IR 05000318/2009016

Safety Insp Rept 50-440/85-16 on 850318-0916.Violation Noted:Failure to Control Design of Pipe Supports

ML20137Y345
Person / Time
Site:	Calvert Cliffs, Perry
Issue date:	10/02/1985
From:	Danielson D, Jeffrey Jacobson, Kaufman P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137Y330	List: IR 05000318/2009016 ML20137Y325 ML20137Y332
References
50-440-85-16, IEB-79-14, IEIN-85-019, IEIN-85-19, NUDOCS 8510070307
Download: ML20137Y345 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/85016(DRS)

Docket No. 50-440 License No. CPPR-148 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, Ohio 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 i

Inspection At: Perry Site, Perry, Ohio Inspection Conducted: March 18-22, July 23, 24, and September 9-12 and 16, 1985

&. b< m, Inspector: P. D. Kaufman /O-/-85 Date wNy

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Date Approved By: D. H..Danielson, Chief /e 2yjPJ-

, Materials and Processes Section Date j Inspot.tio, Summary I

Inspection on March 18 - September 16, 1985 (Report No. 50-440/85016(DRS))

! Areas Inspected: Routine, unannounced safety inspection of the implementation i of actions set forth in IE Bulletin 79-14 and licensee actions on previously

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identified items. The inspection involved a total of 97 inspector-hours onsite by two NRC inspectors.

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Results: Of the areas inspected, one violation was identified (failure to f control the design of pipe supports - Paragraph 5.b).

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DETAILS Persons Contacted Cleveland Electric Illuminating Company (CEI)

• • E. Riley, General Supervisor, Construction Quality Services K. Kaplan, Senior Engineering Technician J. Wilcox, Lead Piping / Welding Engineer J. Carson, Inspector K. Warnock, Licensing Engineer

• J. Lehman, Staff Analyst

• Liddell, Operation Engineer

• Pect., General Supervisor Engineer

• Matthys, Lead Piping /I&C

• Parker, P/M Unit Supervisor

• Ainorelli, Lead QE

• McKenzie, Licensing Engineer

• Tulk, Supervisor Electrical Gilbert Associates, Inc. (GAI)

D. Weaver, Program Manager W. Crosby, Inspector

• J. Ioannipi, Site Project Manager

• P. Wright, Welding and Materials Engineer

• C. Angstadt, Site Support Coordinator R. Shanmugasundaram, Lead Site Piping Analyst A. P. Jones, Licensing Engineer Kaiser Engineering, Inc. (KEI)

C. Dille, Qualtiy Engineer L. Erbacher, Inspector The inspectors also contacted and interviewed other licensee and contractor employee * Denotes those attending the onsite management exit meeting on September 12, 198 ** Denotes those telephonically contacted on September 16, 1985, for the final exit intervie . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (440/84-03-02; 441/84-03-02): Further review required of GAI detailed stress calculations for integral attachments welded to a Class 2 Residual Heat Removal System process pipe. Two integral attachments (lugs) were added per ECN 18187-44F-6123. The ECN was issued for pipe support IE12-H322.

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% A review of_ analysis.for sub-system 1E12-G12(B) at Node Point 115

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revealed that the piping stresses at the lug. attachments were within Code allowable stress limits for Class 2 and 3 pipin ,

' (Closed) Unresolved' Item (440/82-09-08; 441/82-08-08): Questionable

. site design change control measures. Four of the five issues identified were closed in RIII Inspection Report No. 50-440/82-12;

. ~50-441/82-11. The remaining issue was for GAI to further

' clarify Appendix-0 of GAI' Project Procedures Manual, with respect to the provisions on handling the review of non-safety related portions of systems which could affect safety-related system operations. Appendix-0 revision, dated June 30, 1983, was issued to

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resolve this matter. Section 2:04 of this Appendix requires that GAI

{ Field Engineers review non-safety related Field Questions to assure

'that they do not affect any safety systems or component '

_(Closed) Unresolved Item (440/82-09-07; 441/82-08-07)

t Documentation packages for ECNs require further review of backup calculetions and work interface between site and corporate staf A total'of five pipe support ECN documentation packages and calculations were compiled in GAI's corporate office and transmitted to the s'te for the NRC inspectors' review. These five supports were

. field ver.'fied during ;5e inspectors as-built walkdown. Some of the documentation packages contained field issued ECNs, which were then

' forwarded to GAI's c;rrorate office for their overview and concurrence. All f:ia of the packages had gone through GAI's final

as-built verification pieg am. ;The LCNs matched the as-installed support' configuration and tne;- backup calculations coincided with the. latest design change '

d .' -(Closed) Violation'(440/83-31-03; 4s'/83-3t-03): Seismic pipe supports / restraints, in some cases, hu e.not been constructed and inspected in accordance with design equii9ments. Additionally, the as-built: verification program failed te identify.these discrepancies between installed items and design drawings. To improve the overall as-built program, the folh. vin.: steps were

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(1) Pullman Power _ Products (PPP) revised Prc edure X-24, which incorporated ECN 7501-44-732, Revision D, to fur'her clarify

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the requirements for submittal of as-built informat:or, '2) Project Administration Procedure PA-0303, Revision 2, was iss."1 no cler-ly define and. control the QA verification of as-built urv ii.r ., and (3)-ECN'17391-44-5724 was issued to require verification of valve orientation and directional flow at fit-u Inspection of

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this valve orientation attribute will be accomplished during t '

Phase'I piping _ inspection. A review of the improved as-built pro s/am

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was conducted and is documented in Paragraph 4 of this repor P (Closed) Violation (440/85043-01(a-d)(DRS)): Failure to adequately

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l control the welding process'as performed by L. K. Comstock, the electrical contractor. Specific examples previously identified and-their resolution during this inspection were as follows:

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(1) The welding procedures did not adequately control the selection of electrode typ Inspection Reports 17830, 18726, 19141, and Nonconformance Reports 6355 and 6443 were generated by Comstock to review and resolve this issue. A review of all electrode withdrawal slips indicating the use of E 6013 electrodes was performed. The review indicated that a smali percentage of withdrawal slips had unclear information as to the location of electrode usage in the plant. Tensile tests on available heats of electrode were performed as well as a review of electrode Certified Material Test Reports. This test information indicated that all heats of E6013 electrode exceeded 70 KSI in tensile strength. Thus the inadvertent use of E6013 electrode for building structural attachments was of no design significance. Comstock Welding Procedure 4.7.1, Revision July 5,1985, has been revised to specifically limit the use of E6013 electrodes to cable tray welds. In addition, Procedure 4.8.18, Revision July 5,1985, now requires the QC inspector to verify filler metal type during the fit-up hold point. The NRC inspector reviewed all documentation related to this issue and agreed witn tiie invluiion of this ite (2) The welding procedures did not reflect preheat requirements with regard to electrode selection and thickness of materia Comstock requested from Construction Engineering, a list by area of all embed plates with thickness greater than 1 ".

Attachment to plates in this thickness range require preheat per AWS D1.1 Code. A walkdown of plates on this list was conducted to determine if any electrical supports were welded to these plates without preheat being documented. This walkdown, documented on Inspection Report SE-3963 resulted in the issuance of 18 Nonconformance Reports (NCRs).

Comstock proceeded to perform AWS D1.1 Code weld procedure qualification tests using E6013 and E7018 electrodes on base metal 1 " and 2 " thick respectively at a temperature of 34 These qualification tests were successful and documented on Comstock NCRs 6267 and 6268 and Inspection Reports SE 3966 and SE 3968. These tests technically justify using the welds performed without preheat "as-is." Comstock Welding Procedure 4.7.1, Revision July 5, 1985, was revised to specifically delineate preheat requirements. In addition, Procedure 4.8.18, Revision July 5,1985, now requires the QC inspector to verify preheat requirements prior to fit-up. The NRC inspector reviewed all documentation related to this issue and agreed with the resolution of this ite (3) The welding procedures did not control fillet weld size and heat input as required for prequalified status. Comstock proceeded to perform AWS D1.1 Code weld procedure qualification tests for the smallest multi pass weld used in productio Inspection Report SE 3969 and Weld Procecure Qualification

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Reports A48 through A55 document the test results. These tests simulated the most severe field conditions with regard to minimum size multi-pass fillet welds used. All tests were reviewed by the NRC inspector and were found to be acceptabl Comstock revised Procedure 4.7.1 (Revision July 5, 1985) to include the additional qualification tests. This qualification testing is considered an acceptable resolution of this ite (4) The welding procedures were not properly qualified with regard to position, material, and thickness limitations. Comstock proceeded to perform the necessary qualification tests per

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AWS D1.1 Code to support the welding procedure 4. The NRC

+ inspector reviewed the following qualifications: A56-A59, A65-A68, A69, A71-A73, A75, and A76. All qualifications met the acceptance criteria of AWS D Although the base metal thickness information was omitted from Qualifications A37, A38, and A39, the information was found on other related test documentation. The revised qualifications indicating the correct welding positions and thickness l

limitations were incorporated into Welding Procedure 4.7.1, Revision July 5, 1985. Comstock NCR 6269 was issued for not having an approved qualification test record (WPQR) for welding over galvanized surfaces with E6013 electrode. A qualification test was performed and documented on WPQR A74. Comstock Welding Procedure 4.7.1 was revised to state that "All galvanizing shall be removed prior to welding."

The NRC inspector reviewed all documentation associated with this violation and considers the corrective action to be acceptabl . Licensee Action on IE Bulletins (Closed) IE Bulletin 79-14, Revision 1, Revision 2, and Revision 3 (440/79-14-88,440/79-14-18,440/79-14-2B,440/79-14-3B): " Seismic Analysis for As-Built Safety-Related Piping System." The licensee les responded to the bulletin, and the bases for closure of the bulletin is contained in Paragraph 5 of this repor . Licensee Investigation of IE Information Notice No. 85-19 In an effort to assure that discrepant materials were not received and installed in the Perry Nuclear Power Plant (PNPP), the licensee contacted suppliers who, due to geographic location, may have received material from the Familian Northwest Company (FNC). Correspendence from three of the four west coast vendors indicated that no material had been supplied to the PNPP from FNC. One vendor, Bingham-Willamette Company (BWC),

indicated that nuclear grade parts had been purchased from FNC and supplied to the PNPP as part of completed assemblies. Licensee review of

documentation for eight BWC pumps showed that five items procured from FNC were installed in each of these pumps. No detailed documentation had been provided from the material manufacturer for these items, only Certificates of Conformance were provided by FN _ _ - _ _ ___ __ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The licensee requested BWC to obtain the Material Certifications from the material manufacturer (Standard Fittings Company) through FNC. The Certified Material Test Reports that were obtained from the Standard Fittings Company for the fittings verified that correct material had been installed. A review conducted by the licensee demonstrated that the Standard Fittings Company had been properly audited by FNC and approved as a material supplier. Based on their evaluation, the licensee considered the matter closed as of August 19, 198 The NRC inspector's review of the documentation related to closure of this issue identified no violations of NRC requirement . IE Bulletin 79-14 Activities The implementation and verification of the licensee's as-built program as related to IE Bulletin 79-14 requirements for safety-related Seismic Category I piping systems was examined. Attributes reviewed essential to the seismic piping stress analysis included: piping configuration; pipe support / restraint locations, design, function, and clearances; and valve and valve operator locations and orientation. Assessment of these attributes was required to verify that the plant's safety-related piping systems were constructed and analyzed in accordan:.e with the final design documents / requirement Review of Walkdown and Engineering Evaluation Procedures Procedures, specifications, and instruction drawings relative to the generation and reconciliation of IE Bulletin 79-14 Walkdown Packages reviewed by the inspector included:

Pullman Power Products (PPP) Procedure X-24, " Procedure for As-Built Piping Systems and Components," dated July 29, 198 PPP Procedure IX-6, " Installation and Inspection of Pipe Supports," dated October 15, 1984.

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PPP Procedure VI-4, " Pipe Support Drawing and Documentation

! Control," dated July 16, 198 PPP Procedure III-4, " Drawing and Design Control," dated October 25, 198 PPP Procedure X-4, " Final Inspection (Field)," dated November 28, 198 Gilbert Associates, "GAI Job Notes for 79-14 Walkdown Program," Revision _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ - _ _ _ _ - .

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CEI Project Administration Procedure 0303, "As-Built Drawings," Revision CEI Instruction-Nuclear Design 35-0303, " Review of As-Built Drawings," Revision GAI Appendix AA, " General Procedure for IE Bulletin 79-14,"

dated February 18, 198 Gilbert Drawing, 4549-5-322-002, " Pipe Support Dimensions and Tolerances," Revision GAI, Project Pipe Stress Analysis Instructio The procedures were determined to be consistent with regulatory requirements and licensee commitments relative to IE Bulletin 79-14,

" Seismic Analysis for As-Built Safety-Related Piping Systems."

No violations or deviations were identifie b. Safety-Related As-Built Piping System Walkdown Sections of piping systems were randomly selected for assessing the adequacy of the licensee's as-built walkdown inspection and design verification program. The inspector's review encompassed subsystem l as-built packages from the following five safety related piping '

systems:

System Number System Title G41 Fuel Pool Cooling and Cleanup System (FPCC)

E21 Low Pressure Core Spray System (LPCS) *

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E2 Residua's Heat Removal System (RHR)

L:,1 Reactor Core Isolation Cooling System (RCIC)

PS3 Penetration Pressurization System The as-built subsystem packages weta comprised of, but not limited to, the following documents / drawings:

• GAI Support Design Drawings

• Contractor Field Hanger Records (FHRs)

• Contractor Piping Isometric Drawings

• Contractor or Project Organization generated Nonconformance Reports (NCRs)

• Vendor Support Drawings (SFS Drawings)

• GAI Physical Piping Drawings (304 series) and P& ids (302 series)

• GAI Analysis Isometric Drawing and site generated "SK-F" isometric drawings

• All design change documents - (ECNs, FVAs, FHCs, and FQs)

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The inspector performed field walkdowns of the following as-built documentation / drawings selected from the above safety-related piping systems:

Pipe Support / Restraint Drawing Sample 1G41-H142 1E21-H031 1E12-H584 1G41-H145 1E21-H021 1E12-H583 1G41-H150 1E21-H051 1E12-H585 1G41-H183 1E21-H024 1E12-H586 1G41-H495 1E21-H025 1E12-H759 1G41-H155 1E21-H026 1E12-H588 1G41-H149 1E21-H027 1E12-H589 1G41-H148 1E21-H028 1E12-H762 1G41-H151 1E21-H050 1E12-H591 1G41-H154 1E21-H029 1E12-H590 1G41-H153 1E21-H080 1E12-H754 1G41-H147 1E21-H030 1E12-H756 1G41-H146 1E21-H032 1E12-H757 1G41-H144 1E12-H755 1G41-H182 1E12-H592 1G41-H143 1E12-H593 1E12-H582 1E12-H761 1E51-H032 1P53-H3046 1G41-H404 1E51-H005 1P53-H3048 1G41-H401 1E51-H004 1P53-H3049 1G41-H400 1E51-H031 1G41-H460 1E51-H140 1G41-H422 1E51-H003 1G41-H453 1E51-H035 1E51-H034 Piping Isometric Sample 0G41-31, Revision 20 1E21-4, Revision 13 1E51-6, Revision 21 OG41-36, Revsiion 12 1E51-5, Revision 15 1E12-45, Revision 31 Process & Instrumentation Diagram (P&ID) Sample D-302-631, Revision E-6" pipe from Penetration P101 to RCIC pump E51-C00 D-302-705, Revision H-24" pipe from Penetration P103 to LPCS pump E21-C00 D-302-641, Revision C-6" pipe from Penetration P429 to D-302-642, Revision G-6" relief valve F-055 D-302-655, Revision D-4" pipe from surge tank "B" G41-A0028 to pipe support anchors G41-H422 and G41-H40 _ _ __ _ _ _ _ _ _ _ _ _ _ _

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GAI Analyis Isometric Sample SK-F-1G41-G55 Sheet 1 of 1, Revision 3 SK-F-1E21-G01 Sheet 1 of 1, Revision 1 SK-F-1E51-G05 Sheet 2 of 4, Revision 1 SK-F-1E12-G25 Sheet 8 of 10, Revision 1 SK-F-1G41-G58 Sheet 1 of 1, Revision 1 In general, the installed / erected piping runs and suppor M inspected were found to be constructed in accordance with the applicable design and procedural requirements for the attributes verifie iowever, in a few cases, the contractor's generated Field Hanger Records (FHR), which are listings of all applicable design documents utilized during the erection / fabrication process for pipe supports, were incomplete. Because of this deficiency, the licensee issued Action Request (AR-0923) against the contractor, Pullman Power Products (PPP). PPP will reinspect 100 completed pipe supports to assure that all design documents are noted on the FHRs and the installed supports agree with the current design, documentatio In addition, while conducting the as-built verification walkdown the NRC inspector observed an installed small bore safety related ,

pipe support on a Penetration Pressurization System process pipc, whose structural attachment points were located on two independent building structures. The structural frame for pipe support 1P53-H3054 was interconnecting the Intermediate Building to the  !

exterior shield wall of the Reactor Buildin I The licensee was requested to compile the latest design /

installation documentation relative to this particular pipe support. ECN 23205-44-7687, Revision B, war, the current design change which had been stamped " Final As-Built" and the l support design matched the as-installed configuration.

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The licensee was then queried as to whether GAI had accounted for the stresses from the differential seismic movement of the l two independent buildings in their final as-built pipe support reconciliation. The inspector was informed that the calculation

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had not accounted for the stresses due La the relative building displacement The inspector requested the licensee evaluate the support fraine due to the additional loads and stresses created by the relative building movements and determine the possibility of a reportable even GAI's evaluation indicated, through conservative hand calculations, that allowable stresses would be exceeded. However, due to the conservative assumptions (ignoring member, plate, and bolt flexibility) they concluded the support would remain functional under the adverse loading condition. Thus, the condition was considered not reportabl ___

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The licensee was informed that failure to adequately verify plant design to cesign requirements, as specified by GAI, " Project Pipe Stress Analysis Instructicn," is a violation of Criterion III of 10 CF' 50, Appendix B (440/85016-01).

c. Pipe Suppor: As-Built Reconciliation During review and walkdown of the as-built pipe support drawings /

calculations by the NRC inspector, the following observations were made:

(1) It was observed that fillet weld end returns were not being made in the field nor were they being indicated on the support design drawings, for connections about which bending moments are computed. ASME Boiler and Pressure Vessel Code Subsection ,

NF3324.5(d)(8)andAppendixXVII-2457.8bothstatethat

"whenever practicable" side and end fillet welds terminating at ends or sides, of parts or members shall, be returned continuously around the corners for a distance not less than twice the ncminal size of the wel The licensee has submitted a letter dated May 13, 1985, to the ASME Boiler and Pressure Vessel Committee asking for a Code interpretation of fillet weld end return The ASME Code Committee has yet to respond to the licensee's inquiry. This response will be reviewed during a subsequent inspectio (2) After reviewing the licensee's proposed Code interpretation of fillet weld end returns, the NRC inspector queried GAI's Site Support Coordinator as to how GAI's pipe support design engineers analyze weld joint configurations. His response '

was that all welded joint connections were analyzed as " fixed."

A review of calculations for pipe supports 1E12-H760 and 1G41-H149 were inconsistent and lacked uniformity with respect to the design assumptions used in analyzing the welded joint configurations. This inconsistency was even denoted internally within the calculations between the design originator and the verifier. The licensee was requested to select a random sample of pipe support calculations which were analyzed as " pinned" connections and perform a reanalysis of these connections as

" fixed."

The results of the above actions by the licensee will be reviewed during a subsequent inspection as will the procedures which control the design input process. The above two matters are considered to be an unresolved item (440/85016-02).

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. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph 5- . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the onsite portion of the inspection and discussed the scope and concerns of this inspection. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during this inspectio The licensee did not identify any such documents / processes as proprietar Additional information was discussed tele ~ phonically with a licensee representative (denoted in Paragraph 1) on September 16, 198 .

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