of G/C personnel may not have been conducted for all individuals performing safety related activities subject to the G/C procedure for processing of reportable events.
The inspector verified that G/C conducted training classes on Revision 1 of the procedure for Processing of Reportable Events for all G/C organizational units performing safety related activities and transmitted a list of significant changes made in Revision 2 of the precedure to all affected individuals.
5.
(Closed) Follow up Item (Report 80-03,Section I.C.3.c(2)).
Maintenance of records which are required to assure compliance with 10 CFR Part 21 requirements did not appear to be complete for identified safety hazards.
Based on examination of the existing reccrds of the G/C evaluation of identified safety hazards which were made available during the inspection, the inspector could not verify that G/C had fully evaluated and documented the generic impact of identified substantial safety hazards as required by 10 CFR Part 21.
This is considered to be an unresolved item and will be evaluated further during a subsequent inspection.
C.
Action on NRC Regional Requests 1.
Objectives
5 The objectives of this area of the inspection were to verify that:
a.
The available information and documentation are complete and accurate.
b.
The cause and effect of the incident were accurately identified, evaluated and documented.
c.
The corrective action and preventive measures are being planned or implemented.
d.
The generic aspects have been considered and affected organizations have been notified.
2.
Flange Material Design Error a.
Background
South Carolina Electric & Gas Company verbally notified NRC Region II, on July 8, 1990, that as a result of a design error by the architect engineer (Gilbert / Commonwealth),
eleven flanges on safety class 2 systems in V. C. Summer Unit 1 did not meet the material requirements for mating parts that were identified by the NSSS supplier (Westing-house),
b.
Problem SFR (Startup Field Report) 2522, issued May 22, 1980, identified that seven 300 PSI rated flanges, fabricated from SA 182 F304 (304 grade stainless steel), were install-ed in 600 PSI safety class 2 systems in violation of G/C material specification SP-545-044461-00 (Pipe Line Specifi-cation for Nuclear Safety Class Piping).
This specification requires that 600 PSI rated flanges be used in 600 PSI maximim piping systems and that 300 PSI rated flanges be used in 300 PSI maximum piping systems, and that all flauges be fabricated from SA 182 F304 material.
c.
Cause Westinghouse supplied Rockwell drawing 0-449593, Revision C, (Stainless Steel Nuclear Service 10" Butterfly Valve) identified that the valve flanges were sized for 300 PSI service.
The drawing did not identify the materials used to construct the flanges.
Westinghouse material specification G-678854, Revision 1,
6 permits the use of 300 PSI rated flanges in 600 PSI maximum piping systems provided that they are fabricated from SA 182 F316 (316 grade stainless steel) and the maximum system pressure and temperature do not exceed 600 PSIG and 400 degrees fahrenheit respectively.
G/C drawing E-304-645 (through Revision 11 dated July 12, 1980, Residual Heat Removal - Auxiliary Building) improperly identified the G/C supplied mating flange, to be 300 PSI rated SA 182 F304 flange for use in a 600 PSI system, in violation of both the Westinghouse and the G/C material specification requirements.
G/C drawing E-304-645 (through Revision 11 dated July 12, 1980) was checked by a drawing checker and reviewed and approved by two G/C engineers in accordance with approved G/C procedures.
The design error (i.e., not specifying the flange material to be SA 182 F316) was not detected through revision 11 of this drawing.
d.
Effect G/C engineering stated that preliminary stress analysis calcula-tions (CGGS-20874) indicate that the 300 PSI rated SA 132 F304 flange and bolt stresses do not exceed 85 percent of the stress limits allowed by Appendix I to Section III of the ASME Boiler and Pressure Vessel Code.
Based on these results, G/C engineering concluded that operation of the RHR system would not jeopardize the health and welfare of the public.
e.
Generic Impact Review of Westinghouse flow diagrams for the NSSS by G/C indicated that the design error was limited to flanges in the residual heat removal system, chemical volume and control system, and the safety injection system in the V. C. Summer Unit 1 nuclear power station.
G/C engineering stated that these design errors were solely related to interfaces with Westinghouse supplied 600 PSI systems that use 300 PSI rated SA 182 F316 flanges, and did not occur in other G/C designed piping systems.
I 7
f.
Corrective Actions G/C engineering recommended that the installed flanges be replaced with 300 PSI SA 182 F316 flanges in accordance with Westinghouse material specification G-678854, Revision 1.
G/C engineering stated that this recommendation was made prin-cipally because the stress analyses were based on preliminary (not as-built) data, and to assure full compliance of the design with the committed requirements of ANSI B 16.5-1963, rather than on the safety significance of the design erro..
G/C drawing E-304-645 was revised (Revision 12) on November 24, 1980, to reflect this recommendation.
G/C engineering statert that other affected drawings were also revised.
Fiald Change Request number B-10,085 was issued on June 26, 1980, to effect the necessary changes in the installed piping systems at the V. C. Summer Unit 1 site.
g.
Preventive Measures l
G/C engineering considers this to be an isolated design error, and no changes in the existing design control procedures are planned at this time.
See nonconformance identified at the end of this section.
2.
Component Cooling Swing Pumo Starting Failure l
a.
Background
l South Carolina Electric & Gas Company verbally notified NRC Region II on October 23, 1980, that. as a result of a design error by the architect engineer (G/C), the component cooling water (CCW) pump would not start on a load sequencer signal when the pump was lined up as the primary CCW pump.
SCE&G submitted a written finsi report to Region II on November 21, 1980, stating that the necessary control circuit changes had been effectect.
b.
Problem Startup Field Report 2577, issued May 31, 1980, identified that the startup circuitry for the "C" component cooling water pump will not allow "C" pumo to run when it was lined-up as the primary CCW pump and "A" or "B" pump was lined-up to back-up pump "C".
Specifically, interlock contacts from "A" pump, or "B" pump, when either pump was lined up as the backup to "C" pump, prevented a sequence start signal from energizing the "C" pump.
8 c.
Cause G/C er.gineering stated that this was an isolated design error.
Related G/C drawings, B-208-011-CC03 and B-208-001-CC04 (through Revision 5 dated July 23,1980), were checked by a drawing checker and two G/C engineers in accordance with approved G/C procedures.
The design error, i.e., omission of the "C" pump interlock by pass ("after-start") contacts in the "A" and "B" channels of the "C" pump start circuitry, was not detected through these issues of the drawings.
d.
Effect G/C engineering stated that should this design error have gone undetected, the loss of component cooling water that would have resulted, from the attempted use of "C" pump with either "A" or "B" pump lined up as backup to the "C" pump, would have a major impact on plant safety.
G/C evaluated this item as a "Possible Reportable Event" (number SN 009) under the provisions of their 10 CFR Part 21 implementing procedure and concluded that this consitutaa a reportable substantial safety hazard.
NRC Region I war notified verbally on December 10, 1980, and in writing on December 11, 1980.
e.
Generic Irnpact G/C engineering stated that there was no basis for assuming that the omissions of the interlock by pass contacts, which prevented the "C" CCW pump from running, was not limited to the CCW motors' starting circuitry.
Furthermore, they stated that no additional failures of a similar nature were reported to date as a result of the start up tests being conducted at the V. C. Summer Unit 1 site.
f.
Corrective Action G/C drawings B-208-011-CC033 and B-208-001-CC04 were revised (Revision 6 dated August 23, 1980) to include the necessary "C" pump interlock by pass ("after-start") contacts in the "A" and "B" channels of the "C" pump start circuitry.
Field Change Request number B99910E was issued on June 12, 1980, to effect the necessary changes in the installed CCW pump totors start circuitry at the V. C. Summer Unit 1 site.
9 g.
Preventive Measures Since G/C considers this to be an isolated design error, no changes in the existing design control procedures would be effected at this time.
Sea nonconformance identified at the end of this section.
3.
Service Water Pump Speed Switch Signal Misapplication a.
Background
South Carolina Electric & Gas Company (SCE&G) verbally notified NRC Region II on October 23, 1980, that as a result of a design deficiency by the architect engineer (G/C), the service water pump would not continue to run at high speed, as required when off-site power was not available.
SCE&G submitted a written final report on November 21, 1980, stating that the necessary control circuit has been revised, b.
Problem Startup Field Report 2642, issued June 11, 1980, identified that the motor control circuitry for the service water pump properly switched the speed of the pump from low speed to high speed when a loss-of-of fsite power signal was received, but improperly switched the speed of the pump back to low speed when the signal was no longer present.
Specifically, a latching or holding contact was not provided in either the "A", "B" or "C" pump high speed control circuitry to maintain the pump running at high speed when the high speed sequencing signal was terminated.
c.
Cause G/C engineering stated that this was an isolated design error.
Related G/C drawings (B-208-101-SW01, B-208-101-SWO2, B-208-101-SWO3 and B-208-101-SWO4) were checked by a drawing checker and two G/C engineers in accordance with approved G/C procedures.
The design error (omission of a latching or holding contact for the pump high speed control relay) was not detected on these drawings.
j
10 d.
Effect G/C engineering stated that should this design error have gone undetected, the diesel generators aay not have received sufficient cooling when providing emergency power and could have a major impact on plant safety.
G/C evaluated this item as a "Possible Reportable Event" (number SN010) under the provisions of their 10 CFR Part 21 implementing procedure, and concluded that this constituted a reportable substantial safety hazard.
NRC Region I was notified verbally on December 10, 1980, and in writing on December 11, 1981.
e.
Generic Impact G/C engineering stated that there was no basis for assuming that the onission of the latching or holding contact, which prevented the service water pumps from running continuously at high speed, was not limited to the service water pumps' motor control circuitry.
Furthermore, they stated that no additional failures of a similar nature were reported to date as a result of the start-up tests being conducted at the V. C. Summer Unit 1 site.
f.
Corrective Action The above referenced G/C drawings were revised on October 16, 1980, to include the necessary latching or holding contacts in the "A", "B" and "C" pumps' high speed control circuitry.
Field Change Request B9958E was issued on June 16, 1980, to effect the necessary changes in the installed service water pumps' motor speed control circuitry at the V. C. Summer Unit 1 site.
g.
Preventive Measures Since G/C considers this to be an isolated design errer, no changes in the existing design control procedures would be effected at this time.
See nonconformance identified at the end of this section.
4.
Misaoplication of Torque Switches on Limitorque Valve Actuators a.
Background
South Carolina Electric & Gas Company verbally notified NRC
11 Region II on October 23, 1980, that as a result of a design error by the architect enginese (G/C), torque switches used to limit valve positien were broken on three service water discharge isolation valves.
SCE&C submitted a written final report on November 21, 1980, stating that the controls are being ravised on the above three valves and feur other similar valves.
b.
Problem Startup Field Report 2423, issued April 16, 1980, identified that the torque operated position limit switches wcre broken on three service water discharge isolation " butterfly" valves during valve operational testing, and that the torque position switches used on other similar " butterfly" valves could also potentially fail.
Failure of the torque position limit switch could allow the motor operator to jam the valves in the closed position.
The prob 1cm appeared to oc associated with a specific type and size of " butterfly" valves.
c.
Cause The cause of the torque switch failure has not been uniquely determined to date.
One of the broken switches was returned to the manufacturer of the valve actuator (Limitorque Corp.) for examination of the failure and resolution of the problem.
The manufacturer reported that the switch failed because of partial shearing of the cam actuating lug.
No explanation can be given for this particular failure mode.
No previous torque switch testing has resulted in a cam actuating lug failure.
The manufacturer suggested that SCE&G check their maintenance records on this valve, since they suspect actuator abuse.
(Note:
G/C field engin2ering reported that the maintenance records were investigated and showed no evidence of actuator abuse).
d.
Effect SCE&G reported that the valves could jam in the closed position and cause a loss of component cooling water which in turn could cause a loss of diesel generator auxiliary power, both of which could have a major impact on plant safety.
G/C evaluated this item as a "Possible Reportab'o Event" (number SN 007) under the provisions of their 10 CFR Part 21 implementing procedure and concluded that this item was not a reportable substantial safety hazard for the following reasons:
(1) the failure did not result from a design error; (2) there was no safety concern since the valves operated properly; and (3) i I
l l
12 the failure was isolated to specific valves that had been installed at the V.C. Summer site and NRC Region II had been adequately informed of the failure by SCE&G.
e.
Generic Impact G/C engineering stated that there was no known technical reason for the torque position limit switches to fail in this type application.
Review of other plant systems indicated that torque switches were used on three similar
" butterfly" valves in the reactor building isolation system and three in the building service isolation system.
Although failures in these :ystems had not been reported, G/C engine-ering concluded that corrective action and preventive mea-sures should be implemented for all valves.
f.
Corrective Action Sheets SW20, SW21, SW22, SW25, SW26, SW37, and SW38 of G/C drawing B-208-101 were revised on July 30, 1980, to include a conventional position limit switch in series with the torque vperated position limit switch, such that either switch could stop the actuator from attempting to move the valve beyond the desired closed positive.
The basis for this decision was that verbal (but not documented) discussions with Limitorque personnel indicated that " butterfly" type valves may not provide sufficient seating torque to operate the torque position limit switch supplied by Limitorque in their valve actuators, thus permitting the actuator motor to overdrive the switch and shear off its cam actuating lug.
Maintenance Work Request 15098 was issued on June 18, 1980, to effect the necessary field changes.
g.
Preventive Measures G/C engineering stated that a review of other G/C projects indicated that conventional position limit switches were usually specified by G/C; however, since there have been no other reported failures of torque position limit switches in Limitorque actuators used in other " butterfly" valve applica-tions, no retrofit program was contemplated.
To provide additional assurance against valve jamming, Engineering Design Guide i
0421-1.2.2 (Elc.entary Diagrams) will be revis?d to indicate that conventional position limit switches are to be the pre-ferred method for controlling the limit of travel of " butterfly" type valves.
13 5.
Findings Although no specific nokadherences to procedural requirements were found in this area of the inspection, a nonconformarce was issued (See Notice of Nanconformance enclosure, item B) because the approved G/C design control program does not appear to have been effectively implemented in the areas of design interface control and design verification.
Specifically, three of the four reported deficiencies evaluated above resulted from a G/C design error that was not detected by the implemented design control or QA program.
No unresolved or follow up items were identified in this area of the inspection.
D.
Technical Personnel Background Verification 1.
Objectives To verify that measures have been established and are being effectively implemented that assure:
a.
The education and work experience information contained in employees' job applications are being verified by the employing organization.
b.
There is objective, documented evidence or records that attest to new employee alleged education and experience.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Gilbert / Commonwealth corporate procedure V-01, Recruitment and Employment, to determine the corporate policy with respect to verification of new employee alleged education and experience.
b.
Memorandum, issued by the Manager of Employment on June 30, 1980, to determine the specific requirements and forms currently used to verify new employee alleged education and experience.
c.
Eignteen randomly selected personnel records of the approximately 200 employees hired since July 8, 1980.
3.
Findings a.
Nonconformances or Unresolved Items None were identified in this area of the inspection.
Except for a few of the employees hired in the last two months, documented evidence (i.e., attestations of education and experience, signed by the appropriate official of the educational
14 i
institution or former employer) was contained in the personnel files of the employees examined by the inspector.
b.
Follow up Item G/C management stated that a formal corporate policy with respect to verification of alleged education and experience of all new employees would be developed and issued by June 1, 1981.
The new policy will define and regulate these activities, provide guidance when a discrepancy is uncovered, retrofit back through January 1, 197.5, for those employees doing safety related work, and provide for maintenance of the requisite quality assurance records.
The retrofit activity and establishment of the appropri-ate records is scheduled for completion by July 1, 1981.
This item will be followed during a future inspection.
E.
Design Document Control 1.
Objectives To determine that approved procedures have been established and are being implemented for the control and distribution of design documents that provide for:
Identification of personnel, positions, or organizations respons-d.
ible for preparing, reviewing, approving, and issuing design documents.
b.
Ascertaining that the proper documents, and revisions thereto, to be used in performing the design are identified, accessible and being used.
c.
Coordination and control of design interface documents.
d.
Establishing distribution lists which are updated and maintained current.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine if procedures have been prepared, approved, and issued to prescribe a system for the control of design documents that is consistent with commitments to NRC and objectives a. through d. above.
l 15 1
(1) Sections 17.3, 17.5, and 17.6 of the GAI (Gilbert Associates Incorporated) Topical Report GAI-TR-106 (Gilbert / Commonwealth Quality Assurance Program for Nuclear Power Plants), Revision 2A, dated February 1980, to determine the corporate QA pro-grammatic commitments relative to control of design documents.
(2) Sections 3.0, 5.0, and 6.0 of the G/C NQAM (Nuclear Quality Assurance Manual), to determine that the corporate commitments were correctly translated into an approved quality assur-ance program.
(3) Applicable sections of the V. C. Summer and the TMI-1 continuing services (Restart) Project Management Manuals and Quality Assurance Plans, to determine that the corporate commitments were accurately reflected in the approved in place Quality Assurance Programs consistent with the G/C scope of supply.
(4) Sections 1.10, 1.15, 1.25, 1.30, 1.35, 1.50, 2.05, 2.10 and 2.20 of the GAI Design Control Procedures Manual and CAP 1.00 of the Computer Control Manual, to determine that the quality assurance program commitments were correctly translated into effective design control procedures.
b.
Review of the following documents to determine if the in place procedures being effectively implemented consistent with corporate and project commitments in those design activities affecting quality (consistent with the G/C scope of supply for the project).
Analysis / Calculation (1);
Change Notice (1);
Computer Program Certification (1);
Detailed Operating Procedures (1);
Orawings (27);
Engineering Change Notices (4);
Field Change Requests (4);
Letters (10);
QA Audits (5);
Safety Concerns (10);
Specifications (4);
Startup Field Requests (4); and System Design Descriptions (4).
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3.
Findings a.
Nonconformances, and Unresolved Items
- None, b.
Followup Item The verification and control of computer programs that are periodically used to perform safety related calculations is governed by DCP 1.50 (Computer Program Use Control) and CAP 1.00 (Certification and Documentation of Production Computer Programs).
The inspector did not verify compliance with these procedures during this inspection.
However, the inspector noted that single-use programs, whether run on a programmable calculator, or a step by step calculator, were excluded from the certification and documentation requirements.
Furthermore, the existing procedures neither include, nar do they exclude, the requirements for verification and cont.'ol of " mini-computers" and programmable calculator programs.
G/C management stated that calculations executed by single use programs were excluded from the requirements for ver f4ca-tion and control on the basis that such calculations ar-independently verified on a case by case basis in accordance with other procedural requirements and that to impose additional requirements on such calculations would be prohibititely burdensome to administrate.
G/C stated that, to the best of their knowledge there are no
" mini-computers," and only one programmable " hand" calculator, being used to perform safety related calculations at the Reading Office.
The only program reportedly being run on a programmable hand calculator is E10ZTENS, which is used to calculate the tension of cables pulled through concrete.
Documentation for this program indicated that it was fully certified and documented in accordance with DCP 1.50 and CAP 1.00 on December 1, 1980.
No detailed information was available in the Reading Office as to the number and certification status of " mini-computers" a.94 programmable hand calculators in use at the Jackson Office.
G/C management stated that a corporate manual is being developed to define the requirements for the control and utilization of all computers and calculators, ano associated programs, that are used to perform safety related calculations and data reduction /
analyses.
The manual is scheduled for issue by July 1, 1981.
The manual will define the generic types of calculators and computers covered by it, will contain realistic provisions for the initial verification and the periodic recertification l
17 of both the calculating equioment and the safety related programs used.
Further, the manual will require the maintenance of appropriate " problem run" logs.
This item will be followed during a future inspection.
G.
Exit Meeting An exit meeting was conducted with Gilbert / Commonwealth personnel at the conclusion of the inspection on April 2, 1981.
In addition tc those individuals indicated by an asterisk in paragraph A. above, the meeting was attended by:
J. C. Daly, Senior QA Program Manager G. J. Gibson, Project Quality Coordinator P. B. Guidikurst, Manager, Perry Project B. Nemroff, Manager, Electrical Engineering R. E. Pages, Assistant Manager, Structural Engineering E. B. Toll, Manager, Specialty Engineering P. H. Wentrel, Manager, Engineering Support D. P. White, Manager, Nuclear Engineering H. E. Yocom, Manager V. C. Summer Project The inspector discussed the scope of the inspection and the details of the findings that were identified during the insp9ction.
Management comments were generally for clarification only, or acknowledg-ment of statements by the inspector.
In addition to the nonconformancas identified in the enclosed Notice of Nonconformance, the inspector discussed the generic evaluation of safety concerns, quality assurance requirements for spare and replacement parts, and independent design verification. The inspector identified the Gilbert / Commonwealth commitments made curing the inspection with respect to the control of computers and associated computer programs and the verification of employee education and experience.