ML20138J909
| ML20138J909 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20138J889 | List: |
| References | |
| REF-QA-99900404 NUDOCS 9705090159 | |
| Download: ML20138J909 (8) | |
Text
.
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Report no.:
99900404/97-01 Organization:
Westinghouse Electric Corporation Nuclear and Advanced Technology Division i
Pittsburgh, Pennsylvania 15230 i
l
Contact:
Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Activities Nuclear Industry Nuclear steam supply system design, components and Activity:
services Date:
April 17,1997 Inspectors:
Richard P. McIntyre, PSIB/ DISP
{
Juan D. Peralta, HOMB/DRCH Goutam Bagchi, ECGB/DE Diane Jackson, PDST/DRPM Approved:
Gregory C. Cwalina, Chief Vendor inspection Section SpecialInspection Branch Division of inspection and Support Programs 9705090159 970502
~
PDR GA999 ENVWEST 99900404 PDR
1 INSPECTION
SUMMARY
The purpose of the inspection was to evaluate the Westinghouse technical and quality oversight of Empresa Nacional de Ingenieria y Tecnologia, S.A. (INITEC, design activities in general, and to assess Westinghouse's thoroughness in its evaluation and disposition of the audit findings identified in the August 24,1994, NRC " Summary of Audit of the AP600 Structural Design" concerning NRC staff-identified errors in INITEC calculations, as described in Section 3.2.
The inspection bases were:
o Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reoulations (10 CFR Part 50).
AP600 SSAR, Revision 11, Section 17.3, " Quality Assurance" o
WCAP-12600, Revision 2, dated December 1993, "AP600 Quality Assurance e
Program Plan" During this inspection, two instances where Westinghouse failed to conform to NRC requirements were identified. Also, one unresolved item was identified.
1.1 Nonconformance j
e Nonconformance 99900404/97-01-01 was identified and is discussed in Section 3.3 of this report.
e Nonconfo mance 99900404/97-01-02 was identified and is discussed in Section 3.4 of this report.
1.2 Unresolved item e
Unresolved item 99900404/97-01-03 was identified and is discussed in Section 3.5 of this report.
2 STATUS OF PREVIOUS INSPECTION FINDINGS No previous inspection findings were reviewed during this insp2ction.
~
i l
l l
3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 AP600 Quality Assurance Proaram Chapter 17 of the AP600 standard safety analysis report (SSAR) describes the i
Westinghouse Electric Corporation quality assurance (QA) program for the design phase of the AP6;; Advancod Light Water Reactor (ALWR) Plant Program.
i l
AP600 SSAR, Revision 11, Section 17.3, " Quality Assurance," states that activities l
performed prior to March 31,1996, were performed in accordance with the quality assurance plan described in Westinghouse topical report WCAP-8370, " Energy System Business Unit - Power Gene.adon Business Unit, Quality Assurance Plan,"
Revision 12a, dated April 1992. WCAP-8370 applied to all Westinghouse activities j
affecting quality of items and services supplied to nuclear power plants and establishes Westinghouse's compliance with the provisions of Appendix B to l
WCAP-12600, "AP600 Quality Assurance Program Plan," dated December 1993, a project-specific QA plan, was developed by Westinghouse to enhance WCAP-8370 in specific areas and to establish additional commitments needed to support the AP600 Design Certification and First-Of-A-Kind (FOAKE) programs. WCAP-12600 establishes the responsibility of the Advance Technology Business Area of the Energy Systems Business Unit for AP600 Design Certification and FOAKE programs and for control of the technicalinterface between Westinghouse and engineering groups and suppliers providing engineering services under such programs, i
Additionally, WCAP-12601, "AP600 Program Operating Procedures," Revision 13, dated July 8,1994, was developed by Westinghouse to establish requirements and re=ponsibilities for developing, approving, implementing, revising, and maintaining operating procedures to meet the QA and administrative requirements of the AP600 program. WCAP-12601 includes an "AP600 Program Procedure Matrix," currently Revision 15, dated April 4,1995, which identifies the correlation between the Westinghouse commitments to the OA requirements of (1) ANSI /ASME NOA-1,
" Quality Assurance Program Requirements for Nuclear Facilities," 1983 Edition (as endorsed by Regulatory Guide 1.28, Revision 3) and (2) ANSl/ASME NOA-1 1989 Edition through NOA-1b-1991 Addenda, and the corresponding implementing guidance embodied in WCAP-9565, " Nuclear and Advanced Technology Division (NATD) Quality Assurance Program" currently Revision 34, dated May 2,1994, and in WCAP-12601. WCAP-9565 governed the implementation of all NATD activities related to areas within the scope of WCAP-8370.
3.1.1 AP600 Desian Certification and FOAKE Proarams Control of Purchased items and Services l
WCAP-12600, Section 7 " Control of Purchased items and Services," describes the f
application of WCAP-8370, Part B, Section 7, provisions to AP600 activities and l
clarifies that the initial qualification and subsequent pctformance evaluation of l
)
suppliers to which technicalcooperation agreements apply \\ emphasis added) is performed in the same manner as for suppliers of purchased items and services.
WCAP-8370, Part B, Section 7.3, " Supplier Performance Evaluation," requires, in part, "A formal evaluation of suppliers is performed each year to determine if additional actions such as audits are required during the upcoming year. This evaluation includes a review of some or all of the following: prior quality program audits, supplier surveillance activities, nature and frequency of hardware discrepancies, results of audits from other sources (customers, ASME, NRC, etc.)
lemphasis addedl....." This section also specifies that as a result of this evaluation, suppliers requiring a complete quality program reaudit are identified.
3.1.2 AP600 Particioation Proaram Between INITEC and Westinahouse Electric Corooration On March 5,1992, Westinghouse and INITEC signed an agreement under which INITEC would perform engineering, management and execution of certain structural and piping tasks associated with the AP600 Program. The following tasks were identified as INITEC's work scope: (1) Analys.s and Detail Design of Pressurizer Safety and Relief Valve (PSARV) Module, (2) Structural Steel Framing (SSAR Section 3.8.4), (3) Floor Stabs (SSAR Section 3.8.4), (4) Nuclear Island Basemat (SSAR Section 3.8.5), (5) Nuclear Island Shear Walls (SSAR Section 3.8.4), (6) Analysis and Detail Design of Piping, and (7) Structural Steel Framing (SSAR Section 3.8.4).
Additionally, the agreement specified that design inputs, methods, required formats and other design information for structural tasks would be provided by Bechtel Power Corporation (Bechtel) and allowed for technical correspondence and interfaces for these tasks to take place directly between INITEC and Bechtel.
In Section 3.0, " Quality Assurance," the agreement specified that INITEC shall establish, implement, and maintain a quality assurance program meeting the requirements of ANSilASME NOA-1, "Qualit) Assurance Program Requirements for Nuclear Facilities" (1986 edition). The agreement also specified that a Quality Assurance Program Plan (OAPP) would be prepared by INITEC and be subject to review and approval by Westinghouse prior to performing any quality-related work.
3.2 Nuclear Island Basemat Desian - Backaround On July 11 through 14,1994, the NRC performed an audit of the structural design of the AP600 at the Bechtel offices in San Francisco. California. The results of this audit were documented in a letter to Westinghouse dated August 24,1994,
" Summary of Audit of the AP600 Structural Design."
One of the key issues identified during the audit were errors found by the audit team in design calculations performed by INITEC (Calculation No.1010-CCC-001, Rev. A).
The NRC audit team identified the following deficiencies: (1) errors in shear and flexural rebar assessment,in the use of punching shear formula, and in the use of finite element dimension; (2) no consideration of accident pressure loads, and loads A
from construction sequence, and (3) out of phase overturning moment from shield and containment buildings.
In its August 2,1994, letter to the NRC, Westinghouse acknowledged its commitment to: (1) perform an independent review of the basemat design calculations, (2) verify the adequacy of INITEC's in-house post-process computer programs used for the foundation mat design, (3) perform simplified analyses as appropriate to confirm the existing design results, and (4) provide the results of this independent review to the NRC. (This issue was identified by the NRC in the AP600 DSER as DSER Open item 3.8.5-21).
3.3 Review of Westinohouse Corrective Actions for July 1994 NRC Structural Audit Findinos a.
Scoce The inspectors reviewed Westinghouse's evaluation and disposition of the audit findings identified in the August 24,1994, NRC " Summary of Audit of the AP600 Structural Design" report conceming NRC-identified errors in INITEC calculations.
1 b.
Observations and findinas As indicated above, in its August 2,1994, letter to the staff regarding errors identified in INITEC post process computer programs used for the AP600 foundation mat design, Westinghouse made a commitment to conduct an independent review of such calculations. In a letter to INITEC (FOK/lNIO181) dated August 3,1994, Westinghouse forwarded: (1) comments presented by an NRC consultant at the July 1994 meeting, (2) additional interpretation and comments by Westinghouse technical staff, and (3) a copy of the August 2,1994, letter to NRC. Westinghouse also stated that a Bechtel employee had been selected to perform the independent review and the scope of basemat review was attached to the letter (Attachment 4).
The inspectors reviewed the independent review report, " Independent Review of AP600 Nuclear Island Basemat Design," dated November 11,1994, performed by Bechtel to address the basemat calculation issues identified by the staff. The inspectors noted that in Section 6.0, " Summary and Recommendations," of the report, Bechtel made several observations and recommendations related to uncertainties in the INITEC calculation that required further evaluation or study.
l The inspectors reviewed an INITEC letter to Westinghouse (IN!/FOK0175), dated February 15,1995,in which INITEC provided its response to address the root causes of the quality issue relative to the Nuclear Island Basemat Calculation, identified by NRC in its July 1994 structural design audit, as well as the measures taken by INITEC in order to avoid the occurrence of similar situations during the performance of present and future structural analysis. The inspectors noted that j
INITEC's response had been formulated almost contemporaneously with the triennial audit being conducted by Westinghouse on February 20 through 22,1995, at INITEC's facilities. Yet Westinghouse's triennial audit report (OLA/lN10007) does not I
4 i
i i
provide any evidence that INITEC had identified this issue as a condition adverse to quality requiring root cause determination or corrective actions in accordance with INITEC's Westinghouse-approved QAPP (see Section 3.4.a.).
i During the inspection, the inspectors inquired as to whether Westinghouse had initiated any root cause determinations or corrective actions, as required by q
WCAP-12S00, Section 16,
- Corrective Action," since this issue was first identified by the NRC in July / August 199 4 or whether Westinghouse had formally accepted or j
rejected INITEC's proposed corrective actions identified in INITEC's February 1995 i
letter. Weeinghouse representatives responded that, as of April 17,1997, this i
issue had not been identifiod as a condition adverse to quality requiring a root cause determination or correcti<e actions in accordance with WCAP-12600 nor had Westinghouse formally rr sponded to INITEC's February 1995 letter.
c.
Conclusions Based on the above, the inspectors concluded that Westinghouse: (1) failed to identify or recognize the NRC-identified basemat design deficiencies as a condition j
j adverse to quality requiring a root cause d 3 termination or corrective actions in accordance with WCAP-12600, Section 16, and (2) failed to determine and evaluate j
the impact of such design deficiencies on completed or related INITEC AP600 design l
deliverables and activities. This issue was identified as Nonconformance i
99900404/97-01-01.
i l
3.4 Review of Westinahouse Oversicht of INITEC AP600 Desia 1 Activities j
a.
Scope The inspectors reviewed Westinghouse technical and quality oversight of INITEC 1
design activities in general, including the documents describing the contractual
]
agreements between Westinghouse, INITEC and Bechtel for AP600 program design 1
activities, b.
Observations and findinas Westinghouse appropriately specified all technical and quality assurance i
requirements consistent with WCAP-12600. As required by the agreement signed on March 5,1992, INITEC provided a QAPP for Westinghouse's review and j
approval.
As described in Section 3.3 above, in September 1994, Westinghouse contracted j
the services of Bechtel for an independent review of INITEC's analysis and design i
methodology for the nuclear island basemat. The results of Bechtel's independent review were documented and made available to Westinghouse in a report dated November 11,1994.
4 I
I
) :
Although Westinghouse had identified the submittal of this independerst review report as a commitment in its August 2,1994, response to the NRC, the inspectors were informed that a submittal of the report on the AP600 docket was still outstanding. No explanation was given as to why this report had not yet been made available for NRC review.
The inspectors leamed that on August 3,1994, Westinghouse had sent a letter to INITEC (FOK/IN10181) requesting that INITEC provide its response to the NRC audit findings (see Section 3.3.a.). However, it appeared that Westinghouse did not consider the results of the NRC structural audit findings and concerns in its January 1995 annual review of INITEC's performance.
Additionally, the inspectors reviewed Westinghouse's Audit Report OLA/IN10007, l
dated March 20,1995, that documented a triennial audit conducted on February 20 through 22,1995, at INITEC's facilities in Madrid, Spain. Upon reviewing the report, the inspectors found that: (1) an evaluation of INITEC's response to Westinghouse's August 3,1994, letter had not been included in the audit scope, and (2) the audit did not identify any evidence to suggest that INITEC had initiated any internal root cause analysis, and evaluatien. Further, the inspectors determined that no corrective actions had been formally identified by INITEC's OA organization to determine the cause, and document the impact of the design deficiencies identified in Westinghouse's August 3,1994, letter, on INITEC's AP600 design deliverables.
Finally, the inspectors questioned Westinghouse's conclusion, in its March 22,1995, letter to INITEC, " Westinghouse AP600 Audit WES-95-211," that "INITEC Design Quality Assurance Program and implementing procedures meet the applicable NOA-1 requirements for INITEC's AP600 work," in light of the fact that the audit report identified 10 findings of programmatic deficiencies in INITEC's implementation of its QAPP.
c.
. Conclusions Based on the above, the inspectors concluded that Westinghouse's (1) failed to adequately evaluate or assess INITEC's performance, as required by WCAP-12600, for a supplier of AP600 design deliverables that had been the subject of an adverse NRC audit finding, and (2) failed to conduct an evaluation of INITEC's response to
'"estinghouse's August 3,1994, letter, and any associated corrective actions taken.
This issue was identified as Nonconformance 99900404/97-01-02.
3.5 Westinohouse Oversiaht of AP600 Desion Activities Based on the nonconformances identified above, the NRC is concerned that these quality assurance deficiencies may have introduced a level of uncertainty on the acceptability of design deliverables provided by AP600 technical cooperation agreement participants. Of particular concern to the NRC, is Westinghouse's failure to recognize and appropriately address a condition adverse to quality, requiring a root cause evaluation and determination and appropriate corrective actions, even when such a condition was identified by an NRC audit and resulted in re-design of the AP600 foundation basemat.
Westinghouse's failure to address this design and quality assurance program deficiency in a timely manner has raised the issue of whether this is an isolated case and that other design deliverables provided by AP600 technical cooperation agreement participants do in fact possess the level of integrity in design verification and quality assurance necessary to satisfy the design certification provisions of 10 CFR Part 52. This issue was identified as Unresolved item 99900404/97-01-03.
3.G Entrance and Exit Maetinas Since this was a one-day inspection, the entrance and exit meetings were both held on April 17,1997. In the entrance meeting the NRC inspectors discussed the scope of the inspection and outlined the areas to be inspected. In the exit meeting the inspectors discussed the inspection findings and unresolved item.
4 PERSONNEL CONTACTED i
Westinahouse Electric Corooration David Alsing, AP600 Quality Systems Manager Ken Kloes, Projects Quality Assurance Engineer Robert Tupper, Advanced Technology, Project Engineer Richard Orr, AP600 Structures Advisory Engineer Narenda Prasad, Engineering Technology Department, Fellow Engineer Donald Lindgren, AP600 Licensing ITEMS OPENED, CLOSED, AND DISCUSSED Ooensd 99900404/97-01-01 NON inadequate corrective action 99900404/97-01-02 NON inadequate quality and technical oversight of INITEC l
99900404/97-01-03 URI acceptability of AP600 design deliverables 9
'f po Ctc i
y" 2*,
UNITED STATES s
p NUCLEAR REGULATORY COMMISSION 2
WASHINGTON. D.C. 20555 0001
- * * * *,o May 2, 1997 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation I
P.O. Box 355 Pittsburgh, Pennsylvania 15230 i
a j
SUBJECT:
NRC INSPECTION NO. 99900404/97-01 b
Dear Mr. Liparuto:
1 On April 17,1997, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection of AP600 design control quality assurance activities at the Westinghouse Energy Center in Monroeville, Pennsylvania. Tha anciosed report presents the results of j
that inspection.
{
The purpose of the inspection was to evaluate the Westinghouse technical and quality i
oversight of Empresa Nacional de Ingenieria y Tecnologia, S.A. (INITEC) design activities in j
general, and to assess Westinghouse's evaluation and disposition of the audit findings 1
identified in the August 24,1994, NRC " Summary of Audit of the AP600 Structural Desigri," report concerning NRC-identified errors in INITEC calculations.
During this inspection, the NRC determined that the implementation of the Westinghouse 1
quality assurance program for AP600 design certification activities failed to meet certain NRC requirements. Specifically, the team identified nonconformances with program implementation with respect to your: (1) failure to initiate appropriate root cause determination and corrective actions for findings described in the August 24,1994,NRC Audit Summary report, and (2) failure to adequately evaluate and assess INITEC's performance during your annual quality assurance review of AP600 suppliers, and to conduct an evaluation of INITEC's February 15,1995, response to the NRC audit findings as requested in Westinghouse's August 3,1994, letter, during your triennial audit. During j
the required triennial supplier audit of INITEC performed in February 1995, Westinghouse's j
audit plan and scope did not include the calculation audit findings identified in the August
]
1994 NRC Audit Summary report, and any associated INITEC corrective action activities, as issues that needed to be addressed to verify the effectiveness of INITEC's quality assurance program implementation.
i Based on the nonconformances identified above, the NRC is concerned that these quality 4
assurance deficiencies may have introduced a level of uncertainty on the acceptability of j
design deliverables provided by AP600 technical cooperation agreement participants. Of j
particular concern to the NRC, is Westinghouse's failure to recognize and appropriately 1
address a condition adverse to quality, requiring a root cause evaluation and determination and appropriate corrective actions, even when such a condition was identified by an NRC audit and resulted in re-design of the AP600 foundation basemat.
4 i
)
9' 7 C S M S E
Mr. Nicholas J. Lipsrulo
- i j-Accordingly, the NRC requests that Westinghouse: (1) determine and evaluate the impact of these nonconformances on completed or related design deliverables and/or activities i
performed by all AP600 technical cooperation agreement participants: (2) identify the q
steps that it has taken, or intends to take, to demonstrate that other design deliverables provided by AP600 technical cooperation agreement participants do in fact achieve the level of integrity in design verification and quality assurance necessary to satisfy the i
i design certification provisions of 10 CFR Part 52; and (3) provide a list of all AP600 technical cooperation agreement participants, including a description of their AP600 1
program work scope and involvement. The NRC is identifying these concerns as an unresolved item. Please provide the above requested information within 30 days of receipt of this letter.
t l
The responses requested by this letter and the enclosed Notice of Nonconformance are not subject to the clearance procedures of the Office of Management and Budget as required j
by the Paperwork Reduction Act of 1980, Public Law No.96-511.
1 in accordance with 10 CFR Part 2.790 of the NRC's " Rules of Practice," a copy of this j
letter and its enclosures will be placed in the NRC's Public Document Room.
i 2
Should you have any questions concerning this inspection, we will be pleased to discuss l
them with you.
Sincerely, I
OrtIGINAL SIGNED BY i
Robert M. Gallo, Chief Specialinspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation Docket No.: 52-003
Enclosures:
- 1. Notice of Nonconformance
- 2. Inspection Report No. 99900404/97-01 l
cc w/encis: See Next Page Distribution:
See attached list DOCUMENT NAME:G:\\McIntyre:\\AP60M-97.RPT To tooelve e copy of this document. indcate in the box: *C* = Copy without enclosures *E' = Copy withgosures *N' = No copy 0FFICE PSIB/ DISP l E HQMB/DRCH l E PSIB/ DISP l E PSIBf0T5P%E 0:DE l
E_
NAME RMcIntyre JPeralta GCwalina RGal l F f., 4 BSheron DATE 04/30/97*
04/.30/.97*
04/30/97*
04/30/97*
05/01/97*
i 0FFICE A:DRPM N
D: DISP E
0:DRCH E
ADT NAME MSlosson FGillespie BBoger TMartin DATE 05/01/97*
05/02/97*
05/01/97*
05/02/97*
~ ~
OFFICIAL RECCLD COPY
N. Liparulo Letter to Nicholas J. Liparulo, Dated: m y 2, 1997 Distribution:
Central Files PDR Docket Files PSIB R/F DISP R/F PDST R/F ACRS (11)
TOuay TKenyon DJackson WHuffman JSebrosky TMartin MSlosson BSheron FGillispie BBoger RLSpessard SBlack l
RGallo l
GCwalina RGramm GBa0 chi TCheng l
l d
i i
i l
l
}
Mr. Nicholas J. Liparulo Docket No.: 52-003 Westinghouse Electric Corporation AP600
)
cc:
Mr. B.A. McIntyre Mr. Ronald Simard, Director 1
Advanced Plant Safety a Licensing Advanced Reactor Programs 4
Westinghouse Electric Corporation Nuclear Energy institute Energy Systerns Buciness Unit 1776 Eye Street, N.W.
?
P.O. Box 355 Suite 300 j
Pittsburgh, PA 15230 Washington, DC 20006 3706
{
t l
Ms. Cindy L. Haag Ms. Lynn Connor Advanced Plant Safety & Licensing Doc-Search associates Westinghouse Electric Corporation Post Office box 34 l
Energy Systems Business Unit Cabin John MD,20818 l
Box 355 Pittsburgh, PA 15230 l
Mr. James E. Quinn, Projects Manager Mr. M.D. Beaumont LMR and SBWR Programs Nuclear and Advanced Technology Division GE Nuclear Energy i
Westinghouse Electric Corporation 175 Curtner Avenue, M/C 165 i
One Montrose Metro San Jose, CA 95125 11921 Rockville Pike Suite 350
)
Rockville, MD 20852 Mr. Robert H. Sucholz GE Nuclear Energy
)
Mr. Sterling Franks 175 Curtner Avenue, M/C 781 U.S. Department of Energy San Jose, CA 95125 NE-50 19901 Gerinantown Road Barton Z. Cowan, Esq.
Germantown, MD 20874 Eckert Seamans Cherin & Mellott 600 Grant Street 42nd Floor Mr. S.M. Modro Pittsburgh, PA 15219 Nuclear Systems Analysis Technologies Lockheed Idaho Technologies Company Post Office Box 1625 Mr. Ed Rodwell, Manager idaho Falls, ID 33415 PWR Design Certification Electric Power Research Institute Mr. Frank A. Ross 3412 Hillview Avenue U.S. Department of Energy, NE-42 Palo Alto, CA 94303 Office of LWR Safety and Technology 19901 Germantown Road Mr. Charles Thompson, Nuclear Engineer Germantown, MD 20874 AP600 Certification U.S. Department of Energy NE-50 Washington, DC 20585
NOTICE OF NONCONFORMANCE Westinghouse Electric Corporation Docket Nos.: 52-003 Pittsburgh, Pennsylvania 99900404 Based on the results of a Nuclear Regulatory Commission (NRC) inspection conducted on April 17,1997, of activities supporting Westinghouse Electric Corporation's AP600 design i
certification, it appears that certain activities were not conducted in accordance with NRC requirements.
A.
Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
WCAP-12600, *AP600 Quality Assurance P.Jgram Plan," Revision 2, dated December 15,1993, Section 16, " Corrective Action," states, in part, " Application of WCAP-8370 to AP600 activities includes the following:
The root cause of significant conditions adverse to quality are determined e
and documented, and the impact of such conditions on completed or related j
items and activities is evaluated."
WCAP 8370, Quality Assurance Plan (OA Topical Report), Revision 12A, dated April 1992, Section 16, " Corrective Action," states, in part, in:
Section 16.0, " General," that conditions adverse to quality such as failures, malfunctions, nonconformances, and out-of control processes (including fai!ure to follow procedures) shall be identified. Thest adverse conditions are also analyzed, documented, and corrected commensurate with their importance to safety.
Section 16.1, " Corrective Action," that personnel performing activities in accordance with this plan identify conditions adverse to quality and suggest, recommend or provide solutions to the conditions as appropriate. For significant conditions adverse to quality, the causes are determined and documented and the impact of such conditions on items and services is evalusted for significant trends and reported to the appropriate level of management.
Section 16.2, " Follow-up," that for corrective action resulting from reports (e.g.,
nonconformance reports, audit reports, computer software error reports, NRC inspection reports, customer audit reports, etc.) quality assurance participates in verifying that appropriate corrective action is documented and implemented.
'f]DjC f Q.Q C
Contrary to the above, Westinghouse:
1.
Did not identify, analyze, document, and correct conditions adverse to quality as required by the AP600 Quality Assurance program. During a July 1994 NRC structural audit of the nuclear island foundation mat, errors were identified in calculations performed by INITEC that resulted in significant re-design of the AP600 foundation basemat. The findings described in the August h,1994, NRC " Summary of Audit of the AP600 Structural l
Design," report were not identified as a condition adverse to quality requiring or receiving quality assurance participation in verifying that appropriate corrective action is documented and implemented.
j 2.
Did not adequately determine and document the root cause of INITEC's basemat calculation errors nor evaluate the impact of such a condition j
j adverse to quality on completed or related INITEC AP600 design deliverables and activities.
(99900404/97-01-01)
B.
Criterion Vil, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50, requires, in part, that measures shall be established I
to assure that purchased material, equipment, and services, whether purchased directly or through contractors or subcontractors conform to the procurement documents.
WCAP-12600, "AP600 Quality Assurance Program Plan," Revision 2, dated December 15,1993, Section 7, " Control of Purchased items and Services," states, in part, " Application of WCAP-8370 to AP600 activities includes, but is not limited to, the following:
The initial qualification and subsequent performance evaluation of suppliers e
to which technicalcooperation agreements [ emphasis added) apply is performed in the same manner as for suppliers of purchased items and services.
The performance of each supplier is evaluated on an annual basis, commensurate with the complexity and importance to safety of items or services provided. The evaluation is documented and includes evidence, based on direct observation of work performed by the supplier, that the supplier's quality assurance program is continuing to operate successfully."
WCAP-8370, Qu41ity Assurance Plan (OA Topical Report), Revision 12A, dated April 1992, Section 7. ' Control of Purchased items and Services," states, in part, in:
Section 7.3, " Supplier Performance Evaluation," that "A formal evaluation of suppliers is performed each year to determine if additional actions such as audits are required during the upcoming year. This evaluation includes a review of some or all of the following: prior quality program audits, supplier surveillance activities,
...results of audits from other sources (customers, ASME, NRC, etc.)if available lemphasis added),...and the suppliers's responsiveness and cooperation in resolving 2-
E
)
quality questions or problems. As a result of this evaluation, suppliers requiring a
{
complete quality program reaudit are identified...Regardless of the results of the evaluation, suppliers are reaudited every three years."
Contrary to the above, Westinghouse did not provide appropriate OA oversight of design activities performed by INITEC. After the basemat calculation errors were identified by the NRC in July 1994, Westinghouse did not evaluate or assess the i
impact of the errors on other work performed by INITEC. Specifically:
1.
vvestinghouse failed to adequately evaluate or assess INITEC's annual performance, as required by WCAP-8370, Part B, Section 7.3, " Supplier i
Performance Evaluation," for a supplier of AP600 design deliverables that had been the subject of an adverse NRC audit finding.
9 j
2.
In its February 1995 triennial audit of INITEC, Westinghouse failed to j
conduct an evaluation of INITEC's response to. Westinghouse's August 3, 1994, letter, and any associated corrective actions taken. The letter to INITEC described the basemat design calculation issues identified by the f
NRC during the July 1994 structural Jesign audit. (99900404/97-01-02) i j
i l
l 4
1 j
l i
}
Please provide a written statement or explanatic'1 to the U.S. Nuclear Regulatory
{
}
Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Chief, Epecial inspection Branch, Division of 1.ispection and Support Programs, Office j
of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of l
Nonconformance" and should include for each nonconformance: (1) a description of the i
1 j
steps that were or will be taken to correct these items; (2) a description of the steps that have or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventative measures were or will be completed.
i 6
Dated at Sockville, Majr land This M day of ricLy _,1997 i
t
(
I :
i b
i U. S. NUCLEAR REGULATORY COMMISSION
' OFFICE OF NUCLEAR REkCTOR REGULATION Report no.:
99900404/97-01 Organization:
Westinghouse Electric Corporation
-i Nuclear and Advanced Technology Division i
Pittsburgh, Pennsylvania 15230
Contact:
Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Activities Nuclear Industry Nuclear steam supply system design, components and Activity; services i
Date:
April 17,1997
)
l inspectors:
Richard P. McIntyre, PSIB/ DISP Juan D. Peralta, HOMB/DRCH Goutam Bagchi, ECGB/DE Diane Jackson, PDST/DRPM Approved:
Gregory C. Cwalina, Chief Vendor Inspection Section Special inspection Branch Division of inspection and Support Programs 37050"T0 M9
1 INSPECTION
SUMMARY
The purpose of the inspection was to evaluate the Westinghouse technical and quality oversight of Empresa Nacional de Ingenieria y Tecnologia, S.A. (INITEC) design activities in general, and to assess Westinghouse's thoroughness in its evaluation and disposition of the audit findings identified in the August 24,1994, NRC " Summary of Audit of the AP600 Structural Design" concerning NRC staff-identified errors in INITEC calculations, as described in Section 3.2.
The inspection bases were:
Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reoulations (10 CFR Part 50).
AP600 SSAR, Revision 11, Section 17.3, " Quality Assurance" WCAP-12600, Revision 2, dated December 1993, "AP600 Quality Assurance Program Plan" During this inspection, two instances where Westinghouse failed to conform to NRC requirements were identified. Also, one unresolved item was identified.
1.1 Nonconformance l
Nonconformance 99900404/97-01-01 was identified and is discussed in Section 3.3 of this report.
Nonconformance 99900404/97-01-02 was identified and is discussed in Section 3.4 of this report.
1.2 Unresolved item Unresolved item 99900404/97-01-03 was identified and is discussed in Section 3.5 of this report.
2 STATUS OF PREVIOUS INSPECTION FINDINGS No previous inspection findings were reviewed during this insp2ction.
1 1
I 3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 AP600 Quality Assurance Proaram Chapter 17 of the AP600 standard safety analysis report (SSAR) describes the Westinghouse Electric Corporation quality assurance (QA) program for the design phase of the AP6 * ; Advancod Light Water Reactor (ALWR) Plant Program.
AP600 SSAR, Revision 11, Section 17.3, " Quality Assurance," states that activities performed prior to March 31,1996, were performed in accordance with the quality assurance plan described in Westinghouse topical report WCAP-8370, " Energy System Business Unit - Power Gene.adon Business Unit, Quality Assurance Plan,"
Revision 12a, ds.ed April 1992. WCAP-8370 applied to all Westinghouse activities affecting quality of items and services supplied to nuclear power plants and establishes Wer..ighouse's compliance with the provisions of Appendix B to 10 CFR 50.
WCAP-12600, "AP600 Quality Assurance Program Plan," dated December 1993, a project-specific QA plan, was developed by Westinghouse to enhance WCAP-8370 in specific areas and to establish additional commitments needed to support the AP600 Design Certification and First-Of-A-Kind (FOAKE) programs. WCAP-12600 establishes the responsibility of the Advance Technology Business Area of the Energy Systems Business Unit for AP600 Design Certification and FOAKE programs and for control of the technicalinterface between Westinghouse and cngineering groups and suppliers providing engineering services under such programs.
Additionally, WCAP-12601, "AP600 Program Operav g Procedures," Revision 13, dated July 8,1994, was developed by Westinghouse to establish requirements and responsibilities for developing, approving, implementing, revipng, and malntaining operating procedures to meet the QA and administrative requirements of the AP600 progra Ti. WCAP-12601 includes a i "AP600 Program Procedure Matrix," currently Revision 15, dated April 4,1995, which identifies the correlation between the Westinghouse commitments to the OA requirements of (1) ANSI /ASME NOA-1,
" Quality Assurance Program Requirements for Nuclear Facilities," 1983 Edition (as endorsed by Regulatory Guide 1.28, Revision 3) and (2) ANSl/ASME NOA-1 1989 Edition through NOA-1b-1991 Addenda, and the corresponding implementing guidance embodied ~in WCAP-9565, " Nuclear and Advanced Technology Division (NATD) Quality Assurance Program" currently Revision 34, dated May 2,1994, and in WCAP-12601. WCAP-9565 governed the implementation of all NATO activities related to areas within the scope of WCAP-8370.
3.1.1 AP600 Desion Certification and FOAKE Proarams Control of Purchased items and Services WCAP-12600, Section 7, " Control of Purchased items and Services," describes the application of WCAP-8370, Part B, Section 7, provisions to AP600 activities and clarifies that the initial qualification and subsequent performance evaluation of 3-i
. ~ ~ - - - - - - -. - - -. - -. - - - - - - -
I suppliers to which technicalcooperation agreements apply temphasis added) is performed in the same manner as for suppliers of purchased items and services.
WCAP-8370, Part B, Section 7.3, Supplier Performance Evaluation," requires, in part, "A formal evaluation of suppliers is performed each year to determine if additional actions such as audits are required during the upcoming year. This evaluation includes a review of some or all of the following: prior quality program audits, supplier surveillance activities, nature and frequency of hardware discrepancies, results of audits from other sources (customers, ASME, NRC, etc.)
[ emphasis added]....." This section also specifies that as a result of this evaluation, suppliers requiring a complete quality program reaudit are identified.
l 3.1.2 AP600 Particioation Proaram Between INITEC and Westinohouse Electric
[
Corooration On March 5,1992, Westinghouse and INITEC signed an agreement under which INITEC would perform engineering, management and execution of certain structural and piping tasks associated with the AP600 Program. The following tasks were identified as INITEC's work scope: (1) Analys.s and Detail Design of Pressurizer Safety and Relief Valve (PSARV) Module, (2) Structural Steel Framing (SSAR Section 3.8.4), (3) Floor Slabs (SSAR Section 3.8.4), (4) Nuclear Island Basemat (SSAR Section 3.8.5), (5) Nuclear Island Shear Walls (SSAR Section 3.8.4), (6) Analysis l
and Detail Design of Piping, and (7) Structural Steel Framing (SSAR Section 3.8.4).
l L
Additionally, the agreement specified that design inputs, methods, required formats and other design information for structural tasks would be provided by Bechtel Power Corporation (Bechtel) and allowed for technical correspondence and interfaces for these tasks to take place directly between INITEC and Bechtel.
in Section 3.0, " Quality Assurance," the anreement specified that INITEC shall establish, implement, and maintain a quakty assurance program meeting the l
requirements of ANSI /ASME NOA-1, "Qualit) Assurance Program Requirements for
.[
Nuclear Facilities" (1986 edition). The agreement also specified that a Quality Assurance Program Plan (OAPP) would be prepared by INITEC and be subject to f
review and approval by Westinghouse prior to performing any quality-related work.
i 3,2 Nuclear Island Basemat Desian - Backaround I
On July 11 through 14,1994, the NRC performed an atviit of the structural design of the AP600 at the Bechtal offices in San Francisco, California. The results of this audit were documented in a letter to Westinghouse dated August 24,1994,
" Summary of Audit of the AP600 Structural Design."
One of the key issues identified during the audit were errors found by the audit team l
in design calculations performed by INITEC Calculation No.1010-CCC-001, Rev. A).
The NRC audit team identified the following coficiencies: (1) errors in shear and flexural rebar assessment, in the use of punching shear formula, and in the use of finite element dimension; (2) no consideration of accident pressure loads, and loads 4
f
1 fmm construction sequence, and (3) out of phase overturning moment from shield and containment buildings.
In its August 2,1994, letter to the NRC, Westinghouse acknowledged its commitment to: (1) perform an independent review of the basemat design calculations, (2) verify the adequacy of INITEC's in-house post-process computer programs used for the foundation mat design, (3) perform sirnplified analyses as appropriate to cormrm the existing design results, and (4) provide the results cf this independent review to the NRC. (This issue was identified t y the NRC in the AP600 DSER as DSEP Open item 3.8.5-21).
3.3 Review of Westinahouse Corrective Actions for July 1994 NRC Structural Audit Findinas a.
Scone The inspectors reviewed Westinghouse's evaluation and disposition of the audit findings identified in the August 24,1994, NRC " Summary of Audit of the AP600 Structural Design" report conceming NRC-identified errors in INITEC calculations, b.
Observations and findinas As indicated above, in its August 2,1994, letter to the staff regarding errors identified in INITEC post-process computer programs used for the AP600 foundation rnat design, Westinghouse made a commitment to conduct an independent review of such calculations. In a letter to INITEC (FOK/IN10181) dated August 3,1994, Westinghouse forwarded: (1) comments presented by an NRC consultant at the July 1994 meeting, (2) additional interpretation and comments by Westinghouse technical staff, and (3) a copy of the August 2,1994, letter to NRC. Westinghouse also stated that a Bechtel employee had been selected to perform the independent review and the scope of basemat review was attached to the letter (Attachment 4).
The inspectors reviewed the independent review report, " Independent Review of AP600 Nuclear Island Basemat Design," dated November 11,1994, performed by Bechtel to address the basemat calculation issues identified by the staff. The inspectors noted that in Section 6.0, " Summary and Recommendations," of the report, Bechtel made several observations and recommendations related to uncertainties in the INITEC calculation that required further evaluation or study.
The inspectors reviewed an INITEC letter to Westinghouse (INI/FOK0175), dated February 15,1995,in which INITEC provided its response to address the root causes of the quality issue relative to the Nuclear Island Basemat Calculation, identified by NRC in its July 1994 structural design audit, as well as the measures taken by INITEC in order to avoid the occurrence of similar situations during the performance of present and future structural analysis. The inspectors noted that INITEC's response had been formulated alrnost contemporaneously with the triennial audit being conducted by Westinghouse on February 20 through 22,1995, at INITEC's facilities. Yet Westinghouse's triennial audit report (OLA/IN10007) does not provide any evidence that INITEC had identified this issue as a condition adverse to quality requiring root cause determination or corrective actions in accordance with INITEC's Westinghouse-approved QAPP (see Section 3.4.a.).
During the inspection, the inspectors inquired as to whether Westinghouse had initiated any root cause determinations or corrective actions, as required by WCAP-12600, Section 16, " Corrective Action," since this issue was first identified by the NRC in July / August 1994 or whetner Westinghouse had formally accepted or rejected INITEC's proposed corrective actions identified in INITEC's February 1995 letter. Weainghouse representatives responded that, as of April 17,1997, this issue had not been identified as a condition adverse to quality requiring a root cause determination or corrective actions in accordance with WCAP-12600 nor had Westinghouse formally responded to INITEC's February 1995 letter.
c.
Conclusions Based on the above, the inspectors concluded that Westinghouse: (1) failed to identify or recognize the NRC-identified basemat design deficiencies as a condition adverse to quality requiring a root cause d aermination or corrective actions in accordance with WCAP-12600, Section 16, and (2) failed to determine and evaluate the impact of such design deficiencies on completed or related INITEC AP600 design deliverables and activities. This issue was identified as Nonconformance 99900404/97-01-01.
3.4 Review of Westinohouse Oversicht of INITEC AP600 Desian Activities a.
Scope The inspectors reviewed Westinghouse technical and quality oversight of INITEC design activities in general, including the documents describing the contractual agreements between Westinghouse, INITEC and Bechtel for AP600 program design activities.
L.
Observations and findinos Westinghouse appropriately specified all technical and quality assurance requirements consistent with WCAP-12600. As required by the agreement signed on March 5,1992, INITEC provided a OAPP for Westinghouse's review and approval.
As described in Section 3.3 above, in September 1994, Westinghouse contracted the services of Bechtel for an independent review of INITEC's analysis and design methodology for the nuclear island basemat. The results of Bechtel's independent review were documented and made available to Westinghouse in a report dated November 11,1994
.s.
. - ~. -. - _... -
N~
l t
r i
i Although Westinghouse had identified the submittal of this independent revnew j
report as a commitment in its August 2,1994, response to the NRC, the inspectors
{
1 were informed that a submittal of the report on the AP600 docket was still i
outstanding. No explanation was given as to why this report had not yet been made available for NRC review.
d The inspectors learned that on August 3,1994, Westinghouse had sent a letter to l
]
INITEC (FOK/INIO181) requesting that INITEC provide its response to the NRC audit i
findings (see Section 3.3.a.). However, it appeared that Westinghouse did not consider the results of the NRC structural audit findings and concerns in its January 1995 annual review of INITEC's performance.
i i
Additionally, the inspectors reviewed Westinghouse's Audit Report OLA/INIDOO7, I
dated March 20,1995, that documented a t:iennial audit conducted on February 20 through 22,1995, at INITEC's facili'Ns in Madrid, Spain. Upon reviewing the report, j
the inspectors found that: (1) an *
- tion of INITEC's response to Westinghouse's j
August 3,1994, letter had not l'
.ncluded in the audit scope, and (2) the audit 3
i did not identify any evidence to suggest that INITEC had initiated any internal root cause analysis, and evaluation. Further, the inspectors determined that no corrective i
actions had been formally identified by INITEC's OA organization to determine the cause, and document the impact of the design deficiencies identified in Westinghouse's August 3,1994, letter, on INITEC's AP600 design deliverables.
Finally, the inspectors questioned Westinghouse's conclusion, in its March 22,1995, i
letter to INITEC, " West.'nghouse AP600 Audit WES-95-211," that "lNITEC Design j
Quality Assurance Program and implementing procedures meet the applicable NOA-1 l
requiraments for INITEC's AP600 work," iri light of the fact that the audit report identified 10 findings of programmatic deficiencies in INITEC's implementation of its j
QAPP.
i j
c.
Conclusions Based on the above, the inspectors concluded that Westinghouse's (1) failed to j
adequately evaluate or assess INITEC's performance, as required by WCAP-12600, i
for a supplier of AP600 design deliverables that had been the subject of an adverse
[
NRC audit finding, and (2) failed to conduct an evaluation of INITEC's response to j
Westinghouse's August 3,1994, letter, and any associated corrective actions taken.
This issue was identified as Nonconformance 99900404/97-01-02.
3.5 Westinahouse Oversicht of AP600 Desian Activities Based on the nonconformances identified above, the NRC is concerned that these quality assurance deficiencies may have introduced a level of uncertainty on the j
acceptability of design deliverables provided by AP600 technical cooperation i
agreement participants. Of particular cor.cem to the NRC, is Westinghouse's failure to recognize and appropriately address a condition adverse to quality, requiring a root i
cause evaluation and determination and appropriate corrective actions, even when i
i i
4 ;
,m m
such a condition was identified by an NRC audit and resulted in re-design of the AP600 foundation basemat.
Westinghouse's failure to address this design and quality assurance program deficiency in a timely manner has raised the issue of whether this is an isolated case and that other design deliverables provided by AP600 technical cooperation agreement participants do in fact possess the level of integrity in design verification and quality assurance necessary to satisfy the design certification provisions of 10 CFR Part 52. This issue was identified as Unresolved item 99900404/97-01-03.
3.6 Entrance and Exit Meetinos Since this was a one-day inspection, the entrance and exit meetings were both held on April 17,1997. In the entrance meeting the NRC inspectors discussed the scope of the inspection and outlined the areas to be inspected. In the exit meeting the inspectors discussed the inspection findings and unresolved item.
4 PERSONNEL CONTACTED Westinahouse Electric Corooration David Alsing, AP600 Quality Systems Manager Ken Kloes, Projects Quality Assurance Engineer Robert Tupper, Advanced Technology, Project Engineer Richard Orr, AP600 Structures Advisory Engineer Narenda Prasad, Engineering Technology Department, Fellow Engineer Donald Lindgren, AP600 Licensing ITEMS OPENED. CLOSED, AND DISCUSSED Opened 99900404/97-01-01 NON inaderquate corrective action 99900404/97-01-02 NON inadequate quality and technical oversight of INITEC 99900404/97-01-03 URI acceptability of APSOO design deliverables 8