ML20045E628
| ML20045E628 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/14/1993 |
| From: | Blake J, Chou R, Lenahan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045E566 | List: |
| References | |
| 50-324-93-25, 50-325-93-25, NUDOCS 9307020255 | |
| Download: ML20045E628 (14) | |
See also: IR 05000324/1993025
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UGitTED STATES .
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NUCLEAR REGULATORY COMMISSION
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. ATLANTA, GEORGIA 30323
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~ Report Nos.:
50-325/93-25 and 50-324/93-25
Licensee: Carolina Power and Light Company
P. O. Box 1551
Raleigh, NC 27602-
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Docket Nos.:
50-325 and 50-324
License Nos.: DPR-71 and DPR-62
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Facility Name: Brunswick 1 and 2
Inspection Conducted: iiay 17-21, 1993
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Inspect 9r
9.J J/ Lenahan
Date Signed
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.' Chou
Date Signed
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Approved by: - /
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J/A Blake, Chief
Date Slgned
J4terials and Processes Section
/E'ngineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This special, announced inspection was conducted .in the areas of the~
miscellaneous structural steel verification program, repairs to the-Unit I
drywell liner plate, a licensee identified item, and licensee action on
previous inspection findings.
Results:
A violation was identified pertaining to failure of the Nuclear Engineering
Department (NED) to-comply with document control procedures - paragraph 5.c.
A deviation was_ identified regarding failure of the' licensee to implement
corrective actions per their commitment to NRC - paragraph-4.
,
Weaknesses were identified in NED pertaining to failure to conduct self-
assessments, continued use of Draft documents in design, lack of timely
corrective actions, and failure of NED_ personnel to pay attention to~ details -
paragraph 5.c.
9307020255 930618
ADOCK 05000324
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees'
- R. Anderson, Vice-President, Brunswick Nuclear Plant
- W. Biggs, Supervisor, Corrosion Section, Nuclear Engineering
Department-(NED)
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- M. Bradley, Manager, On Site Nuclear Assessment Department, (NAD)
- M. Brown, Unit 1 Plant Manager
- J. Casteen, Document Control Supervisor
- T. Jones, Senior Specialist, Regulatory Compliance
R. Knott, Principal Engineer, (NED)
- J. Leininger, Onsite Manager, (NED)
- W. Levis, Manager Regulatory Compliance
C. Lewis, Site Document Control Unit 1 Supervisor
- G. Miller, Manager, Technical Support
- C. Schacher, Supervisor, (NAD)
R. Stewart, Supervisor, (NAD)
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G. Thearling, Senior Specialist, Regulatory Compliance
- J. Titrington, Unit 2 Operations Manager
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- S. Vann, NED Project Manager, Miscellaneous Steel Verification ' Program
- G. Warriner, Manager, Control and Administration
- C. Warren, Unit 2 Plant Manager
- K. Williamson, Supervisor,' Onsite NED Mechanical- Electrical Group
Other licensee employees contacted _during this inspection included
engineers, technicians, and administrative personnel.
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Other Organizations
- R. Bizzak, Civil / Structural .Consn1 tant, Tennera
- P. Dadlanni, Site QA Manager, Bechtel
- R. Gallager, Project Manager, Bechtel
NRC Resident Inspectors
- R. Prevatte, Senior Resident Inspector
P. Byron, Resident Inspector
- Attended Exit Interview
2.
Miscellaneous Structural Steel Evaluation Program, Unit 1 (37700)
a.
Background
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Miscellaneous structural steel consists of platforms and-other
beams / columns which provide personnel access and/or support for
piping, electrical raceways and conduits, HVAC ducts,
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instrumentation, and other equipment not supported from the main-
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building structures.
Numerous deficiencies in miscellaneous steel
had been identified by either the licensee or NRC, including lack
of design calculations, lack of as-built drawings, missing bolts
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and welds, incorrect size members, undersized welds, missing
members, and other construction deficiencies. The licensee
retained Bechtel Power Corporation to perform walkdown
inspections, prepare as-built drawings, and perform design
calculations to qualify the miscellaneous steel.
The Bechtel structural steel verification program, which is called
the Miscellaneous Steel Verification Program (MSVP), is a two
phase project with the purpose of establishing a high confidence
that the miscellaneous steel is adequate for operation. The Phase
I program was a walkdown inspection- to identify and evaluate any
irregularities which could affect the integrity of the structures.
The Phase II program involved obtaining detailed field
measurements to update design documents, prepare as-built
drawings, performance of a detailed structural analysis, and
preparation of a load tracking program to identify the magnitude
and location of loads.
The licensee has completed the Phase II program in the Unit 1
drywell.
The Phase I program was completed for the remaining
miscellaneous steel-in the Unit I reactor building. The results
of inspection of the miscellaneous steel program for Unit 2
restart is summarized in NRC Inspection report numbers 50-325/93-
15 and 50-324/93-15.
b.
Review of Bechtel Structural Steel Verification Program Procedures
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The inspector examined the Bechtel procedures which control the
Phase I and Phase II walkdown and evaluation of identified
irregularities.
Procedures examined were as follows:
- Procedure No. WDP-001, Phase I Engineering Walkdown
Procedure for Reactor Building Miscellaneous Steel,
Revision 2.
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Procedure No. WDP-002, Phase II Walkdown Procedure for
Reactor Building Miscellaneous Steel and Drywell Platform
Steel, Revision 4.
Procedure No. EDPI 4.90.03, Hiscellaneous Steel
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Verification Program, Unit 1 Restart, Revision 1.
- Civil Design Criteria MSVP-C-001, Civil Design Criteria
for-Irregularity Evaluation-for the Miscellaneous Steel
Verification Program, Units 1 and 2, Revision 4.
Procedure WDP-001 specifies the criteria for performance of
engineering walkdowns using experienced civil / structural engineers
to identify and classify physical irregularities in the structural
steel.
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Procedure WDP-002 establishes the methods for conducting and
documenting walkdowns performed to obtain existing as-built
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information on the structural steel. The existing design drawings
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are used in the Phase II walkdown and differences between field
conditions and the design drawings are recorded in the Phase II
walkdown documentation.
Irregularities are identified and
recorded during the Phase II walkdowns. The Phase II walkdowns
include weld verification.
Procedure 4.90-03 describes the process by which irregularities
identified during the Phase I and Phase II walkdowns are evaluated
and resolved.
Design Criteria MSVP-C-001 is the basis for
evaluating irregularities in accordance with FSAR criteria, as
supplemented by CP&L submittals to NRC.
c.
Review of Phase I Walkdown Documentation
As stated above, the purpose of the Phase I walkdowns is to
identify and classify physical irregularities in the structural
steel construction.
The Phase I walkdowns are conducted by
experienced civil / structural engineers. The qualifications of the
Phase I walkdown personnel were reviewed during an inspection
documented in NRC Inspection Report numbers 50-325,324/92-23.
In
accordance with Procedure WDP-001, the irregularities are
classified in accordance with Table I.
TABLE 1
Structural
Steel Physical Irregularities
CODE
ACTION
A.
No Irregularities Noted
B.
Irregularities Noted:
No Modification Necessary
C.
Irregularities Noted:
Modification Recommended
D.
Further Evaluation Required
E.
Inaccessible: Observation Not
-Possible (Note Area Hot Viewed In
Remarks)
F.
Unacceptable: Restore to Original
Design Requirements
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The procedure also specifies a numerical code, which identifies
the type of irregularity, e.g., weld missing, number 1, bolt
missing, number 4, connection member missing, number 12, etc.
The inspector randomly selected the completed reactor building
Phase I inspection packages listed below, reviewed them for
content and completeness, and reviewed the type and number of
irregularities identified.
Phase I documentation packages
reviewed were as follows:
1-RB-B-El (-) 00-9, P-S/2R-4R
l-RB-B-El (-) 04-1, P-S/2R-4R
l-RB-B-El (-) 04-1, S-T/2R-3R
l-RB-B-El (-) 04-1, S-T/3R-4R
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l-RB-B-El (-) 07-9, R-T/2R-4R
l-RB-B-El
06-0, P-S/2R-3R
l-RB-B-El
10-6, P-S/2R-4R
l-RB-D-El (-) 04-1, P-S/6R-8R
1-RB-D-El (-) 04-1, S-T/6R-7R
l-RB-D-El (-) 11-4, S-T/5R-6R
l-RB-D-El
10-7, P-S/6R-8R
The inspector concluded that the Phase I walkdown inspection
results were properly documented.
d.
Review of Calculations - Unit 1
During the irregularity evaluation of the MSVP for Unit 2, Bechtel
engineers evaluated each individual irregularity and determined if
the irregularities affected the structural integrity of'the
miscellaneous steel platforms. The final disposition for each
irregularity were either use as is, rework, or modify.
For the
irregularity evaluations for Unit 1, Bechtel engineers summarized
and categorized some of the common irregularities into several
standard calculations based on the Unit 2 experience. The
standard calculations evaluated the common irregularities and set
forth the acceptance criteria.
If-the irregularities were beyond
tne acceptance criteria, additional calculations are required to
evaluate these irregularities.
Bechtel engineers generated 14
standard calculations. The inspectors reviewed 13 of them. One
Unit 2 calculation for clip Angle Evaluation was also reviewed and
this one is included in the table listed below since it will be
used for Unit 1 evaluations. The standard calculations reviewed
-are listed below in Table 2.
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Table 2
Standard Calculations for Common Irregularities
Calculation
Revision
Calculation Title
No.
No.
2
Guidelines for Screening Unit
1 Irregularities
IRB1-1106
1
Generic Cope Evaluation Based
on Unit 2 Experience
IRB1-1107
1
Generic Beam Setback
Evaluation Based on Unit.2.
Experience
IRB1-1108
1
Generic Saw Overcut Evaluation
Based on Unit 2 Experience
IRB1-1109
1
Generic Minimum Edge Distance
Evaluation Based on Unit 2
Experience
IRB1-1110
0
Generic. Corrosion Evaluation
Based on Unit 2 Experience
IRB1-1111
1
Generic Bolting Evaluation
Based on Unit 2-Experience
IRB1-1112
1
Generic Partial Penetration
Weld Evaluation Based on Unit
2 Experience
IRB1-1113
1
Generic Abandoned Hole
. Evaluation Based on Unit 2
Experience
IRB1-1114
1
Connection Weld Analysis
IRB1-1115
1
Generic Connection Angle
Dimension Evaluation Based on
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Design Aids for Screening Unit
1 Irregularities
IRB1-1125
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Generic Operability
0
Fabricated Clip Angle
Evaluation by Random Sample
(Unit 2)
The above calculations were reviewed for completeness, accuracy,
adherence to design criteria and procedural requirements, acceptability
of calculation methods with American Institute of Steel Construction
(AISC) code criteria, and good engineering practices.
All the standard
calculations reviewed were determined to be acceptable although the
inspectors found some minor discrepancies which would not affect
operability for restart.
All components categorized as C, D, or E irregularities in the Phase I
walkdowns have been evaluated for plant restart concerns as addressed in
Exhibit A, Plant Restart Evaluation Methodology, using the Civil' Design
Criteria for the MSVP, Project approved generic calculations and
guidelines, design aids, simple computations, the judgement of the
reviewers, and 'the data obtained from the walkdowns. The evaluation of
structural components categorized as C, D, or E were assessed through a .
screening process consisting of an : initial screening,~ Level 1, secondary
screening, Level 2, and final review.
In the Level 1 screening, two experienced structural engineers used the
guidelines of standard calculation IRB1-1105 and screened each component
classified as category C, D, or E for structural acceptability in each
walkdcwn package.
Each component was determined to be one of the
following types:
Type 1: Accept As Is
Type 2:
Restore to Design Requirements
Type 3: Modification Required
Type 4:
Further Evaluation Required
Each component identified as "Further Evaluation Required" (Type 4) from
the initial screening above were evaluated by two engineering
specialists in the secondary screening.
The engineering specialist
evaluated components categorized as "Further Evaluation Required" and
reclassified them as one of the above four types.
If the component
after-re-classification, was still considered to be Type 4, "Further
Evaluation Required", the component was listed-as requiring further
evaluation in an irregularity calculation.
If the component was out of
scope, it was referred to CP&L for disposition. During the screening
and review process, the level 2 screeners performed sample reviews on
level 1 disposition.
Level 2 screeners can over-ride the level 1
disposition. With the same authority, the final reviewer can override
the levels 1 and 2 screeners' disposition. The inspectors also reviewed
the calculations listed in Table 3, below. These calculations were for
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three platforms. The irregularities identified on these platforms were
compared to the irregularities addressed in the generic calculations.
Irregularities which were determined to be non-generic, required further
review.
Table 3
Calculations Reviewed for Individual Platforms
Calculation
Rev. Walkdown
Types of
No.
No.
Package No.
Irreaularities
IRB1-Il62
0
1-RB-D-EL37'-10"
Missing welds
(S-T/6R-8R)
Insufficient welds
0
1-RB-C-EL.10'- 0"
No engineering
(CK-L/7R-8R)
drawing for the
platform
1 RIP-1088
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1-DW-E-EL.17'-10 1/4"
Slip critical
(58 - 81 )
connection
Missing weld
Insufficient welds
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The above calculations were determined to be acceptable.
The requirements for the Level 1 and 2 screeners are specified in
procedure EDPI-4.90-03. Minimum requirements are.as follows:
Level 1 screening engineers shall be experienced, degreed
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Civil / Structural Engineers with previous experience in design or
evaluation of structural steel and be approved by the Chief Civil
Engineer.
Level 2 screening engineers, Engineering Specialists, shall
be experienced, degreed Civil / Structural Engineers, with extensive
experience (15 years or more) in the field of design.and analysis of
structures, with emphasis in structural steel, ten years on Nuclear
Power Projects, and a registered Professional Engineer.
The inspector reviewed the resumes of the Level 1 and 2 screeners and
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verified that the experience and qualifications of these personnel met
the procedure requirements.
Violations or deviations were not identified.
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3.
Repairs to the Unit 1 Drywell Liner
During the inspection documented in NRC Inspection Report numbers
50-325,.324/93-02, the inspector identified a problem with corrosion of
the drywell liner plate at the intersection of the liner with the
elevation 5 concrete floor, around the entire circumference of the
drywell. A violation, item No. 325,324/93-02-01, was identified
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regarding failure of the-licensee to measure and evaluate the corrosion.
After the corrosion problem was identified by the inspector, the
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licensee performed extensive inspections and repairs of the corrosion in
the Unit 2 drywell . This work was examined by the inspector during the-
inspection documented in NRC Inspection Reports Numbers 50-325,324/93-
02 and 93-15. During the current inspection, the.. inspector reviewed
special procedure OSP-93-010, Revision 2, dated May 3,- 1993, Drywell
Liner Corrosion Examination.
The inspector, accompanied by a licensee engineer, walked down the Unit'
I drywell and examined the liner plate corrosion. The licensee was in
the process of sand blasting the liner to remove the corrosion and
deteriorated coatings. The inspector noted that the corrosion was
concentrated in the expansion joint area, below the' concrete floor
elevation. The licensee had performed measurements of some of the
corrosion area to determine the depth of the corrosion and pitting below
the surface of the steel liner plate.
However, the orientation of the
liner plate and the width af the expansion joint made the cleaning'and
inspection process. difficult.
The inspector met with licensee engineers
and discussed the need to remove some of the concrete floor slab
adjacent to the liner plate and expansion joint to be able to thoroughly
clean the corrosion area and properly inspect the liner plate. This
will also be necessary to make any required weld repairs and for
recoating of the liner plate.
Licensee engineers stated that removal of-
some of the concrete slab would be considered after . sand blasting and
the initial inspections were completed. The repairs to-the Unit 1
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drywell liner will be inspected in future inspections.
Violations or deviations were not identified.
4.
Licensee Event Report (LER)
(0 pen) LER 2-92-006,: Control Drive System Scram Discharge Volume
Instrument Line Pipe Supports Were Found Missing
The licensee's corrective actions for their LER are summarized in an
attachment to CP&L letter, serial:
BSEP-92-0019, dated September 21,
1992, Subject:
Licensee Event Report 2-92-006.
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The inspecter examined the licensee's corrective actions for this LER
during inspections documented in NRC Inspection Report numbers 50-325,.
324/93-15 and 93-20. This LER was left open pending NRC review of the
licensee's corrective actions pertaining to procedure revisions. The
inspector verified-that all-hardware-deficiencies had either been
corrected or had been evaluated under the short term structural
integrity program prior to restart of Unit 2.
The licensee committed to
add procedural control enhancements to a procedure which was being
developed to cover the temporary removal of existing equipment
interferences. The licensee committed to have this procedure, number
MAP-004, Modification Work Control Procedure, approved, issued, and in
place by March 31, 1993.
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During the current inspection, the inspector requested a copy of-
procedure MAP-004 for review. The inspector was informed by document
control personnel that procedure MAP-004 had not.yet been issued.
Discussions with Regulatory Compliance personnel disclosed that
procedure MAP-004 will not be issued since it was superseded by
procedure PLP-24. However, the procedural control enhancements for
temporary removal of equipment were not included in procedure PLP-24.
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These enhancements will be included in procedure MAP-005, Application of
Nuclear Plant Modification Program, which is scheduled to be approved-
on/or about May 31, 1993, with an effective date in June, 1993. The
inspector discussed with the licensee the failure to approve, issue and
implement the procedural control enhancements covering temporary removal
of equipment during plant modification projects in accordance with their
commitment to NRC.
The failure to issue a procedure covering their
commitment was identified to the licensee as Deviation items 325,
324/93-25-01, Failure to Implement corrective Action in Accordance with
Commitment to NRC.
5.
Action on Previous Inspection Findings
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a.
(Closed) Inspection Followup Item 325,324/93-02-02, Corrosion of
Nelson Studs on Embedded Plates
During implementation of Plant Modification 92-092, the licensee
discovered that seven of eight Nelson studs on service water pump
2B pedestal were severely corroded and were no longer-attached to
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the embedded plate which the Nelson studs anchored to the
concrete. This problem was documented on Minor Adverse ~ Condition
Report Number 93-065.
Prior to restart of Unit 2, corrective
actions for this problem were examined by the inspector during an
inspection documented in NRC Inspection Report numbers 50-325,
324/93-20.
During the current inspection, the inspector reviewed
documentation pertaining to the licensee's close out of MAC
93-065. This included a summary of the corrective action taken,
the completed minor adverse condition report, and the field
inspection data. The field inspection data included the results
of Ultrasonic Testing (UT) performed on various embedded plates to
determine if the Nelson studs were still attached to the plates.
The embed plates selected for testing were those which showed
indications of possible corrosion which potentially may have
affected the Nelson studs. The ultrasonic test-data indicated
that- the Nelson studs were-still attached-to the-embed plate.
Based on the test data, the licensee concluded that the corrosion
of the Nelson studs identified on the service water pump 28
pedestal was an isolated occurrence. The inspector concurred.
b.
(Closed) Inspection Followup Item 325,324/93-20-01, Revision to
DG 11.20 to Incorporate Transient Loading and Delete Tested
Mechanical Properties
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The inspector reviewed Revision 5 of Design Guide (DG) II.20,
Civil / Structural Operability Reviews which was approved on May 11,
1993. The inspector verified that DG 11.20 had been revised to
delete the option of using tested mechanical properties as
allowable stress values when they exceeded code minimum values,
and that applicable transient loads are included in piping
analysis equations. These revisions were in accordance with the
licensee's commitments to NRC contained in their April 19, 1993
letter, Serial: NLS-93-106, Subject:
Response to NRC Questions
from April 1, 1993, Meeting.
c.
(Closed) Unresolved Item 325,324/93-20-03, Questionable Control
for NED Design Procedures
This unresolved item concerned numerous problems identified by the
inspector regarding document control in the onsite Nuclear
Engineering Department. The particular issues identified by the
inspector concerned apparent use of uncontrolled procedures as
references in design calculation, apparent failure to distinguish
controlled documents from uncontrolled documents, and failure to
issue revisions to controlled documents to the Brunswick site TAC
library. During the current inspection, the inspector verified
that these problems were in violation of NED 3.5, Handling of
Controlled Documents. The specific procedural violation involving
four examples were as follows:
1.
The calculations for short term structural. integrity
evaluations of over spanned conduits, which is a
portion of calculation number OSEIS-1005, referenced
Structural Design Guides (SDGs). These SDGs were not
controlled documents, and in fact, there were no
controlled copies of SDGs available onsite.
This was
contrary to the requirements of paragraph 3.5.3.2 of
NED procedure 3.5 which states that uncontrolled
copies of procedures shall not be used when' designing
changes to systems, structures and components.
2.
On April 20, 1993, the inspector determined that
various copies of NED documents, including procedures,
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SDGs, and Mechanical Design Guides (MDGs) retained by
NED personnel in their work areas and in the NED
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library were not distinguishable from controlled
copies. This was contrary to the requirement of
paragraph-3.5.3.2 of NED procedures 3.5 which states
that uncontrolled copies of controlled documents be
clearly distinguishable from controlled copies.
3.
On April 20, 1993, the inspector identified various
superseded copies of drawings, procedures, and
specifications which were being retained by NED
personnel in their work areas and in the NED library.
The copies were not marked " Superseded." This was
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contrary to the requirements of paragraph 3.5.3.2. of.
NED procedure 3.5 which states that superseded
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revisions of controlled documents which are~ retained
by NED personnel for reference must clearly be marked
as " Superseded".
4.
On April- 19, 1993, the inspector identified that
Revision 3 of Design Guide III.16 had not been issued
to the Brunswick site TAC library (NED Control' Copy
No. 367). Discussion with the librarian in the TAC-
library disclosed that for some reason, Revision 3 was-
not sent to the TAC library when it was issued. This.
was contrary to the requirements of Paragraph II.A of.
Attachment 2 of NED procedure 3.5 which states that
NED controlled documents be serialized and issued to
specific individuals.
The procedure requires a
receipt system be utilized to verify receipt .of the
controlled document and each revision thereto by the
person to where the document or revision was issued.
The receipt system had not been utilized to verify
distribution and determine that Revision 3 of DGIII.16
had not been issued to the TAC library.
The above four examples of failure to comply with the requirements
of NED procedure 3.5 were identified to the licensee as a
violation of 10 CFR 50, Appendix B, Criterion ~ V. Unresolved item
325,324/93-20-03 is closed and upgraded to violation item 325,
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324/93-25-02, Failure to Follow Document Control Procedures in
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NED.
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Subsequent to the inspection documented in NRC Inspection Report
numbers 50-325,324/93-20, the licensee initiated an indepth audit
and review of controlled documents in use by the onsite NED group.
A review was also conducted in the corporate NED office. These
reviews disclosed numerous problems with control. of documents
within NED. These included missing copies of controlled-
procedures, out of date copies of vendor drawings in the Brunswick
site library, and extensive use by NED personnel of uncontrolled'
copies within NED of various other types of controlled documents.
The licensee took some.immediate corrective actions to address
these problems; these included:
- Closing of the Brunswick site NED library for a
--detailed' audit of- documents-contained within. This
audit involved-3 to 5 document control personnel
and required more than.one month to complete.
- Training of NED personnel on document control
procedures.
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- Review of controlled documents issued to individuals to
determine _the status of these controlled documents.
Identified deficiencies' were resolved.
- Review of documents held by all NED personnel to
verify that copies in their possession complied -
with document control requirements specified in NED
procedure 3.5
Walkthroughs of work areas by supervisory personnel
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to ensure document control procedures are being
met.
The inspector concluded that these corrective actions will
contribute to resolution of document control problems within NED.
However, further review is required to determine if other
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corrective actions are required to resolve the' document control
problems within NED.
In addition to the document control review discussed above, the
licensee's Nuclear Assessment Department (NAD) performed an.
assessment of engineering documentation at the Brunswick site from
April 26-30, 1993.
Their-assessment was initiated because of the
document control problems found by the inspector during inspection'
number 93-20. The inspector discussed the assessment finding with
NAD personnel and reviewed a draft copy of the NAD Assessment
Report. The assessment identified, additional document control
problems similar to those identified by the inspector. However, a
problem was also identified with the licensee's NRCS system which
is discussed below.
The assessment also identified other issues
including failure to pay attention to details, weakness in
procedures used to prepare design change packages, use of " Draft"
documents as references in design calculations, and failure of NED
to perform self assessment. The use of draft 1 documents in NED
has been a continuing problem which was previously identified by-
NRC.
This problem was highlighted to licensee management in the
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letter dated October 26, 1992, which transmitted NRC' Inspection
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Report 50-325, 324/92-27 to CP&L.
The particular problem
identified by NAD involved a non-safety related piece of
equipment. This was calculation ODG-0016, Revision 1, for
operable Mod 93-010 which was approved February 25, 1993. The
calculation referenced a Draft of Revision 3 of Desicn Guide DG
VIII.50. However, Revision 3 of DG VIII.50 had not been issued as
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c
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-of tiay 21,1993. - A violation was- not-identified by the ' inspector.
regarding this finding since it involved Quality Class B, a non-
,
'
safety related piece of hardware.
Problems have been identified in the NRCS, which is the acronym
i
for the Nuclear Records Control System, during the most recent
l
assessment and during previous NAD assessraents.
The NRCS system
is the system personnel onsite use to verify that the documents
they are using are the most current revisions.
The-licensee's
,
'
,
_
,
.
..
,
13
corrective actions to . resolve problems they self-identified with
the NRCS system will be evaluated as part of the followup to
violation item 325,324/93-25-02.
The failure of NED personnel to identify the problems identified
by the inspector and NAD through self-assessments was identified
to the licensee as a weakness. The requirements for self-
assessments are covered in NED procedure 2.17, Nuclear Engineering
Department Self-Assessments. Other issues identified as
weaknesses are continued use of draft documents when performing
design work, lack of timely corrective actions to respond to NAD
assessment findings and failure of NED personnel to pay attention
to details.
,
6.
Exit Interview
The inspection scope and results were summarized on May 21, 1993 with-
those persons indicated in paragraph 1.
The inspector described the
areas inspected and discussed in detail the inspection results listed
below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Deviation Item 325,324/93-25-01, Failure to Implement Corrective Action
in Accordance with Commitment to NRC.
Violation Item 325,324/93-25-02, Failure to Follow Document Control
Procedures in NED.