ML20136F046
| ML20136F046 | |
| Person / Time | |
|---|---|
| Issue date: | 01/06/1986 |
| From: | Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Wahl H BECHTEL GROUP, INC. |
| References | |
| REF-QA-99900519 NUDOCS 8601070195 | |
| Download: ML20136F046 (2) | |
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NUCLEAR REGULATORY COMMISSION 7.
j WASHINGTON, D. C. 20555 January 6, 1986 Docket No. 99900519/85-01 i
Bechtel Power Corporation Eastern Power Division ATTN: Mr. H. W. Wahl Vice President and General Manager 15740 Shady Grove Road Gaithersburg, Maryland 20877 Gentlemen:
Thank you for your letter of August 9,1985, in response to our letter dated L
July 11, 1985. As a result of our review, we find that your response did not fully address the items of the Notice of Nonconformt.nce contained in Inspection Report No. 99900519/85-01.
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1.
Nonconformance A - While subsequent to the inspection, Bechtel and the battery charger manufacturer have determined that the AC and DC Transient Voltage Tests results are acceptable, the requirements of Procedure EDPI-1.58-01 were not fully met.
Specifically, during interviews with the responsible engineer, it was determined that the required review of the test results was believed to be a function performed by the receiving inspector.
Thus, the responsible engineer did not perform a review which could have noted and evaluated the fact that the AC test did not satisfy the NEMA Standard and that the charts for the other three DC tests were not provided.
If the required review had been conducted, evidence to support the acceptance of the deviations should have been prepared. A response which addresses the performance of engineering reviews in accordance with EDPI-1.58-01 is, required.
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Nonconformance B - The NRC inspectors requested _ documentation required by EDP-4.54. Contrary to the statement in your August 9, 1984 letter, that the required documentation was available in the Chief Engineer's files, only one resume, which was very brief, was made available during the inspection. No other records or documents were available in the Chief Engineer's possession or Personnel records to support the requirements of EDP-4.54.
Thus, no objective evidence was provided during the inspection to support.tbe certification of the two individuals.
The personal knowledge of these individuals by the Chief Engineer does not constitute objective evidence. Documentation such as, but not limited to~the following, should have been included in
. tF,e -file:
training courses and dates attended, ASME Code meetings and dates attended, and' Professional Engineer license information and dates of renewal. '
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b Bechtel Power Corporation January 6, 1986 Finally, while the primary focus of the nonconformance related to initial certification, maintenance of qualification was also addressed.
Your response states that since the triannual recertification was not needed for these individuals, no evidence was necessary to prove the maintenance of qualification. However, Section 3.3 of the EDP 4.54 requires that personnel files contain evidence that demonstrates the maintenance of qualifications. Exhibit B, " Registry of Personnel Authorized to Perform Code Certifying Activities," to EDP-4.54 does not provide supporting evidence and is only a register of personnel
-selected.
3.
Nonconformance C - Although requested at the time of the inspection, no documentation was made available by Bechtel to support the approval of the 5% damping value in lieu of the design specification value of 4%. Documentation of the information discussed in your response to the nonconformance at the time of approval of the Seismic Analysis ~
Report will be reviewed during a future inspection.
~
Please provide the additional information within 30 days of the date of this
-letter.
Sincerely, odshmtMf s,q a.zad r Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement cc:
Kansas Gas & Electric Company ATTN: Mr. G. L. Koester Vice President, Nuclear 201 North Market Street Wichita, Kansas 67201 Union Electric Company ATTN: Mr. D. F. Schnell Vice President, Nuclear Post Office Box 149 St. Louis, Missouri 63166 Distribution:
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