ML20197B303
| ML20197B303 | |
| Person / Time | |
|---|---|
| Issue date: | 05/08/1986 |
| From: | Jocelyn Craig, Milano P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20197B289 | List: |
| References | |
| REF-QA-99900521 NUDOCS 8605120504 | |
| Download: ML20197B303 (6) | |
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ORGANIZATION: BECHTEL - WESTERN POWER DIVISION SAN FRANCISCO, CALIFORNIA REPORT INSPECTION INSPECTION NO -
Q99005?1/86-01 DATF- 01/?1-?3/96
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' CORRESPONDENCE ADDRESS:
Bechtel Power Corporation San Francisco Area Office ATTN:
Mr. L. G. Hinkleman Vice President and General Manager 12400 East Imperial Highway-Norwalk, CA 90650 ORGANIZATIONAL CONTACT:
Mr. P. Lilligh TE! rP90Nr N!!MRFD-41C_7AD 4E?1 NUCLEAR INDUSTRY ACTIVITY: This area office provides principal architect -
engineering services for Hope Crees and Limerick Unit 2.
Additionally, project management and general service contracts are performed.
ASSIGNED INSPECTOR: 7. D.N 4 - t s - s c.
P. D. Milano, Special Projects Inspection Section Date (SPIS)
OTHER INSPECTOR (S): Richard P. McIntyre, SPIS APPROVED BY:
8'8'N gJohhW.Craig, Chief,SPIS,'VendorProgramBranch Date INSPECTION BASES AND SCOPE:
A.
BASES:
SCOPE:
Followup on allegations of quality assurance training effectiveness and incorrect pipe support loading. Also, review of certification of ASME III Code Certifying Personnel.
PLANT SITE APPLICABILITY:
Peach Bottom Units 2 and 3, (50-277 and 278);
Diablo Canyon Units 1 and 2, (50-275 and 323).
8605120504 860509 PDR GA999 EECDECH 99900521 PDR
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ORGANIZATION: BECHTEL - WESTERN POWER DIVISION SAN FRANCISCO, CALIFORNIA REPORT INSPECTION Nn - o9900E?1/86-01 RESULTS:
PAGE 2 of 6 A.
Violations None.
B.
Nonconformances None.
C.
Unresolved Items A review had been conducted by Bechtel to determine if the pipe support loading conditions utilized on the Peach Bottom 2 and 3 project was adequate. This review was to verify that all loadings could be buunded by the Upset and Faulted conditions.
Formal documentation of the conclu-sions was requested during the inspection but was not available. Thus, it remains as an Open Item (86-01-01).
D.
Status of Previous Inspection Findinos 1.
(Closed) Nonconformance (A/84-02):
The documentation for the Bechtel computer code "BSAP" (CE 800) does not include a Theoretical Manual in that the available User's Guide / Theoretical Manual does not contain the required theoretical information for it to be a Theoretical Manual.
A new control form dated 8/20/84 has been added as a cover sheet of the User's Guide which references to an extended theoretical manual.
This item is closed.
2.
(Closed) Nanconformance (B/84-02): The computer program " FLUSH" (CE 988) has been in use since 1980 without meeting the documentation requirements. The " FLUSH" User's Manual and Theoretical Manual were not available in the Central Information Service Library. A User's Manual is presently being prepared since the only user information that has been available was that contained in the interactive portion of the program.
A complete User's Manual for the " FLUSH" program has been released by Control Data Corporation in July, 1984 and is located in the Bechtel Library.
This item is closed.
3.
(Closed) Nonconformance (C/84-02):
No formal training program or records of training exist for Computer Code Users prior to performing Q-list design activities utilizing computer programs.
ORGANIZATION:
BECHTEL - WESTERN POWER DIVISION SAN FRANCISCO, CALIFORNIA REPORT INSPECTION Nn - 999005?1/86-01 RESULTS:
PAGE 3 of 6 Changes have been made to the Bechtel procedures for design control and verification to ensure that supervisors ensure that personnel are knowledgable of the programs being utilized. This item is closed.
4.
(Closed) Nonconformance (D/84-02):
No error records were located or referenced in the master copy of the "BSAP" computer program User Manual in the Central Information Services Library, although errors have been identified for this program.
Bechtel Information Services has modified the Program Error Notification Procedures to address the requirements for retention of error notices. This item is closed.
5.
(Closed) Nonconformance (D/84-02):
Bechtel Inter-0ffice Memo (IOM)
Number EMF 7414, changes the disposition in the " Changed Approved" section of Startup Change Request SCR Number E-028 from indicating approval to rejection rather than only making an administrative modification to the remarks section.
The subject IOM was voided since it exceeded the administrative limits per Engineering Department Procedure EDP-4.62.
The intent of the EDP has been clarified with appropriate Project supervisors. This item is closed.
6.
(Closed) Nonconformance (E/84-02): Neither Engineering Department Procedure EDP-4.62, Field Change Request / Field Change Notice, Revision 6, dated March 12, 1984 nor Enqineering Department Project Instruction EDPI 4.52.1, Hope Creek Generating Station Field Change Request / Field Change Notice, Revision 8, dated April 26, 1984, require the review and approval by the Project Quality Assurance Engineer of FCRs against Q-listed specifications.
San Francisco Area Office EDP-4.62 has been revised to ensure that PQAE review is conducted for those FCRs which authorize a one-time deviation and do not cause the base document to change. This item is closed.
E.
Other Findings and Comments 1.
Quality Assurance Training The area of the Bechtel Quality Assurance Training was reviewed in order to followup on allegations made in this area. The allegations centered around the possible ineffectiveness of the training given
ORGANIZATION: BECHTEL - WESTERN POWER DIVISION SAN FRANCISCO, CALIFORNIA REPORT INSPECTION P!n. - 999005?1/86 01 RESULTS:
PAGE 4 of 6 to foreign nationals working in the Bechtel Western Power Division Office under contract from a Bechtel subsidiary in Taiwan, Pacific Engineers and Construction Limited.
Since the training was presented in English, the ability of these individuals to satisfactorily complete the training was questioned.
Since the individuals had returned to their parent organization in Taiwan, the inspectors could not conduct interviews with these individuals.
Thus, the reviews and interviews conducted during the inspection were performed to obtain enough subjective and objective information to determine whether or not the allegation was valid.
Personnel records were obtained from Bechtel such that a sample of the training given to contract engineers could be reviewed.
For each of the selected engineers, evidence in the form of records of training was provided. Additionally, the scope of the QA training program was reviewed.
Bechtel utilizes a second tier of quality assurance training which is project unique for Project Engineers and Group Supervisors.
Employees responsible to these individuals receive "on-the-job" training commensurate with their job responsibilities.
Since this form of training per Engineering Department Procedure EDP-5.34 is neither formal nor documented, it was not possible to directly deter-mine the extent or quality of this first tier of training. The effec-tiveness of this training can only be subjectively determined through the quality of the work that these employees performed. Based on interviews with the applicable engineering supervisors, the quality of the work performed was acceptable and did not indicate a lack of training. This was also reflected with the results of quality audits conducted by Bechtel during this period.
Since many of the employees in question were utilized on the Diablo Canyon Project, interviews with personnel responsible for the training on this project were conducted. The project unique training was coordinated and performed by the Licensee, Pacific Gas and Electric (PG&E).
Neither the PG&E personnel involved in this project nor the available training records indicated a lack of effectiveness of QA training provided to the Pacific Engineers and Construction Limited personnel who worked on the Diablo Canyon Project.
This allegation was not substantiated.
ORGANIZATION: BECHTEL - WESTERN POWER DIVISION SAN FRANCISCO, CALIFORNIA REPORT INSPECTION NO.-
99900521/86-01 PESULTS:
DAGE 5 of 6 2.
Pipe Support Design loading Conditions The alleger stated that pipe support design calculations for Peach Bottom Units 2 and 3 existed where the worst desien loading condition was not always used when designing pipe supports and accompanying components. Specifically, the alleger stated that in some instances the worst case condition of either Emergency Loads or Faulted Loads were not used. This condition was identified as part of the Peach Bottom Pipe Support As-Built Reconciliation Program. The allegation, however, was that this problem with pipe support loading calculations was being supressed.
The inspectors interviewed the engineer who was alleged to have made statements concerning the suppression of the problem. This indi-vidual stated that there were not any emergency loading conditions and that there could possibly be cases where the worst case loading conditions were not considered. The individual was not aware of any times where the Pipe Stress Group was asked to recalculate the loads.
However, the engineer stated that no individuals had attempted or were requiring anyone to suppress the concern.
The inspectors interviewed Bechtel Pipe Support Engineering personnel who were involved in an independent audit of the Peach Bottom Project.
They stated that within the last six months questions arose within Bechtel as to whether the pipe supports and components were designed to the correct loading condition. The potential concern was reviewed and evaluated for validity as part of the Peach Bottom independent audit.
Bechtel stated that their review determined that all loading conditions are covered under the Upset and Faulted Conditions.
They also stated that the original design basis for pipe support components was that the faulted condition enveloped the Emergency Condition and therefore was the governing loading condition.
Bechtel stated they determined this concern was not a problem and recently closed the issue.
The inspectors requested the documentation associated with the evaluation of this potential concern and the final justification as to why they consider it not to be a problem.
Bechtel stated i
they did not have anything formally documented at this time. However, Bechtel made a commitment to prepare the appropriate documentation.
This area will be reviewed during a future inspection.
(Unresolved Item No. 86-01-01.)
I ORGANIZATION:
BECHTEL - WESTERN POWER DIVISION SAN FRANCISCO, CALIFORNIA REPORT INSPECTION NO.-
99900521/86-01 RESULTS:
) AGE 6 of 6 3.
Certification of Code Certify'ng Personnel The documentation required by Bechtel Engineering Department Procedure EDP-4.54, Rev. O, Qualification of Personnel Authorized to perform ASME III Code Certifying Activities, and ANSI Standard N626.3-1984, Qualifications and Duties of Personnel Engaged in ASME Boiler and Pressure Vessel Code,Section III, Divisions 1 and 2, Certifying Activities, was reviewed. A sample of documentation (for the Mechanical Plant Design Group) in the files of the Chief Engineer and Personnel Department was inspected. While the documentation supported the selection of the personnel for Code Certification, there were some administrative deficiencies.
In the Chief Engineer files, several of the files did not indicate the state registry number and expiration dates for the Professional Engineer licenses. ANSI N626.3, Section 2, Qualifications, requires that an engineer have four years of varied application experience of which at least two years is to be in the specialty field for which the certifying activities will be performed. The files, while showing the individual's major work history, were limited in defining the accomplishment of the specialty field experience. This was particu-larly evident in the area of individuals certifying Overpressure Protection Reports. The PE in this specialty must have experience in plant operation and safety control as well as system design.
The Personnel files generally contained more information since EDP-4.54 requires the records for certification to be maintained in this location. However, similar clarification on specific field experience was lacking, but to a lesser degree. Cases also existed where PE registry information was not up to date.
Finally, evidence of continuing professional development and Code knowledge was not documented in that courses and seminars attended were not listed.
Bechtel stated that evidence of this training will be included as it takes place in the future.