DOE Letter to Bechtel on Piping Concerns

1.1 MB·

U.S. Department of Energy

OCT 03 20tt

LWTP- 3465

Mr RW. Bradford,

Deputy Project Dizector/Project Manger
Bechtel National, Inc

2435 Stevens Comler Place

Richlum, Washington 99354

Dear Mz, Brad:

CONTRACT NO. DE-AC27-01RV [4136— THE IS, DEPARTMENT OF ENERGY. WASTE
TREATMENT AND IMMOBILIZATION PLANT (DOE-WTP) SURVEILLANCE REPORT $-1|-
WED-RPPWTP-42; REVIEW OF PRETREATMENT FACILITY (PTE) VESSEL. VENT PROCESS
(PVD) SYSTEM HEADER PIPE INSTALLATION IN PLANNING AREA 7

Reference: DOF eter From 8. Charbaneau ts FM. Russa, BNI, “Approval of Bechicl National,
Ine. (BND Justification for Continued Design, Procurement aul Installation (CDP)
2430-P IF-JCDI-ENS-11-0002, Revision 0, Design and Procurement of PVP:PUY
Equipment in Advance of Testing Completion and Hazards Analysis
Alaled September 20. 2011

Inthe referenced letler, DOF indicated it planned ta provide a separa Ketter to address the eomvimued
PVP piping system design, Fabrication, und insallasion until TINT Tues completed is evaluation and

testing al the PVP system to deterine ifthe PVP system is properly size un maintain an ative
confinement safety function. Ja support of this planned leter, the WT? Koaineeting Division (WEL)
performed a review to investigate Bachtcl Nationa, fne."s (HNN) recent instalation of IVP system
piping in PTF Planing Area 7, Attached, is a copy of the surveillance report documenting this review,
[Based on this review, and DOE concerns regarding BNI's process for implemenring safety fuatetion
changes. a Priority Leve. 2 finding is entified inthis Iter, requiring a weilten response.

he currently designed and instlled PVP piping in PY Danning Area 7. suppor an active safety
function thal assume Multiple Sparger or Pulse Jet Mixer Overblew (MOB) controls arc added to tae
PDSA. However, these MOB controls were not addressed in the PDSA. This indicales a bronder
‘concer with INT’s configuration management of safety and design when changes are made after
intial desiyn is approved and issued.
Mr &. W, Bradford
1 TP 346

OCT G3 201

A Priority Teel 2 Finding is ete in this letter (Hinding $-1 |-WRD-RPPWTP-FO} fer not keeping the
WTP salety husis and design udequataly aligned. DOF is eonvernet T's Design Verifieulion und
Authorization Basis Maintenance programs lack sufficient guidance to address when ATS reyuicenients
ste changed after the assoviated design i issaed for proeurcmeut'ssued fox constmetion (LEPIFC

Within 14 days ol receipt af this letter, BINT should respons to the Priority Level 2 Gling discussed
shove an] inthe follawing Notice of Finding, For the Finding, provide n correutive netion pm ust
incluies: 1) immediate and remedial actions to correct The spevife deficiencies identviel in The

finding; 2) the exsent of condition, including a summary of hovs the extent of eovudiion was established,

the apparent cause(si of the finding: 4i corrective actions to correct the eondicion and cause(s} 0)
prevent further findings, and 5) the date when all cosecetive actions sill be completed, veriiod, and
compliance to applicable requirements achiowod, This response should address the tire nlated
‘sbservatinsifenilied i the ausached repr

his lec

noc eansideved to constitute a change to the Contact, Ln the cvent BNI disagrees with this

Jnterpretation. it must immediately nofify the Contracting Oficer urlly. and otherwise comply with the

requirements of the Central clause enitled 52.2432, “Nofilication of Changes.”

I you bse any questions, please caimtac! me, cm you may contact Gary P Bruns, Director, WIP
Engineering Division, [phone],

4 hg

nei an. Ni

WLPEND
Alvuchinent
cc watach:
D. Kymmenzind, BNI

1. Wearaer, BNI
INE Carrespandence

240007
MR. W, Bradford
HWE 346

Notice of

Conleact No, O1-ACZT-O1RV A136, Neetion C, Slanlunl 9, Reological, Nuciewn, and Process
Safes paragraph 2 state: “The conlrctor"s integrated standkrds-sed salely manoyernenl prangaya
shall be developed to comply with the specific auclear safety regulations defined in the elective rules
‘of the 10 CFR 800 soties of nuclear safety

10 CFR 820, Subport B, perageaph 202(0)(1) requires contralors fo update the saley basis to keep it
ceurent gal 10 roel ehamges i The Tuc

Contract No. DE-AC27-01 RV14136, Sestion C, Stundard 9, Table 89-1, Radiolugicr, Nueleur, and
Process Safety Deliverables, sequires the vontesctor to maintain the POSA current 6 sthia 60 days DF
design

Contrvet Wo. DP-AC27-OIRY 1418, Seution
Prngram documented in aQA Manual

Sanehurd 72) (3), requined TENT ea develop u QA

BNPs Quality Assurance Manual. 2454 W 11! QAM-QA-064001, Revision 9. Policy Q.05.1.
Listeuetions, Procedures, and Drirwings, Soetion 51.2.1, roquited ‘work to be performed in accordance
vith instuetions, procodimes, or drawings than include ot reference appropriate quantative or
qualitative accapiines criteria for detsmsining thal preseed] resus have been satisictorily atlaned,

Cemtrary to che ebuve, RINI's Authorization Basis program and Design Vetfleation progiare are not
adequate to ensure Authonzation Basis requirements ate adequately aligned (in timely mannec befor
_marcrial nstalasions), with applicaéle facility design ler the: design has been issued for
procursmentissued for consinieFon (IFPAFC}, Specilically. BN| installed PTT PYP piping in
Parsing Are 7 in lae July 2001 sion the design of this piping was nar in accoudance wit the
Preliminary Documented Safety Analysis (PISA), BNI nd iekentfic this condiiun in May of 2011
Forthermore, a8 of September 30, 2011, NT continued ts install PVP piping tha wus wot fn
compliance will: the approved sully basis. (Tindizg -11-WED-RPPWTE-FO1)
Auadhment
LWP 346
SA1WRD-RPPWTP.042

Attachment

WIP 346

Review of Pretreatment Facility (PTF) Vessel Vent Process
(PVP) System Header Pipe Tustallation in Planning Area 7

September 23, 2011

Repart Number: $-UL-WED-RPPWTP-H2

ages. I [Including Cawershecti
‘Attachmoat
HWTP-346
S-11-WED-RPPWTP-1

WED SurveiMlance Report

Report Nummber: S-I|-WED-RPPWTP-042,

Title: Review of Pretreatment Facility (PTT} Vessel Von! Progoss (PYP) Systom Header Pipe
Installation in Planning Arca 7

Bat

Seplember 12-23, 2011

Surveillance Lead: Elaine Diez, LIVAC and Process Gas Treuttnent Suiety Systems Oversight,
DOE WIP Engineering Division

‘Veam Meubers/Observer:

Brandon Gadish, Conttol Systems Safety Systems Oversight, WTP Lingineering Divisinn
Brad Pavlestin, Facility Representative, WIP Coustnstion Oversight & Assurance Division
Naas Vogel, Hovirenneotal Teal und Safety Teas, WTP Projecl Management, Observer
Scope:

A large piping module was inl in the PTF Planning Arca 7 ir ale July including a section

af 16" SCA, Saety Class PTF PVP systems euler piping (see Tigures 1 & below}:
r

Fig: 1 Mode! view dwn lle ecco Fig.2, 16° Ned: lakcg sont, PWD Blak oe

‘The salety function of the PIT PVP system was changed by 2.2009 Preliovinary Documented?
Safety Analysis (PDSA) Addendum, 24390-W [P-PSARA-ENS-D9-0001, and the associated
Department of Energy (DOR) Approval Letter, 09-NSD-44, However, the design of the
system had been influx sinoc teansenital of hese docuanenis. More details af the bistory of
this issue can be found on Project Risk FING-151 and Technical Tysue cut sheet 2010-0001

‘The PIF PVP system pipe in Planning Ares 7. as installed supporls an active safely fesetion of
the system (either case 3 or 4 fiom CCN; 23433). The pipe SC-T and Salety Class, ib of
the sconatias cited in CCN; 234433 assume Multiple Sparger or Pulse Jel Mixer Overblase
Attachment
LAWTP-346,
8-11 WED-REPWIP-043,

(MOB) controls az added. However, those oontrols do nor Yel exist in the PDSA, The need
Toe MOR eons sas ientitied hy Bechtel Nationa, Ine. (4N1) engineering in May 2011
aneluding proposed comtols (re! CON: 234424),

‘Without MOB conteols, che PIE PVP System would need ur he sited ts actwmmulate the Now
astociated with MOB conditioes. ‘This way sequire increasing the size ofthe PVP fester
a0ugi to near y double the airflow (fiom 4000 co 7000 set}.

‘The aurveillance ‘earn investigated chi poteorial PVP header undersized condi, walked
down the installed setion of piping, reviewell BNP sath forward, anil assossed the scape of
BYPs extent of condition regarding other incensistenvies hetween design and Authorization
Basis documents. ft also cxamined BNI's process for addcessing similar situations where
‘accident miligalions strategies may not be rflooted in design, procnrement, ad installaion,

Design Documents Reviewed:

0002, Rev. 0, Auuust 24,2011

+ 24590-WTP-PIER-MGT-100965-C, current version iu PIER module as of Sepueinber 12,
Dold

» 24990-WTP-PIFR-MGT-I1-0761-B wy , HANS PIER.

# 14590.WTP-GPP-SREG-002, LENS Screening and Audhsization Basis Maintenance,
Rov. 23D, June 15,2011

= 74390-W'1P-SDP-GO4B-00001, Dosign Criteria, Rev, 16, July 5, 2011

= 24590-WTP-GPG-ENG-OL48, Design Ciiteria Detahase Maintonan
2011

+ 24590-WTP-QAM-QA-06-001, Quality Amurmve Manual, Rev. 9, September 31,2011

+ 2439040 TF-M6C-PV-4H0N2, Vessel Vent System Line Caloulations, Rev, E, Qowober 30,
D008

+ 24500.WIP-PSARA-BNS-09-0001, Rov. 1, PDS Addendum, October 29, 2009

Rev. 4, March |

* Loller 09-NSD-D44, Aerdur Approval Letter with Conditions of Acueptance, Nivvamnber
02, 2009

+ DCD Notitica:ion of Change Documents and linpact Voring Records
DED Changs (Rev. 3); CCN: 225678
Responses: CCN: 231136
DCD Caange Rev, 1): CON; 205871, Funuary 19, 2010
Responses: CCN: 215958, March 24, 2016

© Mechanical and Process Lnginecving Design Verification Fucitity Thearmplete andl Open
Action froms Report for Mechanicel Systems, printed Sepuerber 14, 2011

CON: 254904, Proliminary Controls to Proveet PVP-PVY and CSV, May 31, 2011
Attachment
HAWTP-346,
S-L-WED-RPPWTP-042

Discus

of Area(s) Revieweu:

The surveillance team performed reviews ofthe yoventng requirements: intereiewed BNI
personnel regarding ihe scope and path forward of Ine follow yp actions snd the impact ofthis
PYE PVP systers installation, and perlirined reviews of pertinent seclions gF the pipe sizing
calenlatioa, The surveillance wee perfarmed an independent calculation of PVP healer pie
sing, ro determine impact to design nvargia st MOB controls were nc feasible.

Reyulzemeply Process Review:

‘The follesing discussion descrihes the key requirements that address Design Verificetion and
Authorization Basis Maiatenanee. NT had a sound process lor contnilling issuance sf design
‘a ensure no desigr documents were issuod until they were compliant with Ue Auloxizatin
Basis,

Design Vorifivtion (DV:
BNT’s Quality Asounimce Vianusl (QAM) required the design to be vorifiel prier fe release for
rvcuremnent or aomstrustion unless Min timing could not he met, in which suse she design
agency i require lo identi and control unveriFia design elements and eornplete DY prior to
tke ss8.et oe component pertocming its finction and hefore installation becownes imeversiie
is. voquires extensive demelition and rework) (rf, QAM seztion 3.12.34)

BNT design control procedures were elear thal design mata may not be issued for rovuremen™
‘or ccmatraction un chey ace felly compliant with the Authorization Basis.

Authislzatiog Hasis (AB) Maintenance:

‘When che 4B ts modified by BNI in an Auchosizacivn Basis Amendment Request (ABARD,
Justification for Continuod Design, Procurement, a Installation (QCDED, of PDSA Addenda,
Environmental and Novleur Safety (EAWS) has 40 days to Low tat down inte the AB. Upon
revision of an ATI document, Project Dacurrient Contes! nu lies the Design Criteria Database
(DUD) Manager. A DUD Notification of Change is written, to whieh responsible desiga
‘personnel must respone! within 60 days, identifying impacts to design. ‘These impav's ure then
‘menaged within he normal trenlfag,sisk, and design zhange processes. BNI's procedures
‘untain no requirement « individually rack aftecred design clormcats thar havo already bec.
Jssued for procurement or constuction pret tothe AB change,

Yo sommarze the process review, there is arequiretnent put Ip issue non-AB-compliant design
documents for procurement or cans:rueticn, hut there im requirement stup iasallstions ar
procurements already underway when Ihe AB isreviged, nor is Ihete a requirement track
affeoted design clemen's te prevent ireversitic installations, The DCD Nolifcatiom a Ch
process sorves to notify cnginecring disciplines viu the Inegraled Project Tetans (IPT), wich
then are responsible for identifying impuels ln design und tuking appropriate actions. These
Artachmeat
L-WIP-M6
S-1WTED-RPPWTP-€82

‘issues ure munauedl vin the CPR 4.4 dalahase, known as the Safety Systems Reconciliations
Actions, as ell as the Projen’s tak, renin, nnd cul sheet programs.

Tn he: ease of the PVE systous, cho design was issued for procarementisansuuetion (IFPAIEC) as
passive sysiem pos! seismic design bas's event (DBE). ‘Tac system was complant with he
AB unl the AT was chonged in 2008 and 7009, upgrading the post-DER function 0 the
system to active, and changing key inputs thal lm Ihe nae wf the inpuls tothe system
calculations.

‘The vedesygn of PVP veas placod on hold between the 2008 Decisiva-to- Deviate ana the 2009
PDSA Addenda, ponding the outcome of the Material at Risk’ tiydcogen in Piping and
Aucillary Vessels vbanges The impact changes to tac DSA addenda were stole, s,
allsough engingering did reecive the DCD Notification of Change in a tutely manner and
jnmedistely report] that there were impacts tn design, Ihe alfovled euginecring diseiphncs did
‘ot omediately recngmie the broad irepactiif the change upon nnvifiation.. Thexe imewcts
were discovered in the process of atteamting us implement the chaages ic a design change

‘The redesfen efforts Wy allermpl to vomply ith the PDSA axidenda wer: stopped, dve 1 #
projet risk decision, when i wat recxygized Ina dhe sedosign woul he a "major impact to PTT
(aciitional Noor), and an integrated pall forward was aulopled, This inieyraled upprowh
incl.ded a test ui determine zealistc accident challenge conditions lo egeipment,
sharactorivation of performance of system cat jpment under eccident conditions, and
reconsideration of PDSA requitcments given additional inormacion from these eéfors, in
addition to consideration of limited reéesign options. ‘This path forward was documented on
Toclunical Issues Cul Sheet 2010-001, Rick Assessment Shoot ENG" $1, andl in CCN: 23443,

“The issued PVP system line sizing ealeulation was designated as “commited,” allowing For
isuance of inal design, yet conta:ned eleven unverified assuniptians. Thase assumptions were
boing trseked in the Design Verification database tool known as CALCTRAC.

Ik sheuld also ‘oe noted that engineering did not idemtify the need fer MOB controls until very
Tote in the process nf reviewing opfions...Muy 2011. Toe design was sereeneal in February
2010 for inpucts due wo increased flo, hut Mixing was hen thought Lo be the oaly potential
Aeiver fora significant increase to system flow, and it was later detenmned thst the Mixing,
‘mpact Was nol s'gnificanl, {twas Ihe combination oF the appreciation pI te i pcs Lo the
CSV confinement venlilatinn syslem and the aerosol test planning proces ut Prought this
sue (potential PVP header undersized pipe) to Tight

‘Nhumerons extenuating circumstances, suchas those deserted abewve, and the renliation by
caginecring that the PDSA contiols required by the 2000 PDSA Adenia were xt inset 10
be implementod in tae design, le to a two-year gxp doting which the PVP systern had boen
‘unaisle wm meet Authorization Basis requirciments.

The first PVP system piping module was mstalled in Planning Arca 7 i. ste Tuly. the lack of
MOB cantrals inthe AB beings into question whether this pipe was undersized.
‘Anachmeat
L-WTP.346
S-11-WED-REPWTP-042

‘This :ssne was idenstled by BNI aad added to Prjest Issues Fvuluation Rept 24890-1°7P-
PIER-MGI-10-05654C as accom icems 15 und 16, Because this issue sas ieatiied hy BN)
no tinding is cite, Hoveewe. the oover letter to cis surveillance tepore will <equize BRL 0
provide a waiter respons descsibing its path forward to address this PW system piping
instllaron issu

A second piping modu'e is scheduled tu he intal ed ie PTF al dhe end of September. Hover,
this module does not coataia PVP keader piping. fn late October, a PTF piping module in
Panning Area 1 will be installed waich will contain several addicianal scetions of patexially
under sizud HYP header pising (sco atached “PVP Piping ia Mactks te be st Nese")

Became Je pipe siving insu Ha nok been ydldeessed with iullition uf adequate MOB concls
‘nv an AB ange docurnesr, future PTT PVP pipe installason is currently ats

Where Authorization Basis requirements change alter Ure astociated design is IEPHTC,
especially when broad changes sueh a isthe ease for che PVP system ate pending (but before
‘hey happen), robus; discussion betwece, BNL ERAS and the zespensible IPT would reduce
risk co thopvoject and ensure reyuéremens changes ore fully evaluarod up font, The discussion
wild inclale a clear definition othe change in erm al Gmelional reguiernents expestel
‘he sy81em, and the impact of the proposed change oe the issued design, pracureent, al
canstruction. (Observation S+1I-WED-RPFWTP+142-001])

‘Where Authorization asi requirements change after the associated design is IEPAKC, and
impacts arc identified to issued design elements, :n order to prevent ireversible installations as
requiteé by the Waste ‘Treatment anc Immobilization Plant (WIP) QAM, there should bea
process for clearly Irackiny and idenbifying affected clurents. (Observation S-A1-WED-
RPPWTP-042-002}

eaulroments Excerpt

ASME NQA-1-2000, irene 3, Resgn Cony, Seevon 56, Deen Wein
‘crane yor fore Zc procrement or onstvtoa ales tng evmast be met. ck be
‘ait fev Ten Ey andra wend ign and cumple vir kat”

Ecc fie Table $9-L of Carta. Pago #6

eanertencgn ee} SEDANS Chae tie _ _
Attachment
TLAVTP-346
S-1-WED-RDPWTP-042,

2A9C-WIE-QAM-GA-16-CO1, Qual teurce Moma, agen 05.5. xh
“Design veraton shall he erro pr a rele sig he deen lr precoenen ome
coratuten, eb aaoda design engonaioa exes whee this tuning east 3 il. es
tones, the esi pork a he ce a he clelydeaies an xml, al ces de den
‘ertcation sal be ceayplted prio a sliag upon he SC coma progane teem
Fension aa befre fal heroics revere, ese extensive demesne”

"Engincsingcvaastss tho pact of dese chang or teil np-zoaement. canton,
operons, fer the design change Somme hav bron agarose. erginecringcoarinees dh
frocurrev, cotati, pation in Heute speak wet lene he change

Reb Paso

{1500 T-GPP-SREG-N02, FANS Sarccning and Antasizusinn Bays Meine
Sor 15,2311

aso:

>. GUMBO, Desig Catena.

1, fy, 2001
BASMUEH UFC NCLETOS, Design Cram abe Mamlennce, Re. 4 ae 1, 2601

Peesonnel la:erviews:

‘wing an interview between the DOE-W'LP surveillance team and BNI staff on September 14,
2011, the team cvaluated the planned extent of condition review. ‘The BNI Point of Contact for
the exten af condinon review planned to review all ofthe thirteen CPR. 44 issues ard
determine for each isc if procurements or installations are impacted, This review will include
an examination of huss ean of those risks are being managed, ars expevted by bake 2-3
weeks <j avoomplish,

‘The DOE-WTP surveillance team aged this proposed seope was adequate to detemnine if
similor iseves exist elsewhere om the project. Por additional ascuranee, the surveillance tearn
resutnmenils DOE-W'TP periorm an independent review of “he extent of condition upoe

comapletion af BNTs ceview (Assessment Follow-up Item $-LI-WED-RFPW'IP-1M2-A01)

During the incerviows, the DOL-WTP surveillance tear ulsa determined that che Tazactds
Analysis Meetings (8.k.n. “HAZOPS", th review the need for and feasibly of BNL

Engineering's proposed MOB contsois, were not currently seheduled. The Plamaing Area 7
piping male, instilled in lave July, was the list of many to be installed, with the next module

‘aintainig PVP heuder piping scheduled tor installation in late October. Although B&NS may
Ie iting far results fram cogeing test efforts, « HAZO? to determine if controls propose by
Engineering in CON: 234424 were leasible could -eduve the significant risk associated with

the future insielacion af PTE piping modules. {Observation S-11-WED-RPPWTP-(42-043)