ML19257C431
| ML19257C431 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1979 |
| From: | Donna Anderson, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19257C427 | List: |
| References | |
| REF-QA-99900503 99900503-79-2, IEB-79-14, NUDOCS 8001290113 | |
| Download: ML19257C431 (14) | |
Text
.
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900503/79-02 Program No.
51200 Company:
Burns and Roe, Inc.
496 Kinderkamack Road Oradell, New Jersey 07649 Inspection Conducted:
November 13-15, 1979 A[-
/A/Y8 Inspectors:
/d e
D. G. Anderson, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch TT %,-
Iz/s~/77 D. F. Fox, Contractor Inspector Date Program Evaluation Section Vendor Inspection Branch 1
1 Approved by:
Nd D
~7-~ N C. J.<sH fe, Chief Date 3
Program Evaluation Section Vendor Inspection Branch Su= mary Inspection conducted on November 13-15, 1979 (99000503/79-02)
Areas Inspected: Special Inspection of Burns and Roe activities related to IE Bulletin No. 79-14 and followup on a licensee event report for WPPSS Nuclear Plant Unit 2.
The inspection involved thirty-two (32) inspector-hours on-site by two (2) USNRC inspectors.
Results: During this inspection, no deviations were identified.
One (1) unresolved item was identified.
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g 0012 90
2 Unresolved Item: It could no' oe determined during the inspection if commitments to the NRC in the WPPSS/WNP-2 PSAR were being implemented in the Quality Assurance program at Burns and Roe.
(See DetailsSection II, paragraph B.3.b.)
18 M 302
DETAILS SECTION I
-(Prepared by D. G. Anderson)
A.
Persons Contacted R. Baldwin, Nuclear Group Supervisor
- R.
C. Baumbach, Quality Assurance Engineer J. M. Blas, Quality Assurance Manager J. R. Clapp, Senior Supervising Engineer W. Y. Chang, Stress Engineer A. I. Cygelman, Project Engineer J. R. Gorga, Manager, Piping Engineering J. Greenberg, Supervising Civil Engineer R. E. Snaith, Senior Project Engineer
- J. J. Verderber, Project Engineering Manager J. V. Zalavadia, Supervising Engineer
- Indicates attendance at the exit meeting.
B.
Followuo on I. E.Bulletin 79-14 1.
Objectives This was a special inspection related to the follow-up of activities being conducted at the Woodbury, Long Island, New York offices of Burns and Roe, Inc. which have resulted from the issuance of IE Bulletin 79-14, Seismic Analysis for As-Built Safety Related Piping Systems.
The inspection consisted of two (2) phases:
a.
Phase I The objectives of this phase of the inspection were to determine the following:
(1) The licensees that are inspecting systems to the latest drawings and comparing the results with the seismic analysis input used.
(2) The number of people that will be comparing the marked-up drawings with the seismic analysis input, a general descip-tion of their qualifications, and the schedule for these activities.
(3) The guidelines that will be used to identify the noncon-formances of the marked-up drawings to the seismic analysis input used.
(4) The identification of units where eccentric masses have been modeled.
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3 b.
Phase II The objectives of this phase of the inspection were to determine that:
(1)
The 2{ Bulletin 79-14 activities are being conducted in a documented, planned and systematic manner.
(2)
The inputs to the seismic analysis for this system can be readily identified.
(3)
Identified nonconformances are analyzed and the results properly documented.
(4) Personnel conducting these activities have received indoc-trination and training.
2.
Method of Accomplishment a.
Phase I The preceding Phase I objectives were accomplished by discussions between the inspector and Burns and Roe representatives, with the following activities identified:
(1) Burns and Roe has contracts for IE Bulletin 79-14 inspections and analyses for the following licensees:
(a)
WPPSS Nuclear Project No. 2, Washington Public Power Supply System.
(b) Oyster Creek Nuclear Station, Jersey Central Power and Light Company.
(c)
Cooper Nuclear Station, Nebraska Public Power District, (NPPD).
(2)
For WPPSS Nuclear Project No. 2, procedure WNP-2-015, In-spection and Enforcement Bulletins and Circulars, 6/28/78 is implemented for these activities. For Cooper Nuclear Plant, procedure NPPD Special Procedure 79-14, Inspection Procedure to Provide Information for Analysis as Required by IE Bulletin 79-14, 8/13/79 is being implemented for site inspection activities, while Cooper Project Procedure for the Evaluation of As-Builts for NUREC IE Bulletin 79-14, 11/5/79, is being implemented for analysis activities at the Woodbury office.
(3)
For both the WPPSS and Cooper IE Bulletin 79-14 activities, 182st-304
4 the Burns and Roe scope of work is restricted to home office analysis activities, since these two utilities are performing the piping walk down.
Engineers from Burns and Roe are present at the site, but their responsibility is mainly supervision of the inspections and coordination of the transfer of the marked up isometric drawings to Woodbury, New York.
For the Cooper Project, approximately twenty (20) NPPD personnel performed the walk through, while approximately eight (8) engineers and analysts are assigned to the Bucns and Roe scope to work.
(4)
The computer code used at Burns and Roe for performing the piping stress analysis is ADLPIPE, Revision 1C, February 1977 version.
In discussions with Burns and Roe personnel who use ADLPIPE, the inspector determined that the code does model eccentric masses and in particular, the rotatory inertia of valves is also accounted for.
b.
Phase II The Phase II objectives were accomplished by review of the following:
(1)
For the WPPSS Project, the scope of work related to IE Bulletin 79-14 activities is defined in BRWP-79-308, Scope Document 79-14, July 18, 1979; BRWP-79-437, IE 79-14 Isometric Drawing List, August 21, 1979, identi-fics those isometric drawings for piping systems which will be analyzed by Burns and Roe; BRUP-79-435, Project Change Notices, October 26, 1979, identifies nonconfor-mances with As-Built piping systems in the following change notices:
(a)
PCN-6812, IE Bulletin 79-14, July 16, 1979.
(b) PCN-6832, Pipe Interference, August 8, 1979.
(c)
PCN-6818, Pipe Support Design, September 19, 1979.
BRWP-79-341, identifies additional nonconformances re-lated to pipe hanger design, July 2, 1979.
BRWP-79-396, is a response to BRWP-79-308, and defines sources of input to the seismic analysis, August 1, 1979.
(2) For the Cooper Project, the original stress analysis was performed by EDS Nuclear from piping isometric drawings irovided by Burns and Roe.
The Burns and Roe IE Bulletin 79-14 program description and scope of work is identified in, Seismic Analysis for As-Built Safety Related Piping 18 % 305
5 Systems: Response to Item 1 of USNRC IE Bulletin No. 79-14, August 2, 1979. This document identifies the fabrication isometric drawings and piping systems to be inspected and reanalyzed, if necessary, to comply with 79-14.
The document also references those piping or seismic requirements contained in the following sections of the Cooper Nuclear Station Final Safety Analysis Report, Docket 50-298.
(a) Volume VI, Appendix A and C, Section 3.3.3.
(b) Volume V, Section 2.0.
The following transmittals document the chronological order of findings and corrective action related to 79-14 activities by Burns and Roe at the Cooper Nuclear Plant:
(a) July 19, 1979, Site Inspection 79-14, Site Verifi-cation Criteria.
(b) July 31, 1979, Responses to Item 2 and 3, 79-14.
(c) August 1, 1979, Pilant NPPD to Seyfrit NRC, 30 day response NPPD Re:
79-14, Item 1.
(d)~ August 2, 1979, findings Item 1, 79-14.
(e) September 4, 1979, Pipe Hanger Evaluation.
(f) September 4, 1979,.Pilant NPPD to Seyfrit NRC, 60 day response NPPD Re:
79-14, Item 2.
(g) September 4,1979, request for information on Cour (4) pipe supports.
(h) October 11, 1979, NPPD to B&R, request for seismic review of RHR system Loop A and B, including iso-metric drawing 2510-5, RHR.
(1) October 23, 1979, NPPD to B&R, transmits marked up isometric drawings for the Reactor Feed System, Reactor Core Injection Coolant System, Service Water System, at.d the Residual Heat Removal System.
(j) October 30, 1979, Pilant NPPD to Seyfrit NRC, 120 day response to 79-14, Item 3.
The inspector reviewed the following marked up drawings and pipe stress analyses:
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6 (a)
Isometric Drawing 2603-1, Core Spray System. Piping Diagram, CS-3, Core Spray Pump IA Suction, Sep-tember 27, 1973.
(b) Calculation 8.30.8, ADLPIPE computer run-stress analysis (reanalysis) November 6, 1979; Calculation 8.30.08, original pipe stress analysis Core Spray Pump Suction, June 2, 1971.
3.
Findings No deviations from commitment or unresolved items were identified in this area of the inspection.
The inspector noted that implementing procedures on the WPPSS project at Burns and Roa for activities related to IE Bulletin 79-14 were in handwritten form and had not been formalized at this point. WPPSS personnel are per-forming the walk-through piping system inspections at the site and as yet have not transmitted any of the marked-up isometric drawings to the Woodbury office of Burns and Roe.
The inspector encouraged Burns and Roe WPF3S Project Management to assure that procedures are in place prior to the performance of reanalysis activities.
C.
Followup On Licensee Event Report 1.
Objectives The purpose of this section of the inspection was to followup on a Licensee Event Report (LER) reported by WPPSS/WNP-2 and relating to the possible flooding of ECCS pumps during a LOCA with loss of offsite power.
The scenario for this event begins with a LOCA coincident with loss of all off-site power.
Since for WNP-2, the fuel pool cooling system is not a Safety Class I System, the pumps are not powered by emergency electrical AC buses as is normally the case.
The next event would be for the fuel pool to exceed 212 F ar.d boiling to occur. This steam vapor would then condence on the containment walls and propagate to the sump where flooding of the ECCS pumps would oc cur.
The objectives of this area of the inspection we-'
to:
a.
Determine how this item was identified.
b.
Assure that followup actions were conducted under the requirements and procedures of the quality assurance program of Burns and Roe.
c.
Determine the status of corrective action and pre-i Bjlii 307
b 7
ventive action to assure that this item is satis-factorily resolved.
d.
Determine if other Burns and Roe plants, other BWR's, are generically affected.
2.
Method of Accomplishment The inspector reviewed the following documentation re-lated to this item to assure that the above noted ob-jectives were satisfied:
a.
Technical Audit-Audit Report 76-06, Heating, Venti-lation, and Air Conditioning, February 3, 1977. This audit identified the deficiency in the capacity of the Standby Cas Treatment System (SGTS) to process the increased load of the condensate in the containment atmosphere resulting from a LOCA and resulting fuel pool
- boiling, b.
BRWP-77-739, Potential Reportable Deficiency, PRD-77-3, PRD-77-4, this item was evaluated and considered to be not reportable by Burns and Roe, July 1, 1977.
Subse-quently reported by WPPSS on July 29, 1977.
c.
Preliminary corrective action-addition of cooling coils to the inlet of the SGTS to assist in condensing the water vapor from fuel pool boiling during SSE, LOCA, and loss of offsite power, May 1, 1978. Additional evaluation resulted in this corrective action not being taken.
d.
Two (2) conferences between WPPSS and Burns and Roe were conducted to resolve this item:
Conference 704, June 6-9, 1978, and Conference 744, September 12-14, 1978.
A final meeting was conducted on March 21, 1979, in which an evaluation resulted in the conclusion that the Fuel Pool Cooling System should be upgraded to Seismic Class I requirements.
c.
Licensee Event Report to the NRC under the reporting requirements nf 10 CFR 50.55 (e) from WPPSS.
- 3. Findings No deviations from commitment or unresolved items were identi-fied in this area of the inspection.
The inspector determined that since WNP-2 appears to be the only BWR in which the Fuel Pool Cooling System is classified
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8 to other than Seismic Class I requirement;. chis item is not generic to other BWR's.
Now that WPPSS and Burns and Roe have upgraded the Fuel Pool Cooling System to Seismic Class I requirements and since the components in this system are supplied emergency AC power from safety related electrical buses, it appears that this system will continue to function during SIE, LOCA, and loss of offsite power events.
Project Change Notice 6679 was approved on March 22, 1979, to upgrade the Fuel Pool Ccoling System to Seismic Class I requirements.
This action and subsequent modifications prior to initial startup will resolve the SGTS/ECCS pumproom flooding concern.
D. Exit Meeting An exit meeting was conducted on November 15, 1979 with Burns and Roe, Inc. Management Personnel at the conclusion of the inspection.
Those individuals indicated by an asterisk in the details sections of this report were in attendance.
In addition, the follcwing were present:
H. R. Canter, Director, Project Operations Division I. Cabel, Project Manager, Cooper Nuclear Plant D. J. McCormick, Manager, Quality Assurance Planning and Engineering W. P. Rausch, Director, Quality Assurance The inspectors discussed the details of the unresolved item identi-fled during this inspection. Management representatives of Burns and Roe acknowledged the statements with respect to the one (1) unresolved item presented.
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DETAILS SECTION 11 (Prepared by D. F. Fox)
A.
y,rsons Contacted
- Robert C. Baumbach, QA Engineer, Washington Nuclear Plant-Unit 2, (WNP-2), Project
- Denotes those present at the exit interview.
B.
Evaluation of Burns and Roe Procurement Source Selection Practices 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for the selection of qualified suppliers of services, materials, parts and components that' provide for:
a.
Requirements for evaluation of the potential supplier's capability to provide items or services in accordance with the technical and quality assurance specificatior.s of the procurement documents, b.
Methods of evaluating potential suppliers that are consis-tent with applicable regulatory, code and contract require-ments and should include source evaluation audits, review of historical performance, and/or review and evaluation of the supplier's QA program, manual and procedures.
c.
Consideration of the complexity, inspectability, and safety significance of purchased items or services when selecting the method of source evaluation.
d.
Performance of source evaluation audits that inclitde appro-priate checklists or instructions for systematic review of the prospective supplier's QA system.
c.
Qualification requirements for personnel performing source evaluation audits.
f.
Source selection being based on historical product perfor-mance that includes review of past procurement and operating experience with identical or similar items and is limited to relatively simple services or off-the-shelf items.
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I 10 2.
Method of Accomplishment a.
Review of the following sections of controlled copy #49 of the PSAR for the WPPSS (Washington Public Power Supply System)
Hanford No. 2 Nuclear Power Plant through Amendment #16 dated December 8, 1972, to determine WPPSS and Burns and Roe commit-ments relative to procurement source selection:
(1) WPPSS QA Program Sections of the PSAR:
C.2.1.
D.2.5.4.
D.2.5.7.
D.2.5.18.
D.2.2.
D.2.5.4.3.
D.2.5.15.
(2)
Burns and Roe QA Program Sections of the PSAR:
D.3.2.5.
D.3.4.2.
D.3.4.7.
D.3.4.18.
D.3.3.3.2.
D.3.4.4.
D.3.4.15.
b.
Review of the following sections of controlled copy #36 of Volume II of the WPPSS (Licensee) Quality Assurance Program Manual dated October 15, 1979, to determine the QA program-natic commitments made for Burns and Roe by WPPSS relative to procurement source selection:
Paragraph 4.0 (Architect Engineer and Construction Manager Responsibilities) of:
QAP-5; QAP-6; QAP-7; QAP-18; QAP-20, c.
Review of the following chapters of the approved Burns and Roe Topical Report No. B& Roc-COM4-1-NP-1A (Nuclear Quality Assurance Manual) dated February 13, 1978, to determine the Burns and Roe scope of work on the WNP-2 project as de-lineated by Burns and Roe.
d.
Review of controlled copy #13 of the Burns and Roe Project Plan for the WNP-2 project dated August 2d, 1978, to determine the Burns and Roe scope of work on the WNP-2 project as de-lineated by Burns and Roc.
c.
Review of the Burns and Roe corporate Quality Assurance Division Manual to determine the corporate QA programmatic commitments made by Burns and Roe relative to the WNP-2 pro-ject.
f.
Review of the following sections of controlled copy #13 of Burns and Roe WNP-2 Project Quality Assurance Manual dated November 5, 1979, to determine if the commitments contained in the PSAR were correctly traaslated into the WNP-2 Project 1891L 311
e 11 Quality Assurance Requirements:
7.0; 10.0; 18.0; and 21.0.
g.
Review of Subsection NCA of Divisions 1 and 2 of Section III of the 1977 Edition through the Summer of 1979 Addenda of the ASME B&PV Code to determine Code requirements rela-tive to suppliere of Section III materials, items or services for use in nuclear power plants.
h.
Review of the following Burns and Roe procedures to determine that approved procedures have been established for:
(1) Evaluation of suppliers QA Program, facilities, and manufacturing capabilities.
(2) Recognition of suppliers prior facrication history, experience of other users, and possession of valid ASME Certificates of Authorization or Quality System Certificates.
(3) Maintenance of a Recommended, Qualified and Approved Supplier List.
(4) Evaluation of bids from prospective suppliers and resolution of deviations from procurement document requirements.
WNP-2-019 WNP-2 Project Home Office Actions 2808-Q-1.16 Quality Assurance Review of Submittals 2808-Q-1.17 Review of Specifications for Quality Requirerrnts 2808-Q-1.21 Contractor Bid Review for Quality Reautrements 2808-Q-2.1 Requirements for Source Surveillanca of Pre-Purchased Contractors WNP-2-PRO-001 Selection of Bidders (Nuclear Project)
WNP-2-PRO-004 Evaluation and Award of Contracts (Nuclear Project) 1.
Review of the following Burns and Roe " pre-purchased" equipment procurement QA files to determine that the approved pro-cedures relative to procurement source selection are being implemented:
File No.
Item Vendor 2808-23 Standby Service Water Pumps Johnson Valve Co.
2808-32CD Jib & Overhead Cranes Clayton Material Handling, Ltd.
2808-36 Concrete Production & Delivery Acme Concrete & Central Remix Co.
2808-41A ASME III Nuclear Valves Velan Engineering Co.
2808-68 Isolation Valves (HVAC)
B I F Co.
2808-90 Pipe Whip Restraints Leckenby Co.
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12 3.
Findings a.
Deviations from Commitment In this area of the inspection, no deviations from commitment were identified.
b.
Unresolved Item In this area of the inspection, one unresolved item was identified.
The WPPSS PSAR for the WNP-2 Nuclear Project, the WPPSS Quality Assurance Program Manual, the Burns and Roe WNP-2 Project Plan and the Burns and Roc WNP-2 Quality Assurance Manual appear to contain many ' incongruent or ill-defined commitments with respect to implementation of 10CFR Part 50 Appendix B quality assurance requirements for procure-ment, design verification and audits.
Time did not permit the inspector during this inspection to verify the actual Burns and Roe scope of work for the WNP-2 Nuclear Project, nor to determine the adequacy of the Burns and Roe Quality Assurance program for assuring the impic-mentation of those 10CFR, Part 50 Appendix B requirements applicable to the WPPSS approved Burns and Roe scope of work (Amendment No. 3 to the WPPSS/ Burns and Roe Contract dated April 10, 1978).
This item will be resolved during the scheduled Phase I inspec-tion (the initial QA program inspection for the implementation of an approved QA program) at Burns and Roe with specific attention to the comments in the following paragraphs.
c.
Comments (1)
Burns and Roe Management stated that Burns and Roe has no past or current nuclear projects which invoke their approved Topical Report B& Roc-COM4-NP-1A.
(2)
Chapter 17 of the WPPSS PSAR for the WNP-2 project has not been amended since December 2, 1972, and apparent-ly complies with 10CFR, Part 50 Appendix B Quality Assurance Criteria, based on the NRC Licensing review.
(3)
Paragraph 4.0 of WPPSS (Licensee) Quality Assurance Procedures QAP-5 and QAP-7 states that Burns and Roe is to meet the requirements of ANSI-N45.2.13 (QA Require-ments for Procurement Control), and the WPPSS PSAR i 8jlik 5_ 1 3
13 for the WNP-2 project, with respect to procurement practices, including procurement source selection.
(4) The Burns and Roe Project Plan for the WNP-2 project appears to indicate that Burns and Roe's scope of work may have been changed from the Architect Engineer and Site Construction Manager, to the Engineering Designer of Unit 2 and to providing assistance to WPPSS in all other areas including procurement, vendor and site quality assurance, audits, and site construction management.
(5) The Burns and Roe Quality Assurance Program (Manual) for the WNP-2 project does not appear to fully reflect the commitments made for Burns and Roe in the WNP-2 PSAR and the WPPSS Quality Assurance Manual, especially with respect to procurement source selection, audits, and verification of design.
(6)
Section 10 of the Burns and Roe Quality Assurance Program (Manual) for the WNP-2 project identifies requirements for assuring that contracts for ASME B&PV Code Section III materials, it ms or services for use in Nuclear Power Plants are ly awarded to suppliers who either possess, or who commit themselves to obtain, a valid ASME Certificate of Authorization, or an ASME Quality System Certificate prior to start their procurement or fabrication activities.
However, neither the Burns and Roe, nor the WPPSS Quality Assurance program appears to invoke an equivalent set of requirements for safety related items that are not covered by Section III of the ASME Code.
Burns and Roe Management stated that these procurement policies and practices, including not performing supplier pre-award surveys and evaluations, are aligned with WPPSS's guidance.
Furthermore, they stated that it was their understanding that unfavorable results of pre-award surveys and evaluations cannot be used as the basis to disqualify a pot 2ntial supplier nor to prevent them from submitting a bid to supply material, equipment or services for construction projects such as WNP-2 in the State of Washington. Their understan-ing was that any such contract must be awarded to the lowest-price bidder who states that he will meet the technical and schedular requirements of the pro-curement specifications and who commits to establishing i 85fil 314
14 a Quality Assurance Pro 3 ram which meets the Purchase Order Requirements and to providing adequate manu-facturing capability prior to the actual commencement of procurement or facrication activities.
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