ML20058F022
| ML20058F022 | |
| Person / Time | |
|---|---|
| Issue date: | 10/26/1990 |
| From: | Petrosino J, Vandenburgh C Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058F011 | List: |
| References | |
| REF-QA-99900519 IEB-79-14, NUDOCS 9011080062 | |
| Download: ML20058F022 (29) | |
Text
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ORGANIZATION: GECHTEL CORPORATION GAITHER$ BURG, MARYLAND g
ntruru IN5PECTION INSPECTION NO.: 99900519/90-01 DATE: April 23-27, 16 0 ON SITE HOURS: 264 CORRESPONDENCE ADDRESS: Bechtel Corporatier.
Gaithersburg Regional Office 9801 Washingtonian Boulevard Gaithersburg, Maryland 20878-5356 ORGANIZATIONAL CONTACT: Dinesh C. Kansal, Quality Assurance Manager TELEPHONE NUMBER:
(301)417-3777 l
NUCLEAR INDUSTRY ACTIVITY: BechtelCorporation(Bechtel)providesengineering, design, and consulting services associated with basic components to various nuclear power utilities, j
ASSIGNED INSPECTOR: A
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p.TR15-1), Vendor _ Inspection Branch (VIB)
E.pettosino,' Reactive Inspection Section No.
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l OTHERINSPECTOR(S):
H. L. Wescott, NRC:VIB l
J. A. Gavula, NRC: Region !!! Office W. C. Liu, NRC: Region 111 Office A. J. Lee, NRC:NRR W. G. Shier, Brookhaven National Laboratory i
l T. L. Tinkel, on ysts, Inc rporated APPROVED BY:
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l C. A. VanDenburgWection wief gl5-2:VIB Date 1
lh>PECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and Appendix B to 10 CFR Part 50 l
l B.
SCOPE:
This inspection was conducted to follow up on an NRC concern i
regarding errors and deficiencies found in piping and piping support L
stress calculations performed by Bechtel and in associa'ted isometric drawings prepared by Bechtel related to NRC Bulletin 79-14. Also addressed during this inspection was Unresolved Item 89-01-01 from NRC Inspection Report 99900519/89-01.
l PLANT SITE APPLICABILITY:
All Sites.
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78A2 8W eM7h 99900519 PDL
ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 2 of 29 A.
VIOLATIONS:
None.
B.
HONCONFORMAND 1.
Contrary to Criterion 111,(' Design Control " of Appendix B to 10 CFR Part 50 and Section 3 17.1.3), " Design Control," of Bechtel Quality Assurance (QA) Program for Nuclear Power Plants, Topical Report BQ-TOP-1, Revision 4A, dated Febrrary 1988 Bechtel failed to effectively control its design calculation verification process for certain of its piping and pipe support stress calculation pack-ages related to NRC Office of Inspection and Enforcement Bulletin (IEB)7914engineeringserviceswork.
Specifically, Bechtel cal-culation packages that had already been turned over to its custo-mers, were found to contain deficiencies that were either not iden-tified or not reconciled with the design bases.
(90-01-01).
2.
Centrary to Criterion 111
" Design Control " of Appendix B to 10 CFR Part 50 and Bechtel's QA program Topical Report, Bechtel failed to effectively control its design cienge control measures to ensure that calculation packages regarding IEB 79-14 design activities were correctly translated and documented on the design records (90-01-02).
3.
Contrary to Criterion Y, " Instructions, Procedures, and Drawings,"
of Appendix B to 10 CFR Part 50, and Bechtel Engineering Department Procedure (EDP) 4.38, " Computer Program Error Reporting and Correc-tive Action," Revision 4 one of the three CE-901 (ICES STRUDL) com) uter arogram user's manuals that were reviewed did not contain p
i boti of tie Class 3 computer program error notices (Error Notices 85-01 and 88-01). The ICES STRUDL computer program is used in safety-related analyses (90-01-03).
4.
Contrary to Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50 and to Section 3 (17.1.3), " Design Control "
Section 16 (17.1.16), " Corrective Action," and Section 17 (17.1.17), " Quality Assurance Records," of Bechtel Topical Report BQ-TOP-1, "Bechtel QA Program for Nuclear Power Plants," Revision 4A, dated February 1988, and Section 4.6 of Bechtel Policy Procedure Q-3.5 " Computer Programs," Revision 0:
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 3 of 29 a.
Bechtel failed to ensure that the following four significant i
computer program errors were corrected and the cause of the condition and corrective action to preclude recurrence was documented. Additionally, Bechtel failed to implement its l
Section 16 requirements regarding correction of conditions adverse to quality, and to review errors detected after the design document was issued for significance and reportability.
Instead of performing the required evaluations, Bechtel informed the applicable customer of the computer program problems. This problem was found in the following 4 out of I
the35Bechtelprobleminvestigationreports(PIRs)that werereviewed(90-01-04):
PIR No.
Computer Program-Error Level Licensee G-87-12-CQ CE-798 ANSYS -Class 11 error Grand Gulf G-87-11-CQ CE-998 FLUSH -Class 11 error Grand Gulf G-86-35-CQ CE-798 ANSYS -Class 111 error Grand Gulf G-B6-28-CQ CE-901 STRUDL)-Class 111 error Duane Arnold b.
Bechtel failed to establish and implement adequate measures to ensure that errors and discrepancies that are found on calculation packages that were previously performed and released to licensees were appropriately evaluated. Specifically, Bechtel did not provide records as required by Topical Report BQ-TOP-1, Revision 4A, to show that it had identified the causes and corrective action to preclude repetition of multiple deficiencies that have been found in Bechtel piping and pipe support stress calculations related to IEB 79-14 forthefollowingBechtelFrojects(90-01-05):
Duane Arnold Project - During Bechtel's 1983-1985 review of its IEB 79-14 related calculation packages that had been provided as DAEC design bases, numerous L
support deficiencies were identified by Bechtel and the licensee that exceeded FSAR requirements.
Davis-Besse Project - During 1985-1987 Bechtel and the licensee conducted a complete reverification program of previously performed stress calculation packages. The review identified numerous as-built supports that were installed and exceeded FSAR criteria.
Point Beach Project - Because of errors and inaccuracies discovered by NRC staff in 1988, the NRC inspectors reviewed previously performed IED 79-14 related
ORGAN!ZAT10E-BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 4 of 29 calculation packages and identified numerous errors and inaccuracies in the Bechtel calculation packages. The licensee subse removal (RHR) quently identified 44 residual heat service water system supports that required modifications because they exceeded the FSAR design code allowable.
Palisades Project - The NRC inspectors also found errors and inaccuracies in the calculation packages prepared by Bechtel in response to IEB 79-14.
C.
UNRESOLVED AND OpEN ITEMS:
1.
Computer Program Error Control The inspectors reviewed EDP 4.38, " Computer Program Error Reporting and Corrective Action," Revision 4, to identify the controlling actions that would be required when a program error was identified. EDP4.38assignstheprogramsponsor(PS)the responsibility of initiating tirely changes to correct Class 2 and Class 3 errors in computer programs controlled by Bechtel.
The PS is also required to remove a program from service when a Class 3 error is not readily avoidable. A Class 3 error is the highest severity level and may produce incorrect results that can be interpreted as correct. On the basis of discussions with Bechtel personnel in conjunction with the review of EDP 4.38, the inspectors could not determine whether EDP 4.38 adequately controls computer programs with known errors. This area requires additional review before any conclusion can be reached. This area needs to be reviewed further during a future inspection; therefore, this issue is identified as Open item 90-01-06.
2.
Code Verification and Validation Control The inspectors reviewed Bechtel's methods of ensuring that its safety-related computer program code verification and validation control is maintained. ComputerProgramCE998(ANSYS)wasone program that was reviewed in detall; however, the ins)ectors identified some concerns regarding the method in whics ANSYS is controlled. This area is discussed in detail in Section E.9 of this report. This issue needs to be reviewed further during a future inspection; therefore this issue is identified as Open item 90-01-07.
3.
Computer Code Error Logging System As discussed in Section E.11 of this report, Bechtel's system of using several computer code error logging systems needs to
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i ORGANIZATION: BECHTEL CORPORATION GAITHER$ BURG, MARYLAND 4
REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 5 of 29 be reviewed during a future inspection to verify compliance with Appendix B to 10 CFR Part 50. The inspection team's limited review raised a concern that a certain degree of traceability may be lost for significant errors. Therefore, this issue is identified as Open Item 90-01-08.
4.
Indeterminate Status of Bechtel Performed IEB 79-14 Related Services The NRC staff nas identified potential generic implications regarding the adequacy and accuracy of Bechtel contractually-performed siping and pipe support stress calculations that were performed >y Bechtel at approximately 20 facilities under contract to NRC licensees in response to IEB 79-14. This issue is discussed in more detail in Section E of this report. Based on NRC review of Bechtel engineering calculations performed at Duane Arnold, Point Beach, and Palisades, it appears that the Bechtel performed stress calculations and evaluations of identified errors may not ine been adequately performed to assure that the applicable pipeg and/or pipe support system is within the licensee's design basif. The NRC is continuing to review the circumstances surrounding 4
this issue and to determine if those design errors should have been considered and addressed for generic implications. Therefore.
this issue is identified as Unresolved item 90-01-09.
5.
Valve and Valve Operator Locations and Weights i
During this inspection, the NRC inspectors identified an IEB 79-14 issue regarding valve and valve operator location and weight (eccentricity) that may not have been ap(SFO).
propriately i
addressed by the Bechtel San Francisco office This issue is also discussed in Section E.1 of this resort. Mng this inspection, the NRC inspectors identified t1at in M /9, Bechtel SFO personnel and NRC staff discussed how Bechtel Would address the IEB 79-14 issue regarding eccentricity. The circumstances of the NRC-Bechtel discussions were documented in a Bechtel SFO internal memorandum. However, the NRC inspectors review of the Bechtel memorandum indicates that the Bechtel SFO staff did not in some situations consider eccentricity in its IEB 79-14 related work that was performed by Bechtel for several NRC licensees.
This matter requires further review to determine whether or not Bechtel addressed or was required by licensee contracts to address the valve and valve operator weight and locations as specified in IEB 79-14. This issue is identified as Unresolved item 90-01-10.
1
4 ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND l
REPORT INSPECTION l
NO.: 99900519/90-01 RESULTS:
PAGE 6 of 29 D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
l l
1.
Open - Nonconformance 88-01-01:
During this inspection, Nonconformance 88-01-01 from NRC l
Inspection Report No. 99900519/88-01 was not reviewed.
l
.2.
Closed - Unresolved Item 89-01-01:
During this inspection, Unresolved Item 89-01-01 from NRC Inspection Report 99900519/89-01 was reviewed. As discussed in Section E.4 of this inspection report, Nonconformance 90-01-05 was identified in this program area. The.efore, a new item Nonconformance 90-01-05 will follow this previous issue to closure.
I E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
EXECUTIVE
SUMMARY
ThisNRCVendorInspectionBranch(VIB)inspectionwasconductedon April 23-27, 1990 by an 8-member NRC inspection team consisting of staff members from the NRC Office of Nuclear Reactor Regul6 tion, Region !!! and NRC consultants. The inspection tene: independ-ently assessed whether Bechtel effectively implemented its quality assurance program and its 10 CFR Part 21 deviation evaluation and notification program for its IFB 79-14 activities at NRC licensed facilities. The team evaluated a sample of IEB 79-14 related piping and pipe support stress calculation packages to assess t1eir validity and accuracy. The inspection team evaluated previously identified errors and deficiencies that were identified by Bechtel and/or NRC licensees. The inspection team found that Bechtel had not effectively implemented its QA program as discussed below.
The most significant concern involved Bechtel's failure to effec-tively implement its design control and design verification proDram as evidenced by the deficiencies that were identified in IEB 79-14 engineering services Bechtel performed for numerous licensees.
Bechtel became aware of multiple deficiencies around 1983, when the Duane Arnold Energy Center (DAEC) asked Bechtel to reve.'ify all its IEB.79-14 calculation packages. Similar problems were subsequently identified in calculation packages Bechtel had prepared for Davis-Besse Point Beach, Palisades and Arkansas Nuclear One (ANO) between 1985 and 1989.
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ORGANIZATION: BEch.R CORPORATION i
GAITHERSBURG, MARYLAND i
REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
Pact 7 of 2c The inspectors reviewed calculation package deficiencies from DAEC and identified the following relationships: 8 pipe supports used for the RHR service water (SW) return piping were installed such that each support restrained lateral pipe movement and caused thermal stresses that exceeded the design code allowed stresses; i
14 sipe supports were identified where the calculated loads on eac1 individual pipe support for the as-built piping configuration resulted in deflec. ion of the support that exceeded the allowable deflection design code (11 of these 14 supports were used for the l
l SW piping system); the calculated loads on 9 pipe supports for I
the as built piping configuration resulted in either support member stresses, or welded connection stresses which exceeded the design code allowed stresses (4 of these 9 supports were used for the well water retur:. piping supports located inside the drywell).
The inspection revealed that sin.ilar deficiencies were identified at Palisades Davis-Besse, Point Beat.h. and ANO facilities. For example, six Palisades supports were identified because the calculated loads on the pipe supports for the as-built piping configuration resulted in support member stresses which exceeded the design code allowed stresses.
In four of the six Palisades supports, the calculated support member stress exceeded the yield strength of the support i
material by a factor of 1.25 times. These four supports were-used on the main steam piping system and were identified as supports EB1-52 S3, 55, and $6. At the Point Beach facility, the licensee found that 44 of its 200 RHR piping system supports required modification because of inaccuracies that were recently identified which caused the supports to exceed what the FSAR design allowed.
Additionally, one potentially generic failure to comply with IEB 79-14 requirements was identified. The. inspectors' review of NRC Inspection Report 050-313/89-200 for the ANO facility, found l-that a Bechtel letter (MCO-00850) stated that Bechtel did not consider valve eccentricity for ANO. The inspector's review of this letter and its attachments reycaled that personnel in Bechtel's San Francisco office may not have appropriately addressed eccentricity as part of its IEB 79-14 work for at least the ANO and Trojan projects. Furthermore, some Bechtel staff notes that were attached to Bechtel letter MCO-00850, indicate that Bechtel verbally informed the NRC staff that if Bechtel had some situations where eccentric modeling was not considered and Bechtel selected to reanalyze with eccentricity, that Bechtel would do so outside of IEB 79-14. During this inspection, the inspectors l
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 8 of 29 identified that Bechtel San Francisco office staff performed IEB 79-14 related work for several facilities, including: ANO, Hope Creek, Limerick, Point Beach, Susquehanna, and Trojan.
However, it is not known which of these fi 111 ties had eccentricity addressed by Bechtel in support of licen w s IEB 79-14 activities.
Page two of IEB 79-14, dated July 18, 1979, clearly specifies that valve and valve operator locations and weights (eccentricity) were to be included. The Bechtel handling of the eccentricity issue is identified as Unresolved item 90-01-10.
2.
Background for Seismic Analyses issue The NRC Office of Inspection and Enforcement Bulletin (IEB) 79-14
" Seismic Analysis for As Built Safety-Related Piping Systems,"
was issued on July 2,1979, to ensure conformance and consistency between the as-built configuration of safety-related piping and pipe support systems and the associated seismic analyses that substantiate and document the licensee design basis. A revision to IEB 79-14 was issued on July 18, 1979, and two supplements were subsequently issued to provide new information, staff positions, and clarifications. Supplement I was issued on August 15, 1979, and Supplement 2 was issued on September 6 1979.Bulletin 79-14 addressed two issues that could cause seismic analyses of piping i
systems to yield nonconservative results. One issue involved algebraic sunnation of loads in seismic analyses (which is not discussed in this report) and the other issue involved the accuracy of the information provided for seismic analyses. As a result of licensee and staff reviews of the as-built configuration of several piping systems during 1978-1979, a number of nonconformances to design documents were identified that could potentially affect the validity of seismic analyses. Therefore, IEB 79-14 required licensees to take the following actions for certain safety-related piping systems for plants under Regulatory Guide 1.29 and also for 26-inch piping systems that were used for safety-related applica-tions in older plants. These requirements included:
Identify inspection attributes to be used in verifying that the seismic analysis input conforms to the as-built configuration.
Verify by physical inspection at least a part of the accessible piping system to ensure that the inspection elements meet the acceptance criteria.
Inspect the remaining piping systems as soon as practical.
I ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 9 of 29 Evaluate all identified nonconformances for significance to determine whether or not operability might be jeopardized.
Submit nonconformance evaluations to the NRC where the seismic analyses may not be conservative.
Improve the quality assurance program if nonconformances are identified to assure that future modifications are handled efficientl analyses, y.
Revise the design documents and seismic l
As a result of NRC inspection findings in the 1980s at various facilities, it appeared that the initial actions required by lEB 79-14 may not have been adequately implemented or completed i
by all licensees. The recent NRC and licensee inspection find-ings have identified discrepancies between the as-built documents and the analyses, such as:
incorrect input for spring hanger i
i trave), dimensionally inaccurate isometric drawings; inaccurate pipe fitting identification in the isometric drawings; incorrect pipe schedule on isometric drawings; incorrect valve weight and center of gravity (CG); incorrect seismic response spectra value valve modeling inae:uracies; stress intensification factor (SIF);
inaccuracies; incorrect restraint direction and orientation, and incorrect support locations analyzed. Some of the facilities i
at which these prablems have been identified included: ANO, Davis-Besse, Dresden. Duane Arnold, Palisades, Point Beach, and Quad Cities. Consequently, the NRC decided to review implementation l
l of IEB 79-14 at several licensee facilities and to review some of the IEB 79-14 related stress calculation packages at architect-engineers (AE) who were directly involved in the initial activities i
regarding IEB 79-14 seismic analyses. The first staff inspection that was specifically scoped to review licensee implementation of IEB 79-14 took place at ANO in 1989.
i The NRC report of the ANO facility, NRC Inspection Report 50-313/89-200, indicated that the existing analyses were inconsistent with the as-built configuration design bases. The NRC inspectors at ANO also identified numerous discrepancies in L
the IEB 79-14 related calculation packages, including noncon-servative modeling practices, nonfunctional pipe supports, no verification of spring hanger setting, lack of various analyses or documentation to justify the design, wrong response spectra l
input data, and failure to consider the eccentric mass of valve c
i actuators. The NRC inspection team at ANO concluded that "even though Bechtel supposedly fulfilled the bulletin's requirements, many discrepancies between the as-built ANO configuration and we g
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BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 10 of 29 2
design bases were continuing to be identified." Consequently, since Bechte. a s the AE for ANO, DAEC, Davis-Besste, Palisades, and Point Beach, the NRC chose Bechtel for an inspection in this program area.
3.
Method of Inspection The inspectors reviewed a sample of Bechtel's calculation packages and assessed the quality of Bechtel's previously supplied stress calculation packages and associated documents relating to IEB 79-14. Unresolved Item 89-01-01 from NRC Inspection Report 99900519/89-01 was also reviewed. The inspection methodolgy for assuring the adequacy of the stress calculation packages comprised a comprehensive review of design criteria documents, design inputsh drawings, computer models, and reviews of other applicable
' design criteria documents. The calculation packages that were reviewed for the Hatch, Davis-Besse, and SNUPPS facilities were typically analyses Mat had been reverified or modified since the initial IEB 79-14 analysis was performed.
The format of tt,,information in the calculation packages that was reviewed wa. similar. Generally, the analysis package contained the following:
a.
Check Sheet. The check sheet was signed by an analyst, a checker, and a supervisor.
b.
Calculation Cover Sheet. The calculation cover sheet identified the originator, the checker, and provided a record of issues, c.
Piping Design Report. The piping design report contained design document references and a summary package consisting of a stress summary, support design load, nozzle loads, anchor _and penetration loads, thermal expansion calculations, weight-calculations, seismic calculations, a stress analysis math model, and a marked up isometric drawing.
During the inspection, the staff also asked Bechtel for additional stress calculation packages for the Calvert Cliffs and Farley projects. The staff made this request because these analysis packages had not received the same licensee or vendor reverifi-cation that were performed for Davis-Besse, Hatch, and SNUPPS.
NRC gave the Farley and Calvert Cliffs packages a cursory review.
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DRGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 11 of 29 Regarding Unresolved Item 99900519/89-01-01, the inspectors reviewed the method in which Bechtel dispositioned computer program errors within its Engineering Department Precedure (EDP) 4.38 process. This area involved a review of a number of Bechtel probleminvestigationreports(PIRs),discussionswithBechtel
-staff, review of computer program user's manuals, and review of computerprogramerrornotices(ens).
l Additionally, the inspectors discussed with Bechtel personnel past problems that had been identified with its IEB 79-14 related work activities at the ANO, DAEC, Point Beach, Davis-Besse, and Palisades facilities. As discussed in Section E.4, below, the i
NRC inspectors identified nonconformances in Bechtel's failure to I
adequately implement effective design control and verification program and to control evaluations of identified errors as specified in the quality program.
4.
Piping and Piping Support Stress Calculations The NRC inspecters compiled several examples of inaccuracies that were found in Bechtel stress calculation packages related to IEB 79-14. All of the examples used were from Bechtel
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calculation packages that were turned over to different Bechtel customers, such as Duane Arnold, Davis-Besse, Palisades and Point Beach. Nonconformances 90-01-01, 90-01-02, and 90-01-05, and Unresolved Item 90-01-09 were identified in this area.
a.
Duane Arnold - NRC Inspection Report 50-331/90-003, for the DAEC facility, identified U-bolts installed in several piping supports that were overstressed. A review of the circumstances revealed that Bechtel performed the piping and i
pipe support analyses initially as the AE, verified the i
as-built configuration and reverified the stress analyses duringtheIEB79-14effortin1979. However, the over-stressed U-bolt problem was not identified on either occa-sion by the Bechtel personnel reverifying the stress analyses.
Therefore, during a. Region 111 inspection at DAEC, the NRC inspectors asked the licensee to provide a historical perspective regariting the analyses related to IEB 79-14.
During the review of these documents, the NRC Region 111 inspectors noted that Bechtel reverified many of its analyses packages around 1983 and identified 62 pipe supports that l
needed sodification because the as-found conditions of the support.s exceeded the FSAR design limits. Bechtel's SeptemberC,1983,lettertoDAEC(BechtelLetterBLIEG-83-568) stated that:
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 12 of 29 Although modifications were required to restore the original plant safety factors, the results of the Bechtel evaluation for the 62 supports are that the integrity and operability are not jeopardized by the condition of the supports.
Therefore, because a substantial safety hazard had not been created, the condition does not require reporting to the NRC.
Furthermore, none of the 62 discrepancies constitute nonconformances. This was based on the DAEC definition of these terms in DAEC's letter to the NRC, LOR-79-177. Therefore, DAEC's conclusions that no nonconformances exist, remain unchanged.
Attached to BLIEG-83-568 :s a Bechtel Pipe Support Evalua-tion for the 10 CFR Part 21 review. The package contained individual pipe support and spring hanger evaluations indicating various as-found conditions that exceeded the FSAR design bases to some degree. The Bechtel conclusions stated in part, that the stresses in the support coniponents associated with the loading condition are such that failure of the supports would not be expected to occur.
l During this inspection, the inspectors discussed the contents of BLIEG-83-568 and asked if Bechtel had performed any additional evaluation of the DAEC support deficiencies, I
or had expanded its evaluations to consider generic and cumulative implications. The inspectors asked if Bechtel had taken any corrective action under Appendix B to i
10 CFR Part 50 to preclude repetition of this problem.
1 Bechtel was also asked to supply any additional documentation (e.g.,10 CFR Part 21 evaluations) regarding this issue and was specifically asked whether the root cause and potential generic implication of the multiple errors were evaluated 4
for DAEC and for other licensees for whom Bechtel had performed activities related to IEB 79-14. The inspectors also asked whether Bcchtel had performed an evaluation of-the collective safety significance of these individual problems.
In ressonse to these questions, the Bechtel personnel stated that t1ey.were not aware of any specific action that they had performed to address the Appendix B corrective action concern and Bechtel did not provide any records of evaluations I
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ORGANIZATION:
BECHTEL CORPORATION GAITHER$ BURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 13 of 29 to the NRC inspectors.
Further, in review of the deficiencies, the NRC inspectors noted that 33 of the 62 DAEC pipe supports were used in the DAEC residual heat removal (RHR) service water piping. The inspectors review of the DAEC pipe support evaluations noted examples of both a repetitive type of problem and multiple support deficiencies in particular systems or areas, for example:
Eight RHR service water (SW) return pising system supports
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were found with U-bolts installed whici restrained 1ateral pipe movement causing pipe stresses that exceeded thermal stress allowed by the design code. The support numbers are: HBE-31H-38, 39, 40, 42, 43, 44, 45, and 46.
Fourteen supports were identified as having calculated loads on the pipe supports for the as-built piping con-i figuration that resulted in support member loads which exceeded the allowable vendor's support member load capacity. Of these 14 supports 10 were used in emergency SW system applications. SpecifIcsupportnumbersare:
HPD-25SA-179; HBD-255R-180; HBD-28H-14; HBD-31SS-101; GBB-23SR-159; GBC-45R-73; GBC-45R-74; and HBD-82H-40, 41, 42, 43, 44, 45, and 46.
Twelve supports were identified as having calculated loads on the pipe support for the as-built pi)ing configuration i
that resulted in anchor-bolt loads whic) exceeded the manufacturer's maximum working load. Of these 12 supports, 10 were used in SW system applications. Specific support numbers are: EBB-4H-17; EBB-16H-30; HBD-24SA-91; HBD-24SA-160; HBD-255R-174; HBD-28H1-1, 2 and 3; HBD-295A-151; HBD-68SA-43; HBD-28SA-99; and HBD-1005A-147.
> l Nine SW piping system supports were identified as having stresses in either the su) port members, or the welded connection..or both, whic) exceeded stresses allowed by the design code ANSI B31.7.. Specific support numbers are:
GBB-23SA-157; HBD-24SA-91; HBD-295A-151; HBD-31SR-70; HBD-116SA-80, 125, 126, and 128; and HBD-162SA-20.
Four supports were identified as being incorrect for their applications. The calculated loads on the supports for the as-built piping configuration revealed an upward loading which the supports were not designed to react to.
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-ORGANIZATION: BECllTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION PAGE14of'4{
NO.: 99900519/90-01 RESULTS:
Of the 4 supports, 2 were used in SW system applications.
Specific support numbers are:
EBB-4H-16 EBB-16H-18, HBD-28H-3, and HBD-30H-31.
Four'SW supports were identified because the calculated loads on the support for the as-built pipin; configure-tion resulted in deflection of the support M.ch exceeds the deflection allowed by the design code. All 4 of these supports are used in the SW system app (PS-2);
lications.
Specific support numbers are: HBD-64-DP60 HBD-64-DP205 (PS-1); HBD-82H-43; and HBD-82H-46.
Bechtel indicated that they had not performed evaluations of j
the overall cumulative significance of the numerous individual pipe supports for DAEC or any other licensee where these types of deficiencies have been identified, in addition, Bechtel did not consider that the same type of errors and deficiencies could exist at facilities of other Bechtel
. customers where Bechtel performed the same type of~ engineering services-related to IEB 79-14.- The inspectors noted that Bechtel has perfor;ned piping and pipe support stress calculations i
related to IEB 79-14 for more than 20 NRC licensees. These H
- licensees included: ANO, Callaway, Calvert Cliffs Davis-Besse, Duane Arnold, Farley, Grand Gulf, Hatch, Hope Creek, Limerick, Millstone 3, Oconee, Palisades Palo Verde Point Beach, San Onofre, South Texas, Susquehanna. Trojan Turkey Point, and
^ Wolf Creek. Further review in this area is necessary to determine if there is a bases on which Bechtel should have considered the overall cumulative and generic implications of the identified design deficiencies.- Therefore, Unresolved Item 90-01-09 is identified in this area.
b.
Davis-Besse - Between-1985 and 1987, the NRC staff and
^ ;p Davis-Besse personnel identified.many differences between the as-found Davis-Bcsse piping system = configurations and the as-built design drawings..In response to the identifi-
-cation of these differences, the licensee established a comple? reverification program of'the piping and pipe
. support alculation packages :that' Bechtel had performed in respor.9 to IEB 79-14. As a result of the reverification program tha Davis-Besse piping system was modified to restore the facility to the FSAR design limits. As a result of the Davis-Beste piping support inspection and verification-program, the licensee for Davis-Besse'(Toledo. Edison) concluded that many nonconforming conditions had either not
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. ORGANIZATION: BECinEL CORPORATION Gf.1THERSBURG, MARYLAND 4
REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 15 of 29 i
been identified, incorrectly identified, or incompletely identified in the post-construction quality control inspections and in tb programs initiated in response to IEB 79-14.
Toledo . son also determined that IEB 79-14 information had been i arrectly and incompletely transferred to the design documents; consequently, some as-built conditions were not considered in stress calculations or reflected in as-built drawings.
The NRC inspectors reviewed examples of these support deficiencies. The inspectors' review of the results of the Davis-Besse verification program identified the following support deficiencies:
calculated loads on some supports for the as-built configuration exceeded vendor's support member load capacity; calculated loads on some pipe supports for the as-built piping configuration had anchor-bolt loads that i
exceeded the manufacturer's maximum working load; and stresses in either some support' members or the welded connections exceeded the' stresses allowed by the design code.-
i The NRC staff discussed with Bechtel personnel during this inspection whether or not Bechtel had evaluated the deft-ciencies and errors that.were identified at the Davis-Besse facility in accordance with its established QA programs.
Bechtel did not present any records to-support such evaluations, u
Point Beach and Palisades - Recent NRC inspections at Point c.
Beach (Inspection Raports 50-266/89-004 and 50-301/89-004),
i and at the Palisades facility L(Inspection Reports 50-255/89-024 and 90-002) noted that numerous errors and deficiencies ccM inued to be found in calculation packages that Bechtel had prepared. Because the Point-Beach and Palisades
- facilities have only recently begun to' verify calculation packages an accurate count of the number of errors and deviations is not yet complete. However, Point Beach staff recently informed NRC staff that it had found 44 of its l
approximately 200 RHR pipe supports that need to be modified J
'because of errors in IEB 79-14. calculation packages. Gechtel is )erforming the reverification and reconciliation w9rk at bot 1 facilities. Bechtel also performed the initial piping and pipe support stress analyses for both plants.
- 1,
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.' : 99900519/50-01 RESULTS:
PAGE 16 of 29 An NRC enforcement letter to the valisades facility charac-terized the deviations related to IEB 79-14 work as indicative of a significant progrannatic breakdown in the controls associatedwithdesignactivitiesforpip(ingandpipe supports. NRC Enforcement Action Letter EA89-251), dated February 20, 1990, to the Palisades facility, also stated 4
that based on the reviews of historical and recent work-
~
during our inspection, this breakdown has existed, in some j
cases for almost 10 years and continues to exist today.
1 TheBechtelPlantDesignEngineeringChief(Ga'thersburg Office), attended the NRC-licensee meetings at both Point Beach and Palisades. At these meetings, the specific 4
details regarding the deviations were discussed; however, Bechtel stated during this inspection that it had not initiated any 10 CFR Part 21 evaluations or any 10 CFR Part 50 1
Appendix B reviews of the identified deficiencies. Bechtel has current contracts with both facilities to perform the
.IEB 79-14 calculation. package work activities.
During this inspection, the NRC inspectors questioned whether Bechtel evaluated the errors and deficiencies. identified in-its calculation packages and'whether the underlying root cause of the multiple errors were evaluated for any of the facilities discussed above. The Bechtel. staff stated that they-had notified all of'the other Bechtel projects by an interoffice mem0randum (IOM) from the Gaithersburg Manager
. of-. Engineering.. However, after.several NRC requests for a
- l copy of the 10M, Bechtel stated that the IOM did not addrcts the concern and was not relevant to the discussions.
Additionally,-Bechtel stated that it had:not performed any root-cause evaluations of the potential generic implications of the Point Beach or Palisades problems.
The 10M'is discussed in additional detail in Section E.5 (below).. Although the NRC inspectors identified-a relation-i ship between support deficiencies at different facilities, i.
additional NRC staff review will be necessary to determine if there is a basis on which Bechtel should have considered
, ;r
-the overall cumulative and generic-implication of the identified design deficiencies. Therefore, unresolved Item j.'
- 90-01-09 is identified in this area.
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a ORGANIZATION: BECHTEL CORPORATION-
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GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 17 of 29 5.
Bechtel IOM Regarding IEB 79-14 As'discussedinSectionE.4.c(above),theBechtelGaithersburg Office Manager of Engineering wrote an IOM, dated March 27, 1990, that addressed IEB 79-14 issues involving the Calvert Cliffs Nuclear Power Plant (CCNPP) and which was sent to three Bechtel managers (the Nuclear Operations Manager, the Gaithersburg Area Regional Office Manager, and the Calvert Cliffs Project Manager).
The memorandum was also sent to 42 other Bechtel personnel representing Bechtel clients who are NRC' licensees. The licensees
+
represented by Bechtel's addressees included: Browns Ferry, Calvert Cliffs, Comonwealth Edison Project Davis-Besse, Farley.
Hatch, Hope Creek, Limerick, Palisades, Peach Bottom, Point Beach, Susquehanna, Turkey Point, Vogtle, Watts Bar, and Wolf Creek. During discussions with Bechtel's staff on April 25, 1990, the inspection team asked for a copy of this letter; however, Bechtel delayed providing the inspection team a copy of the letter until May 7. 1990, even though the inspectors esked for it.several times during the inspection.
1 The inspectors review of the ION and a subsequent presentation to CCNPP based, in.part, on the 10M' indicated that Bechtel obtained copies of NRC regional inspection reports and summarized the V
programatic and technical issues:that were addressed in the inspection reports. The licensee facilities identified in the i
presentation included 5 of 16 to whom Bechtel provided some engineering services in response to IEB 79-14. The 16 plants identified by Bechtel are: ANO, Point Beach, Kewaunee, Prairie Island, Braidwood, Palisades, Browns Ferry. Turkey Point, North Anna, Surry, Brunswick, Robinson, Oconee, Oyster Creek, Pilgrim, 3
1
.and FitzPatrick. The five plants for which Bechtel performed
's activities related to_IEB.79-14 are: AND, Point Beach, Palisades, Turkey Point and Oconee. Discussions with Bechtel personnel indicate that Bechtel performed varying amounts of IEB 79-14 related stress calculations and analyses related to IEB 79-14 for -
l approximately 21 licensed facilities.
The presentation. discussed in the ION addressed programmatic and technical issues as they relate to the CCNPP. tThese issues are similar to the plant-specific issues discussed in Section E.4 (above)_thatBechteldispositionedforvariouslicensees L
over the last several years. These include: as-built reconcil-l' iation between stress calculations, stress and support design t
criteria, welded attachment evaluations, design analysis documen-1 tation, missing calculations, implementation of design bases-into l'
o
L ORGANIZATION: BECH!tL CORPORATION La-GAlTHERSBURG, MARYLAND i
REPORT lNSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 18 of 29 design documents, quality of as-built documents, FSAR compliance, and design control. The " Recommendations" section of the presentation stated that BG&E should consider investigating some areas related to IEB 79-14 as a proactive measure in the short' run, review status ano quality of as-built documentation and its use in current design, and perform evaluations of stress and pipe support calculations.
6.
Piping and Pipe Support Design Bases Review During the planning stages of-this inspection, the inspectors spoke with Bechtel about the calculation package sample size that g'
could be reasonably reviewed and the projects that were easily-accessible. The projects that were identified for the calculation package review were Hatch, Davis-Besse and SNUPPS. Calculation packages from two other projects,'Farley and Calvert Cliffs, were briefly reviewed..The NRC inspectors revieued a' selected sample i
i L
of calculation packages to verify conformance with applicable codes, FSAR comitments, and NRC requirements.
a ThemajofityoftheBechtelcalculationpackagesthatwere rev_1ewed represented engineering work that had been reverified
- since its earlier verification (1979-1980) in respor.
- o the g
requirements in IEB 79-14. Consequently, the Bechtel calculation packages that.the NRC inspectors reviewed had the benefit of 'e -
ceiving two'different Becitel design engineering reviews.
i f
- Despite these previous reviews, the NRC inspectors found many errors and deficiencies..
No individual error or deficiency was -
identified that, when. considered'by itself, would render a
~
p support inoperable; however, the inspectors identified multiple
- examples that when considered collectively, indicated that.
L ',
Bechtel had ineffectively implemented a portion of its design.
K program process control. The following are examples of the calculation package deficiencies that were identified; Each of the deficiencies indicate a lack of attention to detail in the p
design control process, and could cause errors in the associated-stress calculations. For example, many as-built conditions are.
o, incorrectly documented. incompletely documented or not documented i
at all; therefore, the seismic. analysts would. input incorrect information into their calculations. Nonconformances 90-01-01 n
and 90-01-02 were identified in this' area..
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND B-REPORT INSPECTION N(, : 99900519/90-01 RESULTS:
PAGE 19 of 29 l
Hatch Calculation P41-$WH-125, December 7,1982, ' Pipe l
a.
Support."
Two detailed support drawings were made for this support.
1 Both support drawings showed incorrect orientations; the restraint direction was skewed by.35 degrees.
The pipe support local stress evaluation for the integral welded attachment (IWA) was incorrectly calculated; a nonconservative methodology was used.
Bechtel's Pipe Support Design Manual (PSM) 4.20.1, i
dated November 26, 1979, states that:
ASME Section III Code and B31.1 do not give stress indi;;es for welded attachments to piping elbows. At the present time, there are no analytica'l methods for determin-ing these stress indices. Therefore, in view
-of the above, the following criteria are to-s be used: Welded. support elbows shall not be used for ary critical lines;-for noncritical lines,-welded supports to elbows shall be avoided as much as possible.
If used, the support must be axially loaded. Welded supports to elbows which produce bending
. moments at the connection between the elbow and the support shall not be used; and the above design guide provides the criteria for the design of integral attach:ents, such as lugs and stanchions.
The NRC inspector determined =that, in view of the Bechtel 1
design criteria (above), an integral support was welded :
to the elbow and the support connection at the~ elbow was subjected to a bending moment in response to the horizontal i
load. Therefore, the design criteria were apparently not implemented and an engineering justification for not using the design criteria was not made to ensure design adequacy.
'A weld calculation.shown on Sheet 28 was identified as y
failed. Acceptable weld sizes were not addressed in the calculation package.
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND
'1 REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 20 of 29 s
b.
Hatch Calculation P41-SWH-127, February 24, 1983, ' Pipe Support."
The pipe local stress evaluation for the~ IWA was incor-rectly calculated; the fundamental engineering theory was not applied.
This support contained an IWA which was welded to the elbow and was subjected to a bending moment in response to the horizontal load. Consequently, the aforementioned Bechtel design criteria were not implemented and no engineering justification was made to ensure design adequacy.
The support calculations did not address the base,nlate size and its clearance with the clip angles. As a cesult.
the restraint direction was not assured to meet the utent i
of the design. Furthermore, the 3/16-inch clearance shown on the-drawing was not consistent with the as-built dimension.
Since the design loads for the aforementioned two supports were relatively light, it was anticipated that the dis-crepancies identified above would not result in an opera-bility issue. However, if the design loads becoam criti-cal, then the two sup,, orts in question might not be able to serve their intended function as required by the design.
The NRC team was concerned that the incorrect calculations of local stresses for the integral welded attachments for the subject two supports may exist in other pipe support calculations, not only in the service water system, but also in'other piping systems, perhaps being unable to meet t
the: intent of the design.
~ -
c.
Davis-Besse Calculation 18C, Revision 4, October 5,1986, " Low Pressure Injection Piping." '
The tees at Nodes 40'and 1 s iere modeled~c.s " welding tees;" however, the as-buih configurations were deter-mined to'be "unreinforced fabricated tees." As a result 4
of this error, the stress identification factors (SIFs) i were undercalculated by a factor of 2.68. The significance E
of this error was mitigated by the fact that the initially calculated stresses at the nodes were relatively. low.
If the calculated stresses at these points had exceeded 50 per-cent of allowable stress, these errors would have resulted in the piping exceeding the FSAR connitments.
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ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND
.7 REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 21 of 29 i-l d.
Davis-Besse Calculation 180, Revision 6. December 15, 1988, " Low Pressure Injection Piping."
l Support CCB-6-H1 was a lateral snubber located at Node 22 of the piping model. Because a negative sign was omitted from the restraint cosine, the seismic support was mis-oriented by 57 degrees.
Instead of being modeled as per-pendicular to the pipe, the support was modeled as being skewed 33 degrees tff the axial direction. This introduced an incorrect restraint which could affect the mode. shape of the natural frequency. calculation. Therefore, the calculated seismic loads would be wrong.
For this situation, an adjacent segment of pipe had a restraint oriented in the same direction as the incorrect restraint caused by the error. On this basis, the natural frequency calculation should not be significantly affected; however,-
the incorrect axial load taken by CCB-6-H1 must be added.
to this other support and then be evaluated. Therefore, this calculation was indeterminate and would have to be l..
reverified, Valve HV-DHIA had its motor-operated actuator modeled 4
at Node 105 The as-built configuration showed this actuator to.be angled at 30 degrees from vertical. The ll model,'however, oriented the actuator at approximately 8 degrees from vertical. This error was of particular concern since Bechtel had reanalyzed the piping to l-specifically address changes.in the weight and center of gravity of the valve and'yet, these changes.were incorrectly incorporated into the analysis on two.
occasions. There was no documentation in the calcula-
~'
tion package.that either recognized the modeling error or that reconciled the effect of this modeling error.
e h
Therefore, the system stresses did not appear to have i
been validly assessed.
e.
Davis-Besse Calculation 338-CCB-6-H12, Revision 0, April 13,
-1988, " Pipe Support."
This was a cantilevered support using Bechtel's BOLTS computer program for evaluation of the baseplate and c
anchor: bolts. The attachment on the cantilever to the basep1 ate was shifted off center causing an eccentric 3
load on the anchor bolts. The BOLTS program specifically 1
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T ORGANIZATION:' BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 9900519/90-01 RESULTS:
PAGE 22 of 29 states that it is only valid for synnetric attachments 7
and as such, the use of this program was inappropriate.
For this specific case, the anchor bolts apparently had sufficient design margin that they would not cause an overstressed situation; however, the use of the inappropriate design methodology was not evaluated in the calculation documentation.
f.
Calvert Cliffs Caleviation 2-17 Revision 6. February 4, 1981,
" Safety injection Piping."
Several modeling discrepancies were noted. For support
[
'2-8111,:R-4, at Node 45, the isometric drawing showed a-lateral ~ restraint, whereas the model used a 15-degree skewed support. For the air-operated valves at Nodes 65 and 85, tie center of gravity (CG) of the valves was not modeled.
-g.-
Calvert Cliffs Calculation 2-57, Revision 3, December 2,
[
1981, " Component Cooling Letdown Heat Exchanger Piping."
1 Revision 3 of the c
'atie-p wtage stated " Issue 02 for study only.
J il valid." Issue 01 (Revision 1) stated snat the Unit 1 analysis is valid for the Unit 2' piping evaluation; however, when the NRC
'i
. inspectors compared the two configurations, they found I
that the Unit 1 analyses used a segment of 8-inch-i diameter pipe, whereas the Unit 2 configuration showed
' 6-inch-diameter pipe for the same segment. The overall affect of this discrepancy was.not; reconciled in'either the Revision 1 or Revision 3 calculation package.
The Revision 2 " study only" calculations, which Bechtel i
had reviewed and. approved, contained a number of_ dis-crepancies which were identified by the NRC inspectors.
These discrepancies included inadequate modeling:of a valve CG, inaccurate modeling of the pipe wall thickness, i
and nonconservative values in the "y" direction response spectra. None of the discrepancies were identified or
-reconciled in'the Revision 2 documentation.
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c ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND i
REPORT INSPECTION-NO.: 99900519/90-01 RESULTS:
PAGE 23 of 29 L
L l
h.
Farley Calculation G-65060, Issue 4, date unknown, modeled l
the valve CG for valves V001H and V001G on the pipe center-line axis. This indicates that an-actual CG' location was not used from the applicable vendor's valve drawing.
1.
Farley Calculation 6-65060, Problem 238. Issue 4, date 3
unknown, which included an isometric drawing that did not document a pipe support located at node 308.
j.
Farley Calculation G-70680, Problem 2, Issue 2, date unknown, Farley. Unit 1, " Spent Fuel Piping," included valve V002B weight discrepancy)between the computer program input valve weight (620 pounds and the stress analysis isometric drawing (340 pounds).
k.
Bechtel'sStandardizedNuclearUnitPowei.'lantSystem(SNUPPS)
Stresc Isometric Drawing M-04ALO3(Q), and associated Attachment D.
Sheet 2 of 9, Revision 6, dated October 17,1983, " Auxiliary Feedwater: Piping," showed that the isometric drawing expressed the valve weight of HV5 as 571 pounds; however, the computer data stated t h t HV5 was 623 pounds.
1 1.
-SNUPPS Stress: Isometric Drawing M-04AE04(Q), and associated
- Attachment E, Sheet 1 of 5, Revision o, dated November 4,1983,
" Aux 11ary Feedwater-Discharge Piping," expressed the isometric valve weight for V057 as 275 pounds; however, the valve weight 1
?
for V057 in the computer data was 134 pounds. The weight of 4
1, valve FV39 was expressed as 6200 pounds on the isometric draw-ing; however, the computer data for valve FV39 was 6355 pounds.
m.
SNUPPSIsometricDrawingALO3-C003/135(Q),datedMarch 20, 1985, 3
Datapoint.435, included a 16 percent weight increase that was identified but was not reconciled with the original support design.
L' n.
SNUPPS Isometric Drawing No. ALO3-C005/135(Q), dated February 23, 1984 Data Point 280, includes a-6 percent l
weight increase that was identified but was not reconr.iled j
with the original support design.
j
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SNUPPSIsometricDrawingALO3-0010/135(Q),datedFebruary23, 1984 Datapoint 455, included a 12 percent weight increase that was identified but was not reconciled with the original support design.
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ORGANIZATION:
BECHTEL CORPORATION L,
GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 24 of 29 7.
Computer Program Error' Processing
)
Problem Investigation Reports - The inspector reviewed Bechtel EDP problem investigation reports, computer program user's manuals, and computer program error notices. The objective of p
the review was twofold. First, to evaluate a portion of Bechtel's L
process for dispositioning generic deficiencies within the
. procedure EDP 4.74, " Generic Deficiency Processing." Unresolved l
Item 89-01-01 was identified in the previous NRC inspection in Bechtel Inspection Report 99900519/89-01 regarding EDP 4.74.
Second, to identify and evaluate the adequacy of the method that
-Bechtel employs to control and disposition computer program errors.that are identified in. safety-related design applications.
The inspector reviewed Bechtel EDP 4.38.."Com) uter Program Error Reporting and Corrective Action." On tie basis of this procedure, computer program errors are initially documented y
when the sponsor of each program issues a computer program error notification (error notice).. These error notifications are distributed to each holder of a program usc 's manual and to the chief. engineer of the cognizant discipline. The Central Information Services Library controls the ~ distribution of program user's I
manuals. The cognizant chief engineers are resporsible for determining the projects that could potentially be affected by D
the. program error. This responsibility can also include the gen-eration of'a problem investigation report (PIR) that is distributed E
.to the projects requiring an evaluation for applicability and,-
- possibly, corrective action. These.PIRs include a description of the actions taken and are then approved by the cognizant chief O
engineer.
..j The NRC. inspectors asked Bechtel'for a current listing of PIRs
- related to computer code errors. Bechtel provided a PIR log that-a listed the computer program-related PIRs from 1986 to the present.
The inspectors used this log as a basis for selecting PIRs for review. The inspectors reviewed 35 PIR files ~during this inspection.
1
.This review included veiifying that each project and disciplina identified on the Action Distribution had responded to the PIR with an evaluation of the effect of. the computer code error, as 1
required in EDP 4.74 and EDP 4.38.- This evaluation had not been f
completed for the following four PIRs.
(1)PIR-G-87-11-CQ, dated
. June 8, 1987, identified a Class 2 error in computer program-L' CE988 (.FL'JSH). (2)'PIR-G-87-12-CQ, date not recorded, also p
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.v ORGANIZATION: BECHTEL CORPORATION GAITHERSBURG, MARYLAND 1
REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 25 of 29 involved a Class 2 error which was in the ANSYS program.
The PIR log indicated a closed status for both of these PIRs even though the Bechtel " action addressee," Grand Gulf project, did not complete its evaluation. (3) PIR-G-86-35-CQ, dated December 23,
- 1986, identified a Class 3 error in computer program CE798 (ANSYS) which may have been used for both civil and mechanical engineering activities at Grand Gulf. A Class 3 error is the most severe and most significant type of error. (4) PIR-G-86-28-CQ, date not recorded, involved a Class 3 error in the ICES STRUDL computer program for the Duane Arnold facility.
For all four of the PIRs, the disposition was almost identical, that is, a letter to the client stating in part, " additional review of the problem would be required to determine applicability.
Please advise if you would-like us to perform such a review...."
Section 16, " Corrective Action," of Bechtel's QA Program Topical Report BQ-TOP-1, Revision 4A, requires Bechtel to ensure that errors detected after the design document is issued are reviewed for significance and reportability and documented. Bechtel's
" Computer Programs," Policy Q-3.5, requires, in part, that the
[
effect of errors on work done previously will be evaluated.
However, the examples just given show that Bechtel failed to comply with its nuclear QA program in these four examples.
Therefore, Nonconformance 90-01-04 is identified in this area.
8.
User's Manuals During the review of EDP 4.38, the inspector noted that the procedural mechanism for the notification and control of-computer-code errors is the distribution of error reports to registered
' users of the various codes. These error reports are entered in the manuals associated with each code:for reference by the code
- users. ~.Bechtel indicated that any code user's manual may be accessed by several individuals. Thus, the inspector requested.a list of currently used computer programs, with data indicating how many ind;viduals used each program. Although data concerning code usage were not available, Bechtel produced a list of active m
computer programs with an indication of the programs most commonly used.
On the basis of this list, the inspector selected three-computerprograms(ME-101,CE-901,andNE-650)andaskedBechtel.
w for listings of the registered users for each program. The code manuals held by seven registered users were then reviewed.- The inspector determined that six user's manuals contained a complete l
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ORGANIZATION:.BECHTEL CORPORATION GAITHERSBURG,-MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 26 of 29 set of code error reports.
However, one user's manual for CE-901 did not include the report associated with an error designated as 88-01. Error. Report 88-01 was included in the two other CE-901 manuals reviewed. Error. Report 88-01 describes a Class 3 error, indicating the highest degree of severity. EDP 4.38 defines Clus 3 errors as." Program errors which produce wrong results, j
but which could be interpreted as valid results." Thus, a Class-3 error could potentially affect safety-related analyses.
Following the revtew of the particular. user's manual for CE-901 that did not contain a complete set of error reports, Bechtel indi:ted'that this user's manual had been obtained from an i
indi<idual who was not a frequent user of CE-901, and not the registered user. In addition, Bechtel stated that the original manual given to the inspector for review was not the correct user's manual, and that a different volume should have been reviewed. This misunderstanding came about because the regis-tered CE-901 user was unavailable, and the manual had been retrieved by his associate, a senior engineer.. The inspector O ted that the senior engineer had stated that he was an
' infrequent user of CE-901, and had not used the code for some time.
The. inspector initially interviewed the. senior engineer and reviewed both manuals noting that the technical content of the two. manuals wat not the same. The original manual contained forms from the. Central Information Services Library, indicating the registered user and Error Report 85-01.- The second manual contained the-same forms and Error Reports 85-01 and 88-01.-
The inspector concluded that the CE-901 user's manual:could have been used for an analysis by a Bechtel engineer. Subsequent to this inspection, Bechtel contacted the NRC inspector and indicated that the CE-901 user's manual consisted of three parts:
the two 4
. volumes review =J, and a. third volume that was not identified during the inspection. The user's manual was discussed in detail, including the possibility of inadvertent use of the wrong manual (one'that lacked Error Report 88-01). The. ins)ectors interviewed thret registered users of CE-901 during t1e inspection and two individuals produced a user's-manual that was a single volume containing the registration information and Error Reports 85-01 and 88-01. -Therefare, Nonconformance 90-01-03 is identified in this area.
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ORGANIZATION:
BECHTEL CORPORATION GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/90-01 RESULTS:
PAGE 27 of 29 9.
Code Verification and Validation Control.
Bechtel was asked to explain the computer code verification and validation program for codes used in safety-related applications.
L Bechtel stated that documentation for code verification and validation w'.s maintained by the code sponsor that, in all cases discussed during ti.i: WNe Aspecificexampb, tion,waslocatedattheSanFrancisco k
L office.
co:.puter program CE-998, was u
discussed. CE-998 is a vers ion of the ANSYS computer program R
that Bechtel purchased commercially, and supported code verification and validation program internally. ANSYS is a finite element program that has been used for a variety of safety-related design analyses. The inspectors noted that Bechtel's version of ANSYS was only available as an " executable version,"
and not as " source coding." Thus, CE-998 could be readily executed on the Bechtel UNIVAC computer, but the actual coding of the models and equations could not be determined. Thus, the NRC inspector concluded that it would be extremely difficult to relate unusual or unphysical results to the actual calculations performed in-the code.
Bechtel stated that CE-998 had been deactivated from its com-puter system. The inspector asked if any contractual arrange-ment had been maintained with the ANSYS developer from the i
transmittal of code error reports'that might be discovered in
+
the future.and potentially impact previous Bechtel. analyses.
Bechtel-stated.that no contractual arrangement existed and that-u the validation and verification of CE-998 was Bechtel's respon-l sibility. -The-inspector also noted that a PIR based on errors i
discovered in CE-998 remained open with the code deactivated.
Bechtel stated that the CE-998 could be reestablished if:the j
evaluation of this PIR required additional calculations.
It app <s that Bechtel's practice of not ensuring that it is notifin of any ANSYS error reports could impact a previously performed analysis that~ is currently being used for a licensee's design basis. This area should be reviewed during a future inspection. Therefore, it was identified as Open Item 90-01-07.
- 10. Computer Hardware.
The inspectors reviewed Bechtel's' computer hardware for performing safety-related analyses. Bechtel stated that computer programs were executed on an internal UNIVAC computer and on
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u ORGANIZATION: BECHTEL CORPORATION H
GAITHERSBURG, MARYLAND REPORT INSPECTION-NO.: 99900519/90-01 RESULTS:
PAGE 28 of 29 computing systems utilized through a contract with Power Compu-g ting Company (PCC). -Calculations performed under this contract are completed remotely and utilize software supplied by PCC.
When the inspector asked to review the contract, Bechtel supplied Agreement D58-3-30469, a contract that had expired. Bechtel then produced a document extending the contract for computer 1.j services through February 1991. The inspectors also reviewed the l
PCC contract to assure that 10 CFR Part 21 requirements are imposed for the safety-related software supplied by PCC for use in Bechtel calculations. The contra t required that PCC report to Bechtel those software errors that could potentially L
affect safety-related analyses and to report the requiresents of i
l 10 CFR Part 21 that are imposed.
p The NRC inspectors also noted that the PCC contract included a provision for Bechtel to audit PCC, the' inspector asked Bechtel for'a recent audit report (QAH-PCC-0?, October 1989). The scope of this audit included a' technical review of selected safety-related applications documentation, and programmatic review of the PCC QA program.,The audit resulted in no findings; however, seven observations were noted which required a response from PCC. The p
NRC inspectors did not have any findings in this area.
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- 11. Computer Code Error Logging System l
l During the review of PIR error-reports, the inspector observed L
that Bechtel maintained several log systems for computer code l
errors.
For example, as discussad previously, computer program CE-901'had error reports designated as 85-01 and 88-01; in addi-4 tion, the review of other programs indicated that each program had an independent, sequential system of tracking the reported errors. The review of the PIR log system indicated that some-of these individual code errors generated PIRs; however. the emphasis.during this inspection was on the errors identified in the PIRs. The error reporting systems for each individual program and the process of generating PIRs~from these error reports should be reviewed during a future inspection. Therefore, this issue is identified as Open Item 90-01-08.
12.- Exit Meeting The exit meeting was conducted on April 27, 1990, at'the Bechtel Office,in Gaithersburg. The lead inspector reiterated.the scope of the inspection and identified the calculation packages and PIRs l
that were reviewed. The inspection team also delineated L
potential findings as discussed in the previous paragraphs.
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ORGANIZATION: BECHTEL CORPORATION 3:
GAITHERSBURG, MARYLAND REPORT INSPECTION HO.: 99900519/90-01 RESULTS:
PAGE 29 of 29 l
l F.
PERSONS CONTACTED:
The following Bechtel and NRC licensee personnel were contacted during this inspection and review:
NAME TITLE AND AFFILIATION
- R. H. Stone Bechtel Senior Vice President and Office Manager
- fD. C. Kansal Bechtel QA Manager (effective May 1990)
- fS. A. Bernsen Bechtel QA Manager fB. L. Meyer Bechtel Vice President and Engineering Manager l:
.* R.
L~. Castelberry Bechtel Chief. Electrical and Control Systems
- N. Goel Bechtel Chief, Mechanical Engineering
- J. Brothers-Bechtel Chief, Quality Engineering
- fR. Parekh Bechtel Chief, Plant Design. Engineering fH. W. Mumford Bechtel Assistant Chief Electrical and Control
- W.-J. Engel Bechtel Assistant Chief, Mechanicci Engineering L
- R. H. Fluoragh Bechtel Assistant Chief, Quality Engineering j
- S. Routh Bechtel Assistant Chief. Nuclear Engineering
- C. Reid Bechtel Project Engineering
- fV. Marathe Bechtel Project Engineering i
i
- J. M Parikh Bechtel QA Engineering E. W. Thomas Bechtel Civil Engineering
- dG. H. Goddard Bechtel Civil Engineering
- fN. K. Alyanam Bcchtel Palisades Project APE
-*f R. D. Kies -
Bechtel Vogtle Project APE L
- D. R. Quattrociocci Bechtel Hatch Project APE K. L. Khianey-Bechtel Hatch Project APE S. Deminco Bechtel Hatch Project APE
- R. B. Patel Bechtel Calvert Cliffs Supervisor
- C. J. Falibota Bechtel Calvert Cliffs Project Manager 4
- K.' C. Gandhi Bechtel Farley Project Manager
.fL. Lushbaugh:
Bechtel APE - Farley Project
.R.' Slovic-Bechtel. Staff Assistant C. H. Hsu.
~ Bechtel Farley Project Supervisor J. K. Notwani Bechtel Farley Project Engineer iW. C. Hopkins Bechtel Nuclear Ingineering n
J. D. Heidt Georgia Power Company
- P. H. Straube
-Toledo Edison Company fJ.
G.. Hook Toledo Edison Company I
fJ. C. Sturdavant Toledo Edison Company
- D. T. Ward-Baltimore Gas and Electric Company
- J. S. Gray Baltimore Ga:; and Electric Company-e
- indicates' attendance at the entrance meeting i indicates attendance at the exit meeting
.