IR 05000237/1988021
| ML17202G499 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 06/08/1989 |
| From: | Danielson D, James Gavula NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202G498 | List: |
| References | |
| 50-237-88-21, 50-249-88-22, 50-254-88-23, 50-265-88-23, IEB-79-02, IEB-79-2, NUDOCS 8906270224 | |
| Download: ML17202G499 (7) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
- Reports No. 50-237/8802l(DRS); 50-249/88022(DRS);
50-254/88023(DRS); 50-265/88023(DRS)
Docket Nos. 50-237; 50-249; 50"'.' 254; 50-265 Licenses No. DPR-19; DPR-25; DPR-29; DPR-30 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Names:
Inspection At:
Dresden Station, Units 2 and 3 Quad Cities Station, Units 1 and 2 Sargent and Lundy Office, Chicago, Illinois Nutech Engineers Office, Westmont, I 11 i noi s Inspection Conducted:
August 24-25, 1988 at Nutech
.
~January 24-25, 1989 at Sargent and Lundy ay 22-23, 1989 at Nutech
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_Inspect
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Approved By:
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0: H. Danielson, Chief Materials and Processes Section*
Inspection Summary Date Inspection from August 24 1988 through Ma7 23, 1989 (Reports No. 50-237/88021CDRS); No. 50-249 88022(DRS); No. 50-254/88023(DRS);.
No. 50-265/88023(DRS))
Areas Inspected:
Special safety inspection of licensee action and previously identified noncompliances (92702). *
Results:
No violations nr deviations were identifie *
Both the Piping Configuration Verification Program and Flued ~ead Anchor Program were very comprehensive in scop *
Both efforts were well organized with adequate prioritization to
- address safety significanc n*-:*--:*4 F'[R
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- DETAILS Persons Contacted Commonwealth Edison Company (CECo)
- R. Stols, Nuclear Licensing Administrator
- D. Wilgus, Nuclear Engineering Department
- P. Manning, Design and Construction Program Specialist S. Javioan, Principle Engineer R. Mirochna, Supervising Engineer I. Johnson, Nuclea~ Licensing Administrator Nutech Engineers
- B. Whiteway, Project Manager
- T. Mitoraj, ~roject Mahager
- J. Attwood, Project Engineer Sargent and Lundy Engineers (S&L)
8. Erler, Assistant Manager Structural Department P. Gazda, Structural Project Engineer P. Bhatt, Supervising Design Engineer NRC
~ Reactor Reg~lation (NRR)
B. Siegel, Project Manager A. Lee, Mechanical Engineer Brookhaven National Laboratory (BNL)
K. Banyopadhyay, Engineer
- Denotes those attending the exit meeting May 23, 198 ) Licensee Action on Previous Inspection Findings (92702)
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(Closed) Violation (237/87006-lC; 249/87011-lB; 254/87028-lB; 265/87028-03):
Supports designed as part of the Mark 1 torus attached piping modifications wer~ not installed in accordance with the specified drawin~ *
The letters of response from CECo dated September 24, 1987 and April 21, 1988, were reviewed and determined to be acceptabl The NRC inspector examined the corrective actions stated in the letters of response and concluded that the full extent of the violation had been determine Also the necessary corrective actions to preclude recurrence had been implemented.* See Paragraph 3 of this report for
. additional discussions on the closure of this violatio *
2 (Closed) Violation (237/87006-2B; 249/87011-2B; 254/87028-02B; 265/87028-02B):
Design calculations for the Mark I torus attached piping modifications were not adequately checked and verifie The letters of response from CECo dated September 24, 1987, and April 21, 1988, were reviewed and determined to be acceptabl The NRC inspector examined the corrective actions stated in the letters of response and concluded that the full extent of the.violation had been determine Also the necessary corrective action to preclude recurrence had been implemente See Paragraph 3 of this report for additional discussions on the closure of this violatio (Closed) Unresolved Item (237/87030-01; 249/87029-01; 254/87028-05; 265/87028-05):
Design and installation discrepancies were found on flued head anchor structure *
Based on the technical concerns delineated in the above violations, CECo committed to implement a comprehensive six point program t demonstrate the adequacy of the flued head anchor (FHA) structures at Quad Cities and Dresde The following issues were addressed by the program:
(1) All anchors which utilize concrete expansion anchors (Quad Cities station only) will be reassessed to ensure compliance with NRC I.E. Bulletin 79-0 (2) All anchors affected by the Dresderi recirculation p1p1ng replacement program will be reassessed for pipe break load (3) The two anchors modified in conjunction with the Quad Cities bellows replacement program will be reassessed for pipe break 1 oad (4) Those anchors which showed configuration discrepancies of such nature that assessment had to be performed when examined during the January 1988 Dresden and Quad Cities configuration walkdown; will be reassessed. for OBE, SSE, and pipe break load (5) Based on the results of the configurati6n variation as~essment (4 above), a decision will be made by CECO concerning conducting configuration walkdowns of the remaining anchors at the Dresden and Quad Cities station (6) Technical comment.s concerning the original flued head anchor design calculations which were made by the NRC will be addressed during reassessment The decision reached in item (5) above, was to perform configuration walkdowns for all FHAs at both Dresden and Quad Citie This conclusion was due to the number of discrepancies encriuntered during the initial configuration walkdown The types of discrepancies eventually disclosed during these walkdowns were as follows:
- Brace member orientation
Member substitution
Partial thread engagement of anchor bolts
Minor member mislocation
Anchor bolt spacing variations
Missing members
Missing shear connection pins
Missing stiffener plates and welds
Thru-bolt and anchor plate mislocation
Connection fabrication deviations
Cut or spliced member The NRC inspector accompanied an NRR team during a follow-up audit at S&L on January 24 and 25, 198 The results of this audit were documented in a Safety EvaluatiOn (SE) contained in correspondence from D. Muller (NRC) to T. Kovach (CECo) dated May 15, 198 The conciusions drawn in the SE were that 11 CEC0 1s FHA program has been adequately defined and is being properly implemented."
In addition to.the calculations reviewed in the SE, the NRC inspector reviewed the following FHA calculation/documents:
- Calculation No. 8188-116A-D2, "Dresden Unit 2, Penetration l16A,
Revision 0, January 24, 198 Calculation No. 8188-123-D3,
"Dresden Unit 3, Penetration 123,
Revision 1, December 20, 198 Engineering Change Notice No. D88S-26, Repair Flued Head Anchor X-116A, Dresden Unit 2, 11 dated August 9, 198 This change installed eight lar~er anchor bolts and shim plates between the process pipe, guard pipe and nozzle of the flued hea No violations or deviations were identified during these review Based on the above inspections, this item is considered close.
Piping Configuration Verification Program (PCVP)(37701)
Follow1ng the discovery of multiple discrepancies between the as-built and as-analyzed configurations for the 11A 11 Core Spray System at Dresden Unit 2, CECo implemented a comprehensive Piping Configuration Verification Progra Details of this program and other background information are contained in NRC Inspection Report 50-237/87006; 50-249/8701 At the inception of the program, the completion date was estimated to be the end of 198 Due to the nature and numbe~ of the discrepancies encountered which required complete re-analysis efforts, the program extended well into 198 During this*time CEGo initially submitted bi-weekly and eventually monthly status reports to the NR These reports summarized pro~ress in the program and listed modification drawings issued as a result of the re-analysis and reconciliation effort **
In August 1988, the NRC inspector was contacted by CECo and informed that the PCVP had been complete During the subsequent inspection, the following documents were reviewed:
Nutech Project Plan, "Piping Configuration Verification Program
Revision-1_,. July 31, 198 *
Nutech Instruction, 11Second Level Screening Criteria,i 1 CEC-99-014, Revision 2, June 25, 198 *
Nutech Instruction, 11 Piping Configuration Verification Operability and FSAR Compliance Criteria, 11 CEC-99-017, Revision 2, July 24, 198 *
Nutech Instruction, 11 Piping Configuration Verification, 11 CEC-99-007, Revision 1, June 25, 198 *
Nutech Project Instruction, "Control and Documentation of Field Survey Data for Use as Design Input, 11 COM-PI-003, Revision 6, April 27, 198 *
Nutech Calculation No. 28.0202.1111-47, "Quad Cities Unit 2 RHR 2 CID Discharge, 11 Revision 1, August 1, 198 *
Nutech Calculation No. 29.0201.0804, "Dresden Unit 2 LPCI Discharge.
Dresden/Quad Cities Structural Atta~hment Interface Requi~ement with S&L, 11 TI-018, Revision 0, May 27, 198 *
Nutech 11Corrective Action Report, CAR No-. 87-01 (NEC), March 23, 198 The following comments/concerns were expressed by the NRC inspector:
- Instruction and procedures were well state Walkdown data and walkdown documentation appeared to be of excellent qualit Project planning and prioritization appeared to be excellen Interfaces with other consultants as required by the Flued Head Anchor Program and Embedded Plate Program appeared to be well controlle The corrective action ~eport by Nutech which would address the 10 CFR Part 21 aspects was not closed out and wasn't scheduled to be completed until October 198 Although all of the analyses were completed, the root causes-and trending of the sighificant discrepancies had not yet been determined.
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- Although the PCVP was identified as corrective action in the response to. an NRC violation, no CE Co Quality Assurance audits or survei 11 ances had been performed to verify the implementation of this specific corrective actio Although CECo stated in the response to the violation that 11 implementation of the new modification program... should preclude the recurrence of similar events...,
11 the work associated with the PCVP was not considered as a modification and was not performed under the new progra Due to the above concerns, the NRC inspector did not consider the PCVP ready to be closed at that time and asked the licensee to address these concern An' additional inspection of the PCVP was conducted in May 1989 after the final status report was issued in correspondence from R. St6ls (CECo) to A. Davis (NRC) dated March 31, 198 This was four months later than the projected issuance date of December 1, 1988, originally given by CEC In addition to the final summary report, the following calculation/documents were reviewed by the NRC inspector *
Nutech Stress Report No~ CECo 94.0280, 11 Dresden Unit 2 Model D2.08
March 25, 198 *
Nutech Calculation No. 29.0201.0811-11, "Support M-3208-08,"
Addendum 3, October 16, 1987.
Nutech Calculation No. 29.0201.0811-031 "Su.pport M-3208-03,"
Addendum J, October 15, 198 *
Nutech Calculation No. 28-0202.0734-:-01, "Quad Cities Unit 2, Model Q2.07."
- Nutech Calculation No. 28.0202.0711-21, "Support M-1807-21."
- Nutech Calculation No. 28. 0202. 0711-05, "Support M-1807-0 *
Nutech Corrective Action Report, No. CAR-87-01 (NEC) closed out in December 22~ 198 No violations or deviations were noted during these review After reviewing the final summary report, the NRC inspector noted that all of the significant discrepancies between the as-built and as-analyzed configurations were adequately trended and root causes determine Based on the results of this trending, in conjunction with additional reviews of other work, CECo concluded that there was no need to expand the program to other architect-engineers or perform more comprehensive walkdowns of structures modified during the original progra The NRC inspector concurred with this conclusion.
- Also, even though CECo had not verified the specific corrective actions associated with the PCVP, other QA audits and surveillances had been performed on similar projects during CEC0 1s yearly audit schedul While this was not considered by the NRC inspector as an optimum approach to ensure implementation of specific corrective action associated with the PCVP, it was considered sufficient..
Finally, although the work associated with the PCVP was not considered a 11modification 11 and therefore was not required to meet the 11 letter 11 of the new modification program, the significant portions of the new program were incorporate Partial justification for this approach was based on uncertainties associated with implementation of the new modification*.
proces These uncertainties could have delayed the completion of the required changes under the PCV Since the intent of the new modification program was incorporated into the PCVP, the NRC inspector corisideted this approach adequat The only comment made during the inspection was the apparent lack of timeliness in issuing the final report in light of the licensee's previous statement that the work was completed in August of 198 The PCVP can be considered closed; however, it should be noted that as a result of the reanalyses performed under this program, a number of small bore torus attached piping systems will require reanalysi.
Exit Interview The Region III inspector met with the licensee representatives (d~noted in Paragraph 1) at the conclusion of the inspection on May 23, 198 The inipector summarized the purpose and findings of the inspectio The licensee representatives acknowledged this informatio The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspectio The licensee representatives did not identify any such documents/processes as proprietary.
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