IR 05000373/1981044

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IE Insp Rept 50-373/81-44 on 811222-23,29-30, & 820107,14 & 27-29.Noncompliance Noted:Licensee Design Control Over Ae Placement of safety-related Mechancial Snubbers Inadequate
ML20042C363
Person / Time
Site: LaSalle Constellation icon.png
Issue date: 02/10/1982
From: Danielson D, Yin I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20042C361 List:
References
50-373-81-44, NUDOCS 8203310290
Download: ML20042C363 (13)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-373/81-44 Docket No. 50-373 License No. CPPR-99 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

LaSalle County Station, Unit 1 Inspection At: LaSalle Site, Marseilles, IL Inspection Conducted: December 22-23, 29-30, 1981; and January 7, 14, 27-29, 1982

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h'O Inspector: Je T. Yin Z-

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Approved By:

D. H. Danielson, Chief c2// 0,I,f k

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Materials and Processes Section Inspection Summary Inspection on December 22-23, 29-30, 1981; and January 7, 14, 27-29, 1982

[ReportNo. 50-373/81-44)

Areas Inspected: Review of startup vibratory test procedures for piping systems; inspection of large bore and small bore seismic restraint instal-lations; review of support installation and inspection records; evaluation of snubber design considerations and suspension system functionabilities.

The inspection involved 48 inspector-hours onsite by one NRC inspector.

Results: Of the areas inspected, one apparent violation was identified.

(Inadequate design control and consideration in-placement of safety related seismic mechanical snubbers - Paragraphs 1 and 2).

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t 8203310290 820315 PDR ADOCK 05000373 O

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DETAILS Persons Contacted Commonwealth Edison Company (CECO)

  • . B. B.-Stephenson, Project Manager
  • . D. L. Shamblin, Staff Assistant - Project Manager Office
  • . R. Cosaro, Project Construction Superintendent

. T. E. Quaka, Site QA Superintendent i

B. R. Shelton, Project Engineering Manager

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  • . D. J. Skoza, PCD Engineer

. R. M. Matheny, Technical Staff Engineer

. M. A. Peters, Test Staff Engineer

  • B. J. McAndrew, Project Mechanical Supervisor
  • G. E. Groth, PCD Engineer e

R. Vine, Qi Engineer

  • R. L. Scoct, Project Engineer B. Annis, Project En ineer M. Richter, Technical Staff

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Sargent and Lundy Engineers (S&L)

  • . R. J. Mazza, Project Director
  • . B. R. Parduhn, Mechanical Project Engineer R. H. Pollock, Mechanical Project Engineer D. A. Gallagher, Field Coordinator
  • . G. T. Kitz, Head Engineering Mechanics Division S. O. Killiam, Project Engineer J. M. Nosko, Mechanical Engineer J. Smetters, Testing Staff P. Odisho, Testing Staff D. Olsen, Testing Staff

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Morrison Construction Company (MCCO)

  • J. Hamilton, Project Manager
  • M. Wherry, QC Supervisor USNRC-Region III

. C. C. Williams, Acting Chief, Engineering Inspection Branch

. D. H. Danielson, Chief, Materials and Processes Section

. R. D. Walker, Senior Resident Inspector

. I. T.-Yin, Reactor Inspector

. Denotes those attending the technical discussion held in the Region III office on January 14,'1982.

  • Denotes those attending the management exit interview on January 29, 1982.

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Licensee Action on Previously Identified Items h

(0 pen) Unresolved Item (373/81-2;-01): The CECO STP-17 did not include

. requirements for measuring gap clearances between the process pipe and-the surroundirg pipe whip restraint structural assemblies. The subject

inspection responsibility was transferred from CECO startup group to i

construction staff. A procedure, " Hot Linewalk Inspection Procedure" is~

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in the process of review and approval.

e (Closed) Unresolved Item (373/81-29-02): Procedures for vibration measure-i ments for RPV level, RCIC, and MS flow instrumentation lines, as required in

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i NUREG-0519, Supplement No. 1, had not been developed by CECO. The inspector i

reviewed the revised CECO test procedure, STP-33, "Drywell Piping Vibrations,"

' Revision 1, dated January 11, 1982, and had no adverse comment.

(Closed) Unresolved Item (373/81-33-01; 374/81-17-01): Questionable S&L'

design of tack welds on support components. This item was reviewed by a

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i RIV Contractor Inspector (see RIV Report No. 99900507/81-04 for details).

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(Closed) Unresolved Item (373/81-38-01): Questionable welding design on i

Restraint No. HG06-1080G. The inspector reviewed the S&L evaluation of the

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problem including corrective actions stated in ECN No. FM-5974-LS, dated

October 9,1981, and had no adverse comment.

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(0 pen) Unresolved Item (373/81-38-02):

Licensee implementation of a program to improve MCC0 inspection of safety related support installations was com-pleted. Questionable small bore piping component installation documentation

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was'further identified by sae inspector during the December 22-23, and 29-30,

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1981 inspections. The specific problems and the licensee's followup are

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. enclosed in an Exhibit to this report. During inspection conducted on

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January 27-29, 1982, snubbers No. M-1302-SH24-138, and-137,-rigid struts

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No. RIO9-1037X and -1038X were selected for review in the areas of instal-

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1ation and QC inspection. No deficiencies were identified. The overall

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i licensee corrective program and its implementation will be further reviewed i

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(Closed) Unresolved Item (373/81-38-03): SER NUREG-0519i Supplement No. 1, e

l Paragraph 3.9.2.1, states that, "The reactor pressure vessel level instru-

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mentation lines and'the control rod drive lines inside containment will be visually insp cted to identify any excessive vibration in conjunction with Startup. Test-Procedure 34,' Vibration Measurements." In discussion with the

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site-operation staff, the inspector was told that the STP-34 is for incore vibration measures. Whether or not STP-34 will refer to STP-33 and

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PI-SI-102 for the line vibration test or will include the requirements in

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STP-34 itself will be determined by the licensee. The inspector reviewed

CECO test procedure, STP-34, " Reactor Internal Vibration," Revision 1,

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dated January 13,'1982,-where PT-SI-102 requirements were referenced in-

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Paragraph 10.2.A, Item 34.

(Open) Unresolved Item (373/81-38-04): Piping configuration drawings were f

Lbeing' prepared by CECO for the line vibratica tests.. However,.the packages.

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had not been-fully developed, reviewed, and accepted by the. responsible'

personnel.

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(Closed) Unresolved Item (373/81-38-05):

Seismic motions could have adverse effects on instrument accuracy. The inspector reviewed the S&L to CECO letter, dated December 31, 1981, subject, "NRC Region III Inspection Report No. 50-373/81-38-05: Vibration of Instrumentation," where it stated that instrumentation lines were seismically supported to minimize the potential for pipe vibration effecting the instrument readings.

In discussion with the CECO representatives, the inspector stated that he had no further questions at this time.

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Functional or Program Areas Inspected 1.

Inadequate Snubber Design Considerations - Part I The inspector observed snubber and restraint installations at High Pressure Core Spray (HPCS) Pump Suction and Standby Liquid Control (SC) systems, and had the following findings:

HPCS System

Five snubbers were installed so close to the one rigid single directional pipe guide that the f metionabi14'f of these snubbers could be adversely

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affected. The mechanical snubbers require approximately 1/8" travel to close all open spaces, which exist inside the snubber unit,and the out-side structural gaps such as the ball bushings in the structural and piping connections, before lock-up initiation and loading up to their design capacities. The zero gap observed at the pipe guide will not allow the required snubber travel. The components observed included:

A pair of snubbers HP01-1014S (7,382 lb ) and HP01-1012S

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f (5,837 lbD ) installed horizontally on the 24" diameter pump f

suction, 52.5" from a pipe guide, 45' to the pipe run.

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A pair of snubbers HP01-1004S (22,699 lb ) and HP01-1003S

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f (21,245 lb ) installed horizontally on the 24" diameter pipe f

riser, 28" above the pump suction line. The tee connection is 21.5" from the pipe guide. The orientation of the snubber is 45' to the suction line.

Snubber FHP-1203-H'J2S installed horizontally on the 2" diameter

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branch line, approximately 4'-6" away from the connection to a 24" diameter line 'and near a pipe guide, is in the same loading direction as the pipe guide.

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The horizontal directional pipe guide described above is

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HP01-1019X, with design load of 11,821 lb.g SC-1201 System (Line No. ISC06A-1 1/2")

Snubber FSC-1201-H07S is only 15" away from rigid pipe guide

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FSC-120-1H08G.

Snubber SC02-1004S is only 4" away from rigid pipe restraint

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SC02-1003R.

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Snubber SC01-1007S is only 12" away from rigid pipe restraint

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SC02-1003R.

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Snubber.SC02-1001S is only P1" away from rigid pipe restraint

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SC02-1002R.

The problems observed can be concluded in threefold:

(1) The operability of the snubbers were impaired by the close proximity of the rigid restraints and guides.

(2) The non-functional snubbers could mean load increases at the affected rigid restraints and guides.

(3) The piping thermal movements at these locations are minimal, the lines can be restricted without causing unacceptable increases in the secondary pipe stresses. The selection of these snubbers could be considered to be unjustifiable.

This is an apparent violation (373/81-44-01). During the exit meeting on January 29, 1982, S&L management stated that they had identified a number of similar conditions and determined that some of these snubbers would not function under present conditions.

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Inadequate Snubber Design Considerations - Part II On December 30, 1981, the inspector reviewed the S&L " Piping Loads Data

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List" prepared for the LaSalle Unit 1 small bore piping restraints.

Among the 268 snubbers required, 53 were found to have thermal movement at the pipe connection of 1/16',' or less, and 16 with movement of 1/8" or less. The licensee agreed to conduct a review to determine the total number of snubbers within the same conditions.

During the January 14,

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1982, meeting at Region III office, the licensee presented the following data:

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Unit 1 Support Review Total = 20,105 ANCR = 77 SNUB = 2,025 STRT = 1,568 GUID = 8,788 CONS = 215 VAR = 1,029 RIGD = 6,403 Unit 1 Snubber Review

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Total Number of Supports = 20,100

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(S&L/NSC = 12,200)

(MCCO = 7,900)

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Total Number of Snubbers = 2,025

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(S&L/NSC = 1,670)

(MCC0 = 355)

Total Number of Snubbers With Movements Equal To or Less than

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1/16" = 439

(S&L/NSC = 350)

(MCC0 = 89)

Total Number of Snubbers With Movement Larger Than 1/16",

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1/8" = 144 (S&L/NSC = 110)

(MCC0 = 34)

Snubbers With Movements Equal To or Less Than 1/16" Snubber Size S&L NSC Total PSA-1/4

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PSA-1/2

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PSA-1

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PSA-3

51 104 PSA-10

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PSA-35

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201 149 350 S&L NSC Total Small bore

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Large bore 166 143 309 The inspector stated that radiation exposures received by plant personnel while performing required Technical Specification snubber visual inspec-tion and functional tests for these snubbers with little or no thermal movements, could be avoided if these snubbers were replaced by rigid restraints that require only minimum ISI inspection and no functional testing. This design use of mechanical snubbers inplace of rigid supports does not appear to have been add'equately reviewed for ALARA considerations. ALARA design review guidance is contained in Regulatory Guides 8.8 and 1.70.

This matter was discussed in the exit interview and will be reviewed further in a future inspection.

This is an open item (373/81-44-02).

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Gaps on Large Bore Reinforced Pipe Clamps The inspector observed large gaps (up to 1/2 inch) on the following LaSalle Unit 1 multi-load pipe clamps:

24" clamp for snubber LP01-1L10S, and rigid strut LP01-1011X.

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24" clamp for snubbers HP01-10125, and HP01-1014S.

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InreviewofSSLDrawingNo.M-1100,$heet30,"ComponentSuppc-t General Notes and Details," Revision A, dated November 12, 1980, requirements had not been established for a field inspection of these gaps.

In discussion with the MCC0 staff, it was shown that a ITT-Grinnell Interoffice Correspondence, Subject, " Fit-Up of Pipe Clamp Around Pipe," dated June 3, 1980, was used as QC inspection criteria. While the inspector did not havn any adverse comments on the ITT-Grinnell correspondence, he considered that the reinforced clamp had changed the characteristics of the basic pipo clamp, and that the instruction stated in the correspondence was invalid for the inspection of the modified pipe clamps. Subsequently, S&L issued a ECN No. M-621-LS, dated December 23, 1981. The ECN stated, in part, that " Clamp / piping out-of-roundness is permitted without welded attachments provided there is at least two point contact between the pipe and clamp." The adequacy of the ECN inspection requirements will be reviewed further, because two point contacts on 20" clamp for VGC1-0003, 20 clamp VG07-1003, and 24" clamp for SC21-1004X were found very close together, and were both located on one side of the loading direction. This is an unresolved item (373/81-44-03).

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Observation of CRD Vibration Testings Engineering Inspection Branch inspectors performed the subject inspection on January 7, 1982. The findings were as follows:

Procedures Reviewed LST-81-106 Test Observed Location of Observation SRP-1 (3407-48)

Near D2

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SRP-2 (3407-48)

Between D3-D4 and S1-S4 SRP-3 (3407-48)

" atween D3-D4 and S1-S4 SRP-4 (3407-24)

h.ar D6 SRP-5 Full Scram Near D2 All tests were witnessed at the particular s,nsing device and the visual inspections were witnessed both before and after each scram.

During the single control rod scram, pipe movement was hard to detect

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visually, and no deformation of the piping or supports was detected. '

The full scram produced a greater volume of noise, but no noticable deformation of piping or supports.

Inspections were made at random points on both the north and south sides of containment.

The insert line for 3407 is located within 1/4" of some structural steel supports at a point about two feet downstream of D3 and D4.

The line appears to be susceptible to wear due to vibration. Wear in this line could cause 3407 to lose its ability to insert the rod. Consideration should be given to the location of this line when water hammer aspects

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are analyzed in LST 81-106.

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During the management exit meeting conducted on January 29, 1982, the inspector stated that during a future inspection he will review:

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Maximum line movement due to water hammer and SSE events at the locations discussed above.

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Maximum system water hammer stresses in combination with the primary stresses calculated by RCI/EES.

This is an unresolved item (373/81-44-04).

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Shear Lt 3s for Small Bore Piping During an inspection conducted on December 22, 1981, a pair of snubbers

FHP-1201-H04S installed on the 1HP21A-1 1/2" line were observed not to have shear lugs on the pipe. The question as to whether or not shear lugs were required for small bare piping subjected to axial dynamic

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loading conditions, was raised by the inspector. Studies were made by the S&L design engineering department and concluded that normal friction between the pipe and pipe clamp was sufficient to prevent any slippage

under load. The inspector reviewed the following S&L documents:

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S&L Calculation No. EMD-035109, " Minimum Required Installation Torque For Clamps - 2 Inch and Under," dated December 29, 1981.

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S&L letter to CECO, subject, "PSA Clamps," dated January 12, 1982.

The inspector stated that he had no further questions at this time.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncomplinace, or deviations. The unresolved items disclosed during this inspection are discussed in Paragraphs 3 and 4.

Exit Interview The inspector met with licensee representatives at the conclusion of the inspection on January 29, 1982. The inspector summarized the scope and findings of the inspection. The licensee acknowledged the findings reported herein.

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During the last 2 weeks of 1981, NRC Inspector, Mr.

T.. T. Yin identified several areas of concern at LaSalle.

These are detailed as follows:

a)

FHP 1201-H02S - QC picked up a drafting error during inspection and signed off noting the error.

2ven though this was eventually run thru S&L, the inspector felt it was an examole of inadequate QC training and control.

b)

FHP 1201-H04S - QC corrected a drafting error without initiating an FSCA to have it reviewed.

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FSC 1201-H08G - A review of the documented work indicates a change was made before the FSCA was approved.

Evaluation of the above occurrences indicated that two notential problems exist.

FSC 1201-H08G indicated that Morrison production had apparently drilled holes for a knee brace anchor plate and finished the hanger prior to approval of design change by S&L on FSCA 1893.

FHP-1201-H04S and FHP 1201-H02S indicated that Morrison Q.C. may have made an engineering judgement and accepted a hanger without obtaining engineering resolution of an apparent drafting error and further there is evidence on at least one occasion that Q.C. erred in not properly documenting the results of their inspection activity.

The two general

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(A)

Morrison's production is installing small bore hangers without engineering approval and (B)

Morrison Q.C., on occasion, has improperly accepted work and/or inadequately documented the results of their inspection activity.

As the result of a CECO QA commitment made to the NRC in October 1981, QA has increased it's surveillance of Morrison's Q,C.

inspections of supports / restraints and Q.C. final line walk activities.

Attachment A includes copies of surveillances performed-during November and December 1981 for these specific areas of Morrison activity.

In review of this information it can be noted that no similar problems to the production or QC ones identified above, occurred.

Therefore, during the first week of January 1982, CECO. Q.A.

reviewed Morrison's installation records to specifically address these concerns.

The results of these reviews are documented on surveillance 82-8 and 82-10.

Surveillance 82-8 verified for each support reviewed (15 total)

that Morrison production installed the support after FSCA approval.

No case similar to FSC 1201-H08G was identified.

Surveillance 82-10 indicated that in no case are there problems sirailar to those identified for FHP-1201-H04S anc IHP-1201-H02S.

It should be noted that the sample taken in 82-10'was for QC work performed after retraining of the MCCo QC inspectors in November.

It is therefore concluded that based on the surveillances performed since October 1981 and surveillance 82-08 and 82-10 that the items identifiedbyI.T.YininlateDecemberappeartcbeisolatedoccurrences{

in that Q.A. was not able to substantiate additional occurrences.

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EXHIBIT

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FHP-1201-H02S MAXDGM LOAD: 28#

PROBLEM: Angles of h5 37 3h

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and 26.5 were Present in Inspection Records DRAWEIG ACTION DATE Rev. O S&LApproved(norecord)

Issued Production 11/8/78 Rev. A Approved S & L 2/8/79 (S&L)

IssuedProduction(h5)

2/2/79 Q.C. Inspection (didnot findanglediscrepancy)

7/27/79 Rev. B MCCo Sent to S & L 9/9/80 (S&L)

(NeverIssuedtoProduction or Approved by S & L)

Rev. A Comnents by NSC 11/80 (NSC)

(Change strut to snubber)

Snubber Angle 26.50 Rev. C MCCo Incorporated USC comments (MCCORevisionleftIncorrect Angleofh50)

NSC Approved

1 Issued Production

1 Q.C. Measured 3h0 and wrote

1 on drawing angle should be 370 Line Walk 7/23/81

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FSCA Change angle to 26.50 1102 Approved NSC 7/25/81 Rev. C(NSC)

Q.C. Inspection 7/27/81 FSCA 1102 (Inspection did not crossout 3h0frompreviousinspection)

Rev. D (NSC)

McCoIncorporatedFgCA1102 (SnubberAngle265)

Approved NSC 8/6/81 Rev. E For Record Document.

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(NSC)

(SnubberAngle26.50)

Approved NSC 12/1/81 Hanger closed by MCCo 12/19/81 i

Subsystem HP-62

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MAXII s LOAD: 33#

PROBLEM:

Q.C. Inspection Accepted j

600 Angle, Which Vas Out l

Of Tolerance

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DRAVING ACTION DATE

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Rev. O Never Approved S & L

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or Issued Production Rev. A Approved S & L 12/8/79 (S&L nsp.)

Issued Production 12/2/79 Rev. B MCCo Issued to S & L 9/9/80 (S&L)

(strutangleh50)Never approved by S & L or issued to Production Rev. A Coments by NSC 11/80 (NSC)

(changestruttosnubber)

(snubber angle h5 )

Received MCCo 2/81 Rev. C MCCo Incorporated (NSC)

NSC coments (snubber angle h50)

Approved NSC 6/12/81 Final Q.C. Inspection 7/16/81 (Inspectorcrossedoutapparent drafting error to show 60 field inctallation.

Final line walk 7/23/81 Rev. D For record document issued to

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NSC showing 60 angle.

Approved NSC 12/18/81 Hanger closed by McCo 12/19/81 Subsystem HP-62 i

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FSC-1201-H07(RorS)

7/29/81 S & L drawing Rev. A rejected to indicate snubber is required 8/7/81 Piping load computer listing issued to

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indicate a restraint Rev. B of drawing 8/19/81 sent to S & L by M.C.Co.

Drawing received from 9/12/81 S & L approved (snubberindicatedondrawing)

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Analytical Drawing G101414-1, Sheet 3, indicates anubber is required i'

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FSC-1201-H08G

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MAXIIM LOAD 265#

PROBLEM: Knee Braco Moved

Without Design Apiroval DRAVIIiG ACTION DATE Rev. O S & L Approved 1/79 Issued Production 2/79 QC Inspection Base Plate 3/14/80 Rev. A MCCo sent to S & L

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ApprovedS.&L(changed)

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81 FSCA 1796 Approved S & L 10/9/81 f

Drill holes for Knee 10/13/81

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Brace Anchor Plates and I

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finished hanger i

FSCA 1893 Initiated Knee Brace Change 10/17/81

Approved S & L 10/19/81 l

Rev. A QC Inspection 10/21/81 ISCA 1796 & 1893 Final Line Walk 10/26/81 i

Rev. B MCCo. Incorporated FSCA j

1796 & 1893, Issued to S & L 10 0/81 Approved S,& L 11 /81

Rev. C For record document

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(DrawnbutnotyetsenttoS&L)

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Hanger open Subsystem SC-010

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