ML20207P452
| ML20207P452 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1986 |
| From: | Jocelyn Craig, Mcintyre R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207P426 | List: |
| References | |
| REF-QA-99900509 NUDOCS 8701160148 | |
| Download: ML20207P452 (36) | |
Text
{{#Wiki_filter:~ ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION INSPECTION NO.: 99900509/86-01 DATE: 8/25-29/86 ON-SITE HOURS: 180 CORRESPONDENCE ADDRESS: Stone & Webster Engineering Corporation ATTN: Mr. R. B. Kelly, Vice President Quality Assurance Post Office Box 2325 ' Boston, Massachusetts 02I07 ORGANIZATIONAL CONTACT: Mr. F. B. Baldwin, Assistant QA Manager TELEPHONE NUMBER: (617)589-6566 NUCLEAR INDUSTRY ACTIVITY: Major active projects include Beaver Valley Unit 2, River Bend Unit 1, Shoreham, Nine Mile Point Unit 2, Millstone Unit 3, and Comanche Peak Units 1 and 2 (piping & pipe support requalifi-cation). ASSIGNED INSPECTOR: h MC A/ R. P7 McIntyre, Special Projecfs En'spection Section Date E 24 (SPIS) OTHERINSPECTOR(S): R. L. Pettis, SPIS K. C. Leu, SPIS P. J. Prescott, SPIS X. R. Bockman, Consultant APPROVED BY: X't = - ]- R-M ' U. John W. Craig, Chief, Sf'IS, Vendor Program Branch Date INSPECTION BASES AND SCC E: A. BASES: Stone & Webster Engineering Corporation (SWEC) Topical Report No. SWSQAP 1-74A and 10 CFR Part 50, Appendix B. B. SCOPE: The purpose of this inspection was to review the implementation of Stone & Webster's QA program concerning activities relating to the Design Requalification of Ming and pipe supports on Comanche Peak Units 1 and 2. Specificalij, design control, procurement document control, indoctrination and training, and audits were reviewed. PLANT SITE APPLICABILITY: Comanche Peak 1 & 2 (50-445/446). 8701160148 870102 TSR GA999 EECSWE 99900509 PDR
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 2 of le BACKGROUND ) Ger.eral On March 12, 1984, the U.S. Nuclear Regulatory Comission's (NRC) Executive Director for Operations established a program to ensure that technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities would be addressed in a coordinated and integrated manner by the NRC staff. As a means of executing its assigned responsibilities, the NRC formed a Technical Review Team (TRT). The TRT initiated a series of onsite inspections and evaluations in July 1984, and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report (NUREG-0797, " Safety Evaluation Report Related to the Operation of the CPSES, Units 1 and 2," Supplements 7-11). In response to the concerns and issues identified by the TRT, Texas Utilities Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) for the purpose of addressing various construction and design . issues. The CPRT has been charged with responding to and resolving the issues raised by TRT~ concerns as well as concerns from sources externaT*to TUEC. 'A CPRT action ple . describing reanalysis on a sampling basis as wellcas a ecmplete reanalysis of affected designs are included as a portion of the (piping supports) Discipline Specific Action Plan (DSAP). This action plan initiative was developed to resolve the large number of External Source Issues (ESI) associated with these design areas and have resulted in a significant level of design reanalysis. TUEC has retained contractors not involved with the original design to perform the requalification program for piping and pipe supports (Stone & Webster) and cable tray / conduit supports (Ebasco Services, Inc. and Impell). Piping and Pipe Supports A number of issues have been raised in the area of piping analysis and pipe support design. As a result, TUEC has initiated a piping and pipe support requalification program which has resulted in a significant level of reanalysis and reevaluation of the CPSES piping and pipe support designs. SWEC, under contract to TUEC, will perform this requalification program under the direction of the CPSES project personnel. In addition, the TERA Corporation (TERA), also under contract to TUEC, will review this effort to provide assurance that the objectives of the Design Adequacy Program in the piping and pipe support area are being achieved. The scope of the SWEC program for the requalification of piping and pipe supports, as described in Supplement 13 to the Safety Evaluation Report related to the operation of Comanche Peak Stean Electric Station, Units 1 and 2 (NUREG-0797) includes:
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l ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS l INSPECTION i REPORT NO.: 99900509/86-01 RESULTS: PAGE 3 of 18 l 100 percent of all ASME Code Class 2 and 3 piping larger than 2 inches (large bore), excluding portions within the boundary i of Westinghouse Class 1 auxiliary branch line stress problems 100 percent of all ASME Code Class 1, 2, and 3 large bore pipe supports small bore pi ing and pipe supports on a sampling basis (ASME Class 2 and 3 all non-ASME piping and pipe supports within ASME Code Class 2 and 31arge bore stress analysis problem boundary all non-ASME supports within the ASME Code Class 1 stress problems all ASME Class 2 and 3 small bore piping subjected to significant fluid transients (stress and supports) all high energy ASME Class 2 and 3 small bore piping (stress and supports) hot functional and vibration testing procedures and technical assistance site construction support activities related to piping and pipe supports The SWEC act'.an plan consists of the following elements: (1) development of CPSES pipe stress and pipe support design criteria (2) verification of existing as-built information, performed a walkdown of piping for: support location valve location support function valve and support orientation (3) review and verification of system design ir.put, seismic acceleration, and fluid transients
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 4 of 18 (4) verification of existing pipe support design documents 3 (5) resolution of special technical concerns (6) reanalysis of piping systems end reevaluation of pipe support designs (7) review all existing reports, etc. to identify and develop SWEC resolution to all previous identified technical issues, questions, concerns (Generic Technical Issues Report) (8) identify pipe break / crack postulation requirements. A. VIOLATIONS: None. B. NONCONFORMANCES:
- 1. Contrary to 10 CFR Part 50, Appendix B, Criterion V and the SWEC Standard Nuclear QA program manual, Section 5, paragraph 2.1.1, SWEC had not written and implemented instructions and procedures for the transfer of design information (from the SWEC New York office to the Comanche Peak site and between SWEC offices),
utilized in the final resolution of safety related pipe support design packages. (86-01-01)
- 2. Contrary to 10 CFR Part 50, Appendix B, Criterion V and the SWEC Standard Nuclear QA program manual, Section 5, paragraph 2.1.1, SWEC had not written and implemented instructions and procedures which describe how proposed design modifications are documented i and reviewed by the applicable Project Engineers to determine if they require review by the Option Review Committee. (86-01-02) l I
! C. UNRESOLVED ITEMS:
- 1. The results of SWEC's evaluation of computer code error reports submitted to them by Power Computing Company were not reviewed during this inspection. These error notices were for the computer code P-DELTA STRUDL. These evaluations will be reviewed during a future inspection at the SWEC Boston office. (86-01-03)
i l ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS l REPORT INSPECTION N0.: 99900509/86-01 RESULTS: PAGE 5 of 18
- 2. The NRC inspectors were unable to review the results of SWEC's evaluation of computer code error reports submitted to them by the Impell Corporation. Error reports were unique to the QUICKPIPE
.) system and used on the River Bend Project. This evaluation will be reviewed during a future inspection at the SWEC Boston office. (86-01-04) D. STATUS OF PREVIOUS INSPECTION FINDINGS: Not reviewed during this inspection. E. OTHER FINDINGS OR COMMENTS:
- 1. Pipe Stress Requalification During this inspection,16 packages of ASME Class 2 and 3 pipe stress design calculations were selected for detailed review. These packages represented a spectrum of sample packages from the following systems at Comanche Peak.
- Containment Spray System
- Chemical and Volume Control System Component Cooling System
- Station Service Water System Safety Injection System
- Demineralized Water System
- Auxiliary Feedwater System
- Diesel Generator Fuel Oil System
- Chilled Water System
- Water Processing Liquid System
- Vent and Drain Systems Compressed Air (Instrumentation) System The review included verification of compliance to " Comanche Peak Project Procedures" (CPPP) 6, 7 and 9, " Comanche Peak Project Memoranda" (C.PM) and other applicable codes and criteria. Also reviewed were pipe stress dynamic analysis rodeling, NUPIPE-SW program input and output, fluid transient loads, and load combina-tions for various plant operating conditions. The associated allowable stress limits were reviewed for compliance with design bases and criteria.
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION N0.: 99900509/86-01 RESULTS: PAGE 6 of 18 Special consideration, such.as mass point spacing, valve modeling, stress intensification factor (SIF), pipe thinning and weld g shrinkage were examined among other items for technical complete-ness and performance. In addition, field correspondence and drawings, interfacing documents between stress, support and power groups were reviewed with respect to document control compliance. Pipe Stress Analysis Review The NUPIPE-SW computer program was utilized by SWEC to perform linear elastic analysis of three dimensional piping systems subjected to thermal stctic and dynamic loads. The use of a cutoff frequency at 50 Hz was included in the program so that the contribution from higher modes was reflected in the piping analysis. The inspector selected 16 stress packages from 12 systems for review and assessment of technical adequacy. Each package contained a "Dctailed Pipe Stress Analysis Check-list" (Attachment 9-9, CPPP-6, Revision 2) which referenced general items such as mass point spacing and lumping, SIF, vent / drain connections, component configuration, etc. for inclusion in the analysis. The general package format and contents were in conformance to form " Pipe Stress Analysis Calculation Contents" (Attachment 9-11, CPPP-6, Revision 2) with regard to objectives, assumptions, loads, conclusions, and sumary of results, etc. The methodo-gies and calculations were found to be satisfactory. Three design packages reviewed are discussed below: (1) Calculation No. 00-1-165C: Analysis of buried pipe was in accordance with " Procedure for ASME Section III Class 2 and 3 Buried Piping" in Attachment 3-9 of CPPP-7, Rev. 2, ! where closely spaced lateral restraints were provided to sinulate the stiffness of soil restraining the pipe and coded accordingly in the computer input. (2) Calculation No. CC-1-061A: This calculation reanalyzed j existirg trapeze supports and snubbers and determired that some were either unnecessary or unstable. Corrections were made to install stable supports and maintain their intended functions. The supports were located at various nodal points. l
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ORGANIZATION: STONE & WEBSTER ENGINEERING CORPODATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 7 of 18 In addition, the consideration of " break and crack exclu-sion," and " pipe wall thinning evaluation" were reviewed by g the inspector and fourd to be in conformance to requirements of Section 3.8 and Attachment 3-14 of CPPP-7. (3) Calculation No. SI-1-071B: The design information contained in this calculation was reviewed by the NRC inrpector to verify the following items had been considered and included in the reanalysis:
- Detailed computer input coding for trurMc,n and drain / vent Fluid transient consideration
- Code case N-411 application Based on the review of stress analysis packages, and the inter-views with the SWEC engineering staff, the inspection concluded that the design criteria, analytical methodologies and proce-dures for CPSES Unit 1 pipe stress analyses met the requirements of the Comanche Peak Project Procedures and Project Memoranda.
However, the inspector identified two items as observations:
'(1) In reviewing the interface control between pipe stress and pipe support groups, the inspector found that 11 pipe stress calculations contained a memorandum transmittino the pipe loads to the support group for design use, while five calculations did not include the memorardum. Although this memorandum is not required by SWEC procedures, the five calculations did make it to the support group, and the missing memorandums were produced from other files later on.
It appears that better document control is needed in order to provide consistency and quality in documpnts. (2) In verifying the Options Review Committee's (ORC) review process at SWEC, the inspector found a memorandum (page 2 of Attachment #9, Cal. No. WP-1-N047) from the responsible engineer to the project engineer's office ir reference to a Westinghouse valve overstress. The inspector was informed that the jnb was still ongoing.
OP.GANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 8 of 18 Since the memorandums were not dated when issued and received, the inspector could not determine when the 3 action was initiated or how long it had been an open item. Durirg discussions with SWEC project engineer and QA, the inspector was told that SWEC procedures do not require the memorandum to be dated. This is a poor practice and does not constitute standard QA document control. No violations or nonconformances were identified during this part of the inspection.
- 2. Pipe Support Reoualification
- a. Review of Pipe Support Design Criteria and Procedures SWEC CPPP-6, 7, 9, and 11 were reviewed as well as the modifi-cations / additions contained in the active Project Memoranda.
Procedure CPPP-7, " Design Criteria for Pipe Stress and Pipe Support," contains the reanalysis project design criteria and analysis nethods for plant piping supports. Section 5 indicates that the finite element computer program ANSYS is used for the analysis of pipe support base plates in conjunction with the BAP and other SWEC computer programs. SWEC stated that ANSYS, which presently is not listed as an acceptable computer program for use on Comanche Peak, would be identified on the list of acceptable computer programs used in the Comanche Peak re-evalu-ation program.
- b. Review of Pipe Support Design Calculations Pipe support calculations were reviewed for problems desianated 1.15 B (1-1/2" safety injection system piping) and 1.38 B (3" and smaller reactor containment system piping.) These are safety related ASME Code Class I lines which attach to the reactor coolant system piping. These support design calcula-tions had been completed and reviewed by SWEC. However, other design problems were still open and the calculations had not been certified by a Professional Engineer (PE), as required for Class I supports.
Except for snubbers, tne supports reviewed were welded frames of tubular steel. A typical support would consist of a box or open frame surrounding or partially surrounding the pipe. This would i i
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION N0.: 99900509/86-01 RESULTS: PAGE 9 of 18 be supported by a cantilever beam attached to a baseplate. The calculations for the support were largely computerized. Struc-
) tural analysis including ASME code stress evaluation was done with the STRUDL computer program, required fillet weld dimen-sions were calculated using the SANDUL computer program and the adequacy of baseplate and anchor bolts was evaluated using the BAP computer program. Hand calculations were required for conditions such as the sizing of the welds which were not fillet welds.
Considerable effort was expended in relating analytical models and calculation results to the support drawings. STRUDL computer program input and output listings for structural analysis and SANDUL computer program output for weld design were checked. The sizing of anchor bolts and baseplates using the computer program BAP were also reviewed. Stiffness calculations were . reviewed, including one for support No. SI-1-199-711-C41K. The structure, weld, and baseplate calculation report was reviewed in detail for support No. RC-1-072-C41R. Complete listings of the computer program input were included in the calculations, as well as specific portions of computer output. A calculation checklist was included with each support calculation. The cal- ! culations met the requirements of the applicable SWEC procedures. l l No violations or nonconformances were identified during this l part of the inspection.
- 3. Audits
- a. External to SWEC f The NRC inspector reviewed seven (7) Comanche Peak audit reports perforned by Texas Utilities Generating Company (TUGCO) on the following SWEC offices:
i Audit No. Office Dates TSWEC-1 site 10/21-25,1985 11/4-6, 1985 TSWEC-2 New York TSWEC-3 Boston 12/3-5,1985 TSWEC-4 Cherry Hill 1/21-24, 1986 TSWEC-5 site 4/14-18,1986 l TSWEC-6 Toronto 4/23-24, 1986 TSWEC-7 Houston 5/15-16, 1986
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 10 of 18 The purpose of these TUGC0 audits was to assess the adequacy of SWEC's quality program for Pipe Stress and Pipe Support g Qualification and Reverification of design analysis functions ' being performed for CPSES, Unit 2 activities. Audit scopes included verifications of the SWEC quality program for compliance to CPSES requirements and adherence to TUGC0 procurement documents, with emphasis placed on program and technical assessment. SWEC's response and corrective actions, in most cases, adequately addressed the issues raised by TUGCO. The majority of the findings and observations centered around calculation incon-sistencies, computer modeling errors, evaluation of computer error notices for NUPIPE and BASEPLATE II, unconservative weld calculations performed by computer program SANDUL not matching hand calculations performed using formulas in CPPP-7, inappropri-ate and unconservative use of stress intensification factors (SIF) used in piping stress analysis, valve modeling inconsisten-cies, mass point spacing used in dynamic piping analysis, and incorrect loading assumptions made in conjunction with integral attachment analyses. SWEC's responses to these items were adequate and resulted in documented evidence of increased technical training in those areas in which weaknesses were identified by TUGCO.
- b. Internal to SWEC The inspector also reviewed 12 internal audits performed by
- SWEC's Engineering Assurance Audit Division (EA). These audits
! are identified and governed by SWEC Engineering Assurance Procedure (EAP) 18.1, Revision 5, dated April 7,1982, and cover audit activities of SWEC Engineering Department activities in Boston and New York. The audits reviewed were as follows: Location Dates site 7/31-8/1,1985 New York 10/6-11, 1985 l Cherry Hill 10/28-11/8, 1985 Houston 12/9-2/13, 1986 l 12/17-19, 1985 l Toronto Boston 12/16-2/28, 1986 site 12/16-2/13, 1986
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ORGANIZATION: STONE & WEBSTER ENGINEERING COPPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 11 cf 18 Location Dates Boston 2/10-3/7, 1986
) 3/24-28, 1986 New York Houston 4/28-5/2, 1986 site 5/19-23, 1986 Toronto 6/2-6, 1986 In general, audit findings and observations resembled that of the externally performed TUGC0 audits in that calculation discrepancies and inconsistencies were identified.
SWEC responses to these items were timely and in compliance with EAP 18.1.
- c. Engineering Services Supplier Audits The NRC inspectors reviewed the audit / survey reports of two suppliers of computer services, Power Computing Company (PCC) formerly known as UCCEL, and the Atlanta office of Impell Corporation.
(1) PCC - Dallas, Texas A review of this September 6, 1985 audit. demonstrated several weaknesses in the area of verification / validation of the computer code P-Delta STRUDL. . This computer code is provided to SWEC by PCC through its software supplier P-Delta Inc., and is used primarily in the design verification of safety-related pipe supports and general structural applications. f The SWEC audit report identified examples of technical I discrepancies noted during a review of test records for P-Delta STRUDL among which were results that differed in the range of 200-600 percent for support reaction forces l used in transient analysis. PCC committed to complete
- its qualification testing and incorporate it into the
! 0985 release of P-Delta STRUDL. l
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 12 of 18 The inspector also reviewed SWEC's receipt of error reports supplied to then by PCC, as required by contract. To date g only two error report letters have been received by SWEC which contained five individual error notices as follows: Date of Letter Error Date Error # Error Desc. 5/12/86 5/10/80 B 3.0-402 " Torsion" para-meter ignored during AISC code check 8/14/86 1/20/86 B 3.0-328 Section proper-ties of Tubing and Angle shapes corrected. Slight differences observed in both Static and Dynamic analysis results. 5/15/86 N/A B 3.0-503 Incorrect eigen-vectors and parti-cipation factors for multiple dynamic analyses in same run. 8/8/86 N/A B 3.0-533 Removed message from stiffness matrix command. A review of SWEC's evaluation of these error reports was not performed since documentation is kept at SWEC's Boston offices. In addition, SWEC representatives stated that P-Delta STRUDL had not been used nor any other UCCEL/PCC programs on Conanche Peak. However, the TUGCO-PSE STRUDL group on site may have used P-Delta STRUDL for inputs to SWEC modifications (i.e., load distribution on Richmond Inserts). Dae to the unavailability of the SWEC evalua-tion of these error reports in New York, Unresolved Item 86-01-03 was identified in this area of the inspection. i
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 13 of 18 A related item concerns the manner in which error notices are being distributed to customers of PCC. During an earlier NRC inspection (conducted at the New York office of Ebasco Services August 11-15,1986) several other error report notices received by Ebasco were identified. Mcwever none of these had been received by SWEC. Similarly, SWEC has received notices which Ebasco had not received for the same version of P-Delta STRUDL, version 0385. (2) Impell Corporation (Atlanta office) A May 3, 1984 SWEC EA audit of Impell was performed to evaluate Impell's compliance with the requirements of the QA provisions in SWEC Purchase Order No. E-CH-3245, and to evaluate the overall implementation of the Impell QA program. Several findings identified that Impell was sending error notices for the computer program QUICKPIPE directly to User Manual holders and not to the SWEC Computer Library in Boston, as required in the SWEC purchase order. "Impell's response, as part of the corrective action,.was to transmit to the SWEC Computer Library, on May.15, 1984, all outstand-ing error notices for QUICKPIPE in addition to one copy of all previous updates and revisions used by SWEC for the River Bend Project. QUICKPIPE (similar to NUPIPE) had been used as an optimization program for A" and smaller piping analysis on River Bend but was subsequently replaced by NUPIPE. The results of the evaluation perforned by SWEC were not reviewed, Unresolved Item (86-01-04) was identified in this area of the inspection.
- 4. Design Interface Control
- a. SWEC New York Communication ~with Comanche Peak The NRC inspectors reviewed the process in which design infor-l mation, utilized in the final resolution of a safety related pipe support design package, was being transferred from the SWEC New York office to the pipe support design group at the Comanche Peak site.
I In an interview with SWEC personnel, it was stated, that when additional information is required from the site for the resolution of a final design package, th.e requests for the
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 14 of 18 design information are first transmitted through the SWEC New York office for engineering review and approval. The request is then sent from the New York office to the site using one of 3 three forms, depending on the type of information requested, and the engineering group requesting the information (i.e., stress analysis group, pipe support design group). The NRC inspectors reviewed the three forms utilized by SWEC for the transfer process. The three forms reviewed were: pipe support modifi-cation form (PSM), pipe support drawing change notice (PSC) and stress aralysis request for action fonn (SA). A review of the transfer process was performed by the NRC inspectors and there were no significant inadequacies found in the system. When applicable instructions and procedures for this process were requested by the NRC inspectors, SWEC informed the inspectors that there were no procedures written for this process as part of the Comanche Peak effort. SWEC committed to develop instructions and/or procedures which would outline the transfer of design information, from the SWEC New York office to the Comanche Peak site, including the applicable forms utilized in the process. Nonconformance 86-01-01 was identified as a result of this review,
- b. SWEC Internal Communications The NRC inspector examined the review, transfer and documenta-tion process for safety related pipe support modifications for the Comanche Peak effort, within SWEC.
The document used by the various SWEC engineering departments for this process is the modification report (PM) This pipedocument stress and supports is used proposed to communicate proposed modifications between the various engineering depart-ments internally within the SWEC New York office and for external communications between the SWEC New York office and the other SWEC offices involved in the Comanche Peak effort; (Cherry Hill, Houston, Toronto, and Boston offices).
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION N0.: 99900509/86-01 RESULTS: PAGE 15 of 18 The PM can be initiated by a responsible engineer at any one of the SWEC offices involved in the Comanche Peak effort. The PM and all applicable information (e.g., excerpts from calcula-tion (s), drawing (s)) is then forwarded to the applicable project engineer, who evaluates the proposed modificaticn against the criteria for submittal to the Option Review Committee (0RC). The ORC is responsible for convening meetings at the request of the project engineer to review recommendations of signifi-cant hardware changes, assess the impact of those changes on other disciplines and recommend viable alternatives. During the review of this process the NRC inspectors requested the instructions and procedures which reference the PM docunent or designates the individual responsible for performing the engineering reviews. SWEC stated that there had been no formal procedure written as part of the Comanche Peak effort. However, the NRC inspectors were informed that a draft project memorandum was in process, and would be issued as a supplement to the formal Comanche Peak procedures, once it had received final concurrence from the applicable SWEC cagineering departments. Nonconformance item 86-01-02 was identified as a result of these findings.
- 5. Procurement Control The NRC inspectors reviewed two procurement packages for the contracting of engineering services for the Comanche Peak effort.
EAP 4.1, " Procurement System," is the procedure which establishes the process used to procure power plant equipment, material and services including engineering services. EAP 4.15, " Preparation and Control of Engineering Service Scopes of Work (ESS0W)," describes the procedure for preparation, review, approval, change and control of ESS0W for procurement of engineering services. An ESS0W is a procurement document used to describe, in detail, an engineering service to be performed by an engineering service supplier. This ESS0W accompanies the purchase order to the service supplier, and includes the overall scope of work as well as the applicable QA requirements per 10 CFR Part 50, Appendix B as well as the requirements of 10 CFR Part 21.
ORGANIZATION: STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 16 of 18 SWEC has issued only two (2) purchase orders to date for services on the Comanche Peak effort. The first purchase order was issued to i Stone & Webster Canada Ltd. for engineering and support services for pipe support and pipe stress on Comanche Peak. The second purchase wder was issued to UCCELL/ Power Computing (PCC) for computer services, although no computer services have been used to date through PCC (refer to number 3.c of Section E). The inspector reviewed the procurement packages including the purchase order and the ESS0W for both suppliers. The original purchase order with SWEC Canada Ltd. did not include an ESS0W or any provisions for QA requirements and compliance to the 10 CFR Part 21. Change 1 to the purchase order, written three months later, corrected this item and included the documentation which was originally missing. This deficiency was also identified by TUGC0 in an audit performed in November 1985. The ESS0W, included in Change 1 to the purchase order, referenced a procedure for calculation control which was not applicable to the Comanche Peak project, EMTP 8.26 was referenced instead of EAP 5.3. SWEC stated they were going to issue a revision to the ESS0W which corrected the error. The purchase order and ESS0W to UCCEC/PCC includes the appropriate QA requirements as well as instructions for the receipt of computer program error reports. The procurement package net the requirements of the applicable procedures. No violat'ons or nonconformances were identified during this part of the inspection.
- 6. Indoctrination and Training The NRC inspector reviewed EAP 2.4, " Indoctrination, Continuing
! Education and Certification Requirements." This precedure contains l the requirements for indoctrination, and continuing education and training in the use of procedures and systems developed to govern and support nuclear projects such as Comanche Peak. The inspector reviewed the Engineering Department Training Matrix for the Engineering Mechanics Division. This matrix lists the indoctrination and continuing education requirements for personnel performing quality related or quality assurance engineering functions. l l
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ORGANIZATION: STONE & WEBSTEP, ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 17 ef 18 SWEC has developed Comanche Peak Project Procedures (CPPP), which describe requirements of many activities performed as part of the g SWEC Comanche Peak effort. CPPP-6, 7, 9 are the procedures for requalification activities for ASME III Class 2/3 Pipe Stress Analysis and Pipe Support Verification. This includes the analysis ard Design Criteria. These CPPPs are used in conjunction with applicable (EDPP) and EAP's, Engineering Quality Standarc's (Department Policies and Procedures QS). The inspector reviewed the training records of five engineers performing pipe stress analysis and five engineers performing pipe support requalification to verify they had received the required engineering division training as well as the required project specific training for the applicable CPPP's. This was verified through the review of attendance forms and the Computerized Training Records System, which lists SWEC employees by office location and all formal QA, design, and project specific training they have received up to the computer printout date in the records systems. The inspector also reviewed the training outline for CPPP-6, 7, and 9. Training records for the ten employees reviewed indicated that they had received the training required for nuclear engineering activities and the Comanche Peak specific training. No violations or nonconformances were identified during this part of the inspection.
- 7. Temperature Effects on ASME III NF Code Check Equations - USNRC Regulatory Guide 1.124 In the review of SWEC's pipe support design efforts, the NRC inspector reviewed paragraph 2.3 of Comanche Peak Procedure CPPP-7, Revision 2, dated April 25,1986, " Applicable USNRC l
Regulatory Guides," and the CPSES/FSAR page 1A(N)-64, Item 2 , which references the overall commitment to the use of this Regulatory Guide. l Regulatory Guide, Section B.5, page 1.124-3, cautions the designer to recognize that ASME III, Appendix XVII compression and compression due to bending equatinns were derived based upon mechanical property constants of steel, Young's Modulus (E) and Yield Strength (YS), at room temeprature (i.e., 70 F). Further, page 1/12a-4 of Section C.3b
ORGANIZATION: STONE 8 WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS REPORT INSPECTION NO.: 99900509/86-01 RESULTS: PAGE 18 of 18 that materials with values of E at working tenperatures substantially different from 29,000 ksi, these constants should be rederived with the appropriate value of E unless the conservatism of using these constants as specified can be demonstrated. The NRC inspectors reviewed SWEC's primary computer code for pipe support design and structural analysis, STRUDL-SW, in an attempt to verify what treatment was afforded by SWEC to aodress these concerns expressed in Regulatory Guide 1.124. Discussions with SWEC personnel in both the New York and Boston offices indicated no special treatment is given to rederive the code equation constants as written into the STRUDL-SW program source. However, to account for the overall temperature effect, it is SWEC's practice to adjust the input parameters of Sy and E accordingly where it explicitly occurs in the NF code check equations. Additional information provided the NRC by SWEC after the inspection indicated that at a temperature of 300 F, which is slightly higher than the Comanche Peak containment LOCA temperature, the 197a edition of ASME III lists an E value for SA-36 steel of 27,400 ksi as compared to 27,900 ksi at an ambient tenperature of 70 F. This represents a total variation from the nominal value of 5.5% and only a 1.7% difference from ambient. It was also noted by SWEC that more recent editions of ASME III provide higher values of E (29,500 ksi and 28,300 ksi at 70 F and 300 F, respective!y', thereby reducing the previous 5.5% variation to that of less than 2.5%. SWEC further concluded that they believe their current practice, as outlined, is technically adeouate and no modifications are required to the code check equations, other than that described herein, due to the slight variation of E over the normal design temperature range of pipe supports included under the SWEC scope of work for the CPSES. No violations or nonconformances were identified during this part of the inspection.
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