ML17277A411
| ML17277A411 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/10/1983 |
| From: | Laney R, Roddis L, Sheets H TECHNICAL AUDIT ASSOCIATES, INC. |
| To: | |
| Shared Package | |
| ML17277A410 | List: |
| References | |
| NUDOCS 8301250327 | |
| Download: ML17277A411 (69) | |
Text
REPORT OF -AUDIT of the WASHINGTON PUBLIC PONER SUPPLY SYSTEM'S PLANT VERIFICATION PROGRAM FOR NNP-2 performed by TECHNICAL AUDIT ASSOCIATES, INC.
AT RICHLAND,
$0ASHINGTON ON NOVEMBER 19-22, 1982 January 10, 1983 APPROVED:
R. V. Laney L. H. Roddis, Jr.
B. K, H. E. Sheets 830i250327 830i20 PDR ADOCK 05000397 A
CONTENTS 4
Summary of F'ndings and Observations Introduction Opening Session Pacae 1
Design Reverification Program Construction Quality Verification Program Construction Quality Assurance Effectiveness 15 20 Plant Performance and Operating Envelope Verification 23 ATTACHMENTS A.
Audit Agenda B.
Persons Interviewed C.
TAA's Pre-Audit Questions D.
Documents Reviewed by TAA Before Audit E.
Documents Reviewed by TAA During and After Audit F.
Biographical Information on TAA Audit Team
Survmar of Findin s and Observations*
The Findings from this audit are stated below, together with a page number reference to the text.
Based on a review of documents in the S.S.'s files, we believe that the Supply System personnel engaged in design reverification activities and members of the Findings Review Committee meet the criteria for assessing independence set forth in the S.S.
memorandum of June 30, 1982.
(page 7)
Finding No.'
All three design reverification plans should give greater consideration to system-to-system interactions.
We recommend that a spot check be made of the adequacy of those portions of important interfacing systems which are vital to the functioning of the three systems being reverified.
(page 10)
The S.S.
should incorporate in the reverification process for each of the three systems a way of showing clearly how FSAR design commitments are reflected into engineering requirements documents, and into final detail design.
(page ll)
"'See Introduction, which follows, for discussion of these terms.
Findin No.
4 The S.S.
should select and validate the design of a small number of A-E specified, plant specific, pre-
'urchased components from the three systems, checking on vendor design and A-E review of vendor design.
1 (page 12)
Findin No.
5 Xn view of the significant number of additional loads which have been added to floors and bulkheads since they were originally designed, especially the additional loads represented by piping supports and restraints, we believe that the S.S.
should make a spot check of a selected heavily loaded area to determine if the original structural desi'gn is still adequate.
The bulkhead which supports the Main Steam Isolation Valve may be an appropriate example for this purpose.
(Page 14)
We recommend that QVZ-09 be revised to make clear that its purpose is to permit, with the A-E's case-by-case approval, certain specific deviations from the AWS Dl.l code when found upon reinspection in selected applications.
Xf this were done, we would see no objection to its use as a basis for disposing of the specified deviations.
We recommend also that the Supply System clarify whether QVl-09 is intended to apply to the sacrificial shield wall and pipe whip restraints.
(page 17)
Finding No.
7 The apparent coincidence of discontinuing film quality review of WBG radiographic film, coupled with the subsequent decline in the percentage of welds actually rejected for weld quality should be investigated by the S.S.
and the results documented.
(page 18)
If it is true that the Burns and Roe team engineer has authority to accept or reject structural welds which do not meet the acceptable deviation criteria of QVI-09, we believe that this authority should be withdrawn and that such decisions should be referred to the responsible B&R structural design supervisor.
(page 19)
The Observations from this audit follow, together with a page reference to the text.
Observation No.
1, The S.S.
should consider incorporating into the design reverification program a separate check of the effectiveness of the as-built drawing program, both as to its time-liness for producing as-builts and as to their accuracy in reflecting the actual plant hardware as installed.
(page 13)
Observation No.
2 N'e believe that dealing wi'th the uncertainties of turbine disc cracking requires a total systems
evaluation, including water chemistry, turbine operation, and condenser leakage.
In its turbine planning, the S.S.
should determine as exactly as possible the conditions obtaining in other turbines on which it is relying for its strategic planning model, and compare those conditions with the conditions which can realistically be maintained for the NNP-2 turbine.
Until this has been done and the data analyzed, the S.S.
should be cautious about assuming three years of satisfactory service.
(page 22)
Observation No.
3
\\
TAA believes that the present period of transition of design responsibility from Burns and Roe to S.S.
Technology is a time of exceptional vulnerability for configuration control, and that additional means should be explored and adopted to assure that Generation and Technology have adequate and continuing inter-ties.
(page 23)
AUDIT REPOB.T Introduction The Washington Public Power Supply System retained Technical Audit Associates, Inc. to, first, review and com-ment on the Supply System's Plant Verification Pxogram Plan (PVP), and,
- second, to a'udit its implementation.
TAA's review of the PVP was completed and our final report on the plan submitted on August 6, 1982.
TAA is now engaged in auditing the Supply System's implementation of the PVP, an activity which will continue until readiness for fuel load in August, 1983.
Ãe have been asked to give principal attention to those portions dealing with the reverification of design, the Quality Verification Program (QVP), which addresses the quality of construction before July,"1981, and the effectiveness of management actions to resolve quality problems arising since July, 1981.
The h
ultimate objective of this continuing audit is to enable
- TAA, at the conclusion of the PVP and before fuel load, to state a knowledgeable opinion on the adequacy of implementation of the PVP and the extent to which it provides substantive con-firmation that NINP-2's design and construction comply with applicable Regulatory and Safety Analysis Report commitments.
To assist the TAA panel to prepare for this audit, the panel chairman selected a number of internal Supply System documents which were sent to each panel member and the two panel consultants.
These documents are listed in Attachment D.
Based on a reading of these documents, panel members
l prepared and forwarded in advance to the Supply System a num-ber of questions which provided a framework for the on-site
- audit, November 19-22, 1982.
These questions are appended as Attachment C.
Additional documents were reviewed by the TAA panel during and after the audit.
These are listed in Attachment E.
The audit agenda is appended as Attachment A, and a list of the persons interviewed as Attachment B.
All agenda items were taken up during the audit.
With the exception of Dr.
Salomon Levy, all TAA panel members and consultants shown on Attachment F were present throughout.
In the preceding Summary and throughout this report we have used either a Finding or an Observation to present our conclusions and recommendations.
A Finding is a conclusion or recommendation which, in our opinion, is sufficiently im-portant to require a formal response from the Supply System, leading either to a mutually satisfactory disposition or to continued dialogue.
Each Finding should be formally resolved.
An Observation is a conclusion or recommendation of lesser importance for which no formal resolution is expected.
0 enin Session The opening session was attended by representatives of the Managing Director, Technology, Quality Assurance, Generation, Licensing, the QVP program, the NNP-2 Project/
and the TAA Panel.
A vue-graph presentation was made by S.S; personnel of the status of PVP implementation.
Questions Number 3, 7, 9, ll, 13, 16, 17, 20, 21, and 23 (see Attachment C) were dis-
- cussed, and satisfactory answers were received.
Following this opening session, the Panel was supplied a file showing the steps which the S.S.
has taken to assure that personnel
'I engaged in the design verification portion of the PVP pro-r gram meet the S.S.'s "Criteria for Assessing Independence",
dated June 30, 1982.
Findin No.
1 Based on a review of documents in the S.S. 's files, we believe that the Supply System personnel engaged in design reverification activities and members of the Findings Review Committee meet the criteria for assessing independence set. forth in the S.S.
memorandum of June 30, 1982.
Desi n Reverification Pro ram The design verification audit was divided into two parts.
In part one, Duane Renberger, John Yatabe, and D.
Whitcomb reported on the status of the program and answered and discussed TAA Panel questions number 1,
2, 4,
S, 6,
8, and 14 (see Attachment C).
In part two, the TAA Panel met separately with the team responsible for reverifying the requirements and design of the High Pressure Core Spray System (HPCS).
By meeting with the team members
- alone, we were able to learn of team viewpoints and attitudes free of management constraints.
Part one, the discussions with Technology management, related to program schedule, the adequacy of personnel re-
- sources, and the structure of the HPCS Reverification Plan.
(Reverification plans for the Residual Heat Removal System (RHR) and the Reactor Feedwater System (RFW) were available at the time of the audit, but not before.
Hence the audit focused on the HPCS plan.)
John Yatabe made a vue-graph presentation covering pro-gram objectives,
- schedule, and process flow.
He discussed system selection, requirements reverification, the selection of sampling criteria, and the performance of reverification.
TAA Panel members expressed the importance of considering system interactions, such as the potential for HPCS system to be flooded by a break in another
- system, or to be flooded by intentional operation of the fire protection system.
Following its subsequent review of all three of the system reverification plans, the Panel notes that, the follow-ing words appear, in slightly different form, in each:
"Incorporation of primary requirements necessary for proper functionin'g of the HPCS (RFN, RHR) system,
- then, such as requirements for cooling, flood and fire pro-tection, pipe whip restraint, missile protection, etc.,
will only be reverified to the point of assuring that provisions have been incorporated into the plant design r
via some other systems to accommodate those requirements.
The, systems provided to accommodate these interface re-quirements will not be reviewed for adequacy as part of this effort.
This approach will provide confidence'on a "spot check" basis that the remaining systems are designed correctly."
(See HPCS Plan, page 1-25.)
We understand but are not convinced that this conclud-ing assertion is justified. It assumes that the systems being reverified are typical of the remaining systems, and that reverifying the selected systems validates the design process as well as the design of the remaining systems.
This seems to overlook the fact that the systems selected for validation were designed largely by GE, whereas the inter-facing systems of concern, such as fire protection, compart-ment drains, HVAC, and pipe whip restraints are plant-specific and hence were probably designed by the architect-engineer.
In addition, system interactions occur not only between systems
I which are physically interconnected, but also between systems which share a
common space or area.
A number of the inter-facing concerns involve such system-to-system spatial rela-tionships, such as acce'ssibility for maintenance",
hazard from fire protection flooding, and missile hazards.
We believe that the S.S.'s present interpretation for all systems of System Design Review Question No.
11 (HPCS page 1-10, Table l-l) is too narrow, and that a spot-check should be made of the adequacy of those portions of im-portant interfacing systems, where those interfacing systems are vital to the functioning of the
All three design reverification plans should give greater consideration to system-to-system interactions.
We recommend that a spot check be made of the adequacy of those portions of important interfacing systems which are vital to the functioning of the three systems being reverified.
Responding to a question on the major FSAR commitments, Yatabe presented and discussed a document titled, "Design Verification", which describes the process linking the FSAR, engineering requirements documents, and the detailed design.
The TAA Panel understands that both sections A and B of this document will be followed for each of the three
- systems, HPCS,
Some members of the TAA
- Panel, however, found that the HPCS plan gives insufficient visibility into how design commitments are incorporated into engineering requirements documents, and how they are ultim-ately verified by the design verification check lists in the Plans, with the result that external observers, including N
S.S.
- managers, may find it difficult to understand the Plan's logic.
A specific suggestion on this point was offered by Charles Miller, TAA consultant,'for S.S.'s consideration.
Pindin No.'
The S.S.'should incorporate in the reverification process for each of the three systems a way 'of showing clearly how FSAR design commitments are reflected into engineering requirements documents, and into final detail design.
In discussing the system level and component level sampling matrices which appear in the HPCS plan, TAA members asked whether the S.S.
intended to reconfirm the adequacy of design of various pre-purchased components.
The S.S.
pointed out that most of the components in the systems being reviewed were specified by GE as NSSS supplier, and have been
- used, and hence validated, on other earlier plants.
Gener-ally, the HPCS plan does not provide for reconfirming the de-sign of vendor supplied equipment.
The TAA Panel suggested that the design of some A-E specified, plant-specific, pre-purchased components ought to be reverified as part of the total process.
The Panel notes also that some components in the three systems being, reverified will receive their principal design and construction validation through the test program.
Findin No.
4 The S.S.
should select and validate th'e design of a small'umber of A-E specified, plant specific, pre-purchased components from the three systems, checking on vendor design and A-E review of vendor design.
Yatabe gave the KAA Panel a handout showing the pro-fessional experience of each member of the three reverifica-tion teams.
The Panel noted that the teams could be strengthened by, the addition of persons having system design experience.
Part two of TAA's audit of design reverification was an, interview with the six members of the HPCS team, under the
'eadership of Paul Macbeth.
Principal topics of discussion were the selection of the sampling points (who made the selec-tions and why); the need for considering system interactive ef ects; and how independent the team members feel as they go about their reverification tasks.
Team members described the logic for their own selection of the sampling points, making clear that the choice had been largely delegated to them.
They showed a good understanding of the purpose of the program and gave convincing justification for the sampling points chosen.
It appeared to the Panel that system interactions had not weighed as heavily in plan preparation as would be desirable.
The S.S.
team members exhibited an understanding of the need for total objectivity in their work.
They made clear to the Panel that they have been given complete freedom to perform their reverification tasks in a manner which satis-fies their own professional standards-.
The TAA team learned in the course of the above dis-cussions that verification of the timely completion of as-built drawings is not currently a part of the HPCS plan.
This led to the following observation.
Observation No. l The S.S.
should incorporate into the design rever-ification program a separate check of the effectiveness of the as-built drawing program, both as to its time-liness for producing as-builts and as to their accuracy in reflecting the actual plant hardware as installed.
During the plant tour, TAA team members were struck by the massive weights, heavy structural loads, and access congestion caused by pipe and equipment restraints and sup-
- ports, many of which have been added to the plant after the initial structure was designed.
This observ'ation led to a question of whether the original loadings which had been assumed in designing floors and bulkheads may now have been exceeded and whether the original structural design is now satisfactory.
In view of the significant number of additional loads which have been added to floors and bulkheads since they were originally designed, especially the additional loads represented by piping supports and restraints, we believe that the S.S.
should make a spot check of a selected heavily loaded area to determine if the original structural design is still adequate.
The bulkhead which supports the Main Steam Isolation Valve may be an appropriate example for this purpose.
Construction Qualit Verification Pro ram Messrs.
R. Knawa, C. Anderson, and R.
Ramsgate of the Supply System and N. Leach of Bechtel gave TAA. an informal presentation on the status of the QVP program.
TAA was given handouts on overall program status and on Contract 215 (NBG) system completion status.
ln addition, contract completion
- reports, deficiency disposition reviews, and the reevaluation of personnel qualifications were discussed.
TAA questions number 31 and 32 were answered.
TAA members commented that the several QVP audit reports and contractor completion reports which we have reviewed seem to have one common feature, namely, that none of them reports finding any significant quality deficiencies in work done before July, 1980.
Since a ten percent sample of safety related hardware is being reinspected as part of the QVP pro-
- gram, the virtual absence of significant defects might seem surprising.
Knawa pointed out that a number of hardware defects had already been identified at the time of work stop-page.
He suggested that the small number of additional de-fects which have been found is due to the fact that most of the problems were already known when work was stopped in 1980.
Leach reported that the principal problem which has been encountered in verifying QA documentation, especially construc-.
tion contractor documentation, was locating and assembling verification records for an entire system, since the relevant documents had ori'ginally been filed by date of origin rather than by system.
A large amount of relocating and resorting work has been required, but it has generally succeeded in locating the correct records.
In discussing the ten percent reinspection of structural steel welds, the TAA team was informed of and discussed re-I verification instruction QVI-09 "Special Structural Steel Reinspection Criteria", dated May 13, 1982.
The TAA Panel raised several questions concerning QVI-09 which were not I'atisfactorily answered during the audit.
Subsequently, the Supply System furnished additional information by letter D. C. Timmins to R. V. Laney of December 2, 1982, and by letter J.
R.
Honekamp to R. V. Laney of December 22, 1982.
Our review of QVI-09 and the information contained in these letters reveal the following:
(a)
QVI-09 authorizes the A-E field engineer to make generic dispositions of certain specific deviations from ANS Dl.l when found in selected weld applic-ations during reverification inspections.
(b)
Nhile QVI-09 is currently being used to determine the acceptability of discrepancies found during reverification inspections, it may also be used, under the A-E's direction, to disposition devia-tions of the same type found in new construction.
(c)
The text of QVI-09, especially the eight page "Justification," makes the document appear to be a significant revision of the ANS code, rather than merely an identification of specific accept-able deviations.
(d)
The Supply System intends to inform the NRC of QVX-09 as part of Amendment 27 to the SAR.
(e)
The draft notification attached to the'onekamp letter referred to above, to be forwarded with Amendment 27, appears to be'nconsistent with QVl-09 with respect to its applicability to the sacrificial shield wall and pipe, whip restraints.
(Compare para.
3.1, page 2, Attachment 2 to QVI-09, with the final sentence of 'the draft notification to be a part of Amendment 27.)
The TAA Panel inspected several examples of,welds which had been inspected and accepted to QVX-09 criteria during a tour of the plant.
Ne recommend that QVX-09 be revised to make clear that its purpose is to permit, with the A-E's case-by-case approval, certain specific deviations from the ANS Dl.l code when found upon reinspection in selected applications.
lf this were done, we would see no objection to its use as a basis for disposing of the specified deviations.
Ne recommend also that the Supply System clarify whether QVI-09 is intended to apply to the sacrificial shield wall and pipe whip restraints.
TAA raised a question concerning the discontinuance of review for film quality as a basis for accepting certain WBG radiographic film, referred to in an S.S. letter to the NRC of September 1,
1982, concerning reportable condition No.
175, ~
(See TAA question number 45, Attachment C.)
This question was discussed with Mr. Knawa and, in a subsequent
- meeting, with Mr. Roger Johnson, WNP-2 Q.A. Manager.
Based on these discussions and on review of Bechtel's explanatory letter BEC WNP-2 0437 of April 22I 1982'he Panel concluded that there was justification for 'discontinuing the film quality review.
However, it was noted (S.S. letter to NRC of C
September lg 1982I Attachment A, p.
(65 of 1373) to 1.21%
(16 of 1317) after discontinuance of film quality review, with no apparent reason.
TAA believes that this anomaly needs to be reconciled in order to demon-strate that it is not due to discontinuing the film quality review.
Findin No.
7 The apparent coincidence.of discontinuing film quality review of WBG radiographic film, coupled with the subsequent decline in the percentage of welds actually rejected for weld quality should be investigated by the S.S.
and the results documented.
TAA discussed the "team concept" for reverification in-spection which is being used by the S.S.,
described in QVI-08f
1 "Reverification Inspection Team Concept",
dated Hay 13, 1982.
One member of the reinspection team is a Burns and Roe Design Engineer who is responsible for "accepting or rejecting those items judged by the Bechtel Quality Control Engineer as out of tolerance to the inspection criteria."
(QVI-08, page 2, para.. 3.3c)
Discussions brought out that the BGR engineer can accept structural welds provided they conform to the acceptable deviation criteria of QVI-09.
This is a satisfactory practice provided QVI-09 is clarified as recommended in Finding 6.
- However, we were also told that the BGR team engineer can accept structural welds which do not meet the acceptable deviation criteria of QVI-09.
The limits of this authority to accept or reject outside QVI-09 are unclear to us, and are not explained in QVI-08.
If it is true. that the Burns and Roe team engineer has authority to accept or reject structural welds which do not meet the acceptable deviation criteria of QVI-09, we believe that this authority should be withdrawn and that such decisions should be referred to the responsible B&R structural design supervisor.
Construction Qualit Assurance Effectiveness In assessing management's effectiveness in quali'ty assurance since restart in July,
- 1981, TAA discussed various audit reports, audit findings, potentially reportable condi-
- tions, and the timeliness and effectiveness of management's actions when confronted with quality problems.
Roger Johnson, WNP-2 Project Q.A'. Manager, responded to TAA questions numbers 15'8'9'2 24@ 25'7'8@
29 30 44'5'6'nd 47/
which probed into many of these matters.
In addition, as a
specific example, the TAA panel investigated the S.S.
program for dealing with the possibility of stress corrosion cracking in low pressure turbine discs.
Mr. Johnson's reply to the panel's questions were gener-ally satisfactory, indicating that the present, level and competence of quality audit,'urveillance, and inspection by S.S.
corporate Q.A., Project Q.A., and Bechtel Q.A. are satisfactory.
Several minor problems were noted which, when corrected by the S.S, will further improve ongoing quality assurance.
These problems are:
increased project pressure is required to overcome procedural problems causing twelve month old NRC inspection items to remain unclosed.
Project response to quality findings from S.S.
corporate Q.A. audits would benefit from a Program Director level system for tracking such findings until closed.
the Project should exert greater pressure on Burns and Roe to clear up old audit findings.
TAA's discussion with Dr. Shen, John Yatabe, A. McDonald, and W. Bibb on stress corrosion cracking.in low pressure turbine discs explored the attention being given by S.S.
management to this generic problem.
We found them to be in-formed on the current status of this problem, both in the U.S.
and abroad.
Answers were provided to TAA questions 34 through 43.
We learned that a S.S.
plan for minimizing the chances of cracking in the early years of operation is being developed.
The avoidance of unfavorable environmental conditions, especially the presence of oxygen and other impurities in feedwater, is particularly important for a BWR react'or coupled to a Westinghouse turbine.'he specifi'cations for steam purity from the reactor manufacturer may not be entirely compatible with the steam purity prescribed by the turbine manufacturer.
.The Supply System thus faces a complex of problems in, minimizing turbine disc cracking -- water/steam purity control, condenser leakage control, and avoidance of turbine overspeed.
This makes it quite important, as the S.S.
recog-
- nizes, to make the best use of available operational experience elsewhere (for example, Taiwan),
and to continue the present program of identifying and locating spares and defining a long range strategy.
TAA believes the S.S.
needs to obtain additional detailed information concerning the specific turbines which they are using as models to assist them in developing their strategic plans.
Such information as elapsed time between manufacture and first operation, as-built dimensions and stresses for shrink fits, and feedwater steam purity operating history would be useful.
Without data of the kind indicated, there does not appear to be adequate justification for the S.S.'s present optimistic assumption that they can expect three years of satisfactory service.
Observation No.
2 We believe that dealing with the uncertainties of turbine disc cracking requires a total systems evaluation, including water chemistry, turbine operation, and condenser leakage.
In its turbine planning, the S.S.
should determine as exactly as possible the conditions obtaining in other turbines on which it is relying for I
its strategic planning model, and compare those conditions with the conditions which can realistically be maintained for the WNP-2 turbine.
Until this has been done and the data analyzed, the S.S.
should be cautious about assuming A
three years of satisfactory service.
Plant Performance and Ooeratin Envelo e Verification Xn discussing the status of operating procedures prep-aration with J.
D. Martin, the Panel noted that, with over one thousand plant operating procedures now written, the Generation staff appears to be far ahead of Technology,'which is still collecting tne System Technical Turnover Packages (STTP).
We raised the following question:
how will, the S.S.
assure that the systems which are reflected in Operating Procedures are exactly the same as the systems reflected in the STTP's, these latter being of a later vintage?
Xt has been noted elsewhere that operating plants experience diffic-ulty keeping system descriptions. in 'their engineering files current with the actual hard<are because of continuing system changes.
Messrs.
Martin and Cowan pointed out that Generation and
'I Technology both draw upon the same information source, namely Burns and Roe's Design Control Log, which contains the latest design information.
- Hence, Generation's system descriptive material should match with Technology's.
They also stated that Generation and Technology coordinate with one another' activities in various ways, and that both are in the approval circuits for materials prepared by the other.
Finally, it is intended that Technology will have staff members at the plant site to assure close liaison.
Observation No.
3 TAA believes that the present period of transition of design responsibility from Burns and Roe to S.S.
Technology is a time of exceptional vulnerability for
.configuration control, and that additional means should be explored and adopted to assure that Generation and Technology have adequate and continuing inter-ties.
During the Panel's discussions with Messrs., Martin, Afflerbach, and Cowan, answers were provided to TAA question numbers 10, 12 and 33.
Xn the matter of Burns and Roe's responsibilities in the test program (question number 12),
we understand that, although there is a satisfactory working agreement, the S.S.
has not yet prepared a written confirma-tion, but intends to do so.
The TAA Panel will want to review this document when it is complete.
During the session on Performance and Operations, Doug Timmins gave the TAA Panel a brief account of the work of the independent Electrical Separation Task Force, whose work is to be completed in January, 1983.
The TAA Panel has requested that the Task rorce report be sent to us for information.
TECHNICAL AUDIT ASSOCIATES, INC., AUDIT November 19, 20, 21, and,22, 1982 AGENDA
- Frida, November 19, 1982 8:00 a.m.
TAA Executive Session Hanford House 10:30 a.m.
Opening Session with Supply System Supply System, Snohomish Room Scope of Audit Agenda - who will be addressing TAA's initial inquiry areas Program Status and Summary of NRC meeting on Plant Verification
Response
to TAA inquiry areas of a mole general nature R.
V. Laney J.
R.
Honekamp J.
R.
Honekamp J.
R.
Honekamp/
D. L. Renberger/
J.
M. Yatabe/
R. T. Johnson 12:00 N
1:30 p.m.
2:30 p.m.
gA Audit Program responsibilities for conduct of audits, tracki ng of findings, evaluation of responses LUNCH Status of Requirements and Design Reverification Supply System, CDC Bldg.
Interview High Pressure Core Spray (HPCS)
System Team Supply System, CDC Bldg.
R.
B. Glasscock/.
R. T. Johnson D. L. Renberger/
J. J. Yatabe P. J.
MacBeth/
et al
Page 2
TAA Audit a
Saturda
, Hovember 20, 1982 8:00 a.m.
guality Verification Program MHP-2 Site; Trailer 30 R. L. Knawa 10:00 a.m.
3:00 p.m.
Status report on gVP, including system completion, prepurchase and inactive site contracts, and special tasks.
Identify problems found and actions taken.
Performance as compared to schedule.
Show the significance of gVP findings to the quality of work performed before 1980 shutdown.
Project guali ty Assurance MHP-2 Site, Trailer 56 (Includes working lunch)
Review of selected quality problems which have arisen since 1981 startup, emphasizing Supply System management method of dealing with the problems and the effectiveness of thei r actions.
TAA has submitted a number of questions based on their review of documents transmitted to them.
The intent is not for TAA to track each item to closure but rather by examining a number of examples to assess the effectiveness of management action to resolve quality problems identified since restart.
ltHP-2 Tour R. T. Johnson J.
R. Honekamp/
Shift ttanager (22eZ)
Su~nda,
.'nova.-bar 21, 1982 a.m.
TAA Executive Session Hanford House 1:00 p.m.
Presentation of Supply System Plans for Dealing with Stress Corrosion Cracking of the Discs in the '.festinghouse Hain Turbine Supply Sys tern, Shen '
Conference Room 2-212 P.
K. Shen/
D. L. Renberger/
et al
Page 3 ;
TAA Audit 1
V Monda
, November 22, 1982 8:00 a.m.
Interviews with the Plant Staff on the Process for and the Status of the Preparation,
- Review, and Approval of Plant Procedures and Technical Specifications WNP-2 Site, Service Bldg. Conference Room J.
D. Martin/
C.
M. Powers/
K. D. Cowan/
L. H. McGilton 9:30 a.m.
10:00 a.m.
Overview of Electrical Separation Task Force Activities WNP-2 Site, Service Bldg. Conference Room Interviews with Test and Startup on the Status of the Test Program and the Process for Review and Approval of Test Procedures and Test Results WNP-2 Site, Service Bldg. Conference Room D. C. Timnins G.
K. Afflerbach/
D.
C. Timmins/
D.
M. Myers 1:00 p.m.
TAA Exit Interview Supply System, Ferguson's Con erence Room D.
R.
W.
R.
P.
J.
W. Mazur/
G. Matlock/
C. Bibb/
B. Glasscock/
K. Shen/
R.
Honekamp
LIST OF PERSONS INTERVIEWED DURING TAA ON-SITE AUDIT, NOV. 19-22, 1982 Carl Anderson, QVP Program, S.S.
G. K. Afflerbach, Test and Startup Mgr., WNP-2, S.S.
W. C. Bibb, Director of Power Generation, S.S.
Jack Cole, HPCS Team Member, Technology, S.S.
K. D. Cowan, Technical Mgr., WNP-2 Operations R. B. Glasscock, Director Licensing and Assurance, S.S.
J.
F. Gorman, HPCS Team Member, Technology, S.S.
J.
R. Honekamp, Technical Asst.,
Managing Director, S.S.
T.'. Houchins, Manager of Audits and Surveillance, Corp.
QAg S ~ S-R. T. Johnson, Manager of QA, WNP-2, S.S.
T. H. Keheley, HPCS Team Member, Technology, S.S.
R. L. Knawa,
- Manager, Qual. Verification Prog.,
S.S.
M. N. Leach, Bechtel Supervisor, Qual. Verification Prog.
Paul J. Macbeth, HPCS Team Leader, Technology, S.S.
J.
D. Martin, WNP-2 Plant Manager R.
G. Matlock, Director WNP-2 Program, S.S.
D.
W. Mazur, Director Operations, S.S.
A. McDonald, Plant llgr., Hanford/Packwood Generation/
SOS.
Dennis Meyers, Test Working Group Member, WNP-2 Eng.g SOS.
Adolfo B. Rafer, HPCS Team Member, Technology, S.S.
R. Ramsgate, QVP Program, S.S.
D. L. Renberger, Dep. Director, Technologyf SOS.
P.
K. Shen, Director Technology, S.S.
G. C. Sorenson, Manager Licensing Programs, S.S.
David T. Thonn, HPCS Team Member, Technology, S.S.
D. C. Timmins, Tech. Asst.,
WNP-2 Proj. Mgr., S.S.
D. L. Whitcomb, Reverification Lead Engineer, S.S.
J.
M. Yatabe, Asst. Director Systems Engineering, Technology, S.S.
LIST OF PERSONS PRESENT AS OBSERVERS ONLY W. Chin, Bonnville Power Authority (partial attendance)
Richard A. Feil, NRC, Resident (partial attendance)
Benjamin Reusche, Bonnville Power Authority (exit interview only)
A. D. Toth, NRC, Resident (partial attendance)
0 TAA Questions Page 3
page one:
second bullet refers to "actual"'eview of test procedures extending bey'ond criteria to the complete procedure,"
but calls this "unstructured" with "no disposition of...comments...reauired."
Can the S.S.
be satisfied with "no disposition" of AE comments?
page two:
final paragraph does not commit Burns Roe to review and approve test results, nor does it relate test results to certification.
The allusion to "ability to certify" is unclear to us.
Ne continue to believe that there should be a more explicit statement of the AE's responsibilities in the Performance Verification (Test)
- Program, and that it should include review and acceptance of test results.
13.
bhat information is in hand to show that design reverific-ation personnel meet S.S.
independence criteria'P 3.4.
Reouest design reverification personnel who address the TAA panel to describe briefly the professional qualifications of their tgam members.
A'iTACH.'iENT C A
TAA QUESTIONS FOR NNP-2 PVP AUDIT, OCTOBER 13-15 (Set 51) 1.
Design reverification program schedule.
-Has a complete schedule been established?
Has the actual program met the schedule from start to October 1982?
Is the program ahead or behind schedule?
How does the complexity of systems or components affect'schedule?
2.
Burns
& Roe documentation.
Has any deficiency been found in the Burns
& Roe docu-mentation'?
Has Burns
& Roe supplied the needed docu-mentation for the transfer of engineering information to the Supply System?
Are Burns
& Roe system descrip-tions complete and have Burns
& Roe drawings the latest revisions?
How many deficiencies have been found?
3.
System Technical Turnover Package.
This identifies a complete and thorough documentation.
How mucn additional work by the Supply Syst: em is required in addition to the technical information supplied'y Burns
& Roe?
4 System Technical Turnover Package SDE Instruction 3.1, Attachment
- 4. 1.
The following statement is made:
"The Engineer has reviewed the following items in suf-completeness of the data/information pertaining to this system."
Are the underlined adjectives necessary'?
It is suggested tnat they be omitted.
5.
Design Reverificat'on SDE Instruction 3.5, pages 2,
35, 26, 27.
hnat is the percentage of reverification by:
a) b)
c) design review alternate calculations component testing On wnat basis is a selection made among the above 3 methods?
Ques t.ions Page 2
~
~
6.
Design Reverification SDE Instruction 3.5, Page l.
2.3 Potential Finding:
How many potential deficiencies have been refound out of how many systems and components' 7.
Design Requirements Has agreement been reached regarding the value of seismic loads' 8.
System and Component Interference.
As part of the reverification plan, how many interferences of systems or components have been identified?
a Hanufacturing Q.C.
1 During design reverification walkdowns, how many devia-tions from design drawing have been found in critical areas?
l0.
Turbine, Generator and Pump Readiness for Operation.
The turbines, generator and some pumps have been in-stalled for a considerable length of time.
bhat steps are being taken to check this machinery for full power operation?
The turbines and generator have been rotated for years and the machinery may have deteriorated to some e>:tent.
'l.
System Technical Turnover Package.
Is there a reliable method of tracking and.controlling design'cnanges which are "in process" at the time of turnover of design responsibility' 12.
Burns and Roe letter, Forrest to Holmberg,'f July 30,
- 1982, seems to us to leave several questions unanswered regarding BaR responsibilities in the test program, as follows:
page one:
second bullet refers to "official" scope of review o procedures being limited to acceptance cri"eria.
Is there an "unofficial" scope which differs'
TAA OUJ".S'i'IONS FOR '(;NP-2 PVP AUDIT, OCTOBER 33-3 5 (Set
=;. 2)
(NOTE:
This list supplements Set 51, auestions 1 through 3.4, attached to my letter to J.
R.
Honekamp dated September 28, 1982.)
15.
Refer to Burns
& Roe letter to NRC Region 5, dated August 24,
- 1982, concerning a
10CFR21 potentially report-able condition
",82-04.
has the condiction aescribed
- therein, re3ated to the ECCS pump discharge pressure
- switcnes, discovered as a result of a systematic casualtv analysis program or by accident?
16.
How does the S.S.
assure that design reverification re-viewers do not overlook and fail to report a potential finding to the FRC?
Are the STTps complete enough to give adequate assistance to operating personnel with respect to operating,
- testing, and maintaining the plant?
Can operating,
- testing, and maintenance procedures be prepared by the S.S.
based on the STTP content as described in SDE 3.1?
who checks STTPs for accuracv and completeness?
18.
The prob3 ems identified with NBG welds and radiographs anc the successively wider.
s mpling which the S.S.
found necessary are reported in QVP progress reports to Region V, Nos.
2, 7,
8, 9,
10, and ll.
The l'BG review was reported complete in report No.
11, page 5, with 87.8 percent of radiographs found acceptable, 9.1 percent rejected for ilm auality, and 3 percent rejected for weld auality.
Give the TAA panel a summary report of i BG welding review as it stands now.
Although NBG was the principal contractor responsible for making safety-grade
- welds, we assume it was not the on3y such contractor.
Has the S.S. satis ied, itself respect to the weld and radiograph auality of other on site contractors?
How was this done?
19.
- l. bulletin 82-01 reported e>:amples of altered radio-graphs by AP&E, Inc.
Advise the TAA pane>
of any addi-tional <QiP-2 actions on 82-01, fo owing tne project's interim report to Region V of June 24, 1982.
Bu3.1etin 82-01, Rev.
1, Supplement 1, reported an additional con-tra.:tor/supplier, XTT Grinnell Industrial Piping/ Inc.,
=rom whom altered raniographs have been received by some nuclear plants
(~"NP-2 not included).
Has the S.S.
considered the possib'lity t~ at tnese may e>amples of a generic problem related to safety-grade welds and radiographs received from the shops of off-site suppliers:
For example, were the individual's motivations for altering
t s
radiographs peculiar to the person or shop, or aid they stem from conditions wnich might reasonably be expected to exist elsewhere?
Xs any further inquiry indicated?
20.
What procedures does the S.S.
have in place to assure follow-up and satisfactory close out of action items related to 10CFR21 reportable conditions or 1E bulletins?
21.
The S.S.
has reported difficulty in obtaining access to records of work performed under closed-out contracts.
hhat is the present status?
22.
llost nuclear power plant constru'ctors rece've letters from time to time alleging that certain work has not been performed in a safe manner, or has not followed proper procedures, or that other potentially unsafe conditions exist.
How does the S,S.
handle allegations of this kind?
Are they -investigated and disposed of by some formal process, or are they handled informally.
At what, management level are they handled'
lo/28/82 TAA QUEST IONS FOR WNP 2
PVP AUDIT (Set 53)
(NOTE: This list supplements Set 41, questions 1 through 14, Set 42, questions 15 through 22, previously submitted to the Supply System.)
23.
QA Audit No.82-218 There is no evidence of Project Engzneerzng review of vendor drawin'gs, specifications and other documents.
In addition, the audit does not touch on as-building procedure and policy and, in particular, how these will fit with SS reverification program.
24.
10 CFR 21 Potentiall Re ortable Condition 482-04 What were GE requirements on location of pressure switches for RHR?
Will the reverification program recognize other water hammer findings about BWR RHR systems?
25.
10 CFR 21 Potentiall Re ortable Condition 382-06 How does reverification plan to address separation?
26.
Duplicates Question 20.
27.
hhat is the status of access to the closed out con-tractors'nd suppliers'ecords?
Hy recollection is that
'ome of these QA records are in very poor shape, and in others, unobtainable.
28.
What contractual remedy exists if a contractor, Johnson
- Control, does not utilize qualified personnel nor maintains a Quality/Certification program?
(ref.
Report I2 to NRC.)
29.
hhat changes in sampling procedures were made, if any, as a result of finding unacceptable radiographs on Contract
- 215, WBG?
(ref. Report 67 and 8 to NRC) 30.
What weld inspection or radiographs require disposition by the architect-engineer and why?
(ref. Reports 58 and 10 to NRC.)
31.
@hat is the policy regarding quality veiification and reinspection for off-site shops?
(ref. Report
-10 to NRC and audit reports.)
32 What and who determines sampling size and statistical sampling logic?
33.
What action has the S.S.
taken or planned as a result
'of XE Xnformation Notice 82-16 on HPCX/RCIC high steam flow set points?
II
3 0/ '8/82 I
TAA STEAM TURBINE QUESTIONS FOR hNP-2 PVP AUDIT (Set 54) 34.
What does WPPSS plan to do in addition to memo of 9 September 1982 by J.
M. Yatabe to R. V. Laney, with enclosures, in view of statement in EPRI-project 1398-5 Volume 2, page 3-24, "It should be noted that cracking occurred in the single BWR plant in which Westinghouse rotors were used (Plant 0-1) and that the cracking in this plant was more widespread and more severe than in any of the PWR plants."?
35.
What is blade length of last stage in the. Westinghouse turbine?
36.
Is the steam reheated before the Westinghouse low pressure unit?
37.
Is the arrangement in the Westinghouse turbine such that water cutting can occur, as described in EPRI report?
38.
How many reports and what are the titles of the reports which Westinghouse has submitted t'o the
- NRC, as men-.
tioned in "WNP-2 Status of Turbine Missile Issue" ?
39.
a)
When will WPPSS know NRC's reaction to Westinghouse inspection methods and reports which have been submitted to NRC?
b)
What, will WPPSS do if NRC requires substantial changes to Westinghouse proposed methods and approval if 'delayed beyond WPPSS start up?
40.
41.
bhat are the details of the WPPSS surveillance program which the NRC has accepted?
The memo on "Recommended Strategy-WNP-2 Turbine" has four Recommended Course of Action.
This statement leaves open questions as follows:
a)
&That does the procurement contract define?
b)
What does the specifications identify?
c)
What is the recommended steam purity in oxygen and copper at turbine entrance?
d) hhat action will be taken if a condenser leak occurs?
42.
Is the recommended strategy satisfactory for WNP-2 considering the long building period, the long storage of the turbine, and the increased knowledge of stress corrosion cracking?
43.
Turbine history a)
When was the turbine delivered to WPPSS in Richland?
b)
When was the turbine accepted by WPPSS?
c)
When was the turbine first rotated?
d)
How long has it been rotated?
e)
Was steam used for rotation?
f)
In what turbine was steam used?
g)
What steam purity was specified for this use?
h)
Total length of steam rotation use?
i)
Has turbine been inspected will it be inspected?
rAA QUESTIONS FOR WNP-2 PVP AUDIT (Set 05) 44.
Refer to letters Hatlock to Engelken (NRC) of September 23 and September 28, 1982, concerning reportable conditions
- 522, 37, 40, 49, 53; 54, 60, 64 and 82 in electrical cable routing, and reportable conditions
- 010, 58, 62 and 83 in concrete expansion
- program, and 573, deficiencies in grout.
Both letters refer to "reopening" these 10CFR50.55's, which indicates they once had been closed.
If this interpretation is correct; i.e. if they were once closed and have now been reopened, TAA has these questions:
a)
What was the justification for closing them, and when was this done?
b)
What was the reason for reopening?
c)
Has the SS considered whether these may be examples of a wider problem?
45.
Refer to letter Yiatlock to Engelken (NRC) of September 1,
- 1982, on reportable condition
~<175, WBG radiographs, Attachment A, page 2," para 5.
This paragraph states that, after reshooting 192 WBG radiographs, it was found that there was no significant difference between the original WBG and the new Bechtel film; that all 192 welds wer'e accepted; and that, as a consequence, the review program for evaluating film quality was modified.
Explain in what respects the review program was modified, and whether the original 1373 radiographs were re-reviewed to the new standard.
46.
Refer to letter Glasscock to Forrest (B&R) of September 27,
& Roe No.82-219.
On page 4 of the report is a reference to previously identified QFR's, showing that QFR 2 from Audit Report 82-4 is overdue and therefor has become a violation of 10CRF50.
What additional management level action has the SS taken towards B&R, in addition to the September 27 letter to Forrest, to bring about compliance with QFR 2.
Section A, page 1, final paxagraph states that a
B&R verification checklist was-completed by an employee who was involved 'in the original design.
What has B&R done to correct?
C ~
~
~p E
Section A, page 3, para.
2.
What has B&R done about the pre-xeroxed" checklists with signatures filled in?
What, investigation has SS made of the implications of this practice?
47.
Bechtel Audit 5.4-1, 8-23-82 thru 9-9-82 ~
Has a
- response, scheduled for October 18,
- 1982, been received?
ATTACH'lENT D
~
~
LIST OF DOCUMENTS REVIEWED BY TAA PANEL IN PREPARATION FOR NOV. 19-22 ON-SITE AUDIT 2.
3.
4 5.
6.
7.
8.
9.
10.
12.
13.
14.
WNP-2 Program Director's Monthly Progress Reports for July, August, and September, 1982.
10 CFR 50.55(e) Potentially Reportable Conditions for August and September, 1982.
NRC Region V Inspection Reports issued in August, 1982.
Supply System Corporate Audit Reports issued in August and September, 1982.
Bechtel Audit Reports issued in August and September, 1982.
Contractor Audit Reports 'issued in August and September, 1982.
Summaries of QVP Contractor Audit Reports for Peter Kiewitt Sons Co.
(210A), Oliver B. Cannon
& Son (234)g Sentry Automatic Sprinkler Co.
(217), Oliver B. Cannon
& Son (219),
The Waldinger Corp.
(216), Pittsburg DesMoines Steel Co.
(213A).
NRC IE Bulletin 82-01 of March 31, 1982; Rev.
1 of May 7< 1982, and Rev.
1, Supplement 1 of August 18,
- 1982, concerning Alteration of Radiographs by Assoc.
Piping and Engineering and ITT Grinnell Industrial Piping.
WNP-2 letter to NRC Region V in response to IE Bulletin 82-01.
Supply System (John M. Yatabe) letter of Sept.
9,
- 1982, to TAA (R.V. Laney) forwarding internal S.S. report/
"-Status of Turbine Safety Issues",
and S.S. internal memorandum of Aug. 17,
- 1982, "Recommended Strategy-WNP-2 Turbine.
"Steam Turbine Disc Cracking Experience",
EPRI report NP-2429, Volume 2 of 7, Data Summaries and Discussion.
Paper "Finding the Flaws in Nuclear Po~er Plants",
by Evan Herbert, published in IEEE Spectrum, Sept.,
1982.
Article "Serendipity - and Nondestructive Examination","
by Spencer H. Bush, published in the National Academy of Engineering "Bridge", Spring, 1982.
IE Bulletin 81-03 on Flow Blockage of Cooling Water by Clams and Mussels, dated April 10, 1981.
15.
WNP-2 letter to NRC Region V of July 6, 1981, responding to IE Bulletin 81-03.
16.
Supply System procedures:
System Technical Turnover
- Package, SDE Inst. 3.1; Design Reverification, SDE Inst. 3.5; WNP-2 Findings Review Committee (CPP 4.3.7).
17.
Supply System bi-monthly progress reports to NRC concerning progress of Restart and Quality Reverification Programs per 10 CFR 50.54(f) of July 17, 1980:
Reports No. 1, dated Oct.
16, 1980, through No. 12, dated Oct.
19, 1982.
18.
Supply System Corporate Assessment of Quality Verifica-tion Program, dated June 3, 1982.
19.
QVP Office Response to above assessment dated Aug. 13, 1982.
20.
"Bechtel Audits No. 10.4.2 and 13.3.1 of Johnson Controls, Inc., dated June 28-July 6, 1982.
21.
'Fishbach-Lord formal audit report 82-13, of July 23, 1982.
22.
Bechtel Audit No. 13.8.1 of Sentry/Lord, of April 1, 1982.
23.
Bechtel Audit No. 10.7.1 of WBG, of Aug. 3, 1982.
24.
WNP-2 Project.
QA Audit No.
82-1 of Quality Veri'fication
- Program, dated Jan.
20, 1982.
25.
Bechtel Audit No. 13.4.1 of The Waldinger Corp., dated March 4, 1982.
26.
WNP-2 Pro'ject Quality Control Audit of Bechtel/
Pittsburg DesMoines /teel, No. 13.7,.1, dated Jan.
28 to Feb.
4, 1982.
27.
"High Pressure Core Spray System Design Reverification Plan", Oct.
29, 1982.
28.
Charles Q. Miller Progress Reports to TAA Panel Nos.
1 and 2, dated Sept,.
17,
- 1982, and Nov. 12, 1982.
29.
Salomon Levy letter report to the TAA Panel dated Nov. 15, 1982.
~
ATTACH."iENT E LIST OF DOCUMENTS RECEIVED AND REVIEWED BY TAA DURING AND AFTER AUDIT OF NOV. 19-22 Supply System notes titled "Design Verification" presented by J.
M. Yatabe.
Vue-graphs, "WNP-2 Plant Verification Meeting with NRC",
Nov. 10, 1982.
Qualifications of HPCS Team Members, presented by J.
M.
Yatabe.
"Quality Verification Program Summary-Status Report",
dated Nov. 19, 1982, presented by R.
Knawa.
"Deficiency Evaluation Sheet, Small Bore ISOS",
presented by R. Knawa.
WPPSS Instruction QVI-08, "Reverification Inspection Team Concept",
dated May 13, 1982.
WPPSS Instruction QVI-09, "Special Structural Steel Reinspection Criteria, dated May 13, 1982.,
S.S.
document titled "Contract 215 Reverification Program."
Bechtel letter to S.S.,
BEC WNP-2-82-0437 of April 22,
- 1982, concerning "WNP-2 Reverification of WBG Pipe Weld Radiographs."
General Electric Co. letter, "Nuclear Wheel Newsletter No. 2", dated Nov. 12, 1982, plus Attachment I, "Nuclear Wheel Sonic Test Results."
General Electric "Nuclear Newsletter No. 2", Nov.
8, 1982.
Table I, "Steam Purity Recommendations",
presented by J.
M. Yatabe as an extract from a Westinghouse letter setting purity recommendations for steam entering the WNP-2 turbine.
"WNP-2 Plant Operations Summary",
dated Oct.,
- 1982, presented by J.
D. Martin.
File of ten (10)
WPPSS internal memos which reflect that the professional backgrounds of the Design Reverification Team Members and the Findings Review Committee Members have been.examined and have been found to meet the S.S. Criteria of Independence.
<sc Residual Heat Removal System Design Reverification Plan, dated November 5,
1982.
Reactor Feedwater System Design Reverification Plan, dated November 8, 1982.
Supply System letter D. C. Timmins to R. V. Laney et al, dated December 2,
1982, with enclosures concern-ing Structural Welding Code and the American Welding Society.
r Supply System letter J.
R.
Honekamp to R. V. Laney et al, dated December 22, 1982, enclosing AWS Dl.l pages 20, 21, and 22; page 1 of Structural Welding Code General Provisions; and Supply System Memo SCN 82-165, containing a draft SAR change notice.
. TTACII:liNT F Technical Audit Associates, Inc.
Plant Verification Program Plan Evaluation Team for WPPSS/WNP-2 N
BIOGRAPHICAL INFORMATION Frank B. Jewett, Jr., Assi nment Mana er:
Founder
& President TAA, mern er Tec naca Au xt Boar Assignment Director:
Indian Point -2 Containment Flooding Accident Audit-, Nine Mile Point -2 Cost to Complete Audit.
Former:
President and Chief Executive Officer, Vitro Corporation of America; Director of Engineering Research and Development, General Mills, Inc.
a Vice President Mechanical Division; Vice President
& Manager Vacuum Equipment Division, National Research Corporation; Member President's Council, Cal Tech.
Member:
of the Corp.g Wood Hole Oceanographic Institute; NY Academy of Sciences; ASME Safety Committee.
Merit Citation, Crusade for Freedom.
Registered Professional Engineering, Minnesota.
BS, CIT; MBA (mcl) Harvard University.
589 Oenoke Ridge New Canaan, CT 06840 H
(2D3) 966-3119 0
(203) 966-0383 Robert V. Lanev, Chairman of the Review Panel:
Vice President of TAA.
Former Deputy Director, Argonne National Laboratory; Vice President and General
- Manager, Quincy Shipyard Division, General Dynamics; Technical Representative of AEC at Westinghouse.Bettis Atomic Power Lab; Project Manager, Naval Reactor Program AEC and Bu Ships.
Ch. Engineering Review Team.
Wash.
State Public Power Supply System.
- Member, GPU and Commonwealth Edison Ad Hoc Advisory Committees on Three Mile Island; Member Presidential Board on National Breeder Reactor Policy.
,Consultant:
Department of Energy; Argonne National Laboratory; MA Attorney General; Commonwealth Edison; State of Il'linois. BS, U.S.Naval Academy; MS,MIT; MBA,U of Chicago.
24 Trout Farm Lane
- Duxbury, MA 02332 (617) 585-8912 Dr. Salomon Levy, Consultant to the Review Panel:
Consultant.
Twenty-four years General Electra.c Co.,
San Jose, CA:
General Manager Boiling Water Reactor Operations; General Manager BWR System Dept.;
Manager Des.
Engr. Atomic Pwr.
Equip. Dept.;
Manager System Engineer, At. Pwr. Equip. Dept.;
Manager Heat Trans.
and Reactor
- Program, APED.
Former:
Member AEC Task Force, Emergency Core Cooling; Ch.
ASME Heat Trans. Division; Member Argonne National Laboratory'eview Committee, Reactor Safety; Industrial Advisory Board, TMI-2 accident.
Cons.:
Kemeny Commission; NRC Advisory Code
Commission; V/orld Bank on Nuclear Safety in Korea.
Member National Academy of Engineeri'ng; Fellow ASME.
Adjunct Professor, University of California at Los Angeles.
ASME Heat Trans.
Memorial and Conf. Award.
BS, MS, PhDg University of California, Berkley.
Suite 725 1999 S.
Bascom Avenue
- Campbell, CA 95008 (408) 377-4870 Charles Q. Miller, Consultant to the Review Panel:
Registered Professional Engineer.
Eight years United Engineers Constructors; Dep. Proj. Mgr.,
WPPSS Unit 1; Asst.
Ch. Power Eng., including supervision and management of power projects and studies involving mechanical, nuclear, piping, process disciplines; standards development, tech.
des.
- guides, design reviews; technical support and direction to various major power projects, including seven nuclear plants; supervised design criteria reverification Seabrook Nuclear Units 1
& 2; Sup. Eng. for'reliminary design of five standard nuclear plants, including GE nuclear steam supply system.
Seven years
- USN, including operation,
- testing, maintenance of diesel-electric and nuclear submarines during new construction,
- overhaul, and operation.
B.S.
Mech.
Eng.
and Math.,
U. S. Naval Academy; M.S. Appl. Mech., Stanford; Juris Doctor, Rutgers.
United Engineers
& Constructors, Inc.
P.
O.
Box 460
- Richland, NA 99352 I
Louis H.'oddis, Jr.',
Member of Re'view Panel:
Consulting Engineer.
Char.rman Energy Research Advisory Board of US Department of Energy.
Director: Hammermill Paper Co.;
Gould Inc.; Research - Cottrell Inc.
Former President and CEO, John K. McMullen Associates; President and V. Ch.,
Con Ed; Chairman and President, Penna Electric Co.; Deputy Director Reactor Development, USAEC; Project Officer Power Plant Development Nuclear Subs NAUTILUS and SEMVOLF, USN; Task Force I, Bikini atom weapons tests.
Fellow: Royal Institute of Naval Architects, ASME, American Nuclear Society.
Member and VC US National Committee CIGRE.
Member:
- ASEE, NSPE,
- HFS, ASHAE.
Registered Professional
Member National Academy of Engineering.
Outstanding Service award USAEC.
Expert witness.
110 Broad Street Charleston, SC 29401 (803) 723-0319
Dr. Herman E. Sheets, Member of Review Panel:
Director of TAA.
Director of Engxneerxng, Analyst.s and Technology, Inc.
Former Chairman and Professor, Ocean Engineering Department, University of Rhode Island; sixteen years, Vice President, Engineering and Research, Electric Boat Division, General Dynamics Corporation; Engineer
- Manager, Goodyear Aircraft; Program Manager, Elliott Co.; Director Research, St. Paul Engineering and Manufacturing Corporation; Chief Engineer, Chamberlain Research Corp.;
Design Engineer, Erste Bruenner Maschinen Fabrik. Cit. Sec.
War, Manhattan Project.
Member:
National Academy of Engineering, New York Academy of Sciences, Fellow ASME, AAAS; Member ASNE, SNA and ME.
Associate Fellow/
AIAA.
Dip Ing (1st in class),
Tech. Inst., Dresden; Dr.
Tech Sci (award for excellence)
Tech Univ, Prague.
87 Neptune Drive
- Groton, CT 06340 H
(203) 536-2152 0
(203) 599-3910
Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 March 8, 1983 Hr. Robert V. Laney Technical Audit Associates" 24 Trout Farm Lane Duxbury, Massachusetts 02332 Dear Bob.
Subject:
RESPONSE
TO TAA AUDIT REPORT DATED JANUARY 10, 1983 Enclosed is our response to your first=audit report for the Phase II Program.
Me have addressed each TAA finding as well as observation No.
1 since this observation is closely tied to the design reverification program.
/
I If you have questions related to our response, please call.
Very truly yours, John R.
Honekamp Technical Specialist Enclosure cc:
Mr. F.
B. Jewett, Jr.
Mr. L. H. Roddis, Jr.
Mr. H.
E. Sheets Hr.
S.
Levy Mr.
C. Hiller
RESPONSE
TO TAA AUDIT REPORT DATED JANUARY 10, 1983 TAA Findin No.
1 Based on a review of documents in the Supply System's files, we believe that the Supply System personnel engaged in design reverification activities and members of the Findings Review Committee meet the criteria for assessing independence set forth in the Supply System memorandum of June 30, 1982.
Sup 1
S stem Response No response required.
TAA Findin No.
2 All three design reverification plans should give greater consideration to system-to-system interactions.
We recommend that a spot check be made of the adequacy of those portions of impor tant interfacing systems which are vital t'o the functioning of the three systems being reverified.
Sup 1
System
Response
he aesign reversfication plans as currently written include the pr in-ciple functional interfaces (e.g.,
water supply, containment isolation, pipe and equipment mounting, electrical power supply and instrumentation and con-trol).
Cross-system interactive design dependencies were not included in the original plans to their ultimate design impact.
- However, a few cross-system interactive design dependencies (e.g.,
HPCS diesel heat
- loads, jet impingement loads and RHR pump room flooding) were included to check if the correct design input had been fed into the dependent system design. 'n response to the TAA concerns expressed during the
- November, 1982 audit, the Supply System has augmented the basic plans to include several cross-system interactive reviews covering equipment qualification, fire protection and pipe break/jet impingement/flooding/missile protection.
Draft copies of these supplemental review plans were transmitted to TAA in advance of the
- January, 1983 audit.
We believe that the design review plans as supple-mented by the interactive reviews address the TAA concerns and provide a
substantive check of both the primary functional interfaces and key cross-system interactions.
TAA Findin No.
3 The Supp y ystem should incorporate in the reverification process for each of the three systems a way of showing clearly how FSAR design commit-ments are reflected into engineering requirements documents and into final detail design.
Su 1
S stem Response As discussed during the
- January, 1983 TAA Audit, the process by which the reverification reviews check if FSAR commitments are incorporated into the implementing design documents and the final design consists of several steps.
- First, FSAR commitments are compared with the design implementing documents.
The results of this comparison are contained in the Requirements Reverification Report which was transmitted for your review on January 17,.
1983.
Implementation of the design requirements into the final design is checked in the Design Reverification Reviews.
These reviews utilize a series of system level, component level and field inspection checks to probe details
of the design for a
sample of key components and system design features.
The checks cover a
range of design process elements from specification of design inputs to feedback of as-built data from the field.
Some of these checks have a direct relationship to specific FSAR commitments while others, due to, the depth of the review, are several levels of detail removed from the basic FSAR commitment.
- However, the record of the reviews will indicate what was
- checked, how it was checked and the source of the information used in addition to the results of the check.
TAA Findin No.
4 The Supply System should select and validate the design of a
small number of A-E "specified, plant specific, prepurchased components from the three
- systems, checking on vendor design and A-E review of vendor design.
Su 1
S stem Res onse The design verification plans as currently written include a number of components procured (prepur chased) by the A-E (Burns E Roe).
These compo-nents are listed in Enclosure l.
As indicated, some of these component pro-curements by the A-E were based on process specifications provided by the NSSS vendor (General Electric) while others were specified and purchased by Burns
& Roe.
While it is true that these components are "standard" items (pumps,
- valves, motor controllers, etc.),
they are representative of the major components and design interfaces involved in the systems under review.
The main plant specific A-E specified components in these systems are the piping and supports.
In this
- area, our sample includes pipe and supports designed by the A-E, by an A-E subcontractor (Gilbert Commonw'ealth) and by a construction contractor (Johnson Controls).
In response to your request for A-E specified, plant specific. prepurchased components, we will include in our review several guality Class I, Seismic Category I instrument racks procured by Burns 8
Roe.
These instrument racks will, of necessity, be selected from systems other than
- HPCS, RHR or RFW. 'he HPCS and RHR instrument racks were provided by GE, and the RFW instrument. racks are not guality Class I, Seismic Category I.
The review of theseinstrument racks wi 11 address the following general areas:
o Was the design, as specified, adequate for its intended operation7 o
Did the vendor provide what was specified (i.e.,
check vendor qualification tests)7 o
Were the instrument racks installed as designed and delivered, or if changes were
- made, were they reconciled with the vendor design/
qual ification tests7 TAA Findin No.
S In view of the significant number of additional loads which have been added to floors and bulkheads since they were originally designed, espe-cially the additional loads represented by piping supports and restraints, we believe that the Supply System should make a
spot check of a selected heavily loaded area to determine if the original structural design is still adequate.
The bulkhead which supports the Main Steam Isolation Valve may be an appropriate example for this purpose.
Sup 1
S stem Res onse nitia y,
oca pipe hanger and restraint loadings outside containment were considered in structural wall and floor designs by using specified load levels for equipment types for floor loadings.
This loading level varies by area within the plant.
Burns 5
Roe established criteria for controlling spatial separation of hanger and support loads that may be applied to em-bedded plates or by means of expansion bolts which were given to contractors for their detailed designs.
Burns 5
Roe reviews the contractor design and resulting local loadings from the different contractors to assure that structures to which supports are attached are not overloaded.
In addition, since January
- 1982, Burns E
Roe checks the local loading caused by pipe sup-port designs prior to issuance for construction.
In the room turnover process, Burns E
Roe performs a walkdown to iden-tify areas
-of highly loaded or congested areas.
The local hanger and restraint loads are assembled and an overall slab loading check is made.
The results of the walkdown and slab loading check are'ocumented in calculations.
Because of reviews resulting from the retrofit of hydrodynamic loads into the equipment and structures attached to and inside of the containment, additional controls were instituted to~assure acceptable load levels were maintained for these areas.
Particular emphasis was placed on the radial beams and the primary containment structure.
Burns 8
Roe reviews all attachments to these structures and verifies the overall structures'apacity to accept the required loads.
As a
check of the Burns E
Roe
- program, the design reverification re-views will review the north wall of the steam tunnel which supports seismic restraints, pipe whip restr aints, dead load of mainsteam line and other piping.
The wall was chosen on the basis of being a
very heavily loaded wall.
The review will include:
o Review Burns E
Roe walkdown results as documented in calculations.
o Perform walkdown to identify supports and equipment attached to north steam 'tunnel wall.
o Review overall wall loading calculations to verify their complete-ness and adequacy.
This includes evaluating applicable load combinations.
TAA Findin No.
6 We recommend that /VI-09 be revised to make clear that its purpose is to permit, with the A-E's case-by-case
- approval, certain specific deviations from the AWS Dl. 1 code when found upon reinspection in selected applications.
If this were
- done, we would see no objection to its use as a basis for dis-posing of the specified deviations.
We recommend also that the Supply System clarify whether (VI-09 is intended to apply to the sacrificial shield wall and pipe whip restraints.
Su 1
S stem Res onse guality Vers ication Instruction No.
09
((VI-09) has been revised to make clear that it is a generic disposition for limited deviations from AWS Dl.l in specific applications.
Enclosure 2 provides the Burns 8
Roe input to the revised section of (}VI-09.
The inspection criteria contained in QVI-09 (Enclosure 3) and FSAR Amendment 27 (Enclosure 4) are both correct as written.
Category 8 of the inspection criteria do'es include the sacrificial shield wall (SSW) and pipe whip restraints (PWRs).
- However, the reinspection of both of these areas was completed prior to the use of QVI-09.
- Hence, the statement in FSAR Amendment 27 that the SSW and the PWRs were reinspected to AWS Dl.l is correct.
W TAA Findin No.
7 The apparent coincidence of discontinuing film quality review of WBG radiographic film, coupled with the subsequent decline in the percentage of welds actually rejected for weld quality should be investigated by the Supply System and the results documented.
Su 1
S stem Response The Supply System has directed Bechtel to review all the data from both phases of the WBG radiograph reevaluation for trends or patterns that explain the apparent anomaly in the results.
This includes an examination of the film density data taken during the first phase of the program.
A draft report of the Bechtel review has just been issued.
Upon evaluation of the Bechtel report, the Supply System wi.ll determine if further investigation is warranted.
TAA Findin No. 8 If it is true that the Burns L
Roe team engineer has authority to accept or reject structural welds which do not meet the acceptable deviation criteria of QVI-09, we believe that this authority should be withdrawn and that such decisions should be,referred to the responsible BM structural design supervisor.
Su 1
S stem Res onse The activsty referred to in Finding No.
8 is the Team, I'nspection con-ducted under Quality Verification Instruction No. 08 (QVI-08):
This activity utilizes Burns 8
Roe (BRI) design engineers as members of field inspection teams reexamining work completed prior to the July, 1980 stop work.
The BRI engineers disposition minor deviations within their discipline authority on the Quality Control Inspection Report (QCIR) if they are acceptable as is.
Deviations which are not acceptable as is or which require more extensive evaluation are dispositioned via the normal Nonconformance Report process.
It is our position that the Team Inspection process conducted under QVI-08 meets the requirements of 10CFR50 Appendix B for identification and control of nonconforming conditions.
As indicated during your'November, 1982 audit, the Quality Verification Program (QVP) management identified several problems in reviewing the records of dispositions prepared by one of the BRI engineers formerly assigned to the Team Inspections.
Based on this
- review, QVP management has requested that BRI evaluate all the dispositions prepared by this engineer.
The results of this evaluation are expected to be available in March.
The basic reinspections conducted under QVI-08, except for the reevalu-ations mentioned
- above, have been completed.
- However, the procedure is being revised to strengthen the Team Inspection process in the e'vent that additional reinspections are required as part of the Quality Verification Program.
TAA Observation No.
1 The Supply System should con'sider incorporating into the Design Reveri-fication Program a separate check of thy effectiveness of the As-Built Draw-ing
- Program, both as to its timeliness for producing as-builts and as to their accuracy in reflecting the actual plant hardware as installed.
Sup 1
S stem Response TAA did not request a
response to the observations presented in the audit report.
- However, Observation No.
1, which relates to as-built draw-
- ings, is so closely tied to the Design Reverification Reviews that a response is warranted.
It is correct that problems have been encountered in producing final as-built data for use by Burns 5 Roe in their final stress reconci li-ation.
As discussed during the January, 1983 audit, delays in completion of some pipe supports and problems in producing satisfactory as-built data has resulted in a
schedule slippage in our design reverification activities in the piping and support area.
However, it is not correct that the Design Reverification Reviews do not include a
check of the effectiveness of the as-built program.
The piping and support segment of the Design Reverifica-tion Reviews have always included an independent verification of the accuracy of the as-built configuration used by 'Burns 5
Roe for 'their final stress reconciliation.
As a result of delays in this
- area, we may need to modify the sequence in which we planned to conduct our reviews.
- However, checks of the as-built configuration will be performed.
In addition to the as-built configuration checks in the pipe and support
- area, a
number of other field inspection checks are included in the Design Reverification Reviews.
Some examples include:
confirmation that name plate data on selected mechanical, electrical
'and IEC components match the speci-fied requirements, a
check that manufacturer and model number of selected Class IE components match the equipment qualification records and checks that selected components are installed per functional and general arrange-ment drawings.
The primary focus of the Design Reverification Reviews in this area is on the accuracy of as-built records.
Hhi le some information on timeliness of as-built data may fall out of the design reverification checks, an over-all assessment of the schedular aspects of the as-built program is more proper ly addressed by the WNP-2 program management.
For your information, the as-built pr'ogram as required to meet IEB 79-14 is receiving substantial management attention and resources and is an integral par t of construction completion.
ENCLOSURE 1
A-E PREPURCHASED COMPONENTS INCLUDED IN DESIGN REVERIFICATION PLANS Com onent Descri tion HPCS Process Requirements Component Component S ecif ied B
Purchased By Manufactured 8
Val ve Val ve Restricting Orifice Pump Suction Strainer Water Leg Pump Motor Motor Con-troller for Water Leg Pump RHR HPCS-V5 HPCS-RV-35 HPCS-RO-4 HPCS-ST-2 HPCS-M-3 HPCS-42-4A7C GE*
GE BRI*
BRI BRI BRI BRI BRI BRI BRI BRI Velan J.E. Louergon Co.
Permutit Zurn Gould Val ve Val ve Flow Control Valve Valve Motor Operators Motor Contro 1 1 ers Circuit Breaker RFW RHR-V-38 RHR-V-24B RHR-FCV-64B
/
(Var ious)
(Various)
RHR-P-2B GE GE BRI BRI BRI BRI Vel an Anchor Darling BRI BRI BRI
,-.,-,,'L"imitorque ITE Westinghouse BRI '::-
F isher Main Feed Pump Feed Water Heaters F low Control Val ve Val ve Valve RF W-P-1A COND-HX-5A RFW-HX-6A RFW-FCV-15 RFW-V-32 RFW-V-6J GE Westinghouse Westinghouse BRI BRI BRI BRI BRI BRI BRI BRI BRI Ingersoll Rand S.W. Eng.
S.W. Eng.
Fisher Anchor Darling Vel an
- GE = General Electric; BRI
= Burns 8 Roe, Inc.
Page 1 of 2
ENCLOSURE 1
A-E PREPURCHASEC COMPONENTS INCLUDED IN DESIGN REVERIFICATION PLANS Com onent Descri tion Process Requirements Component Component S ecified B
Purchased By Manufactured B
Signal Converter Flow Element F low Transmitter Signal Converter Motor Controller RF W-E/P-10 RF W-FE-15 RF W-FT-15 RFW-E/P-15 RFW-42-7A3C BRI BRI BRI BRI BRI Circle AW BRI Circle AW BRI BRI Fisher Vickery Simms Rosemount Fisher ITE Page 2 of 2
ENCLOSURE 2
JAN 19 1983 QVP OFFlCE January 19, 1983 BRWP-F-83-0434
Response
Required By:
N/A sE
~r.
Burns and Roe, tnc.
ut Pic, 'ct Nc. 2 Wcshmgtcn Public Pcticr Supply System
~ P.O, Bcx 200 ~ Hich!urtl,Wushingtcc 09352 ~ 509-377-250t r 509-943.8200
Subject:
Work Order 3900/4000 Washington Public Power Supply System WNP-2 Contract 215 RCSW - guality Verification Instruction Manual RECEIVED Justification for WNP-2 Visual Examination Criteria (QVI-09)
Responds To:
N/A Washington Public Power Supply System P.O.
Box 968
- Richland, WA 99352 Attention:
Nr. R.L.
Knawa
Reference:
BRWP-F-83-0088, dated January 7, 1983 Gentlemen:
Attached is Attachment 1, "Justification for WNP-2 Visual Examination Acceptance Criteria" for incorporation 'into (VI-09 of the RCSW - guality Verification Instruction Manual.-
The wording has been modified slightly for clarificatioii'since the "draft" which was transmitted earlier.
Should there be any questions regarding this matter, please contact this office.
Very truly yours, AIC/WNC/RI S/bab Attachment cc:
WS Chin, BPA HA Crisp, 901A BA Holmberg, 906D RT Johnson, 917B TA Mangelsdorf, BPC Manager, Site Engineering Over 7hirry Fivt, Yeors of t:ngineerl'ItgAchieveinenr
JUSTIFICATION FOR WNP-2 VISUAL EXAMINATION ACCEPTANCE CRITERIA The use of the AWS Dl. 1 code for the HNP-2 Plant was specified by the Engineer as the applicable structural welding code on behalf of the Owner, and as such AWS Dl. 1-72 is identified in the FSAR.
Unlike the ASME code, the use of the code is not a mandatory State or NRC regulatory require-ment.
The Engineer has the authority under the AWS code to modify selected provisions of the AWS code to suit a particular application.
It -is important to understand that the AWS Dl. 1 code is the applicable structural code for both completed work (first-line inspection) and ongoing construction.
Site construction and inspection procedures require that welds be made to the applicable AWS criteria and that the first-line inspection be performed in accordance with the AWS Dl. 1 code.
In cases where deviations are evaluated by the Engineer to be non-significant in terms of the ability of the component to perform its designed
- function, the Engineer has the authori ty to disposition the deviation "accept-as-is" as appropriate, or compensate for the deviation by additional evaluation or have construction performed to an approved, revised design.
During the initial QVP reinspections of completed work, a number of minor deviations with respect to some AWS cri teria were encountered which were evaluated by the Engineer as acceptable in certain categories of applica-tion.
Since the specific deviations had been evaluated by the Engineer to be acceptable for these categories of application, the processing of addi-tional deviations of the same type in the same categories served no purpose.
- Thus, a generic disposition was developed by the Engineer for acceptance of specified deviations from the AHS Dl. 1, 1972 code in selected applica-tions.
This generic disposi tion has taken the form of a revised inspection criteria for use by the QYP for reinspection of completed work.
These criteria are embodied within the reverification inspection requirements in Attachment 2 of QVI-09.
ue no imoerg
.JD Martin RG'ivat'i ock RM Nelson PL. Powell:
GC Sorensen CD Taylor WW Waddel JM Yatabe Docket File kt/file-906D PL2/LB BAH/LB-9060'TH/LB-906D GDB/LB-370 JDM/LB-927M sf(2 WG Conn BSR RO A ~eraaen BGR HY NS
~i nolds
- DSL WNP-2 Files
- sumo
- 927M
- 901A
- 905A
- 905A
- 340
- 905A
- 570
- 410 Docket No. 50-397 Januar l7 1983 G02 7 Director of Nuclear Reactor Regulation Attention:
Mr. A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D; C.
20555
Subject:
NUCLEAR PROJECT NO.
2 WNP-2 PROJECT VISUAL EXAMIHA CRITERIA FOR REVERIFICATION' S
WELDED STRUCTURES (QVI-09, RE ENCLOSURE 3
REGL)>ggg AgQ] )aug EP N
H 0 During a reinspection of tructural steel a
miscellaneous metal welds; certain excep ere taken to AWS Dl.l.
These exceptions are descried in the t d report, QVI-09, and referenced in the WHP-2 FSAR, Pa e 3.8-1 Very tr yo s
G.
uch
, Manager, Hu e r Safe and Regu'latory Programs Attachment cc:
R Auluck WS Chin R
Feil NRC BPA NRC AUTHOA:
D ay or SECT)ON FOR APPROVAL OF APPROVED GATE Wt'487 IALTURE OF:
2.
E ouc ey
WP-2 PROMCT QVI-09 Rev.
0 VISUAL EXAMINATIONACCEPTANCE CRITERIA REVERIFICATION INSPECTION OF Approved Burns
& R nc.
A. I. Cygelman Attachment 2
(Page 1 of 9)
Page 11 of 19
QVI-09 Rev.
0 1.0 SCOPE This document provides visual examination acceptance cr'teria for reveri-fication inspection of structural'steel and miscellaneous metal welding performed in accordance with AWS Ol.l, the Structural Welding Code.
These criteria reflect requirements consistent with the engineering approval specified in AWS Dl.l for evaluation of structural welding.
This document also includes acceptance standards for light gauge HVAC ductwork, and other systems which are not specifically covered by AWS 01.1.
I 1.1 These criteria shall be used by Construction Quality Control for performing reverification inspection by including it on the QCIR as an applicable inspection reference criteria document to evaluate deviations to AWS 01.1.
2 0 CODES ANO STANDARDS I
The critez'ia in thi's document provide the basis for visual examination of AWS 01.1 welding.
The required engineering approval, as specified in Paragraphs 3.7.4 and 3.7.5 of AWS 01.1 has been provided by the Architect Enginem'uthoxization for this is given & Paragraph 1& of AWS Ql.l.
3.0 BASIS FOR EVALUATION The applicable weld categories will be entered on the QCIR as a part of the inspection reference criteria based upon the definitions described
'elow.
Must be in'accordance with the visual acceptance criteria of the specified section of AWS 01.1.
This category applies to elements of fms, cranes, rotating equipment, and other machinery subject to frequent stress reversals.
Have an acceptance level modified to meet the required service con-ditions.
This category applies to members of the building frame that carry principal design loads, radial beams, sacrificial shield eall, pipe whip restraints, pipe supports, and similar principal load bearing structures.
Attachtterrt 2 (P ge 2of 9)
Page 12 of 19
QVI-09 Rev.
0 3.3 Cateoor C Welds Are connections between Category 8 Steel and Miscellaneous Metal.
Are not part of the main building frame, but rather provide support or freeing for electrical, instrumentation, and HVAC systems, ccm-ponents and equipment.
Also included in the 0 Category are welds joining miscellaneous metal including, but not limited to, stair-
- ways, embedments, fan housings,
- doors, windows, hatches,
- frames, ledger angles, gratings and their supports.
Is an acceptance level established for relatively thin materials such as HVAC ductwork, cable trays, and unistrut supports.
4 0 ACCEPTANCE CRITERIA Acceptance shall be based on the weld joint meeting each critmia Usted for ~i applicable category.
Screed joints will be evaluated in accordance with Contract Specifications and Project Engineering Directives.
.1 ~1 4.1.1 Category A welds'est comply with. the visual exaaWation requizements of the specified section of AWS Ol.l.
. /
4.2.1 Oversize Fillet Welds 4.2.2 The weld shall meet or exceed the specified s'ize require-ments.
Either or both fillet'eld legs may exceed design size.
Welds may be longer than specified.
Continuous welds may be accepted in place of intermittent welds.
Unequal leg fillet welds are acceptable, provided the smaller Leg meets or exceeds minimum requirements.
Undersize Welds 4.2.2.1 The fillet leg-dimension shall not under run the nominaL fillet size by more than L/16 inch.
For flange to web joints the undersize condition may not be within two flange thicknesses of the weld end.
Attachment 2
(Page 3 of 9)
Page 13 of 19
" gVI-09 Rev.
0 4.2.3 4.2.2.2 Groove welds may be underfilled by 5 percent or 1/32-inch, whichever is greater.
Porosit and Sla 4.2.4 4.2.3.1 The weld may contain a maximum of 5 percent by surface area of unaligned porosity and/or slag.
Prorile 4.2.4.1 Convexity height, roll over, and butt weld rein-forcement are acceptable.
4 2.5 Craters 4.2.5.1 The weld may have an underfilled crater, pro-vided the underfill depth does not exceed 1/16
- inch, and the crater has a smooth contour blend-ing gradually with the adjacent weld and base metal without acute notches.
4.2.6.1 Continuous undercut'hall not be greater than:
1/32 inch for material 3/8 inch and less; 1/16 inch for material over 3/8 inch thick.
Zntermittant undercut may be twic the value for continuous undercgt %m a maximum accumulated length of 10% of old lenoth.
Localized under-cut less than 3/8 inch in length may be accepted provided the depth does not exceed 3/32 inch for thickness 3/4 inch and less or 1/8 inch for Zhicktmss over 3/4 ~es.
4.2.7 Cracks 4.2.7.1 Cracks are unacceptable.
4.2.8 Fusion 4.2.8.1 Incomplete fusion between weld metal and base metal is unacceptable.
Attachment 2
(Page 4 of 9)
Page 14 of 19
QVI-09 Rev.
0 4.2.9 Weld Soatter 4.2.9.1 Weld spatter'hall be acceptable.
4.2.10 Arc Strikes 4.2.10.1 Arc strikes are acceptable provided there are no cracks.
- ..ll 4.2.11.1 The fitup of backing bars is not a basis for rejection.
4.3.1 The welds on the main frame member side shall meet the requirements for Category B.
4.3.2 The welds on the miscellaneous metal. side shall meet the zequirements far Category D.
4.4.1 Oversize Fillet Welds 4.4.1.1 The weld'shall meet or exceed the specified size requirements.
H.ther or both-fillet weld legs tray exceed zhmign size.- olds may be longer than specified.
Continuous welds may be accepted in place of intirmittent welds.
Un-equal leg fillets are acceptable, provided the smaller leg meets or exceeds minimun require-ments.
4.4.2 Undersize Welds 4.4.2.1 4.4.2.2 The fillet leg dimension shall not under run the nominal fillet size by more than 1/16 inch.
Groove welds may be undersize by 5 percent or 1/16 inch, whichever is greater.
Attachment 2
(Page 5 or 9)
, Page 15 of 19
QVZ-09 Rev.
0 4.4.3 Porosit and Sla 4.4.4 4.4.3sl Porosity and slag are not a basis for rejection.
Profile 4.4.5 4.4.4.1 Convexity height, roll over, and butt weld rein-forcement are acceptable.
Fusion 4.4.5.1 Incomplete fusion between weld metal and base metal is unacceptable.
Undercut 4.4.6.1 Undercut not exceeding 3/32" for material up to 3/4" thick, and 1/8" for material over 3/4" thick, may be'acceptable for the full length of'he weld.
~ ~
~
4.4.7 Cratars 4.4.7.1 Underfilled groove weld craters shall be accepted provided the depth of'nderfill is 1/16 inch or less.
Lhderfilled single-pass fillet weld craters shall be accepted provided the crater length is less than 5 percent of the weld length.
Qn mu1ti-pass f33Zet we1ds a cra&r depth of 1/16 inch or less-is acceptable.
4.4. 8 4.4.9 Cracks 4&.8.1 Ml cracks are unacceptable.
4.4.9.1 Misalignment not in excess of the thinner member thickness is acceptable.
4.4.10 Arc Strikes 4.4.10.1 Arc strikes are acceptable provided there are no cracks.
Attachmerrt 2 (Page 6 rF 9)
Page 16 of 19
QYl-09 Rev.
0
.11 ~i 4.4.11.1 The fit-up of backing bars is not a basis for rejection.
4.4.12 Held Soatter 4.4.12.1 Weld spatter shall be acceptable.
4.5e1 4 5-2 Oversize Fillet Welds 4.5.1.1 The weld meats or exceeds specified size re-quirements.
%ther or both fillet weld legs may exceed design size.
Helds may be longer than specified.
Continuous welds may be accepted in
'lace of intermittent welds.
Unequal leg fil-lets are acceptable, provided the smaller leg meets or exceeds minimum requirements.
Undersize Helds 4.5.3 4.5.2.1 4.5.2 2 Porosit The fillet leg dimension may not under run the nominal fillet size by more than 1/16 inch.
Fillet weld size need not be greater than the thickness of the thinner member.
Groove olds may be undersize by 5 percent by 1/32 inch, whichever is greater.
or Sla Enclusions 4.5.3.3.
4.5.4 Profile Mrosity or slag inclusions are not e crit~ria for rejection.
4.5.4.1 Convexity height, roll over, and weld reinforce-ment are acceptable.
4.5.5 Cracks 4.5.5.1 All cracks are unacceptable.
Mtachment 2 (Page 7 of 9)
-Page 17 of 19
QVZ-09 Rev.
0 4.5.6 Fuetcn 4.5.6.1 Zncomplete fusion between weld metal and base metal is unacceptable.
4.5.7 4.5.8 Undercut 4.5.7.1 (Same as 4.2.6.1)
Misalianment 4.5.9 4.5.8.1 Misalignment is not a basis for rejectian.
Corner Welds 4.5.9.1 Comer welds used to seal ductwork are design<<
ated partial penetration welds.
Such welds do not require full f'usion.
Weld reinforcement greater than the material thickness. shall verify the adequacy of'he weld, provided that the toes of the weld have complete fusion.
4.5.10 Burn-throuoh 4.5.10.1 Fillet welds gaining turning vanes to turning vane rails or to heavier gauge ductwork may ex-ceed the prof'ile and convexity limits as pre-viously described and are acceptable far this application.
Minor burn-through on vanes will be permitted up to 1/4 inch in length, provided equivalent lengths af'illet welds are added to ccmpensate for welds weakened by burn-through 4.5.10.2.
Burn-through is permitted provided there are no visible through-thickness holes.
Metal f'law an the inside of the duct is per-mitted, provided it is fused completely with the parent metal and metal thickness is not reduced by greater than 50 percent.
4.5.11 Arc Strikes 4.5.11.1 Arc strikes are acceptable provided "here are no cracks.
(Page 8 of 9)
Page 18 of 19
4.5.12 Held Soatter 4.5.12.1 Weld spatter shall be acceptable.
QVI-09 Rev.
0 4.5.13 8acklna Fit-Uo 4.5.13.1 The fit-up of backing bars is not basis for re-jection.
Attachment 2
O'age 9 of 9)
'Page 19 of 19
ENCLOSURE 4
WNP-2 ENDMENT NO.
27 November 1982 TABLE 3.8-9 (Continued)
Page 3 of 8
REFERENCE NUMBER DESIGNATION TITLE EDITION 18 AISC-69
.Specification for the Design, Fabrica-tion, and Erection of Structural Steel for Buildings Feb.
12, 1969 19 AISC-68 Specification for the 1968 Design of Light Gauge Cold-Formed Steel Structural Members 20 21 AWS Dl.l-72 AWS D12.1-61 Structural Welding Code 1972**
Recommended Practice 1961 for Welding Reinforc-ing Steel, Metal In-
- serts, and Connection in Reinforced Concrete Construction As part of the WNP-2 Quality Verification Program, visual reinspection of selected structural steel welds, including radial and structural framing systems, steam tunnel beams i and pipe hangers (AISC scope only), was performed under Supply System procedure QVI-09, Attachment 2.*** This procedure included alternative acceptance criteria to AWS Dl.l.
These alternative acceptance criteria were established by the Architect/Engineer and determined to be acceptable based on specific knowledge of the design and the significance of these types of minor deficiencies.
The criteria were implemented in order to provide a conservative and practical basis for performing a reinspection of the structural steel.
Sacrificial shield wall and pipe whip restraint weld rein-spections were performed to AWS Dl.l.
Transmitted to NRC via letter G02-83-007, G.
D. Bouchey to A. Schwencer, "WNP-2 Project Visual Examination Acceptance Criteria for Reverification Inspection of Welded Structures",
dated January 7, 1983.
3.8-190