IR 05000237/1982008
| ML20054N076 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 06/15/1982 |
| From: | Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054N056 | List: |
| References | |
| 50-237-82-08, 50-237-82-8, 50-249-82-09, 50-249-82-9, 50-254-82-09, 50-254-82-9, 50-265-82-10, IEB-79-14, NUDOCS 8207150327 | |
| Download: ML20054N076 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/82-08(DETP); 50-249/82-09(DETP);
50-254/82-09(DETP); 50-265/82-10(DETP)
Docket Nos. 50-237; 50-249; Licenses No. DPR-19; DPR-25; 50-254; 50-265 DPR-29; DPR-30 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Dresden Station, Units 2 and 3 Quad-Cities Station, Units 1 and 2 Inspection At: EDS Nuclear Inc., Walnut Creek, CA (EDS)
Sargent and Lundy Engineers, Chicago, IL (S&L)
Inspection Conducted:
May 3-6, 1982 at EDS May 17-18, 1982 at S&L
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dX l2.
Inspector:
I. T. Yin r
kN MS
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,['k Approved By:
D. H. Danielson, Chief Materials and Processes Section
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Inspection Summary Inspection on May 3-6 and 17-18, 1982 (Reports No. 50-237/82-08(DETP);
50-249/82-09(DETP); 50-254/82-09(DETP); 50-265/82-10(DETP))
Areas Inspected:
Licensee actions relative to IE Bulletin No. 79-14 activities, including general discussions on NRC requirements, work procedure review and review of analysis and calculations; review of analysis for transient events that occurred while operating the HPCI and CCSW systems for Dresden Unit 2.
The inspection invoved 38 inspector-hours at the A-E offices by one NRC inspector.
Results: Of the areas inspected, three apparent violations were identified.
(Inadequate design analysis for the effects of CCSW check valve slamming -
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Paragraph 3; lack of design procedure for the new hanger base plate and concrete anchors - Paragraph 4; Inadequate licensee QA audit and design review for the EDS IE Bulletin No. 79-14 evaluation program - Paragraph 6.).
8207150327 820701 PDR ADOCK 05000237 O
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DETAILS Persons Contacted Inspection Conducted at EDS on May 3-6, 1982 CECO
- M.
Strait, Engineer
- G.
Frizzell, Engineer EDS
- R.
A. Fortney, Vice President
- R. Ayres, Manager, Corporate QA
- W.
D. Gallo, Supervising Engineer
- T.
P. Davis, QA Engineer
- K. Wong, Supervising Engineer
- 0.
W. Zuniga, Supervising Engineer
- W. Tschudi, Project Manager
- S.
Jaffer, Section Manager
- T. C. Chen, Regional QA Manager
- M.
Scholtens, Division Manager
- G.
Slagis, Division Manager
- C. Y. Wong, Supervising Engineer
- D.
F. Brosnan, Division Manager
- R.
M. Torsen, Manager, Administration H. T. Ying, Supervisor I. Harris, Supervisor Inspection Conducted at S&L on May 17-18, 1982 CECO
- G.
Frizzell, Engineer S&L
- R.
Rabin, Senior QA Coordinator
- P. Gazda, Supervising Design Engineer
- R. West, Senior Structural Engineer
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- T.
Duffy, Assistant Division Head, SED
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R. McCluer, Structural Project Engineer A. Walser, Senior Structural Project Engineer R. Goebbert, Lead Project Engineer
- Denotes those attending the management exit meetings at the conclusion of the inspections.
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Licensee Action on Previous Identified Items (Closed) Unresolved Item (237/81-25-02): The design of the pipe whip restraint system appeared to be questionable. The inspector reviewed the design criteria at S&L on May 17-18, 1982, and had no adverse comments. The generic issue relative to pipe whip restraint settings, effects of thermal movements due to addition of new rigid restraints, and the possible interferences by the whip restraints during seismic conditions are discussed in Paragraph 2 of this report.
(Closed) Unresolved Item (237/81-25-03): Review of IIFCI IE Bulletin No. 79-14 evaluations.
Detailed review was conducted in January 1982.
(Region III Report No. 237/82-01, Paragraphs 2.b. and 2.c.).
While no deficiency was identified in the computer analysis, the generic issues, i.e., operability analysis required for the supports (Paragraph 1 of this report), and adding restraints into the system that could adversely affect the pipe whip restraint settings (Paragraph 2 of this report), could af fect the validity of this and other previously analyzed systems.
(Closed) Unresolved Item (237/81-25-04):
Long term system evaluation subsequent to system severe transient event.
The inspector reviewed the EDS calculation No. 02-IIPCI-FTG," llPCI System Fatigue Assessment," Revision 1, dated January 25, 1982, which included the damaged pipe whip restraint 2-23025-G-219, and damaged sway braces 2-2305-M-213, 220, and 232.
The licensee stated that pipe whip restraint 2-2305-G-209 was not included in the analysis because the damage was prior to the transient event, and the damaged condition was not severe.
(0 pen) Violation (237/82-01-01; 249/82-01-01; 254/82-01-01; 265/82-01-01):
Part A:
Inadequate piping suspension system operability analysis. This item remains open.
See discussions in Paragraph 1 of this report.
Part B:
Lack of safety relief valve evaluation. The EDS management stated that there are no steam line safety relief valves within the EDS evaluation scope. The inspector reviewed the EDS Calculation No. SC-13, " Relief Valve Loadings" Revision 0, dated February 5, 1982, for the worst conditions of water relief valve systems, and stated that the corrective measures taken appeared to be adequate.
(Closed) Violation (237/82-01-02; 249/82-01-02; 254/82-01-02; 265/82-01-02):
Pipe whip restraint gap clearances were not measured in accordance with the IE Bulletin No. 79-14 walkdown inspection procedure. This item is resolved, see Paragraph 2 of this report for details.
(Open) Unresolved Item (237/82-01-03):
Excessive seismic restraint gaps.
The licensee committed to find out the extent of the problem existing in the Dresden 2 and 3 and Quad-Cities 1 and 2 piping systems.
In discussion with the licensee representatives, the inspector concurred with the licensee plan to utilize the resolutions for the similar problems identified in Zion 1 and 2 in resolving this issue.
i (Closed) Unresolved Item (237/82-01-04): The inadequate evaluation for the CCSW check valve slamming effects was considered to be a violation item.
See
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Paragraph 3 for inspection details.
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(Closed) Unresolved Jtem (237/82-01-05): The inspector reviewed the EDS Calculation No. D2-CCSW-FTG, "CCSW System Fatigue Assessment," Revision 0, dated Februar-11, 1982, and had no adverse comment.
Functional or Program Areas Inspected 1.
Piping Suspension System IE Bulletin No. 79-14 Operability Analysis Subject matter was discussed in Region III Reports No. 50-237/82-01; 50-249/82-01; 50-254/82-01; and 50-265/82-01 as a violation item.
The licensee responses and proposed actions were contained in a CECO letter to Region III, dated April 16, 1982. To assist in Region III management decision on whether or not to accept the CECO proposals, the inspector discussed the EDS staff plan, and the design and construction schedules.
The summary of the discussion was as follows:
a.
Present EDS staffing for the project amounted to 134, increasing
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from 95 as of February 1, 1982. The technical personnel assignment was approximately 25 in piping stress analyses, and approximately 78 in pipe support and restraint design and calculation. The EDS management also stated that additional personnel resources are available if needed to meet the completion schedule.
b.
Support design status:
New Hangers Released New Hangers to be Designed Dresden 2 and 3 Approximately 290 Approximately 500 Quad-Cities 1 and 2 Approximately 100 Approximately 600 c.
The systems in the Hot Shutdown Path (HSP) included:
High Pressure Coolant Injection (HPCI)
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Diesel Generator Service Water (DGSW)
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d.
The overall schedules for the HSP, Control Rod Drive Hydraulic System (CRDHS), and the rest of the safety related piping system stress analyses and support design, component modifications, and new support installations are contained in Attachment A of the report.
Subsequent to the inspection the licensee was notified by telephone call to Mr. T. Rausch that Region III will require a basis for the licensee's definition of the systems required for the Hot Shutdown Path as stated above. This is an open item (237/82-08-01; 249/82-09-01; 254/82-09-01.
2.
Gap Measurements at Pipe Whip Restraints In followup of a previously identified violation item, the inspector checked all the gap clearance dimensions against the piping thermal movements, and obtained the following information:
Pipe Whip Restraint EDS
- Thermal and DBE No. 2-2305-G-Node Displacements (in.)
Note 1 Note 2 Pt.
Vertical Lateral 201 3A
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Structure in No insulation contact with 1/8" max.
,01
.01 pipe elbow
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204
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t.56 3" pipe to No data structure below I'-0" pipe to
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+0.10 ceiling
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3" to the rods 219
.20 tl.73 Based on Pipe No insulation OD = 10.75, 3/4" at 2:00 o' clock there is 3 1/2" at 8:00 o' clock
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+ 22 2 13/16" clear
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all around 209 9B
.23
+2.48 Based on S-W view
"l-1 1/2" (D.
1/2" at 11:00 o' clock Ring", 1 3/8" 3" at 5:00 o' clock I.60 I.20
' ^'^"
I around
.20
+2.45 210 Similar to 0" insulation to-1.71
.93 G-204 structure below 212 IIA
.12
+1.67 4 9/16" (1/4 S-W view (from insulat)
circle side 1/2" at 11:00 o' clock
+1.34
+1.22
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restr.)
3" at 7:00 o' clock 217
+.10-1.23 Similar to With insulation approx.
G-212 2" pipe to structural-1.00
.56 below 205
t.19-1.09 2 13/16" No insulation
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clearance all 2" circular around and 3" from bottom
+2.35
+ 07
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of channels
- The thermal movements and DBE displacements were taken from EDS Calculation No. D2-HPCI-08B(C), Revision 1, dated December 1, 1981.
Note 1: The gap clearances are based on IE3 79-14 walkdown inspection.
The circular dimension of the pipe isolation was measured to be 60 inches, or 4.18" thick by calculation.
Note 2: Actual gap clearance based on EDS measurement on April 6, 1982.
The information was provided during inspection at S&L on May 18, 1982.
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Subsequent to the review, the inspector raised the following questions:
Affected Restraints Questions No. 2-2305-G a.
If we can assume that the pipe is to be moved 212, 217, 204, 210 to the center of the restraint collar, why had the clearance between pipe insulation and restraint not been measured per procedure?
b.
In conjunction with b. above, the adding of generic rigid restraints could alter the pipe whip restraint piping hot position setting. Why was the effect not studied?
c.
In conjunction with a. above, how can the 209 pipe be at the center position while the thermal movement exceeded the gap clearance?
d.
The DBE movements exceeded the gap 209 clearance. Why were the scismic effects not studied?
This is an unresolved item (237/82-08-02; 249/82-09-02; 254/82-09-02; 265/82-10-02).
3.
CCSW Check Valve Slam Evaluation In follow up of a Region III unresolved item 237/82-01-04, the inspector reviewed the EDS Calculation N. OP-009/LPCI-04C, " Evaluation of Hanger 1510-36 for Check Valve Closing Loads," Revision 0, dated February 11, 1982. The calculated piping loadings were based on time-history analysis because the original static analysis loadings were viewed to be overly conservative. The calculation predicted 1120 transient events in the 40 year plant operating life, and recommended no system operation pro-cedures to minimize the check valve slamming loads. The resulting loadings at the main equipment and support are as follows:
a.
Pumps Forces (Kips)
Moments (Kip-Ft.)
I.D.
Axial Y
Z Torsional YY ZZ i
2A-1501 13.3 20.3 1.8 2.0 3.0 20.9
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-44 2B-1501 14.8 10.8 2.6 6.1 4.7 20.7-44 b.
Maximum of 18.96 Kips.
c.
Pipe Anchor No. SK-B-2-1510-36 Load Direction Forces (Kips)
Axial 29.1 Lateral 10.0 Vertical 4.6 The inspector reviewed the support calculation for the pipe anchor No. SK-B-2-1510-36, and observed the following questionable design matters:
Acceptance Criteria and Stress Allowables
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Allowable Ultimate Stress and Load on Bolts A-36:
Ft = Fb = 36 ksi Fv = 36 Ksi Weld E70XX:
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f = 70 ksi
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Self-Drilling Anchors 3/4":
T uit = 16.5 kip / bolt V ult = 16.5 kip / bolt Design Conclusions Total bolt pull out w/o prying action = 10.1 kips / bolt
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Bolt pull out w/ prying action = 14.7 kip / bolt Bolt shear load = 1 kip / bolt Interactions
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= 0.95 1.0
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16.5 16.5
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Check Base Plate Effective distribution between center line of anchor bolts and loading = 13.5" t= 1.04", 1" (existing plate thickness)
"The plate may be o.k.
due to the conservatism built in the assumptions."
Subsequent to the review, the inspector stated that the design consideration was apparently inadequate based on the following reasons:
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l There was a lack of verification to ensure that the transient
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loadings will not af fect the long term operability of the check valve and the pumps. The manufacturers' permissible loading criteria had not been obtained and evaluated.
The use of ultimate stress allowables in the support calcula-
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j tion was not addressed anywhere in the project procedures.
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The criteria had not been discussed or concurred in by the
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NRC-NRR or IE.
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The self drilling anchor bolt allowable load was different from
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the Phillips Red-Head, Size No. S-34, allowable design loads, where it states, "16.2 kips ultimate load capacity in 3500 psi
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stone aggregate concrete. Average pullout and shear values i
(1bs.) for maximum embedment of largest anchor shown.
(Shear i
value is given across threaded section of bolt.) Maximum working loads should not exceed 1/4 of the values for a t
specific anchor size. Actual factor of safety to be used
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depends on the application." Per FSAR and IE Bulletin No. 79-02 criteria, the shell type concrete expansion type anchor bolts i
should use only 1/5 of the test value.
The statement, "The plate may be o.k.
due to the conservatism
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built in the assumptions" can not be justified. The design was based on 1/4 cycle loading condition obtained from the "Strud1" j
computer program output.
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This is a violation item.
(237/82-08-03)
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4.
Support Calculations Review - Part I
The inspector reviewed the following support calculation procedures in the areas of concrete expansion type anchor bolt and baseplate calculations:
i EDS Project Instruction No. 28.0, " General Pipe Support Design
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i Engineering Procedures," Revision 2, dated October 30, 1981.
EDS Technical Procedure No. 2.6.1, " Baseplate Design Procedure,"
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Revision 0, dated April 1981.
Subsequent to the procedure review, the inspector selectively reviewed the following support calculations for implementation verification:
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Evaluation of Existing Supports No. 1510-2/D2-LPCI-04C, Revision 0, dated December 31, 1982.
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No. 1510/11/D2-LPCI-04C, Revision 0, dated April 7, 1982.
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No. 2-1410-38/D2-LPCI-04(c), Revision 0, dated April 12, 1982 l
Evaluation of Modified Supports l
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No. M-1162D-73/D2-DGSW-01B(C), Revision 0, dated April 30, 1982.
No. M-1162D-72/DGSW-01B(C), Revision 0, dated April 30, 1982.
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New Support Calculations No. M-1163D-72/D2-ISCO-01C, Revision 0, dated April 16, 1982, using simplified method.
No. M-1162D-139/D2-DGSW-02B(C), Revision 0, dated April 29, 1982, using EDS Technical Procedure No. 2.6.1.
In conclusion, the inspector stated the following:
a.
The responsibility of baseplate and concrete anchor bolt evaluations for the existing and modified supports belong to S&L.
EDS supplied loadings to S&L for these types of evaluations. No deficiency was identified.
b.
The procedure for the simplified baseplate and concrete bolt design was considered to be inadequate. The instructions contained in the Project Insturction No. 28.0 stated the following:
"31. Concrete Fasteners Only Hilti " Kwik-bolts" shall be used for new/ modified designs.
In place Phillips " Rad-Head" bolts are acceptable for existing designs.
A minimum safety factor of 4 shall be used for all service load conditions.
New supports bolted to concrete floors shall have a minimum grout thickness of 1/2 inch.
Loads due to plate flexibility shall be included as required in the total calculated anchor loads.
Combined bolt tension and shear shall be evaluated by the following expression:
E- + I- $ 1.0 Vo To Where T, V are actual bolt tension and shear, and To, Vo are allowed bolt tension and shear.
Concrete expansion anchor bolts shall conform to the Commonwealth Edison specification for same, Form No. Ceco /CEA (Revision 9)."
The general type instruction is considered to be insufficient for work performtnce and review checking.
Furthermore, the instruction did not include when the more detailed analysis as contained in T.P. No. 2.6.1 should be utilized. This is a violation item (232/82-08-04; 249/82-09-03; 254/82-09-03; 265/82-10-03).
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5.
Support Calculation Review - Part II During a followup inspection conducted at S&L on May 17-18, 1982, the inspector reviewed the hanger load data transmitted to S&L from EDS, and the evaluation of such data including calculations to ensure that the existing base plates and concrete expansion anchor bolts can with-stand the new loads. The calculations selected from review included No. EA-02-HPCI for the following hangers:
No. M-1151D-53, Revision 0, dated January 6, 1982.
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No. 2-1510-H81, Revision 0, dated April 21, 1982.
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No. 1510-11, Revision 0, dated April 29, 1982.
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No. 1514-2, Revision 0, dated April 23, 1982.
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The inspector's review was based on criteria established in IE Bulletin No. 79-02.
No items of noncompliance or deviations were identified.
6.
Licensee QA Audits and Design Review The inspector reviewed the following subject documents:
CECO QA Audits Audit Report, QA 22-80-8, "QA Program Implementation" conducted
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on February 20-21, 1980.
QA Manual review, not an audit of program implementation.
CECO letters to EDS, dated April 17, 1980 and July 28, 1980,
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" Approval of QA Manual of EDS Nuclear, Revision March 7, 1980."
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CECO letters to EDS QA, dated October 15, 1980, December 16, 1980, and September 30, 1981, accepting the EDS Nuclear QA Manual. The letters also stated that the acceptance does not include approval of specific QC procedures, instructions or any technical data which may be contained in those documents.
CECO Design Review Transmittal letters from EDS Assistant Project Manager to CECO
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responsible engineers, requesting IE Bulletin No. 79-14 project procedures review and approval.
EDS Internal QA Audits No. A04-1014, conducted on November 9-19, 1981.
No. A04-1001, conducted during December 1980 to February 1981.
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EDS Design Review Reports
"IE Bulletin No. 79-14 Piping Seismic Verification and Procedures,"
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dated February 19, 1980.
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"IE Bulletin No. 79-14 Piping Seismic Verification and Procedures,"
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dated March 27, 1982.
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"IE Bulletin No. 79-14 Piping Analysis," dated August 17, 1982.
"IE Bulletin No. 79-14 Piping Analysis," dated December 7, 1981.
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Subsequent to the review, the inspector stated that the licensee QA audit program to ensure the contractor program inplementation was apparently deficient since from CY 1980 to CY 1982, there had not been any QA audit and/or surveillance performed to ensure QA program implementation.
Furthermore, the licensee and EDS design reviews were considered to be ineffective.because the obvious procedural deficiencies discussed in Region III Reports No. 50-237/81-21; 50-249/82-15; 50-254/81-16; 50-265/82-16; 50-237/82-01; 50-249/81-01; 50-254/82-01; and 50-265/82-01 had not been disclosed by these design reviews.
This is considered to be a violation item.
(237/82-08-05; 249/82-09-04; 254/82-09-04; 265/82-10-04).
Unresolved Items Unresolved items are matters about which more information is required in order to ascetain whether they are acceptable items, items of noncompliance, or deviations. The unresolved item disclosed during this inspection is discussed in Paragraph 2.
Exit Interview The inspector met with licensee representatives at the conclusions of the inspections. The inspector summarized the scope and findings of the in-spection. The licensee representatives acknoweldged the findings reported herein.
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Q 'y Qy INFORMATION ONLY Hot Shut-HSP HSP**
CRDHS I/W IEB79-14*
IEB79-14*
IEB79-14*
IEB79-14*
IEB79-14 *
down Path Pipe Support Pipe Support Pipe Support Piping Piping Pipe Support Pipe Support PipeSuppokt (HSP) Pip-Design to Modification Modification Eval for Eval to Evaluation Design / Mod Modification ing Eval FSAR Completion Completion Operability FSAR to FSAR to FSAR Completion a
D2 July July April Complete Complete July Feb 1983***
December December l
1982 1982 1983 1982 1982 1983 l
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D3 July July 7pril Complete Complete July Feb 1983 December December 1982 1982 1983 1982 1982 1983 I
Q1 July July April Fall '82 May July Feb 1983 December December 1982 1982 1983 (EAS Scope]
1982 1982 1982 1983
1 Q2 July July April Outside May July Feb 1983 December December 1982 1982 1983 Drywell-1982 1982 1982 1983 Complete Inside-
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Fall '83
[EAS Scope]
- Drywell piping and support modification completed. Data shown only BOP accessible piping and supports.
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- At the present time a unit unique schedule is not available. The completion for installation will not vary greatly t
y between units.
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- Final qualification of supports determined not to require modification. Will continue until February 198..
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CECO QUAD CITIES STATION IE 79-14 ACCESSIBLE AREA SUPPORT DESI6NS 5-1-82 NO 0F SUPPORTS
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800 SCHEDULED
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700
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600
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ACTUAL
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500
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400
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300
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200
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JAN FEB NAR AFR NAY JUN J1 AUG s
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1982