U. S. ITUCLEAR REGULATORY COM:4ISSIONOFFICE OF INSPECTICil Ai!D ENFORCEMENT

REGION IV

Report No. 99900524/73-02 Program No. 51200

Company: Gibbs & Hili incorporated393 Seventh AvenueNew York, New York 1CC01

Inspection Conducted: December 11-15, 1978

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Inspectors: ) MC N bh' / [R. H. 'SMckley, Princip'al (Inspector, Vendor Date

Inspection Branch

a| h ~.3I, -5nu m / M| v 2/ ? t'

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tiJ,.j . Johns,on, Contractor Auditor, Vendor DateInspect 1An Branch

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Approved by: Lv L [,) UUV-

C. J. %14,' Chief, Program Evaluation Section, Date~

Vendor Inspection Branch

Summary

Inspection on December 11-15, 1978 (99900524/78-02)

Areas Insoected: Implementation of 10 CFR 50 Appendix B and Tcpical ReportNo. GISSAR-17-A including design inspection, implementation of the QualityAssurance Program on Gibbs & Hill Standard Safety Analysis Raport (GISBSSAR),and action on previous inspection findings. This inspection involved 60inspector-hours on site by two (2) NRC inspectors.

Results: In the three (3) areas inspected there were no unresolved itemsidentified in any of the areas. The following deviations were identified.

Deviations: Cesign Inspection: 1. Failure to identify the revisor andsoprover of a revision to a design calculation as required (Enclosure, ItemA), and 2. Failure to obtain the approval of the structural discipline on as;ecification as required (Enclosure, Item 3).

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Implementation of the Quality Assurance Program on GISBSSAR: 1. Failureto audit GIBBSSAR activities on a semi-annual basis as required (Enclosure,Item C.); 2. Failure of five (S) personnel to attend the Technical

Indoctrination Program as required (Enclosure, Item D.); and 3. Failureto obtain satisfactory corrective action to audit findings and schedulere-audits of deficient ereas (Enclosure, Item E. ).

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DETAILS SECTIOh I

(Prepared by R. H. Erickley)

A. Persons Contacted

*J. R. Ainsworth, QA Resident Engineer, Texas UtilitiesGeneration Company (TUGCO)

A. 3eary, Manager, Quality ControlJ. Galperin, Senior Engineer

*N. Hyman, Manager, QA*J. Jusco, Assistant QA SupervisorC. N. Yeh, Nuclear Engineer

* Denotes those present at the exit interview.

B. Action on Previous Inspection Findings

1. (Closed) Deviation (Report No. 78-01) Failure to reaudit four (4)conditionally approved suppliers within the past year that wereperforming work on issued purchase orders. The inspector examinedthe corrective actions and preventive measures described in theletter of response dated May 4, 1978, and found the following:

a. A master list of vendors with conditionally approved QA programswas prepared and transmitted to the G&H QC/ Vendor SurveillanceDepartment and TUGC0 QA as committed.

b. The Executive Vice President issued a directive to the QAand QC Departments with a copy to TUGC0 reemphasizing thata vendor must have an approved QA program prior to performingwork.

c. A Vendor Document & Drawing Status listing was issued bythe G&H QC/ Vendor Surveillance Department as committed.

d. Both the master list of vendors with conditionally approved

QA program? and the Vendor Document & Drawing Status listinghad been revised on a monthly rather than a bi-weekly basisas committed. The inspector noted that the G&H QA ProgressReport No. 2 to NRC Inspection Report 73-01 dated Novemcer 13,1978, had identified this item and recommended that managementnotify NRC; however, no notification was made.

e. The responsibility for performance of sucplier pre-awardsurveys, follow-up surveys and audits was assumed by TUGC0QA as of August 15, 1977, as stated in a letter from theTUGC0 QA Manager to the GSH Project Manager dated Aoril 21,1978.

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f. The master list of vendors with conditionally approvedQA programs. Revision / issuod Novemt3er 1973, indicated thatone vendor remained with pre-award restrictions

?. (0 pen) Deviation (Report No. 78-01) Failure to conduct internalproject audits. The inspector exa:nined the corrective actionsand preventive measures described in the letter of responsedated May 4,1978, and found the following:

a. A QA Department Master Audit Schedule and supplementalAudi t Schedule and Recor i Sheets have been issued as cc:nni tted.

b. Additional QA personnel (approximately eleven) have beenassigned to the project.

c. The audits of the Print Department, Proiects, and Instrumentationand Controls were not perfonred until five (5) ranths af terthe G?di commitment date of June 15, 1978.

d. The audits of Purchasing, Central Files, and Applied Mechanicshave not been perfonned.

3. (Closed) Deviation (Report No. 78-01) Failure to perform auJitson six (6) vendors. The inspector examined the corrective actionsand preventive measures described in the letters of responsedated May 4, 1978, and June 30, 1973, and found the following:

a. A Vendor QA Audit Schedule was issued on March 1973 as comnitted.

b. The records of vendor audits are maintained by TUGC0 since theyhave assumed responsibility for these activities (see paragraphB. l.e above)', therefore, the only evidence of audit performancethat was available for examination was in the documentsreferenced in paragraphs B. l.a and B. I.c above.

4. (Closed) Unresolved item (Report No. 78-01) Project procedureswere not clear with respect to design interf ace review requirements.The inspector exa.ained Revision i to procedure DC-13 (Procedurefor Identification Control of Design Interfaces, Both Externaland Internal) issued in August 1978, applicable revisions (SectionIII, page III-9) to the Project Guide issued April 14,1973, andthe results of the specification and drawing reviews, and foundthat this item has been resolved.

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C. Design Inspection - Containment Soray System

1. Objectives

The objectives of this area of the inspection were to verifyfor the containment spray system that:

a. Design criteria, requirements and commitments, as listedin the SAR, were utilized in design input during systemand component design.

b. Analyses of containment spray pump net positive suctionhead (NPSH) during all phases of operation folicw theguidance of Regulatory Guide 1.1.

Design analyses ec'3blish the capability of the system toc.provide flow at .tes and temperature which result in heatremoval rates consistent with those utilized in the LOCAand/or main steam line break analyses.

d. Specifications and/or procurement documents for systemcomponents require them to be designed, fabricated, erectedand tested in accordance with applicable ASME Section III and10 CFR 50, Appendix B, requirements.

Provisions arid plans have been made for pre-operational ande.operational testing consistent with SAR commitments andstatements.

f. The analysis (design) of system spray coverage supportsSAR commitments and statements.

9 The system design for pH control including analyses ofpH versus time af ter system actuation supports SAR commitmentsand statements.

h. Provisions to prevent trapping of chemical additives imple-ment SAR commitments.

i. Calculations of iodine removal constants, use parameters, andsystem characteristics are consistent with those in itemsa-h above.

j. Iodine removal constants used in the analyse of the radio-logical consequences of a LOCA are consistent with item i.above.

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2. fje_thod of Acccmplishment

The preceding objectives were accomplished by an examination of:

a. Sections 6.2.3 (Containment Air Purification and CleanupSystem), 6.2.2 (Centainment Heat Removal System), and Table6.2-11 (Containment Spray System Ccmponent Design Parameters)of the Comanche Peak Steam Electric Station (CPSES) FSAR; andSection 17.1.2 (Quality Assurance During Design and Construction(Gibbs & Hill)) of the CPSES PSAR to identify the technicaland programmatic comitments for the Containment Spray System(_C SS ) .

b. Procedure Nos. QA-1 (Design and Engineering SurveillenceProcedure), DC-5 (Specification Production and Solicitationof Bids Procedure), DC-7 (Technical Calculation Procedure),DC-9 (Design Review Procedure - Specifications), and DC-10(Design Review Procedure - Calculations) of the CPSES ProjectProcedures Manual, and QAII-D (Engineering and Design VerificationProcedure) of the G5H QA Manual to determine that they wereconsistent with SAR commitments.

c. Calculation No. 232-1 (. Containment Spray NPSH) and associatedrecords, e.g. Analysis & Calculation Control Sheet, I.O.M datedFebruary 11, 1977 (Design Review Action), Design andEngineering Surveillance Record Sheet, Design Review -Calculations - Record Form, and Mechanical Checklist -Calculations to verify that it satisfied C.1.a and C.1.babove and was done in accordance with applicable procedures.

d. Calculation No. NC-AA-13 (Containment Spray Iodine Removal)and associated records, e.g. IOM dated September 26, 1977,and Design Review - Calculation - Record Form to verifythat it satisfied C.1.i above and was done in accordancewith applicable procedures.

e. Calculation No. 232-12 (Containment Spray System OrificeSizing) and the associated Analysis & Calculation ControlSheet to verify that it satisfied C.1.a above and was donein accordance with applicable procedures.

f. Specification No. MS-12 (Containment Spray Pump) Revision 2dated April 29, 1975 and associated records, e.g. theSpecification Review - Record Forms for Revisions 0,1, and2 te verify that it satisfied C.1.a and C.1.d above, utilizedthe results of appli ?ble c acign analysis, and was done inaccordance uith apglicauie procedures.

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The objectives of paragraphs C.1.c, C.1.e, C.1.f, C.1.g, C.1.hand C.1.j above were not completed and will be scheduled for afuture inspection.

3. Findings

a. There were no unresolved items identified.

b. Two (2) deviations were identified. (See Enclosure, ItemsA and B).

D. Exit Interview

An exit interview was held with management representatives on December 15,1978. In additicn to those individuals indicated by an asterisk ineach Details Section, those in attendance were:

P. P. DeRienzo, Vice President, Consultant Engineeringand Quality Assurance

R. H. Gordan, Senior Vice President, Power and EnergyN. N. Keddis, QA SupervisorH. R. Rock, Project Manager

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The inspector summarized the scope and findings of the inspection.Management representatives had no comments in response to each itemdiscussed by the inspector.

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DETAILS SECTION II

(Prepared by J. M. Johnson)

A. Persons Contacted

D. Conrade, Assistant Chief, Computer Services*il . I. Hyman, Manager, Quality AssuranceC. M. Jan, Assistant Chief Structural EngineerJ. E. Triolo, Senior Engineer, Quality AssuranceR. Prieto, Assistant Project Manager (GIS3SSAR)C. it. Yeh, *;uclear Power Engineer

* Denotes those present at the exit meeting.

B. Implementation of Quality Assurance Program on GIBBSSAR

1. Objectives

The objectives of this area of the inspection were to examinepertinent records associated with GIBBSSAR to assure that it isbeing developed under a controlled Qualtiy Assurance Programr.ad procedures meeting the requirements of the Gibbs and HillTopical Report, GIBSAR-17. The applicable areas in the GISBSSAR3 cope of work include: QA organization, QA program, training,design, procurement, QA records, audits and corrective action.

2. Method of Accomolishment

The preceding objectives were accomplished by an examination of:

a. Gibbs and Hill Tooical Report, GIBSAR-17: Section 17.1.1(Organization); 17.1.2 (QA Program); 17.1.J (Design Control);17.1.4 (Procurement Document Control); 17.1.16 (CorrectiveAction); 17.1.17 (QA Records); 17.1.18 (Audits). Theseestablish program commitments.

b. Quality Assurance Manual: QAI-D-2 (Procedure for Indoctrinationand Training); QAI-G (Procedure for Performance of Audits);QAI-E (Procedure for Control of Ncnconformances and CorrectiveAction); QAI-F (Procedure for Control of QA Documents); QAII-C(Interface Control Procedure); QAII-D (Engineering and DesignVerification Procedure); QAII-B.1. (Procedure for Preparationof Q-List); QAII-B.2. (. Technical Data Input Procedure);QAII-B.4.1. (Analyses and Calculations Procedure - PcwerDivision); QAII-B.4.2. (Analyses and Calculations-StructuralDivision); QAII-B.7. (Safety Analysis Report Procedure).

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These procedures provide detailed requirements to implement topicalcommi tmen ts.

c. Gibbs and Hill Project Manual, including EDP-5 (TechnicalCalculations Procedure) and EDP-10 (Use and Control ofComputer Programs). These procedures provide detailedrequirements to implement topical commitments.

d. Project Guide for GIBBSSAR, Revision 0 dated September 1,1978, nich identifies applicable sections of the QA Manualand Project Manual above, any exceptions taken, and projectunique requirements.

e. Documents to verif y implementation of topical comitmentsand procedural requirements in the area of audits andcorrective action:

(1) Audit of GISBSSAR activities issued May 2,1973. Thisis the only audit that has been performed, and consistsof thirteen parts and attached deficiency forms coveringthe activities of:

(a) Nuclear Analyses and Calculations

(b) Nuclear Engineering

(c) Project Administration

(d) Applied Mechanics Engineering

(e) Structural Engineering

(f) Electrical Engineering

(g) Instrumentation and Control Engineering

(h) Shielding Engineering

(i ) Shielding Calculations

(j ) Chemical Services Engineering

(k) Chemical Services Calculations

(1) Mechanical Calculations

(m) Mechanical Engineering

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(2) Responses to audit findings; saluation (where available);memo dated June 30, 1978 rejecting c. rtain responses;memo dated November 21, 1978 requesting response;and a memo dated December 13, 1973 accepting certainresponses.

(3) Auditor qualifications for one auditor.

(4) Audit schedules of GIBBSSAR for 1978 and 1979. Noprior schedules were available.

(5 ) Scheduling of verification activities for aboveaudit deficiences and responses. This schedule wasissued December 13, 1978.

f. Documents to verify implementation of topical commitmentsand procedural requirements in the area of training:

Training records for QA Seminar and Nuclear EngineeringCourse and/or Structural Engineering Course for seven (7)GIBBSSAR project-assigned personnel.

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g. Documents to verify implementation of topical commitmentsand procedural requirements in the area of design:

(1) Safety Analysis Report Signoff Record (Form F 787)authorizing publication, signed by the originatingdiscipline job engineer, supervisor (as applicable),chief engineer, supporting (i.e. interfacing) disciplines(as applicable), project manager, and quality assurance;Verification Record (Form F 782) signed by independentreviewer, and applicable checklists, for the followingGIBBSSAR Chapters / Sections:

(a) Section 3.9 - Mechanical Systems and Ccmponents:Arrendment 2 and Amendment 4; Table 1.9-3 ofAmendment 4; Table 3.9-2 of Amendmen. 7. Thecurrent SAR (to Amendment 7) was also checked forinclusion of all approved revised sections andtables.

(b) Qualifications of independent reviewer for theabove section.

(c) Section 3.8-Design of Category 1 Structures(Containment): Subsection 3.8.1.6.e.1 ofAmendment 3; Figures 3.8-1, 3.8-2, 3.8-3 and3.8-4 of Amendment 3; Figures 3.8-1A, -1B, -1C,-10, -1E, -1F, -1G, -1H 2 & 3 of Amendment 6.

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(d) Section 6.3 - Emergency Core Cooling System(ECCS): Original issue (showing this as ilSSSscope); Subsection 6.3.1 of Revision 5 (interfaceinformation).

(e) Section 3.7 - Seismic Design: Original issue,Amendment 4, and A:rendment 5; Figure 3.7-18 ofAmendment 5; Subsections 3.7.1.4, 3.7.2.1, 3.7.3.12b,and 3.7A, Revision 6. Text of the SAR was also checkedfor inclusion of approved revised sections.

(f) Chapter 7 - Instrumentation and Controls: Originalissue and Arrendment 1; Section 7.7 of Arendment 4.

(g) Spot check for above approval documents fororiginal issue of Chapters 1, 2, 4, 8, and 12.

(2) Calculations examined for checker's initials, requiredapproval, and check lists F870 and F769 (as applicable):

(a) Calculation t1C-AA-03 - Control Room Dose Analysis(input to TACT IV computer code program used forLOCA (Loss of Coolant Accident) analysis inChapter 15, pages 15.6-15.12).

(b) Calculation t;C-AA-13 (input to TACT IV and graphs15.6-5 through 15.6-18). Approvals were checked forFigures 15.6-7, 15.6-8, 15.6-14, 15.6-17, and15.6-18 which were generated from input from flC-AA-13fed into TACT IV program.

(c) Calculation t;C-AA-20 - Droplet Distribution andgraph which became Figure 6.5-3 of A:rendment 5.

(3) Computer Codes used in GIBBSSAR checked for verificationstatus and records (see also paragraph 3.h.(4) belowfor addition informatinn):

(a) QUAKE: verification done but not yet reviewed,approved and filed in house -(verified by STARDYNEand hand calculations).

(b) TIME: verification done but not reviewed, approvedand filed yet (STARDYliE used to verify).

(c) SCONV: verification done but not reviewed, appoved,and filed yet (IBM program CSMT used to verify).

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(d) SPECTRA: verification done but not yet reviewed,approved, and filed (Verification by comparison ofcomputer output with spectrum curves).

(e) LCOL: verification complete (by hand calculation).

(f) GALEGAS and GALELIQ: source was NRC, modifiedin h .se. Verification is complete (verified bysample pragram in user's manual).

(g) AtilSN: used for Fort Calhoun 1. tio verificationexcept standard use.

(h) KALNINS: used for Fort Calhoun 1, No verificationexcept standard use.

(i) NASTRAN: Public domain. Used by NASA. Noverification except standard use.

3. Findings

a. In this area of the inspection, three (3) deviations wereidentified (See Notice of Deviation Enclosure, Items C. ,D., and E.) No unresolved items were identified.

b. Concerning Notice of Deviation Enclosure, Item E. , prior tothe conclusion of inspection, management obtained correctiveaction replies from three (3) departments / disciplines, andscheduled folicw up action dates for five (5) departments /disciplines. However, measures to prevent recurrence ofthis type of deviation have not yet been addressed by Gibbsand Hill.

c. QA program requirements appear in GIBSAR-17 and in applicableprocecures listed in paragraph B.2.b. above.

d. The project organization is headed by a Project Managerand an Assistant Project Manager. The QA function is beingperformed by the Gibbs and Hill QA Manager. The projectgroup includes Job Engineers / Supervisors assigned for eachdiscipline to perform GIBBSSAR functions. No consultantshave been used, by report.

e. No procurement activities have been perfor .ed for theGIBBSSAR project, by report.

f. GISBSSAR records are considered preliminary by Gibbsand Hill until final acceptance by NRC. Hence allGISBSSAR records are handled as " working documents" andhave not come under the QA records procedures or controls

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requiring duplicate storage. In general, they are maintainedin working areas in single, non-fireproof files. On thisproject, the documentation will be duplicated wnen NRC acceptsGIBBSSAR, by report.

g. The status of the project is that the original submittal wasmade to the NRC on October 15, 1976, and docketed on May 2,1977. Revision 7 has been generated and sent to NRC, andRevision 8 will be submitted approximately December 18, 1978.First round questions frcm the NRC for Electrical and PowerSystems are expected in January,1979, and the projectedPreliminary Design Approval (PDA) by NRC is anticipated forJanuary 15, 1980, issuance.

h. All audit findings identified by Gibbs and Hill duringtheir April audit of GIBBSSAR activities issus in May,1978 are still open. These have not been re-identified asnew findings by the NRC inspector since they have alreadybeen identified by Gibbs and Hill. However, they doappear to include significant items, such as:

(1) Project Q-List not prepared or issued.

(2) DDIRs (Design Data Input Records) not generated and/ornot maintained properly by a number of disciplines.

(.3 ) Certain shielding calculations not submitted for designverification.

(4) Certain computer programs do not have verificationrecords. (The procedural requirement became effectiveMay, 1977. Prior programs generally did not haveverification records, although some are being generatedat present, as was verified by the NRC inspector).

(S) Several calculations were identified that were notchecked or not approved by job engineer. An index ofcalcs had not been prepared by Chemical Services.

(6) No Project Guide had been issued. (NRC inspectorobserved that it was subsequently issued on September 1,1978).

Further review will be made during a subsequent inspectionto assure that verification and closure have been performedby Gibbs and Hill for the deficiencies identified by Gibbsand Hill during their audit issued May 2,1978.