ML20058F013
| ML20058F013 | |
| Person / Time | |
|---|---|
| Issue date: | 11/02/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058F011 | List: |
| References | |
| REF-QA-99900519 IEB-79-14, NUDOCS 9011080056 | |
| Download: ML20058F013 (6) | |
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APPEND 1X A NOTICE OF NONCONFORMANCE Bechtel Corporation Docket No.: 99900519 Gaithersburg, Maryland i
During an NRC inspection conducted on April 23-27, 1990, it was determined that certain of your activities were not conducted in accordance with NRC
'i requirements which were contractually imposed on Bechtel Corporation (Bechtel) by purchase orders with NRC licensees.
These items are set forth below and have been classified as nonconformances to the requirements of 10 CFR Part 50, Appendix B.
1.
Criterion 111, ' Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR Part 50.2 and as specified in the license application, for the applicable structures, systems, and components be correctly translateo into specifications, drawings, procedures, and instructions.
These meoures will include provisions to assure that quality standards are specifitd and included in design documents and that deviations from such standards are controlled.
The design control measures will provide for verifying or checking the adequacy of design, such. as by the performance of design reviews or-simplified calculational methods. Design control measures will be anlied to items such as stress and accident analyses.
Design changes w' l1 be subject to design control measures cossensurate with those applied to the original design and be approved by the organization that performed the i
original design.
Section 3 (17.1.3), ' Design Control," of "Bechtel Quality Assurance Program for Nuclear Power Plants," Topical Report BQ-TOP-1, Revision 4A, dated February 1988, states, in part, that ' Engineering department policies, standards, design guides, procedures, and instructions are employed for control of engineering design work to meet technical and regulatory requirements.
These controls... provide procedures to assure that the design requirements are correctly translated into the final design.
The controls also provide for preparation of appropriate
. documentation to permit review of the process used and of the results obtained.... Essentially all engineering docusents are prepared by project personnel and include drawings, specifications, design analyses....They are verified in accordance with Engir.eering Departrint Procedures....
Procedures and instructions for verification of drawugs, calculations, and specifications are included in' the procedures....These procedures...
require that design errors be identified and followed up through correc-tion....The design verification process includes checking and independent reviews, as required... Calculations and design output documents receive an independent check by an individual...who is familiar with the design requirements and intent and who has adequate qualifications.... Checking of a calculation ~ includes.a review of input information, assumptions, methodology and either a detailed check of the calculation or confirmation of the results by an alternate calculation."
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' NOTICE OF NONCONFORMANCE Contrary to the above requirements, the inspection identified that:
a.
Bechtel failed to effectively control its design calculation verifi-cation process for certain of its piping and
>ipe support stress calculations regarding NRC Bulletin 79-14 wort activities.
The following calculations were found during this inspection to contain errors or discrepancies that were neither identified nor reconciled tothelicensee'scurrentdesignbasis(90-01-01):
(1) Hatch Calculation P41-SWH-125. December 7,1982, " Pipe Support,"
contained multiple incorrect support restraint directions, incorrect local stress evaluation for the integral welded attachment (IWA), did not reflect the correct Bechtel design criteria, and the acceptable weld sites were not stated.
(2) Hatch Calculation P41-LWH-127 February 24,
- 1983,
" Pipe Sup ort
- included incorrectly calculated local stress eva untIons for one IWA, one IWA was not reconciled using the correct Bechtel design criteria, and the su) port calculation did not address the support baseplate size wuth its clip angles.
(3) Davis-Besse Calculation 180, Revision 4. October 5,1986, " Low Pressure Injection Piping,' iiicluded certain ctress identifica-tion factors (SIFs) that were undercalculated by a factor of 2.68.
(4) Davis-Besse Ct.lculation 18D, Revision 6. December 15, 1988,
" Low Pressure Injection Piping,' showed seismic support CCB-6-H1 that was misoriented by 57 degrees, and an incorrect model angle for valve HV-DHIA was used.
(5) Davis-Besse-Calculation 33B-CCB-7-H12, Revision 0, April 13, 1988, ' Pipe Support," included incorrect design program method-ology.
The Bechtel BOLTS design program for symmetric attach-ments was inappropriately used for this cantilever support that was off center and therefore caused an eccentric effect.
(6) Calvert Cliffs Calculation 217 Revision 6, February 4,1981,
' Safety injection Piping," included - several modeling discre-pancies such as for support 2-8111 (R-4) at node 45, where the isometric drawing showed a lateral restraint; however, the model used a 15-degree skewed support.
(7) Calvert Cliffs Calculation 2-57 Revision 3. December 2, 1981,
" Component Cooling Letdown Heat Exchanger," failed to recon-cile a two-inch pipe diameter increase between two revisions of ~
this calculation.
(8) Farley Calculation G-65060, Issue 4, date unknown, includes an incorrect valve center of gravity (CG) that was used in the calculation for valves V001H and V001G.
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' NOTICE OF NONCONFORMANCE b.
Bechtel failed to effectively control its design control measures to assure that certain of its pipe support stress calculational and isometric packages regarding NRC Bulletin 79-14 activities correctly translated as-built configuration and design parameters, specifically l
(90-01-02):
(1) Farley Calculation G-65060, Problem 238, Issue 4, date unknown, includes an isometric drawing that does not document that a pipe support is located at node 308, and actual valve CG for valves V001H and V001G are shown incorrectly on the isometric drawing at the piping centerline.
(2) Farley Calculation G-70680, Problem 2, Issue 2 FeHey Unit 1,
" Spent Fuel Pool Piping,' includes a weight discrepancy between the computer program input valve weight (620 9ounds and the
. stress analysis isometric drawing weight (340 rounds))for valve V002B.
(3) Bechtel Standardized Nuclear Unit Power Plant System (SNUPPS) for Callaway-Wolf Creek stress Isometric Drawing M-04ALO3(Q),
and associated Attachment D, Sheet 2 of 9. Revision 6, October 17, 1983, " Auxiliary Feedwater Piping,' includes a deviation where the isometric drawing expresses the valve weight of HV5 as 571 pounds; however, the computer input data states that HYS is 623 pounds.
(4) SNUPPS Stress Isometric ~ Drawing M-04AE04(Q), and associated Attachment E,- Sheet 1-of 5, Revision 6, November 4,
- 1983,
" Auxiliary Feedwater-Discharge Piping," includes a deviation where the isometric valve weight for V057 is expressed as 275 pounds; however, the valve weight for V057 in the computer input data is 134 pounds.
Also, the weight of valve FV39 is expressed as 6200 pounds on the isometric drawing; however, the computer input data for valve FV39 is 6355 pounds.
(5) $NUPPS Isometric Drawing ALO3-C003/135(Q), dated March 20, 1985, Data Point 435, shows a 16 percent weight increase but the increase was not reconciled with the original support design.
(6) $NUPPS isometric Drawing ALO3-C005/135(Q), dated Februau 23, l
1984, Data Point 280, shows a 6 percent weight increase, bt.t the increase was not reconciled with the original support design.
(7) SNUPPS Isometric Drawing ALO3-0010/135(Q), dated February' 23, l
1984, Datapoint 455, shows a 12 )ercent weight increase but the increase was not reconciled wit) the original support design, i
NOTICE OF NONCONFORMANCE 2.
Criterion V, " Instructions, Procedures and Drawings," of Appendix B to 10 CFR Part 50, requires, in part, that activities affecting quality will be prescribed by documented instructions, procedures, or drawings, appro-priate to the circumstances, and will be accomplished in accordance with these documents.
The documents will incluor appropriate quantitative or qualitative acceptance criteria for determini,ig that important activities have been satisfactorily accomplished.
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Bechtel Engineering Department Procedure (EDP) 4.38, " Computer Program Error Repor.ing and Corrective Action,' Revision 4, states, in part, that "The purpose of this procedure is to define the actions to be taken when errors are discovered in computer programs used for engineering design and I
analysis....The requirements of this procedure shall also be invoked by l
engineering upon notificatior. af a system error which could cause the computer programs to produce a CLASS THREE program error.... Class three...
[ errors are) program errors which produce wrong results, but which could be interpreted as valid results.... User's manual holders are responsible for:...c.
Inserting Computer Program Error Notifications in assigned User's Manuals....'
Contrary to the above requirements, one out of three CE-901 (ICES-STRUDL) computer program uter's manuals that were reviewed did not contain both of the. Class 3 computer program error notifications (Error Notices 85-01 and 88-01).
The CE-901 computer program is used in safety-related analyses (90-01-03).
3.
Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50 i.
l requires, in part, that measures will be established to assure that L
conditions adverse to quality, such as failures, malfunctions, deficienc-l
- 1es, deviations, and nonconformances are promptly identified and L
corrected.
In the case of significant conditions adverse to quality, the l
measures will assure that the cause of the condition is determined and L
corrective action taken to preclude repetition. The identification of the significant condition adverse-to quality, the cause of the condition, and the corrective action taken will be documented and reported to appropriate levels of management.
1 Section 3 (17.1.3). " Design Control,' of "Bechtel Quality Assurance Program for Nuclear Power Plants," Topical Report BQ-TOP-1, Revision 4A, dated February 1988, states, in. part, that " Procedures and instructions for verification of drawings, calculations, and specifications are included in the procedures governing the preparation of these documer,ts or in separate procedures or instructions.
These procedures identify the positions responsible for verification and require that design errors be identified and followed up through correction.
Cognizant engineering personnel on the project are required to verify the incorporation of required corrections...."
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- NOTICE OF NONCONFORMANCE Section 16 (17.1.16), ' Corrective Action," of "Bechtel Quality Assurance Program for Nuclear Power Plants," Topical Report BQ TOP-1, Revision 4A, dated February 1988, states, in part, that "The corrective action program provides procedures for prompt identification and correction of conditions adverse to quality which may require corrective action.... Errors detected af ter the design document is issued for use are reviewed for significance and reportability and are documented.
Corrective action for such errors is processed in accordance with the corrective action program.
Significant problems are also reviewed for programmatic corrective action by Quality Assurance."
Section 17 (17.1.17), " Quality Assurance Records,' of Bechtel Quality Assurance Program for Nuclear Power Plants," Topical Report BQ TOP-1, Revision 4A, dated February 1988, states, in part, that " Documentation of the design review process is prepared and maintained in accordance with Section 3 of this report...Bechtel Engineering retains control of design calculations and analyses.
These are available for review by client and appropriate regulatory bodies...."
Section 4.6, of Policy Q-3.5, ' Computer Programs," Revision 0, dated August 1989, states that " Errors fount in sof tware or hardware, by Bechtel personnel or error notifications received from external organizations, shall be evaluated, controlled, and disseminated to the current users.
Effect of errors on work done previously and implications for possible reporting to the NRC shall be evaluated."
Contrary to these requirements, the NRC inspection identified that:
a.
Bechtel failed to perform the required evaluations of the signifi-cance and reportability of computer program errors in the following fourBechtelprobleminvestigationreports(PIRs)(90-01-04).
1 PIR No.
SUPJECT LICENSEE APPLICABILITY l
PIR-G87-12-CQ CE-798 Class 11 error (ANSYS)
Grand Gulf l
PIR-G87-11-CQ CE-998 Class 11 error (FLUSH)
Grand Gulf PIR-G86-35-CQ CE-798 Class 111 error (ANSYS)
Grand Gulf l
PIR-G88-28-CQ CE-901 Class III error (STRUDL)
Duane Arnold b.
Bechtel f ailed to establish and execute adequate measures to ensure that appropriate evaluations are performed and documented for errors and discrepancies-found on calculations that have been previously performed and issued for use by licensees.
Specifically, Bechtel W,
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. NOTICE OF NONCONFORMANCE could not provide documentation to demonstrate that it had promptly identified and documented the cause and corrective action to preclude recurrence for piping and pipe support stress calculational errors that have been found by Bechtel on the following Bechtel projects (90-01-05):
(1) Duane Arnold Project - A complete reverification of Bechtel's initial IEB 79-14 stress calculation by Bechtel's and the licensee's staff. packages was performed The review identified approximately 60 supports that had to be modified due to errors or discrepancies in the calculations found between 1983 and 1985. These supports exceeded the FSAR design limits.
(2) Davis-Besse Project - A complete review of Bechtel's initial 1
IE6 79-14 stress calculation packages was performed by Bechtel's and the licensee's staff.
The review identified numerous supports that had to be modified because of errors or discrepancies in the calculations.
These supports exceeded the FSAR design limits as a result of the errors in the Bechtel's IEB 79-14 work activities.
(3) Point Beach Project As a
result of the licensee's reverification of a sample of Bechtel's IEB 79-14 work activi-ties the utility. discovered approximately 44 out of 200 RHR piping system supports that exceeded the FSAR design limits.
Each of the RHR supports require modification. The licensee committed to the NRC staff to perform a 100 percent reveri-fication of Bechtel's IEB 79-14 related calculation packages.
(4) Palisades Project - Bechtel's and: the ' licensee's staff found errors and discrepancies with Bechtel's initial stress calcu-lation packages performed for Bulletin 79-14.
The licensee is still performing reviews and has currently identified several supports that were found to exceed FSAR criteria limits.
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I Dated at Rockville, Maryland This 2nd day of November,1990
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