GO2-83-338, Forwards Rept of Audit 2 of WPPSS Plant Verification Program for WPPSS Unit 2

Forwards Rept of Audit 2 of WPPSS Plant Verification Program for WPPSS Unit 2

ML17277A556
Person / Time
Site:	Columbia
Issue date:	04/15/1983
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML17277A557	List: GO2-83-338, Forwards Rept of Audit 2 of WPPSS Plant Verification Program for WPPSS Unit 2 ML17277A558
References
GO2-83-338, NUDOCS 8304220464
Download: ML17277A556 (15)

Text

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AOCESSQON 58R;8+04220464 DOC ~ DATE: 83/04/15 NOTARIZED:

NO DOCKET l"SCIL:50 397 WPPSS Nuclear Projects Uni,t 2~ Washington "Public Powe 05000397

-'huT~, NAME AUTHOR" AFFILIATION BOUCHEY<G,D, Washington Public Power Supply System ROC I Pi NAME REC IP IENT AF F IL'IATION SCHWENCERi"e Licensing Branch 2

SUBJEOT: Forwards,"Rept of Audit '2 of WPPSS Plant Verification Program for WPPSS Unit 2,,"

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Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 Docket No. 50-397 April 15, 1983 G02-83-338 Director of Nuclear Reactor Regulation Attention:

Mr. A. Schwencer, Chief Licensing Branch No.

2 Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555

Subject:

INDEPENDENT AUDIT OF WNP-2 PLANT VERIFICATION PROGRAM Enclosed for your information is a

copy of the second TAA Report prepared during their Phase II activity and the Supply System' response to the TAA findings.

If you have questions related to the TAA Report or the Supply System's

response, contact John R.

Honekamp (509: 372-5359).

Very truly yours, G. D. Bouchey

Manager, Nuclear Safety and Regulatory Programs

Enclosures:

1.

TAA Report 2.

Supply System

Response

cc:

R

Auluck, NRC RT Dodds, NRC JL Creuts, NRC NS Reynolds, D8L A

Toth, 917(

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RESPONSE

TO TAA AUDIT REPORT DATED FEBRUARY 15, 1983 TAA Findinq No.

9 The Panel believes that the Supply System should take additional steps to inform reverification team members of the importance of deciding and indi-cating on the report whether a Potential Finding is or is not a reportable event.

Sup 1

S stem Res onse TAA noted that the reportabi lity box

( 10CFR50.55(e))

had not been filled out by the reviewer for several Potential Finding Reports (PFRs) as re-quired by the procedure.

The reportabi lity reviews have been performed and none of these PFRs are reportable.

The incomplete lead sheets have been corrected.

The importance of documenting the reportabi lity evaluation has been re-emphasized

.in meetings and via a

memorandum to all reviewers (Enclosure 1).

TAA Findin No.

10 TAA does not agree with the present plan for the RFW system in which no piping or support/restraints are being reverified.

We believe that a

sample should be

included, using design level information, if necessary, to avoid the schedule delay which would result from awaiting as-built verification.

Su 1

S stem Res onse In the Plant Verification Report and the early draft design reverification

plans, the scope of the engineering mechanics reviews were intended to be distributed among the three systems (HPCS, RHR and RFW).

However, when it became apparent that the final reconciled stress analysis for the RFW piping would be significantly delayed, the Supply System redistributed the engineering mechanics reviews originally planned for the RFW systems to the RHR and HPCS reviews.

The redistribution, which is shown in Enclosure 2,

is reflected in the issued design review plans (page 10 of TAA Audit Report).

This change was justified on the basis that equivalent scope involving the same design organizations was being reviewed.

While in our judgment the scope of the engineering mechanics review is

adequate, we.

understand the TAA concern and, therefore, will review several significant items in the modified RFW design.

Items to be reviewed will include re-vised loads on the RFW pump and RFW-HX-6A and 6B heater nozzles and revised loads on a selected support.

The review will be based on the design pack-age rather than the final reconciled stress analysis.

TAA Findin No.

11 The Requirements Reverification Report requires additional review and improvement to ensure that the relationship between commitments and re-quirements are more thoroughly analyzed and more clearly presented.

Su 1

S stem Response The TAA Panel made several specific comments on the Requirements Reveri-fication Report.

The Supply System has taken these comments and -will resolve them by the following process:

1.

Resolution by individual team members; 2.

Review by Discipline Supervisor for correctness in terms of area of specialization; and 3.

An interdiscipline review by each team member.

Resolution will follow these guidelines:

2.

3.

Correction of specific errors such as the err or of copying or transposition identified by TAA; Resolution and clarification of areas where the backup in-formation does not fully support the comparison statement; and Clarification of wording where necessary.

We agree that not all commitments are covered in the Reverification Report.

The purpose as stated to the NRC at the November 10, 1982 review was to sample FSAR commitments to ensure they are carried out in the implementing documents.

The commitments presented in the report represent a substan-tial sample but not all commitments as pointed out by the Panel.

TAA Findin No.

12 The RFW design reverification team is behind schedule and requires strengthening in order to complete on schedule.

Su 1

S stem Res onse The Supply System had recognized the schedule problem and agrees with the TAA finding.

The actions taken to resolve the issue are:

2.

3.

Review of detailed schedules to evaluate the areas behind schedule and the cause of delay

( e.g.,

construction not

complete, inadequate review resources, other priority).

Where schedule problems were caused by priority, specific tasks were reassigned to provide design reverification team personnel additional time to support reverification activities.

Where inadequate integration

occurred, individual team meetings with program supervisor were held to resolve interdiscipline requirements.

Where resources were inadequate, the following action was taken:

a.

gualified analysts from other Systems Engineering Departments were added to address the system analytical reviews.

b.

Added Supply System help from other projects.

c.

Added outside contract help (S&W) in the mechanical discipline area.

d.

Reviewed all work tasks assigned to the team lead and established firm priorities for reverification tasks.

TAA Findin No.

13 We be ieve t at t e pipe stress/nozzle problem should be investigated by the Supply System to determine the root causes of it, and whether the root causes have any implications for other Supply System work done by the architect-engineer.

Su 1

S stem Response Both the Supp y ystem and Burns E

Roe (BRI) have investigated the cause of the late identification of a significant number of nozzle load recon-ciliationn problems at WNP-2.

The conclusions from the two evaluations are consistent and are supported by the engineering record.

It is clear from project documentation that reconciliation of nozzle loads has been a

requirement since the earliest stages of the project and that considerable correspondence, took place between BRI and various vendors to resolve spe-cific nozzle load problems starting as early as 1972 and continuing to the present.

However, a

formal program for case-by-case reconciliation of nozzle loads was not implemented until late in the project.

The delay in initiation of the case-by-case reconciliation was the result of several factors, primarily:

2.

3.

Problems with the piping and mechanical contractor (C-215) which led to the July 1980 stop work and changes in the piping design and installation contracts.

The need to perform a status as-built program as a result of item

1. to define the construction status of the C-215 piping and supports and identify and resolve areas where this construction 'was not in conformance with the design.

A conscious decision by BRI and the Supply System to wait until final hydrodynamic loads were available before per-forming the final reconci liation of nozzle loads.

The causes of the nozzle load problems identified during the status as-built stress evaluation are new/increased loads; as-built deviations from design; changes in configuration; application of a uniform, more conserva-tion design criteria identifying as potential overloads previously accepted loads; the existence of excessively conservative vendor allowable loads; and the discovery of previous errors or omissions.

The Design Reverification Program management has reviewed these evaluations and concluded that the late identification of a significant number of noz-zle load reconciliation problems is not the result of a design process breakdown.

In addition, the Design Reverification Program already includes

'the review of several Class I nozzles to determine if the applied loads have been adequately reconciled with the acceptance criteria.

Furthermore, in response to TAA's request to restore some structural mechanics checks in the RFW System

Review, we will also be checking a non-Class I nozzle.

Based on the high visibility being given to the Burns

& Roe nozzle load program and the independent checks already planned to be performed, it is our conclusion that no further changes to the design reverification plans are needed in this area.

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TAA Observation No.

5 For the purpose of deciding whether or not to extend the sample size, tray and conduit supports which do not conform to design

plans, but are found acceptable as is, should be analyzed.

It is important to determine if the same deviations might be unacceptable in other tray and conduit support situations.

If so, such "acceptable as is" items should be counted as deviations for sample size analysis.

Sup 1

S stem Response In the ATI review of Contract 218 conduit and tray supports, deviations in generic designs were traced to all affected supports.

As discussed

below, every individual support reviewed was shown to be satisfactory, hence, it was not necessary to increase the sample size.

~

Cable Tray Supports Cable tray supports were individually designed, but utilized generic calculations which formed the basis for the original support designs.

Both the detailed individual tray support and the associated generic calculations were r eviewed by ATI in the design verification process.

The tray support designs were found, in all 59 cases in the sam-ple, to be satisfactory for the loading conditions specified and resulted in no rework.

Since no failures in the cable tray sup-ports were found, the initial sample size of 59 was sufficient to provide a

95 percent confidence level that there would be 5

percent or fewer structurally inadequate cable tray supports in the population.

~

Conduit Supports Fischbach/Lord utilized generic conduit support

designs, rather

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than individually designed conduit supports.

In the

'sample selected by ATI for design verification, no two supports utilized the same generic conduit support design.

Therefore, 59 separate generic conduit support designs were evaluated.

In some

cases, errors were found in the generic support design which would have resulted in an overloaded condition if the as-built conduit sup-port had been loaded up to the theoretical capacity of the sup-port.

These were identified by ATI to Fischbach/Lord with a

recommended reduced load-carrying capacity.

Each of the defi-cient generic conduit support designs identified by ATI were traced to all the individual as-bui lt supports utilizing that generic

design, and it was found that in no case did the actual loading on the individual conduit support exceed the recommended reduced load-carrying capacity of the generic support.

Thus, no rework was required on these

supports, and the generic conduit design was revi,sed to reflect the reduced load-carrying capacity.

Even though some deficiencies were found in the initial sample of generic conduit support

designs, all of the individual con-duit supports which utilized these designs were satisfactory.

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This is because the theoretical generic conduit support capacity is an upper limit, and

,the actual loading on a

given support will generally be less than the theoretical capacity.

Since the objective of the design verification effort was to provide 95 percent confidence level that 5 percent or fewer supports (i.e.,

not generic designs) in the population are structurally inade-quate, this was accomplished in the initial sample size of 59.

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~ a Dater January 28, 1983 To:

From:

Subject:

Distribution D. L. Whitcomb (420)

Q. f. 44tux~

COMPLETION OF PFR TRANSMITTAL FORMS CLASSIFICATION OF PFRS

Reference:

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I N T E f+F F I 0 E M E M'0 R II N 0 0$

WASHINGTONPUBLIC POWER SUPPLY SYSTEM ENCLOSURE 1

Distribution:

~ 0 EDC WNP.1/4 0 EDC WNP-2 0 EDC WNP-3/5 Cl Admin Filo M Basu 420 DM Bosi 440 GL Gelhaus 440 JR Honekamp 387 DM Myers 420 DW Porte 420 DC Timmins 901'L Whitcomb 420 JM Yatabe 410 Chrono DLW/lb SDE Instruction 3.5, Section 3.11 requires that each System Engineer determine if a PFR is potentially reportable and directs that the top section of the PFR transmittal form be completed.

Please be advised that the line stating "Potentially Reportable-Transmitted to PRAM (Form Attached)

Yes No" is for the purpose of documenting this determination and shall be co~pTete~or each PFR.

The next revision of SDE Inst. 3.5 will clarify any confusion that exists.

SDE Inst. 3.5, Section 5.7.1(5) advises that the Findings Review Committee procedure for processing PFRs be used

'to assist in establishing the recommended classification of the PFRs.

Attached is a copy of CPP 4.3.7, WNP-2 Finding Review Committee.

This CPP provides the guidance discussed in SDE Inst. 3.5.

DLW/arg Attachments:

1.

Potenti al Finding Report Transmittal 2.

CPP 4.3.7, WNP-2 Findings Review Committee s

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ENCLOSURE 2

REVER IF ICATION PROGRAM SUBSTITUTIONS (Engineering Mechanics)

Item Small Bore Pipe Small Bore Hanger Pipe Whip Restraint Large Bore Hanger Large Bore Hanger Large Bore Stress Analysis Subtracted From RFW Com onents M200-341 None included in original scope PWS-27-2 COND-28 RFW-186 M200-27 (Class I)

Added to RHR or HPCS Com onents RHR-2289-1 RHR-2289-11 PWS-2-1 HPCS-901N HPCS-52 HPCS-100A (Class I I )*

• Class I already being reverified in HPCS.

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