ML20151S340
| ML20151S340 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1988 |
| From: | Jeffrey Jacobson, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20151S315 | List: |
| References | |
| REF-QA-99900519 NUDOCS 8808150164 | |
| Download: ML20151S340 (8) | |
Text
..
ORGANIZATION: PlCHTEL EASHRN POWER COMPANY GAITHERSBRUG, MARYLAND REPORT INSPECTION INSPECTION NO.:
99900519/88-01 DATES: 04/11-13/88 ON-SITE HOURS:
40 CORRESPONDENCE ADDRESS:
Bechtel Eastern Power Company ATTN: Mr. S. A. Bernsen
~'
Manager of Quality Assurance 15740 Shody Grove Road Gaithersburg, Maryland 20877-1454 ORGAN!ZATIONAL CONTACT:
Dinesh Kansal TELEPHONE NUMBER:
301-258-3777 NUCLEAR INDUSTRY ACTIVITY:
Provides extensive engineering services to various nuclear utilities.
7/"/ff ASSIGNED INSPECTOR:
a m
J. B. /a o,' Special' Projects Inspection Date Sectio (S 5)
OTHERINSPECTOR(S):
Robert L. Pettis, Jr., SPIS APPROVED BY:
_ (
M
~?f8f%
grU.Potapovs, Chief,SPIS,VeEdorInspectionBranch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B ano 10 CFR Part 21.
B.
SCOPE:
This inspection was conducted to review recent engineering evaluations performed for Alabama Power Company eno to review the handling of computer code error notifications, in addition, a brief review was conducted of engineering evaluations that were recently performed for various other utilities.
PLANT SITE APPLICABILITY:
Farley 1/2(50-348/364).
h$O b0 99900519
a ORGANIZATION: BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND REPORT INSPECTION N0.:
99900519/88-01 RESULTS:
PAGE 2 of 8 A.
VIOLATIONS:
None.
B.
NONCONFORMANCES:
1.
Contrary to the requirements set forth in Bechtel Power Corporation procedure EDP 4.38 Revision 1, dated November 30,1984, "Computer Program Error Reporting ano Corrective Action," specifically Section 6.0, "Notification to Users and Others," the Bechtel computer code sponsor for the GT STRUDL computer program failed to initate the error reporting process which promptly advises Bechtel users of GT STRUDL, as registered viith Bechtel's Central Information Services Library, and appropriate chief engineers of these errors.
(88-01-01)
C.
UNRESOLVED ITEMS:
None.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
None.
E.
OTHER FINDINGS AND COMMENTS:
1.
Review of Bechtel evaluation of suitability for use of 480 volt U.L.
rated breakers in the Farley Nuclear Plants 600 volt motor control centers.
As the architect / engineer for the Farley Nuclear Plant, Bechtel was asked to evaluate the acceptobility of 204 molded case circuit breakers procured by Alabama Power Company for use in safety-related motor control centers at the Farley Plant.
These breakers were the subject of recent enforcement action takca against Alabama Power Company by the NRC as described in W.RC Inspection Report No. 50-348, 364/87-11.
Basically, the violation concerried the use of 480 volt U.L. rated breakers in Farley's 600 volt motor control centers.
Although documentation existed suggesting that these breakers are dCCeptoble for use in 600 volt applications, no testing or documen-tation had been ubtained that would establish an interrupting rating at 600 volts for the subject breakers. The original Bechtel specifi-cation for the procurement of the motor control centers required the breakers be able to interrupt 18,000 amps rms symmetrical at 600 volts.
ORGANIZATION: BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/88-01 RESULTS:
pAGE 3 of 8 In Alabamo Power's response to the subject violation, they-stated that their architect / engineer (Bechtel) concluded that there was reasonable assurance that the subject breakers would perfonn their intended function when used in 600 volt applications.
During this inspection, Bechtel was questioned concerning the basis for these conclusions. Specifically, Bechtel was asked how the interrupting of 18,000 amps at 600 volts could be ensured. Bechtel stated that they felt that documentation exists which would lead one to believe that the 480 volt rated breakers are the same as the ones that were previously rated at 600 volts.
It was pointed out by the NRC inspector that this infonnation was in the form of two second hand letters from a commercial grade vendor and is not an adequate basis for providing acceptability of the subject breakers.
Specifically, the two letters were from Siemens (the breaker manufacturer) to Satin American Corporation (the supplier of the breakers to Alabama Power). The first letter dated August 19, 1986 stated that the commercial grade breakers built today with the 480 volt rating are the same as those produced years ago with the 600 volt rating. The second letter dated June 3, 1987 objected to the use of the previous August 19, 1986 letter as a basis for inferring it would be proper to use any 480 volt labeled breakers at a nuclear plant. The letters are at best confusing and seem to conflict with one another.
Siemens (the manufacturer) has apparently not certified these breakers as being acceptable for 600 volt applications for use in a nuclear plant.
To use the Siemens letters as a basis for accepta-bility is inappropriate.
In addition to the letters, Bechtel provided an analysis which showed that should the subject breakers fail to interrupt the rated current the plant could still reach a safe shutdown condition.
This analysis assumes apparently without basis that should the subject breaker fail, damage would be limited to one train of safety equip-ment.
Also, the fact that the plant can be brought to safe shutdown with redundant circuits is inadequate basis for allowing the installation of a component.
In summary, the Bechtel stctement to Alabama Power that the subject breakers would be suitable for use in 600 volt safety-related applications at the Farley nuclear plant is not adequately supported.
ORGANIZATION: BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/88-01 RESULTS:
3 AGE 4 of 8 2.
Review of EQ work for the Farley plant.
~
A brief review was conducted of the Bechtel work recently performed in connection with the environmental qualification program at the Farley plant.
A recently developed production change notice B-88-1-4984, Revision 2 written to replace Raychem/ Chico seals on Namco EA-180 limit switches with environmentally qualified EC 210 Namco seals was reviewed by the NRC inspector.
The reviewed docu-ment provided adequate guidance for performance of this change out.
The inspector also reviewed an investigative report concerning containment air cooler nozzle loads.
The report concluded that the operation of the air coolers would not be required for mitigating worst case LOCA or MSLB conditions.
No deficiencies were noted with this analysis.
3.
Review of work performed for the Davis Besse Nuclear Plant.
Two engineering packages generated by Bechtel for the Davis Besse Nuclear Plant were reviewed by the inspector.
The first package, Design Modification 87-1198 concerned tha replacement of two auxilliary feedwater motor operated valves with two auxilliary feedwater valves of a different type and fitted with different motor actuators. The inspector verified that consideration for degraded voltage of 75% was used in the sizing of the new actuators. Also, due to the fact the new valves have an increased stroke time (from 10 to 30 seconds), the temperature and pressure transients used in environmental qualification needed to be recalculated.
The inspector verified that Bechtel properly considered the effects of the increased stroke times on the temperature and pressure transients, that the change was negligable, and that the corresponding curves need not be changed.
Facility Change Request 86-432 concerning the removal of the Safety Features Actuation Signal from make-up discharge isolation valves MU 6421 and MV 6422 and the addition of throttling capability to MU 6419 was reviewed by the inspector. The electrical schematic for accomplishing this change was also reviewed.
The throttling capability was achieved by celeting the seal-in contact circuit to MU 6419. No deficiencies were identified with this facility change request.
ORGANIZATION:
BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/88-01 RESULTS:
PAGE 5 of 8 4.
Review of work performed for the Hatch Nuclear Plant.
The inspector reviewed three work packages recently completed by Bechtel for the Hatch Nuclear Plant. Work package 86-94 contained instructions for replacing pigtail leads on Volcor and Target Rock solenoid valves with high temperature environmentally qualified silicon wire. The purchase requisition for this wire was also reviewed.
No deficiencies were noted with this Work package.
Work package 86-106 concerned the installation of Raychem/ Scotchcast seals on environmentally qualified solenoid valves.
The work package also contained instructions for the installation of ?.wo terminal boxes near the solenoid valves.
No deficiencies wera noted with this work package.
Work package 85-094 was written to incorporate setpcir.i. changes tr.to appropriate documents as a result of a transmitter changc out.
No deficiencies were noted.
5.
Review of 10 CFR Part 21 Program.
A brief review was conducted of Bechtel's program for reporting of defects as required by 10 CFR Part 21.
Bechtel procecure EDP-4.66, Revision 5, "Reporting of Deficiencies, or Defects and/or Noncom-pliances to the Nuclear Regulatory Comission" is the applicable Bechtel procedure for 10 CFR Part 21 reporting.
The inspector reviewed Part 21 log books from both the Farley and the Davis Besse projects.
The Forley log book contained entries for three potentially reportable items. The items had been evaluated and determined to be non-reportable.
The Davis Besse log contained eight entries with two having been determined to be non-reportable and the other six having been reported to the NRC via Toledo Edison. No deficiencies were noted in this area.
6.
Computer Program Error Reporting A review was conoucted to determine the adequacy and implementation of Bechtel's system utilized for the control and processing of computer program error reports received by Bechtel from outside suppliers (Service Bureaus).
The controlling procedure within this area is Bechtel Engineering Department Procedure (EDP) 4.38, Revision 1, "Computer Program Error Reporting and Corrective Action," dated November 30, 1984, specifi-cally Section 5.0 through 8.0 which outline the responsibilities of
V ORGANIZATION:
BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND I
~
REFORT INSPECTION NO.: 99900519/88-01 RESULTS:
PW ^ d 0 the codesponsorwithrespecttoerroranalysis,nol.ification tc corrective action. Section 6.0, "Notification To Users ant equires in Section 6.1 that the code sponsor initiate the 3rting process, which promptly advises users of the comi
, ram registered with the Bechtel Central Information Serv:
.orary (CISL) in San Francisco, and the appropriate chief engineers of class two and three errors.
Class two errors are defined as oroducing results which are obviously meaningless or conspicuously o'etectable, while class three errors produce inaccurate results which could be interpreted as valid. Class one errors have no effect on the results. The sponsor is then required to complete a Computer Program Error Notification form which is sent to the CISL for distribution to those individuals listed for the affected prcgram.
Correction of errors in outside developed and controlled programs and docementation is required to be monitored by the sponsor for compliance with contractual agreements. The cognizant Bechtel chief engineer is then required to issue a problem investigation request, upon notification of a class three error, requiring follow-up action by each project discipline group supervisor to investigate and report their finaings and any action taken to correct the problems to the project engineer.
Documentation of the disposition of each error notice is maintained by the discipline group supervisor in the pro,iect files.
Final acceptance or rejection of the results is made by the chief engineer.
Program users then determine if past and present final design calcula-tions are af fected by those specific errors and take the appropriate action.
The sponsor is required to notify the CISL when program errors have been corrected.
During the inspection, the inspectors reviewea computer code error reporting in conjunction with the Georgia Tech STRUDL computer program supplied to Bechtel by the Control Data Corporation (CDC).
Georgia Institute of Technology (GT) notified the NRC on November 24, 1987 of an error involving the torsional constant for structural tubing which had a significant effect on smaller tube sections.
In one case, the variation calculated was 61% lower than tee original value.
This error may cause a redistribution of force within certain structural models and may also affect dynamic analysis results due to changes in structure stiffness.
This error was initially identified by GT and was sent to GT customers on August 31, 1987.
CDC then classified the error (STR0211) as a Severity Level 1 error which indicates the computer program would result in incorrect answers.
GT stated that this error had been in the program since it's inception, estimated around the 1972 timeframe.
ORGANIZATION:
BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND REPORT INSPECTION N0.-
99900519/88-01 RESULTS:
PAGE 7 of 8 A review of the Bechtel files indicated they did not contaI~n all the error notices sent them by CDC.
A CDC letter, dated October 8, 1987, transmitted an error notification log which indicated Bechtel's receipt and acknowledgement (signed by the cognizant code sponsor) of GT STRUDL error notices during the period April 16, 1984 through December 16, 1987.
Although CDC issued approximately 75 individual error notices on GT STRUDL during this same period (identified as STR0142 through 0218), a review of the Bechtel files identified only 22 were received during the same period, despite positive acknowledge-ment by the Bechtel code sponsor.
The NRC inspector attempted to verify Bechtel's compliance to EDP 4.38 for the error notices in the possession of the GT STRUDL code sponsor, who was located in the Gaithersburg office.
This review indicated that the code sponsor failed to evaluate error notices sent him by CDC from approximately January 1985 to the present, based on a belief that the program had never been used by any of the Bechtel offices. This belief was later confirmed in writing by several Bechtel projects engineers in May 1987 for the following projects within the Bechtel Eastern Power Corporations responsibilty:
Hatch, Calvert Cliffs, Pilgrim, Farley, Grand Gulf, Wolf Creek, Davis Besse, Turkej Roint, and Three Mile Island. A simil6r letter was also received from Bechtel's Western Power Corporstions project engineer in December,1987 also confirming that GT STRUDL had not been used in the final de:ign calculations and as a result would have no affect on their projects.
However, preliminary information obtained by Bechtel during the inspection indicated possible GT STRUDL usage during the February-March 1986 time frame.
In addition, information was obtained from the CISL in San Francisco which inoicated several Bechtel employees were named to receive GT STRUDL error notices during the January 1985 time frame, which would indicate possible program usage.
It was noted that the employees identified received GT STRUDL Users Manuals during the period l
August 15, 1983 through July 27, 1984, and were based in the San l
Francisco, Gaithersburg, and Houston offices of Bechtel during this period.
l A review of purchase order no. DS8-3-30469, dated March 29, 1983, (with the last amendement dated March 28,1988), indicated that l
Bechtel imposed error reporting, corrective action, and the require-i ments of 10 CFR Part 21 on CDC under the Special Terms and Conditions l
Section.
Exhibit 2, Attachment 1, "Application Sof tware Program List" l
further specified that GT STRUDL be classified as a validated applica-J
ORGANIZAT'rh:
BECHTEL EASTERN POWER COMPANY GAITHERSBURG, MARYLAND REPORT INSPECTION NO.: 99900519/88-01 RESULTS:
PAGE 8 of 8
~'
tions software, which is defined in EDP 4.36 as software requiring full documentation and verification by CDC. Within this area of the inspection, nonconformance (88-01-01) was identified.
F.
EXIT MEETING:
At the conclusion of the inspection, an exit meeting was held with the Bechtel staff.
The following people were in attendance.
Bechtel D. C. Kansal, Deputy QA Manager T. V. Sarma, QA Manager Audits T. E. Johnson, Chief Civil E. W. Thomas, Assistant Chief Civil G. H. Goddard, Civil Staff Engineer W. C. Lowery, Project QA Engineer, Davis Besse A. Herrera, Assistant Chief, Engineering QE J. W. Brothers, Chief, Planning & QE J. E. Love, Assistant PE, Farley A. J. Diperna, Farley CS/ Supervisor P. K. Dadlani, Sr. QA Engineer B. L. Meyers, Manager of Engineering S. A. Bernsen, Manager of QA R. H. Stewart, APL, Project Engineer K. C. Gandhi, Bechtel Project Engineer V. Marathe, Bechtel, Project Engineer, Davis Besse R. L. Castleberry, B2chtel Chief Elect /CS W. C. Gund, Project QA Engincer B. Henry, Bechtel Sr. Vice President NRC R. L. Pettis, Jr.
J. B. Jacobson