ML20212G068
| ML20212G068 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1986 |
| From: | Jocelyn Craig, Robert Pettis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20212G042 | List: |
| References | |
| REF-QA-99900505 NUDOCS 8701120261 | |
| Download: ML20212G068 (23) | |
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ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION INSPECTION NO.: 99900505/86-01 DATES: 8/11-15/86 ON-SITE HOURS: 108 CORRESPONDENCE ADDRESS: Ebasco Services Incorporated ATTN: Mr. Charles R. Healy Director, Quality Assurance Two World Trade Center New York, New York 10048 f
ORGANIZATIONAL CONTACT: Mr. Herman J. Kunis, Jr., QA Engineering TELEPHONE NUMBER: (201) 460-6345 NUCLEAR INDUSTRY ACTIVITY: Major projects include: Shearon Harris Units 1 and 2; South Texas Project Units 1 and 2 (Constructor); and Comanche Peak Units 1 and 2 (cable tray and conduit support effort).
A A > A .a r > . i ASSIGNED INSPECTOR: -_h l - V>A442, d. [2-[30/5 R. 1. Pettis, Jr., Special Projects Inspection Date Section (SPIS) s OTHERINSPECTOR():]R.P.McIntyre,SPIS
(. C. L ,S S APPROVED BY:
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- bnW.Craig, Chief,SPIS,VyorProgramBranch Date l
INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Parts 21 and 50 Appendix B, Ebasco Topical Report ETR-1001, and Ebasco prepared Comanche Peak Topical Report ETR-1001.
B. SCOPE: Status of previous inspection findings, procurement process, l design control, indoctrination and training of personnel, audits and computer program error reporting, and evaluation with respect to Ebasco's cable tray and conduit support design verification efforts on Comanche Peak Units 1 and 2.
l PLANT SITE APPLICABILITY: Conanche Peak Units 1 and 2 (50-445/446).
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. ORGAhlZATION: EBASCO SERVICES 1NCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/86-01 RESULTS:
PAGE 2 of 11 BACKGROUND General g On March 12, 1984, the U.S. Nuclear Regulatory Commission's (NRC) Executive Director for Operations established a program to ensure that technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities would be addressed in a coordinated and integrated manner by the NRC staff.
As a means of e.xecutin its assigned responsibilities, the NRC formed a Technical Review Team (TRT)g .
The TRT initiated a series of onsite inspections and evaluations in July 1984, and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report (NUREG-0797, " Safety Evaluation Report Related to the Operation of the CPSES, Units 1 and 2," Supplements 7-11).
In response to the concerns and issues identified by the TRT, Texas Utilities Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) to addre various construction and design issues. The CPRT Program Plan indica.tes that all cable tray supports in both units will be "as built verified" by- the CPSES personnel and " design verified" by both the Ebasco Services and Impell7 Corporation. ,
TUEC has also developed a program to review conduit supports.
Under this program, TUEC has retained Ebasco Services to perforrthe design verification for all Unit 2 conduit supports. The design verification of a sample of Unit 1 and common conduit supports selected in accordance with Appendix D of the CPRT Program Plan will also be performed by Ebasco.
Cable Tray and Conduit Supports TUEC will designs have 100 percent verification reviews of the cable tray support performed.
performed by Ebasco. All Unit 2 analysis / design verification work will be In addition, a CPRT third-party overview of this effort is being condu by the TERA Corporation to provide assurance that the objectives of the plan in the cable tray and conduit support area are being achieved. This program includes:
analysis and design review of all cable tray supports to criteria t responsible to external source design concerns and in compliance with CPSES licensing commitments; testing to verify and/or establish specific component or system behavior characteristics; and hardware modifications as necessary to ensure final acceptability of all supports.
ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/86-01 RESULTS: PAGE 3 of 11 Dynanic analysis methods are employed in the design verification process for cable tray supports for Unit 1. Both Ebasco and Impell will utilize their own design procedures for performing the work; however, design methods O and criteria will be consistent. For both units, loading combinations and stress limits will be checked in accordance with acceptance criteria conforming to CPSES licensing commitments. For any support that fails to meet these criteria, design modifications will be prepared that result in acceptable qualification. A testing program has been defined to support the cable tray support verification effort. Modifications will be prepared for all cable tray supports that fail to meet specified acceptance criteria. All supports will be qualified in their existirg state, or required modifications will be implemented.
CPRT Quality Assurance Program The Comanche Peak Response Team (CPRT) Quality Assurance (QA) program is described in the CPRT Program Plan. The objective of the CPRT QA program is to ensure the quality of CPRT Program Plan activities and results. The CPRT Senior Review Team (SRT) directed that the QA program be developed based on appropriate criteria in 10 CFR 50, Appendix B.
This inspection is the first in a series of inspections to be performed at the Architect-Engineers (A/E) (Ebasco, Stone & Webster, and Impell) engaged in performing design verification activities for piping and pipe supports, cable tray and conduit supports for both Unit 1 and 2 of the Comanche Peak facility.
These inspections will review the implementation of the A/E's QA programs as modified to address the concerns identified in the CPRT Design Adequacy Program.
A. VIOLATIONS:
None.
B. NONCONFORMANCES:
None.
C. UNRESOLVED ITEM:
During the review of a Potentially Reportable Condition file, pursuant to the provisions of 10 CFR 50.55(e) for Conanche Peak Unit 2 cable tray and conduit support effort, documentation was not available which could demon-strate that an evaluation had been performed for applicability to Ebasco projects, other than Comanche Peak, in relation to P-Delta STRUDL computer code errors. (86-01-01)
This item will be reviewed during a future inspection.
ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/86-01 RESULTS: PAGE 4 of 11 D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (0 pen) Nonconformance (84-02-01): Ebasco procedures do not define a I system for reporting and evaluating computer program and system errors.
Ebasco stated in its response to this nonconformance that Procedure A-30, " Computer-Based Safety Related Programs - Development and Control" is undergoing a revision which will more fully define a system for the reporting and evaluation of computer program errors.
The inspector reviewed the latest issue of A-30, dated March 26, 1986 and A-37 dated May 31, 1985 " Control of Operating Systems Software Problems Affecting Computer-Based Safety-Related Programs," developed by Ebasco. A-30 now includes Section 10.0, " Errors and Defects," and Section 11.0, " Problems & Errors and Defects in Supplier Developed Programs." These sections define a system for reporting and evalu-ating computer program errors. However, they do not completely address the dissemination of computer program error reports and the evaluation for potential effect of errors on current and previous design calculations. This is particularly evident in Section 11.0 for errors in supplier developed codes.
This item will remain open pending a further review of Ebasco's commitment to further revise Precedure A-30.
- 2. (0 pen) Nonconformance (84-02-02): No formal method is available for the dissemination of computer program and system error reports ard the evaluation of these reports for the effect on current and previous design calculations.
The response for Nonconformance 84-01 also addresses this ocnconformance. This item will remain open pending a further review of Ebasco's revision to Procedure A-30.
- 3. (0 pen) Nonconformance (84-02-03): Contrary to Section QA-II-6, "Nonconformances," of Ebasco Services Topical Report ETR-1001, nonconforming conditions being detected by Vendor Quality Assurance Representatives are not being documented on nonconformance reports to ensure that both product and process corrective actions are being completed.
This item was not reviewed during this inspection.
. ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/86-01 RESULTS: PAGE 5 of 11 E. OTHER FINDINGS OR COMMENTS:
- 1. Cable Tray and Conduit Support Design Verification Review I
During this inspection, samples of design calculations (or cable tray hangers and conduit supports for Comanche Peak Unit 1 and 2 were selected for review. The review included verification of compliance to " Comanche Peak Manual of Procedures," "Ebasco Nuclear QA Program Manual Topical Report" and applicable codes and criteria.
In general, the inspectors reviewed the technical adequacy of the design calculations and stress analyses related to cable tray / conduit support member stresses, weld design, base plate and anchor bolt design. In addition, seismic and static modeling, STRUDL (Structural Design Language) input and output, loading combinations and conduit span frequency calculations were also reviewed. In addition, the inspectors examined the references, assumptions and drawings associated with the design and analysis,
- a. Design Verification of Cable Tray Supports The following documents from Comanche Peak Unit 1 and 2 were selected and reviewed by the NRC inspectors.
CTH-2-7388 CTH-2-7388 J4177A
- CTH-2-9895 CTH-2-10801 CTH-2-12997 CTH-2-7520 CTH-2-7502 CTH-1-1893
- CTH-2-9895 represents design calculations for another thirty cable tray hangers which include the following: CTH-2-9871, 9872, 9874, 9875, 9877, 9878, 9885, 9886, 9888, 9889, 9891, 9894, 9900, 9901, 9945, 9946, 9951, 9968, 9970, 9971, 9973, 9974, 9979, 9980, 9982, 9983, 9985, 9986, 9988, and 9989.
The STRUDL computer program was used in both static and dynamic analyses. The design and analysis of cable tray support members, including base plate and anchor bolts was performed by STRUDL internally. However, weld design was performed by hand calculations.
1 ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK l REPORT INSPECTION N0.: 99900505/86-01 RESULTS: PAGE 6 of 11
- b. Conduit Supports and Span Verification Calculations The inspector selected the following support and span documents O for review and examination: SUPT-1226, SUPT-1024, SAG CP 10-6/86, and SPAN-1122 A review of conduit span design calculations was performed which included span frequency and conduit stress calculations. In addition, accelerations for conduit support design and clamp capacity analysis were also reviewed. The STRUDL computer pro-gram was used in both conduit support design and span analysis calculations.
As a result of the review, the NRC inspectors determined that the general design requirements and procedures were being followed.
However, two items were identified as observations with respect to general references in design calculations. These two items are as follows:
Item No. 1 As shown on Sheet No. 41 of design calculation No. CTH-2-9895, a combined monber stress coefficient of 0.48 was being compared to a value of 0.75 without reference to the basis for such comparison. Ebasco personnel stated that this 0.75 value is used to account for the effects of bolt holes, in lieu of performing a rigorous design calculation. The design basis of 0.75 governing the bolt hole effect should have been referenced in the calculation so that the reviewer is able to understand the basis of the analysis and verify the adequacy of the results.
Item No. 2 The NRC inspector observed that the peak "g" values for Safe Shutdown Earthquake (SSE) and Operational Basis Earthquake (0BE) were selected from a refined response spectrum without additional documentation to support such practice. The ratio of SSE to 0BE was used to determine the governing loading condition for member stress, weld, and anchor bolt design, as referenced on Sheet No. 3 of design calculation No. CTH-1-1893.
Additional documentation to support this determination was not available in the calculation.
No nonconformances or violations were identified during this part of the inspection. .
- ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/86-01 RESULTS:
PAGE 7 of 11
- 2. P-Delta STRUDL Computer Code Error The NRC inspector reviewed Ebasco correspondence concerning deficien-A cies identified in an Ebasco procured conputer program provided by the Power Computing Corporation (PCC), formerly known as UCCEL. The errors were identified in the 0385 version of the P-Delta STRUDL program used in the design verification of safety-related cable tray hangers and conduit supports for Comanche Peak Unit 2. Two errors were found by Ebasco in the code checking portion of the program while performing design verification activities. The errors consisted of (1) the incorrect use, by the program, of an allowable stress factor for axial loads which resulted in improper code checking of several sections along the members length and (2) the program analyzing structural tubing as a tee section. Ebasco comnitted to perform a ,
100 percent review of the hangers through a revision to Appendix K of l their Comanche Peak procedure. Prior to the error correction, Ebasco had used the program to verify the design of approximately 2600 cable tray and 200 conduit supports.
Ebasco determined that the program produced unconservative results when checking the combination of two-directional bending stresses.
These results, if left uncorrected, would result in unreliable and unconservative design verification conclusions. In September 1985, Ebasco Services reported the condition to Texas Utilities Generating Company (TUGCO) as potentially reportable under the provisions of 10 CFR 50.55(e). TUGC0 later reported the problem as a potential deficiency to the NRC Region IV office on September 18, 1985. After Ebasco's review of over 1000 calculations, TUGC0 notified the NRC, on February 28, 1986, that the potential deficiency earlier reported has now been determined not reportable under the provisions of 10 CFR 50.55(e).
Documentation was not available during the inspection to support a similar evaluation for reportability under the provisions of 10 CFR 50.55(e), or 10 CFR 21, as applicable, for other Ebasco projects.
Unresolved inspection.
Item (86-01-01) was identified during this part of the
- 3. Ebasco Use of an Unverified Computer Code f
l A review of an Ebasco internal QA audit of the Comanche Peak site, perforned during the last quarter of 1985, revealed that Ebasco engineers in the field Damage Study Project used the computer code
l ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/86-01 RESULTS: PAGE 8 of 11 l
" SETS" to perform high energy line break analysis used by Ebasco to confirm earlier results perfcrmed by the original Architect-Engineer, Gibbs and Hill. During Ebasco's analysis, it was discovered that the i program was unverified and not suitable for nuclear use in its present form. However, Ebasco decided to continue such program use concurrent with the verificatien process being performed through UCCEL.
During this verification process, Ebasco attempted to verify the program using an alternate fault-tree analysis, which produced assur-ance that the code would perforn satisfactorily after final verifi-cation. The studies generated by this group would continue pending further results from UCCEL.
UCCEL, in its attempt to verify the program, contracted a third party consulting organization to help with the code verification and later concluded that the code met UCCEL's QA progran and was certified for nuclear use. This certification came approximately three months after the problem had been identified to UCCEL by Ebasco.
The NRC inspector reviewed Ebasco audit report No. E1606/833 performed at UCCEL during November 5-7, 1985, in which UCCEL was cited by Ebasco for allowing SETS to become part of Ebasco's QA; library of computer programs without undergoing the proper baseline testing. QA library programs, known as QALIB, are those programs which are considered to meet the UCCEL QA requirements for nuclear safety-related applications.
The " BASE 29A" version was to be tested against the most current installed version (which appeared to be " BASE 26") using all inputs available from UCCEL files. Testing documentation reviewed by Ebasco demonstrated the UCCEL input files were run twice for " BASE 29A" only, and not compared to the earlier version.
Since the nature of the work performed by the Ebasco Field Damage Study Project was confirmatory in nature, the use of this unverified program did not affect hardware already installed.
No nonconformances or violations were identified during this part of the inspection.
- 4. Ebasco Topical Report Referenca to 10 CFR 21 Ebasco Nuclear QA Program Manual ETR-1001, adapted for Texas Utility Generating Company CPSES Project, was reviewed by the NRC inspectors.
It was observed that reference to the reporting of defects ard noncompliarces as required by 10 CFR 21 was not addressed, however Ebasco's implementing procedure N-23 coes state this commitment as referenced in Table I-1.2, page 7, Section QA-I-1 " Matrix of
~
ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/86-01 RESULTS: PAGE 9 of 11 Compliance of Principal Implementing Procedures to 10 CFR 50 Appendix B." Table I-1.3, page 10, " Principal Implementing Procedures" also addresses this reference. Section QA-III-6, para-3 graph 3.3 "Nonconformances," which deals with activities affecting quality performed at construction sites, addresses this issue with respect to the overall reporting requirements of 10 CFR 50.55(e).
Ebasco stated they would review this item for possible inclusion into their overall Corporate Topical and CPSES Project Specific Report.
- 5. Procurement of Computer Services Ebasco contracted with UCCEL, which later became Power Computing (PCC),
in January 1986, after being purchased by Babcock & Wilcox, for Data Processing Services. These services include the accessing of safety-related computer programs which are part of the UCCEL/PCC library.
One of these UCCEL/PCC computer codes is P-DELTA STRUDL, which Ebasco is using as part of their verification program of cable tray / conduit supports for Comanche Peak.
The inspector reviewed the original purchase contract with UCCEL, No. D84046 dated September 27, 1984 and Ebasco Specification No.
862-84. This specification establishes the QA requirements for suppliers of nuclear safety-related computer services and software, and is the document which imposes 10 CFR Part 50 Appendix B, and 10 CFR Part 21 on the service bureau or code supplier. The speci-fication defined a defect, as applied to software or services and is restricted to those deviations in delivered software or services frcm technical requirenents that could, on the basis of the suppliers evaluation, create a substantial safety hazard.
The contract left the determination of whether a computer program l error could create a substantial safety hazard up to the supplier, l based upon his evaluation. When Specification No. 862-84 was revised '
to No. 862-86 in 1986, the definition of a defect was changed to l remove this statement concerning supplier evaluation. Ebasco stated 1 that they interpreted this change to mean that all defects are to be sent to Ebasco.
Purchase Contract Supplement No. D-84046, dated May 15, 1986, was ;
revised to include, amcog other changes, a mailing address for !
computer program error rotices.
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ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/86-01 RESULTS: PAGE 10 of 11 A new Purchase Contract No. D-86039, which was written with PCC on May 26, 1986, also referenced Ebasco Specification No. 862-86 for QA requirements. This is the contract which is current for the I
accessing of computer programs such as P-DELTA STRUDL from the PCC library.
No violations or nonconformances were identified during this part of the inspection.
- 6. Computer Program Error Reports A review was conducted of Ebasco Administrative Procedure No. A-30,
" Computer Based Safety-Related Programs - Development and Control,"
to deternine if the revisions made in response to Nonconformances (84-02-01) and (84-02-02) adequately address the control of computer program error reports. This includes the methods established to evaluate the impact of these errors on present and previous designs.
The inspector reviewed the sections of A-30 for both Ebasco developed programs as well as supplier developed computer programs. Section 10.0 " Error and Defects" defines the process by which computer program errors of Ebasco developed programs _shall.be distributed and evaluated for impact on current or previous calculations. This ,
section adequately defines this process, except for the overall )
control and review of these documented evaluations.
Section 11.0 " Problems & Errors and Defects in Supplier Developed Programs," defines the system by which a Project Ergineer and holder of a user's manual for a safety-related program acknowledges receipt of a program error using the Supplier Developed Program Error and Defect Notice (SEDN). However, the section has no provisions for the evaluation of these errors to determine their impact on current and previous design calculations, as well as documenting and reviewing of these evaluations, l
Previous nonconformances (84-02-01 and 84-02-02) which address this I area will remain open.
- 7. Training The inspector reviewed Section QA-I-3, " Personnel Indoctrination and Training," of the Nuclear QA Program Manual (Adapted for the TUGC0 Comanche Peak SES Project). This section describes the program for indoctrination and training of Ebasco personnel engaged in activities affecting quality with respect to Comanche Peak SES.
ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/86-01 RESULTS: PAGE 11 of 11 The NRC inspector reviewed the Comanche Peak SES QA Training Matrix which lists the design activities performed en the Comanche Peak effort and the appropriate procedural training which is required to g perform this activity. Also reviewed was the QA training / directories of all personnel in the New York and Lyndhurst, New Jersey offices.
These directories are broken down by discipline listing personnel and their job title.
The inspector reviewed training records for eight Ebasco employees from both the Cable Tray and Conduit Support Group, to assure they had received the training required for their particular position and job activity. This group represents both Ebasco offices and the personnel reviewed had received the required training for work on Comanche Peak. A review of these records demonstrated compliance to the Ebasco procedure with respect to Quality Related Training.
Ebasco stated that some special technical training was given
" conference room style," but this training was not documented and no attendance sheets were circulated. There is no requirement for technical training, however Ebasco stated that technical training is received via on-the-job training.
No violations or nonconformances were identified durirg this part of the inspection.
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