ML20092P161
| ML20092P161 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/03/1984 |
| From: | Ballard R, Chapman D, Deubler R, Finneran J, Parker A, Powers D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20092P152 | List: |
| References | |
| NUDOCS 8407060012 | |
| Download: ML20092P161 (266) | |
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July 3, 1984 0'J 'l
'84 UNITED STATES OF AMERICA Ed ~$
NUCLEAR REGULATORY COMMISSION 49.'JO ob.c ln, v BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _ 'I In the Matter of )
) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY, ET AL. )
) (Application for (Comanche Peak Steam Electric ) Operating Licenses)
Station, Units 1 and 2) )
AFFIDAVIT OF D.N. CHAPMAN, J.C. FINNERAN, JR.,
D.E. POWERS, R.P. DEUBLER, R.E. BALLARD, JR.
AND A.T. PARKER REGARDING QUALITY ASSUrtANCE PROGRAM FOR DESIGN OF PIPING AND PIPE 4
SUPPORTS FOR COMANCHE PEAK STEAM ELECTRIC STATION l
We, D.N. Chapman, John C. Finneran, Jr. , David E. Powers, R.
- Peter Deubler, Robert E. Ballard, Jr. and A. Thomas Parker, here-by depose and state, as follows
- 1 (Chapman) My name is David N. Chapman. I am the Quality l
Assurance Manager for Texas Utilities Genera ing Company. A statement of my educational and professional qualifications was received into evidence with Applicants' Exhibit No. 9.
0407060012 p0 5 PDR ADOCK 0 PDR 0
1- Each affiant adopts those portions of this affidavit to which the questions are directed. Questions to the " Panel" are directed to the representatives of each design orga nization, viz., Finneran, Powers, Deubler, Ballard and Parker (answers designated by "All," include Mr. Chapman).
(Finneran) My name is John C. Finneran, Jr. I am the Project Pipo Support Engineer for Texas Utilities Generating Company. My business address is P.O. Box 1002, Glen Rose, Texas, 76043. A statement of my educational and professional qualifi-cations was admitted into evidence as Applicants' Exhibit 142B.
i (Powers) My name is David E. Powers. I am the Engineering i
Manager for ITT-Grinnell Corporation. My business address is 260 1
West Exchange Street, Providence, Rhode Island, 02901. A state-1 ment of my educational and professional qualifications is attached hereto as Attachment A.
(Deubler) My name is R. Peter Deubler. I am the Project Manager for NPS Industries, Inc. My business address is 300 Harmon Meadow Boulevard, Secaucus, New Jersey, 07094. A statement of my educational and professional qualifications was l
attached as Attachment-G to the Affidavit of Mr. Finneran, Dr.
1
, Robert C. Iotti and myself regarding the design of Richmond Inserts and their Application to support design, filed June 1, J .
i 1984.
i (Ballard) My name is Robert E. ' Ballard, Jr. I am the Pro-i i
jact Manager for Gibbs & Hill, Inc. My business address is 11 Penn Plaza, New Yo rk , New Yo rk , 10001.' A statement of my educa-l l tional and professional qualifications is attached hereto as Attachment B. )
1 (Parker) My name is A. Thomas Parker. I-am the Manager, Structural Engineering, Plant Engineering Division, for Westinghouse Electric Corporation. My business address is P.O.
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Box 355, Pittsburgh, Pennsylvania, 15230. A statement of my educational and professional qualifications is attached hereto as Attachment C.
I. PURPOSE Q. Gentlemen, what is the purpose of your affidavit?
A. In this affidavit we will respond to the questions the Board posed in its December 28, 1983, Memorandum and Order (Quality Assurance for Design) and its February 8, 1984, Memorandum and Order (Reconsideration Concerning Quality Assurance for Design) regarding the existence and imple-mentation of procedures applicable to Applicants' design process for piping and supports which satisfy provisions of 10 C.F.R. Part 50, Appendix B. These questions may be sum-marized, as follows:
(1) whether Applicants have implemented quality assurance measures for identi-fying, documenting and correcting design errors as part of the pipe support iterative design process, and not just a OA inspection of construction, -
(2) whether Applicants " wait until the and of the design process to locate and correct design errors,"
(3) whether Applicants have implemented measures to assure that the cause of significant conditions adverse to quality is determined and corrective action taken to preclude repetition, (4) whether there was a mechanism by which individuals' concerns regarding possible design errors could be brought to Applicants' attention, and
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l (5) whether Applicants' QA program satisfies the requirement of 10 C.F.R. Part 50, Appendix B, Criterion I that persons
, performing quality assurance functions j
[for design] have the necessary authority and organizational freedom, including-independence from cost and schedule.
In response to the Board's questions, Applicants proposed, on February 3, 1984, a plan that would provide the Board with the information necessary to satisfy the questions presented in its Memorandum and Order.2 Applicants supplemented their plan on March 13, 1984.3 This affidavit prcvides Applicants' response to the first task of the plan. The task, as stated in the Applicants' plan, is to Provide a detailed description of the iterative design process f6r piping and pipe supports, including a discussion of the '
design control process during all stages of 4
design, with reference to written procedures that govern and control the design and design control process, and a discussion of the various documents employed as a part of the QA/QC process (including CMCs, NCRs and DCAs) and justification for the use of these docu-ments in the quality program (e.g., trending, document retention).4 l
2 Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design), February 3, 1983. (" Applicants' Plan").
3 Supplement to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design), March 13, 1984. 1
(" Supplement to Applicants' Plan") j l
4 Applicants' Plan at 5.
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5-Comments and suggestions regarding the plan were received both from the Board 5 and the NRC Staff.6 Specifically, the Board requested that Applicants demon-strate not only that procedur'es exist for the design and f
design control process, but that Appendix B criteria were satisfied in the implementation of the design OA process.
4 Similarly, the NRC Staff indicated it believed that "a discussion limited only to a general discussion of how the process was intended to work would be insufficient . . .
" 7
, Having considered these comments and suggestions, we are providing in this affidavit a detailed description of the design process for piping and pipe supports and of the 4
QA program as it applies to this piping and support design 5 Telephone Conference, February 10, 1984 (Tr. 9257-98).
6 NRC Staff Comments on Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design), March 9, 1984.
7 The Staff also recommended that Applicants address any design control process issues which arise in connection with any of the specific technical issues of Applicants' Plan. ,
To the extent appropriate, Applicants have provided this information in connection with their affidavits on the respective plan items. However, as Applicants have
. demonstrated in those affidavits, the assertions by CASE
, that certain design practices were inadequate are generally incorrect. In these. cases, there is no " design control process issue" to address. To the extent there was a possibly valid question as to whether certain' effects should have been considered (i.e., certain potentially unstable j supports, and certain TToor-to-ceiling supports), as Applicants indicate in their affidavits on these topics, i
Applicants had identified these conditions during their normal design process prior to CASE's ' concern with the
, issue. Accordingly, Applicants believe they have responded to the Staff's suggestions in this regard. .
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process. In Section II we demonstrate that Applicants have been committed to the implementation of a OA program for design activities since the inception of the Comanche Peak project. We also describe, in Section III, the process for the design of piping and supports at Comanche Peak. There we demonstrate that each of the organizations involved in the design of piping and pipe supports has implemented a program applicable to all stages of the design process that provides assurance that errors or deficiencies in design will be identified and corrected. In Section IV, we provide, in tabular form, a cross-reference between the procedures of each organization (discussed in Section III),
and the provisions of 10 C.F.R. Part 50, Appendix B and ANSI N45.2.ll applicable to the activities within each organization's work scope on piping and support design.
Finally, in Section V we provide a detailed discussion of particular examples of the implementation of the QA program for design to illustrate satisfaction of the criteria of 10 C.F.R. Part 50, Appendix B, ANSI N45.2-1971 and ANSI N45.2.ll Draft 2, Rev. 2, May 1973, pertinent to the identification and correction of errors or deficiencies in design.8 8 (Parker) Westinghouse is committed to the 1974 version of ANSI N45.2.ll.
l In sum, we will demonstrate that the commitment to quality assurance for design activities at Comanche Peak has been in place from the initial stages of the design process. ,
i We will also demonstrate that this design QA program is much !
more extensive than the program perceived to exist by the Board. In particular, we will demonstrate that design control and verification measures as well as procedures which provide for corrective action with respect to iden-tified design deficiencies have been established by each piping and support design organization from the inception of the design process, and that similar measures, commensurate with those applicable to initial designs, are established by each organization for design changes as they occur through-out the design process. In this manner, we demonstrate that Applicants' OA Program contains measures to locate and correct design errors at all stages of the design process.
We also address in this affidavit Applicants' Plan Item 6, regarding weld design. This Plan Ite'm provides, as follows: -
Provide a description of the modifications of
- procedures that were made in response to the NRC audit regarding weld design, and a description of the review of weld design that was conducted during the code certification (N-5) process.
i II. APPLICANTS' COMMITMENT TO 4
QUALITY ASSURANCE FOR DESIGN
, Q. - Mr. Chapman, would you please describe Applicants' commit-ment regarding the establishment of quality assurance,
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measures applicable to design activities?
A. Since the inception of the project, Applicants have been committed to the implementation of a comprehensive quality 1
assurance program that requires that nuclear safety-related activities performed by the Applicants, its contractors, subcontractors and vendors comply with 10 C.F.R. Part 50, Appendix B, including quality assurance for design .
See 1
FSAR Section 17.1.9 To this end, a quality assurance i
program for the design of structures, systems and components has been an integral part of the quality assurance program for Comanche Peak. Specifically, the QA Plan for Comanche Peak requires the implementation of procedures to assure, inter alia, design verification of nuclear safety related designs. .
j l 1 i
! 9 As noted above, design activities performed.by contractors, subcontractors and vendors are also to comply with 10 C.F..R.
Part 50, Appendix B. Applicants verify that those l activities are conducted in accordance with Appendix B requirements -through regular audit and inspection. (See, I
- e. ., Applicants' Exhibit 43 (Testimony of Antonio Vega) at
, 19-20.)
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I r.d e e d , the Quality Assurance Plan for Comanche Peak recognizes the importance and requires the establishment of i quality assurance controls for design activities affecting
, safety-related activities at Comanche Peak. The Statement of Authority of that Plan provides, as fellows:
This Quality Assurance Plan establishes the Comanche Peak Steam Electric Station (CPSES) t quality assurance system to be used by Texas i Utilities Generating Company in performing design, engineering, procurement, fabrication and construction activities in conformance with the United States Code of Federal Regulations, the ASME Boiler and Pressure Vessel Code and other. applicable industry j codes and standards. (Comanche Peak Steam Electric Station Quality Assurance Plan, Statement of Authority (Applicants' Exhibit ,
i 43, Attachment 1) (emphasis added).)
. From the beginning of the project, Applicants were committed to assure that design verification procedures were
! implemented to require thats drawings, specifications, procedures and 4
instructions-accurately reflect the design i bases, conform to the repre~sentations in the i license application, meet stipulations of -
l related codes and standards, fulfill appli-
, cable regulatory agency requirements and
, implement the provisions of the TUSI Quality.
j Assurance Program.
, (PSAR Section 17.1, page 17.1.2.)
Further, measures to implement the design control function of 10 C.F.R. Part 50, Appendix B, Criterion III were established to assure, inter aliar the review and approval of initial design, j including changes or revisions,.and that personnel performing design reviews are thoroughly familiar with the regulatory i
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requirements and design basis described in the PSAR/FSAR and independent of those originating the design. 4 (PSAR Section 17.1.1.2, p. 17.1-18.) l Thase same commitments to a thore.agh program of quality as- rance for design tre reflected in the FSAR for Comanche Ps . (See FSAR Section 17.1.) The FSAR provides that '
methods of design review and verification for safety-related activities to be performed for Comanche Peak include:
- 1. Checks to compare information presented on a drawing or other document with a definite figure, criterion, or design base.
- 2. Supervisory reviews of design work, conducted by a supervisor in a given discipline.
- 3. Interface reviews, by personnel of one discipline, of work performed by another discipline to determine that the re-viewer's discipline requirements and commitments are satisfied.
4
.for the item being reviewed.
Design verification to review, confirm or substantiate
, the design is performed to provide assurance that the design meets the specified inputs. Methods of verifi-cation include but [are] not limited to Dcgign Review, -
Alternate Calculations and Qualification Testing.
( FSAR $ 17.1. 3.5, p. 17.1-19.)
i In addition to the above, Applicants have committed to the standards set forth in ANSI N45.2.ll'(Draft 2, Rev. 2)
(May, 1973), " Quality Assurance Requirements for the Design of Nuclear Power Plants," See FSAR Section. lA(B), pp.
lA(B)-26 to lA(B)-26a. This standard sets forth l
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, requirements and guidance for a quality assurance program for the design of nuclear power plant structures, systems and components.
In sum, Applicants are and have been fully committed to the establishment and implementation of a thorough and .
effective quality assurance program for design activities, in full compliance with the requirements of 10 C.F.R. Part 50, Appendix B. This commitment was made prior to the commencement of construction at Comancho Peak and has been implemented throughout the design and construction phases of the project.
III. APPLICANTS' DESIGN QUALITY ASSURANCE PROCESS FOR PIPING AND PIPE SUPPORTS A. Piping and Support Design Organizations 4
Q. Panel, which organizations are responsible for the design of
, safety-related piping and pipe supports at Comanche Peak?
A. The design process for safety-related piping and pipe sup- -
ports at Comanche Peak involves several organizations and groups within those organizations. The organizations l l
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involved are Gibbs & Hill, Westinghouse, ITT Grinnell (ITTG), NPS Industries (NPSI)10 and Texas Utilities Generating Company (TUGCO).
Gibbs & Hill is responsible for piping design with the exception of Class 1 piping, the responsibility for which rests with Westinghouse, and some small bore piping which is within the responsibility of TUGCO Pipe Support Engineering (PSE) Analysis Group.ll Responsibility for pipe support 12 design is assigned to three organizations: ITT Grinnell, NFS Industries (NPSI) and the Pipe Support Engineering (PSE) Group of Comanche Peak Project Engineering.
10 There are two NPS group companies working on the Comanche Peak Project. TUGCO has a contract with NPS Industries (NPSI) for the design and fabrication of pipe supports, and NPSI maintains overall responsibility relative to this contract. - NPSI subcontracts the pipe support design portion to Nuclear Power Services (NPS). Each company maintains its individual QA program. NPS is a vendor to NPSI in accor-dance with NPSI's QA program and thus NPS' QA program implementation is monitored by NPSI. '
11 Applicants provided information regarding the iterative design process for piping in response to a Board Inquiry on June 6, 1983. At that time Applicants submitted that the record in the proceedings is replete with evidence concern-ing the iterative design process for piping and supports (see Applicants' Response to Board Inquiry Regarding Itera-tive Design Process for Piping, at 2), but that because the -
evidence for piping alone was not easily compiled from the '
record, that evidence was consolidated for the Board. The focus of that document was more on the description of the iterative design process for piping than on the associated quality assurance program effort. The design-process for piping is, therefore, described in more detail in this a f fidavit.
12 Design of moment restraints (there are 51 in Comanche Peak, Unit 1), is performed by Gibbs & Hill.
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Q. Mr. Finneran, please summarize the evolution of the l assignment of responsibilities for pipe support design.
i A. The assignment of pipe support design responsibilities to various organizations occurred over several years as Appli-cants determined that additional design and fabrication
- resources were required for pipe supports. Initially, total
- responsibility for pipe support design rested with ITT Grinnell. That effort was subsequently divided into large and small bore (2 inch and under) piping support design e f forts , the PSE group having been established principally
- to provide designs for small bore piping supports. In 1978, j
- responsibility for large bore piping support design was subdivided between ITT Grinnell and NPSI. PSE also assumed l some responsibility for large bore support design.
j Q. Panel, please describe the organizational responsibilities for the piping support design process?
l A. The present organizational responsibilities for the piping i
and pipe support iterative design process is depicted in Chart 1. The chart clearly shows the role played by each j organization and group within individual organizations. It also illustrates that the evolution of the pipe support
, design effort has resulted in the assignment to each'of the above organizations separate and distinct responsibilities for the design of pipe supports.
1
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Generally, ITT Grinnell is responsible for the design of pipe supports in buildings associated with Unit 1 and
! common areas. The pipe supports in the containment building itself are the responsibility of NPSI (although a few con-tainment supports were assigned to ITT.Grinnell). The PSE l
{- Group is responsible for small bore piping supports and a l
limited number of large bore supports. (Applicants' Exhibit 142 at 9; NRC Exhibit 207 at 12; Tr. 5277-78.)
l B. Piping and Support Design Process Q. Panel, what are the concerns which have been expressed 1
I regarding the piping and support design process at Comanche Peak?
A. The principal concern is one raised by the Board in its December 28, 1983, Memorandum and order. Therein, the Board l construed the evidence of record to indicate that Applicants
" wait until the end of [their] design process to attempt to i
- locate and correct design errors" (Memorandum and Order' at i
20-21.) However, as we discuss below, the quality assurance program for the design process includes design control and i
verification meesures, as well as corrective action. These
- activities are conducted in all phases of the design pro-cess, from its inception through the final certification of design. Accordingly, we describe below in detail that de- '
sign process, defining the activities of each design organi-zation in that process.
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Q. Before describing the quality assurance program for the i
piping and support design process, would you comment on the nature of the iterative design process for piping and supports.
A. Yes. We have observed some apparent misconceptions regard-ing the need for an iterative design process, including i
questions as to whether the process is unusual in the design of piping and support systems in power plants, including nuclear facilities. It is important to understand, when i
considering the quality assurance program applied to the 1
design of piping and supports, that this process is used and is necessary for designing these systems at virtually any power plant.- Rather than present a lengthy discussion of
. this process, however, we have attached an article from
" Power" magazine, titled " Standardization and computers cut l costs of pipe-hanger and support system design" (February t
! 1979) (Attachment D), which describes the nature of and the I ' need for the process. We adopt the statement in the article (at 119-20) , that: .
. The hanger-design process is not simple. It
! is complex and tedious, involving many dis-ciplines at the A/E firm, at the hanger
- manufacturing plant, and at the site. The
- process is iterative, continuing until the plant goes oporational. (Emphasis added).
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In sum, the iterative process Applicants have employed in the design of piping and supports at Comanche Peak is not only common but is necessary for designing adequate piping and support systems.
- 1. Gibbs & Hill i
- a. initial designs Q. Mr. Ballard, what is the design process employed by Gibbs & 1 Hill for the design of Class 2 & 3 piping and supports?
A. (Ballard) The process of Class 2 & 3 piping and support j design begins with the generation of design specifications by Gibbs & Hill. Separate design specifications are prepared for piping (MS-200) and for supports (MS-46A) and i
! are transmitted to the responsible design organizations.
! The Gibbs (: Hill Applied Mechanics Discipline functions as the piping. stress analysis organization. Its
! responsibilities are summarized below and illustrated in Chart 1.
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, In performing its function as a stress analysis organization, Applied Mechanics first establishes the pipe routing based upon a conceptual piping flexibility analysis. ,
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This is accomplished in cooperation with the Gibbs & Hill i Mechanical Department. That Department generates composite i
! piping drawings from the mystem descriptions and general arrangement drawings. Piping layout drawings showing the i routing of systems from equipment to equipment are then-F y v .--ye- -
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generated and supplied to Applied Mechanics. It is Applied Mechanics' responsibility to locate anchors along the piping ,
l system, to assign " stress analysis problem" numbers and to perform a free thermal analysis to verify that each " stress analysis problem" routing contains sufficient flexibility.13 Also, if the stress problem contains equipment, thermal loads imparted onto equipment nozzles from the pipo routing are verified to be within established allowables.14 Those allowables are incorporated into equipment specifications by i the G&H Mechanical Department.
Recommendations by Applied Mechanics to improve'the piping flexibility and/or decrease the equipment nozzle loads are supplied to the Mechanical Department. Such
- recommendations may include the additio.n of expansion loops, I
expansion joints or flexible connectors and pipe routing changes. Completed pipe routing drawings, resulting from j
i acceptable flexibility analyses, are then transmitted to the pipe support vendor.
Q. Messrs. Deubler and Powers, what do NPSI and ITT Grinnell,15 as the pipe support designers, do with the pipe routing i 13 A piping " stress problem" consists of a designated length of pipe for which a pipe support is an accessory that cannot be designed separately from the overall length of pipe, i.e., l the design must interface with the stress analysis of the pipe.
14 The method for performing the thermal stress analysis is set forth in Gibbs & Hill Analytical Engineering Guide AEG-501.
15 (Finneran) The PSE Group had not been formed at the time those activities were undertaken.
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i drawings received from Gibbs.& Hill?
i A. (Deubler and Powers) NPSI and ITT-Grinnell utilize these drawings to locate deadweight and seismic pipe supports.
NPSI and ITT Grinnell design engineers prepare preliminary drawings locating deadweight and seismic supports. Support i
location feasibility is based upon an interference check i .
utilizing piping, structural, electrical and HVAC drawings.
l Pipe routing drawings indicating preliminary deadweight and l
seismic support locations are then transmitted to Gibbs &
i Hill Applied Mechanics. ;
, Q. Mr. Ballard, what does Gibbs & Hill do upon receipt of the 1
preliminary support locations? ,
A. (Ballard) Applied Mechanics uses this information to perform f
an "as-designed"16 deadweight, thermal and seismic analysis of the piping systems. Direction and guidelines for per-j forming these analyses are set forth in Gibbs & Hill's Analytical Engineering Guides, AEG-501, 502 and 503, enti-tied " Thermal Stress Analysis for ASME Code Section III
- Class 2 and 3, ANSI B31.1 Piping Systems", " Seismic Analysis i
of Piping Systems in Nuclear Power Plants" and " Pressure and Deadweight Analysis, " respectively.17 Upon completion of j-l 16 The term "as-designed" is used here to distinguish this
,' phase of the design process from thellater "as-built" phase.
~
I i At this stage of the ' process, the analyses utilize design information as input rather than as-built information.
17 Further, direction is supplied by the following AM internal l memoranda, as follows:
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these analyses, support loads and corresponding support locations are released to the support vendor for design and fabrication. The support vendors proceed with the design l and fabrication of the supports, as will be described later in this affidavit. If changes to support types or locations are necessary, Gibbs & Hill is requested to approve the changes before pipe support design proceeds. If piping 0 reanalysis is required, the process previously described is
- utilized to. generate a new "as-designed" stress analysis
, with new support loads. Upon satisfactory- completion of 4
that reanalysis, pertinent support info'rmation is trans-i mitted to the support vendor for design and fabrication.
! Q. Mr. Ballard, what is the role of the Site Stress Analysis Group?
t (footnote continued from previous page)
- 1. Memorandum dated January 17, 1979, titled " Stress
- Analysis Procedures"
- 2. Memorandum AM-M-2179, dated November 14, 1979, titled
" Hand Inputted Stress Intensification Factors" t *
- 3. Memorandum dated, January 10, 1979, titled " Coding of Valves for Stress Analysis"
! 4. Memorandum AM-M-694, dated March 3, 1979, titled
( " Procedure for Analyzing Seicmic Anchor Movements"
- 5. Memorandum, dated June 7, 1979, titled " Moment Restraint Modelling-Procedure" 1
The aforementioned documents establish mechanisms in accor-dance with 10 C.F.R. Part 50, Appendix B, Criteria III, per--
- taining to the' establishment of measures to assure that applicable regulatory requirements are. correctly translated j into procedures and instructions, j
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i A. The Site Stress Analysis Group (SSAG) is administratively i part of the Site Technical Services Group but reports to Gibbe & Hill. SSAG was established to evaluate and approve proposed changes and modifications to pipe routing, pipe 4 support locations and/or pipe support type, as requested by site engineering groups. The evaluations are made employing i
the latest as-designed piping stress analysis. SSAG provides revised design information to the applicable site
- organizations. All these activities are conducted in accordance with CPSES Engineering Instruction CP-EI-4.6-9, j Rev. 1, entitled " Performance Instruction for Piping i
I Analysis by SSAG" and Gibbs & Hill Applied Mechanics procedures previously cited. These documents have been established to assure that the SSAG activities are i
accomplished in a manner commensurate with the original as-designed analyses.
- b. design checking and verification Q. Mr. Ballard, how is the design checking and verification f process implemented by Gibbs ' & Hill?
' A. In accordance with Analytical Engineering ' Guide ("AEG")-501, calculations are checked and verified.18 This procedure 1 18 For Gibbs & Hill, " verification," or design review, is an independent assessment of tdie acceptability. of piping analysis in accordance with specifications and regulatory i
criteria. It can consist of a spot check of critical parts of an analysis, line-by-line review or performance of separate proof calculations or testing. Personnel assigned the role of design reviewers are chosen by the chief engineer for their experience and knowledge of the appli-I' (footnote continued) t
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1 establishes tb- interface between analyst, checker, job engineer and design verifier. Each calculation must first receive a checker's comments on a check copy, which along with the original, is submitted to the job engineer. The job engineer assures that all the checker's' comments have been resolved prior to design review.19 As I will discuss later, if a significant or recurring error is detected during this process. an internal memorandum is issued to correct this deficiency. Once checking is completed to the satisfaction of the checker and job engineer the stress analysis is examined to determine whether equipment nozzle loads exceed those contained in equipment specifications.
As discussed previously, further adjustments in the piping and support system may be made in accordance with memorandum procedure AM-M-702. When the system is totally in balance, then the analysis may proceed to design review.
To accomplish these tasks, Applied Mechanics' "as-designed" calculation documentation is prepared in accordance with Gibbs & Hill procedure " Seismic and Thermal (footnote continued from previous page) cable criteria. These reviewers report to the chief engineer in a separate reporting path from the analyst.
" Checking" is perforned by a senior member of the staff analyst's group and consists of a line-by-line review of all assumptions, input and results presented by the analyst.
19 Drawings that are required during this phase and subsequent phases of the analysis are governed by GEH Project Control Procedure, PC-2, entitled, " Drawing Control Procedure" and ;
Design Control Procedure, DC-3, entitled, " Drawing l
-Preparation, Checking and Approval Procedure".
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Restraints - Release for Design and Fabrication," dated December 1977, and is based upon the requirements contained in Design Control Procedure, DC-7, titled " Technical calculation Procedure" which establishes guidelines to ensure that technical calculations are prepared, checked, i reviewed, approved and maintained in a controlled manner. !
Q. Mr.-Ballard, what are the criteria which govern personc performing independent verifications?
A. Independent verifiers are persons who may be within the same engineering organization, but who are not the individuals who performed the initial analyses, in accordance with the requirements of ANSI N45.2.ll, Section 6.1, and 10 C.F.R. Part 50, Appendix B, Criterion III.
- c. Audits Q. Mr. Ballard, what mechanisms exist to provide assurance that the design and design verification process is being properly implemented?
A. In accordance with the requirements of 10 C.F.R. Part 50, Appendix B, Criterion XVIII and ANSI N45.2, Section 19, Gibbs & Hill has established a comprehensive audit program.
This program requires that audits of the design procens be performed on a r,egular basis by independent, i.e., not having direct responsibility-in the audited area, appro-priately trained audit personnel. The audits verify that the design program satisfies applicable regulatory require-ments and that the procedures are properly implemented.
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1 These audits are governed by Gibbs & Hill Quality Assurance Procedure, QA-4, titled "CPSES-Internal Audit Procedure" and the Gibbs & Hill Quality Assurance Department Instruction, QAI-7, titled " Audit Performance, Reporting and j Follow-up." These procedures implement the requirements of i 10 C.F.R. Part 50, Appendix B, Criterion XVIII. Follow-up action by the Gibbs & Hill Quality Assurance Department is f
- also governed by Instruction QAI-7. In accordance with i
- QAI-7, the audit results are reported to the manager of the i
- audited area. In short, this auditing process assures an 1
- independent evaluation of the design control prooram.
1 j In addition,'although not mandated by NRC regulations, i Gibbs & Hill has established a procedure (QAI-3) which I provides for the QA Manager or Project Manager to request that unscheduled surveillances or technical audits be performed under the direction of the QA department. Tech-l l nical expertise may be provided from other departments,; or
, outside consultants may be utili=ed. Independence is main-
! tained as with internal audits, and a written report is presented to the QA Manager for further action, if required.
- These technical audits provide an additional mechanism by i
I which the need for corrective action in the design process i
- may be identified.
Q. Mr. Ballard, is the Gibbs & Hill organization which performs the piping stress analyses subject to audit?
4 4
l
, l
! A. Yes. In fact, during the design process (including the as-
{ built stress analysis) Applied Mechanics has been audited by 1
Gibbs & Hill Quality Assurance 14 times. Nine (9) of the 14 internal audits were performed on "as-designed" piping j i
j' stress analysis process. The remaining' audits focused on l ,
"as-built" piping stress analyses.20 4
l In addition, external audits of Applied Mechanics' j activities have also been performed by the NRC (Region IV No deficiencies or required action s
andNRR)andTUGCCf. '
- items were identified in the NRC audits. TUGCO QA has j audited Gibbs & Hill Applied Mechanics twice. Findings
] requiring corrective action have been addressed and resolved
- in those audits. Further, TUGCO audits the Gibbs & Hill Quality Assuran:e Department to assure proper implementation j of the Gibbs & Hill audit program. Also, two internal
! audits have been performed on the Gibbs & Hill Site Stress
, Analysis Group within the past year by Gibbs & Hill Quality
~
i Assurance.., Prior to those audits, TUGCO Quality Assurance i had also audited the SSAG. One of these audits was a joint Gibbs & Hill and TUGCO QA effort.
l 4
i 20 In addition to these internal audits, the Gibbs & Hill QA
! Department periodically conducts seminars to indoctrinate i Applied Mechanics engineers in the requirements and l importance of DC-7, DC-8, 10 C.F.R. Part 50, Appendix B and i ANSI N45.2.11. The channels for resolving technical issues )
(e.g., comments by the checker, questions by the design j reviewer or generic . memoranda by the Chief or Job Engineer) were reemphasized. ,
l 1
Finally, five technical audits, described above, have been performed of the Applied Mechanics discipline piping .
analysis functions. Findings requiring corrective action ;
have been addressed and follow-up reviews have confirmed problem resolution.
- 2. Westinghouse
- a. Initial Designs Q. Mr. Parker, please describe Westinghouse's responsibility for piping design and analysis at Comanche Peak.
A. Westinghouse is responsible for piping design and analysis of the reactor coolant loop and for analysis of Class 1 auxiliary piping. In addition, Westinghouse has the ,
1 s responsibility for analysis of some non-Class 1 auxiliary piping. The geometric layout (i.e., routing), sizing and support design was performed by others. Two specifications are used by Westinghouse in the piping and support design process. Westinghouse is responsible for the development of ;
one specification (Westinghouse specification 955125, Rev. 1 (5/17/83), and attachments). This design specification applies to ANS Safety Class 1 and ANS Safwty Non-Class 1 extensions. The other specification is developed by Gibbs &
Hill. It pertains to all ASME Code Class 2 and 3 piping.
These specifications are incorporated into our design process as indicated in Chart 1.
e
- 26 -
f It is important to understand that Westinghouse is !
{ functionally organized in its engineering disciplines. This
- means that the same people, computer codes, quality assurance program and practices, and procedures used on the 1
I Comanche Peak Project are utilized on other Westinghouse
)
- nuclear power plant projects. Another benefit of being functionally organized is that the process is monitored i
continually. Westinghouse, as an NSSS supplier, is subject i
I to review and audit by diverse organizations including the ASME, utilities, architect / engineers, and government
- agencies. The NRC has audited Westinghouse 30 times from l
- 1975 to 1984, inclusive. Nineteen of these audits focused
{ [
i j specifically on design control. TUGCO QA has audited
- Westinghouse eleven times from 1976 to 1983 inclusive. Ten li of these audits included design control, two specifically in l
l the piping area.
l Q. Mr. Parker, describe the process Westinghouse uses to
- implement these responsibilities.
i j A. The Westinghouse design process is essentially the same for j . .
1 Class 1 and non-Class 1 piping except that the analysis for Class 1 piping includes a fatigue analysis and concludes
- with the issuance of an ASME Class 1 Stress Report, neither I
t of .which are required for non-Class 1 piping. In addition, l actual support stiffnesses based on values computed by the l j support design organizations are used in the evaluation of i
Class 1 piping., Support stiffnesses provided by TUGC0 in a
{ generic format as a function of pipe size, based on (
) information provided by Gibbs & Hill, were used in the analysis of non-Class 1 piping. Chart 1 illustrates the :
4
- Westinghouse /TUGCO interface and the design process for the !
scope of activity for which Westinghouse is responsible as l
defined in Westinghouse /TUGCO interface procedures.
i The Westinghouse /h0GCO interface is controlled by
] agreed interface proceduros. These interface procedures i
i detail functional responsibilities of each organization l
relative to scope assignments, work locations, applicable l
quality assurance programs, project correspondence methods, ;
i !
- and record retention requirements. Detailed interface 3
} matrices define specific activity responsibilities for 1
interfacing parties relative to Class 1 and non-Class 1 piping and also define specific design document
} responsibilities.
]'
The design process is initiated by TUGCO when it i provides Westinghouse with input data in the form of h response spectra, seismic displacements, operational I
I characteristics, stress isometric drawings, support i
i locations, and support stiffnesses. 'Mie process is completed when Westinghouse transmits the final as-built j project piping documentation. Analysis, verification, '
reanalysis and reverification are all considered part of the
- design process.
e
Upon receipt of the design input data, Westinghouse performs a detailed computer analysis of the piping system to establish that the piping stresses satisfy applicable design criteria. Implicit in this portion of the analysis is the determination that the support locations and types (i.e., snubbers, springs, rigids) are acceptable. In the process of performing these evaluations, it is sometimes' necessary to go back through the design process several times, i.e., iterations, to arrive at a piping system configuration where the input parameters accommodate acceptable results.
Q. Mr. Parker, please explain Westinghouse's role in the remaining aspects of the iterative process.
A. Af ter the analysis is completed and verified, Westinghouse transmits support design information to TUGCO. This information includes the calculated loads acting on each support and the piping displacements at support locations.
In addition, if the analysis results in changes to the support locations and/or types, these changes are also provided to TUGCO. If these changes are accepted by the support design organizations, Westinghouse is notified that the analysis is acceptable. Correspondence is made using l agreed controlled interface procedures as previously discussed. Should the support design organizations' review indicate that the suggested changes are not acceptable, as would be the case if a recommended change in location of a
support rusults in interference with other equipment or structures, then TUGCO informs Westinghouse. A new piping evaluation, and piping analysis if deemed necessary, is ,
l performed and the process outlined above is repeated until acceptable results are obtained.
l When an acceptable piping analysis is completed, t
Westinghouse performs fatigue analyses for class 1 lines and i
! evaluates the impact of postulated pipe breaks and asso-l
! ciated jet impingement loads on the qualification of the i piping. TUGCO also provides to Westinghouse for review the l l >
l locations of potential interferences with piping for which i Westinghouse has responsibility. If the results of the reviews are acceptable, Westinghouse transmits to TUCCO !
i deflections at branch piping connections, anchor icsos, and i increases in support loads. If they are unacceptable, the l design process is reinitiated.
Following the support design organisations' evaluation of the Westinghouse transmittal, these organisations confirm '
the adequacy of the esisting support configuration, or l
l redefine the support locations, stiffness characteristics,
- or support types to Westinghouse. If any support changes l-are proposed by TUGCO, Westinghouse performe a reevaluation.
If support changes are not required, the piping and support design is released for construction by TU0CO.
l I
1 I
- b. Design Checking and Verification Q. Mr. Parker, please describe the verification process Westinghouse uses as part of its design process.
A. The verification process employed to reduce the likelihood of errors in the calculations and design approaches is an important part of performing the piping analysis. Piping system analysis ve'.ification is accomplished in accordance with a procedure that requires independent qualified engineering review and documented verification of each analysis package. The verification process requires the reviewing engineer to ascertain such information ass (1) is work properly documentedt (2) are the purposes and assump-tions statedt (3) is reference material appropriately des-cribedt (4) are the assumptions and engineering evaluations used in the work clearly defined and justifiedt (S) are the correct equations utilizedt (6) does the derivation of the work follow a logical sequence and is it organized; and (7) are the results clearly marked and do they accomplish the stated purpose. Cnly after the verifier is satisfied that the work is correct does he document his review and approval. The procedures governing this process are identified in Section IV, Table IV.1 and Chart 1.
In addition, I would note that with respect to the analytical tools used by Westinghouse on which designs are based, e.g., computer codes, Westinghouse reviews and verifies those to assure their validity prior to their use.
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- c. Audits Q. Mr. Parker, what mechanisme exist to provide assurance that t '
the design and design verification process is being properly '
f I implemented?
- A. It is Westinghouse policy that audits be carried out and i documented in accordance with established schedules and t
)t procedures to verify the compliance and effectiveness of !
ongoing safety-related activities such as design and design verification with applicable areas of the Westinghouse quality assurance program.
] Audits are carried out by qualified auditing personnel f
- under the direction of a lead auditor responsible for 4 '
j reviewing the results of prior audits, developing a written i I audit plan, notifying the involved organisations and '
l .
I conducting the audit, preparing and issuing the audit ,
l .
{ report, and performing the follow-up required to close out [
open action items. Members of audit teams do not have
- direct responsibilities in the areas being audited.
1 Management of the audited organisation is responsible for reviewing and investigating audit nonconformances, taking 3
appropriate corrective action including action to prevent j recurrence, and documenting such action. .
A typical audit includes interviews with key personnel, review of procedures for adequacy and content, review of work and records to verify implementation of the quality
, assurance program, and an assessment of the effectiveness of
that program in accomplishing its intended purpose. Audit findings are presented in a post-audit conference and in the audit report in detail sufficient to assure that corrective action can be taken effectively by the audited organization.
Follow-up activities include recording and tracking action items, report,ing to management the status of open items and the progress being made to resolve them, verifying that corrective action has been accomplished, and maintaining the documentation of follow-up, evaluation, and resolution of open items in the audit files. Such audits of safety-related activities are functional in nature. They generally cover a number of projects beitig worked on.
- 3. Pipe Support Design Organizations
- a. NPSI (1) initial designs Q. Mr. Doubler, what design specifications and requirements govern the NPSI support design process? '
A. NPSI pipe support design activities are governed by Gibbs &
Hill Design Specification MS-46A, " Nuclear Safety Class Pipe Hangers and Supports." This document establishes the cri-teria for pipe support design, and was subject to NPSI review prior to its being utilised for design, pursuant to NPS Work Procedure No. 3.0 1, " Owner's Design Specification Review." After review the specification requirements are incorporated in the project procedures and instructions.
Revisions to the specification are similarly reviewed and ,
incorporated into the design requirements. Similarly,
l design requirements generated internally at NPSI are reviewed prior to implementation, in accordance with Work Procedure No. 3.0.2, " Design Requirements Review."
l Q. Mr. Deubler, please describe the design control and design review process of NPSI for preparation of new support l designs for Comanche Peak.
l A. New pipe support designs for the Comanche Peak Project are r
l controlled by NPS Work Procedure 3.0.5 " Pipe Support Design control New Design." The design and review process estab-lished by this procedure is illustrated in Chart 1, and r
described below. Additional procedures applicable to these activities are identified in Chart 1 and Table IV.l.
The first step in the design process is the accumulation of necessary data (e.g., piping analysis summary, piping isometric, applicable equipment drawings) regarding the design. Upon receipt of incoming design info rmation, the Design Project Engineer reviews the ,
information to ensure that all necessary design information is contained in the design package and forwards the design l
l package to the Design Team Leader. The Design Team Leader also checks to assure himselt that necessary information is in the design package, affixes a support design / review checklist to it, and assigns the package to a designer.
Upon receipt of the design package, the designer produces a conceptual drawing of the support. If the designer finds that a support cannot be designed at the
l location indicated by Gibbs & Hill (e.g., due to interference or the absence of an accessible attachment to the supporting structures), the following action is undertaken:
- 1. The Design Project Engineer notifies Gibbs & Hill Applied Mechanics and proposes a solution.
- 2. Gibbs & Hill, after reviewing the proposed solution, notifies the NPS Design Project Engineer and indicates their concurrence or alternative recommendation.
- 3. Based on the resolution of the particular problem the design will proceed as outlined.
When the designer completes the design of all supports in the design package, the package is returned to the Design Team Leader. A checker assigned by the Team Leader performs preliminary checks of the conceptual design by verifying the design information (e.g. , su'pport loads, location, type and interferences). Any errors disclosed are corrected by the designer and rechecked by the checker.
Upon completion of th.s checking phase, the Team Leader .
sends a copy of each Class 1 (and Class 2 & 3 if deemed necessary) conceptual design to the site for field
! verification. Any information that will affect the installation of the support is noted on the copy of the conceptual drawing.- This copy is signed by the field engineer and sent back to the Design Team Leader. A
! designer incorporates all field comments on the original conceptual drawings.
Upon incorporation of field comments, a copy of the -
complete design package, along with a pipe support calcula' tion transmittal form is forwarded to the Structural Team Leader. The design package is then assigned to a structural engineer who performs the structural cniculations for the support. Any modification to the conceptual design as a result of these calculations is coordinated between the Structural Team Leader and the Design Team Leader.
In addi tinn to the above process, another iteration cycle is involved in the design of Class 1 supports. This cycle consists of providing support stiffneos values for inclusion by Westinghouse in the piping analysis. After inclusion of the stiffness values, revised support loads are l received. The supports are modified, if necessary, for the l revised loads and any revised stif fness values are provided for use by Westinghouse in reevaluation. This cycle con-tinues until the support stiffnesses generated in the sup-port design are consistent with those used in that piping analysis which provided the loads for the support design.
The initial support design is then finalized and transmitted to TUGCO.
(2) design checking and verification Q. Mr. Doubler, please describe the design verification process NPSI employs as part of its design process.
7 t
' I
[
l
! I A. When the design activities described above are complete, a j l
structural Designer checker (who is not the same individual ;
l i who performed the calculation) performs a complete check 21 of the calculations. After modificatione, if necessary, j have been made by the structural Engineer and rechecked by :
the structural Design Checker the design package is returned ,
to the structural Team Leader.
f The completed structural calculatione and design j l
package are sent to the Pipe support Design Team Leader for assignment to a Draftsman. A checker assigned by the Design i l i Team Leader performs a final check of the pipe support de- !
i tail, utilising the checklist for design and final checking.
i Any drafting errore disclosed are corrected by the Draftsman and rechecked by the checker. If design errors are die- l closed the design is returned to the original designer for (
correction and rechecking as described above. Once the j design package is accepted, the Design Team Leader forwarde
+
the original detail drawings and calculatione to the project Engineer for his review, approval and sign off. If the l 1
Project Engineer determines that additional work should be performed, the package is returned to the Design Team j Leader. Upon completion of the additional work, the support j 21 In addition to checking the data utilised and the mathemation f
, of the calculations, the checker verifies the following (1) l
! the proper design inpute were utilised, (2) assumptions, I
where required, are reasonable, (3) en appropriate design method was used, and (4) the support design conforme.to the ,
appliemble code and specifications. l I i l 1
___________________________-__-________-______a
f l
i
(
l drawings and calculations are again reviewed by the Project Engineer for final approval. Aftes the Project Engineer's l
[
approval, the design package is forwarded to the QA j i department, Which reviews the design packages on a sample :
l basis for inclusion of quality requiremente as defined by l the contract specification and internal procedural ;
j requirements, i.e., appropriate approvals, references, etc. :
1 !
1 After the above activities have been completed the !
original pipe support drawings are forwarded to the Project 4 t'
] Manager for transmittal to TUGCO for construction of . the I
z supports. j 4
(3) audits :
j Q. Mr. Doubler, what mechanisms exist to provide assurance that [
I ;
the design and design verification process is being properly 4
. implemented?
A. NFS has established a comprehensive system of planned and
} periodic audits in accordance with 10 C.F.R Part 50, Appen-dix B, Criterion XVIII. Section 18.0 of the NFS Quality
)
1 Assurance Manual and Work Frocedure 18.0.1, "QA Program -
1 I
j Audit control" establish the requirements for the conduct of i .
I audits. The audits are the responsibility of the QA j department, which reports to the Es,eoutive Vice President.
I i l
This reporting level givee QA the required authority and -
- organisational freedom, including sufficient independence
} from cost and schedule. A QA Lead Auditor, who does not
, i j have direct responsibility for the area being audited, is
.s
. . . . - - - . . - - - . - - - - . . . . . . - . ~ . . - . . . . . . . . .. w..... . . . - - . . . .. . ~ - .
responsible for supervising and/or performing audits.
Audits are performed by qualified individuals, but who have no direct responsibility for the activities being audited.
Internal audits by the NPS QA Department are performed utilizing written checklists, and results are documented in a written report to the QA Manager and the manager of the audited department or discipline. Follow-up action, as appropriate, including reaudits conducted in the same manner as the original audit, is taken with respect to audit findings. For example, over the last five years eleven (11)
- internal audits were performed with respect to design
! activities associated with Comanche Peak. During this same time period, five audits of NPS by NPSI, three audits by TUGCO and two audits by the NRC have been conducted.
Finally, in addition to the audit program established pursuant to 10 C.F.R. Part 50, Appendix-B, NPS management has i,nstituted a program of technical audits. This program began in 1981 and is designed to provide a review of'the technical aspects'df design activities, rather than the ,
.x programmatic aspbits reviewed in the normal audit process.
. . . 4 ,
This review is performed by engineers who were not involved in the original design. The review is performed on a sample =
basis, tosassure: (a) design conformance.with applicabl'e.
ccodes,-design specification and standards and (b) adequacy
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I of the design analysis. The results of the review are documented in a written report to the Engineering Manager who initiates corrective action, as necessary.
I
- b. ITT Grinnell 1 (1) Initial Designs Q. Mr. Powers, what design specifications and requirements govern the ITTG support design process?
A. Gibbs & Hill design specification MS-46A " Nuclear Safety Class Pipe Hangers and Supports" is the controlling project design specification for pipe support design activities by ITTG. This specification is reviewed, accepted, and implemented in accordance with Section OCH-2.0 of "ITT Grinnell Corp. QA Manual - Pipe Hanger Division" ("PHDOAM")
and Section QCES-2.3.0 of "ITT Grinnell Corp. Engineering ...
Services Quality Assurance Manual" ("ESQAM").
Q. Mr. Powers, please describe the design control and design review process of ITT Grinnell for preparation of new pipe
~
support designs for Comanche Peak.
A. The manuals described above, PHDQAM and ESQAM, are the principal quality assurance documents through which ITTG procedures governing the design activities for the Comanche Peak Project are established. Chart 1 and Table IV.1 list j the procedures employed at each step of the design control process.- The discussion below summarizes that process.
i
, _ . . _ - - - . _ . _ . _ - . . _ . , - . - - . _. .~ -
The design and design control process employed by ITT Grinnell is very simila'r to that of NPS described by Mr.
Deubler. Similar information which is provided to NPS by Gibbs & Hill (e.g., piping analysis sammaries, piping isometrics) is transmitted to the ITTG Project Manager for his review. He will forward the data to the Engineering Manager who in turn assigns the material to the Engineering Supervisor. Once document review and control activities are accomplished, the Engineering Supervisor assigns the per-tinent data to a Design Engineer to develop the decign. The Design Engineer returns the work package, which includes all calculation's, to the Supervisor for assignment to a design checker. When checking is completed, the work package is again returned to the suporvisor who forwards the package to drafting. At this point the support detail is prepared by a draftsman (and checked by a drafting checker) .
(2) Design Checking and Verification Q. Mr. Powers, please describe the design verification process ITT-Grinnell employs as part of its design process.
A. Errors or deficiencies identified during the design review process can be identified by any individual including the design checker, drafter or by a drafting checker. The design checker is responsible for the " verifying or checking process" described in 10 C.F.R. Part 50, Appendix B, Criterion III. The design checker assures the accuracy and completeness of the calculation, assures that the support
-: . x : . = . :. = . . . - . a ;- . . . ..- .w :.z ; .--- . : :... . . . . . . . ; =:.u will perform its intended function and that the design methodology is acceptable, and that all codes, standards and specifications are satisfied. This individual is not the person who performed the original design, although he is part of the ITTG organization. In all cases, the work is returned to the Engineering Supervisor Who reviews the work and determines appropriate action. In each instance the
, original Design Engineer must concur with, and sign off, the change made to the original design.
Finally, the Design Engineer reviews the final detail l prepared by the draftsman and, if satisfied, signs it and forwards it to the design checker for his review and sign-off. The work package is finally approved by the Engineering Supervisor provided he determines that all work has been satisfactorily completed. At this point the package is transmitted to TUGCO by the Project Manager. If the Engineering Supervisor had not approved the package, he would reassign it to the Design Engineer with his comments, and the design process repeats as outlined above,.until a satisfactory work package is obtained.
(3) Audits
-Q. Mr. Powers, What mechanisms exist to assure that the design and design verification processes are being properly; .
l implemented?
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a>w.-.- ner*. %- yew -m+- .---mV w m -- e. w %m- yw ^
.- a .. . . - . . . .a.- '
A. The principal means by which this is accomplished is through J audits. Internal and management audits are the responsibility of the Vice President and Director of Quality Assurance and are performed by trained and qualified audi-tors assigned by him, who have no direct responsibilities in the audited area. Procedures QAM 12.1 of PHDOAM and QCES 2.18 of ESQAM cover the monitoring of these Quality Assurance Program Audits. Audit results are transmitted to the appropriate department manager. Audit findings are resolved and corrective action te. ken, as negessary, in accordance with QCH 10.1 of PHDQAM and QCES 2.16 of ESQAM.
The design process at ITTG has been routinely audited by i
both internal as well as external organizations. Fifteen ITTG internal audits have been conducted with respect to design activities associated with Comanche Peak. During the same time frame, the ITTG Engineering Departments underwent an average of ten additional internal audits per year.
There have also been three external audits (and one surveillance) conducted by TUGCO and about twenty audits conducted by other customers. Also, two ASME and six NRC audits were performed.
In addition, beginning in 1978 ITT Grinnell's resident Quality Assurance engineers were not only trained and quali-fled (pursuant to-QCES 2.18) as' Quality Assurance Systems Auditors, but were selected on the : basis of expertise as l pipe support engineers. (In some cases these individuals 1
. --, , -- ,- , - - r-, ,, .,
a ..
are Registered Professional Engineers). Accordingly, these auditors are responsible not only for reviewing the implementation of the PHDQAM and ESQAM procedures, but also l for auditing technical activities for compliance with the ASME Code, technical specifications, and other applicable codes and standards.
- c. Pipe Support Engineering (1) Initial Designs Q. Mr. Finneran, what procedures are employed by PSE to review design specifications and requirements for incorporation into the support design process?
A. When the PSE Group was organized, Specification MS-46A was a well-established document and had already been used exten- ,
sively on the project by ITT and NPSI for several years.
Thus, there was no need for PSE independently to review and comment on MS-46A. MS-46A was adopted as a required refer-ence for PSE in Section I of the PSE Engineering Guidelines.
In addition, information set forth in MS-46A is included in the Guidelines, as appropriate, and drawings are prepared in accordance with the requirements of MS-46A.
Further, MS-46A is required indoctrination for all PSE 1
design engineers under the CPSES " Indoctrination Program,"
CP-EP-2.0. As such, whenever MS-46A is revised, all design engineers are re-indoctrinated. Finally, proposed changes 4
l I
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to the specification are evaluated and appropriate action (e.g. modification) is taken with respect to affected procedures and guidelines.
Q. Mr. Fingeran, please describe the design control and design review process of PSE for the preparation of new support designs.
A. To implement Applicants ' commitments regarding design activities performed by Comanche Peak Project Engineering (CPPE)22 engineering procedures have been established to assure that quality assurance measures are imposed for all design, design control and verification, and design change activities. These procedures set forth requirements that govern all design activities performed by CPPE. The principal implementing procedure for these activities is CP-EP-4.0, " Design Control" the purpose of which is, . as follows:
to outline general requirements for the site design control program to ensure that -
activities that affect the design of safety-related or other designated items will be adequately defined, developed, verified and documented . . . . (CP-EP-4.0, Section 2.1)
The procedure further specifies that engineering managers are tp ensure that engineering design activities for which
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they are responsible are identified, planned and controlled l
22 Comanche Peak Project Engineering is a multi-discipline organization of TUGCO, which provides various engineering services to the project. PSE (formerly called PSDG - Pipe
, Support Design Group) provides pipe support design services.
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N in accordance with procedures governing design verification and design change control. Consequently, CPPE design activities are also performed in accordance with the procedures CP-EP-4.5, " Design Verification," and CP-EP-4.6,
" Design Change Control" (or in later revisions " Field Design Change Control").
The basic design document governing PSE design activities is instruction CP-EI-4.0-1, " Design and Design Verification Control for Pipe Support Engineering". PSE support engineers use load and support location information provided by the appropriate piping analysis group for their support designs. Gibbs & Hill, Westinghou'se and PSE Engineering (for a limited quantity of small bore piping) each serve as piping analysts and provide load information to PSE support designers. If proposed support locations are determined not to be feasible, PSE resolves the matter with Gibbs & Hill or Westinghouse, as appropriate. ' Subsequent reanalysis and reissue of support loads on a particular str'ess problem may be required.
CP-EI-4.0-l' specifies that guidance for support' design is set forth in the " Pipe Support Engineering Guidelines".
This guideline serves as a basic support. design manual. All design engineers receive indoctrination in the guidelines before beginning any design work- at CPSES.- Support design documentation is also created in accordance with that instruction, which provides:
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. . . . - _ . . . . . . . . _ , . . . . . . . , . ,, . ._ , . . . - - , . .. c- . -
l 46 - 1 Design documents generated by PSE shall have sufficient design input documentation (criteria, data, calculations, etc.) to allow a consistent basis for. making design decisions, accomplishing design verification and evaluating design changes.
Upon completion of a support design, taking into account the load information from the piping analysis groups, the engineer forwards the completed design to another engineer for design verification. Check copies of the finished sketches and calculations are made and the package forwarded to an engineer with authorization to perform design verification. i i
(2), Design Checking and Verification Q. Mr. Finneran, please describe the design control and verification PSE employs as part of its design process.-
A. The CPPE procedure governing design verification (CP-EP-4.5)
! requires that new or revised designs be subjected to one or more methods of reviewing, confirming or substan'tiating the
! design to provide assurance that the design meets the specified inputs and will perform its intended function.
With respect.to design change controls, CP-EP-4.6 requires that each engineering discipline establish' control measures f
in accordance with this procedure, supplemented by specific procedures and instructions for each engineering discipline 1:
l if necessary, to document and obtain approval of changes or . l deviations to approved engineering documents.- Consistent i
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with the above procedures, Comanche Peak Project Engineering groups have established -implementing instructions applicable to their respective activities.
4 PSE has implemented the general procedure applicable to design verification (CP-EP-4.5) through Engineering Instruction CP-EI-4.0-1, " Design and Design Verification control for Pipe Support Engineering." Specifically, CP-EI-4.0-1 provides that The engineer performing this task [ design verification] may or may not be in the same 4 group as the engineer who . performed the 1
original design. The engineer shall not, however, have been involved in the original design process or be in a supervisory position relative to the individual designated by " Engineered" on the cover sheet, DHE-3.
The design is reviewed by the design verifier employing a form (DHE-6), which includes the questions suggested by ANSI N45.2.11, Section 6.3.1. The package is returned to the original engineer for resolution of changes identified in the verification process. Following drafting of the i
construction drawing from the engineering data, the design verifier finalizes his activities by completing form DHE-6 and transmitting the entire package to the ' lead engineer for
\
final approval. The lead engineer reviews'the. complete package and, if everything is in order, he will sign and reiease the drawing for construction.
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As I will discuss in more detail later, any subsequent revision to the design will be subjected to design and l design verification procedures commensurate with those
, applicable t'o the original design.
(3) Audits Q. Messrs. Chapman and Finneran, what mechanism exists to assure that the design and design verification process is being properly implemented?
A. (Chapman) Section 17.1.3 of the FSAR provides that*"the verification of engineering design control measures is performed by TUGCO through review or audit." TUGCO QA's audit function is further specified in FSAR Section 17.1.3.6, " Design and Engineering Surveillance." There it is noted that engineering activities "are reviewed by Quality Assurance through surveillance or audit. In accordance with these provisions, the TUGCO Engineering Division, of which PSE is a part, has been routinely audited l 1
by TUGCO QA. From December 1979 to December 1983 TUGCO QA l has audited PSE 11 times. In addition to the SIT review, two full technical audits have been performed by the NRC.
Findings from those audits requiring corrective action have been addressed and followup reviews have confirmed l resolution.
(Finneran) In addition, I established in November, 1981, a surveillance group within PSE to conduct " audits . of PSE activities. Although such " audits" are not required by 10 4
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C.F.R. Part 50, Appendix B, I initiated this practice to provide me with an additional independent assessment of the technical merits of our design activities. Accordingly, this group is to conduct design package review,t engineering procedure " audits," maintain training records and distribute revised instructions and procedures. I receive each report prepared by this group directly, and prescribe appropriate follow-up action.
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C. Design Change Control Q. Messrs. Deubler, Finneran and Powers, having completed the initial design process, what is the next step in the piping and support design process?
t A. All three support vendors have now completed their initial designs and are ready to release supports for construction.
The release is accomplished as follows: NPSI, ITTG and PSE 4 (large bore) forward their approved drawings to Technical Services Mechanical Drafting, which transforms the vendor drawings into Brown & Root Hanger drawings (BRH) (see Applicants' Exhibit 147). The completed BRH drawings are sent to the Document Control Center (DCC) which distributes controlled copies to Welding Engineering. Welding Engineering creates weld data cards and construction traveler packages. For small bore supports, PSE releases their approved drawings directly to the Document Control Center. DCC then distributes controlled copies of these ~
drawings to Welding Engineering.
Q. Messrs. Deubler, Finneran and Powers, please describe the initiation, control and review of field design changes.
A.
During the course of construction of the pipe supports, changes in design are virtually unavoidable. The majority of these changes are, however, of a minor nature. Changes may be required, for example, due to' interferences or i t
changes in specifications or regulations. The PSE Field '
Engineering Group, which is a subgroup of PSE,.has been
i i
l-i established to initiate and control field changes in support i .
designs. Although a subgroup of PSE, it also includes personnel from ITT Grinnell and NPSI, and is responsible for documenting field modifications and drawing changes.
Issuance of these modifications and changes is governed by CP-EP-4.6, " Field Design Change Control."- This general procedure is applicable to all disciplines. A more detailed daughter procedure (instruction), CP-EI-4.6-8, " Design Change Control for Large Bore Pipe Supports" (CP-EI-4.6-10 is the equivalent procedure for small bore pipe supports),
provides specific guidance for processing and controlling i
field-initiated changes on pipe supports. The most commonly used method is Component Modification Cards ("CMCs"). CMCs may be used to document any field modification. As discus-sed below, CMC's are subject to design review, verification and approval by the responsible design organization.23 we will discuss below the review process for CMCs.
i CMCs require approval by authorized. field engineers -
before release for further action, i.e., construction and
! submittal for design review. Authority for approving these i
23
' A method of drawing revision, commonly referred to as the-
"blueline process," involves a markup by the Field Engineer ;
in blue pencil on a BRH to create a Field Modified Hanger 5 ketch (FMHS). The FMHS is incorporated into a revision of
, the BRH drawing. Also, Design Change Authorization ("DCA")
forms are used for identifying proposed changes such-as to specifications. Both of these changes are subject to design review, verification and approval by the responsible design organization.
changes is granted to individual Field Engineers by the PSE Chief Engineer, and is based on each person's work performance and experience. It is common practice for the 1
field engineers to perform calculations, request STRUDL analyses or consult with Design Engineers in PSE to obtain reasonable assurance that the change made will be acceptable when it is design reviewed.
It is important to note that the CMC process was intentionally devised to provide a means to permit the craft to proceed with necessary modifications of the support .
without awaiting incorporation of the CMC into the design and design review. Thus, when a CMC is issued, it is recognized that the proposed design change may itself be
, subsequently revised. In short, approval of the CMC by the authorized field engineer does not constitute approval of the change as a design change, only a release to make the field change, subject to revision at any point by the
-support design organizations during the process of incor-porating the CMC into the design and design review.
- The CPPE requirement that CMCs initiated by any discipline be design reviewed either prior to1 or after release for implementation, is delineated in Section 3.2.5 of CP-EP-4.6, " Field Design Change Control." CMCs initiated by field engineers against PSE support designs are design reviewed i'n accordance with CP-EI-4.5-10, " Control of Approval and Design Verification of Large Bore Field Design l
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l Changes". (The equivalent procedure for small bore supports is CP-EI-4.5-ll.) Section 3.4 of this procedure provides
- that review and design verification of the CMC is to be l performed and documented in accordance with the same process used in the original design of the support.
CMC's written against ITTG and NPSI pipe supports are design reviewed in accordance with CP-EI-4.5-4, "
Technical Services Engineering Instruction for Pipe Hanger Design Review and Certification," and each organization's veri-i fication procedures (QCES-2.3.0 for ITTG and NPS W.P. 3.1.5 i
for NPSI). As part of the review process, the CMC will be i incorporated into the support drawing. If, however, the responsible design organization determines that the modi-1
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i fication set forth in Ehe CMC would result in an unacceptable condition, the design will be modified (again
- via CMC) in accordance with that organization's direction and will also be subject to design review. '
Q. Messrs. Deubler, Finneran and Powers, what assurance is
- there that field design changes are tracked and accounted for in the design process?
} A. Field design changes are tracked via an independent tracking group to provide assurance -tlutt CMCs are properly accounted 2
for. This group is called the Design Change Tracking Group.
Their work is controlled by Procedure CP-EP-4.7, " Control of
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l Engineering / Design Review of Field Design Changes," which provides for the tracking of field design changes by means l.
of a Field Design Change and Review Status Log. -
Q. Mr. Chapman, have any procedures been established to provide ,
for trending of design changes resulting from CMCs?
A. Yes. Applicants have established a procedure, CP-QP-17.0,
" Corrective Action," to review documented conditions adverse to quality for the purpose of providing corrective action to preclude repetition of significant conditions adverse to quality. This procedure provides for Quality Engineering i Staff to review design changes documented on CMCs. The results of these reviews are tracked using trend analysis i techniques as an objective method of ascertaining the need for corrective action to preclude repetition of significant conditions adverse to quality. Periodic reports summarize the results of the reviews, including trends, and provide recommendations, where appropriate, for corrective action >
}
- with respect to identified conditions which are' considered .
, to be significant. Examples of trending reports for CMCs are in the record of this proceeding as CASE Exhibits 48, 49A and 50. ,
Q. Messrs. Deubler, Finneran and Powers, please describe the process by which design changes not initiated by field
- modifications are controlled and reviewed.
4
4 A. (Deubler) Work Procedure 3.0.9(b) " Design Control Procedures
- Revisions," establishes the method for reviewing the new or revised Plant Drawings, e.g., piping drawings from Gibbs
& Hill, upon receipt by NPSI and the incorporation of the new or revised drawings into the pipe support design group activities. The procedure includes provisions whereby i
existing support designs are reviewed to determine if the design is impacted by the new or revised Plant Drawings.
Impacted support designs which require revisions are redesigned and reviewed in a manner commensurate with the procedure for new designs.
(Finneran) When PSE was formed, most plant drawings were already complete. Thus, there were virtually no plant drawing changes which could affect PSE designs. If field
- structural or mechanical changes were made that did affect PSE support designs, these changes were identified in the field and CMC's could have been issued against the support -
design. Other causes (revised piping stress analysis, etc.)
may also require design changes in previously approved and J
released designs. When these revisions are required they are processed in the same manner as the original design as
! indicated in section 3.7.1 of CP-EI-4.0-1. All revisions are reviewed to ensure compatability with the entire design package.
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A. (Powers) ESQAM - QCES-2.3.0 " Design Control" defines the criteria to process design changes not resulting from field modifications. As with NPS, the engineering supervisor is responsible for evaluating the impact on support designs j resulting from changes to contract specifications, drawings, approved designs, internal and external documentation, etc.
When it is determined that a change is required, the Engineering Supervisor vill process the support design in the same manner as new support designs, discussed I
previously.
D. As-Built Certification Q. Panel, please describe the as-built certification process for piping and support design.
- 1. Gibbs & Hill A. (Ballard) The as-built certification of Class 2 and 3 piping for Gibbs & Hill is controlled by two principal procedurest -
CP-EI-4.5-1, entitled " General Program for As-Built Verification," and Gibbs & E,ill procedure AB-1, entitled "As-Built Verification Instruction". Procedure AB-1 is also based on the requirements contained in Design control Procaiure DC-7, which I discussed previously.
The first stage of the as-built e.nalysis involves the assembly'and distribution of the surveyed as-built stress analysis piping problem package to Gibbs & Hill Applied Mechanics by the Technical Services As-built Coordinator
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i (TSABC). This package includes surveyed piping drawing's reflecting the as-built routing and location of supports and j
individual pipe support detail drawings. The Gibbs & Hill 4
as-built coordinator reviews the package for completeness,
! resolves discrepancies and requests and obtains additional i information, if required, to perform the as-built stress
- verification.
The Gibbs & Hill Design Specification MS-200, titled j " Design Specification for All ASME Section III, Code Class 2 f-and 3 Piping" is the standard to which as-built analyses are performed. This specification establishes the functional i
and design requirements which form the basis for the design,
{
procurement, fabrication, erection, examination, testing, l
inspection and certification of all ASME Code,Section III, h Class 2 and 3 piping systems for Comanche Peak.
In accordance with procedure AB-1, the stress analysis i input package is assigned to an Applied Mechanics Lead "
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Engineer for review of the as-built information and comparison with the latest as-designed stress analysis.
This comparison is a detailed criteria review where each i
-input to the stress analysis is dispositioned as to the effect of any variation on the overall results of the j analysis. A checklist-is completed and signed by the Lead Engineer and the Job Engineer before it is determined that
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i additional stress analysis on the as-built configuration is necessary, based upon-the degree of change in analysis I
7 l
input. If this review concludes that reanalysis is not required, an as-built calculation book, as described by AB-I, is developed based upon the as-designed analysis. The as-built calculation book is checked and design verified, as
, . described below.
If as-built analysis is required, the analysis is performed reflecting the as-built configuration of the pipe routing, support locations, types and orientations and 1
i equipment location. Direction and guidelines for performing the as-built analysis are provided in Gibbs & Hill
{ Analytical Engineering Guides AEG-501, 502 and 503 and also the memoranda previously discussed. In addition, Gibbs &
Hill Procedure AB-1, mentioned above, provides ,
i ..-
3 administrative guidance.
! Upon completion of the as-built analysis, checking is performed utilizing a standard as-built analysis checklist, provided as part of AB-1, which will assure that analyses satisfy the requirements of the ASME Code and FSAR-criteria.
This checklist is attached to each completed as-built calculation. Once checking is completed, design review is performed according to the guidelines of Design Control Procedure, DC-8, title 1 " Design Review Procedure-Calculations, Drawings, Specifications".
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l Upon completion of the as-built design review, the
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Applied Mechanics job engineer approves the as-built stress
. analysis pcckage and transmits it'to the TSABC. This
I package contains the as-built analysis support loads, equipment nozzle loads (when required), the calculation book, a listing of future actions that may be required by
- site and/or Gibbs & Hill, and the statement of as-built verification.
Swnmary sheets based on the as-built stress analysis are submitted to the original design o'rganization for review of any changes in support loads. If the as-built analysis support loads cannot be accommodated by the supports; if the support cannot be modified for the loads; or if the as-built analysis results exceed equipment nozzle allowables, the TSABC advises Gibbs & Hill Applied Mechanics and requests t
additional review and possible reanalysis. The equipment vendor nozzle load interfacing is performed by the TSABC who advises Gibbs & Hill, accordingly. Design changes, if i required, are reviewed in the same manner discussed i
j previously. -
- 2. Westinghouse A. (Parker) The as-built evaluation performed by Westinghouse
- is in acxordance with the same verification process undertaken for the,as-designed conditions. The input parameters used in the as-built evaluation are the installed conditions as determined by TUGCO in a walkdown of the piping system. The walkdown results in the transmittal to Westinghouse of as-built piping drawings,' hanger location ,
and orientation drawings, and support stiffnesses. '
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Westinghouse evaluates this information to determine if changes that warrant reanalysis have occurred. If reanalysis is required because, for example, supports were relocated or support stiffnesses were changed, the design
- process is repeated. At the completion of the final as-i built evaluation, Westinghouse generates the final project piping design documentation which includes the ASME Code Stress Report for Class 1 lines prepared in accordance with I the requirements of the applicable provisions of the ASME Code.
- 3. NPSI and ITT-Grinnell i
A. (Deubler and Powers) The as-built certification processes performed by NPSI and ITT Grinnell for ASME Class 2 and 3 1
supports are very similar. The as-built certification process is conducted in accordance with CP-EI-4.5-4
" Technical Services Engineering Instruction for Pipe Hanger Design Review and Certification" and in accordance with each organization's proced'ures. Due NPSI work procedures. I governing this work effort ama 3.1.6 "As-Built Design Review Procedure (ASME Class 2 & 3), 3.1.7 "As-Built Design Review Procedure (ASME Class 1), and 3.1.8 "
Procedure for Final '
Approval", which establish the methods for the review of ' the as-built support to the piping as-built analysis loads, and final certification of the support design by an authorized
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4 engineer. For ITT, the procedures employed for this purpose l
are those used for the original design, discussed previously.
1 The management for each organization is responsible for appointing an as-built design review Team Leader, both in i
4 the home office and at the site. For activities performed
{ at the home office, the Project Manager receives the as-built package from TLGCO. For work done on site the as-built package is given to the TUGCO Technical Services i
, Design Re' view Engineering (TSDRE) Supervisor. These packages are forwarded to th'e NPSI or ITT as-built Team Leaders at their respective locations. The Team Leader is responsible for assuring that in the review of these 2
- , packages the comparison of the loads and displacements from the piping reanalysis is performed to the latest BRH pipe i support drawing. This review is performed utilizing i
{ established criteria to verify the design for the as-built j condition. After checking, the completed package is 1
returned to the Group Leader for review, and transmitted to i
a TSDRE Supervisor. Within TSDRE, representatives of each i
i vendor (appointed by their organization's project management) perform the actual as-built certification.
t If the reviewer-is satibJied, he indicates his approval on the .BRE drawing by stamping the drawing " Vendor Certified" and signing the drawing. If the reviewer is not j satisfied, he returns the. package to TSDRE for correction of . !
the unsatisfactory condition. TSDRE will send a memorandum to PSE Field Engineering noting the corrective action required. Field Engineering will initiate corrective action via CMCs. This process of review and certification is l 1
repeated until the support is vendor certified.
i (4) PSE A. (Finneran) PSE final review and certification of a support to as-built loads proceeds in accordance with CP-EI-4.0-37,
" Control of Final Review of Pipe Support Engineering Design." This work includes a review of the support design and any outstanding changes by a design engineer and verification of that review. This certification process 1
i includes a review and update of all previous calculations for the support to incorporate the as-built analysis loads.
4 Any unacceptable conditions are resolved generally by further modification to the support by CMC. The process continues, including design review in a manner commensurate -
1, with the procedures applicable to original designs, until the support and all changes are acceptable. Final certifi-cation is achieved by a complete review of the support design package by a PSE engineer authorized to perform certification.
Q. Messers. Deubler-and Finneran, please describe the dif-forence between the as-built certification process-for Class 1 supports and the process for Class 2 and 3 supports.
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A. The as-built certification process for Class 1 is essen-l tially the same as for Class 2 and 3 with two exceptions.
The Stress Report prepared for Class 1 supports is revised i
l to include the as-built loads and as-built design changes
.! (if any). The final Stress Report must be reviewed and 1
approved by a Registered Professional Engineer. A copy of ,
the final approved Stress Report is transmitted to TUGCO.
In addition, as-built stiffness values are calculated and transmitted to Westinghouse for reconciliation with the l
piping analysis.
IV. APPLICANTS' DESIGN QA PROGRAM: PROCEDURES IMPLEMENTING APPLICABLE PROVISIONS OF 10 1
C.F.R. PART 50, APPLNDIX B AND ANSI N45.2.11 Q. Panel, what is the purpose of this portion of your
A. We recognize that a. may be difficult, because of the 1
complexity of the iterative process, to associate each of 4
4 the procedural controls described above with a specific
- regulatory requirement or commitment. To ease this task, we J
have prepared a matrix comparison'of the QA program proce-dures for design, design control (including review end i
verification), corrective action and reporting, utilized by
/s
- each organization involved in the piping and pipe support .
design of Comanche Peak. This matrix graphic'lly a illus-
[ trates the controlling document.s by which each organization satisfies the applicable requirements of 10 C.F.R. Mart 50, Appendix B, and the provisions of ANSI N45.2.11 in their u~ , .
_ i l
- - _ . - . , _ - , . _ , _.- _. - - , . - - ~ _ ., _ _ _ _ ,. _-
design process for piping cr.d supports. Our discussion in the other portions of this iffidavit describe the activities which carry out mont of these procedures.24 l
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i i,
i 24 As with any QA program, the procedures and instructions for the piping and support design activities discussed herein have evolved over the years. Accordingly, the attached matrix includes, as appropriate, referentes to previous procedures or the effective time frame of existing procedures.
1 J
SECTION IV TABLE IV.1 CROSS REFERENCE OF 10 C.F.R. PART 50, APPENDIX B AND ANSI N45.2.11 PROVISIONS TO DESIGN RELATED QUALITY ASSURANCE PROCEDURES OF ITT GRINNELL, NPSI, PSE, GIBBS & HILL, AND WESTINGHOUSE List of Abbreviations:
1
- ITTG j PHDQAM -
Quality Assurance Manual-Pipe Hanger Division ESQAM -
Engineering Services Quality Assurance Manual QAP -
QA/QC Procedures Manual ENG3 -
Engineering Quality Assurance Procedures #3 4 NPS QAM -
Quality Assurance Manual WP -
Work Procedure PSE TQAP -
CPSES Quality Assurance Plan DQP -
Dallas Quality Procedures CP-EP -
Comanche Peak Engineering Procedure CP-EI -
Comanche Peak Engineering Instructions WESTINGBOUSE25 WCAP - 9550 NSSS WRD Policies and Procedures WCAP - 9565 NTD/ SOD Design Control Manual WCAP - 9805 Structural and Equipment Engineering Department l Instruction and Guidance Manual WCAP - 9625 NTD ASME Quality Assurance Program Manual Westinghouse Specification 955125, Rev. 1 (5/17/83 and Attachments GIBB8 & HILL QA -
Quality Assurance Instructions, PPM DC -
Design Control Instructions, PPM PC -
Procedure Control Instructions, PPM PMT -
Purchasing Dept. Instructions, PPM PG -
Project Guide PA -
Project Administration Instructions, PPM PPM -
Project Procedure Manual 25 These documents.are Westinghouse proprietary documents.
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V. IMPLEMENTATION OF PROVISIONS OF THE DESIGN QA PROGRAM FOR PIPING AND PIPE SUPPORTS AT COMANCHE PEAK FOR THE IDENTIFICATION, DOCUMENTATION AND CORRECTION OF ERRORS OR DEFICIENCIES IN DESIGN A. Intrcduction Q. Panel, what is the purpose of this portion of your affidavit? A. This portion of our affidavit illustrates the implementation of the various measures discussed above regarding the identification, documentation and correction of errors or deficiencies in piping and support design. To accomplish l this task, we have provided examples of instances in which design errors or deficiencies were routinely identified as part of the design process, in accordance with established procedures. B. Governing Requirements and Standard _s_ Q. Panel, what are the governing regulations regarding corrective action for errors or deficiencies in design? A. ( All) Criterion XVI of 10 C.F.R. Part 5 0, Appendix B,
" Corrective Action" establishes dual criteria for corrective i
action regarding conditions adverse to quality, including I those regarding design. This criterion requires that measures be established to assure that conditions adverse to quality, such as deficiencies, "are promptly identified and corrected." With respect to significant conditions adverse to quality,. Criterion XVI also requires that measures be taken to " assure that the cause of the condition is
_.. . _ _ . . . .. ~ _ _ _ _ . - - - _ _ _ _ _ _ - - - _ _ _ - _ _ determined and corrective action taken to preclude repetition." The duality of the corrective ac* ion scheme established by criterion XVI is also reflected in the ' governing industry standard implementing quality assurance provisions for the design of nuclear power plants. Specifically, ANSI N45.2.11,26 Section 9.0, provides with regard to corrective action for design, as follows: In addition to correcting a discovered error or deficiency, corrective action also includes for significant and recurring errors or deficiencies, determining.the cause and instituting appropriate changes in the design process and the quality assurance program for design, intended to prevent similar types of errors or deficiencies from recurring. As we describe below, each of our organizations has implemented procedures which satisfy the provisions of Criterion XVI and ANSI N45.2.11. Q. Panel, what methods may be utilized to identify design conditions. adverse to quality pursuant to 10 C.F.R. Part 50, Appendix B, Criterion XVI, and ANSI N45.2.ll? A. Although Criterion XVI requires that conditions adverse to quality be promptly identified and corrected, it does not require that any specific method or document be employed for this purpose. Section 9.0 of ANSI N45.2.ll, however, does J, identify means by which deficiencies or errors in design may i 26 ANSI N45.2.11 " Quality Assurance Requirements for the Design of Nuclear Power Plants", May, 1973 (Draft 2, Rev. 2) (Applicants' Exhibit 148). The 1974 version of ANSI N45.2.11, provides similar guidance for corrective action.
be detected. Specifically, that standard provides that i deficiencies or errors may be detected by (1) design verification, (2) personnel using design documents, (3) audits, (4) tests or (5) actual failure during operation. Each of our organizations has established and implemented 4 measures, as appropriate, that provide for the detection of design errors through any of these means. However, we will focus on the first three aspects of the deficiency l identification process because of the Board's expressed interest in Applicants' program for identifying deficiencies prior to completion of the design process. In addition, as we discuss below, pursuant to. Criterion XV of 10 C.F.R. Part 50, Appendix B, deficiencies in i materials, parts or components identified by QC personnel I through inspections which may have resulted from inadequate I designs are documented on Nonconformance Reports ("NCRs") and dispositioned in accordance with established procedures. - Q. Panel, what is the purpose of Criterion XV of 10 C.F.R. Part 50, Appendix B? A. (All) Criterion XV requires that materials, parts or compo-4 nents Which do not conform to requirements be identified, documented, segregated and dispositioned. These noncon-forming conditions are those in materials, parts or components Which when manufactured, constructed, delivered l or installed are not in accordance with design documents. ' To identify. such nonconforming conditions, _ inspections are 1
I l l l 1 performed by QC inspectors by visual examination or measure-ment against acceptance criteria established by others i (using applicable specifications and design documents). ' i Q. Panel, may deficiencies or errors in design be detected by inspections performed in accordance with the provisions of Criterion XV? - A. Yes. As we just mentioned, materials, parts or components which do not conform to requirements are to be identified pursuant to Criterion XV. Lack of conformance to require-ments map result from an inadequate design. For instance, two components may be designed to fit together in a certain l manner to enable them to perform their intended functions. When constructed and/or installed, however, these components may not fit together. Thus, the cause of the deficiency could be an error inherent in the design of one or both components. Such a' deficiency would be identified by a QC inspector during routine inspection of the-components, using established inspection criteria. It is important to note, however, that the inspector is not expected nor is he re- . quired to recognize that the cause of the deficiency is a design error. He accepts or rejects the item based on applicable acceptance criteria. The inspector is to identify the deficiency on appropriate' documentation and-submit that documentation for evaluation and corrective action as necessary. o ,.
- - - , - . . . . . - - , - , . , . , , - . - e ,
Q. Panel, how does the identification of errors or deficiencies in design pursuant to Criterion XV differ from the identification of errors or deficiencies in design pursuant to Criterion III? A. (All) As already indicated, errors or deficiencies in design which could be identified in accordance with Criterion XV are those capable of identification by QC inspection utilizing established acceptance criteria. However, QC inspectors are not required to be trained in engineering. Accordingly, they are not expected or relied upon to recognize deficiencies inherent in a design which are not manifested in a manner _ susceptible to detection by com-parison of installed and/or fabricated materials, parts or components to inspection criteria. In contrast, in accor-dance with criterion III, design deficiencies such as incor-rect design assumptions or errors in calculations would be detected through design verification or checking of design - documentation. Such verification or checking is performed by persons with appropriate engineering knowledge. Q. Panel, does each of your organizations have in place procedures for identifying, documenting and correcting errors or deficiencies in design as part of the piping and support iterative design process? A. Yes. We have already described the design verification process for each of our organizations. As indicated in Section 9.0 of ANSI N45.2.ll, and as we discussed above, g -
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this process is one of the ways by which errors or deficien-1 cies in design may be identified and corrected.' As we indi- ) cated, this is an ongoing process performed from the initial stages of the design process through the implementation of design cht_nges and the as-built certification process. Thus, prompt identification and correction of such errors or deficiencies is achieved. In addition, each of our organizations has implemented procedures by which any person using design documents may identify errors or deficiencies. We will discuss these measures below with respect to each of our organizations. Also, as we have already discussed, each of our organi-zations has in place a comprehensive audit program by which the design process is regularly audited for compliance with the quality assurance program. Further, each organization performs review and/or verification of design and analysis methods in addition to the formal audit and design review process to assure the technical adequacy of that work. Q. Panel, what means exist in your organizations to detect recurring errors in the design process? A. As previously discussed, numerous methods exist for the detection of design errors in the design process. These errors are evaluated for the possibility of recurrence as a ! matter of practice.
t ! l l l l l In fact, identification of recurring errors is inherent l to the design process. First, each supervisor and design reviewer is aware of the importance of identifying recurring errors. In addition, a limited number of engineers are designated as checkers to perform design review and therefore, can readily identify either on their own or in discussions with each other any recurrence of errors made by i both individuals and the group as a whole. Further, the Supervisors of each group are responsible for the review of all work performed by that group. Communication with the checker,s and actual review of the design packages enable the Supervisors to promptly identify recurring errors. In view of these factors, there is reasonable assurance that recurring errors or deficiencies in designs will be detected. Of course, corrective action with respect to such errors or deficiencies includes a determination of the cause of the error and action to preclude its repetition. Finally, it is important to note that for each of our design organizations there are factors which provide a strong motive for identifying recurring errors. Specifically, errors made by the design organizations have a negative impact on both schedules and financial considerations. It is, therefore, advantageous from a business standpoint for each organization to promptly ! identify and correct design errors, and in particular recurring design errors, to prevent their recurrence. l
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_ _ ~. - - . -- . _ . C. Implementation of Measures for Identifying, Documenting and Correcting Errors or Deficiencies in Design j 1. Pipe Support Engineering
- Q. I4r. Finneran, what procedures have been established by which PSE identifies and corrects design deficiencies in the design verification process? Can you provide an example to illustrate such corrective action?
A. (Finneran) As I have already discussed, the design verifi-cation process for PSE support designs assures prompt cor-rective action is taken with respect to errors detected at any stage of the design process, including those contained in original designs. This design verification process is j described in CP-EI-4.0-1 " Design and Design Verification Control for Pipe Support Engineering." By performing design review prior to the release of the drawing to construction, PSE achieves prompt identification and correction of errors ~ d'etected in the verification process. . The design verification process is implemented from the initial stage of the design process for PSE and is implemented with respect to all design and design change activities. Accordingly, examples of this process are generated continuously. I discuss below two illustrations of this process. j In PSE Attachment 1 an example of corrective action
-through the design verification process is provided. There the design verifier identified certain deficiencies in the .
i 1
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74 - original design calculations, which he noted on a calculation check copy. The calculation was then corrected by the original designer and the design verifier completed the design verification checklist form after assuring the corrections had been made. The next example involves the design verification of a . CMC. PSE Attachment 2 includes documentation of the design ', verifier's review of a member stress calculation, the l original designer's corrections and the design verifier's completed checklist after assuring the calculations were corrected. The examples both illustrate the timely identification and correction of design deficiencies through the design verification process. Q. Mr. Finneran, what procedures does PSE have in place to assure that significant conditions adverse to quality are identified and measures taken to assure that the cause of . the condition is determined and corrective action taken to preclude repetition? A. (Finneran) The principal procedure by which significant conditions adverse to quality are addressed is CP-EP-16.3,
" Control of Reportable Deficiencies."27 This procedure 27 Procedure CP-EP-16.3 has been in effect since March, 1982.
Prior to that time, engineering personnel employed CP-QP-16.1, "Significant Construction Deficiencies," for the identification and-disposition of potentially significant deficiencies.
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l requires that all personnel involved in design and pro-curement activities at Comanche Peak inform their manager of i a potentially significant deficiency, who in turn is either to review or direct the completion of a review of the po-l tential deficiency within 24 hours. This review includes the documentation of the deficiency on a Deficiency Review j Report (DRR), which serves as a tracking mechanism for its resolution. The review includes an assessment for possible generic implications. This procedure provides for management involvement in the resolution and reporting of the deficiency to the NRC if necessary. 4 An example of the use of the CP-EP-16.3 procedure is provided by DRR-018 (PSE Attachment 3). This deficiency
; involved certain Class 1 bolting and rod materials provided by NPSI which had not received all the nondestructive ; examination required by ASME Code Section NF-2500. The deficiency had been identified by NPSI and reported to TUSI by letters dated May 16, 1983, and May 19, 1983. (Both letters were received on May 25.) In accordance with
- procedure CP-EP-16.3, PSE prepared a DRR identifying this as l
- a potentially reportable deficiency. Following review it '
was determined that none of the materials were used under highly stressed conditions. Thus, there would have been no adverse safety implication had the condition gone 4 \ undetected. Accordingly, the matter was not reportable
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l 76 - pursuant to 10 C.F.R. $ 50.55(e) Nonetheless, as further corrective action, all suspect material was replaced. The matter was closed out on June 15, 1983. j Q. Mr. Finneran, what procedures provide for the identification of design errors or deficiencies by persons utilizing design documents? I A. (Finneran) All personnel using design documents are authorized to identify any potential error or deficiency in i those documents. Procedure CP-EP-2.0, " Indoctrination .
,I Program" provides that all personnel whose activities affect ! quality are to receive indoctrination and training in pro-cedures concerning corrective action. For PSE, this train-ing includes CP-EP-16.3 a nd ANSI N45.2.11 which require, in i part, that corrective action be taken with respect to any errors detected.
Two examples of corrective action being initiated as a { result of action by persons using design documents are CMC - No. 97241, Rev. O (against drawing CS-2-309-701-S33R) SE Attachment 4) and CMC No. 97423, Rev. I (against drawing , CH-2-215-709-S23R) (PSE Attachment 5). The first CMC was
- initiated by a PSE field engineer in order to identify and correct a drawing on which no NF number had been given for 4
the weld symbol. Another example involves an instance in which it was noted, again, by a PSE field engineer, that the site engineering organization had used an incorrect weld symbol on a drawing calling for a fillet weld where a fillet
s I 77 - 4 weld could not have been performed because of the roundness of the bracket. Upon review, the drawing was revised to reflect the approved change. Another area in which errors or deficiencies in design documents may be identified by persons using those documents , l is with regard to design guidelines. In this regard, PSE engineers are authorized and encouraged to identify errors i or deficiencies in the PSE Guidelines or associated design Section i of the Guidelines establishes a criteria. procedure for the design engineers to follow in proposing j modifications to the Guidelines. (PSR Attachment 5.) l Evaluation of any proposed modification includes an i l assessment of the impact of the modification on prior 1 j J designs, and an assessment for reportability pursuant to 4 CP-EP-16.3. To illustrate this method of corrective action, I have i included an example in which the PSE Guideline for weld ' j design (Section XI of PSE Guidelines) was modified to I a reflect the concern of a design engineer (PSE Attachment 7.) The design engineer had noted that application of the rules i of AWS 10.12.1.5 for fillet welds in tube steel stepped l joints could result in a smaller than assumed effective ( . l throat of welds for certain tube steel dimensions. To ' correct this condition, the guidelines were modified by r l adding a table of reduced effective throat areas, which the
- i. designers now use in their calculation of weld allowable t
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loads. In addition, because of the possible generic implications of this finding, PSE also reverified the adequacy of designs completed prior to this modification. PSE evaluated welds that could have been affected by the change and determined that no modifications were required. Q. Messrs. Chapman and Finneran, what measures have been established for audits of the design process? A. Pursuant to 10 C.F.R. Part 50, Appendix B, Criterion XVIII,
- i the TUGCO Quality Assurance audit program includes audits of Comanche Peak Project Engineering activities. These audits include examination of the design processes of CPPE to verify that appropriate controls and procedures have been established and are being implemented. There have been 37 1
audits by TUGCO QA of CPPE activities in the last five
; years, including 11 audits specifically of PSE.
To illustrate the implementation of this audit function, we have attached an example (PSE Attachment 8) in which TUGCO QA identified, as a result of an audit, a deficiency in the manner in which certain design control requirements were being addressed. This example represents the audit process by which TUGCO QA verifies program adequacy and implementation and illustrates the corrective action taken in response to audit findings. Q. Mr. Finneran, would you provide an e'xample of the technical l
" audits".of the PSE Group you previously discussed?
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h 79 - A. To illustrate the activities of this group, I have attached 4 audit package CC-1-RB-047 (PSE Attachment 9), in which an instance where the designer had not properly considered Hilti bolt separations was identified. Corrective action with respect to this finding was to have the original de-
; signer make the necessary corrections to the calculations.
i Thus, this deficiency was corrected in a manner which would i
- preclude its repetition. ,
l 2.. ITT-Grinnell Q. Mr. Powers, what provisions has ITT-Grinnell made with respect to the identification and correction of design deficiencies? ] A. The design review process previously described and controlled by PHDQAM & ESQAM assures that design i deficiencies that are detected in this cycle are promptly addressed and' corrected. QCES 2.16, Corrective Action," provides means by which deficiencies identified may be ., l corrected and evaluated for significance. Potentially i ). significant conditions adverse to quality are evaluated and 1 I resolved by the initiation of a Corrective Action Request, l evaluation and resolution of which requires management j involvement for determination of necessary corrective action, including the assessment of generic implications and the need to take action to preclude repetition. e o
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i , In addition, ITT-Grinnell conducts routine, internal l audits of its engineering groups. These audits, which are conducted in accordance with Criterion XVIII of Appendix B, are designed to verify that the design process is function-
- ing in accordance with established quality procedures.
5 Further, although not required by Appendix B, ITT-Grinnell also performs technical reviews of its design groups' i , activities. These reviews are designed to assess whether design specifications, codes, standards and internal i technical procedures are being followed. In addition to the corrective action outlined above, other forms of corrective action may take place after the completed sketches or drawings are released to the client or at any time during the design process. Errors, deficiencies 4 or questions regarding generic concerns or particular i designs can be brought to the attention of and evaluated by i the Engineering Manager by any member of the engineering f organization, or as a result of internal and management audits. Corrective Action Plans are developed by the Engineering Manager and implemented by the Engineering Supervisor. The normal design process is followed for q resolution of the corrective action. The Engineering Manager is informed of satisfactor'y completion of the corrective action. l
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e Further, any employee of ITT Grinnell may submit ques-tions regarding the need for corrective action. Questions which arise in this manner may be asked via a Request for Information form or by other means to the Engineering ~ Manager. The Engineering Manager either responds directly or forwards the request to the appropriate department for resolution. If corrective action is necessary, the , Engineering Manager may, based on his evaluation, forward the request to management for an evaluation pursuant to the requirements of 10 C.F.R. Part 21. Upper management dispositions the Part 21 evaluation. If action is taken, the Engineering Manager is charged with implementation of the action. A Request for Information form need not be sent
, to the Engineering Manager but can be forwarded directly to upper management for a Part 21 evaluation.
Q. Mr. Powers, please provide examples of corrective action initiated by each of the procedures you describe above. A. (Powers) The initial stage of the design process at which corrective action may be taken is at the design and drafting i
- stages with respect to design errors or deficiencies I
t identified by the design or drafting checkers. In these instances, the checkers will identify the necessary changes to the design or drawing for the Supervisor who in turn l transmits the changes to the original engineer for correction. In the case of design changes, the original engineer will initial the change and the checker will
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4 e initial the corrected calculation sheet (ITT-Grinnell Attachr_ ant 1). For drafting errors, the changes will be submitted to the original drafter for correction and redrafting (ITT-Grinnell Attachment 2). An example of how the request for information form is j used to pose a question with respect to a matter believed to be a potential design error is seen in ITT-Grinnel Attachment 3. In this instance, a question related to maximum edge distance was asked by the quality assurance engineer to the manager of piping and structural analysis. A copy was also transmitted to the Engineering Manager ( myself) . A response to the question was provided and the concern of the engineer was resolved. Two examples of corrective action originating from internal audit activities are presented in ITT-Grinnell
' Attachment 4. The first example, CAR 3030, deals with a deviation from the ESQAM procedure, QCE-2.3.6.C.1.b, which ~
provides'" Errors in design documents noted during design verification shall be reconciled, corrected and documented.
. . . The second example, CAR 3034, deals with a technical error identified during an audit. Both deficiencies were documented on the " Corrective Action Request" form for !
assessment of significance and transmitted to the Engineering Manager. Action taken is addressed on the form, signed and dated by the Lead Engineer assigned by the Engineering Manager.
Finally, ITT instituted in September, 1978 a policy of fonnally " auditing" the design calculations and design approach of each engineer on at least a monthly basis. These " audits" are used to identify potential problems with ; individual engineers as well as recurring errors by one or more individuals. The memorandum directing the implemen-tation of this procedure, with examples of the reviews, is attached as ITT-Grinnell Attachment A.
- 3. NPSI Q. Mr. Deubler, what mechanisms has NPSI established for correcting design errors or daficiencies?
A. (Deubler) NPS has established procedures which assure the prompt identification and resolution of design deficiencies and potentially significant deficiencies. Routine design errors, i.e. those errors resulting from dimensional or mathematical errors, errors in transposing information or - other errors of a random nature, are identified in the checking and verification process and are corrected'in accordance with NPS W ork Procedure 15.0.3, " Control of Derign Errors." More significant design deficiencies, such as the use of superced'ed design input, use of incorrect or inadequate design criteria or incorrect interpretation or application of design criteria, are controlled by the use of l design nonconformance reports, in accordance with NPS W ork Procedure 15.0.1, " Identification and control of
k l Nonconformances," which provides for the documentation of j such deficiencies for determination of appropriate corrective action. Each nonconforming condition is documented on a Nonconformance Report, reviewed for validity i by the Manager of Quality Assurance or the QA Engineer, and submitted to the Project Manager for disposition. The Quality Assurance Manager reviews all dispositions to assure they satisfy quality requirements, including consideration of implications for other work. In addition, where design t deficiencies are considered to involve potentially signi-ficant conditions adverse to quality, the condition is to be documented on a Corrective Action Request in accordance with NPS Work Procedure 16.0.1, " Corrective Action Request," which initiates the appropriate corrective action. Design errors or deficiencies which may be reportable are evaluated in accordance with NPS Work Procedure 15.0.2, " Control of Issued Nonconformances." l To illustrate the corrective action mechanisms inherent in the design process and to demonstrate their l implementation, I set forth below several examples of such L measures: i i First, errors discovered in checking are noted on the design package, which is returned to the original designer for correction. In this manner, the originator is made aware of his error and learns by the error so that he can l correct his practices to avoid repetition. An example of l l l
4 1 l i this form of corrective action is set forth in NPS Attach-i' ment 1. This attachment includes the check copy of a case where a checker detects a bolt hole size error in revision 2 l-of support MS-1-01-002-C72S. The issued drawing shows the j incorporation of the correction by the designer and recheck
- by the checker.
j NPS Attachment 2 is an example of corrective action resulting from persons using the design documents. In this instance, site personnel noted that several field design , changes to supports were necessary because of an interfer-l ence with the equipment hatch in Unit 1 containment. To
- correct this condition, the Project Engineer prepared and
! distributed a memorandum for all designers to remind them of 4 the need to check"for such interferences. Further, as previously described, each supervisor i reviews the work of the designers, checkers and verifiers l for errors and deficiencies. Because he reviews the work on - , a continuing basis he can note any trends that may develop. l Whenever he detects errors or undesirable trendo, he will
- discuss them with his engineers and instruct them to the proper design practices. Examples of the results of such
! reviews are set forth in NPS Attachment 3. This attachment i contains various memoranda regarding consideration of I component weights, inclusion of design i fn ormation and review cycles. These are supervisory instructions resulting from the supervisory reviews. l 1
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j l l Also, as part of design verification, design reviews are conducted of selected design packages to verify the i adequacy of the d'esign methods and assumptions used. The l packages are selected by the design reviewers to be repre-sentative of the project design activities. Significant l deficiencies are corrected and their cause determined and resolved to prevent recurrence. Any areas Where the design methods could be improved are noted and brought to the j attention of the appropriate supervisor. NPS Attachment 4 provides an example of this form of corrective action. This I attachment contains a May 14', 1982 report concerning a review of computer programs utilized by NPS. As a result of l this review a new procedure was issued to address directly 1 review of procured computer program verification. An example of an NPS nonconformance report is set forth
! in NPS Attachment 5. This attachment is NCR-1-1015 Which concerns the use of initials Which do not appear on the authorized signature list. Also attached are documents setting forth the corrective action that was implemented.
Finally, the Manager of Quality Assurance will also initiate an evaluation when a defect or nonconformance is thought to be a potentially reportable deviation, as defined by 10 C.F.R. Part 21. Such conditions normally are brought to his attention through an NCR, in accordance with Section 4.1 of WP 15.0.1 and WP 15.0.2. The disposition of a , reportable deviation includes notification of the client. i
j~ i i l ! i An example of this process is set forth in NPSI Attachment 1 { .6. These meeting minutes from a 10 C.F.R. Part 21 eval- ; 1 ! 4 untion illustrate the evaluation of a nonconformance I
, concerning the NPS stiffplate computer program. As seen in :
i t this attachment, it was determined that this matter was not i reportable under 10 C.F.R. 21. j j Q. Mr. Doubler, are there any other methods by which corrective
- action is implemented?
i A. Yes. As I described previously the implementation of the QA { i ! j Program is monitored through the use of audits. When these i {i j audits reveal a deficiency, an audit finding is issued to i
- correct the deficiency. NPS Attachment 7 presents examples of the corrective actions resulting from NPS Internal Audit ,
i Findings. The various corrective actions resulting from l this audit finding are set forth in the attachment. l i In addition, as previously discussed technical audits to evaluate the technical adequacy of design activities are I also performed. An example of these audits is included in I NPS Attachment 8. These audits, althoug1. not required by 10 1. C.F. R. Part 50, Appendix B, illustrate the overall 4
. commitment to quality in NPS design activities.
Finally, findings in audits of NPS conducted by NPSI, i by TUGCO and by the NRC also result in similar corrective l action. An example of this is included in NPS Attachment 9. 4 j This attachment describes the corrective action resulting i from an NRC inspection of NPS on November 17-20, 1981. This
- - . _ _ . . _- _ ~ _ . __ .. . .. _. - _ -_
88 - l s inspection revealed that several supports did not meet the minimum weld size criteria of the ASME Code. The
"~
ident'ification of this deficiency prompted NPSI to issue [ Nonconformance Reports, Corrective Action Requests and ~ perform a 10 0;F.R. Part 21 evaluation. The evalution revealed that the deficiencies did not constitute a !
'I -
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substantial safety hazard. The corrective actions which \ , , , i f . , , resulted from 'this deficioncy included additional training
~
l , , . of design personnel, correction of all previously issued desi'gns,und the performa'dce of a comprehensive design review to dete/mine that design activities satisfied the ! code and client specifications. In addition, because the ' L inspection revealed programmatic deficiencies, a comprehen-l sive corsective ' action pla'n was established. This plan
-involvedthe60mp}etereviewoftheproceduresconfronting
~
the design activities and revisions were implemented where improvement could be..made. Also, the audit checklists were . revised to address more specifically the various areas of design activities.- The NRC closed this finding through an
~
inspection conducted on Geptember 12-16, 1983. Further, in
^
this same time frame, the technica1 audits described earlier l . were implemented. m These correctiv's actions provided increased assurance ~that design deficiencies would be detected. ' t g I e TV w $s g SY
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i 1 { j Q. Mr. Chapman, in addition to the review of welds performed in response to the NPS findings regarding weld designs, what . assurance is there that welds on ASME component supports ; satisfy applicable code and design requirements? l j A. The principal means by which this assurance is provided is l I i through the inspection of ASME welds culminating in the N-5 ! certification of piping, components and component supports. i Q. Mr. Chapman, please describe the inspection of welds on ASME I component supports and how that inspection relates to the-j ASME N-5 certification process? 1 l A. The ASME N-5 certification process entails a detailed inspection of ASME piping, components and component supports ; j to verify compliance with the drawings and requirements of
- the ASME Code and the design specifications. Both the ASME i i j
Certificate Holder, Brown & Root, and the Authorized '
- Inspection Agency, Hartford Steam Boiler Inspection Company,
l
; certify such compliance. Records of this certification are j l '
l retained which contain documentation to substantiate the material acceptability, fabrication, installation, ! examination and Lusting of the ASME systems. , With respect to the inspection of welds on ASME
; component supports, the ASME inspection process requires the i
inspection of all Brown & Root welds for size and i i _ l conformance to ASME Code and designer's requirements, as the welds are made. As a result of the NPS finding regarding weld design, the applicable welds on NPS designed supports
l l l were reinspected and evaluated for acceptability. Additionally, all welds on ASME component supports regardless of the designer, on which unauthorized work could have been performed after installation, were reinspected to assure that corapliance with the design requirements had been maintained. Documentation regarding each weld for a support is prepared and the weld size for each weld is indicated. This documentation is retained in the hanger package for each support and is reviewed as part of the review for the N-5 certification to assure these inspections have been performed.
- 4. Westinghouse '"
Q. Mr. Parker, what measures has Westinghouse established to assure that appropriate corrective action will be taken with respect to errors or deficiencies in design. - A. As I previously discussed, Westinghouse has established procedures to assure prompt correction of conditions adverse 1 l to quality. These procedures provide for corrective action of design deficiencies or errors identified from any source, including design verification, audits and persons using l design documents. Further, Wcstinghouse procedure WRD-OPR-l 19.0 established a Safety Review Committee to consider items e eferred to it for reportability. The procedure' requires
6 i any person in the organization having an item which may be reportable under the regulations to report that item for i
- evaluation by the Safety Review Committee.
Q. Mr. Parker, what evidence is there that the Westinghouse d esign process has adequately implemented measures to assure that design deficiencies or errors are promptly identified and corrective action im'plemented as appropriate? A. During the course of our design on the Comanche Peak Project, design verification, review of records and audits provided assurance-that design deficiencies or errors were promptly identified and corrective action was implemented. Following are examplas to illustrate how each of these provide that assurance. Design verification'is an integral part of the design process described above. In fact, design verification is { j carried out before the analysis is completed. In reviewing I a check copy of_the analysis, the verifier may identify significant errors such as incorrect' material, incorrect placement or orientation of a support, incorrect piping
~
segment length, or incorrect insulation weight which can affect the analysis and advises the analyst'who then corrects-the: calculations as required. After the verifier is satisfied that the work is' correct,_the review and approval is documented. . Westinghouse Attachment 1 provides
~
an example of this activity. ,
.~ . . ~ ... - -;
92 - The role that review of design records plays in iden-tifying design deficiencies and in taking corrective action is illustrated in the following example. At the beginning of the final as-built stage of the design process for j Comanche Peak, a review of stress problem notebooks for analyses previously performed disclosed inconsistencies relating to the manner in which analysts had performed and documented calculations. In these notebooks which if not corrected, could hava introduced errors into the final as-built evaluation. To preclude such errors a procedure was prepared and transmitted to Plant Engineering Division piping analysis management for implementation. This pro-cedure provides a uniform set of acceptance criteria and includes a detailed checklist of the items that must be considered by the analyst in the evaluation. Documentation relating to this matter is provided in Westinghouse Attach-ment 2. Finally, Westinghouse Attachment 3 illustrates how our audit program contributes to the identification of design deficiencies and the taking of corrective action. As part of our internal audit program, Westinghouse Nuclear Tech-nology Division QA Systems and Compliance conducted audits ! in areas relating to work being carried out at the comanche-i l Peak site by Westinghouse employees. A 1981 audit I identified certain non-conformances in the design area which i required corrective action, specifically, this audit f 6
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disclosed that design interface activities between the Westinghouse Structural Analysis Mobile Unit (SAMU) and TUSI involving drawing and correspondence control were not I adequately described. In this instance, an interface control agreement defining these design interface activities was prepared and approved by Westinghouse and TUSI. This audit also disclosed as a nonconformance that training documentation assuring that Westinghouse SAMU personnel were knowledgeable of quality assurance and technical require-ments and the pertinent procedures governing their work were not available on-site. To correct this condition, a training program was instituted for Westinghouse SAMU personnel and a file was set up on-site for records which document the training provided and show that personnel meet training requirements.28 4 28 Finally, I note that further evidenco of the adequacy of the - Westinghouse OA Program is provided by a recent decision by the Atomic Safety and Licensing Appeal Board in Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-763 (March 20, 1984); In that l proceeding, the Appeal Board found to be invalid a claim by the joint intervencrs that "there'is no meaningful assurance that the Westinghouse design of safety-related equipment at ! Diablo Canyon meets applicable licensing criteria." 'In - j denying this claim, the Appeal Board stated, as follows: t Contrary to this claim, however, the assurance that the Westinghouse-supplied equipment meets licensing criteria is pro-l vided by the Westinghouse quality assurance program. . .. . .The. Westinghouse quality assurance program has been audited many times ! by utilities, architect-engineers and profes-(footnote continued) l
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i
- 5. Gibbs & Hill O. Mr. Ballard, what provisions does Gibbs & Hill have for the identification, correction and preventive action of significant or recurring deviations during the design l process for piping and pipe supports?
A. The primary design function performed by Gibbs & Hill for piping and pipe supports is the development of drawings and specifications. Throughout the process of development and use of such design criteria documents as specifications MS-200 and MS-46A (referenced previously) deviations to those design documents must be reported on a Design / Engineering Change / Deviation Raquest form (Gibbs & Hill Attachment 1) . This control is specified by procedure PC-9, Design / l Engineering Change / Deviation Request Procedure. All (footnote continued from previous page) i I sional organizations, as well as the NRC.
. In addition, Westinghouse has designed the NSSS for some fifteen, four loop nuclear
, power plants similar to Diablo Canyon which ! have been licensed by the NRC. [Diablo Canyon, ALAB-763, supra, NRC , slip op. at 78-80.] As I previously noted, the Westinghouse QA program' is an integrated program. Thus, the program applied to the activities addressed by the Appeal Board in Diablo Canyon, including the procedures which assure prompt correction of conditions adverse to quality, is_the same. program being implemented by Westinghouse ~ for Comanche Peak.- Accordingly, I believe this decision provides additional assurance that the Westinghouse QA program, including corrective action measures implemented for design activities, satisfies applicable NRC criteria.
. . _ - _ . __ _ - . __ _ ~ . - _ _ - - - . . _ _ . _ - . . .
1 deviations submitted via this form must be evaluated by the specification originating discipline, a checker, design reviewer, and affected disciplines and the job engineer. This deviation request form requires that three questions be answered by either the originating engineer, design reviewer or job engineer:
- a. Is this a significant deviation or error?
- b. Is this a recurring deviation or error? And
- c. Is change potentially reportable under 10 C.F.R. 21?
A positive response to any of the three questions requires that a memo be issued identifying to the job engineer, project engineer and project QA supervisor the potential design deficiency, significant design deviations or recurring deviations or errors. These three individuals or their representatives determine if the deficiency is valid, the cause and action to be taken to correct the deficiency. If the deficiency is valid, the Project Manager institutes appropriate corrective changes in the design process and measures to prevent recurrence of the deficiency. And the QA department issues changes to QA program, as necessary, to monitor the deficient area.
)
There have been no significant deficiencies or recurring deviations reported with reference to-specificatio'ns MS-200 or MS-46A in accordance with this I
4 procedure. Requested deviations are traced via a master index and sorted by affected design document for ready reference. Q. Mr. Ballard,.what provisions has Gibbs & Hill made with respect to the identification and correction of design deficiencies during the design verification process? A. As I previously discussed, Gibbs & Hill has established procedures which provide for the identification and cor-rection of design deficiencies or errors from the initial stages of the design process, through design checking and verification. Such corrective action is taken in accordance with the procedures discussed above regarding design verification. An example of corrective action taken during the design verification phase is set forth in Gibbs & Hill Attachment
- 2. There, during the design review of a stress problem, the design reviewer questioned whether equipment seismic move- -
l raents were consistent with those established for the build- , ing. He documented this concern on the design review record form and returned the stress problem to the original de-l signer. Upon review by the-job engineer and discipline chief engineer'it was determined-that the movements were, in i fact, properly accounted for and the analysis was, there-fore, approved.
In another instance the design reviewer observed that the movement of a 3-inch branch connection to a 6-inch run of pipe had not been accounted for in the analysis. (Gibbs
& Hill Attachment 3.) To correct this deficiency, the original analyst performed a detailed calculation that was added to the analysis book before the reviewer would accept the analysis. It was also determined by the design reviewer that this condition did not raise a generic issue. Thus, no further corrective action was required.
- Q. Mr. Ballard, what mechanism has Gibbs & Hill established for the identification of design errors by persons utilizing design docunents?
A. Persons utilizing design documents are required to identify any potential error or deficiency in accordance with the specifications referenced earlier. This provides that any inconsistency between the design specification and other j criteria referenced by the designer be reported to Gibbs & - l i Hill. An example of this form of . corrective action is set forth in memorandum AM-M-694, dated March 20, 1979, titled
" Procedure for Analyzing Seismic Anchor Movements." (Gibbs.
& Hill Attachment 4) This memorandum was generated by the stress analysis supervisor.
12 Mr. Ballard, what measures have been established for audits of the design process? Please provide examples of implemen-tation of those ' measures.
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A. As I previously discussed, Gibbs & Hill Applied Mechanics is routinely audited by Gibbs & Hill Quality Assurance. In addition, technical reviews, called surveillances, ,are conducted of selected as-built stress problems by the Gibbs
& Hal Quality Assurance personnel, supplemented as necessary by engineers from the Consulting Department.
These technical reviews are performed pursuant to Procedure I QAI-3. i An example of corrective action resulting from a tech-nical surveillance of selected as-built stress problems is presented as Gibbs & Hill Attachment 5. There, the Gibbs & Hill Quality Assurance Department reported to project management that an error had been identified in the analysis of minimum pipe wall thickness violations in the as-built analyses of two stress problems. A piping analyst had failed to model minimum wall thickness violations in these problems at the location on the piping with the highest. - , stress for the worst case, required by design procedare AB-
- 4. Instead, the analyst had evaluated the minimum wall
- violations at the actual locations. Upon review.it was
\ determined that, although there had been a technical violation of'the procedure, the conclusions of the analyst based on actual conditions were valid and, thus, the additional stresses that would be calculated by assuming the l
worst case locations need not be considered in this instance. Other instances where minimum wall violations had
- . . . - .= ,.- - . - . . - , .- . . .- - -.
been evaluated were reviewed and it was concluded that a generic deficiency did not exist. Further corrective action was initited by revision to AB-4 to reemphasize that piping minimum wall violations were to be correctly incorported in the appropriate analyses. Panel, do your organizations require employees to bring t Q. quality concerns to the attention of appropriate supervisory personnel? 4 A. Yes. In addition to the design controls established in the ~ review, approval and independent verification cycle, and the provisions to resolve matters identified thereby, all em-ployees working in quality-related jobs are required to bring observed deficiencies to the attention of appropriate supervisory personnel. In particular, all. personnel in the P procurement and engineering organizations whose activities may affect quality, and who may use design documents, are required to undergo indoctrination and training regarding quality-related requirements.- For PSE, Procedure-CP-EP-2.0, " Indoctrination Program," prcvides for indoctrination and training in the requirements
, of 10 C.F.R. Part 50, Appendix B, the TUGCO/TUSI CPSES QA Plan, 10 C.F.R. $50.55(e) and ANSI Standards N45.2 and N45.2.ll. Similar procedures are in place for ITTG (QCES
-2.2.1), NPS (WP 2.0.1), Westinghouse (WCAP-9550, WRD-OPR-2.0 and WRD-OPR-19.0; and WCAP 9805,S&EED 1.2) and Gibbs & Hill (Procedures QA-5, "
Procedure for Indoctrination and c . og gc-- -'+ww- yy v--- - y a-*e-we - W -- g 9---
- 100 -
i Training" and OPD-1 " Reporting Safety Related Defects and Noncompliance Pursuant to 10 C.F.R. 21"). In addition, personnel employed in the Pipe Support Engineering and Technical Services Group (including the STRUDL group), ITT, j l NPSI, Gibbs & Hill and Westinghouse are indoctrinated with respect to requirements and procedures app? tcable to reporting potential deficiencies and are held responsible for adherence to those requirements and procedures.29 Further, all employees are on notice regarding the requirements imposed by 10 C.F.R. Part 21, " Reporting of Defects and Noncompliances", by notices posted in work areas throughout the site and home offices. In sum, employees engaged in design or design-related activities.affecting quality are indoctrinated, trained and held responsible to report deficiencies they may observe. This assures that persons using design documents, even those without any responsibility for design, are procedurally able - to promptly identify and initiate corrective action with respect to possible design deficiencies. 29 We have attached the attendance records for the indoctrination classes in which Messrs. Walsh and Doyle participated, and the course outline for that training l course. In~ addition, copies of the required reading list (part of the indoctrination program) signed by Messrs. Walsh and Doyle are attached (Attachment'E).
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101 - t A David N. Chapman [ Subscribed and sworn to before me this 3rd day of July, 1984 - 8 0 ( b em.u Notary - Dallas County Commission Expires 10-20-85 l
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1 _ _ , - , . - -1
- 102 -
Robert E. Ballard, Jr. Subscribed and. sworn to before me this 3rd day of July, 1984. M #- /h My f~- J #" E4I "8 788"Y U' N Notafy Public G 'l 9
- 103 -
R. Peter Deubler gaobnc.rinneran, arf
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A. omas ParWer 0H1/ F2 n t 1 A /
/ vid E.' oQers Subs.ris ed and sworn to before me this1 day of July, 1984
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1 ATTACHMENT A PROFESSIONAL QUALIFICATIONS DAVID E. POWERS ITT GRINNEL CORP. 260 West Exchange Street Providence, RI 02901 PROFESSIONAL EXPERIENCE 09/80- Engineering Manager - Responsible to the customer and present ITTG management for overall planning, scheduling and managing of all engineering projects assigned to the section. Develop design concepts and technical procedures in keeping with current technical advances in the industry. Responsible for the engineering related to a number of assigned major projects within an engineering design group from the quotation through design, manufacturing, and erection phases of the project. The projects involved affect all product lines of the Division. Assignments (Nuclear): Comanche Peak Bellefonte Midland GE-NSSS (materials) Davis Besse 11/76- Engineering Supervisor - Supervise an Engineering 09/80 section to assure the orderly design and processing of assigned projects. Responsible for design and application of pipe supports in conformity with customer and industry codes and specifications. Responsible for the application of technical expertise effecting decisions concerning complex engineering related to pipe supports. Assignments (Nuclear): Comanche Peak Midland Davis Besse Cofrentez - Spain Lemoniz - Spain ASCO - Spain a
O 02/73- Engineer - Planned, scheduled and executed the design 11/76 of pipe hangers and suppcrts for industrial complexes (i.e., nuclear or fossil fueled power plants) . Engineering was performed in accordance with applicable codes and customer specifications. Assignments (Nuclear): Arkansas I Davis Besse Almaraz - Spain EDUCATION 1973 - B.S.M.E. Wentworth College Boston, Massachusetts 1971 - A.S.M.D. Wentworth Institute of Technology Boston, Massachusetts 9 E i 1
ATTACHMENT B PROFESSIONAL QUALIFICATIONS ROBERT E. BALLARD, JR. 1978 to Senior Project Manager present Mr. Ballard controls the staffing and costing of the firm's efforts on the Comanche Peak Steam Electric Power Station Units 1 and 2 (1150 MW aach, PWR) for Texas Utilities Services, Inc. Currently, Mr. Ballard oversees the work of approximately 150 engineers, designers, and support personnel and is the firm's primary representative to the client utility. He reviews all engineering and design work and systems to ensure conformance to regulatory and Gibbs & Hill standards. He monitors work progress and schedules and directs necessary adjustments in manpower and resource allocation to achieve timely coupletion of interim and long-term objectives. He is in charge of meeting all licensing criteria and preparation, and for defense of the Final Safety Analysis Report (FSAR) on this ' project. 1966- Senior Engineer, Project Test Engineer, Project 1978 Engineer, (Westinghouse E16ctric Corporation; U.S. Army, Material Test Directorate; Reynolds Metal Company) Mr. Ballard performed quality assurance ! i engineering and surveillance of various components for power generating facilities. He was responsible for confirming that equipment met ASME codes, and quality assurance and regulatory requirements. He negotiated licensing criteria with the Nuclear Regulatory Commission, which in one case resulted in a $40 million savings for the client utility. He was also ' responsible for $4 million in internally and externally funded development and design procurement programs involving mechanics and materials technology and
- refueling operations. He was in charge of design, test, and procedures for military projects. involving ordinance material.
Education Virginia Polytechnic Institute and State University, B.S.M.E., 1966-M.B.A., University of Pittsburgh, 1975 l l 1 1 l
' ~ -
ATTACHMENT C A. Thomas Parker t EDUCATION
- B.S.M.E. - University of Dayton, 1963 M.S.M.E. - Pennsylvania State University, 1964 PROFESSIONAL QUALIFICATIONS 1983 -
Westinghouse ' Plant Engineering Division - Manager of present the Structural Engineering group of sixty engineers and technicians engaged in the design'and analysis of piping supports,. soil structure interactions, building design and modifcations, and heavy structural configurations. 1978 - Westinghouse Nuclear Operations Division - Project , 1983 Management and Engineering for four Nuclear Steam Supply Systems provided for the Comanche Peak and South Texas Nuclear Projects. Prime responsible manager between Westinghouse Water Reactor Divisions and the utility customers. Responsible for all on site and home office personnel required to support these
- projects on a functional group matrix management basis.
1977 - Westinghouse Pressurized Water Reactor Division - 1978 Development manager for.the Westinghouse PWR next 4 4 generation nuclear steam supply system. Responsible for the design and drawing information provided to f customers initially (Standard Model 414 Information Package). 1973 - Westinghouse Pressurized Water Reactor Division - 1977 Project Management and - Engineering for the - Angra (Brazil) Nuclear Steam Supply Systeam (NSSS). Prime-commercial, management and engineering responsibility for all. components and systems supplied as the NSSS portion of- the turnkey power plant. Provided lead direction in Brazil for subsuppliers selection, establishment. of suppliers quality assurance program, design and procurement.of selected pressure vessels and heavy structures' fabricated by Brazilian firms.
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l 1 _2_ 1968 - Lead engineer engaged in the design, testing, and field 1973 construction of Nuclear Power Plant, Engineered Safeguards Systems, designed to protect the containment , and Auxiliary Buildings during potential loss of l coolant transients. Tasks included basic HVAC and structural design, seismic and environmental qualification, licensing and field work. Member of the ANSI /N45-8.1.1. Subcommittee for engineered safety features design. 1964 - Aerospace, aircraft, and missile propulsion systems and 1968 design. Mechanical engineer engaged in broad applicable of propulsion systems for space flight and weapon systems. Assignments with Pratt and Whitney
. Aircraft, General Dynamic, and The Boeing Company.
Westinghouse Electric Corporation, Atomic Power Division, Nuclear Service Department i w
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r l nTTACHMENT D I
.l Pumps, compressors, valves, and p! ping l s a 1' W Standardization and computers cut costs '
4, of pipe-hanger and support-system design h 70 Here is how a large engineering firm is increasing efficiency and saving - A calculation time, while reducing chances of error, in both fossil and nuclear piping systems, where $13,000,000 may be price for support elements L By G T Kitz and S Zidonis, Sargent & Lundy I Depending hn design requirements, a Although extensive standardization is Every time a piping system is revised, for , typical 600-MW fossil plant will have possible, each support considered as a any reason, every hanger on that system '_ from 4000 to 7000 pipe-support ele- system is a unique design, requiring a may also require revision. ments, with an installed cost of about unique drawing and a separate set of The hanger design process is not p 52-million. An 1100-MW nuclear unit design calculations. This is one of the simple. lt is complex and tedious, involv-ing many disciplines at the A/E firm, at will need about 10,000 support elements, main contributurs to the high cost; revi-costing about 513-million installed. sion is another major factor in cost. the hanger m.aufacturing plant, and at G, . - _ ._, _
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- Three types of hangers keep pipe !n posi,, systems are the principal application for.. ' rnore complicated, because two variable- ,
tion vertically. The rigid hanger goes into this type of support.M .@ tMp: 'M . support hangers are required in the typical ' . _, cold-fluid systems or
- where . designers 4The snubber f of either.. mechanical cr . arrangemen.t.i. .alo.ng wi.th. attachments . .
,g expect only negligible ' vertical . thermal , hydrr.alle type is the final basic element.Jt welded to the pipe itself. ~., .s-' .P -
- . movement. The variable-suppcrt- hanger . allows low-velocity motion, tunder?.2 cy . . f.The last example in the figure,can serve ,
g can accommodate no more than 3/4 in. - cles/sec, such as occurs during thermal. y o support t a pipe riser but is 6ess desirable g vertical thermal movement.- A : constant . _ expansionc but .the device ' locks rigidly than -the previousty mentJoned arrange.- . 7# support hanger can be installed to handle - under 'a rapid excitation, such as earth- ' ment, because it requires a welded lug on - ' Mn targer move:.nent. 'M W 2./ ' : ' quake-ind"ced vibration. - * ~.# the elbow. The high stress concentrat.ons
,Several different methode of eleme'nt resutting from the lug keep this type of j Guides and limit stoprare elements that are attached tc the building structure to . attachment to the pipe are possibie.-The
- support from service on a ' critical hot VJ prevens &!! pipe motion in a gh'en direction. methods of attachment to the. building - system, although it would be acceptable 3
f) A sway t. Pace is a preloaded spring de,1ce. structure are almost infinite in number. Fig. on a t old icw-pressure system. .Y . . . . - p to reduce or darrpen vibration ,n a system.- 4, at upper' left on the ned cage; shows .o Any:of tno ;typica! configurations can f This element goes p edominantry',into : three suppor* . variations. possible with a 2support. pipe in either. nuc'earlor fossfl
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t M coolduio sistems.~~ :fDN, o/fd-h v'ariable-suppor't hange'r'.*, d'fj@=U.Nplants. in ger.eral, however, fossil plants
% ~ rne r;g!d strut nili restrain all pipe move / s >The si nplest design in the figure, wtr a-- have more loom .availabio and present A mer;t tong the axis of the strut. Motion, in . variable support and pio+ chmp,"eften is " fewer soading conditions than for nuc. ear, 4 this direction, from weight; vibration, and et osan to support a hort:cmal run et pipe.1:,; wriich have conflicting thermal-eipt.nsion tnermat effects is preverded.b Col , Pipe risers er vertical runs of pipe be.ome}'[end seism.c requirements. P,g,*M,'q .
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8 iPipe hangers (1, left) support pipe in' vertical direction. Amount
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. SIMPLE TYPICAL INFREQUENT l
[* ., _k^~-- i Fj Vcriable-support hangers (4, above) take several different configurations. For a nuclear plant, designs are more complex L. . [ d I5, right), because of space limitations and loading conditions , Q 1 J
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thm site. The process is iterative, continu- the sequence in Fig 6). When a nuclear embedment plates, and so on, on the . ing until the plant goes operational. steam-supply-system contract is awarded basis of the final loads, but this is not g Improvements in the process come and work starts on plant P& ids and always possible. To understand why, we _d from reduction of unnecessary inter. gas, data must come from the client, must backtrack a little in the design fcces, standardization of designs, and the. NSSS vendor, and every major process for a nuclear plant. Q:.y bettering of design procedures. Reduc- design discipline in the A/E firm. Start of the piping analysis requires tion of engineering cost per hang'er and Once the gas are settled, work can information on containment design. For :d~5 also of operating problems results. start on the b zilding analysis, which . example, when the embedment loads are J?i-Let's look now at design factors, new includes seismic work. Piping layout and being estimated, building seismic re-requirements imposed in recent years, composite drawings, start, too. All sponses are preliminary or unavailable. n cad man-hour-saving innovations in use. through this process, continual interfac- Effect of the loads on piping, and the M ing deals with interferences as they arise. size and location of the resulting support Supp rt-design process An example: estimated support loads are loads, must be estimated. The piping-support design process needed before structural steel and If significant changes come after load (Fig 6) starts with the general arrange- embedment steel are released for pro- definition or in pipe routing, the design
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;y ment (GA) drawings established for the curement. This information dissemina- can become a patchwork, as in Fig 7. ed plant These drawings determine the tion, occurring as the composite draw- There the areas outlined by the channels n lineal footage of pipe, and indicate ings take form, precedes work on the are pipe-load support embedment plates whether it can be supported convenient- analytical drawings. Also, before piping in the containment liner. The channels
!y After the GA drawings and piping analysis can start, building seismic are Icak-test channels to test welds.
.d:i and instrument diagrams (PalD) are analysis must be ia, giving the requiced i
One way te rede:e this problem is L cvailable, work begins on composite dynamic input for piping streu analysis poaitioning of belly bands-strips of 1/2- f drawings and pipins sna'ysis. Modifications during analysis may be in steel instead of the usual 1/4-in.-in j Piping-system layout to avoid physical necessary to satisfy the syste.rs's stress containment areas of possible high j interferences with the mechanical, elec- allowables. The designer checks changes support. load density. The designer can 1 trical; cr structural cornponents is done to detect interferences with components. place a support anywhere on the band of 1 cn composite drawings, which must be He may have to reinforce steel or add steel. In Fig 8, belly bands are just above d checked against the mechanical, electri- new members or embed.nnts to carry and below the ponerrstions. Top and cal, and structural drawings. the loads. With the final restraint pack- bottom of these bends are also heavily 'ks A pipir:g anrJytical drawing, based on age agreed on, system reicase occurs, reinforced, and designers can bridge - the composite drawing, carries prelimi. and the hanger designer can complete between the heavily reinforced areas, nary pipe supports, located by designer's hanger details. with structural steel to carry a larger , judgment. This drawing records and Although most changes will be in the load. Although belly bands require more summarizes all information needed for drawings released for fabrication and steel initially, they have cut some costs piping-system stress analysis to deter- erection, modifications may still be because of welding reduction. mine system-support configuration. needed because of field changes stem- A similar technique in other parts of i Next, single-system drawings reflect ming from interferences, and because of the building relies on a grid of embedded th configuration, modified as needed. field erection tolerances. These changes steel plates for attachment of support ( Reanalysis may be needed if analysis can be accommodated. Changes in den- elements. This saves design time because assumptions and the final hanger loca- nition of a loading condition are another pipe supports will be where required, not tions differ significantly. When analysis and more serious reason for modifica- where an embedment dictates. Total t is satisfactory and support locations tion-more serious because they often design time to be saved is large. The assured, system drawings are completed affect all systems in a plant. Changes of , estimate for one plant is 75,000-100,000 cnd released for fabrication. Support this type are often regulatory in origin. attachments to the grid for pipe, HVAC, details follow. and electrical-cable pan supports. Support-des.ign approaches , Int:rf;ces enter p,icture Pipe-whip restraints are supporting 3 With all design changes in, the final devices to restrain a pipe after postulated Up ta here, the design process seems design loads are released for structural failure or rupture. Restraining forces can simpts and straightforward, but now design. Ideally, the structural designer be up to several hundred thousand interfrees complicate matters (refer to should be able to select proper beams, pounds. Because the restraints are large, tse PUMPS, COMPRESSORS. VALVES. ANo PtPINo Power. Feeruary 1979
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*** Structural : Esttmstsd l
*7 lands to ;
O . p,ng,,, g electrical mechanical , stm c Wral g==w- instrumentation I drawings l ' Building seismic ]$ Chent r Composite , l analysis from structural G.A , Engineer drawings Vendor Analytical General r , drawings arrangement l W , drawings * ' . p,,,,, , analysis Single ; _3,,,,, ,.,,,gy;,,.
' release 5 drawings Major interfaces (6) in nuclear dr w7n s piping-support design orocess '
t1 Ok? [ i' include seismic analysis. Except for this, the sequence of piping drawings is similar to that for { y,, No Reco system fossU work Ok , g,,;g, Q l very early location in the project is Wn necessary to allow embedment design g stmeturalmodmeauons l M and fabrication. Because at the time of , W location pipe routing is not firm nor is
$. piping analysis complete, the necessary high margin for error requires many lim'ited menu of piping attachments or for error in the bill of material and hvi.
rupture restraints. The restraints take up lower subassemblies, as well as structur- hanger-design calculations. Concurrently with the support-design M@. valuable space ordinarily occupied by al attachments or upper assemblies. Q other support elements near relief valves When one of each is picked and the program, the designer uses " washout or elbows. appropriate input specified, the program drawings" when he draws hanger details. ! JiT will size the components, performing These drawings are transmitted to the g3 Standard. .izing des.ign design calculations, and print out the bill hanger vendor, who can " wash out the In the past, when an A/E firm was of material. Sargent & Lundy title block, add his [@.'T. responsible for detailed design of only a This program will design approxi- own information, and then issue the few hundred supports, each support mately 75% of all hangers in a nuclear drawings to his shop for fabrication. ?)]
- 4.;. could have an individual design. With plant, but it cannot handle all possible Previously, checking a vendor drawing -
- 10,000 supports, this is no longer feasi- configurations. Interferences are still to for interferences took as long as design-ble. At Sargent & Lundy,approximately be checked by the designer. ing the support.
- 9 The support-design program has Another advantage is the reduction in
-M 300 configurations, most with detail ,f 7 drawings like Fig 10, meet the need. speeded up the harg:r-design process timm No :onger is the one-to-three /G A computer program that for certain considerably,in spite of the extra burden month period reeded to send a drawing .E standa*d hanger types will $ elect and site represetted by depict;on of pipe. HVAC, to the veador, have him design it, and i the hanger components and print out a and electrical support locations and then return a copy for review.
till of rr.atrrial is a recent development loads en special hanger load drawings. The pipe-support list (PSLIST) is a l
'.f: - ;? at Sargent & Lundy. This program The program is a " visual" fcr the second major program in use by Sargent W sienplifies the design process by complet. support designs of nuclear plants, and a Lnndy. This program sorts, accurnu.
U ing the design calculatiens for the major- provider the documentation to satisfy lates, totals, and hsts pipe supports, such ASME Secti cn Ill and NRC require. as whip restraints, hangers, and snub-l
@g ity of the hengers.
The program gives the des:gner a- ments. It alst elirninates most chances bers, duiing design and after release for l
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contamer liner er,bedment platos (7 Left) can be changed after later fp rp ' rt. . y p .. analysis. Bands of heavier steel just above er:d below penetrations (s,
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-gINy @h on vibration Codes & Standards. One subcommittee, monitoring, currently is t9
writing an ANSI standard on preopera- ;
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6 and piping supports will be affected by the standard to unknown extent. W-k f.e. j , .-]. . t -- The immediate eKect of the design 17 3 f'2 - s ' M 824 [s> ' jl o L @ innovations described above1.1 has Pipe-whip restraint (9, above)is 1%-in.
- reduce h 6 Ge mechanicaWgn e ort ,that was required for support
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thick band around a 12-in, feedwater line. Standard hanger drawing (10, right) is one l"b ~
.-r- J 2 des,gn i in 1970. In addition, many of the newer qualification and documentation 1y--d cf 300 required for computer program # %~%
U ' . requirements also are being satisfied. J:%
components tot,al wt. = 205 b. (.
/d'./ This was accomplished while the man- 6 fabrication. Data can be sorted 52 diEer- condition of the piping and supports. hours needed by the vendor for design In the latest addendum to Section III, were eliminated or greatly reduced.
ent ways, and the program results will track the design and installation esort. an important change concerns the part of Over the past several years, design loads ,g@ One typical sort could be by building, the support element that has to be imposed on nuclear plants, such as the i,-;y status, and hanger type. Alternatively, to designed to Section-III requirements. In operation-basis earthquake, have in- 79 determine the hanger-design status rela- eKect, the change requires that every* creased significantly, and the analysis 71 tive to the construction of a certain area, thing on the hanger detail drawing be and design process have become more , eq9p the sort could be by area or elevation. designed per Section-III requirements.' sophisticated. The techniques are now PSLIST is a tool to monitor progress and Everything else must be designed to applied to many piping systems that .y to assess design-manpower allocation. some acceptable design code, such as the previously were field-supported, using :)4 American Institute for Steel Construc- conservative approximations. The 9 gft Impact of ASME/NRC demands tion code. This simplified the design and changes in the analysis and design l process have significantly reduced the Many of the procedures and programs documentation requirements. discussed so far either originated or A one-year review period was com- number of supports required. % underwent modification because of NRC pleted in July 1977 for the proposed With these fewer supports required, 7% and ASME requirements. Although ANSI B31.1 power piping addenda. and with resulting loads less conserva- . these requirements, escalated greatly This document, now under committee tively defined, three savings are realized. @fl from 1967 through 1974, now seem to be review, could require as-built documen- First, hangers and supporting steel can A stabilizing, there are still a few areas tation and periodic inservice inspection be smaller. Second, there are fewer oper-where some expansion of the regulatory fcr piping supports. The exact format- sting problems becauss there are fewer J(- requirements is expected. whether mandatory or nonmandatory supports. Third, supports are now engi- .j( The NRC mechanical engir.cering appendix-is not known yet. neered for all exrected loads, so there S branch (MEB) has issued a draft v,ork- Several years sgo, the Committee on will be fewer problems in the future. . ing paper on snubbers. Although it's Operation and Maintenance of Nuclear Edited by Will:am O'Keefe %y currently limited to hydraulic snubbers, .. . . _ __ _ _ . . _ _ _ . _ ,
. . , g there's a good chance it will expand to E, dh- W*- " ' . WWW-Wm0W M.' . _ _N '(
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! include racchanical snubbers. If imple- 0Further; design-process upgradin cA mented, the paper would af"ect not only WMyf}.TMJfLM.9.El ejp;%MQ;.sf-W.jn%g coming i$$p -> S / h ,
the inspection of snubb:rs on operating K Better'eng!r.eered piping systems ard supports,will help satisfy emerging interests / Not ASME and NRC in operation and maintenanedin other. arras, their' require-:d f 12 - plants but also the analysis. The MEB document classifies snub. Qments appear to.be,stabiltzirs:The adthors' firm is reviewing the hanger design y bers as active or passive, and implies t. sat p process with ,an eye to further reductions injengineering costs to follow the )f 'g , a piping system would have to be able to g; reductions from computerized 's'uppdrt desigsand, the MLIST program.Vr:.: ,, , h withstand the toss of an active snubber. - jTThe first improvement is to be computer-aided drafting (CADR). In addition lthe .*~ One implication of this is that the h sUp~ port-design program is' tieing'm6dified'to'drM.he hariger details and print the " ' h piping-system design would have to take dbill of material on each drawing. Onci this'm6illfication is dona, the piping-analysis ?. account of a snubber that failed in the Uprog'arriichnl r tie'IInked,tojhelh'ang'er,'pyirgtoitie;thianalys!s and hanger- [ h'i 3 : rigid mode, because this failure would y design procedures together. This will assure that design information is correct at, ~ - ~ W seriously arrect thermal expansion. In- fga!! tirnes7an'd'will' eliminate' tholo'ssibility 8f in' correct jransfer of design data. 9 [.i F
~
dustry has commented on the document, h,' CADR'and thelink' age can be schleved relativ'ely easily, arid both will help reduce . rnd NRC is considering comment. M the'desig'n cost 7,/.W$ j.N34$$.'i%3(-f-U'c';.Q.W ' i ? dj
~
Similarly, NRC begt.n recently to p'The~next step will occur when the CADR system creates the single-system j distinguish between " seismic" snubbers, ; drawings. CADR wi!! theri both define the'pipirig analyticaI drawing and generate i j~ which are those required for safety cate- ; Sthe information required for system analysis.This step will significantly reduce the t
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gory I considerations, and vibration [40 man _ hours _riow needed to code alipirifs stem}for analysis. Once the piping ] snubbers, those not required to satisfy !{ system has been analyzed and found acceptable, the single-system drawing may
~
category I. The impact of the changes is % be modifle'd Jautomatically to 1ncorporate'anylequired changes.' Although the , j T program woUld not be able to' check f6rilnte'rferences,.lt would co not clear yet. In another area, NRC is beginning to require more-detailed pre- M' # c d operation records for the "as-built"
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ATTACHMENT E , r~ -
- 1. INTRODUCTION. ATTEND?)(CE SHEET
- 2. SLIDE SERIES A. 10CFR5D, APPENDIX B '
B. QA CRIs -:IA - AFFECTED GROUPS
; 3. SPECIFIC CPSES REGULATORY COMMITTMENTS:
A. PSAR B. FSAR "AS-BUILT" PSAR C. DRAFTS
- 4. CPSES ORGA.NIZATION A. TUSI V. TUGC0 INTERFACE .
B. QA RESPONSIBILITY C. NRC V. OM ER (10CFR50, B)
- 5. ASME CODE P.ES?0NSIBILITY - BROWN & ROOT
- 6. EVOLUTION CF THE CODE A. CODE UP MTE
- 1) AD:E'OA
- 2) EDITICNS
- 3) DIVISION I V. DIVISION II
- 4) GEhE?.AL REQUIREMENTS - NA V. NC and NCA (1977)
B. DATE OF EFFECTIVE EDITION / ADDENDA
- 1) DATE OF CONT?ACT
- 2) ENG:NEERING SPEC / SYSTEM C. CODE CEVIATIONS 11 CC E INTERPRETATIONS
- 2) CC:E CASES - #SPLICABILITY
- 3) RES. BUIDE 1.82/85
- a. F?.E MAY, 192,0
- b. CURRENT PROCEDURE
- 7. DESIGN CGNT:.?_ - ti:SI M45.?.11 A. CONTR2'_ CF ORIG"iAL DESIGN B. C0!!TRG*_ CF DESIGN C:-JJiGES .
C. CONTROL CF FIELD DESIGN CHANGES
- 8. RECORD REC.0::EMENTS
- 9. CPSES - SYSTEM UNIQUENESS A. N-3 DATA FORM - OWNER B. N-5 CATA FORM - INSTALLER (B&R)
C. IMPACT C: N-5 FCR ENTIRE SYSTEM
- 10. SAFETY l
i, . ! ! i ,
- . i. -
i 8 l .i l
! , I
. l . i l
DATE .I/ fV l ! PAGE / OF /
- I i i j ! ,
i COURSE: CPPEINDpCTRINATIONPROGRA(1 , j l ! SUBJECTS: k!1TRODUCT10N' T0110 CLEAR CODES AND STANDARD i i l
, INTRODUCTION T0 QAlRECORlS SAFETY ORIENTATION i LOCATION: , Classroom x I '
. . _ NAME ORGANIZATION l ,
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. .I_NSTR'UCTOR ((87M . . . , , , _
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cc: CPP Engineer - Mechanic 1 Desi n V Safetp l/
- Ci il/St ctural d' .. Train}ng..
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! __aTechnical, Support' Group! / .
- Electrica,1 _
l . SpecialProjects i /
- Field Mechanical / Procurement
, _ . . , I u~ _ _ - .
l : ; l 1 I i . i l l ' ' DATE :2/ 3't. l PAGE / OF ! / 8 i l g l 1
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; COURSE: CPPE IllDOCTRINhT10N >ROGRAti ! i '
SUBJECTS: TO NUCLEAR bODESANDSTANDARD lNTRODfCTION
,1NTRODljCT10N TO QA RECORI)S SAFETY ORIENJATION I
- LOCAT'10N: blassroom
.! I
._. NAME. .. ... _. , _
ORGANIZATION j
/ I
~2 C V-1~ %>DGUSLAV }R2 civil-f STRUcTUBM- l 2.. S.fq16 5S .. C.
Tsex.f a T/9yc 7 3 poy,w~7poip(/o o/ ~ scmemcef 74 d kcK. Dov'LG T6CHNIG L fc=Rlls CESl ls. I Sam Shazdoa_m reawn t_. Feemeg i
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. s INSTRUCTOR ,
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. cg t CPP, Engineer - Mechanic 1 C ai;;n k' .
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- Ci il/, Structural. v' _.
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- Ele,ctrica,1 l Speci1Prohects l
- Iiild ik.d Hcn Procurement ! v*
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- CPSES Project Engineering Indoctrination Program m -
TECHNICAL SERVICES - FILE j NAME: ftfrf4/L Nelsd - DOCUMENT: GROUP A l 1.' 10CFR50, Appendix B
- 2. TUGCO/TUSI CPSES QA Plan
. 3. 10CFR50.55(e)andCP-QP-16.1 4.~ ANSI N45.2
- 5. ANSI N45.2.11 -
' 6. Comanche Peak Engineering Manual (as applicabl.e)
- 7. FSAR 17.1 s' e, GROUP B 1
- 1. FSAR (applicable disefpline information)
- 2. ANSI N45.2.9
- 3. ANSI N45.2.10 ,
4 ANSI N45.2.12, , f 5. Reg. Guide 1.28 -
- 6. Reg. Guide 1.29
~
- 7. Reg'. Guide I'.64 f
I have read the a aove documents in accordance with CP-EP-2.0 GROUP A ^ Signature + // 4
,. .Date ~7 = *1 ?. f l .
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Ch0UPB Signature bb e
~~_
,: Date ) ~ ?
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.' CPSES Prnject Engine: ring Indoctrination Program '
TECHNICAL SERVICES - FILE , [ACf NYL6
~
NAME: DOCUMENT: ! GROUP A ,
- 1. 10CFR50, Appendix B
- 2. TUGCO/TUSI CPSES QA Plan .
- 3. 10CFR50.55(e) and CP-QP-16.1
- 4. ANSI N45.2 ,
- 5. ANSI N45.2.11 -
- 6. Comanche Peak Engineering Manual (as applicable)
- 7. FSAR 17.1 i
GROUP B
- 1. FSAR (applicable discipline information) j 2. ANSI N45.2.9 -
i
- 3. ANSI N45.2.10
- 4. ANSI N45.2.12 j 5. Reg. Guide 1.28
- 6. Reg. Guide 1.29 i 7. deg. Guide 1.64 I have read the above documents in accordance with CP-EP-2.0 f GROUP A Signatu e c Date /
~
3' /cP ! l ) ,/) i I _ GROUP B Signature n # (I / l Date / , 3/[f/ , l 4
k~ }.i }. ? 3 s ) PIPE SUPPORT ENGINEERING ATTACHMENTS 1 l
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FORSt DHE.5 lEXAS UTILITIES SERVICES INC. A CO\tANCHE TEAK S.E.S. om -/2 77 f. gent For ' wing c..Je DALLAS POWFR & LIGitT CONtPANY
**'N' "I C* 8) TEXAS ELECTRIC SERVICE COAtPANY
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*J FORM DHE-5 4 TEXAS UTILITIES SERVICES INC.
COMANCHE PEAK S.E.S. Das I~/2 #I7 Apm For sig caw yy DALLAS POWER & LIGHT COMPANY h* Of g Cak b TEXAS ELECTRIC SERVICE COMPANY kg TEXAS POWER & LIGHT COMPANY p777 m Fu - s- ot r - 714- e c2 e Rev. o ,,1 o.v,,,,. s. REF. 3
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a e FORM DHE-6 REV. 2 JOB NAME D 51
/ ? & ~ l - / 7 - 130 3 -2 PACKAGE TITLE
' DRAWING NO. Fu - 04 7- 7/4- c.5 2 g REv d PIPE SUPPORT ENGINEERING DESIGN VERIFICATION CHECX LIST YES N0 N/A
- 1. g e ge de g inputs correctly selected and are they incorporated! /
, 2. Is the output reasonable compared to inouts !#
- 3. Are the applicable codes, standards, references and/or design guidelines identified and were their recuirements net /
4 Are assumptions adecuately identified. described and reasonable /
- 5. Was an appropriate desian method used #!
- 6. Was constructability, accessibility & interferences adequately considered /
- 7. Are the specified components suitable for the required aoplication., /
- 8. Are the specified uaterials compatible with each other and the environmental conditions to which they will be exposed /
- 9. Are material / component identification reauirements adecuate /
- 10. Was impact test reauirement considered /
l 11. Was inserviei inspect.cn 4 requirements considered / l 12. Are location plan, co-ordinate system, pipe size, elevation, steel sizes, at.d dimensional build-up adequate or correct /
- 13. Are all design loads and movements specified on the drawing /
- 14. Was proper veld type and sizes soecified /
~ ' '
- 15. Is P.E. sign off recuited /
- 16. Are general notes adequate for the design
- 17. Are coating requirements specified /
- 18. $*sS*an"eglati n sheets / drawings properly identified and initialed y
- 19. Were the design interface requirements satisfied. /
- 20. Was insulation thic< ness considered /
- 21. Is correct code clsss and type of suoport indicated / '
l l
- 22. Have open items beers added to the punch list l l/
Checked by: . 4 Date: i 17 4 / 4 ' l The above (Mark Number) design package is in accordance with TUSI design guidalines and applicable codes. Desi Verified-By: Princ Name:' K,~'d.FPP V. :6C Signature: , Date: i 7dlC% t i
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*h* FORM DHE.5 COMANCHE PEAK S.E.S.
D=e *
Agent For m com a DALLAS POWER & LIGHT COMPANY sw m / or
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TEXAS ELECTRIC SERVICE COMPANY cw%. ., K/OA- #h(/D TEXAS POWER & UGHT COMPANY g7
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s FORM DHE 5 TEXAS UTILITIES SERVICES INC. Da
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COMANCHE PEAK S.E.S. Agent For F.hn, code DALLAS POWER & LIGHT COMPANY ['rj, TEXAS ELECTRIC SERVICE COMPANY sw w /4/o or 'T'O C* MAS wwER c tioHT COueANY m _ f ;f > T m._, 87 ,, - AvA 4h4/as s.de-/-d4'/-724-8-TR fno //M,0f ,,,. ,, ,,,. . _ WA/W //bM,iddf '. -MGWeS f Wpx / pyr,pc == 5'6~flg 3,37s,'p//)' i;ys' b *2 / dd
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F0Dt DHE-6 REV. 2 JOB NAME COMANCHE PEAK S.E.S. PACKAGE TITLE 0 M1 8 78 g @ [ -
, DRAWING NO A4.-/-Or, 2 y h,( , gg fygg pg PIPE SUPPORT ENGINEERING DESIGN VERIFICATION CHECK LIST YES NO N/A j
1- ye g gign inputs correctly selected and are they incorporated] / ' Is the output reasonable cemoared to inouts / 2.
- 3. Are the applicable codes, standardn, references and/or design V guidelines identified and were their recuirements met Are assumptions adequately identified. described and reasenabla /
l 4. V
- 5. Was an aporopriate desian method used
- 6. Was constructability, accessibility & interferences adequately /
~ considered Are the specified components suitable for the recuired acolications W
7.
- 8. Are the specified materials compatible with each other and the ,y environmental conditions to which they will be exposed v V
- 9. Are material / component identification reouirements adecuate
- 10. Was impact test recuirement considered
/
t/
' 11. Was inservice inspection requirements considered
' 12. Are location plan, co-ordinate system, pipe size, elevation, steel sizes, and dimensional build-up adequate or correct f
- 13. Are all design loads and movements specified on the drawing i/
V 1 14. Was proper veld type and sizes specified V
- 15. Is P.E. sinn off reouired i/
- 16. Are general notes adequate for the design i 17. Are coating requirements specified v
; gg, gegc41ation sheets /crawings properly identified and initialed j d
- 19. Were the design interface recuirements satisfied V
- 20. Was insulation chickness considered b 21. Is correct code class and type of suoport indicated V l v
- 22. Have open items been added to the ounch list i j
l Checked by: f.awt.# k 74 (, Date: 8/MS *3 { The above (Mark Number) design package is 'in accordance with TUSI design guidelines and applicable codes. Design Verified By: , Print Name: $bWPTN Ys$ AJE>YR W ^] Signature: u M h/, Aw Date: 4ll4/[}'&
, , - , .,- ,___.,_e, _ _ . _ _ _ . . . , _ _ _ . - . ,..-,,._..,__,______-_..,__..m.,_.,...,_ . - . _ . . , . _ _ , _ . , , _ _ . _ _ _ _ . _ , . _ _ _ - _ . _ ,
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.- . TEXAS UTILITIES GENERATING CO.TIPANY m.. inn n v m .:n inu.wwus ram .. ,
R. J. GARY June 21, 19 M "l::'L'::::'";y*
-369 RECEHIED 1 JUN 2 31983 Mr. G. L. Madsen, Chief Texas Util!!ies Services, Inc.
Reactor Project Branch 1 U. S. Nuclear Regulatory Commission CPSES Const. Office Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.: 50-445 Arlington, TX 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION CLASS 1 MATERIAL DEFICIENCIES QA FILE: CP-83-12, SDAR-112 FILE NO.: 10110
Dear Mr. Madsen:
On May 25, 1983 we verbally informed your Mr. R. G. Taylor of a deficiency regarding Class I support material which had not received all the NDE required of NF2500. We have completed our investigation and concluded that the matter is not reportable under 10 CFR 50.55(e). Records supporting this determination are available for your Inspector's review at the CPSES site. Very truly yours, RJG:ln cc: NRC Region IV - (0 + 1 copy) _ Director, Inspection & Enforcement (15 copies)- 9' $ / U. S. Nuclear Regulatory Commission 0 [ J. Johnson - -[d. Washington, DC 20555
-[ i FoMe.ed F atchinson Creamer Calder Kissinger g/
C. Wilson _ _ _ finneran "- i fAurray Norman .-
^
' N. Smith Bernier lSchoen Davis
. I f,chs ce.,try ao
/g File !
i
.. .- 1;
,P bec: .R. J. Gary (2)
B. R. Clements i
~D. ii. Chapman R. L. Ramsey J. C. Kuykendall -
R. A.' Jones , J. T. Merritt D. Frankum H. C. Schmidt B. S. Dacko R. G. Tolson 4 R. G. Taylor D. L. Kelley ' F. B. Shants ' J.B.Gorg
$??$f Terri mart jag 4
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. CTPA-51,240 .EXAS UTILITIES SERVICES I.,J.
OFFICE MEMOR ANDUM ~ e - ro R.b.101 son Glen Rose, Texas June 15. 1983 subject COMANCHE PEAK STEAM ELECTRIC STATION SDAR CP-83-12 ' CLASS 1 MATERIAL DEFICIENCIES REF: 1) IUQ-1681 The following is submitted in response to the subject potentially reportable deficiency forwarded per Reference 1. The concern was initiated by vendor (NPSI) notification that certain Class 1 materials supplied to CPSES did not receive all NDE specified per NF-2500 of the ASME Code. Our evaluation has indicated that none of the referenced material has been used in applications which exceed 55% of the allowable loads indicated in the Load Capacity Data ' Sheet for emergency conditions. In addition, no material has been installed on more than one pipe support on the same line and restraining direction. In the event the hardware did fail, the failure of a single support would not result in the breach of a pressure boundary. Even though the material will be replaced, we have concluded the conditions do not constitute a safety issue and is not reportable under the provisions of 10CFR50.55(e). Please contact this office if additional information or clarification can be provided. Wfh M. R. McBay m ' g Engineering M ger FRM/JCF/RPB/cp cc: ARMS J. B. George
/ '
i J. T. Merritt !_ George f y J. D. Hicks /R. D. Gentry 1 Merritt 7 J. Johnson R. Wright b Popplewell D. N. Chapman LHall G. R. Purdy Hutchinson Creamer Kissinger (Calder C. Wilson Finneran -; JAurray Norman H. Smith Bernier Schoen Davis j Hicis Gentry
. _ _ . _ . . l File _,
= niesl j't f ' L TENAS UTILITIES GENERATING CO.TIPANY O F F I C E M E l.t O P. A N D U M
**' May 26, 1983 To J Glen Rose, T Subject Comanche Peak Steam Electric Station _g CP-83-12 h,
- r. Jil (1 J 1983 Texas Utilities - S CPSES Constebtgc'
The attached form documents a deficiency recently verbally reported to the NRC. Please assign an engineer to evaluate this deficiency working directly with the undersigned to resolve this problem. We need to jointly determine by June 15, 1983, if this deficiency is formally reportable under 10CFR50.55(e). .
~
Thank you for your cooperation. Ab Nb R. G. Tolson TUGCO Site QA Supervisor RGT/bil Attachment
- cc: D. N. Chapman B. C. Scott C. T. Brandt G. R. Purdy M. R. McBay J. D. Hicks j_ George ' [Mc[h .
l_Merritt J.#J ohnson Hall Popplewell Hutchinson Creamer Calder Kissinger _C. Wilson Finneran _Murray Norman - _N. Smith Bernier _Schoen Davis p Hicks _Gentry R. M File (& 7 -- _ t
' "D M O .@ 9N - __ _9 _ _ N _ _ I N
. . c, DESIGN / CONSTRUCTION )
S!GNERCANT E3iCENCY ANALYSIS REPORT t.D. _ ga
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1 w_qj Vtc < L4 990 V ~ T*P l
. 2-
!l On,afgn Descript form of lief tetency:
O Coast ruc tion O/h d M k Date TUCC. q4 Nottfled flee Date Termat Identified 'er Time , TMSI - YNAy 6 C. .d$d 6 93 F Es2 WaWas AAALY511: Prelleinary entineering analvsts indicates s fety of plaat operations advessely af fected had O Tes O so
- 1. .M deficier.ry none vedetected.
- taptstn briettyt .
, iS/
- f l hl 47 0 rts O ro .
s
- 2. tef f etency considered strnttleast ,
t.,,t.. t _ c esse r ,i..t. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .0 ,,., 0 ,o a . s
.. C_e ric qA Pretrae treakdown _ _ _ _ -_ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , p TE5 O ho #8I/ ,
- b. .
- c. Des i re pe r S Alt pe r ference c ri t e ria _ ,,; _ _ _ _ _ _ ,, _ _, ,,, ,, , , _ ,, _ _ _ _ ,, ,, J Yts No 3.,,. .
Constrvettaa met as specified and'esteestve veelmattee or repair required i !. to meet destge critetta. ,_,,,,a_,______.__________,_______OTes No
- e. L..
- - - % De f telency discovered a f te r QC sece ptance , ,,,, _ _ ,, , _ ; _ _ _ _ _ ,, _ _ 7t3 O ia) ..
~' 1:. . . . , . + . .
Tes O no
- f. Could Jef telency have, gene, i.nde,tected _ _ ,,,,
s
.fystem test meets SAE performance critetta..u'd ,. ,__m..,_,,,,,, _.,,. ,,,,_O TT.s O No ..1. . . . . . . . .
g . g .
]
.....,.?
-* h. " Sy s tee test seewi t s reqvf re'e,stessive ova tea t ten and rede s (ge,,, _ _ _ _ _ .,, _ _ _ _ _ _O Tts O Mo .
g System test failure can be corrected by laternal adjusteest er replaceeest with t. s t viJ a r d c oe pane.r_ _ _ _ _ _ ,,, _ _ _ _, ,, _, _ _ _ _ _ _ _ _ _ ., _ _ ,,, _ .,, _ _ ., . ,p it s O noy ,
- j. Does defielbey require test tag and analysts to one.er part I above_ _ _ ,,, , , ,,,, _ _ JES O ho A
e f By: -
. CopCLy$lmes , ,__
Thef triency reporteJ - - M.33h ) TIS O wo Dates f4083 Times i [M t . n . **1=s te g 4ef* rmf M T __Page Tiec tvun 27 PtMtstat1W ft [
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f-DRR S/f i DEFICIENCY REVIEN REPORP Design I. IDENTIFICATIW Construction A.
Description:
2"/es/ MS ,dMinna/2r Procurement Y JacM sw/ s'exusf sH #AE saarW mr D 7scur Data Ident. f*-f!r 63 Date Distr. g Es45 B. Basist ffds!//)V/) n/2/ #p/kr # lWes fa,&M ' ' ! Yes it) Unknown II. EVAIIRTIN
- A. Deficiency identified in construction process M B. Deficiency violates technical specifications y ,
C. Deficiency requires further testing / evaluation #1 Tv' D. Deficiency generic on other plants E. Deficiency warrants extensive rework L III. PRELIMINARY CWCLUSIW Yes 143 Potentially Deficiency asportable i IV. EVAIDATIN PERSWNIII Identified By: tame OlGWIZATIM m% aae-ste Name 'dtganization V. COMMENIS ,
- i VI. APPROVED M[ W Organization . er A - 8' 2 8~ /~3 Date
[/ APPROVEI) M '
, [ ~~ 8 8 ~ b Engineering & Cc ion Manager Date VII. DISTRIBUTIW CRIGINAL - FILE cc TVGC0 Site QA Supervisor .
Engineering & Constructicn Manager jf.p f/W :$. W y -. - -
, -- , + - - . ..-,.m., -
l nps industries. loc. . r.m hce.nm L>ata ncwv.. rex y' swr OKym
@ 70' 6Wh%O 'c+.n 14 rm ff -
i i f ...... NPSI-12-2240
- ". o i 9 . " '
RECEIVED foxas utilitics Services. Inc. P.O. Box 1002 Iexas Utilities Services, in6
.. . - Clen. Rose, .TX 70043 CPSES Const. Office Attention: J. C. Finneran
Subject:
Texas utilities Gen. Co. - ! Comn:ho Peak Sim. Eles. Co. l Units 1 & 2 ( Purchase Order No. CP0016A.1 i . ... . .....Subjcett - tioncunfomanco Class T' Poit'iiig itatorials Ref: !! PSI-12-2239 / k reentlement. .. Inis, letter supplements my correspondence of Hoy 16, 1933, / llPSI-12-2239 regarding Class 1 bolting :uterials which required _.,
!iDE per flF2500.
~
The panel that was convened for tite purposes of deterinining if .' the deviation on the m3terials shipped to you- in our previous corresponden:e was unable to evaluate the following item and i therefore has not reported the deviation as part of our report to the NRC. M 870 ltem 1 FliN-2Y Ouantity 6 MIC f5640NB No NDE perfomed SN !12431/TDA 2/17/83
'.n* therefore request that yuu evaluete the deviation. Should you e.aluate the deviation as a defect and report it to the NRC under previsions of 10CFA 50.55e, please advise us of this fact.
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;'; 't ic,.as Unitues iereir.cs, Inc. Fogc 2 ti?5I i,ill arr .nge raplats. ents for m.3ter ials in a ;iramat on.1 expedi tic.:5 r. inner.
t if you nne ar,y questions, or require additional inforration.
;;1 ease do not hitsitate to call this of fice.
Very truly yours. NPS IN0'JSTRIES, Ilic. 9 g g-Heman W. D' Errico Project 14anager HWD:nl cc: J. C. Finneran, TUSI OL, IL J. D. Hicks. TUSI, IL R. Maurici, flPSI Qt, IL i
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npsindust6es. inc. i - - , .,. n-w<oxus.rm)xt.cy O.'mt
- 20. 565 W.0 to;es 14-i(31 NPSI-12-2239
. _. em 16 i m Texas Utilities Servicer , Inc.
" RECEIVED P.O. Box 1002 IfM 2 5 BB3 -
Glen Rose Texas 76043 gges Services, Inc. Attention: J. C. Finneran
Subject:
Texas utilities Gen. Co. Co,mnche Peak Stia. Elec. Sta. Units 1. & 2 - Purchase Order No. CP0046A;1
Subject:
.Nonconformance Class I hol)ing Materials Gentle en:
in reference to the 10 CFR 21 telephone conversation with John Finneran of TUS1 on 14y_.13,1983. The following is a listing
- of Class i bolting and rod rnsterials that did not receive all the NDE required of NF 2500.
Bulk Sale Releases Mark Ec. Item SNA/ Oste Shipped,
- 1. IM-1209 1 TEM f4 SRSd20-S0-QTY.5 14606/T0A 11/11/82
' NO N0E performed on Zi ga eyerods
- 2. IM-1228 ITEH #4 SRS-20-50 QTY.2 14611/TDA 11/11/82 HD NDE performed on 28 s" eyerods Suptorts Mark tio. . I ters . . Stif/Da te. Shipped
- 1. RC-1~007-001-C41Tl R.3 . Sway. Strut No NDE perfonned 12835/TDA 3/24/82 on eyerods .
- 2. AC-1-069-002-C41R R.4 Sway Strut No HDE parfonned 12638/TDA 3/9/82 g
on eyerods -
^ ~ ' ~
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. lte- $!i4/03 te Shinnett i
- 3. RC-1-135-009-C51R k.1 Sw y Strut 12440/10A 2/22/S2 l No Rft! perfortt.ed on eyerod;
- 4. RC-1-135-010-C41K R.1 Clgnp Solting 11983/70A 12/23/P,1 N) tiDi performed
- 5. RC-2-135-402-C4 tK P. 0 Claea Jolting 13957/TDf. 8/16/82 Ho MDE perfomeo
(. . RH 1-001 013-c41R a.1 Ciamp Belung 125iO/TDA 3/3/82 No liDE perfor.Nd 1
- 7. RH-1-002 013-C41R R.! Svecy itrat 13915/10A s/10/82 No tiDi perfortned cn cycrods
~
S. SI-1-091-001-C41R P. 2 Sway Strut f 13161/104 3/4/82 No NDE performed on eyerods
- 9. S!-1-179-036-C41R R.1 Sway Strut 11983/TDA 12/23/81 No NDE perfomed t on eyerods
- 10. SI-1 180-005-C41K R. ! Clamp Bolting 13230/TDA 5/18/82
~ -
No NOE performed'
- 11. SI-1-1BO-003-C41R R.2 Sway Strut and Clamp 12440/Tok 2/22/82 p J Bolting, Eyerods tio NDE perfomed The above material will' be resupplied to T051 at no c!:arge. If l you have any question, or require additional infornation please do
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FOR .APPRCVEC* Section i GUIDELINE Requirements for Issuing John c. Finneran
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REVIS!ONS New or Revised Pipe Support . Od /d f p e b Engineering Guidelines "PSE PROJ. ENGR. I i
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I. INSTRUCTIONS FOR FILING GUIDELINE PAGES
- 1. Remove the " Cover Sheet for Guideline Revisions", Rev. O, dtd. 10-15-81, for Section i and pages 1 and 2 Rev. O of Section i.
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.SECTION 1: Requirements for issuing new or.rsvised pipa rupport
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1.0 REFERENCES
4: . 1-A Pipe Support Engineering Guidelines s l
'2.0 GENERAL b Purpose and scope l
This section of the Pipe Support Engineering Guidelines.
-describes the method used to issue new or revised engineering
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3.0 METHOD Responsibilities ! It is the responsibility of each PSE group member to reco:nmend new or revised guidelines when the need becomes apparent. When an individual identifies a need for a revision he/she !. should consult with his/her immediate supervisor for applicability I - of the revision. If necessary, the supervisor may consult with ! higher levels of management. i 1 3.2 DRAFT REVISION REVIEW G,, The draft revision shall be submitted to the PSE Project 1 Engineer through the author's supervisor. j l j The Project Engineer. shall route the draf t revision to selected , i personnel to assure review by the proper level of supervison and expertise. The Project Engineer (or his designate) will consolidate any i ccaments on the draft revision and forward to the author's supervisor for review and possible resolution.. After resolution or incorporation of the comments, the draft i revision ~shall be submitted for final typing through the design control supervisor (DCS). , 3.3 APPROVAL
'After final typing the author shall proof read and forward to i his immediate supervisor. ,
The supervisor shall verify that all agreed upon cousnents have l been incorporated and forward to the DCS. i !h.Q . Denotes change. 1 1 ~ , . . . . . , . , .O , , _ .v..,,.. , - ,...,e . - , . . m . y .,m1, , ,m, - , ,. _
SECTION i: 3.3 con't. NE)\S The DCS shall complete a " Cover Sheet for Guideline Revisions", revise the guideline $'ndex as necessary, and forward the package to the Project Engineer for approval. 3.4 DISTRIBUTION The DCS shall make distribution of new or revised guidelines and maintain records of receipt. l The guideline holders shall be responsible for maintaining the i guidelines in a current status. The DCS shall perform periodic audits to insure guidelines are current. t i L I 4 e f i ,*,
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1 Page 9 of 20 SECTION XI l OFFSET I
- @ l d Figure 5 V I j l W [, Two structural tubes of unequal size.
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Where d/D 4 .8 a fillet weld can be used. Effective throat "te" is equal to. 707 x weld size, with exceptions for certain step joints with a 1/2" o'r 1" 0 t, offset (see table below). THK. - s . _ __._.___._ Effective Throa.ts For._ Step Joints Where te / .707 x W i . ,: T .~ u . - . --
~
FILLET SIZE
.707 1/4" ; 5/16" 3/8" 7/16" ' 1/2" x "D" 3/16" OFFSET. (.1325) > (.1767) (.2209) (.2651) (.3093)_ (.3535) = W
(?iK.
.1307 .1693 2039 -------
------- ------ = te 3/16"- 1/2" =%
98.64% 95.81 % 92.3%
.1203 .1548 .1859 .2127 ------- ------ = te 1/4" 1/2" =%
90.79% 87.6% 84.15%~ 80.23%
.1138 .1456 .1745 .1994 .2180 ------ = te 5/16" 1/2" , 70.48% =%
85.88% 82.39% 78.99% 75.21 % 1/2" .1142 .1444 . 1716 .1950 .2123 ------ = te 3/8" 68.63% =% 86.18% 81 .72 % 77.68% 73.55% 1" .2200 .2614 .3010 .3387 = te 3/8" . ------- -------
~98.6% 97.3% 95.81% = %
99.59%
.1368 , .1693 .1975 .2209 .2375 ------ = te 1/2" 1/2" 76.78% .~=%
-103%' 95.81% 89.4% 83.32%
1" .1264- .1659 ;2040 .2407 .2759 .3096 = te 1/2" 89.2% 87.58% .= %
~95.39% 93.88% 92.34% 90.79%
5/8" 1/2" Groove weld must be used - Gao exceeds 3/16".
.1586 .1937 .2276 .2601 .~ 2913 = te 5/8" 1" -- --
=%
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89.75% 87.68% 85.85% 84.09% 82.4% CALC. BY: h e b d & %-
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PSE
Attachment:
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< - CEXAS UTILITIES SElWICES w.'ir.
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. v OrriCC M! MOR ANDUM ra . D. N, Chapman. __._ . ._,_._._, _ ,___ cn.,, n. .
- r. su, Augus t 20, 1981____
N hiert ._ .. _ COMANCHE PEAK S. TEAM ELECTRIC STATION . . .. TUGC0 CORRECTIVE ACTION REQUEST CAR t10. 003 TUGC0 QA AUDIT TCP-6, FOLLOW-UP #3
REFERENCE:
MEMO D. N. CHAPMAN TO l J. T. MERRITT DATED AUGUST 19, 1981 j In response to the referenced correspondence, please find the attached Corrective Action Request Response. Please concact this office if additional infonnation can be provided.
- $M. R. f' McBay "9
ger g Engineering M MRM:RPB:km cc- ARMS N J. T. Merritt __ bhb[y d , R. G. Tolson
- 8. R. Clements [,UG 21193]
J. B. George J. N. Baker Tens Utilities Services, Inc. CPSES Const. Office AW1N3D
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. ," ' . .r -, ., ' CORRECTIVE ACTION REQUEST (CAR 1 CAR f 003 Date: an9/g1
...p Response due _Qf_g4I81 '- ; Assigned to: J. T. Merritt / Manacer Enaineerina/ Construction . Name Title I -
SUBJECT:
INADEQUATE CORRECTIVE ACTION
. .i f - - . .
I. D script' ion of Original Dediciency: (Audit / Surveillance ! TCP-1 Deficiency # 3 ) w.3 . .. , y . Follow-up 2&3
.)@ approMcf.iihstdiijt.jon[has been estabTished by PSDG to assure that loads indicated ,;
;.on-Grinnell'pipsihanger. drawings are' commensurate with loads reflected in the latest < '
'. .s. tress (pfotileinsyg-Q , -
Description of' Corrective A~ction Conrnitments-(Ref: Response.-le,tter-J CPPA 9628 4/21/81 ) , TCorrec tif e ifit.{ciEf[lu as an: interdal- P30G idel i nePSDG.then
.ponse s stated that.the"su'bject committed to incorporate instruction the guidelinewas intc.issued thePSDG,Engineerjs.Manualon'or(hefdr,e'5/15/,81. 1 l..
Details of Present Condition of Deficiency: - [" .. The guideline was ' incorporated .into the engineering Manual as Instruction XVII on 8/07/81. Rev.' l'.o.f this instruct. ion: was then- issued on 8/17/81. !All Engineers except.for those.on vacation had fi,gned off on the, distribution lis.t.I' During a random sample.of.-the Engineering manu'als that had been signed off, 6 manuals were . Description ~of Restrictions / Holds Appliedi observed. Only.two had incorporated the in-
.4 - - -
struction into the manual and voided the old instruct
~
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See attachmen't for details.
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< A WAuditof ., ,~ 'Date ' ,
U tead Engineer (./ , Date Ohh 'Ut Date Y Manage'r, Quality Assurance
'II Details of Proposed Corrective Action: To insure that all future revisions' to the PSDG E.ngineering. Manual ate incorporated,. a transmittal form will be .used which
/will require each person to acknowledgs that the revision has been received and ~.. . , .
incorporated by~ signing and dating .the tr'ansmittal form; attaching the superceded -
. pages toithe transmittal form and r'etur'ningit to the PSDG clerks.The clerks will -
Implementation Date: 20/81 re.tain the transmittal fonns and destroy the' super '
' W k f//= a t 1
- / .Date kl -
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R3sponsible Sitepager , , y III. Response Acceptable: Yes No / Auditor /Date Lead Engineer /Date
% Implementation of Corrective Action Verified: - / (Ref: Audit /Surv'e illance # )
CAR Closed: / Manager, Quality Assurance Date
. 8 . F5 h ,
ATTACHMENT The following is a detailed breakdown of the six Engineering Manuals observed by random sample, checking for the inclusion of Instruction XVII. Manual # Status 52,60,&83 Instruction XVII,R.1 had not been incorporated into the manual and the original issue had not been voided. 29 Instruction XVII,R.1 had been incorporated into the manual;however, the original issue had not been removed or voided. (Rev. 0 is not identified as such or dated) Manuals 12 and 27 were found in acceptable condition. E o e a G 9 e O
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v TEXA UTILITIES GENERATING COMPANY OFFICE MEMORANDUM clen rtose Texas Auoust 19. 1981 To Subject Comanche Peak Stecm Electric Station TUGCo Corrective Action Request CAR No. 003 & 004 QA File: CAR No. 003 & 004 Audit No. TCP-6 Follow-uo 2 & 3 Attached is a copy of TUGCo CAR No. 003 & 004 which is transmitted to you i for imediate action. Please complete Part II of the attached form and return it by 8/24/81. l By copy of this memo to J. B. George, we request your involvement in I ( providing an expenditious resolution to the cited deficiency. Should ! you have any questions, please. contact Antonio Vega or me. D. .'Chapm n Manager, Quality Assurance DNC/AV/AEK/ls cc: B. R. Clements J. B. George l G
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TEXAS UTILITIES GENERATING COMinNY QTN-437 OFFICE MEMOR ANDUM To J. T. Merritt Dallas, Texas Octo k ou l9Ji_ . .
^ AY, COMANCHE PEAX STEAM ELECTRIC STATION saje- -
iuutu cuxxtuiivt aciiun uttow-u" W 13 M QA FILE: CAR NO. 003 . AUDIT NO. TCP-6 FOLLOW-UP 3 i reus uuitoes Services, Inc. l l CPSES Const. Office 1 On October 7,1981, auditors, Al' An Kesler and Debra Anderson reviewed four PSDG Engineering Manuals for verification of corrective action on CAR 003, ! concerning document control activities. The four manuals reviewed were: the master, #27, #29 and #38. The following problems were observed:
- 1. All the manuals had two or more missing documents.
- 2. None of tne 20 sections within the four manuals had been documented to show they had been reviewed and approved except for part of Section XVII.-
- 3. Ten of the 20 sections were not dated.
- 4. Revision numbers within each section were inconsistent.
- 5. Pages were not numbered or only partially numbered.
. 6. In manual #38, five outdated revisions were still in the manual.
- 7. Manuals #29 and #27 had handwritten revisions that were not present in the master or #38.
- 8. There are no formal controls on changes / revisions.
Due to our current findings, CAR 003 cannot be closed at the present time. At the conclusion of our review, John Finneran committed to a rework program to correct the problems and to a new document control program to prevent recurrence. The rework program should include a review to assure the adequacy of design documentation contained in the Engineering Manual. We request a response from you by October 13, 1981, delineating the details and anticipated completion dates of these commitments. We will review your response and advise you of its adequacy as soon as our l evaluation is complete. Should you have any questions, please contact A. Vega at 214-653-4895.
,' T!.ORGE . n.c mY ,
EMiTT N. SAKER z.u. scE D. N. Chapman
.- - Manager, Quality Assurance -
g ; O Ci:Ig01 PCP: ley! LL DNC/AV/DLA/AEX:med,c,q n,q 73,,.gg cc: B. R. Clements C. WILSCN-'- KISEGER J. B. George n.,g,y,f,y 3 33 g.g N. S.'llTH a f(phl/b 5CMCEN ,
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. i' CPPtr-13235 gXAS UTILITIES SERVICES Ih];
< OFFICE MEMOR ANDUM To D. !!. Chaoman Glen nose. Texa, October 12, 1981 Sul icet CObjAtRIEJEAK STlW1 ELECTRIC STATIOtl TUGCO ON AUDIT 'ICP-6 FOLIGFUE to. 3 CORRECTIVE ACI'ICII REGJEST (CAR) 10. 3
REFERENCE:
- 1) QI1b437
- 2) CPP-5704 In response to reference 1 dated October 8,19 81, the following i corrective actions will be inplemented to establish positive control '
of the PSE (PSEG) Engineering Manual.
- l. A program has been established to review the Manual in its entirety. Reference 2 details the schedule for this review. ,
2 An additional section will be added addressing control of the Manual. These efforts will be conpleted on ce before December 1,19 81.
. Please advise if additional information can be provided.
,e M. R. McBay Engineering F FRM:RPB:km cc: ARMS B. R. Clements , J. B. George - - - I J. T. Merritt -
.c3AY J. C. Finneran .-% ,'.--
I N. BAKER 3ERRITT - Au. ; V' -
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RECEIVED u.eaaw -
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Tens utiliues Services, IE I 1 CPsts Const. Offa v.tcK3 . I sMTRY I
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CPP-5704-
, ty'.XAS UTILITIES SERVICES I.@
, OFFICE MEMOR ANDUM ,
To Distribution c'en Rose. Texa, October 9, 198_1 i suWeet C0t1A_t[CHE PEAK STFJ.M ELECTRIC STATION REVIEW 0F THE PSE ENGI'!EERING DESIGN MAf.UAL Due to an outstanding Corrective Act. ion Report (CAR) issued by-Quality , Control, it is necessary that a comprehensive review of our design manual i be performed. l
' f In this respect, all individuals requested to review all sections of the manual should do so in the time frame indicated in Attachment 1 to this -
memo. ,
.) All comments should be submitted to C.R. Smaney via a marked-up copy of the applicable section or by placing your coments on a separate piece of paper.
Please be specific with your coments t'o help in the consolidation of the reviews. Please look for inconsistencies and duplications; wel are -looking also to strengthen all areas where th;re may be deficiencies, j , If you have any questions, please contact C.R. Smaney at exten;sion 351. I
,e -
i t t* JCF:gr [ohnFinnera'n} [ cc: C. Sm'aney .
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'W.. Fleming i M. Chamberlain l K. Williams i G. Brown .
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O TEXAS UTILITIES GENERATING CO31PANY QTN-440 OFFICE MEMORANDUM October 16, 1981 To J. T. Merritt Dallas, Texas Comanche Peak Steam Electric Station n n e n,- Subjec, TUGC0 Corrective Action Request RLUL1VLh Response Evaluation 00T 191981 CAR No. 003 Texas Utilines Services, Inc. QA File: CAR-003 & APSES Const. Office TCP-6 Follow-up 2 & 3 y Your response logged CPPA-13235 dated October 12, 1981 has been evaluated and found acceptable by TUGC0 QA. Verification of implementation of your corrective actions will be performed consistent with your commitment dates. M 7o4 _.D. N. Chapman Manager, Quality Assurance
&dk. ,
DNC/AV/DLA/AEK:ljj cc: B. R. Clements J. B. George J. C. Finneran M. R. McBay
' M U r.t E wM l "EU;iiTT N. EAKER.
i $tt iv/ADE l UCi:1.'dD[2P3I.E?! ELL CALDER _' CRD./ER _
.O. W!LSON K!S3??:GER f/,UR:j.AY ; SUF.GESS i
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QTN-468 q.. , ... . '], TE:6TS UTILITIES GENERATING COMPiNY l OFFICE MEMOR ANDUM January 4,1983-- To J. T. Merritt Dallas. Texas Subjen
- COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 CORRECTIVE ACTION FOLLOW-UP
. QA FILE-CAR NO 003 AUDIT NO. TCP-6-FOLLOW-UP 3 On December 14, 1981, auditors Al'An Kesler and Steve Davis reviewed the PSE Manual rework program for verification of corrective action on CAR No. 003 l concerning document control activities, l The rework program, committed to as part of the corrective action, had not at this time been completed. Each section of the manual is currently being rewritten, and a new system for control of the PSE Manuals has been established. Four sections of the manual were ready for issue, and the rest were in varying stages of completion. After reviewing the work that has been done to date, auditors feel that upon completion and full implementation the problems previously identified will not occur again. We are, however, unable to close the CAR No. 003 based on
. the present amount of work complet'ed.
During the course of our review, we obtained a firm commitment date of April 1,1.982, from John, Finneran for the completion of the rework program. Consistent with that comitment date, we will verify completion of the
~
corrective action on CAR No. 003. At that time we will review the manual from an administrative and also a technical viewpoint. We acknowledge PSE's comitment that no technical changes to the manual will effect present or past work. Should you have any questions, please contact Al'An Kesler at (214) 653-4665 Manager, Quality Assurpnce-q . e: n. c - > DNC/AV/DLA/AEK:pko- - # "9. yl~ V ) -
.!T) l N. BAKER ,
cc: B. R. Clements ; f.J t yff,tg i J. B. George ; --
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QTN-499 - OFFICE MEMORANDUM J. T. Merritt Dallas, Texas April 26,1982 To Subjec, ' COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 QA AUDIT REPORT TCP-38 s PIPE SUPPORT ENGINEERING l QA AUDIT FILE: TCP-38 Attached is TUGC0 QA Audit Report TCP-38 which details the result of our audit of Pipe Support Engineering perfomed on April 13-14, 1982. The audit was conducted by Al'An Kesler ( Acting Team Leader) and Tony Valdez. I Attachment A contains an audit sumary including attendees of the pre- and post-audit meetings and personnel contacted during the audit. No deficiencies or concerns were identified; therefore, a response to this report is not required. Should you have any questions, please contact Al' An Kesler at 214-653-4665. b . h Manager. Quality Assurance g DNC/AY/DLA/AEX:med Attachments < r i cc: B. R. Clements f.fy/I R. G. Tolson G. R. Purdy i RECEIVED se - Qg TJR 2 81982 Po3?'N M~~}_creatner g'utchinson g c, Tens u.aines seruces, Inc. y CPSES Ccnst. Offs:e _M C C. WIISU finneran
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g h N O & i 6 e l d ATTACHMENT A AUDIT SIM4ARY TCP-38 1 l TUGC0 QA 1 g - - - p y g- - . -. myy, - gg,+
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5 - .. . Attendance - Pre Audit Meeting QA Audit No. Tc P-Ag Date 4/l3ft::t Name Title Name Title 1 LL Wb $ y& ., .. M s M W r<ct kmd h%z M;mL .fse su ' bl.L Pse' - Arsd/ 4 Attendance - Post Audit Mceting . Date 4ll4lRL N Title Name Title oh&isVA Micee a A- _/ , O}l:,10AA -u
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1 TCP-38 Audit Summary Audit Team: Al' An Kesler - Acting Team Leader Tony Valdez Personnel Contacted: J. Finneran C. Smaney J. Busby N. Harrelson 4 Audit Scope: - TCP-38 was conducted to verify corrective action taken by PSE on the Control of the Pipe Support Engineering Manual in response to CAR-003. In addition, i auditors reviewed the revised manual to verify no changes had been made that could have an adverse impact on past or present work. The audit was divided into the following two categories: 4
- 1. Control of the Pipe Support Engineering Manual
- 2. Review of the revised manual for changes that could have an adverse affect on past or present work l Al' An Kesler reviewed Pipe Support Engineering's system for controlling the Engineering Manual. Section "1" in the Pipe Support Engineering manual governing the control' of the manual was reviewed and found to have the controls required per 10CFR50, Appendix B, Criterion VI. Implementation of i
Section "1" was also verified and Pipe Support Engineering (PSE) was found to be in satisfactory compliance with this procedure. A detailed review of the entire Pipe Support Engineering manual was - conducted by Tony Valdez. No changes that could have an adverse impact on past or present work were identified. L 1
-Tucco QA
Summary: B,ased on the scope identified above, auditors feel that Pipe Support Engineering's corrective action has been adequately accomplished. CAR-003 i is, therefore, considered to be closed.
! s A. E. Kesler Acting Team Leader l
f 1 i l 1 1 Tusco QA l
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PACKAGE //0. CC-1-RB-049 A/O : DATE 2 - 2 4 - 84 ' ~^ ' REGU/REMEA/TG - YES /A) REM 4RXS - m o.i 4 1* 2 , + , - h a w A d 5
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- ITT GRINNELL - Attachment 1 PIPE HANDER ENGZNEERINO DIVYS20N M r*@. #
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i-/3 LOAD FOR Y OLOBAL UNIF W- I'07 / . PEM IV~I LOAD FOR Y OLOBAL UNIF W- A*i* ! f ! HEM II LOAD FOR y ff y+9 232 7 4//f }.g X#f858 3'tS J01 J01 3/ LOAO FOR y 973 y+/d/8I 7 yiG Mas Mvae d.wc,l 7 i J01 LOAD FOR X Y MOM LDAD~FOR' X Y 7 MOM ; J01 , LOADINO 2 Y LOAD FOR X Y 7 MOM LOAO FOR X Y 7 . MOM J01 X Y 7 MOM J01 LOAD FOR 7 MCM J0' LOAD FOR X Y LOADINO'3 Y LOAO FOR X Y 7 MGM LOA 0 FOR X Y 7 MOM JO1 LOAD FOR X Y 7 MOM J01 LCAO FCR X Y 7 MOM J01 LOACINO 4 Y LOAO FOR X Y 7 MOM J01 LOAD FOR X Y 7 M3M J01 LOAD FOR X Y 7 MCM J01 LOAD FOR X Y ? MCM Page 2. SCF. NO. 3 Rev. _1
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ll ITT GRINNELL - Attachment 2 WER $ 9. A (M TIME 3 NE5 DATE //* 8* 8"L. CHECKER _ b ND jus NUMBER AND COIAR 'b b k6,M 1 TYPE OF SKETCHES AND DEGREE OF DIFFICULTY: MARK NUMBER TYPE dF ERROR l ES-8SE. dote Th Aesow ,,a GoenTu.a % skCs %s Silo,aa ow7's/D6 C+( um ^) dowb v 7)(obiu Fog Fes. zii sdute ge 3;x>h o ,7-h'- \\ W s3 hw ice. u st,a . s ALis i- Airs Rs A.t> Tue >A t EssTRaic t A m %.LY o 7- (suor A%s A G. o.3 Q ho do t- s now A.A.S.LE r4 9A.a u Foc. R % %ATse. 4!seeneme, W T-s% TOTAL AwegIbu, ,.To . FAs s W .u,0 TA) R . c. A . FE -832 0091 th h. O . k M Q os VLJTe XTE.s A\fS L bA blooa E'D b_AT cot o 4.06df 6 D rd S/L k Qh co r s i4.w L . A. s, t e P. e. W m sy s:% l-Es83tdo9A \\ D O M ~ % $Oud
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%3 5 0A INTER OFFICE CORRESPONDENCE 4
TO: P. J. Fang - PHD Analysis , DATE: Feb. 14, 1983 FROM P. M. Salcone - PHD QA @ @ l SUBJECT ASME Paragraph XVII-2463 Please reference the attached request for information. TUSI has requested ITTG's interpretation of Para. XVII-2463 and raised the questions noted on the attached form. Although ITTG does not generally design base plates with edge distances greater than 6 inches, I believe it is a possibility some as-built unsymmetrical base plate bolt patterns may violate the 6 inch max. criteria. Please respond to this request as soon as possible; a TCSI expeditor 0111 be in Prov. on Thursday, 2-17-83, and may possibly want a response at that time.
~
PMS/v cc: D.M. Sewell - Warren R.B. Mulcahey - Prov. V. Kumar - Prov. _ R.T.Wisniewski-Prov.% T.E. Smith - Prov. THIS COPY FOR D.E. Powers - Prov. J. Mangassarian - Prov. I e l
.......,_.m_. - . _ . . . . _ . . . . - : _. ,_
. . . 1 REQUEST FOR INFORMATION FORMS ES-0!.4 l
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M3 pef, g I
- g. P TOs a MANAGER PRODUCT ENGINEERING -
[D MANAGER PIPING 8: STRUC. ANALYSIS P.J. Fang - PHD Analysis O DIVISION 0.A. MANAGER O MANAGER RDB E
. O MANAGER APPLICATION ENGINEERING O OTHER pgg. P.M. Salcone - PHD QA DATE, 2-14-83 INFORMATION REQUESTED Please provide ITTG's official interpretation of Para. XVII-2463 Maximum Edge Distance (ASME 1974 Code) .
- 1. Does it apply to base plates? (Consider base plates with large j shear forces.)
- 2. Can the concrete be considered as a "part in contact"? If so, wouldn't base plates have to be considered?
- 3. In the diagram below. which edne is considered as " nearest edee"?
. i a? a & b? or all four? 4 0 -
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CC: C3 MANAGER APPLICATION ENGINEERING T.E. Smith - PHD O MANAGER SITE ENGINEEING O ' ~ MANAGER SPECIAL PROJECTS O MANAGER ROB E EZ1 OTHER D.E. Powers - PHD J. Mangassarian - PHD ACXNOWLEDGEMENT THE ABOVE INFORMATION HAS BEEN RECEIVED, RESPONSE TO THIS REQUEST WILL BE ISSUED BY ACKNOWLEDGED bye DATE
ITT GRINNELL INTER OFFICE CORRESPONDENCE TO: PETE SALCONE - PHE DATE: 2/16/83 FROM: RON WISNIEWSKI - PH ANALYSIS .Q-
SUBJECT:
YOUR REQUEST FOR INFORMATION DATED 2/14/83 With respect to the above Request For Information concerning XVII-2463 (Maximum Edge Distance), our response is as follows:
- 1) No, it does not apply to baseplates.
- 2) Not applicable.
- 3) Not applicable.
Also included as part of aur response are the minutes of our 2/15/83 meeting concerning this topic (see attached). Please reference R.I. #33 on any further correspondence concerning this matter. RW/msb 473 Attachments cc: T. Smith D. Powers J. Mangassarian V. Kumar P. Fang d e I D
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1 ITT GRINNELL INTER OFFICE CORRESPONDENCE - TO: DISTRIBUTION DATE: 2/16/83 FROM: RON WISNIEWSKI - PH ANALYSIS e-
SUBJECT:
MINUTES OF 2/15/83 NEETING CONCERNING PETE SALCONE'S 2/14/83 REQUEST FOR INFORMATION (MAXIMUM EDGE DISTANCE) ATTENDEES: Ron Wisniewski, Pen Fang, Vipin Kumar, Frank Vasiliadis, Frank Birch A brief meeting was held 2/15/83 concerning the above Request For Information (R.I. f33). The following was decided upon. , Paragraph XVII-2463 Maximum Edge Distance (ASME 1974 Code) does not apply to baseplates for the ic11owing reasons:
- a) This criteria falls under XVII-2460 " Design Requirements For Bolts" and l not XVII-2470 " Design Requirements For Column Bases.
1 b) This criteria is primarily to prevent the phenomena known as " dishing" in bolted linear type plate connections loaded in tension. c) This phenomena is a function of stability and not strength. d) This criteria is also to prevent separation at the ends of a bolted plate - connection, i.e. to maintain a tight fit. DISTRIBUTION R. T. Wisniewski P. J. Fang V. Kumar F. Vasilladis F. Birch . RW/msb 474 k
. _ ,. _ _ , _ . . _ , _ - . _ . _ , . . , _ = _ - . . _ . . . . . , , _ _ _ _ , . . , _ . . _ . _ . _ . . _ , , _ _ _ _ _ _ , _ . .. ,
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JT9 M28MiggLL - Attachment 5
,, D. Powera k THIS COPY FOR ms c~...<si cua. -. o s a
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, INTER OFFICE CORRESPONDENCE 1
o TO: Engineering Supervisors / Managers DA TE: Sept. 14, 1978 FROM: R. B. Mulcahey SUSJECT: Design calculations l . 1 . Effective immediately all Supervisors are required to audit on a random basis the design calculations of each Engineer reporting to him. This must be done for each Engineer at least once a month. All results must be documented in writing. I have asked Ed Eramian to begin auditing this docu-mentation to identify recurring errors. If analysis assistance is required, please contact
. D. Ledo.
RBM/V cc: M. Grosso E. Eramian D. Ledo D. Sewell - Warren
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, - - - + -
{ L PROJECT DATE: /,3 I - 2 9 CALCULATION REVIEW
~
Rev. No. * ? bEO Sketch No. 2 6 39- [c Y Codes: Engineer f. O e tt ' & O.K.: v S r . , ) c_
! C eL: 6- C.A.R.: Corrective Action Cbecker E Required.
N/A: Not Applicable Reviewer h ,er WJ. A G Specific Comments:
- 9. Legibility: O(
- 1. Loads: o( 5. Bolts: M/A
/j r.; te 6. Welds: n '4 10. SCN:
- 2. Movements:
3, Steel: ot 7.
References:
CK 11. Errors #
- 8. Assumptions: ok Reconciled: /j;,#
- 4. Plates: />% 12. Code Accept- ,
ance Criteria: // - Action Items: I have reviewed the above comments and have completed the required actian items: Engineer: ifp/ _ W e?,d Checker: -[ .r - 1 t ..s f s' f . ... . ary
FRO.'ECT DATE:
/
// I //
j 84
)lG CALCULATION REVIEW
.i .2 tch ::o . 2. -u/ C ?.e v . ::*a . //4o 1
Engineer G .S I Codes:/ O.K.: k Checker d C.A.R.: Corrective Action Required. Reviewer M/ N/A: Not Applicable Specific Comments: , Ok /'4 9. Legibility: Oh
- 1. Loads: 5. Bolts:
- 2. Movements: Ox 6. Welds: c art. 10. SCN: c #n.
- 3. Steel: OR 7.
References:
0,< 11. Errors .
- 4. Plates: e 4+ 8. Assumptions: OK Reconciled: f"6s
- 12. Code Accept-ance Criteria: O k.
Action Items: 6 60 c v~+nd- g g, d, 5 T 2, i w y T T i5 W s m 6T ( u N rc OTh M ('C's %C- 41 re. s -4 .3 r , e, w As,s u,, e m ~ l l I have reviewed the above comments and have completed the required action items: r 7 Engineer: s /g jgn Checker: f ~ .-/ ' Reviewer: I u/fd~
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To: G. Breidenbach NJ-01-3354 nps Y on b lsutnect ' From 3 May 14, 1982 I Review of'NPS Standard and Computer Programs P. Mot 1 Deubler
- INTRODUCTION 1
On May 10 and 12, 1982, a joint review of the Standards and Computer Programs uti- - lized by Nuclear Power Services, Inc., was conducted by Pete Deubler, Director of Engineering and Richard Maurici, Q.A. Manager of NPS Industries, and Pete Mottola, Q. A. Manager of Nuclear Power Services, Inc. The purpose of the review was to detemine if proper verification was perfomed' prior to utilization of the Standards and Computer Programs. This report presents the results of the review.
- 1. Standards - '
Four Standards were reviewed as follows:
- a. Design Standards for One-Line Contact Supports for ASME Class 1, 2, & 3 pipe. SDS-82-001-R1 3/4/81 - The technical backup for this standarc.
I is "A Brief Review of the ASME Design and Assessment criteria for (. lass - 1 components and a Design method for One Line Contact Pipe Support Structures" NPS- AM83-003-001/Rev. O. A review of these documents indicated that the backup document provides adequate verification of the Design Standard.
- b. Structural Design Requirements SDS: hF11.1 thru 11.5 and 12.1 thru 12.3.
- _. These documents are summaries of the requirements of ASME III Subsection NF and Appendix XVII design formulas and allowable stresses. '
Therefore, the technical backup is the Code itsdif and the checking performed during the preparation of the document is sufficient. ,
- c. Computational Sheet for Local Stress in Cylindrical Shells. This document is a computational sheet and it was verified using WRC-107/Aug. 65 prior '
to its issuance.
- d. Design Procedure for Shear Lugs. This document is a sample calculation !
f and was verified using Kellog " Design of Piping Systems" second edition. , f The.above four reviews indicate that standards are adequately verified prior to thair issuance and use. -
- 2. Computer Programs - ' '
The computer programs used break down into two areas: Computer Programs originated by Nuclear Power Services, Inc. , and Computer Programs procured from outside sources. , 4.w,e ,
- a. Computer Programs originated by Nuclear Power Services, Inc.:
There are currently three programs in use and one under development. The ' three programs in use are BASEPLATE, DYNAPO, and PIPLOC. Development of computer programs is covered by NPS generic Work Procedure 3.1.2 Rev.1 ' dated 4/15/82 (not yet formally issued). ' . m ,,-. ~,. --.s.s -n- - ^ "
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.odoG.Breid:nbach 1 / Hay 14, 1982 .1 Review of NPS Standard and Computer Programs Page 2 ,
i i The BASEPLATE version 3.0~ was certified on 5/13/81. The certification and ' backup verification were in accordance with the requirements of W.P. 3.1.2 Rev. 1. The DYNAPO 3 was certified on 2/19/82, and the certification and backup verification ' were in accordance with W.P. 3.1.2 Rev.1. DYNAP0 4 verification and certification on 10/20/81 were also in accordance with W.P. 3.1.2 Rev.1. ; The PIPLOC was verified by report NPS-AM-82-005-005-2, however certification in ' accordance with the latest W.P. has not been completed yet since the program predates the revised procedure. ;
- b. Procured Computer Programs:
There are currently several procured computer programs in use by Nuclear Power Services , Inc. Their verification is covered by W.P. 3.1.2 Rev. O. This W.P. requires verification either by the Supplier or Nuclear Power Services, Inc. ' Currently, Nuclear Power Services, Inc., is in the process of reviewing for acceptance the documentation of verification by the supplier for STRUDL and t and ANSYS and obtaining documentation for other programs. It should be noted ; that the programs being utilized have generally been accepted for use in the industry. - Conclusions and Recommendations The items examined during this review revealed that the standards and computer programs beir.g utilized were generally adequately verified. However, it is recommended that a new procedure be issued as a parallel to W.P. 3.1.2 Rev.1, the new procedure to cover procured computer programs and that the ongoing 1 efforts relative to reviewing the verification of procured computer programs be completed. s [PeteMotola_ pn i
'R Pete Deubler "l
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wNE Rich Maurici PM/PD/RM/dmp cc: J. Gartenbero ' ' i. J. Grabie - J. Lefter ( F. Samaan . l
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Yaps ' gc,go, w oi NONCONFORMANCE REPORT SITF HO M MARK NO. _ gNO. 6 SPEC. NO. O CALG No.: DATE F
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. o I-2-197-401-S32K, Rev. 2 PAmAM m s TUSI J.
OTHER Crnhio r t DESCRIPTION OF NONCOWORMANCE ISE SPECIFIC 3 D-N Rev. 3 _ Revision 2 of this denuing une nne e n km < c
- o -1 fnv O.A. Review as recuired bv Pnenernnh 4.1.17 of Proiect Procedure CP-PP-11. Rev. 3.
{ In addition , _rbfn voviefnn une ciened nff an "Dr n un " nnd " Checked" by oersonnel whos j fniefnle an nne nnnone en eho nnehnvi en i efennenro line. l I i -
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r :2 CATEGORY I D I SPOS I T I ON r"1 CATEGORY 2 w PROCEED WITH r 1 CATEGORY 3 r 1 CATEGORY 4 CRK w PROCEED WITH L.J HOLD SOE r 10 TIER i SORK. NOLD HOLD L.J CORRECT Ll TRANSMITTALS PMV1005 TRANSWITTAL TRANSWITTALS DATE DATE QUALITY ASSURANCE l i DATE CUSTONER i lDATE lDATE e / // SPEC 1F1C 1 N S T R U C T'I ONS P. }&Mn is?Aln Thn rovfeinn in nuestinn in dn eed 10-71 -R'1 For the TUSI Proiect. determine which drawings were transmitted without going through QA for the period 8-21-81 to 12-21-81. QA is to review any that are found and specifically check for unauthorized signatures. These must be rechecked and upgraded to the next revision level. Work to be com-i _pleted by 4.-19-82. , VERIF3 CATION OF DISPDSITION M0/OR CONNDfTSs.Drnwinen hnvp heen vo -ch a cic e d nna ~
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those affected have been marked for revision (See P. Corbo to G. Henry dated 6-2-82). e memo attachfrom X d l O O DATE Of,TE OF A. y% j A'3*Sb DATE o ks Q p t-3-92
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e CORRECTIVE ACTlON REVIEW 1 t g REQUIRED i
! REPUtENCE DOCUNENTS (14 CAR)- '
Baar mu=ED h A $$&7
/ NANAGER OF SUAL7Y ASSURAN
- DATE i 4 .
inter-offica memc To: Pete Mottola : nps ro % - e ,.m , May 11, 1982 NCR No. 1-1015 -TUSI Project- P. Corbo The supports issued during the period of 8-21-81 thru 12-21-81 have been reviewed for unauthorized signature. During this period only 5 of 505 supports have been found to have signatures not listed in the authorized signature list.
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These supports will be rechecked and upgraded when the next revision will occur. P The entire work related to this NCR No.1-1015.is available to Q.A. personnel upon request. PC:rm , cc: J. Gartenberg G. Breidenbach H. D'Errico F. Labay G. Henry , t
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Inter-offica meme To: G. Henry nps F Date Sutgoct From 7 June 2, 1982 NCR No.1-1015 - TUSI Project P. Corbo e Reference inter-office memo to P. Mottola dated May 11, 1982. Rechecking the 505 supports 13 sued during the period of August 21, 1981 thru December 21, 1981 only the following 4 supports have been found to have a signature not listed in the authorized signature list: NPS-2213 CS-1-079-029-C42A Rev. 2
-3077 CC-1-207-015-C53R Rev. 2
-996A MS-1-004-005-C72K Rev. 3 U -262 SI-1-106-003-C42R Rev. 4 A note has been added .o the originals of these drawings which says that they will be upgraded when the next revision occurs. ,
P. Corbo h Nth - June 2, 1982 PC:rm > fd , ro : f e i t ; l . . . . , . . . - . . . . . . . . _ . ~ . - _ . _ . . . . . . . . , , - /. - --.-
NPS Attachnent 6
. inter-offico memo To: Distribution g g QA-83-864 m sem 10 CFR 21 Committee Decerrber 8,1983 Meeting Minutes P. Mottola on this date, discussions were held to review those actions taken by [
NPS to verify the close-out of Nonconforn.ance Reports 1-1020 & 1-1021. Those involved were: P. Mottola - Manager of Quality Assurance J. Gartenberg - Vice President of Engineering - D. Behan - Vice President of Projects G. Burke - Manager of Computer Program Appl'ications ,. B. Goldman - Project Manager, Computer Program Development e By review of all documentation describing those actions taken and the results of those actions, (potential reportable deficiency investiga- , tion), it is our opinion that NPS is not required to advise the NRC as stated in 10 CFR 21.21(b) (3) and 10 CFR 50.55(e). , It is also our opinion that NPS Client, Westinghouse Electric Corp., user of the STIFFPLATE Program be advised of the error for their in-formation and handling. All supporting documentation justifying this decision is located within the Quality Assurance Departments Nonconformance Report Files.
- 4 P. Mottola PM/ka
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P. Mottola G. Bur ~ke Manager of Quality Assurance Manager of Computer i gr A lications M 1 / Gartenberg j __ _ ice President, Engineering [.Doldman I Project Manager, Computer
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Program Development Behan
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Vic President, Projects l cc: A. J. Moellenbeck G. Breidenbach D. Ravad G. Henry O. A. File 10 CFR 21 File (original) l H v '
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NPS Attachment 7 .i i nuclear pOer cerviccc,Inc. n ,. AUDIT FIND 1NG SHEET e' til AUDIT NUMBER (2) FINDING NUMBER (3) AUDITOR , 1 1 Felix R. Labay (4) AUDIT AREA A udi-Lomancne t'caK (S) AUDIT DATES Design Control - Revisions June 25-26, 1981 I5) REQUIREWENTS Section 4.1.5 of CP-PP-ll, Rev. 1 Dated 2-17-81, Design Control - I Revisions, states, the Design Change Notice will be forwarded by the Design Project
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l Engineer to the Support Design Team Leader, who will assign it to a designer. After I appropriate action has been taken, that action shall be indicated by the dated initial; . of the responsible party. (7) CRITERIA Stated in Section (6) (B) FINDING . Based on the number of DCNs reviewed (10), it has been found that all I actions taken are not indicated on the corresponding activity block on the DCN form. ' i. (9) AUDITOR , DATE , FIND KNO BY ATE f
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d)4 7//d/j/ ti13 RECOWWENDED ACT10N The method of indicating actions taken on the DCN sheet should be modified to comply h with the requirements stated in Section (6) . The activity blocks on the DCN sheet should be marked to indicate completion of that appropriate activity.
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t12) EFFECTIVE DATE E IL - Rt t13) WANAGER OF QA APPROV C L RE-AUDIT h ti4i ACTUAL CORRECTIVE ACT10N t Corrective Action has been implemented per Section 4.1.5 of CP-PP-ll. Inter- - office memo dated 8-4-81 has been issued to Team Leaders to correct discrepancies found during the audit. a t15) DATE ACTION TO BE N 10-9-81 t181 RESPONSIBLE SIONATURE g o _ I, O RE-AUDlT RESULTS u I 1
** A review of the DCN books showed that the discrepancies had been corrected.
[ The Quality Assurance Department shall make further surveillance for compliance - O of this requirement. Q. H O
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fy) nuclear power ccrviccc,Inc. M,.n AUDIT Fl'NDING SHEET . (1) AUDIT NUNBER (2) FINDING NUNBER (3) AUDITOR 3 8 G. Henry (4) A E T AREA ) DATES TUSI-COMANCHE PEAK Design Control - New December 15-16. 1981 : (Si REQUIREMENTS P Upon completion of the incorporation of field comments, the i Design Team Leader or his designee reviews the design sketches i and forwards them along with a signed Pipe Support Calculation Transmittal form...to the Sturctural Team Leader. (T) CRITERIA
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%ct4nn A 1 1A nf NP pp 1 n nm, 9 tal FINDING -
Pipe Calculation Transmittal Sheet transmitting support or Problem : 2-56A.were..not signed..by. Team. Leader (or his Designee). - t t9I AUDITOR DATE (l0I FIND 1NO ACKNOWLEDGED BY DATE (l11 RECOMMENDED ACTlON l' 2 0 - % %- (kl6f Or%h LZA82 I e Institute controls so that the requirement for the above section i of the procedure is complied with. '
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l h t12) EFFECTIVE DATE t - E ~ E 1-- t133 MANAGER OF QA APPROVAL - i-n i - A L RE-AUDIT h l t143 ACTUAL CORRECTIVE ACT10N , Pipe Support Calculation Transmittal Sheet for Problem 2-56A will be . signed and dated by Team Leader or his Designee to comply with Section ! 4.1.14 of CP-PP-10, Rev. 2. O t153 OATE ACTION TO SE COMPLETED
'3/2/82 t18) RESPONSIBLE SIONATURE N_ [dth f
I RE-AUDIT RESULTS U t
- The Pipe Support Calculation Transmittal Sheet for Problem 2-56A has '
been signed and dated by the Team Leader in compliance with the re- ; o quirements stated in Section (6) of the audit finding sheet. a. l-i El () O AUDITOR DATE MANA y 0F GA DATE + A .o a N.n .V'W 4/$ s or n, m . .>.m , . , . . . . _ , . . . . . ._._. . . . . . _ ~ . . . . . .
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nuclear po%r ccryicce,Inc. e np. AUDIT FINDING SHEET ) (2) FINDING NUMBER (3) AUDITOR , (1) AUDIT NUMBER 1 7 Felix R. Labav (4) AUDIT AREA TUSI-Comanche Peak (5) AUDIT DATES Design Control - Revisions June 25-26, 1981 - (6) REQUIREMENTS Section 4.1.11 of CP-PP-ll, Rev.1, dated 2-17-81, Design Control - ' Revisions, states, the Structural Team Leader assigns the drawing package to one of the Structural Designers who will perform the necessary revisions to the existing calculations to qualify the Support / Restraint for the applicable conditions. These calculations will be performed on standard NPS Form 101 6/77. , (T) CRITERIA Stated in Section (6) (8) FINDING The Structural Department currently perform their calculation on a new form utilizing a revision sticker, thereby superseding NPS Form 101 6/77. l F 3 i t101 FINO t.CKNO BY DA DATE iSt AUDITOR
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F zi.m tiI3 RECOWWENDED ACT10N i Revise Section 4.1.11 of CP-PP-ll to incorporate the new form being used for the Structural calculations. t t t (121 EFFECTIVE DATE R- It -Rt (13) MANAGER OF QA APPROVAL AE-AUDIT // t14) ACTUAL CORRECTIVE ACTION ' Section 4.1.11 of CP-PP-ll has been revised to 4.1.10 of CP-PP-ll, Rev. 2 to in- ) corporate the new form being used for the structural calculations. I l (15) DATE ACTION TO BE COWPLETED 10-0 Al (181 RESPONSIBLE SIGNATURE h_ p O RE-AUDIT RESULTS O Revised Sections 4.1.10 and 4.1.11 of CP-PP-11 of the TUSI Project Procedures *
," Manual was issued on 9-30-81. After this date, all structural calculations shall {
r be performed on standard NPS calculation sheets. ' 0 O. u DATE WANAGER OF GA DATE - O AUDITOR I I ese J h $ ( ! *il e St U T\
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NPS Attachm nt 8 g . intbr-offke memo T;: Felix Iabay nps ; 7 r o.= suomt From 12-23-81 Technical Audit Bruce Goldman t-Reviewed Problem~ #2-56 A f
'1hree support designs audited - CC-2-201-402-C53R ,
CC-2-201-407-C53R CC-2-201-404-C53R d 3 OC-2-201-402-C53R .
- t Reviewed cxmceptual - .g Iccation plan agrees with Iso Shop weld plate to CC-2-247-402-C53R not possible,should be field weld, three sides cmly.
Field weld to CC-2-193-409-C52R weld synbol indicates welding on top of tube. '1his is not accessible. Weld symbol should indicate welding on far side. Dinension 9 7/16 disagrees with other dimensicn on detail (4 9/16" + 5") i Stiffeners are located at 10" 0.C. 'Ibese will interfere with U-bolt. ' On drawing stiffeners were correctly relocated. 'Ihis does not agree with wawtual Reviewed Stnictural analysis - Ay and Az have different values. Fbr a square tube they should be equal. [
'Ibrsicmal loading does not agree with arranoment and load in conceptual. [
Weld calculaticms for rear bracket does not agree with geometry of weld t on detail. {l il CC-2-201-407-C53R . 1
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Reviewed conceptual - i Iccatim plan agrees with Iso. l Cbnnection to 2C-2280 A cannot be fillet welded on bottcm. l CC-2-201-404 C53R Reviewed conceptual - Iocaticn plan different than Iso CC2-RB97 (6' - 1 1/2 vs 6' - 8 1/8) Drawing shows 6' - 4 3/4" 3 k' f J l m .,.m.,_~ .
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To : Felix Imbay Fran : Bruce Goldren
Subject:
'IUSI Project Date : De h 23, 1981 Page 2 Reviewed calculation - OK .
f Reccmnended Acticri General $, Review a surple of support details to assure accessibility for welding to existing structures all aromd, particularly to upper attachnents is not a I generic problen. t Review a surple of support details to assure welding syrrbols are correctly l detailed with regard to near side vs far side weld. Soecific Revise details to correct errors.
- Revise structural calculaticos for cc-2-201-402-CS3R.
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'." M DUCbc.f p6Kr CCfVICCO,IOC. NCR NO. ' -*
- Nops NONCONFORMANCE REPORT S rrr sob WARK NO. O DWG. NO. O SPEC. NO. O G4 G N0*8 DATE y,, s/s n.2e.ai SYSTEM NO. FROJECT: INITIATCRs 1 w / a, via. .. (see Baue w).
l net Ga na r a_ f PACKAGE NO.: CTHER NF5 esecEDusEs j w/s ccAn S ec.tsem is.o CESCRIPTICN CF NCNCCNFORWANCE GE SPECIFICI
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! O I S P O S I T I O N CATEGCRY I CATEGORY 2 CATEGCRY 3 CATEGORY 4 r Y"0THER O PRCCEED WlTH PRCCEED WlTH HOLD WORK. CCRRECT 1.;J S SG-WCRK WORK. HOLO HOLD PREVIOUS TRANSWlTTALS TRANSWlTTAL TRANSWITTALS ho*4 ,
A r/ DATE / CATE GUALITYgSSURANCE DATE i 5' ' lll ~bs .81 VW llf-1st-V&) 1Ai, l n.ac.g1 . CUSTCMER CATE l DATEL,/ i l CATE l S PEC I F I C I N S T RuC T I oN S put_,- m may . e s ie inie u a_to i m_, ui- ymis p e.- , _ . - m m. e r s -_., %y.. 94 f* 11 L*S iME t_ t 9 D t o a f* T O s 1, C"D *"* L A M *.H AM iA#.mt.1 N k N R ESG- I n 9% s=t f R Lha h EvR s'%hl
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c..,_-. im . . i ea,i n m us ut. w o._ne e n,, e n i s o-.s . n n m * .5 iu . a . %,a es . a- u o se. . e - - ie.m,,v =uen-e., ime,_ a e, : i
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/ PANAGER CF GUALITY ASSURANCE DATE
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S q g J . . ATTACICfENT NONCONFORMANCE REPORT l-1005 h
;i verification of Disposition and/or Comments The'following have been issued to satisfy the stated disposition on g this NCR. All further actions necessary are s in the instruc- j tions areas on NCR'S 1-1006, 1-1007, 1-1008, -1009, 1-1010, 1-1011 ;
.and 1-1012. Tosr I A) Stated Disposition 1 - I F
Initiate NCR for each project to identify supports involved. I Action Taken l
- 1) Inter-Office Memo QA-82-376 dated 1-18-82 has been issued for:
(a) NCR-1010 - Eyron Proj ect 1064 (b) NCR-1011 - Zimmer Project 1040 ) (c) NCR-1012 - Zimmer Project 1047 '
- 2) Inter-Office Memo QA-82-377 dated 1-18-82 has been issued for:
(a) NCR-1-1006 - Laguna Verde Proj ect 3133 MCR-1-1007 - STP Proj ect 3006 (b) i (c) NCR-1-1008 - Maanshan Proj ect 3043/3044 (d) MCR-1-1009 - TUSI Proj ect 3010/3011 ,
- 3) Stated Disposition 2 '
Initiate 10CFR21 review to determine safety implications and report. , Action Taken -
- 1) Inter-office Memo QA-82-373 dated 1-13-82 has been issued outlining the procedures to be followed for the performance of the required review. '
This Nonconforman,ce Report is considered closed. e L l l f e 3
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t To: A.J. Moellenbeck rig >s j u QA-82-373 'l l *** 10CFR 21 Review January 15, 1982 Reference NCR Joel Grabie Please be advised'that a 10CFR 21 Investigation Panel was > convened on December 14, 1981 to discuss the investigation relative to the referenced Nonconformance Report. The attendees were as follows: i A. J. Moellenbeck - President J. Gartenberg - Vice President Engineering ,
, G. 3reidenbach - Engineering Manager D. Ravad - Site Engineering Manager ,
J. Grabia - Manager of Quality Assurance i The following items wara discussed during the meeting:
- 1) Drawing review criteria
- 2) Preltninary review results
- 3) Scope of review to be performed __.
- 4) Reporting requirements Future meetings are to be held to discuss the progress and interim results of the review. The scheduled completion :
date of the review is January 30, 1982. r
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cel Gracie ; JG/ka , i cc: J. Gartenberg i G. 3riedenbach ! D. Ravad j l I
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Yaps NONCONFORMANCE REPORT siTr soE SPEG No. O N *8 MARK NO. O N. A.awG. No. O N.A. * ~ 12-14-81 SW NO. '"' '^ N.A. 3hlY[3'11 0 TUSI G. Breidenbach PACKAGE No.: OTHER Wg 8 ction 15.0 CESCRIPTICN CF NCNCCNFORMANCE (BE SPECIFIC) Design Drawings for this project may include fillet welds which are undersize per ASME criteria based on member size. 9 h D I S P O S I T I O N CATEGCRY l CATEGCRY 3 CATEGORY 4 .. OTh 7r
- FaccEED WITa O CATEGCRY pacCEEo wiTa2 scto work CCRREc7 :
WCRK WORK. HOLD HOLD PREVIOUS l l ,q TRANSWITTALS TRANSWITTAL TRANSWITTALS See Below : h'
- b .-l CATE
{ CUSTCMER l CATV / l 6 l.-
, DATE :
I, I i u i ! S PEC I F I C I N S.T R U C T I O N S j Perform a documented drawina review to detemine if the creblem exists. tha avtant of the problem, and required disposition. f, l I Review is to be initiated immediate1v with ceriodic meetinos to be held (usually i biweekly) as called for by the Project Manacer. Tarceted comoletion date for the review is 1/30/32. l' I
.I I
VERIFICATICN CF DISPCSITICN AND/CR CCMM2NTS: _ Review has bean enm la*=d ed Aa a corrective action taken verified. Refer to nernched memn #*nm T . Crabia to P. Mottola (0-0E-82-070 dated 10-4-82T. 1 0 DATE MANAGER OF G. ^-
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CORRECTIVE ACTION REVIEW !: g [RECUIRE3 Re..-_r.ENCE CCCUMENTS (1.a. CAR 1 O NOT REGUIRED - s , r,mAm ,o,=uAL m ,SSu,, C, fo43J-2l,. oA1.
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o , inter-Off.lCe memo a To: Pete Mottola nps 0-QE-82-0 F Date Subiect From 7 -j Undersized Weld Evaluation Joel Grabie I October 4.1982 ! ;
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l With regard to NCR l-1006 (as it relates to the Laguna Verde Project), NCR l-1007 (as it relates to the STP Project), NCR 1-1008 (as it relates to the Maanshan Project) and NCR l-1009 (as it relates to the TUSI Pro-j ect), a detailed review of designs was performed. The , total review covered approximately 13,700 sketches, of which 1,300 sketches included welds which were under- " sized by Appendix XVII criteria. Evaluation undersizad, overstressed welds - For its potential use in dispositioning welds found to be [ undersized by the review, the design stress was noted from - the design data, or calculated if the weld was sized by in-spection. The review indicated that 12 (out of the 1300
- noted undersized) welds were overstressed.
- 1) Laguna Verde - there were no undersized overstressed welds discovered.
- 2) STP Project - eight (8) undersized, overstressed welds were discovered. On further review of the related cal-culations, four (4) were found not to be overstressed.
The remaining four (4) shared a common condition of ex-ceeding the through plate thickness tensile limits which - wera in the Code in effect on that project. These ten-sile lLaits were deleted in the W78 Addenda as being counter-productive, therefore, it was evaluated as not a defect and not reportable. l
! 3) Maanshan Project - four (4) undersized, overstressed 3 i
welds were discovered. A review of the related cal-culations revealed that the allowable stresses selected were too conservative, and the welds proved to be not overstressed when comoared to the actual Code allow-
~
ables.
- 4) TUSI Project -
there were no undersized overstressed I welds discovered. A series of training sessions had been given to design personnel instructing them in the use of Appendix-XVII criteria. It is .; ( l hoped that this Corrective Action will avoid a recurrance of this ; f problem. ,
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o e p CPP,-7 JAS UTILITIES SERVICES I.( 35Il@3 0 f(t//WAY U i OFFfCE MEMOR ANDUM
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To M.R. McBay *
- CI'e n Rose. Tens - Mav 1I. 1982 sLbject .
CCMANCHE PEAR' STEAM ELECTRIC STATION
, F.ILLET WELD SIZING' REQUIREMENTS t
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As requested in your later of 3-15-82, I am responding concerning the above subject. The requirements for minimum fillet weld sizes are specified in Appendix XVII to the ASME g O Y#d4 Code; paragraph XVII-2452.1 and table XVII 2432.1-1. NPSI has iltformed us by letter of 663 supports that were released with fillet welds specified that did not meet the above re-yA Y
/
i l quirements (letter 12-1768 listed 382 Q ' supports and letter f.C , l 13-318 listed 231 non-Q supports). PSE ha's reviewed our ,f,I situation in light of the above and we have identified 8 SB typicals that have the same problem. The weld sining criteria k.3
- f. f;p ;
have always been a part of our " Engineering Guidelines", so we feel there is no problem-with SB special designs or LB sita I O* designs. As a backup however, we will cake actions 3 & 4 f-//. described below. f3 - d , Our corrective actions are: 1
- 1) The suppors identified in NPSI's letters have' all been placed on "HM" hold, which is not a iold on construction. If the einimum welds t.till exist on these supports they will dispo- Y sitioned by CMC., These would be coded *dMR" as progress on the PSE "ACT" report.
- 2) George Bunt is identifying where he has used the problem SB typicals (CP-AA-101,102,114, .
300, 302, 406, 426, and 427). None of these ' are commonly used typicals. Each support where , these typicals were used will be CMC'ad. '
- 3) Both SB and LB CMC review groups have been told to check each support they review for veld sizing problems. l 4)' Our PSE past design audit will include n check for veld sizing problems also.
With the above actions we' feel that all veld sizing problens
- will be identified and corrected. '
i s h f. 5 >W l ' gehnC.Finneran JCT /cs _ [ *
. i cc: J. Ryan NPS INOUSTF.lES, INC. .
P. Chang R. Baker 60 20005 i c. Bunt itm 16 1987
- R. Custafson
- J.R. Johnson
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- Inter-off1co memo To: J. Takeuchi NJ-01-3130 '
nps ; F " 8"*'* 10 CFR 21 Review F '** ' February 15, 1982 NCR-H15-009/HO-0003 Leo Hovi ' i NCR H15-009 was issued on November 20, 1981, to review nuclear designs for I the undersized fillet welds identified in that NCR. On December 10, 1981, Deubler, Hovi, Hoera, and yourself convened a 10 CFR 21 panel and concluded this situation also required review for reportable defect under 10 CFR 21. ' The review of nuclear designs prepared for pipe support projects and for miscellaneous sales is now complete. The detail by project is on the E individual NCR's, but the total review covered approximately 13,700 sketches, J of which 1,300 included welds which were undersized by Appendix XVII criteria. j On February 9,1982, the 10 CFR 21 panel was reconvened to discuss and reach a final evaluation on these welds. The panel membership consisted of: NPS Industries: P. Deubler - Director of Engineering W. Hoera - Director of Projects L. Hovi - Senior Vice President i - R. Maurici - H.O. Manager of Quality Assurance Nuclear Power Services:G. Breidenbach - Engineering Manager i J. Grabie - Manager of Quality Assurance A. Moellenbeck - President
- F. Samaan, NPS Structural Group Supervisor, also was present at the meeting. '
Note that this was a joint meeting for those projects where NPSI has subcontracted design to NPS, to allow simultaneous resolution of NPS' 10 CFR 21 requirements. The design sketch . review perfonned under the NCR identified (1) welds which were undersized, and (2) also indicated that a few of these undersized welds were t t-1 overstressed. The evaluation was performed separately for the two conditions. I 4 (1) Evaluation of undersized welds - Subsection NF of the Code references Appendix XVII for the design of linear supports. Appendix XVII was adopted l by the ASME from the AISC Specification for the design, fabrication, and ' ' erection of structural steel for buildings, and includes a Table XVII-2452.1-1. , This table establishes minimum sizes for fillet welds based on the thickness . of the members being joined. The relative need for and importance of this ~ minimum weld size for NF Code and AISC Code welding, and the differences in welding parameters and inspection practices was discussed. The panel concluded that these weld joints, even if as-built welded to the dimension on the sketch, did not constitute a substantial safety hazard and thus were not reportable. ,. The panel requested that P. Deubler and G. Breidenbach prepare a detailed report l covering the technical aspects of this evaluation. .
-{
(2) Evaluation of undersized, overstressed welds - For its potential use in dispositioning welds found to be undersized by the review, the design stress , was noted from the design data, or calculated if the weld was sized by inspection. ' The review indicated that 12 welds were overstressed and resulted in the panel ; reviewing this condition independently as a reportable defect. an -
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J. Takeuchi NJ-01-3130 - 2/15/82 , 10 CFR 21 Review - NCR-H15-009/H0-0003 Page 2 ' Four of these supports are on the Maanshan Project. A review of the calculations revealed *that the allowable stresses selected were too conservative, and the welds proved to be not overstressed when compared to the actual Code allowables. . These supports were therefore evaluated per (1) . above as not reportable, but the panel noted that this project was for a foreign customer and not subject to 10 CFR 21. . The remaining eight overstressed supports are on the STP Project. Four of the i eight were found to be not overstressed on further review of the calculations. : The four remaining shared a comon condition of exceeding the through plate thickness tens 41e limi.ts .which were in the Code in effect on that project. . These tensile limits, NF-3226.5 and 3321.1(c) were deleted in the W78 Addenda, as being counter-productive for the'lamellar tearing problem they were intended for. This was evaluated by the panel as not a defect and not reportable. Two ' of the same four were identical and also had a shear stress of 1037. allowable. This safety condition hazard andwasnot evaluated reportable. as .a defect which could not create a substantial The shipping status of all 12 of these supports was unknown at the time .of this evaluation, and was not a pertinent factor in view of the evaluation. There were no other deviations from this NCR equiring evaluation. Signed for NPS Industries: . Director of Engineering La, d ,0 ' - Dirrctor of Projects ' dv Senior Vice President g _4 .. J i -I.,. . .....! -HO Manager of Quality Assuran Signed for Nuclear Power Servcie _' Engineering Manager f -M]A- Manager of Quality Assurance { WbYs//b/ '
) -
[ ('f ; LH:dmp Attachments for file: (a) Technical report for (1) abeve {- (b) Sketch identification and
, supporting data for (2) above '
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f InCiUSVies. Inc. r& CORRECTIVE ACTION REQUEST 0 TO: _
- Nuclear Power Services _LCCATION C
! One Hannon Plaza, Secaucus, NJ Attn: A. Moellenbeck n
- CORPORATE N '..BER CAD-nna_v?
l ' AUS i cc: T H0(NPS) (V)' 3M G. Breidenbach, J. Gart,enberg.
,J. - DATE Grabie G PDX DESCRIPTION OF CONDITION: -
)
j Reference NRC Inspection Report #99900531/81-01 dated February 18, 1982, page 2 para. 3 (relating to design errors and verification) and page 5 of 8 first para. I (relating to programatic deficiencies). NPSI concludes that these situations Work Procedures.are caused by lack of implementation of and training in NPS QA Ma j - - 7 . _REOUIREMENT OF: NPSI purchase l work (TUSI, STP, Maanshan, and Laguna Verde) subcontracted to NPS. o 1 RECOMMENDATION (S) FOR CORRECTIVE ACTION: ral a y 3/5/82 Implement QA Manual Rev. 4 April I,1981; and Define detailed
" Generic Work Procedures 9/22/80 on Project training _ schedule by 3/12/82 Work for NPSI -
Comp. priority sections by 5/15/82 Complete all sections by 7/15/8 MANAGER OF QUALITY ASSURANCE , , Q DATE' 6/r//2 COMMITTED CORRECTIVE ACTION: . See Attachment , SCHEDULED DATE , 0F COMPLETION: /) 7-15-82 _ BJ;-.4MI [J TITLE Mgr. Q.A. DATE 3-5-82 DWIW OF COMMITTED CORRECTIE ACTION: CNOTAPPROVED
@ APPROVED e
MANAGER OF QUALITY ASSURANCE D d h = J DATE 4 - 2. ) - g 2__ CORRECTIVE ACTION HAS BEEN RE"IEWED/ VERIFIED ED FOUND ' - TO SE: OUNSATISFACTORY q a 2 SATISFACTORY AND THIS CAR IS CLOSED. -
!ANAGER OF QUALITY ASSURANCE rms.
m , MM , DATE 7 2. 2_, _ - . . . - - . - - - - - - - ~ - ' ~ _
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ATTACHMENT CAR-004-V2 Page 1 of 2 l To satisfy the requirements of NPSI Corrective Action No. CAR-004-V2, it is the intent of NPS, Inc. to: '
- 1) incorporate the applicable sections of the Generic Pro- '
Manuals for the TUSI, Maanshan, Laguna Verde and jects. 2) conduct training sessions for personnel performing " quality on the aforementioned t related" activities for NPS, Inc.These training sessions shall be developed projects. Cover. (a) general requirements of the overall NPS, Inc. Quality Program (b) specific items contained in the individual Pro-This specific train ject Procedures Manuals.shall be presented to those individu in those areas. This overall plan shall be implemented on a priority basis for both the individual projects affected and the applicable Generic ProjectB Procedures required. ed for both of the items indicated above:
- 1) Proicct Implementation Priorities .
(a) TUSI ( (b) Maanshan < Laguna Verde (c) (d) STP UOTE: If during the course of implementing this plan, work is suspended on any of these listed projects, that project l shall be removed from the priority listing.
- 2) Generic Project Procedure Priorities (a) 2.0.1 - Training (b) 2.0.2 - Technical Proficiency Training I (c) 15.0.1 - Identification & Control of Nonconformances '
(d) 15.0.2 - Control of Issued Nonconformances ' (e) 15.0.3 - Control of Design Errors (f) (g) 16.0.1 - Corrective Action Requests 3.0.5 - Pipe Support Desig (h) 3.0.6 - Manual Analysis - Control and Verification (Structural) 3.0.8 (1) 3.0.9 - Design- Pipe Support Design Control - Details , (j) Control Procedure - Revisions > (k) 3.0.7 - Preparation of Design Reports 6.0.1 - Incoming Document Control (1) 6.0.2 - Outgoing Document Control (m) (n) 2.1.1 - Control of Distribution of Revisions 3.1.1 - Requests for Information (o) i
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/ (p) 5.0.1 - Work Procedure Preparation dit ions Control (q) 18.0.1 - Quality Assurance Records d Program Au (s) 17.0.1 - NPS Quality Assurance Recor sas for the Projects l i ed to Training incorporate shall The individual Project Procedures Manua slisted in P listed procedures.iduals performing each indivi the requirements of the abovethen be performed for the indiv ' ta s .k . ivities on a per pro-It is the intent of NPS to complete these actn Maanshan, TUSI shall ject basis (ie - prior to initiation o complete). . Y b
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M. SNTC-TR -025 ,/ File # X-145/ / ; PROCEDURE FOR FINAL AS-BUILT RECONCILIATION AND STRESS REPORT ISSUANCE FOR COMANCHE PEAK UNIT #1 AUXILIARY PIPING ANALYSIS AUGUST 1983 PREPARED BY:' J. S. SHULMAN l l WESTINGHOUSE ELECTRIC CORPORATION NUCLEAR TECHNOLOGY DIVISION SOUTHEASTERN NUCLEAR TECHNOLOGY CENTER TAMPA, FLORIDA i
'i* -
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- SNTC-TR-83-025 PREPARED BY: c l" 4-#
8 O Datd y[. Shulman, SNTC CHECKED BY:
- 4- 8888 E. W. Pianka, SNTC Date Y
G. L. Adkins, SNTC
$/]/C Date '
APPROVED BY: v P. P. DeRosa, SNTC [!3 Date' O N i I n l
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SNTC-TR-83-025 TABLE OF CONTENTS j Page No. P RO C E D U RE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3 ATTACHMENT 1: SNTC D'eliverables . . . . . . . . . . ...... 4-6 ATTACHMENT 2: Unresolved Issues . . . . . . . . . . ...... 7 ATTACHMENT 3: As-Built Quality Review . . . . . . . ...... 8 ATTACHMENT 4: As-Built Support . Stiffness Comparison - (Class 1 Only) . . . . . . . . . . . . . . . . . . 9 ATTACHMENT 5: Final As-Built Class 1 Support Stiffnesses - Letter to TUSI . . . . . . . . . . . 10 - 11 ATTACHMENT 6: Final As-Built Reconciliation Review - Letter to TUSI . . . . . . . ...... 12 - 13 ATTACHMENT 7: Evaluation of Final As-Built Reconciliation Summary . . . . . . . . . . . . . . 14 - 21
~
ATTACHMENT 8: Final As-Built Check List . . . . . . ...... 22 ATTACHMENT 9: Final As-Built Reconciliation
- Reanalysis Required - Letter to TUSI . . . . . . 23 ATTACHMENT 10: Final As-Built Reconciliation
-Reanalysis Not Required - Letter to TUSI- .... 24 ATTACHMENT 11: Stress Report Compilation - Design Condition Primary Stress Surnary . . . . . . . . . 25 ATTACHMENT 12: Stress Report Compilation - Faulted Condition Primary Stress Summary . . . . . . . . . 26 ATTACHMENT 13: Stress Report Compilation -
Summary of Fatigue Evaluation . . . . ...... 27 e
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. SNTC-TR-83-025 ABSTRACT The intent of this report is to document the procedure to be implemented in the final as-built reconciliation of Westinghouse scope auxiliary piping analysis.
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f *I t l PROCEDURE FOR FINAL AS-BUILT RECONCILIATION AND STRESS REPORT ISSUANCE FOR COMANCHE PEAK UNIT #1 AUXILIARY PIPING ANALYSIS I. Search the TBX 145/15C file and notebook and record: A. SNTC deliverables on form shown as Attachment 1. Incorporate this completed form into problem notebooks and files. B. All Unresolved Issues /Open Items (including as-built letter "open items") on the form shown as Attachment 2. For any unresolved issue that appears to be overdue report to SNTC manager. Incorporate . completed Attachment 2 in problem book and file. II. Perform As-Built Analysis Quality Review using the fonn shown as Attachment 3. Incorporate the completed Attachment 3 into the problem book and file. I
- III. Receipt / Review of Final As-Built Documentation from TUSI
'A. Receipt / review of Final As-Built Support Stiffnesses (Class 1).
#'1. Compare Final As-Built Support Stiffnesses with As-Built Analysis Values (see Attachment 4 and pages 3-4 of Attachment 7).
/2. Identify missing Final As-Built Support Stiffness data.
- 3. Report conclusions on Final As-Built Support Stiffnesses by:
- a. Transmitting letter to TUSI in form of Attachment 5 if all other Final As-Built Documentation (BRPs, BRHLs, BRHs) has not been resolved. -
OR l b. Proceeding to Step III.B.2 (i.e. input to Attachment 6) if all
- needed Final As-Built Documentation has been received.
B. Receipt / Review of Final As-Built BRPs, BRHLs, BRHs, GHHs
- 1. Compare those Attachment 2 Unresolved Issues /Open Items, requiring TUSI input, with responses provided by TUSI in their Final As-Built Documentation. If there are "open items" which are still unresolved report per III.B.2 as input to Attachment 6.
l
1<-
.i , . . 1 l
- 2. Review TUSI As-Built Verification Package Contents (BRPs, 'BRHLs, BRHs, GHHs) and identify any missing data; report on form shown as Attachment 6. Transmit Attachment 6 form.
. 3. Conduct final as-built reconciliation in accordance with the evaluation summary, shown on Attachment 7, as follows:
- a. Compare fdg1 as-built drawines with as-built drawinas and ideali.fy. deviations. Use Attachment 4 data to sunmarize stiffnessTe'vTafions for Class 1 problems only.
- b. Review deviations between as-built analysis and as-built drawings
~ ~
(BRPs, BRHLs, BRHs, GHHs) 'ddEiirmsiisd on marked up' "cheik package" for as-built analysis only if deviations are identifed in a. above. Incorporate with deviations identified in a. above into summary.
- c. ds.against those used in as-built Review _. final . as-built~(1. . - - -
analysis.-"
~
- d. Perform evaluation. conclusion and incorporate completed Ahachment 7 form in problem' notebook and file. "
m~ ..,. ;... ., ....
~ - >
- e. Document reconciliation with conclusions being:
- 1) Reanalysis required - report to TUSI per fom shown as Attachment 9 file in problem book and file. Proceed to III.A.
- 2) Reanalysis not required - report to TUSI per form shown as Attachment 10, file in problem books and files. Proceed to IV. A. , Stress Report Compilation.
- f. Close out deliverables identified in Attachment 1. and items identified on Final As-Built Evaluation checklist, Attachment 8.
IV. Final As-Built Reanalysis A. Receive concurrence from TUSI as to the need for reanalysis. B. Receive TUSI response to our forms shown as Attachment 5 (missing data) and Attachment 9 (TUSI reponse regarding support stiffness modifications). C. Remodel, as necessary, to address the deviations identified in III.B.3 and documented on fom shown as Attachment 7. D. Reanalyze. E. Retransmit, as necessary, analysis data identified in I.A., incorporate into problem file / book. Proceed to V, Stress Report Compilation, for Class 1 stress problems. e
- 9 ...- "
, i V. Class I Auxiliary Piping Stress Report Compiliation A. Obtain and/or generate system schematics and PAGES data base plots for each auxiliary line.
B. Tabulate Design Condition Primary Stresses and Limits for the RCS, CVCS, RHRS and SIS from the individual stress analysis books on form shown as Attachment 11. C. Tabulate Faulted Condition Primary Stresses and Limits for the RCS, CVCS, RHRS and SIS from the stress analysis books on form shown on Attachment 12. D. Obtain and Tabulate Primary plus Secondary stresses and Fatigue Usage Factors for the RCS, CVCS, .RHRS a'nd SIS from the stress analysis books on form shown as Attachment 13. VI. Class 1 Stress Report e o e
.! 4 ,
STRESS PROBLEM J
' ATTACHMENT 1: SNTC DELIVERABLES *
. RESPONSE ' RESPONSE ENTRY ITEM (1) ' INTERFACE (2)TRANSMITTAL DUE RECEIVED 'C0 MENT (3)
(Organization) (Letter #) ( Individual ) ( Date ) R1 Stress Report, Class 1 TUSI (Class 1 Lines) R2 Letter Report TUSI (Non-Class 1 Lines) V1 W Supplied Class 1 Valve, TUSI Nozzle End Loads and Acceleration: Report Satisfaction of Limits. (Should be in - Stress Report). Same as "V1" except limits TUSI/EMD / cannot be satisfied. j Letter Report.
- V3 Owner Supplied Class 1 Valves TUSI or Valves in Non-Class 1 Extensions, Nozzle End Loads Letter report.
1 V4 Same Valves as "V3", TUSI Accelerations.
. Report Satisfaction of Limits. (Should be in Stress Report).
Same as "V4" except limits TUSI cannot be satisfied. Letter Report. V5 Owner Supplied, Non-Class 1 TUSI Valves, Nozzle End Loads & Accelerations, Letter Report. B1 Report Pipe Breaks. TUSI Letter Report. B2 Report-Jet Impingement Effects. TUSI (Should be in Stress Report).
- Incorporate a copy in Problem Book.
ATTACHMENT 1 CONTINUED RESPONSE RESPONSE ENTRY .ITEMII) INTERFACE (2) TRANSMITTAL DUE RECEIVED COMMENT (3 , (Orcanization) (Letter e) 1 ( Individual ) ( Date ) LZ Provide all Support Loads. TUSI Letter Report. 4 L2 Provide Branch Displacements TUSI for all non-W problen branches. , Letter Report. l L3 Provide Loads on Primary SEED /SSD Equip. Noz. All lines. E. Johnson Letter Report. L4 W Thermal Equip. Noz. Loads, SEED /AEA Report satisfaction of Limits. M. Patel (Should be in Stress Report). Same as "L4" except limits SEED /AEA not satisfied or no limits M. Patel given in E-Spec. Letter Report. L5 Non-W Thennal Equipment TUSI NozzTe Loads, Letter Report. L6 Provide Nozzle Loads at TUSI Moment Restraints. Letter Report. L7, Provide Nozzle Loads at TUSI Penetrations. Letter Report. G I
~ . - -- .. . --. . . - . . , . . . . ,
- ~
,, l e .e (1) If several transmittals were made to accomplish complete delivery of a particular item, list each on a separate line. Keep all transmittals on a particular item adjacent to each.other.
(2) Organization and/or individual to whom the item should be transmitted. (3) Indicate " Complete", "What further action is required", or " Supplements / Supersedes (Letter #). (5) Owner may subsequently specify Jet Impingement Loads. (6) Unless new support scheme mandated. 9 O e e S e
- p. ..,,.. ,, . _ , _
~ .
7 ATTACHMENT 2 COMANCHE PEAK UNIT #1 UNRESOLVED ISSUES - STRESS PROBLEM Issue Documented Issue Resolved Closure Description of Unresolved Issue In Letter No(s)/Date(s) To Letter No(s)/Date(s) l l
~
_ _,I,_ , , . , _ - 7 * , ;- - , -
- _ e
WESTINGHOUSE NUCLEAR TECHNOLOGY DIVISION ATTACHMENT 3 1 1 PAGE TITLE Stress Problem , As-Built Analysis Quality Review 1 Os 1 PROJECT AUTMOR QATE CM K'D, g y DATE CM g 0. S V QATE Comanche Peak (TBX) S O. CALC.NO. FILE NO. GmOUP TUAP TBX 145/15C SNTC-PAD l Yes No Coment ! l i l
- 1) Has C.P. been signed and checked? l (EngineerSignature)
- 2) UPDATE Doc Sheet signed and checked (EngineerSignature)
- 3) Doc Sheets for DW, TH, OBE, SSE, LOCA, JET LOADS THRUST LOADS (where applicable) signed and checked (Engineer Signature)
- 4) Does use count for (3) agree with C.P.? (If No, state reason)
- 5) Post Processor Doc Sheet signed and checked (EngineerSignature)
- 6) Is As-Built Reconciliation complete and verified?
REv, AUTMom OATE CHK'O. S Y DATE CM K*0. S v OATE mEv. NO. DATE WESTIN0 MOUSE PORM 552130
4 . ~ . eW' gm$zOIOC1mU gCngm>N nmOIgorOO< O25oN
>d>O3mh *
;e _
_ $ ra , v *. g ,3 s g ,-
%ay':,,;ogg4 ,++ )s3^*
7']3p*.$= 3sM ~ 3 sl' C
- o. _
_ b- ,Sx0 .o o= 59 .< y: oN? ! O%-
?a;,s* y= ,g5
? o;n. z9 wp*29 o o. t s i
$=u dX gauDuO EM' ,>U c
%e D
eg n .
- - ac hn -
e e t CI t a a s D D s
. e .
n df if gi 1 t RS s t s l e
= l n C uf U - Bf A i
. P st p C AS C
C. s s s I i e S s yl f n
- U 1 T l ef adi M m not E o r
AMS L f B O ee pz
- R l P a ii t PS .
S t S i s E m e p ._ R s _ T n y _ S e a T g r l a t k e c s d a s o P e M# n kff c f eni hut CRS _ 123 s e c n e r f e e t r R o pe pm ua SN ro SN
, 5 10 Oto O1?9 = 4 ?2 aN? i ?.a .
$, ,= -
o3a g1og* g* Eg
;s l ;;:
'., ,. 10 f
?A ATTACHMENT 5
** "'"""I' 0 *
- Westinghouse Water Reactor Electric Corporation Divisions scai seen *ersnore souewa Tampa nonaa 33616 WPT-S.0. TBX-145 Ref: 1. CPPA 30,870 x (6/3/83)
Mr. J. B. George Project General Manager Texas Utilities Services, Inc. P. O. Box 1002 Glen Rose Texas 76043 Texas Utilities Services, Inc. Comanche Peak Steam Electric Station Final As-Built Class 1 Support Stiffnesses
Dear Mr. George:
We have reviewed the final as-built stiffness data provided to us in Reference (s) for the following stress problems: i The final as-built stiffness data provided to us is complete with the following exceptions: It is important to note that this review addresses stiffness data exclusively and therefore necessitates routine, possibly conservative, conclusions to be reported at this time. It is only upon review of complete final as-built documentation identifying piping layout, supports' type and directionality (i.e. BRP's, BRHL's, BRH's) that final judgment can be made regarding the need for support modifications. e 1 l l e
11 Mr. J. B. George Page Two Our review indicates that the following stiffness deviations may require support stiffness modification as per~ Reference 1. Pending receipt and review of the remaining final as-built data, this response may be considered for information only. Very truly yours,
' WESTINGHOUSE ELECTRIC CORPORATION A. T. Parker, Manager Texas Projects CC: ARMS, TUSI, IL 1A D. A. Bartoi, _W, IL F. G. Burgess, TUSI, IL H. A. Harrison, TUSI, IL R. Moller, W, IL 1A J. S. Shulman, _W, IL 1A D. W. Westbrook, TUSI 2L 2A .
l
' a.
~
*
- f4 i.MY:
ATTACHMENT 6 23-Westinghouse Water Reactor "'8"'" o D D"'5* Electric Corporation Divisions som seen westsnore acuevarc Tamoa Fionaa 33616 WPT-S.0. TBX-145 Refs: Mr. J. B. George Project General Manager Texas Utilities Services, Inc. P. O. Box 1002 Glen Rose Texas 76043
, Texas Utilities Services, Inc.
Comanche Peak Steam Electric Station Final As-Built Reconciliation Review
Dear Mr. Westbrook:
We have reviewed the final as-built documentation provided to us in Reference (s) i for stress problem We are lacking the following information, needed to complete the final as-built reconciliation:
- 1. Final As-Built Support Stiffnesses (Class 1)
- 2. Final As-Built BRP l
! l l-l, .
Mr. D. W. Westbrook l Pa ge Two
- 3. Final As-Built BRHL (or GHH) i 4 Final As-Built BRH
- 5. As-Built Analysis Letter No. "Open Items" This lacking information will impact our schedule if not received within days of the date of this letter.
Very truly yours, WESTINGHOUSE ELECTRIC CORPORATION A. T. Parker, Manager Texas Projects CC: ARMS, TUSI, IL 1A D. A. Bartol, _W, IL F. G. Burgess, TUSI, IL , H. A. Harrison, TUSI, IL R. Moller, W, IL 1A IL 1A J. D. S. W.Shulr.an, Westbrook,3,TUSI 2L 2A .
WESTINGHOUSE NUCLEAR TECHNOLOGY DIVISION ATTACHMENT 7
" Stress Problem ''
Evaluation of Final As-Built Reconciliation Summary 1 os 8 PROJECT AUTMOR DATE CH K'D. B y DATE CM K'O. S V DATE rnmanche Peak (TBX) 5.0. CALC.NO. FILE NO. GROUP TUAP TBX 145/15C
Purpose:
To reconcile the Comanche Peak piping analysis to the final as-built condition. Method: The attached checklist is used to verify the acceptability, within stated tolerances, of the present analysis to the final as-built condition. Any deviations exceeding these tolerances are addressed using engineering judgment. Conclusions as to the acceptability of the model are then made.
References:
- 1) Latest applicable PAGES Data Base Filename UC Date a) Is this data base same as WESTDYN Model _ Yes No b) If no, Update changes are:
Rund Tape Name E D I.D MF, Date i i l ' l
- 2) Building: Containment H. E1. Auxiliary H. El. Otherl
- 3) Final as-built documentation package CPPA- , dated REv, A g y, AUTMOR OATE CME'D.SV OATE CM E* 0. 0 V OATE NO. DATE WBSTINOMOUSS PORM SS2130 e
s _
, ,, -. .rn-w,----, ,, , , - - - ---,---,--.-,e a e- -- ~ ~
~
A
- s j
1 5j , ITEMS TO BE CHECKED. TRUE FALSE N/A ' REMARKS ;-f $ 4 3>
&j {
n a n c w d PART~I I TO EVALUATE THE MODEl. 9. f T= -s K'
- +,
2 25 (I.1) GEOMETRY CHECK .
- % 8m "3 !
b
, f VM , l '. All segment orientation angles are -
,"$ within 150 of the actual g
- S{ ;
E o-i 2 *E S'" 7 o . 2 5 S E . E
~2 .' Segment ler.gth discrepancies are S 5 within the following tolerance,: , 9 3T e .
I o W C Pipe Segment length L Tolerance 5; y L s 5' 6"
- 2 L > 5' +10% := c
* - e ae t
E 8 G G-
-z 38 > *
? g: o c ~3 7;
Jx;3 5 9 *g 1 O -
- 3. . All segments & branches are ,_. 9 T included; also branches and tees $; *
" I sre modeled at correct locations D o on the run pipe E e o
o
.E -< <
Q o ! I y 2
- E o n o k 4. All elbow types (i.e. SRE, LRE, 50) g ; z P in analysis are consistent with 3 y%
H P ' i final as-buil t. I [ ; i E "E , o
- 5. A11 reducers and fittings in
=
analysis are consistent with =
, i final as-built condition - ?
. .t ,
5 e
t l-3 $3 3 '< dE
>- ge 25 3 r
E ITEMS TO BE CHECKED " *
- 1 RUE FALSE N/A REMARKS s Y -
S~ IE ?! PART i - TO EVALUATE THE MODEL (Con't)
- 2N 7 "2 y (1.2) SUPPORTS CHECK s "e EE n
- 1. All supports shown in the final
~ 1o E
GI S3 as-built documentation package 5 oE :E are included in the model (Check n > *E "' E Update changes - include penetra- # 5@ T tion anchors) P ' 5 5
" 2 $
I E O
- 2. All support location discrepancies - c are within the following toler-
, y p 2 ances: m c ,
o Nominal Pipe 0.D. Tolerance e
- b o
OM y*
, 0.0. s 4" Greater of Nominal o 2
0.D. or 3" 3 o 2 g
-4 r m -i
$ 0.D. > 4" Lesser of Nominal E~ 6S $
=
0.D. or 18" g j 5 $ R 0
~
- o
- 3. No support has been relocated from E 8 O
- one side of a fitting to the other. *
[ g g - All Class 1 As-Built support vi
- s, u
- 4. "
j stiffnesses are within: gg 2 q, g z 6 . . Pipe Design Temp s 2000F ME .; P 4 ; ST s 0.8* MST i 20% " (, ?
" +NTR
.8* MST < ST s MST :20%
o +NTR " o t ST > MST .-20% below MST
' " l $
. 2= 8 l- - - d o* no =- e 4 j - <1 ITEMS TO BE CHECKED TRUE FALSE N/A REMARKS g- g[
, n
. o l on PART I - TO EVALUATE THE MODEL (Con't) e" TN 12,
~ - - -
.E ?, ;
m e, -
, ee y 4. Pipe Design Temp. 2 2000F $ [
fn ST s 0.8* MST;! 20I
~
d 0h o-
- x += g
" " m 4
1; .8* MST < ST s MST $ +-NTa 20% 0 E I $
~
n 1 n 2 1 C 4ggg z - o
" ST > MST 9 a I
< 1 esser of -25% "
. and 20% below MST 2-
- y, J -NiR = h Tolerance Required $
-.' MST = Minira Rigid Stiffr.ess S. c
, g. ST = Design Stiffness g
;;' pj m ,
j , 3'
;9 5. All' support directions are d* p g j
within,1 100 to the actual *E r 5 8 9 m n
.y. . _ -
g9 . ; g I 6. All support types are modeled 3 % o correct)y W o o
, 3 o
- v, C
lt g 7. Supports on the C.G. of the valve o g { n are modeled correctly o h n g, 5 l m8 l 2 9
- 8. Pipe material.s and welds are k F. *
< specified correctly 4 ;
E e.E ,
c. L l d-
* * * * * * = = = - .y-
'E '5 ITEMS TO BE CHECKED TRUE FALSE N/A REMARKS db &5 5
% 25 "
E oa PARI I - TO EVALUATE THE MODEL (Con't) R* mm E 5 a ,4,
$ 0 .E 5 (I.3) EQUIPMENT TAG NO. & PIPE LINE NO. CHECK
? sN E
% 1m 3g
- 1. Valve & equipment tag number in the -
]
c final as-built are the same as d o, those used as a basis for the as- 5 " .% y c, built analysis. C ! ?* I; ; 3 g 2. Pipe line numbers in the final as-
= built condition are the same as 9 2 22 O 3 @
those used as a basis for the " c as-built analysis.
? l0 a z i o (I.4) VALVE MODELING ;
5.
" 8e r- 5; O
- 1. Valve locations are within the
' ;m '$
m n % i greater of 3" or nominal OD of the g; x I. 3 M O analyzed locations. 91 o
' " 2. Valve stem orientations are wit ~nin $; '
I
+ 100 of the analyzed orientations. O D %
A C o 3 O W -< { g O y ?N E
- d E k
e E j ' P do c d i
* ?' .
~
s o m-a
?
O O 4
. ;;l
.~
9
.b 5' @E E $
j PART II - LOADS RECONCILIATION - FOR LOAD CHANGES IDENTIFIED SUBSEQUENT TO AS-BUILT ANALYSIS %' ;'2 $ E g= . Used in (1) Final (1) (2) W g .< Existing As-Buil t , 13 3 Analysis Definition
- E -
??
, 2g g Design Pressure d 3,, g g u
y s m
- ; Deadweight y !; $
1 E 7 5 E
. g Pipe Runs g i g o
Insulation h g m i Valves
- z n C
= o ,
y Misc. Components y g-y 0 . ' 2, 9
^
Fluid Weicht ga ? 5 O
; m x
$ Seismic ~5 2. @
< 3; <
g z O Thermal D
- o LOCA ! O 4 o y Jet Impingement y E g Pipe Whip Impact Loads g g o MO F Valve Thrust Loads M ( .,
4
- s Anchor Motions g as - ,
, (1) Insert a value, report # or source used including revision or date if needed. ? g (2) Use additional pages, if necessary, to explain differences from the " Existing Analysis". y co
. # 2
b Yo ?E $
-y PART Ill - EVALUATION CONCLUSION (Check One) %' 2$ ;
y SO mm p
;> Model represents 100% as-built condition (i.e., all deviations are within tolerance) g .<
() i n J 5 am
; Model adequately reflects 100% as-built condition (all deviations exceeding tolerances %"
y
=
are satisfactorily addressed in the attached pages) () [ y g a () i E Model significantly deviates from final as-built condition; reanalysis is required x : ,, 7 g E ^ Jn
- m
; List of significant deviations () E E T $
1 - F 1h 5 S E 5 T E k 8 i m
- z E be
%. s ;a d ,
fiI 1' I. di J 4 9 *z # 4 $
%9 s= I e 5 c: o g o o PART IV - DOCUMENTATION COMPLETENESS REVIEW l
< o I. All calculations, doc sheets, pages models, etc. are signed by both author and ? 3 n
checker (s). Anything written for information only is clearly stamped as such. () o
=
a 2 o i m z p Doc sheets are written for all computer runs including the CDC update portions of 2j E $
; CRAY runs. All these runs are listed on the final computer runs sumary. () ?'
4 A minimum of I copy of microfiche is available for each computer run. () " 2
=
a zu . o . 4
! '5 Final Computer Runs CDC/CRAY Runs F j$ *U i s E E o, Type of CDC Runs CDC Update CRAY S" n ta E
Source Co. Analysis (Inc. Microfiche Microfiche CRAY Run Microfiche 54 of Run* No. Post Processor) Name Date Name Name Name Date 2 II
=w o
n
=
x 4 g -m
=
a 7 m 33a
- x 2 -
g -
+ =a E m
E 9 E 2 G V E is E o o" o " o
. I a o
.. m
; 2 C
= n .
O 0 9 p m 5 g
.t ,
my n , n a x
! F 1
2 a m 6 on
% O 9 = $ I a z
= o m r e o 3
0 1 0
$ 3
. . e a o n o i
p 8 i 2
=
g% # 4 _. 4 n b m2 , 8 O
- 1 = Phase 1 Analysis o 2 = As-Built o m
, $ 3 = Final As-Built j
J
$ b$ d5 $
o j _ ' App 11calbe D-Specs g *la [In :; N
- .. , .a 7, ITEM EVALUATED ACCEPTABLE COMENTS g g 2 (Y or N or NA) (Y or N) w y, d aB
^
; Welded Attachments ci, cr,
; #3
- m
! Sleeve Penetration C l;
m $ 1 Displacement Limits ig 3 O y O a g 9 Non-Class 1 Branch Stress k ** C o :> m Flange Evaluation s -j m 9 z NB-3673 Restrictions g ?; g 84 (Class 1 Only) , g y
- a g. n = ao m X .
m . - 1 O 9 ng
# A ,
< m < z
- o m r-0 0 0
O E S E
- 5
- . ? mE 2 @
F d fO n5 F. 0 S Z B -E o 4 1
^ --
, . v.
~
. ATTACHMENT 9 7 Westinghouse Water Reactor " '8"' " :D D"'5*
Electric Corporation Divisions Sca1 scum wesum scaevar: Tam a Fionda 33616 WPT-S.O. TBX-145 Re fs . Mr. J. B. George ! Project General Manager ~ i Texas Utilities Services, Inc. P. O. Box 1002 Glen Rose, Texas 76043 Texas Utilities Services, Inc. Comanche Peak Steam Electric Station Final As-Built Reconciliation
Dear Mr. Westbrook:
We have reviewed the final as-built documentation provided to us in Reference (s) for the following stress problem: From the review, we conclude that a reanalysis of the subject stress problem is required for the following reasons: Your concurrence for reanalysis is required by . Very truly yours, WESTINGHOUSE ELECTRIC CORPORATION A. T. Parker, Manager Texas Projects CC: ARMS, TUSI, IL 1A W, IL D. F. G. A.Burgess, Bartol, lSI, IL H. A. Harrison, TUSI, IL R. Moller, W, IL 1A l J. S. Shulma_n, _W, IL 1A D. W. Westbrook, TUSI 2L 2A l
, , . , . - - . . , - - - - . _. - . _ - - . - ~ - , - -
24 <% ATTACHMENT 10
~%
.b r Westinghcus Water Reactor ** ' '"**' D U"""
Bectric Corporation Divisions scai sm nemnere e=evar: Tarnoa Florica 33515 WPT-5.0. TBX-145 Refs. Mr. J. B. George Project General Manager Texas Utilities Services, Inc. P. O. Box 1002 Glen Rose, Texas 76043. Texas Utilities Servfces Inc. Comanche Peak Steam Electric Station Final As-Built Reconciliation
Dear Mr. George:
We have reviewed the final as-built documentation provided to us in Reference (s) for the following stress problem: From the~ review, we conclude that a reanalysis of the subject stress problem is not required. The analysis of this stress problem is considered complete and reconciled to the closure documents listed on attachment 1. _ Very truly yours, WESTINGHOUSE ELECTRIC CORPORATION A. T. Parker, Manager Texas Projects CC: ARMS, TUSI, IL 1A
'D. A. Bartol, _W.~1L F. G. Burgess, TUSI, IL H. A. Harrison, TUSI, IL R. Moller, W, IL 1A J. 5. Shulman, W, IL 1A D. W. Westbroos, TUSI 2L 2A a
l I
.v ATTACHMENT 11 TABLE DESIGN CONDITION PRIMARY STRESS SU M RY LINE, LOOP Allowable Maximum Stress Node Piping Equation 1.5 Sm Point Component Stress (ksi) (ksi)
Butt weld Long radius elbow Branch connection CRUN Tee Socket weld Socket-welded elbow Stress Report Compilation Stress Problem 1 Author Date i Verifier Date _ . . _ - _ . , _ ~ _
J. #
,? ATTACHMENT 12 TABLE FAULTED CONDITION PRIMARY STRESS SUNIARY LINE, LOOP Allowable Maximum Stress
~ Node Piping Equation 9 3.0 S , Point Component Stress (ksi) (ksi) l Butt weld Long radius elbow Branch connection CRUN Tee Socket weld Socket-welded elbow
- b. Allowable stress at Stress Report Compilation '
Stress Problem Author Date Author Date
~^ ~
- ~ _
. . ATTACHMENT 13 EXAMPLE TABLE StM1ARY OF FATIGUE EVALUATION LINE, LOOP Aaximum Naximum illowable Maximum Equation 12 Equation 13 Stress Cumulative Piping Stress Stress 3.0 Sm Usage Section Component (ksi) (ksi) (ksi) Factor 1 CRUN -(a) -(a)
Butt weld -(a) -(a) Long radius -(a) -(a) elbow Valve butt -(a) -(a) weld 2 Butt weld Tee (12x12) 3 Long radius elbow CRUN Butt weld Tee (12x8) 4 CRUN Butt weld f
- a. Equation 10 not exceeded-Stress Report Compilatibn Stress Problem Author Date ' Verifier Date
,- - , , , - , , ,--,,,-,,n- , , - - - - , - - ---,r---- - , , - , , , , - ,----,v- ---r. ,,,-,-----w -,--~,--,--,e---,, ~~- r
~ ~
s' Westinghouse Attachment 3 e - I i IA-81-16
"$AMI - COGNC.kE PEAK" JULY ?k,1v ,
/. o i
>c'.S' $ d/ 7, , 8/
S. M. 'auai, Lead Auditor Date " ! Syste s hmaliar.ce APPROVEC: A./d D. N. As si7nf, 'anager p/s7/g/ Date Syste :s Compliar.ce . l
o - e ~ t' i IA-81-16 j "5 AMU - COMANCHE PEAK" 1.0 Audit Purpose 1.1 Audit the NT0/hC00 divisional anc departmental controls necessary for adequate description and ir olcmentation cf quality-related activities performed at the 5"d 5: actsral Anal, sis Mobile Unit (SAMJ) located at the Comanche Fe A Site, Texas, against the re-quirements presented in the Audit 3'an (P!-DA-81-123, 6/16/81). 1.2 Assess the effectiveness of the a clicable cuality program through implementation verification. 1.3 Identify noncompliance and recon-'91 sc'utions to aporopriate levels of management. 1.4 Verify corrective acti:n .to ass. e 9:e-out of identified non-conformances. 2.0 Audit Data 2.1 Audit Dates Introduction Meet 197 - Ju!/ R.1 1 Audit Interviews .'uly 9, 14, '-
'N' Exit Meeting - July 15, 1981 2.2 Audit Team
- 5. M. Stahl, Lead Auditor A. C. Chan, Auditor 2.3 Audit Scope The audit criteria and departments contacted are presented in the Audit Plan (PI-DA 81-123, 6/16/81). Personnel certacted during the course of the audit are as 'a' lows:
i S. M. laitte. Manager. Piping % Struc.aral Site Engineering C. W. . Manager Comanche reak structural 5erstces P. T. . Menever. Design Assurance Systems A. T. Porter Project Manager Sauta Texas & Tesas Utilities R. S. Reno. Engineer. Coennene Peak 5tructural Services J. R. Luna. Engineer, Cossacne :eak structmet Services
^- . ---
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- I
. 2-l 3.0 Audit 5.aenary -
The audit results see 'avorable. Dersorcel working 1: the site were knowledgeable concerning technical s:cects ' :neir we-k and were able to provide adequate respceses :s tr.e au:it :uestions. The work accears to be progressing in a controlled mar.ner, ws:h weekly roducifon meett gs held between Westir; house and Texas '.'tilittes Services cersonnel. There were two findings and one osservation identi'ted as a result of this audit. Areas crasently deficie9: include external interface definition and training do: ace 9tation. Follcnt : the asdit, a triining presentation was provided at Coeanche 8eak :s SAM.' ce-sonnel on the recutrer.ents of 10CFRSC, Appendix 3 and ICCFR2!. 3.1 Aud': ei :'- s .
**e areas 151: re ; ire ::rrec:t e 1::f: :re s. marized in the a a:heect :: :nis re: Ort. :c:sils e-;2ir.tr.; :o the audit firdings are alsc cov'de:. Each fir.tir; and s:se-.atier requires .
a 'ormal wr sten resconse to Sy:ters C: :11ance from the identified rescons:::e a-agerts) :y Au;as 'E, 173'. Tne 'crms provided in the atta:h e .t may te c:::le:ed by -es:c s ;1e . 4 agement as a reans of providing :Se f:rnal res:: :.e. ~ T^e res:Orse ust indicate tne correct' .e a: tic 9, action : .re e : es:urrence cf similar deficiencies and sche:.'et :P actual :T:'+.':- dates :' : e.e a::icns. Cc -ec:1,e action re:or e*:a: :rs arc : :.i:e: - : e -e::<:. b.: it shou': te unders:c:c : t; alternate S cr.s ay a' a :seficiently accres: the audit #1-dings, if agreed :: tj t's tend aut ::r. A follow-u: repor should be er:vi t ed to Sjste : ~; :lian:e **+ :: erective actiens are completed.
e ~ t souctaAA TecMasotooy Devseecos AUplT RESULTS auoeTme. IA-81-16 OASANs5AT90s @ ft AWOtf TITLA NTD P!&DA 7-15 81 SAmi-Comanche Peak AssosTosi pu,oesse 3,o, 1 S. M. Stahl OsasRVATlost Osc.
- s. maouinensenT M -3.0. Rev. 2 iuer easea oescaminne se neewmementi The flow of infomation involving design interfaces within and betiseen participating design and suppurt organizations is to be depicted in appropriate decoments and is to include interface actions involved in conducting reviews, approvals, releases, distributions, retention and revisions.
- 48. De8CsttPfloft OP Famoteso OR OME AVATION Besign interface activities are currently not adequately described for the Comanche Peak SAMU Trailer in the following areas:
A) Drawing Control, and
- 8) Correspondence Control.
i (CONT!NUED ON NEXT PAGE) Ii1. RECOam8 ENDED ACTION Write an interface agreeniant and receive required approvals describing flow of in-femation between W SAM) Trailer and Texas Utilities Services Incorporated. iv. asmoNe0 TO C. W. Gay /A. T. Parker nasPONSE QUE DATE 8-15-81 r0 e8 CearLEf t0 U *H4 ASSPONStekt AUDITED MAN AGEnsENT (PLE AsE TYFel V. ACTION TAKEN OR TO SE TAKEN ACTscoe consPtsTices DATW seeseATunt Tms i V' 8888cmes AcesPrasta ,,,, Wf f.VSABpgSAfl0Bf ACTIGI weaspesa este V 61. =======.- . . CW enes U ..s.- .. h d d . 1 l
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- COMINUATIOR SNEET NUCLEAR TECHNOLOGY DIVISION AUDIT RESULTS
. apostaso. IA 31-18
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. ,S. N. Stahl oessavAriosssec. _
7
- 44. oGaCalPflast te pieteesse ofl osed nVArto80
. Findina ha. 1 (Responsible Management: A.T. Parker /C.W. Gay) , j The method used by SAMU parsonnel to implement required draring re.
- visions is not adequately defined by an external interface agreement.
, Isometric drawings, originated by Gibbs and Hill, which require re. visions based on S M design analysis results, are marked up by S M personnel indicating necessary changes. This information is provided to TU31 drafting personnel who issue a new drawir.3 which incorporates the required revisions. This new drawing is then initialed by W SMel personnel indicating that the revision was made as indicated on~the Gibbs and Hill drawing. The method used to control correspondence information between Westing-house and SAftJ personnel is also not adequately defined by an external interface agreement. Personnel at the SAMU trailer use a TU5! typing
- pool to issue letters. Thus. Westinghouse letters written to TU51 I personnel are contained on TUS! letterhead. This information is avail-able for TUSI use at the time of typing rather than being transmitted to the customer through the NC00 Project Office as required by existing procedures.
The required scope of work definition is not forna11y issued, but the weekly production meetings held between W SAMU personnel and TUSI representatives alleviates the potentiaT of misconsnunication relative to organizational responsibilities. It is, however, re-commanded that a clear definition of responsibilities be developed within an external interface agreement between W SAMU and TU51 pereennel. It is also noted that the W work proposal letter WPT-39U states that, "Others are to provide a mastually upon Progree F1ee ftr the conduct of the work which provides a) designation of piping system and related equipment included. (b work procedures . , and methods, and (c) identification of responsible parties for each ' estivity and essociated interfaces.' This document was not faced to esist. O e
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l e i s seUCLEAR TECHNOLOGY OlvtsIOpt ' AUDIT RESALTS Auge7 seo. IA-81-la YDE Yb81 ""J P I FA Puk f assesToa - pusense see.
- 5. M. Stahl 08EERVAT428 880-
- a 1
- 8. aseuensassm7 NTD-OPP-1C. Rev. I a ,an.es mesenerviener meanneesswei l It is Iml policy to provide for indoctrination and training of personae 1 assectat.1 with saftrty-related activities to assure that they are knowlewgeable air queltty assurance and technical requirements and the pertinent procedurge governing such activities.
1
- . Descaintom or riseosaso on ossanvarion Contrary to the above requirement, docuinentation of trai'11ng for 3AMI personnel was '
- not available for review at the site locat*on.
i l l III. mEcometeNoED ACTION ; Provide training to Comanche Peak SAMU personnel according to requirensets Itttes in NTD-DPP-1C Rev. I and document such activities. ase a v. Assaamso To C. W. Gay maerones sus ears 315 31 _ l j vo es cesetateo av ras aesponeists acoerso enamassamer snames vwei V. ACTloN TAKEN on To M TAKEN 3 I i e i l l l .l N 6 MTE 6 W _ -- l vs. nesseems aegyvaans -- --- - _, weI.wealfte4Teenassage Vt 1. , . empe
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.ustwweesace e. wne w i Section 206 of the Energy Reor9anfration Act of 1974 and other docesseats needed to satisfy the requirement of 10CFR21.6 shall be posted in conspicuous locatter.s en the premises where activities subjected to this procedure are conducted.
it. StacmiPTious 07 FaNDeseG OR OestRvAfloN Contrary to the above, such requirement on 10CFR21.6 and Section 205 of the Er.er, hoorganization Act of 1974 was not posted at the Comanche Peak $ Aft). .I. . I til. ASComentssCED ACTION 'J Post the recutrement in a conspicuous location at Coranche Pe4k SAMLl. W. ASWOutD TO C. W. Gay RESPONSE Out DATg 8-15-81 j ro es comets tso av r e assacusists avoirso ua=4canas=t etease evoei V ACT10ss TAKEN OR TO BE TAKEN A4700Af COesPbf 78088 SAft Sl486ATUA8 TITkt - vs. noseones Acesnests
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/ Appendis DC-8-1 nav.,l.
~* . Page 1 of 5
- - DESIGN REV1tW ARCORD FORM .
La=anche Peak '8 3,8, 2323 Tomas Utilities Services. _ tat. inwssr een Joo no. Ga.IENT Tit.le _9 c:# T . 4 * (., r% C C** Le " 4 I C' ;"A " ,"3"
)~_l SpecLiisation l] DesvLag S Calculatien **
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l Sht. / Of 1 Denian Review !DR) of Calculation Ab /57A . Design Review By: N W. t
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D3 Package Received: DR Package Started: /o//r/d L
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DR Package Retu.med (with comments): Resolved / Package Signed Of f s i ' ^ '/-f /s ;, D7. Comments i-
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- 1. As /r/A Calculation Book '
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- 2. AB /r/,4 As-Built S.A. Checklist ,,, -
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6, the ji i: Comunents/ Questions are on the Attached Sheets Accordina to ' ; Following Format: i-A. Computer Output / Drawings j l, ! B. Calcula, tion S e,* A, I C. As-Euilt Stress Analysis checklist ' D. Design Review Checklist i Miscellaneous I
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. . . . . Appendix DC-8-I Rev. 5 Page 5 of 5 i
DESIGN REVIEW (- . l RECORD FORM.
. . Texas Utilities Services, Inc. Comanche Peak'S.E.S. 2323 -
PROJECT ~"' GsE Joe Ho f' CLIENT
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_ @ Calculation l_l Specification 7, ' k h ." l " S S 0 O 4 $2 weerrw- - m mww- - - oT h i . - COMMENTS ARE AS NOTED ON DOCUMENT SHEETS LISTED SELOW EXCEPT AS - -~~ 5TATED HEREIN ~ l
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. q NOTED APR 211982 ums Desian Review (DR) of Calculation AB (,2 ? Sht. / of 7 Design Review By: H. W. Mentel DR Package Received: 4-[2/ g2 / l r.f s4*r DR Package Started: g[p//52 // Sa /*%. <
DR Package Finished: g /3//E'2- ( *' * # DR Package Returned (with comments) : //2 t/tr'2 W 'A* #'*' . DR Comments Resolved / Package Signed Off: , l Contents of Package Received: p p.5 r (# 8 bt *:'*C#) ### C p 1[* 99ep9sT# v r '
- 1. AB d, E C Calculation Book ' S 9'8 3"7"#*/'I# #~/, ~
- 2. AB # Ar As-Built S. A. Checklist
- 3. AB (,2 C. Computer Output M 3 /4 DTD. 4YZ
- 4. DrawinrJs: L
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HOTED APR 211982 us.ma Design Review (DR) of Calculation AB S26 Sht. 2. Of 7 COMMENTS / QUESTIONS A. Computer Output /Drawingc ,
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NOTED APR 211982 am7a Desian Review (DR) of Calculation AB 62c snt. 4 of 7 COMMENTS /OUESTIONS . B. Calculation Book W CtV 3,//$$' f.5 37 As S$ i l . y n s ++ ~ "m r es a e c. c, o , a ,- ,, ,n, t/ syc7 / ff C 0 .
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Design Review (DR) of Calculation AB I20 Sht. 6 Of 7 COMMm. HTS / QUESTIONS C. As-Built Stress Analysis Checklist J 6 I e 9 9 i b
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l NOTED APR 211982 arma 4 Design Review (DR) of Calculation AB $3 Sht. b Of 7 _ COMMENTS / QUESTIONS i D. Design Review Checklist: (Comment Numbers Correspond to Design Review Checklist Item Numbers) e N 9 S O U y
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NOTED APR 211982 uans . 1 e Design Review (DR) of Calculation AB [ 2 d- Sht. 7 Of / COF.MENTS / QUESTIONS, E. hiscellaneous: .l 1 hj n$*/**' $ b Wil' S- 85 ff, [ [Y$
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GIBBS & HILL Attachment 5 .
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S O I N S O N III' 8 N - Interof fice Memoranif um l l l , 70: DIsTRTsuTTON DATE: 7/16/s2 l pgoM: H.W. Mentel - JOB NO: 2323 SUPJECT: MINIMUM WAM,_VIO11TTON REF. NO-PROCEDURE AB-4 Attached is the latest revision of the TUSI CPSES minimum wall violation procedure. The technical content of the procedure was not changed, only the format and the assigned procedure : number AB-4. Note that the procedure requires that for high energy lines the "K" values should be applied at the actual violation locations; for other systems the "K" valves should , be applied to the maximum stress values regardless of where the violations are located. This portion of the procedure must be adhered to, and the designated design reviewers are requested . l. to assure that this is done. Cooperation by all is appreciated. O i* f t 6 i t t e
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- Gibbs B HIII,ino. Interoffice Memorandum TO: Distribution DATE:
Auoust 12, 1982 , FROM. H. W. Mentel JOB M. 11-2323-001
SUBJECT:
Minimum Wall Violation REF. M - Procedure AB-4 , Approximately a month ago (7/16/82) the latest revision of the minimum wall violation pmanre AB-4 was issued. What is not explicitly , clear in the procedure but what must be done is the use of the "K" values in all the problems. As of this memo all as-built calculations must contain a minimum wall violation (MWV) calcula-tion; for high energy problems considering the actual MWV loca-tion (s) ; for other problems using the maximum ADLPIPE stress - values for the stress, equations regardless of the MWV locations s or even if a MWV exists. A separate calculation will be performed
) to account for those problems already issued to date. Note that this requirement for applying the "K" values across the board was the result of a quality asrurance surveillance report, hence this matter is of high visibility and will be closely reviewed in future ,
audits. HWMe:ecm 2 t-6 r 1 gp l l r_ us,a-7s !'
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