ML17277A558

Rept of Audit 2 of Wppss Plant Verification Program for Wppss Unit 2.

ML17277A558
Person / Time
Site:	Columbia
Issue date:	02/15/1983
From:	Laney R, Roddis L, Sheets H TECHNICAL AUDIT ASSOCIATES, INC.
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REPORT OF AUDXT NO. 2 of the WASHINGTON PUBLIC POWER SUPPLY SYSTEM'S PLANT VERXFXCATION PROGRAM FOR WNP-2 performed by TECHNXCAL AUDXT ASSOCIATES, INC.

AT RICHLAND, WASHINGTON ON JANUARY 26-28, .-.1983.<< <<

February 15, 1983 APPROVED:

R. V ey L. H. Roddis, Jr.

8304220466 8304i5 PDR ADOCK 05000397 t PDR

CONTENTS Pacae I Summary of Findings and Observations II Introduction III Design Reverification Program A. Findings Review Committee'FRC)

B. Discussions with Design Reverification Management 7'l C; Requirements Reverification Report D. Design Reverification Logic and System Interactions 12 E. Discussions with the RFW Team, 13 F.'iscussions. with the RHR Team 14 G.'iscussions with Burns 6 Roe on the -Pipe Stress/Nozzle Problem IV Construction Quality Verification Program 16 A; Review of QVP Status with Program Management 16 B. ATI Review of Fishbach/Lord Supports 18 C. Skewed Weld Evaluation 19 V Effectiveness of S.S. Management in Quality Assurance Problems 20 ATTACHMENTS

, A. Audit Agenda B. TAA's Pre-Audit Questions C. Design Reverification Schedule D~ Reverification Program Substitutions (Engineering Mechanics)

E. Response to TAA December 9, 1982 Letter F. WNP-2 Fire Hazard Evaluation, Design Reverification Plan TECHNICAL AUDIT ASSOCIATES. INC.

1 WNP-2 Reverification Program',

Pipe Break,and Missiles Review Design Reverification of Fishbach/Lord By Associated Technologies, Inc.

Skewed Weld Evaluation Contract 215 Reverification Report Outline (Draft)

Documents Reviewed by TAA Before Audit QVP/QAP Pie Chart Biographical Information on TAA Audit Team TECHNICAL AUDIT ASSOCIATES. INC.

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~ti jc4 I. Summar of Findin s and Observations*

The findings from this audit are stated below, together with a page number reference to the text.

The Panel believes that the S.S. should take additional steps to inform reverification team members of the importance of deciding and indicating on the report whether a Potential Finding is or is not a reportable E

event. (page 7) 'I Findin No. 10 I

TAA does not agree with the present plan for the RFW system in which no piping or support/restraints are being reverified. We believe that a sample should be included, using design level information, if necessary, to avoid the schedule delay which would result from awaiting as-built verification. (page 10)

• Findings No. 1 through 8 and Observations No. 1 through 3 appear in TAA's Audit Report dated January 10, 1983.

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Find in No. 11 The Requirements Reverification Report requires additional review and improvement, to ensure'hat the relationship between commitments and requirements are more thoroughly analyzed and more clearly presented. (page ll)

Findin No. 12 The .RFW design reverification team is behind .schedule and requires strengthening in order to complete-on-schedule. (page 14)

Findin No. 13 We believe that the pipe stress/nozzle problem should be investigated by the S.S. to determine the root causes of it, and whether the root causes have any implications for other S.S. work done by the architect-engineer. (page 15)

The Observations from this audit follow, together with a page reference to the text.,

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gi Observation No. 4 Nhile recognizing that additional commitments will continue to be issued, the Panel believes that the, Requirements Reverification Report contains enough comparisons to provide an adequate assessment of whether commitments are expressed in design documents. (page l2)

Observation No:. 5 For the purpose of deciding whether or not to extend the sample'size, -tray and conduit supports:which do not conform to design plans, but are found acceptable as is, should be analyzed. It is .important to determine if the same deviations might be unacceptable in other tray and conduit support situations. If so, such "acceptable as is" items should be counted as deviations for sample size analysis. (page 19)

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AUDIT REPORT II Introduction The Washington Public Power Supply System (Supply System or S.S.) retained Technical Audit Associates, Inc. (TAA) to, first, review and comment on the Supply System's .Plant Verification Program Plan (PVP), and, second, to audit its implementation.. TAA's review of. the.-.PVP.was completed and our.

final report on the plan submitted on August, 6, 1982.

=TAA is now engaged in auditing the Supply System's implementation of the PVP, an activity which will continue until readiness for fuel load in August, 1983. We have been asked to give principal attention to those portions dealing with the reverification of design, the Quality Verification Program (QVP), which addresses the c(uality of construction before July, 1981, and the effectiveness of management actions to resolve quality problems arising since July, 1981. The ultimate objective of this continuing audit is to enable TAA, at the conclusion of the PVP and before fuel load, to state a knowledgeable opinion on the adequacy of implementation of the PVP and the extent to which it provides substantive confirmation that WNP-2's design and construction comply with applicable Regulatory and Safety Analysis Report commitments.

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This is the report of the second on-site audit, conducted on January 26, 27 and 28, 1983. The first on-site audit was reported in TAA report dated January 10, 1983. As in the previous audit the TAA panel selected and reviewed a number of pertinent documents, listed in attachment K. TAA prepared and forwarded to'he Supply System various questions, arising from the 'document review and from the previous audit, which provided a focus for this audit. .These questions appear as attachment B.

The audit agenda=(attachment~ A) shows.-the .topics covered- in.:

the audit. All TAA Panel members and consultants were present.

In the preceding Summary and throughout this report we have used either a Finding or an Observation to present our conclusions and recommendations. A Finding is a conclusion or recommendation which, in our opinion, is sufficiently important to rea~ire a fo'rmal response from the Supply System, leading either to a mutually satisfactory disposition or to continued dialogue. Each Finding should be formally resolved.

An Observation is a conclusion or recommendation of lesser importance for which no formal resolution is expected.

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III Desi n Reverification Pro ram TAA reviewed the status of the requirements and design reverification program as shown on agenda items numbers 1 through 10 (attachment A). Since the TAA panel reviewed the High Pressure Core Spray System (HPCS) in November, this audit concentrated on the Reactor Feedwater System (RFW) and Residual Heat undiscussed Removal System (RHR) systems. The following TAA questions were during these sessions: 3; 5;.6; 7; Sa," b; c, d; 9a, .b, c, d, e, f; and 10a, b, c, d, e, g, h (attachment B);.

Except as appears in the following discussion, satisfactory answers were received.

1 A. Findin s Review Committee (FRC)

The Panel discussed with Chairman Newell S. Porter, C.

H. McGilton and Ronald J. Barbee, members, and Doug Timmins, secretary, of the FRC the results of their first meeting and potential findings reviews which had been held on Wednesday, January 19, 1983, with TAA Consultant Charles Q. Miller present as an observer. Mr. Porter summarized the professional credentials of each committee member and provided copies of the memoranda by which each member stated his compliance with the S.S.'s independence criteria.

Potential Findings Reports (PFR) HPCS-l, -2, -3, -5 and -6 and RHR"1, -2, -3, -4, -5, -6 and -7 were discussed TECHNICAL AUDIT ASSOCIATES. INC.

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individually with respect to the comittee's depth of review and actions taken.

The 'Panel noted that three of the PFR's did not indicate, as required by the S.S.'s FRC procedure, whether the originating engineers believed that the potential findings were reportable events. While agreeing that they should have done so, S.S. spokesmen pointed out that another, independent routine exists for the same purpose. We later learned that none of 'the-=three is; in fact; reportable;",.

Findin No.'*-

The Panel believes that the S.S. should take addition-al steps to inform reverification team members of the importance of deciding and indicating on the report whether a Potential Finding is or is not a reportable event.

B. Discussions with Desi n Reverification Mana ement The TAA Panel discussed program status, scope and schedule (agen'da item No. 3) with J. R. Honekamp, D. W. Porter, D. L. Whitcomb and G. L. Gelhaus; at a later time we discussed related questions with John Yatabe. Dave Whitcomb told the Panel that the initial three design reverification plans which

• . Findings No. 1 through 8 are in TAA's Audit Report dated Janauary 10, 1983.

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the Panel had received are being revised in order to incorporate clarifications, corrections, and scope changes.

Using a bar chart (attachment C), he explained that the Engineering Mechanics reverification for HPCS and RHR are pacing the program.

The Panel inquired whether team engineers have a ready way to raise questions which come to their minds during walk-downs or at other times, but which are not on their checklists and which may not be directly related- to their. area=~

of interest. We were told that -this is encouraged, and that cross-team discipline meetings will be hold to make C

it convenient to raise questions. However, such questions must be subordinated to accomplishing each engineer's main tasks.

In answer to TAA's question No. 9(a) (attachment B),

S. S. spokesmen advised that, due to Burns 6 Roe's late discovery of a piping-nozzle mismatch at the main feed pump, final design stress confirmation, based on as-built drawings, would become available too late to allow RFW system reverifica-tion to be completed on the present schedule. For this reason, the S.S. had decided and shown in their reverification reports that they would perform no analysis of RFW piping, supports, or restraints, and that they would compensate for this omission by increasing the number of such items to be reverified in the other two systems. Mr. Yatabe later supplied the details of these substitutions (see attachment D).

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The TAA Panel pointed out that it is especially important to reverify pipe and support stresses in the RFW system for the following two reasons:

a) It is consistent with the original, intent expressed in the PVP plan to reverify three complete systems.

b) .Among the three .systems, RFW provides the largest sample of Burns & Row system design.

To look more closely. into. the possibility of doing..;

some reverification of piping or hanger stress analysis in the feed system, the Panel arranged to discuss the status of feed system design with Mr. Andre Cygleman of Burns & Roe. He informed the Panel of two problems in the RFW system. The first, involving a Quality Class I interface, required replacing a six-way anchor support with five new supports located from the, containment through the main steam tunnel.

This work is in progress; final as-built information is expected from Bechtel in May, 1983, with final stress verification to be completed by Burns & Roe in July, 1983.

The second problem arose when Burns & Row discovered, during design verification of Quality Class ZI hot systems, that main feed piping was causing excessive stress on the main

'eed pump nozzles and baseplat'e. The resolution of this problem has required piping redesign to incorporate TECHNICAL AUDIT ASSOCIATES. INC.

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additional expansion loops, hanger redesign and obtaining pump vendor (Ingersoll Rand) acceptance of high'er base plate loads.

Some of this work may still'e in progress, although the Panel observed during their plant tour that the affected piping is installed.

In light of the discussion with Burns & Roe, the Panel understands that fully verified as-built information which would be needed for reverification of RFW piping and supports will not become available from Burns & Roe.until a date which--

would'be too late to support present design reverification scheudles. However,-it does appear possible to include some smaller sample of RFW piping or supports for reverification at the design level, before as-built verification. Even recognizing the limitations of this course of action, we believe it is preferable to the present plan. If personnel resources are a limitation, we would suggest an offsetting reduction in the effort on the HPCS and RHR'ystems.

Findin No. 10 TAA does not agree with the present plan for the RFW system in which no piping or support/restraints are being reverified. We believq that 'a sample should'e included, using design level information, if necess'ary, to avoid the schedule delay which would result from awaiting as-built verification.

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C. Requirements Reverification Re ort There was considerable discussion of the Requirements Reverification Report which the Panel had received and reviewed prior to the audit. -The discussion centered on three types of C problems which TAA's review had revealed:

cases for which the information presented in the report does not fully support the Comparison Statement (example;- page D-51, ]f 10.1) comparison statements which are imprecisely leaving uncertainty as to'their meaning

.'orded, (example, page B-32, g 7.1) at least one example where the information is clearly incorrect, apparently caused by errors in copying or transposing (example page A-88, g 12.1)

In addition to those cited above, a number of other similar examples were raised and discussed with design management and team members.

Findin No. 11 The Requirements Reverification Report requires additional review and improvement,- to ensure that the relationship between commitments and requirements are more thoroughly analyzed and more clearly presented.

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"12-The Panel noted that the Requirements Reverification Report does not include all commitments since issues are still being raised and settled, as, for exampl'e, in Supplement Safety Evaluation Reports 42 and 43.

Observation No. 4*

While recognizing that additional commitments will continue to,be issued, the Panel believes. that the Requirements. Reverification Report contains enough comparisons to provide an adequate assessment of whether commitments are expressed in design documents.

D. Desi n Reverification Lo ic and S stem Enteractions Mr. Gelhaus, using a handout {attachment E) discussed and explained the logic for the sampling used in constructing the design reverification plan, answering questions which had been raised by TAA's letter of December 9, 1982. This discus-sion brought out a concern, felt by some members of the TAA Panel, that the S.S. may place itself in an ambiguous position by its various references to use of N45.2.11, when, in fact, the S.S. has made clear that it is not actually committed to.do

• Observation Nos. 1 through 3 are found in TAA Audit Report Number 1, dated January 10, 1983.

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-13" so. The S.S. pointed out that N45.2.11 has been used only as a guide to assure covering the necessary design input areas.

Mr. J. Cooney discussed how fire hazard evaluation is being taken into account, using a January 18, 1983 "Fire Hazard Evaluation (RHR System) Design Reverification Plan", previously supplied to Panel members, and a handout (attachment F). Mr.

I D. M. Bosi discussed the'everification pxogram for missiles, pipe break, and flooding, based on a previously supplied document;. "Evaluation of Interactive Design Commitments" and handout (attachment G).

.'sing a

Based on these presentations, on TAA's review of the above mentioned interaction documents, and on additional interaction reverification. instructions provided us concerning seismic and hydrodynamic loads and other environmental V

conditions, the Panel believes that the S.S. has made a good plan for dealing with this difficult subject. The S.S.'s responses to Findings No. 2 and 3 of Audit No. 1 will also deal with these topics.

E. Discussions with the RFW Team TAA met with R. L. He'id, Team Leader, and G. L.

Waldkoetter, C. C. Patel and- J. M. Curren of the RFW reverif-ication team. Subjects discussed included the reasons for omitting pipe stress reverification, feed pump control systems and tests, heat balance reverification calculations, and TECHNICAL AUDIT ASSOCIATES. INC.

P schedule. The Panel observed that the RFW team is experiencing schedule difficulty and needs strengthening.

Findin No. 12 The RFW design reverification team is behind schedule and requires strengthening in order to complete on schedule.

Xn discussing this. finding later with management, we.,

were advised-that the S.S. is taking steps to .bring qualified design engineers from outside. contractors. in'dditional F. Discussions with the RHR Team TAA met with RHR Team Leaders F. J. Markowski, and J.

T. Person, W. Edwards, J. R. Cole, and M. A. Mihalic, team members. Mr. Markowski and his team discussed and answered questions concerning all RHR Potential Findings Reports, as well as TAA's questions 10a, c and g. Mr. Markowski estimated that all but about 10 percent of his time is devoted to reverification activity and,that he expects to meet his schedule.

'. Discussions with Burns & Roe on the Pi e Stress Nozzle Problem During the discussion with Mr. Cygleman reported above and a follow-up discussion'he next day, January 28, with Mr.

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Forrest and Mr. Cygleman of Burns & Roe, the Panel learned that a number of similar nozzle problems have been discovered, some only recently. We were told that there are sixty-four problems of a similar nature, and that twenty-seven of these potentially involve safety related piping. At least one large valve, the main steam crossover valve to the main condenser, and the main turbine to main condenser exhaust trunk are implicated, in addition to nozzles. Resolution of these problems may involve only'hanger adjustment or.,may require more extensive hardware changes. In the brief time available we did not learn if Burns

& Roe is attempting to learn why these problems, are apprearing at this late date.

In order to scope the extent of this problem, Burns &

o Roe stated that they have already reviewed all large and small bore safety class piping, all large bore non-safety piping, and that they are presently reviewing all small bore (under 8 inch diameter) non-safety piping. Burns & Roe believes, thereforef that they now know the full scope. We believe, nonetheless, that the S.S. management should learn considerably more about this problem.

Findin No. 13 We believe that the pipe stress/nozzle problem should be investigated by the S.S. to determine the root causes of it, and whether the root causes have any implications for'ther S.S. work done by the architect-engineer.

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'f IV Construction Qualit Verification Pro ram The status of the QVP program was reviewed in three sessions which are reported below.

A. Review of QVP Status with Pro ram Mana ement TAA reviewed the status of the QVP program with Rob Knawa, S.S. QVP Program Manager, and Mel Leach, Bechtel Reverification Group. Discussions included responses to TAA ...

questions No. 2, 11, 12, and 13 (attachment B).

Mr.'-Leach, responding to question No. 2, said that out of approximately'8400 large bore hanger welds, 41. had been rejected for weld quality, or 0.49 percent.

In responding to TAA question No. 11(a), Mr. Knawa pointed out that the QVP program does not attempt to evaluate the contractor or the design adequacy, but instead focuses only on the acceptability of work installed and inspected before the July, 1980 work shutdown. Th'erefore, when work is known to be unsatisfactory and is to be reworked or replaced after restart, it is justifiable to remove such work from the population being sampled for the QVP. This point was discussed in detail with repsect to work which has been removed from the population for sampling in the Pittsburgh-Des Moines Steel Co. (PDM) (213A),

Waldinger (216), and O. B. Cannon (219 and 234) contracts. TAA accepted the S.S.'s answer to the question.

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Mr. Knawa and Mr. Leach responded to question ll(b) by stating that simple, hard-and-fast rules for sample size enlargement are not feasible due to the complexity of the situation in which numerous hardware features and applications are involved. However, the S.S. is preparing written guidelines or criteria which, together with use of engineering evaluation and judgement, will enable such decisions to be made.

The two.O. B. Cannon reverification reports (219 and 234) are to be edited.-so as to make clear that major exemptions.

of Cannon work from the QVP program were based, .in effect, on 100 percent rejection followed by 100 percent reinspection and rework as necessary. This responded to question No. 13.

During the QVP discussion, TAA asked whether the final QVP report would include identifying and summarizing those various related inspection programs which are shown in the PVP as being in support of QVP but which have been carried out at differ'ent times and under different (not QVP) management. In reply, Mr. Knawa showed a pie-chart (attachment L) which expressly identified those programs as being part of the total QVP concept; Mr. Leach showed a draft outline of Contract 21S Reverification Report which identified twelve such "other programs", for example', Anchor Bolts, As-Built, Grout, Sacri-'ical Shield Wall, Pipe Whip Restraints, etc. (attachment J).

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h TAA requested certain reports on the Sacrificial Shield Wall (to L. H. Roddis), Grout (to all but Levy), and Electrical Separation (to all) for its review.

B. Associated Technolo ies, 1'nc. (ATl) Review of Fishbach Lord Su orts Thomas Bostrom of Bechtel, a'ember of the Project Engineering Staff, reported on this subject in response to TAA's'question 9(d)."(attachment B). .The content of Mr.

Bostrom's report is contained in'attachment H. TAA notes that the S9 tray and 59 conduit. supports were "designed verified" by individual engineering review. Based on these reviews, all were accepted "as is". However, we also understand that a number of the supports sampled, although structurally acceptable, were not in full conformance with design. We do not question the acceptance of such supports, based on engineering analysis, but we believe that the na'ture of the deviations found should be analyzed before deciding that the deviations do not require consideration of enlarging the sample size. A deviation which, upon engineering evaluation, can be accepted in one application may be unacceptable in another application.

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Observation No. 5 For the purpose of deciding whether or not to extend the sample size, tray and conduit supports which do not conform to design plans, but are found acceptable as is, should be analyzed. It is important to determine if the same'deviations might, be unacceptable in other tray and conduit support situations. If so, such "acceptable as is" items'hould be counted as deviations for sample size analysis.'.-

Skewed Weld Evaluation J. C. Mowery reviewed skewed welds in response to TAA's question No. 4 (attachment B). The substance of Mr.

Mowery's presentation is shown on attachment I. He stated that his final report will be issued in early February, 1983. TAA will review this report.

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1 p V Effectiveness of S.S. Mana ement in Qualit Assurance Problems This subject was discussed with Roger Johnson, NNP-2 Project QA. The discussion included his preliminary response to Finding No. 7 and comments on pages 20-21 on TAA's Audit Report of January 10, 1983.

Mr. Johnson is preparing a report on TAA's Finding No. 7 concerning the matter. of .WBG radiographic film. The report will be available for review in mid-February. He also advised TAA that a status sheet showing Project response to Corporate QA audit findings will be included in future issues of the Program Director's monthly report. This status sheet will identify late and unsatisfactory responses and bring them to the attention of Project Management both through the report and .

in monthly presentations.

Mr. Johnson stated that the most recent Program Director's Report (December,'982) shows nine (9) NRC inspection items which are awaiting S.S. actions as compared with twenty-eight (28) in October, 1982. During this same two month period the number of items submitted to, and awaiting NRC approval grew from sixteen (16) to twenty (20) . The total number of open items was reduced from forty-four (44) to twenty-nine (29).

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This reflects Project 'I activity to reduce the backlog of un-resolved NRC inspection items, which had been urged in the report of TAA's November audit.

TAA observed that the S.S.'s approach to WNP-,2 'construction quality relies heavily on the QVp program for construction which was completed before July, 1980, and on Bechtel for construction which has taken place since restart. Persistent S.S. appraisal and audit of Bechtel's quality performance is, in'our':opinion, essential. Mr. Johnson discussed the activity to assure that Bechtel .is discharging- their S.S.!s'ontinuing responsibilities adequately. He showed an awareness of the need for S.S. oversight, and, by citing examples, indicated that effective, surveillance is being conducted. Specific S.S.

reports were mentioned, which TAA will review.

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ATTACHE'CHT A 26.22.07 TAA AUDIT January 26,'7, and 28, 1983 AGENDA Wednesda Januar 26 - CDC Buildin Clallam Room) 10:00 a.m. No. 1 Interview with Findings Review Cormnittee FRC Members 10:30 a.m. No. 2 Agenda Review JR Honekamp 10:35 a.m. No. 3 Design Reverification Schedule/Status DL Whitcomb 10:45 a.m. No. 4 Response to General guestions JR Honekamp (Nos; 3, 5, 6, 8a,><8b,'8c,".9a, 9e,..., GL Gelhaus;;

9f,'-10e,'nd'10h from 1-13-83 1tr) : DL Whitcomb;:,.

ll:15 a:m. No. 5 Reverification Logic GL Gelhaus (Response to 12-9-. 82 ltr)

No. 6 System Interactions 11:30 a.m. a; General Approach GL Gelhaus

b. Fire Protection 11:45 a.m. ,Overview of WNP-2 Fire Protection DT Evans Design and Fire Hazard Analysis 12:00 N Fire Protection Reverification . J. Cooney Review (also'question.No. 8d 1-13-83 ltr) 12:15 p.m. (lun'ch) 1:00 p.m. c. Equipment qualification Reverifica- E. Vogeding tion Review 1:30 p.m. d. Missile, pipe break, and flooding DM Bosi review 2:00 p.m. No. 7 Interviews with Reactor Feedwater Team RL Heid

. Members (individual interviews, CC Patel RL Heid address question 9b, 1-13-83 JM Curren ltr) 4:00 p.m. No. 8 Review of Findings from last TAA Audit JR Honekamp DC Timains GL Gelhaus RL Knawa'

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Agenda - Page 2 Thursda , Januar 27 - CDC Buildin .Clallam Room) 8:00 a.m. No. 9 Interviews with Residual Heat Removal FJ Markowski Team Members (individual interviews, JT Person JR Cole address questions 10a, 10c, M. Edwards and 10g in 1-13-83 ltr) JR Cole HA Hihalic ll:30 a.m. No. 10 Followup questions in Design Reverifica- JR Honekamp tion area GL Gelhaus DL.-Whitcomb DW Porter 12:30 p.m. (lunch and travel to MNP-2)

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Construction'Mana ement Conf;Room)"--

2:00 p.m. No. 11 Overview of Scope, Status,. and Results . BA Holmberg from ATI. Review of Fischbach 8 Lord et al hanger/support design activities 3:00 p.m. No. 12 Results of Burns 5 Roe review of skewed JC Mowery welds which lack increased leg length (reference BRWP-R0-82-347) 3:15 p.m. No. 13 Interview with Project gA Hanager (general RT Johnson (tour)'R followup from pr evious audit, Finding No. 7 and Comments on pages 20 and 21 of 1-10-83 Audit Report) 4:15 p.m. Honekamp Frida , Janua 28 - WNP-2 Site QVP Trailer) 8:00 a.m. No. 14 Interview with gVP Staff RL Knawa (guestion No. 2 from 1-13-83 ltr plus questions Nos. 11, 12, and 13 in '1-18-83 ltr) 11:00 a.m. Travel to MPF, TAA Executive Session 1:30 p.m. Exit Interview RB Glasscock PK Shen WC Bibb RG Matlock DM Mazur A. Squire JR Honekamp JH Yatabe

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ATTACHtii:NT B 26.22.04 TA'A 'QUESTIONS FOR WNP-'2 'PVP 'AUDIT NO.'

'SCHEDULED 'JANUARY '26'-'2'8,'1'9'83 Set No. 1g January 13, 1983 TAA's report of Audit No. 1, transmitted to the S.S. on January 12, 1983, contained eight findings. We request that each of these, except Finding No. 1', be discussed by the 'S.S. at the appropriate time in. the January 26-28 agenda. Findings Nos. 2, 3, 4 and 5 are related to design reverification, and Nos. 6, 7 and 8 are .related to the Quality Verification Program.

In the S.S.'s discussion of Pinding No..6 concerning QVI-09; the TAA Panel would. like'o..know what design=and, inspection codes,.and. standards. have 'been .useQ in the ...

Qesign, of pipe supports;-pipe whip.,restraints; and cable-.-.

tray supports? .We would. also like to know what percent of the 10 percent. sample of structural-welds reinspected under QVI-09 were rejected for weld. quality.

Xn the text and in Finding No..2 of TAA's first audit report we recommended that, there be increased attention to system interactions. We emphasize, in this connec-tion, the. possibility that the WNP-2 fire protection system could pose a flooding threat to vital electrical equipment, something which has been observed in other plants. See attached letter, L. H. Roddis to R. V..

Laney, dated January 1, 1983. Please inClude such a consideration in your response to Finding No.

1 to Burns 6 Roe (Forrest) letter BRWP-RO-82-347 2.'ttachment to WNP-2 (Holmberg), dated November 8, 1982, advises that BGR will .have completed, by the end of November, 1982, .its evalua'tion of skewed welds which lack increased

, leg length. Please'nfoxm TAA Panel of. the results.'age 17 of the PVP states that the design requirements to be used are "based on" ANSX.N 45.2.11-1974. A

.document titled "Design Reverification" provided to the TAA Panel by John Yatabe on November 19, 1982, states that 'the requirements completeness review will utilize a checklist "based on" ANSI 45. 2.11, Sect. 3.. NRC Region V inspection report No. 50-397/82-13, page 2, notes that the Supply System,',s position, stated in FSAR Amendment No..23, is that ANSI N 45.2.11 does not apply to WNP-2.

Since WNP-2 design is not committed to conform to ANSI 45.2.11, but to requirements "based on" it, how will the 'S.S assure that design reverification is carried out at,:..the same level a's cominitted in Amendment.23 to the FSAR?

6. Refer to SS's report of audit of Burns and Roe's WNp-2 and Richland office's report No.82-226 for audit per-formed September 17-27, 1982. We would like to know Burns and Roe's actions on QFR's Nos. 1, 2 and 3 referred to on, page '2; these BGR responses were requested by November 12, 1982.. Zn addition, we would like to know how .the reported deficiencies.may have impacted Burns and Roe's design of the three systems being reverified.

.7. Refer to TAA letter, R. V. Laney to J. R. Honekampg dated December 9, 1982, concerning sampling logic as used in requirements reverification: in the selection of major FSAR design commitments; in tracing these to the.

engineering requirements documents; in preparing Design Requirements Reverification Checklist and Design Review Questions; and the selection of questions in the System and Component Checklists. Please address the questions..

posed=in this:letter; . A copy of the referenced letter=-

is attached-for convenience;-.

8. Qu'estions related to the HPCS reverification plan:

(a) Pages 3-45 and. 3-50 all include'onsiderations of condensation water interfering with insulation.

Shouldn't this apply with equal force to stray water from the fire protection system'?

page 3-52 reference is made to the motor being (b) On class lE or, if non-lE, having a drip proof enclosure.

The main core spray pump motor is not a totally enclosed waterproof motor. Fire. spray activated in the area--could take the motor out of service.

Shouldn't the Design Reverification include an appraisal of the possible effect of fire system spray on electrical equipment and a validation of the equipment selected'? The comments on page 1-25 are also applicable in this regard.

(c) We note-on page 1-26 the statements that flooding of t.he HPCS pump room will not preclude safe shutdown/

and that. verification of the adequacy of the floor drain system is beyond the scope of HPCS reverifica-

'tion. Xn view of the importance of HPCS, .shouldn' some limited evaluation of drainage be made, if only to assure that drains are not themselves a potential source of flooding? (See also Finding No. 2 from TAA's Report, of Audit of November 19-22, 1982.)

(d) During our WNP-2 plant tour 'on November 20, 1982, '

we noted a battery installation with a non-standard

4 hood design located directly under t a fire protec-tion sprinkler head. If the function o f this battery is crucial to the startup of the diesel, the installation should be looked at critically.

There is apparently a single hydrogen off-gas system serving the hood. Whether there are hydrogen level alarms was not clear. Also, a nearby charger/

inverter is. directly under the spray and is unprotected.

If its function is probably adequate, only battery charging, this is but some DC terminals exposed to direct water spray could lead to shorting and inactivation of the battery. We do not see any mention in the Design Reverification Plan of this battery installation.

(e) Please comment on current plans for reviewing other system interactions with HPCS. (Refer to

. Fin'ding No. 2 of TAA Audit Report, on November 19-22, 1982 audit.)

Questions related to the Reactor Feedwater System reverification plan:

(a) The following-appears on page 1-25: ."There".are.-.

currently'no.plans to include FW piping, support/.

restraints or: their associated analysis as part of the reverification plan-"- The'eason given -for'-

this omission is that current engineering and con-struction schedules make it unlikely that a final design verification could begin before May, 1983.

We also note that the PVP, Sect. IV, page 15 g states that Bechtel and SS engineers are conducting in-depth reviews of -ASHZ Code piping and supportsg as described in PVP App. B, -and that these reviews will be "taken credit for" in the piping and support portion of the Design Reverification reviews.

'Please inform the TAA Panel how'he design of

, feedwater piping and supports are to be reverified.

(b) Inasmuch as the. purpose of design reverification is to show that applicable design.requirements have sheen incorporated into the final plant configurationsg

.< and in view of the incomplete design and construction of RFW systems, how will t'e system walkdown, described on page 4-1, be .modified to suit the circumstances?

(c) Please comment on current plans for reviewing other system interactions with RFW- (Refer to Finding No. 2 of TAA Audit Report on November 19-22, 1982 audit.)

(d) We note on page 3-16 that Fishback and Lord has contracted with ATl to review F/L design of cable trays, conduits~ and their supports. The TAA Panel'ould like to know the scope, status, and results of the 'ATI review.

(e) On page 1-31 this appears, "The selection process results in a broad enough coverage...to ensure that the design complies with the commitments...."

Please 'discuss, the basis for the "broad enough" statement.

(f) On. page 2-2, this, appears, "Sufficient numbers and types

.. -.will be reevaluated to provide .assurance, when coupled with the 'component level reverification...that the design of the RFW system (meets) its specified design require-ments..." Please discuss %he basis forl this assurance.

Questions related to the Residual Heat Removal System reverification plan:

(a) On pages 3-20 .and 3-21 a statement is made concerning the design of support RHR-436. It -contemplates des'ign review based on ASME Section, 3 conditions.

It

<<of does not mention the applicability or otherwise the American'elding Society code. At the back, the- book- on- pages 6 and. 6-4:applicable. codes ...

and .standards are'isted~.= neithe'i .the:.American Welding Society code nor QVI-09 are mentioned in this listing, To what applicable. code is the design.

review to 'be made?

(b) Please comment on current plans for reviewing other system interactions with RHR. (Refer .to Finding No- 2 of TAA Audit Report on November 19-22, 1982 audit.)

w (c) On page 1-10 it is noted that the structural engineer-ing discipline is not planned for review on the system level. Only a few specific structural engineer-ing supports will be evaluated as specified on page 1-3 in figure 1-lA. Please clarify which are the specific structural features which will be reverified.

(d) On page 1-.8 it is mentioned that operation of the system from the remote shutdown panel is different "in that all of the valve interlocks are removed."

Exactly what switching is involved in defeating these interlocks is apparently not going to be looked at in the scope of the review. We believe such an important function should be included.

(e) On page 2-2 at the bottom of the page it mentions that any deficiencies in design related matters on interfacing systems will be documented "but they will be pursued further outside of the RHR Reverification Program." Does this mean they will

~

not.constitute "preliminary findings".? We believe that any design related findings which could affect the reliable operation of the three systems being rever'ified should be pursued within the reverification program, including the .treatment of potential findings by the FRC.

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(f) Page 3-16 of the plan states that review of cable tray, conduit, and their hanger/support design will not be performed as part of this reverification activity, and that 'Fishback/Lord have a separate contract with ATX to review the F/L design. He would like to know the scope, status, and results of ATX's work.

~ (g) Page 3-17 indicates that pipe supports will be looked at on a sample basis, but does not tie back to the statement on page 1-3.0 or to figure l-la.

It is not clear from this page which pipe supports will be re-examined.

(h) On page 2-2 this statement appears: "Sufficient numbers and types of system requirements will be reevaluated to provide a high level of confidence, when coupled with the component level reverification strategy."-;, that.;the: RHR.system as- a whole is designed. in'ompliance .with='its specif ied require=.

ments'nd FSAR-commitments". Please advise what is meant by "a'high level of confidence" and explain.

your basis for it.

k 26.13.08 LOU)S H. RODDIS. JR.. P.E.. C. ENG.

COHPVL1IHO CHOIHCCh PO PhOAD PTPCCT tHAhl 447OH. POVTH CAhtlJHA 44API POPra4+PIP January 1, 3.983.

Nr. Robert V. Laney, 24 Trout Farm Iane, Duxbury, NA., 02552.

Dear 33ob:

I recently had occasion to visit a nuclear plant under construction which had a fire protection system that I believe had been designed with considerable input from knowledgeable and compent utility power plant and electrical equipment people.

Considerable care had been taken to keep water from electrical equipment. .Steps"included--the following.:"-

1. All'cabinets'were bottom-entry-,'and.-of:spray tight construction.

2. In the control room,:computer room, and relay room only a Halon system was installed. -.

3. The cable spreading room had both a Halon and a water spray system.

4. Cable racks generally had water spray systems installed either for them alone, or as part of an area system.

5. The electrical drive safety systems had. no installed spray systems, only a standpipe and hose.

6. Where steam turbine drive safety systems were installed a water spray system was installed, but'he only electrical equipment (aside from lighting) was a valve

-'perater that was of watertight construction.

7. The emergency diesels themselves had a C02 system only,

'he Diesel day tank had a water spray system in a separate room, and the electrical equipment was in a separate room, with only a hose and standpipe outside the door.

'8. The only bad spot. I saw was where all three of the battery chargers for the station batteries were under the same water spray head. While I did not check the circuitry, the chargers were ofthe the Trickle charge type, so presumeably the charger had DC leads inside. The batteries themselves were in separate rooms, no fire protection except the room separation and hose outside.

that some further look at the WNP-2 fire protection I really thinkorder system micht be in by someone knowledgeable about the ability of the electrical equipment, including those large motors, to perfor=

their assigned safety function in case the spray systems installed in those compartments are activated. Same for the Diesel installation.

cc: Jewett Sheets faithfully Yours, I evy Niller Louis H. Roddis, Jr.

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26.22.00 TECHNICAL AUDIT ASSOCIATES, 1NC.

589 OENOKE RIDGE NEW CANAAN, CT 06840 IRO3) Q6~383

. December 9, 1982 Mr. John H. Honekamp Washington Public Power Supply System P. 0. Box 968 Richland, WA 99352

Dear John:

According to schedules. enclosed in the HPCS, RHR, and RFS. reverification plans,=three -principal inilestones will:have.

been"completed for. all;,three. systems=-by 'the::time;of our January visit.- These are'STTP Updating, Requirements" Reverification, and. As-Built Xnspections.. We-write to advise you and John Yatabe that,:.during the .January 28 .audit, the TAA 'Panel will look closely at Requirements Reverification activities for all three systems..We will examine the logic and the methods by which CESAR commitments are traced to the engineering requirements documents and from the engineering requirements documents to the detailed questions which are used for testing the design. Wherever the process involves sampling, we will want to understand the sampling plan, the selection criteria, and the level of confidence which the p'lan provides.

We are particularly interested in the logic of four steps in Requirements Verification. These are:

First, what is the'logic .for selecting the "major PSAR design commitments". referred to in para. B of "Design Verification" given us by John Yatabe on November 19? We would like to review the criteiia. used in'aking these selections, learn the total numbers of 'major (and minor) commitments, and understand what level. of confidence the sampling plan produces with respect to the incorporation of PSAR commitments into engineering requirements documents.

Second, how have these major commitments been traced to the applicable engineering.,requirements documents? We would like to see several examples of working documents for each of the three systems which demonstrate the "extract and compare" process. We would like to review for each system several of "statements'summarizing the compliance of the engineering requirements."

Mr. John H. Honekamp December 9, 19 82 Page 2 Third, what rat'ionale was used 'in preparing the list of Principal Design Documents, Attachment 4.1 of SDE 3.1 and the Design Requirements Reverification Checklist which appears as Table 5. 3. 1 of SDE Instruction 3. 5'? What is the logical process by which this checklist leads to the System and Component Design Review Questions which appear in each plan (for example, on pages 1-10 and l-ll of the HPCS Plan)?

Fourth, starting with th es e System and Component Design Review questions, what was the logical process which resulted in the selection of the- questions which appear in the plans as Specific System and Component Checklists (page 2-11 of RHR plan and page 3-24 of the RHR plan)'

Ne would like to see- any materials .available which ..

address the questions of- logic posed above.- Xn addition, when they become available, we would like to receive working papers showing the details of implementation of these four steps.

I have requested Chuck Miller to assist in selecting this material to assure that the TAA Panel. will have sufficient information to comprehend the rationale governing the Requirements Reverif ication process as well as the thorough-ness with which it is being carried out.

Sine ly, Robert V. Laney RVL:.pb cc: Mr. Prank. B. Jewett, Jr.

Dr.'alomon Levy Mr'. Charles Q. Miller Mr. Louis H. Roddis, Jr.

Dr. Herman Z. Sheets TECHNICAL AUDIT ASSOCIATES. INC.

0 26.22.06 TAA QUESTIONS FOR WNP-2 PVP AUDIT NO. 2 SCHEDULED JANUARY 26-28, 1983 4

SET NO ~ 2 J JANUARY 18 ~ 1983 (NOTE: Set No. 1 contained questions 1 through 10.)

11. Since TAA Audit. No. 1, Nov. 19-23, 1982, we have re-viewed several QVP Contract Reverification Reports:

213A, PDM; 210A Peter Kiewitt; 216 Waldinger; 217 Sentry; 219 and 234 Cannon. These reviews have raised several questions which apply generally to all of these reports. These general questions are grouped here as a part of Question ll. Questions which are specific to individual reports are separa-tely numbered below.

(a)-..We'-'find that identified deficiencies have been.

eliminated from QVP consideration ..by redef ining.-

~

the work which is subject to reverification.

This( in our view, tends to give a wrong view of .the contractor's'work quality, even -though the practice may result in achieving a satisfac-tory level of quality, through later rework.

Example 1 In Waldinger, 216, when it was dis-covered that forty-.one out, of 148 supports re-quired redesign, the population for reinspection was reduced to 107 and nothing more appears in the report concerning the 41 cases.

Example 2 In PDh1 213A, electrical penetrations and downcomers were, by reassignment to Bechtel, removed from the scope of PDM work which is sub-ject to QVP reverification.

As a result of such practices, QVP reverification reviews t'end to.give an assessment of the work quality which is based on an unrepresentative sample.

These reviews and observations lead to the follow-ing questions:

ll(a)(1) Might this practice of excluding selected work from the population being reverified cause overall assessments of contractor work quality to be misleading?

ll(a) (2) Might this practice lead to a distortion of accept/reject ratios, obscure trends, or hide a need for sample enlargement'P (b) As mentioned in our Audit Report No. 1, none of the QVP Contract 'Reverification Reports which we have seen has identified either an unsatisfactory trend condition or reject percentage, leading to a

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need to increase the 10% sample size. Since the major mechanical contractor report (NBG-215) is still 'incomplete, however, we believe it important for the S.S. to state now its criteria is or guidelines to be used -for this purpose. This leads to a question:

11 (b) What criteria or guidelines will be followed for increasing inspection sample sizes, following evaluation of discrepancies found in original and subsequent reverification inspections?

12. The following questions relate to TNC-216 Contract Re-verification Report:

12(a)' Nhy"-was TNC"home"office 'documentation'on-cerning TNC-'fabricated..materials'never-re-:-.

viewed by TNC QA and what are the implica-tions of. this QA breakdown?

12(b) Why was this not discovered earlier by S.S.

or B&R audits?

12(c) Considering the loss of timely information, why was the review of this documentation deferred until the turnover review process?

12(d) Has the turnover document review taken place' What were the results?

12 (e) Were there, as"the report suggests, two significant. overhauls of IHP QA management and processes during the two year period beginning in 1979?

causes, what affect If so, what were the did they have on work quality, and are there any implications for work, quality beyond those noted in the TNC report?

13. The following question applies to O.B. Cannon 219 Contract Reverification Report:

13 (a) Attachment 2 of 219 is concerned with rein-spection of the drywell before and after recoating. Hardware inspections, document

,reviews and personnel qualification are presented in the future tense: "will be performed.", "will be reviewed", "personnel who will perform...". This raises a question concerning the value of a final report which

concludes, "the actions to be performed...

meet the requirements of the Quality Verification Program".... (Summary and Conclusions, page 1) Wouldn'0 it be more convincing to report on what hae been done?

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j.]z4/83 TASK J J 0 F PLANT VERIFICATION REPORT 0>> e~~>>

PREPARE PROCEDURES ASSENBLE REVIEH TEAf1S ..

INDEPENDENCE REVIEWS AND TRAINING REVERIFICATION PLANS DETAILED CHECK LISTS SAMPLE SELECTION AND PLANT PREPARATION REQU I REMENTS REVERIFICATION DESIGN REVERIFICATION FIELD INSPECTIONS SYSTEM AND COMPONENT ec I~

REVIEWS

" REVIEW FINDINGS R REPORT .

FINAL ASSESSNENT REPORT ENGINEERING RECORD REVIEI<

FINDINGS REVIB CONNITTEE PROCEDURES L STAFF PROCESSING FINDINGS FINAL REPORT TAA I JTS A REPORTS

ATTACHMENT D 1

REVERIFICATION PROGRAM SUBSTITUTIONS (Engineering Mechanics)

Subtracted Added to RHR From or Item RFW Com onents HPCS Com onents Small Bore Pipe M200-341 RHR-2289-1 Small Bore Hanger None included in RHR-2289-11 original scope Pipe Whip .Restraint PWS-27-2. PWS-2-1 Large Bore Hanger. COND-28 HPCS-901N Large Bore Hanger RFW-186 HPCS-52 Large Bore Stress Analysis M200-27 (Class I) HPCS-100A (Class IZ)

"Class I already being reverified in HPCS.

ATTACHMENT E 26.22.00A RESPONSE TO TAA DECEMBER 9 LETTER Concern 81: "...what is the logic for selecting the major FSAR design commitments given us by John Yatabe on November 197 We would like to review the criteria used in making these selections, learn the total number of major (and minor) commitments, and understand what-level of confidence the sampling plan produces with respect to the incorporation of FSAR commitments into engineering requjrements documents."

s

~Res onse: For the applicable FSAR chapters addressing design commit-ments (Chapters 1, 3, 5, 6, 7, 8, 9.5, and 1'0) all design commitments identified were compared to the engineering documentation. It should be noted the detailed 'equirements review of the FSAR showed two types of FSAR information:

1) Commitments, and 2) Descriptive tlaterial. The latter classification was not included in the requirements reveri-fication'n that it only provided .a description of the ..

plant--design..or-design parameter which .implemented..a..

commitment.

Based on the total of 125 FSAR commitments .identified, eight resulted in PFRs due to document inconsistencies.

On this basis, good confidence can be established in relating the FSAR commitments were incorporated to the WNP-2 design.

Concern 82: "...how have these major commitments been traced to the applicable engineering requirements documents? We would like to see several examples of working documents for each of the three systems which demonstrate the "extract and compare" process. We would like to review for each system several of "statements summarizing the compliance of the engineering requirements ."

~Res onse: Applicable paragraphs from the FSAR were extracted or paraphrased and compared with paragraphs extracted or paraphrased as obtained from the engineering requirements documentation.. See the requirements reverification report for examples.

Concern 83: "...what rationale was used in preparing the list of Principal Design Documents, Attachment 4.1 of SDE 3.1 and the Design Requirements Reverification Checklist as Table 5.3.1 of SDE Instruction 3.57 What is which'ppears the logical process by which this checklist leads to the System and Component Design Review guestions which appear in each plan (for example, on pages 1-10 and l-ll of the HPCS Plan)7"

~Res onse: The list of Principal Design Documents in'DE 3.1 is based on the known documents utilized on WNP-2. The original intent of the li.st was to provide the system engineer guidance in assuring all applicable documents that were

4 1 ~

v l

known to be used in Burns and Roe's design and necessary for 'performing any follow-on design change engineering were included in the engineering record for each system.

SDE 3.1, while "frozen" .for the three system reverifications, has been revised as a Technology-level procedure for system turnover and includes a defined document hierarchy for configuration control. This list of documents was verified by Burns and Roe to be complete. The later revision does not differ materially from SDE 3.1. The table 3.5.1 is an abridged version of Section 3.2 of H45.2.11, which (in our opinion and use) represents an accepted industry concensus on the definition of a typical listing of design input areas. This listing has been used as a guide to assur e ourselves that requirements extracted from documents types listed in Table 5.3.1 do cover the necessary design input areas (or rationalized as to why a design input area. is not applicable in specific cases). The product of this effort is the literature survey (verified for completeness) for future design modification work relative to a system or for use 'in the 'design -reverifi'c'ation program; The system and component design review questions represent a list of candidate areas to be probed during this design reverification. These questions are based on basic qvestions ~re aired as part of 'design reviews per Section 6.3.1 of H45.2.11. They are not intended to be all-encompassing (i.e., do not cover every aspect of the design process), but rather are intended to address the more important considerations given in the design of a system or component. Each question is used as a probe for "softness" in the design adequacy. It was intended that a given probe would be expanded whenever initial efforts revealed a problem area. Each reverification plan iden-tifies, those design review questions which will be addressed for each system and component. We have chosen to use this level of review (which is the level of review in current industry practice for design '-'verification) as an acceptable approach for reverifying the adequacy of the 'three WHP-2 system designs.

Concern 84: "...starting with these System and Component Design Review questions, what was the logical process which resulted in the selection of the questions which appear in the plans as Specific System and Component Checklists (page 2-11 of plan and page 3-24 of the RHR plan)7" 'HR

~Res onse: The detailed (specific) system and component design review questions (checklists) were prepared to address the system and component design review questions for each component type being reverified. These checklists are based on the combined experience and judgement of our engineers. These checklists have been reviewed and approved by each of our discipline Lead Engineers. As noted in each system reveri-fication plan, each checklist item may address portions of different design review questions as judged applicable.

The WNP-2 design reverification is not checking of all steps for each selected component throughout the WNP-2 design process. The WNP-2 design reverification does identify the required design inputs and uses them in review of the design. These questions become a test of the reas'onableness of the final design.

+NNP-2 FIRE HAZARD EVALUATION ~ AA ~ACR."1KNT F 26.19.07 DESIGN REVERIFICATION PLAN I. GOALS The goal of this plan is to reassure that fire protection features will provide protection of the RHR SYSTEM (Suppression Pool Cooling Mode) per 10CFR50 Appendix R.

o The plan will also review fire protection features to assure that no adverse interaction wi 11 occur with the RHR System.

o 'ther systems required for 'hot or cold shutdown to meet 10CFR50 Appendix R requirements are not included .in the reverification plan.

I I. CRITERIA The principal criteria document is Appendix F of the FSAR. Appen-dix F has successfully demonstrated how WNP-2 meets the intent of Ithe. regulatory, requirements .of 10CFR50 Appendix R. .

o  :>> Burns -and Roe fire analysis methodology .is contained .in Techni-cal Memo 1227."

o There .is no other overall 'system description.

o Commitments made in Appendix F are implemented on functional design drawings.

II I. PLAN DETAILS o Section 1, 2 and 3 provide background, regulatory requirements '..

and a summary of WNP-2 fire protection features.

o Section 4 limits the review to the RHR system and commits

'to.:tracing Appendix F commitments to .lower level drawings for selected fire areas.

Section 5 describes the boundaries which include the onsite power supply and electrical distribution system (Table 1).

Section"6 - Program Definition (Six Steps)

l. Commitments Review

2. Intruding Cable Review

3. Protected Cable Review

4. Suppression Systems Review

5. Fire Barrier Effects

6. As-built Inspection The copy of the plan that has been prepared is preliminary and we are now reviewing the attachments to it with the intention of eliminating repetition and questions that address the Fire Protection System design rather than the interactive effects.

We expect that the effort required to implement the plan will be more clearly defined and should be reduced from that shown on page 7-1.

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e DESIGN VERIFICATIOH OF 'CHBACH/LORD (CONT. 218)

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BY ASSOCIATED TECHNOLOGIES INCORPORATED (ATI) o ATI was retained on 1/1/82 to perform design verification of electrical cable tray and conduit supports originally designed for Fischbach/Lord by NPS. ATI was also contracted to provide ongoing engineering design services.

0 Scope of Design Cal cul ati one

~300 original HPS tray support generic designs.

~ 2400 individual tray support drawings.

~1100 original HPS conduit support designs.

~1100 generic conduit support drawings.

~14000 individual conduit supports.

o Random numbers were applied to the items in each of the five categories, and a random'sampling plan per NIL-STD-105D implemented. 'his sampling plan is based on obtaining a 95K level of confidence that the total population has 5X or less deficient supports.

o 59 tray supports were design verified, all were demonstrated to be structually acceptable:

o 59 conduit supports were design verified, all were demonstrated to be structurally acceptable.

o Software or drawing changes, not affecting hardware was required as a result of the design verification on 41 of the 59 conduit supports and on 41 of the 59 tray supports; o =

The design verification program is complete with the final report submitted 9/17/82 to Burns and, Roe/Supply cn System. n UJ

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t AV. ACI!b)EteeT 26.22.09 I

Skewed Weld Evaluation Problem 0 0 Skewed welds with obtuse anqles between 90 and 135 did not have the additional leg required by >WS.D.l.l specified by the designer or added by the constructor for the 215 and 250 contracts.

~Pro ram I

Since the hangers were complete andthe skewed welds had not been evalu- .

ated during as-builting, a sampl.ing program for past work was undertaken while procedures to assure the extra fillet leg was added and the as-built program incorporated evaluated of skewed welds for future work beyond November 2, 1982.

Random sample 'of:

'60 WBG large piping hangers with skewed welds.

60 'Bechtel large piping hangers with skewed welds.

60 WBG small piping welds with skewed welds.

60 Bechtel small piping welds with skewed welds.

Basis of sampling:

Each of the above four samples represent groups of hangers done by the same design methods, fabrication procedures and fabrication management.

'esults:

All welds that had the weld size specified on the drawing* were within code allowable stresses. The reasons why they were adequate are attributed to:

(1) Most skewed welds are on kicker supports for seismic loads where the, member size is large compared to the welds size required.

(2) Burns and Roe design procedures do not take credit for the skewed weld, even .t)ough the weld symbol calls for them, for angles less than 45 .

• Two Bechtel LP welds were below the specified size. One WBG LP weld was below the specified size.

0

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(3) The acute angle weld was always larger than specified even after subtracting the 1/8" allowance for lack of penetration for acute groove welds less than 60 .

'I A TACHMENT J

'2C.. it 3)E'AP:T'ONTRACT 215 REVERIFICATION REPORT OUTLINE AND STATUS

. X COMPLETE SECTION INTRODUCTION Report Hierarchy . 100

SUMMARY

Im CONCLUSIONS PROGRAM DESCRIPTION Organization . 100 Special Instructions . 100 QVI'--08 ";s . ~ ~ . 100 QVI-09 ".' . 100 Program Directives ~ ~ ~ ~ ~ ~ ... 100' Major Decisions . ~ ~ 100 Offsite Fabricators ~ ~ . 100 Reinspect Prior to System T/0. ~ ~ 100 Sandblasting . . 100 Inspection Reference Documents . 100 WBG Document Review Program Supply System Involvement SCOPE Total Work Scope and Type Work Remaining after Redesign Subcontractors OTHER PROGRAMS Anchor Bolts As-Bui lt Grout Pre-Service Inspection f

Sacri i ci al Shi el d Wal l Pipe Whip Restraints Start-Up Test Program . ~ ~ 50 Drywell Seel ~ ~ ~ ~ ~ . 100 Cranes 5 Hoists Hanger 8alancing Concrete E Rebar Structural Steel Bolting 009

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CONTRACT 215 REVERIFICATION REPORT OUTLINE AND STATUS SECTION  %%d COMPLETE Generic Problem Areas Documentation Hardware ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 50

~Samp 1 in Logic System Reports Selection for Hydro Reduction in Numbers because of Rework" Selection Matrix:: ~ ~ ~ ~ - ~ e ~ ~ 50 Deviations Socket Weld Sandblasting in Containment gCIR Re-Evaluation Chronolo ical History . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100 Results Results Evaluation 009

TACH!'::. K DOCUMENTS REVIEWED BY TAA BEFORE AND DURXNG AUDIT

1. S.S. Xnterof fice Memo, D. L. Whitcomb to N. S. Porter, dated January 7, 1983, with attachments: PFR Nos.

.HPCS-1 -2g -3, -5, -6, and .7; RHR-lg 4g -5.

2. S.S. Interoffice Memo, D. L. Whitcomb to D'. C. Timmins, dated January 13, 1983, with attachments: PFR Nos.

RHR-2, -3, -6, and -7.

3. Residual Heat Removal Design Reverification Plan, dated November 5, 1982.

4. Reactor Feedwater System Design Reverification Plan, dated. November, 8, .1982.

5... S.S.=.letter;"J.:R..-Honekamp'o .R..V..Laney; dated January 19; 1983; with'-enclosure-dated January 18, 1983 (draft copy):

"Plant Verification'Program-- Evaluation of Interactive Design Commitments", containing the following sections:

a) Seismic and Hydronamic Loads b) Fire Hazards Evaluation, RHR System c) Pipe Break/Missile Evaluation/Jet Impingement/

Falling Ob j'ects/Flooding d) Qualification of Safety Related Equipment for Environmental Conditions and Dynamic Loads

6. Design Reverification Program Schedules (bar charts)

Engineering Mechanics Jan. 14, 1983 HPCS, Mechanical, Diesel, I&C, Electrical Jan. 14, 1983 RHR, Mechanical, I&C, Electrical, Structuial Engineering Jan. 14, 1983 RFW, Mechanical, I&C, Electrical Jan. 14, 1983

7. "Requirements Reverification Report" for HPCS, RFW, and RHR Systems, forwarded by S.S. letter J. R. Honekamp to R. V. Laney, dated January 17, 1983.

8. SDE Xnstruction 3.5, Revision 3, titled "Design Reverification", dated December 8, 1982.

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9 ~ WNP-2 Program Director's Monthly Progress Reports for October, November, and December, 1982.

10. Final Contract Reverification Reports for the following construction contracts:

210A Peter Kiewitt Sons Co.

213 Pittsburg-DesMoines Steel Co.

216 The Waldinger Corp.

217 Sentry Automatic Sprinkler Compapy 219 O. B. Cannon and Sons, Inc.

234 0. B. Cannon and Sons, Inc.

11. NRC Inspection Report of WNP-2 No. 50-397/82-13, dated October 19, 1982.

12. NRC Inspection Report of WNP-2 No. 50-397/82-19, dated November 4, 1982.

13; S.S.=Corporate-:QA report of..'-audit:of:.Bechtel.Power.Co..

at WNP-','No.'2-221, dated-October. 7, 1982.

14. Burns and Roe letter to .the S.S., J..A..Forrest,to .B. A..

Holmber'g, dated November 8, '982; concerning evaluation of skewed welds.

15. Bechtel interof fice memorandum, J. A. Gatewood to T; A.

Mangelsdorf, dated October 12, 1982, concerning skewed welds.

16. S.S. Corporate QA report of audit of Burns a Roe, No.82-226, dated October 12, 1982, enclosing QFR Nos.

1 through 6.

17. Bechtel QA report of. audit No. 5.6.,1 of Bechtel Test Engineering, dated October 17, 1982.

18. Bechtel QA report, of audit No.- 8-1-1 of Bechtel QC Field Engineering and Procurement, dated October 18, 1982.

19. Bechtel QA report of audit No. 10.2.2 of Fishbach/Lord Elec. Co., dated October 29, 1982.

20. Johnson Controls report of audit No. 220-6-1-1982, dated December 7, 1982; audit No. 220-8-1, dated October 5, 1982; audit No. 220-12-1-1982, dated December 9, 1982.

21. Fishbach/Lord report of audit No. 82-18, dated November 9, 1982.

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22. S.S. interoffice memo from R. T. Johnson to B. A.

Holmberg, dated January 6, 1983, concerning evaluation of potential reportable findings I127.

23. S.S. letter, C; S. Carlisle to D. M. Sternberg, NRC Region V, dated December 2, 1982, concerning NRC Xnspec-tion Report 82-21 Notice of Violation.

24. NRC Region V report of inspection of VKP-2, No. 50-397/

82-26, dated Decembei 8, 1982.

25. NRC Region V report of inspection of NNP-2, No. 50-397/82-28, dated December 15, 1982.

26. NRC Region V report'f inspection of WNP-2, No. 50-397/

82-27, dated January 3, 1983, enclosing Notice of Violation dated January 4, 1983.

27.'echtel QA.report=-of. audit. of.Bechte3:..QC'program,-.

No.', 4.1.1, 'dated. July:23,';1982 =..

28. Bechtel QA report of audit of.Bechtel QC program, No. 11.1.1, dated June 4, 1982.

29. Bechtel QA report of audit of Best Co., No. 10.1.2,=

dated January 5, 1983.

30. Fishbach/Lord report of audit No. 82-,19, dated December 14, 1982.

31. S.S. 13th Progress Report to NRC Region V dated January 27, 1983, concerning Notice of Violation 10CFR50.54(f),

dated July 17, 1980.

32. Professional resumes of G. L. Naldkoetter, R. J. Cooney, E. L. Vogeding, Nestinghouse employees assigned to the S.S. design reverification program.

33. S.S'. interoffice memo, L. T. Harrold to J. R. Honekamp, dated October 28, 1982, enclosing "statements of inde-pendence" from members of the Findings Review Committee.

34. Minutes of Meeting of Findings Review Committee for meeting of January 19, 1983, dated January 21, 1982.

35. S.S. interoffice memo, R. T. Johnson to L. C. Floyd, dated January 25, 1983, concerning TAA Audit Observations.

ATTACHMENT L 26.21.02 3 Cgj, 0~

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':TASKS SAC Q

'C ~ tPP, E.lA COI<TRACTS SHLD WALL SV,STFM" RESTART A

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ATTACHMENT Technical Audit Associates, Xnc.

Plant Verification Program Plan Evaluation Team for WPPSS/NNP-2 BXOGRAPHI'CAL"'INFORMATION Frank B. Jewett, Jr., Assi ament Mana er: Founder 6 President TAA, member Tec naca Au xt Board. Assignment Director:

Xndian Point -2 Containment Flooding Accident Audit, Nine Mile Point: -2 Cost to Compl'ete Audit. Former: President and Chief Executive Officer, Vitro Corporation of America; Director of Engineering Research and Development, General Hills, Inc.

6 Vice President Mechanical Division; Vice President a Manager Vacuum Equipment Division, National Research Corporation; Member President's Council, Cal Tech. Member: of the Corp.,

Wood Hole Oceanographic ASME',Safety Committee; -:

Institute; NY Academy of Sciences; Merit Citation, Crusade for. Freedom'.."

Registered-Professional=Engineering; 'Minnesota';-~ BS", 'CXT; MBA.:.

(mcl). '.Harvard University'.v.

589 Oenoke Ridge.:,

New Canaan; CT 06840

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H (203) 966-3119 0 (203) 966-'0383 Robert V.'aney, Chairman of. the Review Panel: Vice President of TAA. Former Deputy Director, Argonne National Laboratory; Vice President and, General Manager, Quincy Shipyard Division, General Dynamics; Technical. Representative of AEC at.

Westinghouse Bettis Atomic Power Lab; Project Manager, Naval Reactor Program AEC and. Bu Ships. Ch. Engineering Review Team. Wash. St'ate Public Power Supply System. Member, GPU and Commonwealth Edison.Ad. Hoc Advisory Committees on Three.-

Mile Island; Member Presidential Board on National Breeder Reactor. Policy. Consultant: Department of Energy; Argonne National Laborato+; MA Attorney General; Commonwealth Edison; State of Illinois. BS, U;S.Naval Academy; HS,MXT; MBA,U of Chicago.

24 Tzout. Farm Lane Duxbury, HA 02332 (617) 585-8912 Dr. Salomo'n'ev, Consulta'nt 'to'the'Review Pan'el: Consultant.

Twenty-four years General Electric Co., San Jose, CA:

General Manager Boiling Water Reactor Operations; General .

Manager BWR System Dept.; Manager Des. Engr. Atomic Pwr.

Equ'ip. Dept.; Manager System Engineer, At. Pwr. Equip. Dept.;

Manager Heat Trans. and Reactor Program, APED. Fozmer:

Member AEC Task Force, Emergency Core Cooling; Ch. ASME Heat Trans. Division; Member Argonne National Laboratory Review Committee, Reactor Safety; Industrial Advisory Board, TMI-2 accident. Cons.': Kemeny Commissio'n; NRC Advisory Code

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Commission; World Bank on Nuclear Safety in Korea. Member National Academy of Engineering; Fellow ASME. Adjunct Professor, University of California at Los Angeles. ASME Heat Trans. Memorial and Conf. Award. BS, MS, PhDg University of California, Berkley.

Suite 725 1999 S. Bascom Avenue Campbell, CA 95008 (408)"'77-4870 Charles Q. Miller Consultant,to the. Review Panel: Registered Professional. Engineer. Eight years United Engineers &

Constructors; Dep. Proj. Mgr., WPPSS Unit 1; Asst. Ch. Power Eng., including supervision and management, of power projects and studies involving mechanical, nuclear, piping, process disciplines;.:standards .development; tech.. des.-guides, design

~

reviews; technical. support.'and.direction to various major ~

power projects, .including;>even.nuclear .plants; supervised design reverification Seabrook Nuclear,.Units 1 & 2; Sup; Eng."

'for preliminary design of five standard nuclear plants, including GE nuclear"steam supply .system.. Seven years USN, including operation, testing, maintenance of diesel-electric'nd nuclear submarines during new construction, overhaul, and operation. B.S. Mech. Eng. and Math., U. S. Naval Academy; M.S. Appl. Mech., Stanford; Juris Doctor, Rutgers.

United Engineers & Constructors,, Inc.

P .. O. Box 460 Richland, WA.-99352

'oui's"H.'-Rod'di's','Zi.,'eimb'e'r'o'f Rev'iew'a'n'el: Consulting Engineer. Chairman Energy Research Advisory Board of US Dep'artment of Energy. Director: Hammermill Paper Inc.; Reseaich '- Cottrell Inc. Former President and Co'.;'ould CEO, John K. McMullen Associates; President and V. Ch., Con Ed; Chairman and President, Penna Electric'Co.; Deputy Director Reactor DeVelopment, USAEC; Project Of ficer Power Plant Development Nuclear Subs NAUTILUS and SEAWOLF, USN; Task Force I, Bikini atom weapons tests. Fellow: Royal Institute of Naval Architects, ASME', American Nuclear Society.

Member and VC US National Committee CIGRE. Member: SNE, AS5iE IEEE, ASEEi NSPE, HFSi ASHAE. Registered Professional Engineer, NY, NJ, PA, DC, SC, Chartered Engineer UK; Member National Academy of Engineering. Outstanding Service award USAEC.

110 Broad Street Charleston, SC 29401 (803) 723-0319

Jh I I L

Dr. Herman E. Sheets, Member of Review Panel: Director of TAA. Director of Engineering, Analysxs and Technology, Inc.

Former Chairman and Professor,.Ocean Engineering Department, University> of Rhode Island; sixteen years, Vice President, Engineering and Research, Electric Boat Division, General Dynamics Corporation; Engineer Manager, Goodyear Aircraft; Program Manager, Elliott Co.; Director Research, St. Paul Engineering and Manufacturing Corporation; Chief Engineer, Chamberlain Research Corp.; Design Engineer, Erste Bruenner Maschinen Fabrik. Cit. Sec. War, Manhattan Project. Member:

National Academy of Engineering, New York Academy of Sciences, Fellow ASME, AAAS; Member ASNE, SNA and ME. Associate Fellow, AIAA. Dip Ing (1st in class), Tech. Inst., Dresden.; Dr.

Tech 'Sci (award for excellence) Tech Univ, Prague.

87 Neptune. Driye--

Groton,.-CT 06340 H '203) 443-1140 0 (203) 599-3910

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