ML20215J682

Notice of Nonconformance from Insp on 860519-23

ML20215J682
Person / Time
Issue date:	10/10/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20215J668	List: ML20215J664 ML20215J682 ML20215J710
References
REF-QA-99901058 99901058-86-01, 99901058-86-1, NUDOCS 8610270150
Download: ML20215J682 (3)

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APPENDIX A Southern Company Services (SCS)

Docket No. 99901058/86-01 NOTICE OF NONCONFORMANCE During an inspection conducted May 19-23, 1986, engineering activities and the implementation of your quality assurance program were reviewed. The areas reviewed were related to SCS's activities and operational support for plant modifications at Georgia Power Company's Hatch facility and Alabama Power Company's Farley facility. The SCS Quality Assurance Program requirements are described in Policy and Procedure Manuals written for each facility. The requirements include ANSI N45.2, 10 CFR Part 50 Appendix B and reference and ASME applicable codes and standards such as IEEE-344-1975, IEEE-279-1971, Boiler and Pressure Vessel Code,Section III.

Based upon the results of this inspection, it appears that certain activities were not conducted in accordance with NRC requirements. In accordance with the NRC Enforcement Policy,10 CFR Part 2, Appendix C, the specific items of nonconformance are set forth below.

1. Criterion III of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

Contrary to the above, quality classification were not specified in design calculations and procedures for the preparation and review of design dalculations (SCS procedures 10502.4-4 (Hatch) and 220100.4-4 (Farley)) do not require identification of the system, structure or basic component's quality classification. (86-01-01)

2. Criterion III of Appendix B to 10 CFR Part 50, requires, in part, that appropriate quality standards are specified and included in design documents.

SCS' procedures 10502.4-4 (Hatch) and 220100.4-4 (Farley) requires, in part, that calculations be identifiable by subject, originator, reviewer and date; or by other data such that the calculations are retrievable.

The design analyses should be sufficiently detailed as to design inputs and references for understandability and verifiability without recourse to the originator.

Contrary to the above, SCS calculations SNE-86-002 Rev. O, (Hatch) 85082-MP, Rev. 3 (Farley) and SNC-85-098 Rev.0 (Hatch), do not contain the required data such that the calculations were retrievable and were not sufficiently detailed for understandability and verifiability. (86-01-02) 8610270150 861010 NOIN99EUTS

3. Criterion III' of Appendix B to 10 CFR Part 50 requires, in part, that applicable regulatory requirements and design basis, such as requirements derived from analysis of the effects of a postulated accident for which a structure, system, or component must meet its functional goals, are correctly translated into specifications, drawings, procedures, and instructions. In addition, measures are required to be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.

Section 4 of IEEE-344-1975 requires that the seismic qualification of equipment demonstrate the equipment's ability to perform required functions after a seismic event.

Contrary to the above, DCP-85-165, which incorporates an addition of non-seismically qualified fuses in a class IE DC ammeter circuit, contained a safety analysis which states that this circuit will not be required during and after a seismic event. The non-seismically qualified circuit and fuse / fuse holders may damage other IE components or may fail which may cause an electrical fault in class IE systems which would be required to function during and after a seismic event. (86-01-03)

4. Criterion III of Appendix B to 10 CFR Part 50 requires, in part, that measures are required to be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.

Section 3.9 of IEEE-279-1971 requires that the specific protection system design basis provided for each nuclear power generating station shall document as a minimum, performance requirements including (a) system response times; (b) system accuracies; and (c) ranges (normal, abnormal, and accident conditions) of the magnitudes and rates of change of sensed variables to be accommodated until proper conclusion of the protective action is assured.

Contrary to the above, SCS modification packages for plant Farley 82-0-1346, 82-2-2387 and 84-0-2642 did not include the required analysis to establish margins for the instrument setting; the new instruments' characteristics (accuracy, drif t, minimum resolution, response time, etc.) are different from the instruments which were replaced. (86-01-04)

5. Criterion III of Appendix 8 to 10 CFR Part 50 requires, in part, that design control measures provide for verifying or checking the adequacy of design and that design changes, including field changes, be subject to the same design control measures as those applied to the original design.

_ _ _ _ _ ~ _ _. _ _ . .

Section 4.2 o'f ANSI N45-2.11 requires, in part, that design analyses be sufficiently detailed as to purpose, method, assumptions, design input, references and units such that a person technically qualified in the subject can review and understand the analyses without recourse to the originator.

Section 4.4 of SCS procedures 10502 (Hatch) and 220100 (Farley) require that calculations contain the necessary assumptions and information required to permit independent review by a technically qualified engineer or designer and that revisions be processed in the same manner as the initial calculation.

Contrary to the above, supporting documentation for modification packages PCR-82-1-1306, PCR 82-0-1345, DCR 85-051, DCR 79-134-1, DCR 83-218, DCR 83-262 DCR 85-215, and DCR 83-236 did not contain sufficient information such that verification of the adequacy of the design could be completed by an independent review by a qualified engineer. Applicable field changes were not subjected to the same design control measures commensurate with those applied to the original design. (86-01-05)

6. Criterion III to Appendix B, of 10 CFR Part 50, requires, in part, that measures shall include provisions to assure that appropriate quality standards are specified and included in the design documents.

Criterion Section 4.2 of ANSI 45.2.11, reauires that an analysis should be sufficiently detailed as to purpose, method, assumptions, design input, references and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without recourse to the originator.

Contrary to the above, (1) references in calculations SNC 85-083 for DCR-83-236 were missing, methods of analysis were not specified with respect to seismic loads and the calculations and analyses were not sufficiently detailed and difficult to understand and (2) criteria and assumptions were not separated and that information critical to the analysis used in calculating the clearance to the New Fuel Bridge Crane was obtained verbally without written confirmation in Farley 1 calculation SC-84-1-3052-001(86-01-06).