ML20209E313

Forwards Request for Addl Info Re Response to Question 210.15 Concerning Use of Stiff Pipe Clamps.Request Will Be Transmitted to Applicant for Resolution

ML20209E313
Person / Time
Site:	Perry
Issue date:	04/18/1985
From:	Cherny F Office of Nuclear Reactor Regulation
To:	Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML20209C752	List: ML20209C747 ML20209E313 ML20211C446
References
FOIA-86-689 NUDOCS 8504250240
Download: ML20209E313 (2)

Text

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UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION B ,E wash NoToN.o.c.2osss

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APR 181985 l

MEMORANDUM FOR: Br J. Youngblood, Chi.ef r Licensing Branch #1 .

Division of Licensing FROM: Frank Cherny, Acting Chief Mechanical Engineering Branch l Division of Engineering

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION-PERRY NUCLEAR POWER PLANT The Mechanical Engineering Branch has reviewed the applicant's response to Q 210.15 regarding stiff. pipe clamps used at Perry. We find the response does "

not adequately address the staff's concern and requires additional information to complete our review. Attached is a request for additional information to be transmitted to the applicant for resolution. -

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Frank C. Cherny, Acting Chief Mechanical Engineering ~ Branch Division of Engineering

Attachment:

As stated

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210.15

• Your response to Q 210.15 provided in your letter from M. R. Edelman to B. J.

Youngblood dated March 18, 1985 does not contain enough detail to adequately address the staff concerns.

The staff had requested that you provide in detail the technical justification which showed the impact of lower preload torque values of stiff pipe clamps on the required stiffness of the support as assumed in the piping stress analysis. In your response, you stated that, "the stiffness of. a ' stiff' clamp without pretorque is compatible with those of other components in the support assembly."

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(a) Provide the stiffness values of various sizes of stiff clamps both with and without pretorque. ,

(b)'Specifically, for stiff clamps on large bore piping (e.g., 24 inch '

nominal pipe diameter), provide a quantitative comparison of the -

stiffnesses associated with the stiff clamps, other support

- _ . components, and the piping.

(c) Provide the basis for your statement that " lower pre-load torque --

values do not affect required stiffness of the support as assumed in the piping stress analysis." Include the results of any studies, analyses, or t~ests performed which were used to reach your conclusion.

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Ig UNITED STATES

[%je"Ecg g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 5 -[

\...../ September 30, 1986 Docket No. 99900302/86-01 Western Piping and Engineering ATTN: Mr. Kenneth A. Friedman President 1485 Yosemite Avenue San Francisco, California 94124 l

Gentlemen:

This refers to the inspection conducted by R. P. Correia of this office on August 11-12, 1986, of your facility in San Francisco, California and to the discussions of our findings with you and members of your staff at the :onclusion of the inspection.

The purpose of the inspection was to examine Western Piping and Engineering records related to allegations concerning the qualification of personnel performing certification activities for pipe clamps and materials supplied by Western Piping and Engineering. Areas examined during the inspection and our findings are discussed .in the enclosed report. Within these areas, the inspection consisted of an examination of representative records, interviews with personnel, and observations by the inspector.

The Comission's enforcement policy applicable to vendors states that products or services provided for use in nuclear activities are subject to certain requirements designed to ensure that the prooucts or services supplied that could affect safety are of high quality. NRC inspections of vendors are a

' part of the effort of ensuring that licensees fulfill their obligations in determining that their vendors are meeting contractual obligations with regard to applicable requirements including 10 CFR Part 50, Appendix B. .

l t During the inspection it was determined that the certifying engineer of pipe clamps manufactured by Western Piping and Engineering, was not a registered Professional Engineer in the state of California. However, as discussed in i the enclosed report, these clamps met the requirements of the ASME code I specified on purchase specifications for certification, manufacturing and i testing which were to be used in specific United States nuclear plants. In addition, the same results were found in representative records of similar pipe clamps supplied by Western Piping and Engineering for customers procuring clamps for unspecified United States facilities and for foreign nuclear plants.

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Western Piping and Engineering September 30, 1986 The specific findings and references to the pertinent requirements are identified in the enclosed inspection report.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased l to discuss them with you.

Sincerely, cp W

Robert F. Heishman, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement

Enclosures:

1. Appendix A-Inspection Report No. 99900302/86-01

2. Appendix B-Inspection Data Sheets (1 page )

cc w/ enclosures:

Gulf States Utilities Company ATTN: Mr. William J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group Post Office Box 2951 Beaumont, Texas 77704 Cleveland Electric Illuminating Company ATTN: Mr. Murray R. Edelman Vice President, Nuclear Operations Post Office Box 5000 Cleveland, Ohio 44101 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 N. Olive Street, L.B. 81 Dallas, Texas 75201 Philadelphia Electric Company ATTN: Mr. Edward G. Bauer, Jr.

Vice President and General Counsel 2301 Market Street Philadelphia, Pennsylvania 19101

Western Piping and Engineering ,

cc w/ enclosures: (continued)

Public Service Company of New Hampshire ATTN: Mr. Robert J. Harrison President and Chief Executive Officer rest Office Box 330 Manchester, New Hampshire 03105 General Electric Company Nuclear Energy Group ATTN: Mr. J. Fox, Senior Program Manager 175 Curtner Avenue San Jose, California 95125 Paul-Munroe Hydraulics, Inc.

Energy Division ATTN; Mr. John M. Cabe 1701 W. Sequoia Avenue Orange, California 92668

ORGANIZATION: WESTERN PIPING AND ENGINEERING SAN FRANCISCO, CALIFORNIA REPORT INSPECTION INSPECTION DATE: 8/11-12/86 ON-SITE HOURS- 11 NO.: 99900302/86-01 CORRESPONDENCE ADDRESS: Western Piping and Engineering ATTN: Mr. K. A. Friedman, President 1485 Yosemite Avenue San Francisco, California 94124 ORGANIZATIONAL CONTACT: Mr. G. Pappas, Quality Assurance Manager TELEPHONE NUMBER: (4151 822-6464 NUCLEAR INDUSTRY ACTIVITY: Design and engineering of vessels, appurtenances, component supports, piping subassemblies, and material supplier of ferrous forgings, plates and welding materials.

ASSIGNED INSPECTOR: -

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q. P. Correia, Special ProjQts Injpection Section Date (SPIS) r APPROVED BY:

fobn W. Craig, Chief, SPIS, Vende Program Branch ate INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 21, and 10 CFR Part 50, Appendix B. i B. SCOPE: The inspection consisted of an examination of quality assurance and engineering records related to allegations concerning the certifi-cation and manufacturing of pipe clamps supplied by Western Piping and Engineering to various U.S. nuclear plants, a foreign plant, and other U.S. customers.

PLANT SITE APPLICABILITY: River Bend (50-458); Perry (50-440); Comanche Peak (50-445); Peach Bottom (50-277); Seabrook (50-443); and Cofrentes (Spain).

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ORGANIZATION: WESTERN PIPING AND ENGINEERING SAN FRANCISCO, CALIFORNIA REPORT INSPECTION NO.: 99900302/86-01 RESULTS: PAGE 2 of 4 A. VIOLATIONS:

There were no violations identified during this inspection.

B. NONCONFORMANCES:

There were no nonconformances identified during this inspection.

C. UNRESOLVED ITEMS:

No unresolved items were identified during this inspection.

D. STATUS OF PREVIOUS INSPECTION FINDINGS:

There-were no open items from previous inspections.

E. OTHER FINDINGS OR COMMENTS:

The inspection at Western Piping and Engineering (WPE) was performed in response to allegations concerning the certifications of the engineer who performed either the design calculations or the certification of such calculations for clamps manufactured by WPE. The allegation was that the engineer was not a registered Professional Engineer (PE) in the State of California. Also an allegation concerning the use of illicit materials in the clamps for the River Bend Nuclear Plant was addressed.

1. Pipe Clamp Certification Activities The NRC inspector reviewec the WPE files of the engineer who performed design calculations and/or certification of such calculations. The files examined were of a recent WPE QA audit (dated 6/21/86) in which a resume of the engineer was included as-well-as an audit question-naire which followed the guidelines for demonstrating PE qualifica-tions established by Appendix C of the ASME Code,Section III, as required by Section 2 of ANSI /ASME N626.3 " Qualifications and Duties of Personnel Engaged in ASME Boiler and Pressure Vessel Ccde,Section III, Divisions 1 and 2 Certifying Activities." In particular, paragraph 2.2 of ANSI /ASME N626.3 requires, in part, that personnel engaged in ASME certifying activities be a registered Professional Engineer in at least one state of the United States or Province of Canada with specified years of. experience in certifying activities as delineated in paragraphs 2.3 through 2.6 of the aforementioned standard.

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ORGANIZATION: WESTERN PIPING AND ENGINEERING SAN FRANCISCO, CALIFORNIA REPORT INSPECTION N0.: 99900302/86-01 RESULTS: PAGE 3 of 4 Also, maintenance of current knowledge of Code requirements and continued professional development in his or her speciality field through various means is required. The standard also requires in part, that the Owner, Designer, or N-Certificate Holder, as applicable, must review the qualification of the PE at least once every three years to assure that his/her qualifications have been maintained with a continuing record of all such activity included in the qualification records of the PE. The records demonstrated that the engineer identified in the allegation was at the time period in question, and is currently, a registered Professional Engineer in the states of Pennsylvania and New York but not in California.

The allegation specified that the following nuclear power plants have had clamps designed and manufactured by WPE and were certified by personnel not having a PE registration in the state of California:

River Bend, Perry, Peach Bottom, Comanche Peak, Seabrook and Cofrentes (a Spanish nuclear plant). The NRC inspector examined the WPE record files for each of these nuclear pcwer plants except Seabrook. WPE has no record of having designed or manufactured a clamp which was to be used in the Seabrook facility. All purchase orders and technical specifications for these nuclear plants indicated that the clamp assemblies, as a minimum, be designed, in accordance to the require-ments of ASME Boiler and Pressure Vessel Code,Section III, Subsection NF, Class 1. In addition, the record files for purchasers of WPE clamps by the Paul Munroe Hydraulics Company, which did not specify the facility in which they were to be installed, also required the same ASME design certifications.

The file examined during the NRC inspection included all requirements set forth in the ANSI /ASME standard referenced above.

t 10 CFR Part 2, Appendix C, Section VIII states that NRC inspections of vendors are conducted to determine whether they are meeting their contractual obligations to licensees. There were no requirements identified in any of the examined record files which indicated that the design engineer certifying the clamps procured from WPE i be a registered PE in the state of California. This allegatior, was not substantiated and no nonconformances found during this part of

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the inspection, since the certifying engineer did neet the ASME requirements as required by procurement specifications.

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ORGANIZATION: WESTERN PIPING AND ENGINEERING SAN FRANCISCO, CALIFORNIA l REPORT INSPECTION NO.: 99900302/86-01 RESULTS: PAGE 4 of 4 )

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2. _ Materials in Pipe Clamps supplied for River Bend The allegation that pipe clamps supplied for the River Bend Nuclear  :

Power Plant contained improper materials was reviewed. All WPE clamps designed and manufactured for the River Bend facility were purchased by General Electric (GE) (ref: GE P0 No. 205 AM 674). GE require-ments for certifications, data sheets, drawings, codes and standards were examined and found in WPE QA records including GE QA certifica-tion that their requirements were met. All materials, their respec-tive certifications for compliance to P0 specifications, both non-destructive examinations and destructive testing requirements, chemical analyses and results were reviewed. All WPE nonconformance reports (NCR) written during the design and manufacturing of the River Bend clamps were reviewed. Of the twelve total NCR's written, ten were dispositioned with appropriated approvals for acceptance or rejection. Two NCR's were voided upon discovery that the suspected nonconformance was not valid. All nonconformances disposition "use-as-is" were justified by either being within code requirements or included an engineering analyses with results being acceptable without compromising code requirements. Based upon the documents reviewed, pipe clamps supplied by WPE were manufactured in accordance with the utility's purchase specifications.

The allegation was not substantiated and no items of nonconformance were identified.

F. PERSONS CONTACTED K. A. Friedman, President, WPE M. Wright, Project Manager, WPE G. Pappas, Quality Assurance Manager, WPE

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