IR 05000373/1981033
| ML20032C091 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/08/1981 |
| From: | Daniel D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20032C087 | List: |
| References | |
| 50-373-81-33, 50-374-81-17, NUDOCS 8111060688 | |
| Download: ML20032C091 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEhT
REGION III
Report No. 50-373/81-33; 50-374/81-17 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 Inspection At: General Electric Company (GE), San Jose, CA Quadrex Corporation (Quadrex), Campbell, CA Inspection Conducted: September 21-22, 1981 at GE September 22-23, 1981 at Quadrex
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Inspector:
I. T. Yin
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Approved By:
D. H. Danielson, Chief Materials and Processes Section Inspection Summary Inspection on September 21-23, 1981 (Report No. 50-373/81-33; 50-374/81-17)
Areas Inspected: Followup on previously identified inspection findings; inspection of GE document control system, and work interface with S&L; followup on allegations made against Quadrex.
The inspection involved a total of 20 inspector-hours at licensee contractor r fices by one NRC inspector.
Results: No apparent violations were identified.
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DETAIIS
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Persons Contacted l
Inspection at General Electric Company (GE) on September 21-22, 1981.
Commonwealth Edison Company (CECO)
- B. Annis, Projtet Engineer
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GE j
- R. C. Boesser, Manager T and AP
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kD. E. Lee, Manager, QC
- J. L. Thompson, Manager, Piping Analysis
- D. B. Laine, Project Engineer
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- E. O. Swain, Manager, Piping Design
- J. C. Major, Manager-Piping ' pipment
- P. Binesh, Piping Design Engineer
- R. J. Valencia, Audit Coordinator J. A. Kahermanes, Senior Engineer, T and AP B. J. Waters, Analyst B. J. Erbes, Program Manager J. Wallach, Manager, Dyamic Loads Evaluation i
K. Dawley, Manager, Plant Definition
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- Denotes those attending the Management exit interview on September 22, 1981.
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Inspection at Quadrex Corporation (Quadrex) on September 22-23, 1981.
t CECO
- B. Annis, Project Engineer Quadrex
- R. Naymark, Vice President, Piping and Supports Systems Division
- A. Monshedi, Project Manager
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- C, D. Roady, Manager of QA
- J. R. Reddy, Manager-QA Engineering
- H. Lee, Manager, Pipe Support Engineering
- C. McGovern, PQAE D. F. Seidel, Assistant Project Manager
C. P. Ng, Section Manager, Pipe Support E. B. James, Project Administrator Sargent and Lundy Engineers (S&L)
- B. R. Parduhn, Mechanical Engineer
- Denotes tcose attending the management exit interview on September 23, 1981.
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Licensee Action on Previous Inspection Findings (Closed) Unresolved Ites (373/79-19-02; 374/79-13-02): The need for evaluation of the adequacy of ITT-Grinnell supplied hangers and snubbers in terms of code requirements and design criteria. The recirculation loop piping suspension systems for Units 1 and 2 were purchased to ANSI B 31.1 and MSS-SP 58 design requirements. All items were considered to be standard catalog components. The main steam piping suspension systems wera purchased to ASME Section III, Subsection NF, Article NF 2000 - 1974 Edition including Summer 1974 Addendum. The inspector reviewed the "ITT-G Pipe Hanger Division ASME Section III, Subsection NF Load Capacity Data Sheets for Standard Com-ponents" and had no adverse comment. The snubbers on the MS and Recirculation systems were manufactured by PSC and were provided by ITT-G.
The inspector reviewed the GE Vendor Print File (VPF) No. 5650-162-3, dated May 12, 1979, and had no adverse comment.
(Closed) Unresolved Item (373/80-48-03; 374/80-30-03): Questionable Quadrex internal audit program. The inspector reviewed the recently updated Quadrex QA audit program including:
(1) identification of all the applicable criteria in 10 CFR 50, Appendix B relative to La Salle Project activities, (2) project audit plans that identified project functional activities and re':ted control documents, and (3) semiannual audit schedules including systematic evaluation of implemtation of all the program functional areas covered in work instructions and procedures.
In addition, there were also surveillances performed at both the Campbell Design Engineering office and at La Salle site, external QA audits and surveillances conducted by CECO and S&L relative to Quadrex funtional areas applicable to La Salle Unit I contract work scope. The total
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number of Quadrex, CECO, and S&L QA audits and surveillances in 1980 and 1981 amounted to 34 and 114 respectively. The inspector also re-
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viewed draft copies of the Quadrex QA program procedures, QAP-1001 l
and QAP-1003 relative to QA audit scheduling, preparation, implementa-
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tion, reporting, and followup and had no adverse comment.
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(Closed) Noncompliance (373-81-17-02; 374/81-11-02): Lack of document control identified at GE.
The inspector reviewed the following documents and had no adverse corament:
a.
GE Engineering Operating Procedure, OP 30-4.00, " Engineering Information System," dated February 19, 1981.
b.
GE NEDE-24563, "EIS Users Guide," dated December 21, 1978.
c.
GE Nuclear Engineering Division "QA News Letter," No. 35, dated August 11, 1981.
However, generic problems relative to GE document controls were identified, see Paragraph 1.a of this report. These matters will be forwarded to the Region IV, Vendor Inspection Branch for review and resolution.
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(Closed) Unresolved Item (373/S1-17-03; 374/81-11-03):
GE design veri-fication per IEB 79-14 requirements. The inspector reviewed the following documents and had no adverse comment:
GE Engineering Review Memorandtm (ERM) No. DMC-1639, " Recirculation a.
Piping System," dated July 30, 1981. Where it stated in the ERM that La Salle 1 Recirculation loops A and B have been checked and imple-mented in the analysis.
b.
GE Design Procedure Y1003K01A04, "AE Design Certification", dated May 6, 1980.
It required the GE design engineer to obtain AE design information for use in piping stress reports and to verify all inputs received from others for use in the GE stress analysis.
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c.
GE Installation Instruction 22A4228, " Installation Instruction for GE Piping Systems, " Revision 1, dated May 9, 1977. This instruction requires that " Deviation for design location of either the beam attachment or the hanger pipe clamp in excess of 4 degrees or 3 inches, whichever is less, will require prior GE approval via an FDDR", and "where movement of the attachment point is necessary and the change is 5 degrees or more from the ir. tended centerline of the snubber, prior GE approval via an FDDR will be required."
Functional or Program Areas Inspected 1.
Inspection at GE on September 21-22, 1981 a.
Inspection of GE Document Control System The following discrepencies were observed:
GE Specifications Revision No.
Revision No.
Revision No.
(Date)
(Date)
(Date)
Note 1 Note 2 Note 3 22A6011
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l MS Design (April 28, 1978)
(June 11, 1980)
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22A6011AA
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Design Certification (April 6, 1981)
21A9415
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MS Purchase (June 16, 1971)
(June 24, 1974)
767E106
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HS Pipe Suspension (January 8, 1381)
l 21A3502
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Snubber Purchase (August 9, 1978)
21A9422
2
Hanger Purchase (Janua ry 11, 1977)
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Note 1:
These six out a total of eleven GE Specifications referenced in the La Salle GE Design Report 22A7431, " Main Steam Piping and Equipment Loads," Revision 0, dated March 5, 1981, indicate revisions as listed.
Note 2:
These are the latest Revision Nos. based on computer print-outs presented to the inspector on September 21, 1981 wten the Engineering Information System (EIS) terminals were down.
Note 3:
These are the revisions the EIS indicated as being applicable to La Salle project on September 22, 1981.
This matter will be forwarded to the NRC Region IV Vendor Inspeciton Branch for a generic evaluation. Areas in question include:
(1)
utilization of the latest design specification in the Design Report, (2) reason for difference between Note 1 and Note 2, (3) EIS informa-tion on purchase specifications per contract agreement, and (4) use of Product Quality Certifications (PQC) in conjunction with the EIS.
b.
GE and S&L Design Interface During a inspection at S&L on August 26, 1981, relative to the adequacy of piping stress analysis, some guestionable stress levels on GE piping were observed.
In review of S&L calcula-tion No. EMD - 024316, " Main Steam MS-03 (GE line No. C),"
Revision 3, dated February 26, 1981, one of the 8" GE Sweepolet connections below the Safety Relief Valve (SRV) (No. 250T computer node point) was noted as having a fault design condition that was calculated to be 64,780 psi in compare with 36,000 psi ASME Code allowable. This matter was reviewed at the GE office, and the stress et1culated by GE engineers was found to be mur n lower, i.e., 27,401 psi in compare with the ASME Code allowable of 54,600 psi. Further review of the matter was made and th, ip~
spector considered both calculations acceptable based on the following rationale:
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(1) S&L applied uniform response spectrum input and GE used multiple response spectrum inputs at specific floor
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elevations.
(2) The S&L calculation was based on ASME III, Class 2, Equation 9 and the allowable was 2.4 S. The GE calculation was h
based on ASME III, Class 1 Level D and the allowable was 3S.m (3) The S&L stress intensification factor for the Sweepolet was i = 2.1, where GE bending stress index was B2 = 1.17.
(4) Difference in load combination based on code interpretation.
During a telephone conference with S&L and GE on September 22, 1981, the S&L Mechanical Project Engineer informed the inspector that changes on SRV discharge piping suspension systems due to-5-
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design ocasiderations and construction interferences had been forwarded to the GE responsible design staff.
Some of the transmittal letters included:
Date of S&L Letter System changes that could affect GE Piping Analysis July 9, 1981 MS - 2, 4, RH-01 June 12, 1981 MS - 01, 2, 3 June 11, 1981 MS - 4 October 3, 1980 MS - 1, 2, 3, 4 September 30, 1980 MS - 1, 2, 3, 4 August 8, 1980 RH - 2 July 24, 1980 MS - 1, 2, 3, 4 June 10, in80 Drawing MS 12 The inspector reviewed the S&L June 11, 1981, and June 12, 1981 letter transmittals, and the GE engineering evaluation packages, and had no adverse comment. During the management meeting on September 22, 1981, the GE design staff management stated that the rettified stress reports will either include all as-built information or all affected changes will be evaluated and
- conciled in the overall piping stress analysis.
2.
Inspection at Quadrex on September 22-23, 1981 Followu_g on Allegations - Part 1 a.
On May 20-21, 1980, IE Headquarters assisted RV in an investi-gation into allegations lodged against Quadrex. These allega-tions concerned Quadrex's work on its contract with Sargent and Lundy. Two of the allegations and the inspector findings are addressed below.
(1) Allegation:
"Quadrex sent 28 Engineering Change Notices (ECN)
on pipe stress analyses to S&L in Chicago, Illinois without sny calculations done on them."
The inspector reviewed Quadrex letter to S&L, NSP-PM-SAR-3-013,
" Transmittal of ECNs," dated February 13, 1980 int. ng all 26 ECNs (not 28 ECNs) transmitted through the letter. Two of the ECNs were selected for review. After a preliminary review of all 26 ECN's, the two ECN's reviewed represerted the more complex design and computation. Additional review of other packages was planned if deficiencies were disclosed in these two ECN's.
In view of the fact that, (1) hanger calculations are not required to be physically present at the site at the time of installation, (2) all calculations were performed prior to issue of the approval of ECN's and transmitted to the site, and (3) all calculations reviewed were based on established
criteria and performed in an orderly manner, the inspector concluded that there was no impropriety on the part of Quadrex.
The following are the two ECN's reviewed:
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ECN FM-511LS, Unit 1, Subsystem DO-15, Hanger Drawing No.
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'fhe original S&L drawing sent to the site for construction was dated July 27, 1978. The subject ECN was initiated on-October 12, 1979 due to a structural interference. The ECN was received by Quadrex on December 10, 1979. The calculation for the revised design was performed from December,1979 to Februa ry, 1980. Revision B of the design drawing, dated February 9, 1980, stamped " Advance Copy," was forwarded to the site with the approved ECN.
ECN FM-658 LS, Unit 1, Subsystem RI-13, Hanger Drawing No. RL 24-1504V The original S&L drawing M09-RI24-1504V sent to the site was dated September 20, 1978. The subject ECN was initiated on December 8,1979 because of a floor elevation change. The ECN was received by Quadrex on January 10, 1980. The cal-culation for the revised design was performed on February 12, 1980. Revision B of the design drawing, dated February 13, 1980, stamped " Advance Copy," was forwarded to site with the approved ECN.
(2) Allegation: "Quadrex performed work on safety related com-ponents without any procedures. Then after doing the work wrote the procedures and back dated them. An unannounced audit by experts in the field of pipe stress analyses would have to be done in order to catch them at this violation of accepted NRC procedures."
Between May 1980, when the allegations were made and the l
first Region III inspection at Quadrex, in November 1980, f
extensive audits of Quadrex were conducted by CECO and S&L.
These audits identified many findings which were corrected.
Subsequent to the above CECO and S&L audits the inspector reviewed the Quadrex procedures and internal audit program during November 3-4, 1980 inspection (Region III Inspection Reports 50-373/80-48; 50-374/8030), and May 5, 1981 inspec-tion (Region III Inspection Reports: 50-373/81-17; 50-374/81-11). The work procedures developed by Quadrex were considered to be adequate and acceptable. The inspector could find no basis on which to question the quality of the work performed by Quadrex personnel.
No items of noncompliance or deviations were identified.
b.
Followup on Allegation - Part 2 IE:HQ staff informed the inspector by telephone on September 11, 1981 that they received allegation relative to La Salle project activities that Quadrex design allowed safety related small bore pipes to be connected at large non-seismic categor pipes. For example, a VOI 8" safety related line was branched into a 20" non-safety related header.
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The inspector reviewed S&L Drawing No. F-88, "P&ID Off Gas" Revision N.
System OV0-01 showed 30" off gas header with a 2" branch connection, and was a non-safety related system. The stress analysis for the subsystem OV0-01 was documented in Quadrex report QUAD-1-79-639, "Off Gas System," Revision 0, dated November 26, 1979.
No item of noncompliance or deviations were identified.
c.
S&L Design Problems During the review of the allegation items, the inspector found that the variable spring support, RI 24-1504 V, originally designed by S&L, and subsequently change' by Quadrex, showed tack weld at the contection between the pipe stanchion and variable spring support. Such design is not permitted in S&L Specification PI-LS-16, Appendix J, " Selection and Calculation Requirements for Piping Support Assembly Components for the La Salle County Station," Revision 3, dated March 13, 1981.
Tack welds are permitted only (1) on fasteners (nuts) that could be loosened due to system vibration, and (2) on fasteners above the cross structural beams to naintain the hanger rods at their design vertical positions.
A problem similar to the above was identified at another site.
As this matter is potentially generic it will be forwarded to the NRC Region IV Vendor Inspection Branch for review and resolution.
This is an unresolved item (373/81-33-10; 374/81-17-01).
Exit Interview The inspector cat with licensee representatives at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection. The licensee acknowledged the findings reported herein.
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