IR 05000373/1980020

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IE Insp Repts 50-373/80-20 & 50-374/80-13 on 800401-03 & 08. Noncompliance Noted:Inadequate Design Control,Lack of Work Procedures & Lack of QA Audits
ML19323J102
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 04/22/1980
From: Danielson D, Yin I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19323J087 List:
References
50-373-80-20, 50-374-80-13, NUDOCS 8006170774
Download: ML19323J102 (6)


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T U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-373/80-20; 50-374/80-13 Docket No. 50-373; 50-374 License No. CPPR-99; CPPR-100 Licensee:

Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: La Salle County Station, Units 1 and 2 Inspected At: Reacter Controls Inc., San Jose, CA Earthquake Engineering Systems, San Francisco, CA UShTC Region III, Glen Ellyn, IL Inspection Conducted: April 1-2, 1980 at RCI April 3, 1980 at EES April 8, 1980 at USNRC RIII

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Inspector:

I. T. Yin Mw b

Approved By:

D. H. Danielson, Chief

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Engineering Support Section 2 Inspection Summary Inspection on April 1-3, 1980 (Report No. 50-373/80-20; 50-374/80-13)

Areas Inspected:

Inspection of Control Rod Drive (CRD) suspension system design including design control, documentation, and audits of work imple-mentation. The inspection involved a total of 20 inspector-hours at the licensee contractor office and at RIII office.

Results: Of the areas inspected, three apparent items of noncompliance were identified.

(Infraction - inadequate design control - Paragraph 2; infraction - lack of work procedures - Paragraph 3; infraction - lack of QA audits - Paragraph 8).

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DETAILS Persons Contacted Inspection at Reactor Controls, Inc. (RCI) on April 1-2, 1980 Commonwealth Edison Company (CECO)

S. R. Dileto, Engineer RCI R. D. Millett, President R. Weitenstein, Engineer and Construction Manager R. K. Crum, QA Manager R. Kananen, Assistant QA Manager D. W. Hill, Project Engineer A. S. Nelson, Project Engineer A. Vonstockhausen, Stress Analyst Inspection at Earthquake Engineering Systems, Inc (EES) on April 3, 1980 Ceco S. R. Dileto, Engineer RCI D. W. Hill, Project Engineer

.R. Kananen, Assistant QA Manager EES N. Chauhan, Vice President E. Van Stigjeren, Vice President H. Suryoutoro, Associate R. E. Hamati, Associate Exit Meeting at RIII Office on April 8, 1980 CECO

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G. F. Marcus, Director of QA, Engineering and Construction J. T. Westermeter, SNED J. T. Merwin, SCD G. Sorensen, SCD R. Tuetken, SCD R. Cosavo, SCD J. T. McIntire, QA J. P. Woods W. F. Naughton, Nuclear Licensing-2-

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I A. W. Kleinrath, Station Construction, G.O.

L. C. Bird, Station Construction, G.O.

B. J. McAndrew, Station Construction, La Salle B. Annis, Station Nuclear Engineering, G.O.

USNRC -RIII 1. T. Yin, Reactor Inspector D. W. Hayes, Section Chief D. H. Danielson, Section Chief J. E. Konklin, Reactor Inspector G. Fiorelli, Branch Chief J. Neisler, Reactor Inspector C. E. Jones, Reactor Inspector Functional or Program Areas Inspected This inspection at RCI and EES is as a result of questions identified relative to the acceptability of the CRD suspension system design and installation (373/80-12-06; 374/80-08-06).

1.

Review of Design Documents The inspector reviewed the following documents:

a.

S&L Specification J-2922, " Reactor Internals Installation and Control Rod Drive System Erection," Revision CA, dated September 13, 1976.

b.

Form 350-B of the Specification J-2922, " Standard Specification for Seismic Qualification Criteria for Category I (Essential)

Equipment Installed in Nuclear Power Plants."

c.

S&L Specification DS-RD-01-LS, " Certification of Design Speci-fication for CRDHS," Revision 0, dated December 16, 1976.

d.

S&L "SRV/LOCA Hydrodynamic Loads Revised Design Basis Summary Report," dated December 3, 1979 - No signatures of issuance, review, and approval.

e.

RCI QA Manual, Revision 4, dated November 21, 1977, Section 2,

" Design and Document Control."

f.

EES Nuclear QA Manual, Revision 5, dated April 18, 1978, Section 3.8, " Computer Programs."

g.

RCI Welding Procedure Specification (WPS) WP-100, Revision 1, dated March 4, 1980, h.

Unistrut Corporation publication on P-1000 steel and structure channel.

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RCI Drawings, LA-1015, " Unit 2 CRDHS Hangers and Restraints Outside Containment, 90' Inside," Sheets 1 to 6, Revision i dated January 26, 1979 and Sheet 7, Revision 3 dated September 6, 1979.

2.

Review of Restraint Calculations The inspector reviewed the following EES restraint design calculations at the RCI office:

Sheet B3-53, " Hanger Lesign," dated August 14, 1978, for Section G-G structure shown on RCI drawing LA-1015 sheets I and 4 using load case SL-13.

SL-13 was shown on Sheet B1-4, "CRDHS Hangers and Restraints SL-13, Outside Containment," dated October 1, 1978.

Sheet B3-11, " Pipe Hanger Review Outside Containment," dated October 9, 1978 for section A-A structure shown on RCI drawing LA-1015 sheets 1 and 2 using load case SL-14.

SL-14 was shown on Sheet B3-52, "CRDHS Hangers and Restraints, SL-14 Outside Containment," dated August 16, 1978.

Sheet B3-54, " Hanger Design," dated August 14, 1978 for Section F-F structure shown on RCI drawing LA-1015 Sheets 1 and 4, using load case SL-13.

SL-13 was shown on Sheet B1-4, "CRDHS Hanger and Re-straints SL-13, Outside Containment," dated October 1, 1978.

The inspector concluded, after discussions at RCI and EES, that:

a.

There appeared to be lack of design and acceptance criteria established for the performance of calculation. Deficient areas include lack of (1) justification for allowing the use

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of ASME Code Case 1644 material, (2) Code structural and hanger stress allowables for upset and emergency conditions, (3) de-flection or stiffness criteria, (4) hanger and structure natural frequency considerations, and (5) loading combinations for OBE, SSE, SRV, and other transient conditions.

b.

The calculations, performed by EES had not been reviewed and accepted by RCI.

c.

Design was changed by RCI subsequent to completion of calcula-tions made by EES, such as that shown in Section AA structure on RCI drawings, LA-1015 sheets 1 and 2.

The EES engineers had not been made aware of the change. Furthermore, revisions to the calculation had not been requested by RCI.

The lack of design control is considered an item of noncompliance iden-l tified in Appendix A.

(373/80-20-01; 374/80-13-01).

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3.

Review of Work Procedures In conjunction with Paragraph 1, 2.b, and 2.c above, the RCI work procedure was incomplete in that there w6s no requirement to review j-4-

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O and approve subcontractor calculations, and to systemati' ally con-trol communications relative to design information and changes. Fur-thermore, there war an apparent lack of inter-and intra-organizational structure to clearly identify authorities, responsibilities,.and work interfaces.

The lack of complete work procedures to perform safety related work

'is considered an item of noncompliance identified in Appendix A.

(373/80-20-02; 374/80-13-02).

4.

Review of EES Computer Program The inspector reviewed the EES computer program, PSA (Piping Stress Analysis), which was developed based on the SAP IV program of the University of California, Berkeley, Cal. The PSA had been verified closely with (1) ANSYS program developed by Swanson Analysis Systems, Inc., Elizabeth, Penn., (2) ADLPIPE of Arthur D. Little Company, Cambridge, Mass and (3) PIPDYN of Computer Science Corp., Los Angeles, Cal. However, there appeared to be a lack of formal control of program revisions and indication of which versions of the program are authorized

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to any specific analytical application. This is considered an unresolved

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item (373/80-20-03; 374/80-13-03).

5.

Review of EES Procedures and Personnel Qualification The inspector reviewed the work procedures contained in the QA Manual, and had no adverse comments.

In review of the qualifications for personnel performing calculations, in the areas of education, back-ground, previous work experience, professional affiliations, and in discussions and interviews, the inspector had no questions. All per-sonnel involved were permanent employees of the company.

6.

Review of RCI Welding Procedure Specification (WPS)

WPS, RCI WP-100, Revision 1, for welding the CRD Unistrut structural channels was reviewed by the inspector. Paragraph 2.1 states, " Arc welding of carbon steel shall be in Hardenability Classification Group P1 of the ASME Boiler and Pressure Vessel Code." The inspector indi-cated that clarification should be made in two areas, i.e., (1) the ap-propriate Section of the ASME Code should be writcen in the WP-100, and (2) the Unistrut material, ASTM-A570 Grade C, as specified in RCI Ma-terial Specification MS-14, Revision 0, dated January 23, 1978, is a Code Case 1644 material but is not a Subsection NF material. The welding procedure qualification should have taken this into consideration. This is considered an unresolved item (373/80-20-04; 374/80-13-04).

7.

Review of Revised CRD System Design Criteria The inspector reviewed the S&L document, "SRV LOCA Hydrodynamic Loads Revised Design Basis Summary Report", dated December 3, 1979. The report covered various new design considerations including (1) LOCA boundary loads, (2) water jet loads initiated below the vent exit,

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(3) air bubble loads inside vent lines, (4) upward pool swell loads, (5) condensate oscillation loads, and (6) SRV symmetric and asymmetric chugging loads. The inspector noted two questionable areas i.e., (1)

The report had not been issued formally with all approval signatures including issuance, review, approval, and client acceptance documenta-tion, and (2) The present EES design of the CRD suspension system has reached, in a number of cases, the Code allowable stress limits. An increase of criteria of such magnitude could mean design revision of the entire CRD suspension system.

This is considered an unresolved matter (373/80-20-05; 374/80-13-05).

8.

Audit Adequacy a.

S&L Specification J-2922, Form 350-B, Paragraphs 3.3 and 3.5 state, in part, that "The seismic qualification shall be achieved by testing and/or analysis.

After contractor

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submits his equipment drawings for final review, he is required to submit the seismic report for the test result: and/or seismic calculations. The drawings, test results, and analytical calcu-lations will be reviewed for acceptability by the Consulting Engineers." These requirements were not implemented by RCI/EES and audited by CECO.

b.

The EES huclear QA Manual, Revision 5, Paragraph 3.8, " Computer Programs," sub paragraph b.2 states, " Properly verify and docu-ment in the verification and user's manuals each version of the program used on the project." In conjunction with Paragraph 4 of this report, CECO and RCI did nat audit EES for implementation.

The inspector concluded that the lack of CECO and RCI past and presently planned audits on their contracotors was in noncompliance with S&L Specification, J-2922, " Reactor Internals Installation and Control Rod Drive System Erection", Revision CA, dated September 13, 1976, where Division 2, QA and QC, paragraph 201.4 " Audit", states "A comprehensive program of and periodic audits to be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program shall be described."

This is an item of noncompliance identified in Appendix A.

(373/80-20-06; 374/80-13-06).

Exit Interview On April 8, 1980, the RIII staff met with licensee representatives (denoted in the Persons Contacted paragraph) to summarize the scope and findings of the inspection. The licensee ackowledged the items of noncompliance.

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