IR 05000237/1982021
| ML20027D710 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 10/14/1982 |
| From: | Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20027D705 | List: |
| References | |
| 50-237-82-21, 50-249-82-22, 50-254-82-17, 50-265-82-19, IEB-79-14, NUDOCS 8211080272 | |
| Download: ML20027D710 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/82-21(DETP); 50-249/82-22(DETP);
50-254/82-17(DETP); 50-265/82-19(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: Nutech Engineers, San Jose, CA (Nutech)
EDS Nuclear Inc., Walnut Creek, CA (EDS)
Inspection Conducted: August 25, 1982 at Nutech August 26-27, 1982 at EDS Inspector:
I. T. Yin
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Accompanying Personnel:
D. H. Danielson etnc
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Approved By:
Danielson, Chief
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Materials and Processes Section Inspectton Summary Inspection on August 25-27, 1982 (Reports No. 50-237/82-21(DETP);
50-249/82-22(DETP); 50-254/82-17(DETP); 50-265/82-19(DETP))
Areas Inspected: Licensee actions relative to Mark I torus modification program and IE Bulletin No. 79-14 activities, including general discussions on hTC requirements, work procedure review and review of analysis and calculations. The inspection involved 20 inspector-hours at the A-E offices by one NRC inspector.
Results: Of the areas inspected, one apparent violation was identified (Inadequate licensee QA audit of the Nutech Mark I program - Paragraph 1.e).
8211080272 821026
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DETAILS Persons Contacted Enforcement Meeting Conducted at RIII on July 14, 1982 CECO C. Reed, Vice President E. R. Zebus, Project Engineer G. Frizzell, Project Engineer N. P. Smith, Engineer J. S. Abel, Manager, Station Nuclear Engineering L. O. De1 George, Director, Nuclear Licensing M. Strait, Engineer T. J. Rausch, Nuclear Licensing EJDE R. A. Fortney, Vice President W. Tschudi, Project Manager G. C. Slagis, Manager, Engineering Division Nutech B. Whiteway, Project Director W. V. Weber, Engineering Director NRC-NRR-MEB Y. Li, Mechanical Engineer NRC-NRR-DL D. B. Vassallo, Chief, ORB No. 2 J. D. Hegner, Project Manager R. Wessman, Technical Assistant, ADSA NRC-IE J. R. Fair, Senior Mechanical Engineer NRC-RIII i
L. Spessard, Director, Division of Project and Resident Programs C..Norelius, Director, Division of Engineering and Technica) Programs R. D. Walker, Chief, Projects Section 1C D. H. Danielson, Chief, Materials and Processes Section
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I. T. Yin, Senior Mechanical Engineer i'
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Inspection Conducted at Nutech on August 25, 1482 CECO
- J. S. Abel, Mana3.sr, Station Nuclear Engineering
- H. C. Strait Engineer Nutech
- N. A. McClean, Engineering Manager
- W.
V. Weber, Engineering Director
- A.
Ozeroff, QA Administrator
- W. E. Booth, QA Manager
- T.
J. Victorine, Project Manager
- B.
J. Whiteway, Project Director
- D.
A. liignite, Project Quality Engineer
- G. R. Edwards, General Manager J. A. Pryatel, Auditor K. L. Zeman, Auditor A. K. Kundu, Project Engineer P. Pandey, Lead Engineer
- Denotes those attending the management exit interview on August 25, 1982.
Inspection Conducted at EDS on August 26-27, 1982 CECO
- J.
S. Abel, Manager, Station Nuclear Engineering M. C. Strait, Engineer EDS R. A. Fortney, Vice President, Regicnal Manager
- R.
M. Torren, Manager, Administration
- C. Y. Wong, Supervising Engineer
- W.
D. Gallo, Section Manager
- R. A. Ayres, Corporate QA Manager
- T. C. Chen, Regional QA Manager S. M. Jaffer, Section Manager
- 0. W. Zuniga, Supervising Engineer
- J.
A. Young, Section Manager
- W. Tschudi, Project Manager
- Denotes those attending the management exit interview on August 27, 1982.
Licensee Action on Previous Identified Items (Closed) Violation (237/82-01-01; 249/82-01-01; 254/82-01-01; 265/82-01-01):
Inadequate piping suspension system operability analysis.
This item is closed. See discussions in the Enforcement Meeting section of this report.
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(0 pen) Unresolved Item (237/82-01-03):
Excessive seismic restraint gaps.
This item remains open. See discussions in Paragraph 2.a of this report.
(Closed) Unresolved Item (237/82-08-01; 249/82-09-01; 254/82-09-01; 265/82-10-01):
Licensee definition of the systems required for the Hot Shutdown Path. The systems were identified and accepted by NRC-NRR and NRC-RIII.
(0 pen) Unresolved Item (237/82-08-02; 249/82-09-02; 254/82-09-02; 265/82-10-02):
Questionabic piping seismic and pipe whip restraint inter-action and interference. The licensee stated that evaluation effert for HPCI had been initiated, and should be completed by end of October, 1982.
Determination will be made on whether nor not extensive investigation is warranted.
(0 pen) Violacion (237/82-08-03): The CCSW check valve slamming evaluation was considered to be deficient. The licensee response stated thet plant system operation procedures will be revised tc minimize the slamming situ-ation. The inspector concurred with the licensee approach in solving the problem, and will review the updated operating procedures.
(Closed) Violation (237/82-08-04; 249/82-09-03; 254/82-09-03; 265/82-10-03):
Inadequate procedure for the simplified base plate and concrete bolt design.
The inspector reviewed the new Project Instruction 39.0, " General Base Plate Design," Revision 1, dated July 21, 1982, and considered it to be acceptable.
(Closed) Violation (237/82-08-05; 249/82-09-04; 254/82-09-04; 265/82-10-04):
Inadequate licensee design QA audits of EDS. The inspector reviewed the licensee responses, and the CECO QA Department Audit of EDS-Nuclear, QA-20-82-46, conducted on July 12-13, 1982, and had no adverse comments.
Enforcement Meeting A NRC-RIII enforcement meeting was held at RIII on July 14, 1982 relative to tha IEB 79-14 piping suspension system operability analysis requirements.
The meeting was attended by representatives of RIII management and technical staff, and the NEC-NRR and IE technical cnd licensing staffs. A presenta-tion was given by CECO and EDS responsible personnel. Topics included:
(1) Introduction; (2) History and status of IEB 79-14 evaluation program for Dresden ond Quad-Cities stations; (3) Licensee actions and responses to the NRC-RIII citations; (4) CECO's understanding of the IEB 79-14 operability program; (5) EDS project status and overview; (6) Technic:1 justification for not performing piping suspension system operabllity analysis prior to determining that the piping system is operable; and (7) Conclusions.
Sub-sequent to the meeting, the NRC staff accepted the licensee's resolution, and issued a Confirmatory Action Letter (CAL), dated July 14, 1982. The CAL essentially requires the licensee to complete all analysis and modification work for the Hot Shutdown Path (HSP; systems to meet the FSAR conditions on or before February 15, 1983, and all other safety related systems on or before December 31, 1983.
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Functional or Program Areas Inspected 1.
Work Performed at Nutech on August 25, 1982 a.
Review of Specifications The inspector reviewed the following Nutech torus attachment piping modification specifications:
Dresden 2 and 3 COM-11-001, " Torus Attached Piping Analysis and Modification,"
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Revision C, March 9, 1982.
(For torus external piping design)
COM-01-853, " Design Specification for Suppression Chamber
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Internal Piping and Piping Support Modifications," Revision 2, February 24, 1981.
COM-23-076, " Specification for Installation of Torus Atteched
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Piping Modifications and Pipe Support Additions," Revision 0, May 27, 1982.
Quad-Cities _1 and 2 COM-09-003, " Design Specification for Torus Attached Piping
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Analysis and Modifications," Revision 0, April 14, 1982.
(For torus external piping design)
COM-01-749, " Design Specification for Suppression Chamber
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Internal Piping and Piping Support Modifications," Revision 2, January 30, 1981.
COM-24-085, " Specification for Itscallation of Torus Attached
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Piping Modifications and Pipe Support Additions, Quad-Cities Station 1 and 2," Revision 0, July 1, 1982.
Due to the lack of available inspection time, these specifications will be reviewed further during a future visit. This is considered to be an open item.
(237/82-21-01; 249/82-22-01; 254/82-17-01; 265/82-19-01)
b.
Design Interface Between Nutech ar.d EDS In discussion with responsible licensee and Nutech personnel relative to the CAL, dated July 14, 1982 conditions and require-ments, it was stated by the licensee that the subject interface work dividing lines were marked on the P & ids. However, the work interface procedures had not been developed to define the work scope, responsibilities, analytical methodologies, and line communications. The inspector expressed his concern that the interface work procedure must be established in the near future
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in order.to meet the February 15, 198) deadline to assure com-pletion of modifications on all the ESP systems. This is an unresolved item.
(237/82-21-02; 249,'82-22-02; 254/82-17-02; 265/82-19-02)
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Review of Procedures
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The. Inspector reviewed the Nutech IEB 79-14 evaluation procedure, Project Instruction, COM-PI-008, " Piping Operability Assessment,"
Revision 0, dated August 20, 1982, and had the following comments:
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Step 6:
In addition, the spectra will be' conservatively
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modified to 2% of critical damping which is more reasonable
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for SSE level loads, and is supported by USNRC Reg. Guide 1.61, Reference 4.5."
j The inspector stated changing the FSAR loading stresses of 2 x OBE to utilization of 2% damping, is equivalent to increasing the pipe stress allowables by approximatcly 100%.
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The inspector requested documentation of NRC-NRK concurrence
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to this change in stress allowables.
Appendix C Paragraph C.2.2:
For all stainless steel:
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o SSE + o DW + o press 5 2.2 o yield
The inspector stated that 2.0 a yield should be used. This was committed to by the licensee and concurred with by NRC-NRR.
This is' considered to be an unresolved-item.
(237/82-21-03;
g 249/82-22-03; 254/82-17-03; 265/82-19-03)
i d.
Review of Calculations
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The inspector reviewed the following Nutech HSP calculations:
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File No. 28.0202.1133, "RHR Pump 2C and 2D Discharge,"
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dated June 3, 1982. Areas reviewed included the modeling of Valve No. 2-1001-37-B in the computer, including:
(1) valve weight; (2) operator weight; (3) water weight; (4) operator orientation; and (5) valve physical dimension.
Review also included selection of four different segments
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of pipe runs for configuration checks.
i File No. 28.0202.10, "T-Quencher Safety Relief Valve Bubble
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Loads," dated September 29, 1981. The loadings and move-
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ments of restraint No. 568 was selected for review. The directional spring stiffness shown in the computer. output was checked against manual calculation.
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Subsequent to the review, the inspector determined that the.
measures taking in the calculation and verification control were adequate. The inspector noted that clarification on design assumptions would be helpful in improving timeliness of data retrieval.
e.
Inadequate Nutech Internal Audit Program The inspector reviewed the following Nutech Project Planning Forms:
Dresden 2 and 3 No. COM-23, " Mark I Torus - Attached Piping." The original contract date was April 14, 1977. A change order was issued on November 21, 1977.
Prior to April 2, 1982, the PPF was No. COM-09.
Quad-Cities 1 and 2 No. COM-24, " Mark I Torus - Attached Piping." The original contract date was April 14, 1977. A change order was issued on November 22, 1977.
Prior to April 2, 1982, the PPF was No. COM-11.
To assess the Nutech audit program adequacy for the above contract activities, the inspector reviewed the following Nutech internal
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audit reports:
No. 78-1, a multi-corporation (client) audit, conducted
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on January S-9, 1978. This was an audit of structural design and analysis to ensure compliance with QA manual and applicable engineering procedures and administration instructions.
No. 78-03, a multi-corporation (client) audit, conducted
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on August 17, 1978. This was an audit of mechanical, structural, and system engineering departments, and also special projects to verify compliance of Engineering Procedure QEP-006, " Project Planning."
No. COM-0000-01, conducted on January 25, 1980. This was
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an audit of the structural engineering department perform-ance on all CECO projects to verify compliance with the Nutech QA Manual.
Subsequent to the review, the inspector stated that the Nutech internal audit program was deficient in the following ways:
(1) The multi-corporate project type audits carried out at selected engineering departments would not ensure that all other projects not evaluated were in compliance with the program establishments.
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(2) There was a lack of systematic measures to ensure that all the applicable regulatory and committed technical require-ments had been incorporated and implemented in all Nutech safety related nuclear power plant design, modification, and construction projects.
(3) There appeared to be an absence of thorough and in-depth technical audits performed for all disciplinary engineering design, analyses, and calculations.
(4) Specific deficiencies in the audits were identified as follows:
Applicable documents including acceptance procedures
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had not been identified in the audit reports (No. 78-1 and No. COM-0000-01).
Documents reviewed, that were used to substantiate the
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auditor's conclusion, were not identified in the audit checklist (No. 78-1, No. 78-3, and No. COM-0000-01).
Audit checklists were not followed in their entirety, and
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no reasons were given for deviation.
(No. COM-0000-01).
Prior to the conclusion of the inspection, the Nutech QA Manager presented to the inspector an outline of the " Audit Program Improvements" areas. The inspector stated that he was in concurrence with the proposal.
Improvement areas included:
Documents examined by the auditor shall be listed in the
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audit checklists.
QA Department shall provide only general scope of the audit
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to the organization scheduled for audit.
QA Department shall document justification for any audits
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that will not be performed for any particular projects and engineer departments.
QA Department shall assure audit coverage is complete by
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the examination of QA elements, projects, and engineering disciplines.
There will be more technical audits.
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The inspector reviewed the following CECO audits of Nutech:
Program Audit No. QA-20-80-27, conducted on August 19-20,
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1980.
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Program Audit No. QA-20-82-47, conducted on July 14-15,
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1982.
The inspector concluded that the CECO audit of Nutech was inadequate in that there had been no audits performed during the period 1977 to 1979, and that the apparent Nutech QA audit program deficiencies had gone undetected by CECO..This is a violation.
(237/82-21-04; 249/82-22-04; 254/82-17-04; 265/82-19-04)
2.
Work Performed at EDS on August 26-27, 1982 a.
Excessive Seismic Restraint Gaps The subject problem was first discussed in RIII Report No. 237/82-01; 249/82-01;'254/82-01; and 265/82-01, Paragraph 3.b.
During a followup insepetion conducted on May 3-6, 1982 at EDS, 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.
The inspector reviewed the EDS preliminary document, SC-20,
" Support Gap Evaluation, IEB 79-14."
Six systems including:
(1) DGSW; (2) Recirc.; (3) FW; (4) SLC; (5) HPCI; and (6) RHR/LPCI were evaluated. The evaluation was divided into the fellowing categories:
Category 1:
IEB 79-14 walkdown inspection identified the gaps that had exceeded the original design requirements.
Subsequently, the gaps were modified to the design conditions.
Category 2:
IEB 79-14 walkdown inspection identified the gaps that had met the original large gap design require-ments, but the design basis was in doubt.
The result of the EDS evaluation showed the following:
(1) A total of 2,022 pipe restraints were reviewed.
(2)
101 restraints were classified as Category 1 items.
(3) 35 restraints with 1/4" or larger gaps were classified in Category 2 items. Most of the items were in the HPCI or LPCI systems.
The CECO representatives present committed to continue their effort to identify the rest of the large gap restraints.
Decisions will be made on whether to shim all Category 2 restraint gaps or to utilize the Zion report to determine the' acceptability of the large gaps by analytical means.
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b.
Review of HSP Piping Analysis The inspector reviewed the following'HSP piping analyses:
(1) EDS Q2-RHR-01C, RHR, Revision 1, dated March 5, 1982 Areas reviewed included:
(a) modeling of the " Link Seal" wall penetration; and (b) design output verification checks.
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No problem areas were identified.
(2) EDS Q2-LPCI-01C, LPCI, Revision 0, dated September 21, 1981 Areas reviewed included:
(a) mathematical checklist; (b) analysis checklist; and (c) equipment nozzle loading evlauation.
Subsequent to the review, the inspector stated that the increased loadings at the piping component or mechanical equipment nozzles had not been evaluated to ensure that the new IEB 79-14 loads did not exceed the manufacturer's allowables. The inspector was informed that the NRC SEP evaluation for the Dresden 2 plant included this consideration. However, the equipment evaluation for Dresden 3, Quad-Cities 1 and 2 had not been initiated. The licensee committed to establish plans and schedules for such
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reviews prior to the inspector's followup inspection. This is an unresolved item.
(237/82-21-05; 249/82-22-05; 254/82-17-05; 265/82-19-05)
c.
Review of USP Support Calculations The inspector reviewed two sets of rigid restraint calculations in the D2-LPCI-01C system:
(1) M-1164D-146, Revision 1, dated Imgust 6,1982 and M-1164D-147, Revision 1, dated August 9, 1982.
(Replaced Guide 1514-6, Revision 0, dated April 30, 1982 because the U-bolt had exceeded the manufacturer's rating.)
(2) M-1164D-138, Revision 0, dated April 7, 1982 and M-1164D-139, Revision 0, dated April 7, 1982.
(Repisced Guide 1514-17, Revision 0, dated April 7, 1982 because of the disqualified U-bolt.)
Areas reviewed included:
(a) summary of design loadings; (b) resolution of multiple directional loads; (c) maximum offset per manufacturer's recommendation; (d) anchor bolt prying action consideration; (e) concrete expansion anchor bolt minimum t
embedment length check; (f) bolt tension and shear interaction
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o calculation; and (g) beam formula condition assumption and selection.
No items of noncompliance or deviations were identified.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. The unresolved items disclosed during this inspection are discussed in Paragraphs 1.b, 1.c, and 2.d.
Open Items Open items are matters about which additional inspection effort is planned.
This is due to unavailabilitv of review time at the site. The open item assigned in this report is discussed in Paragraph 1.a.
Exit Interview The inspector met with licensee representatives at the conclusion of the inspection. The inspector summarized the scope and findings of the in-
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spection. The licensee r2presentatives acknowledged the findings reported herein.
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