IR 05000387/1982031
| ML20028A324 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/04/1982 |
| From: | Chaudhary K, Durr J, Narrow L, Rhoads G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028A322 | List: |
| References | |
| 50-387-82-31, NUDOCS 8211180325 | |
| Download: ML20028A324 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
l Report No. 82-31 Docket No. 50-387 Category C
License No. NPF-14 Priority
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Licensee: Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Susquehanna Steam Electric Station, Unit-1 Inspection At:
Berwick, Pennsylvania Inspection Conducted: July 21-23, 1982 Inspectors: bw
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. K. Chaudhary, Reactor Engineering
' dite Inspector
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L./Jiarrow, Reactor Engineering date
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Inspector b ukk)
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G{)G. Rhoads, Senior Resident Inspector
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Approved By:
a m&41 4) P. Durr, Chief, Material and
' d'a t e Processes Section, EPB Inspection Summary:
Inspection on July 21-23, 1982 (Report No. 50-387/82-31)
Areas Inspected: A special unannounced inspection by two region based and one Senior Resident Inspector of pipe supports, structural steel and design activities in this area. The inspection involved 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> onsite by three inspectors.
Results: Of the three areas inspected, violations were identified in all areas:
(1) Failure to provide suitable design for small bore pipe anchors; (2) Failure to distribute current and approved design documents; (3) Failure to provide adequate training for inspection.
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PDR ADOCK 05000387
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DETAILS 1.
Persons Contacted Pennsylvania Power and Light Company R. A. Breslin, Project Construction
- R. G. Byram, Supervisor of Maintenarce
- T. M. Crimmins, Manager, Nuclear Plant Engineering
- N. W. Curtis, Vice President, Engineering and Construction - Nuclear
- S. L. Denson, Project Construction Manager R. H. Featenby, Assistant Project Director
- B. D. Kenyon, Vice President - Nuclear Operations
- R. A. Lengel, Mechanical Maintenance Engineer R. Mattens, Senior Analyst T. C. Newman, QA Engineer
- R. A. Schwan, Assistant Manager - NQA Bechtel Power Corporation G. Bell, Project QA Engineer J. Dahnert, APFQCE G. Gelinas, PFQCE G. Glorvigen, QAE L. B. Mangoba, Piping Support Engineer B. Mukherjee, RE-PD J. E. O'Sullivan, Assistant Project Field Engineer R. V. Parekh, Plant Design Group Supervisor R. Slaughter, Lead QCE - Pipe Supports In addition to the above, several other engineers and licensee personnel were contacted during the course of inspection.
(Persons denoted * attended exit interview at NRC, Region I offices in King of Prussia, Pennsylvania on July 28,1982)
2.
Small Bore Pipe Support Adequacy of, Design and Installation The inspector selected one specific type of small bore pipe support for a detailed examination.
The item selected was a clamp used as an anchor on small bore pipe. The examination included:
the evaluation of design i
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adequacy of the clamp for intended use; proper installation to meet the design; and the adequacy of "As-built" verification of the installed item to document the actual installation. The small bore pipe design drawings applicable to the above supports were:
Detail 600 SPA 1312 SPA 600 A review of these drawings disclosed that the support was designed as a three directional (x, y, z) anchor, and the fabrication of the clamps were done per Detail 600. The design, however, provided a fabrication tolerance on the plus side. Therefore, if clamps with such tolerances were installed on the pipe, the clamp flanges would come into contact with each other, and frictional contact between the pipe and the clamp would not function properly as an anchor. NRC inspectors verified by visual examination and feeler gages that four out of a sample of seven installed supports did not provide frictional contact adequate to assure proper functioning of the supports as an anchor point.
a.
The review of drawings " Detail 600, SPA 600, and SPA 1312" also dis-closed that the bolts specified on these drawings were of two different grades. Detail 600 specified SA 307 bolts, whereas SPA 600 and SPA 1312 specified SA 325 bolts for fastening the clamp halves together.
The torque value specified on SPA 600 and SPA 1312 drawings for the i.
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SA 325 bolts was considerably higher than the Detail 600 requirement.
Because the frictional resistance between the pipe and the clamp is
dependent on the bolt clamping force, the difference in torque requirements significantly affects the design of the support. This is especially significant in view of using Detail 600 for installation and SPA 600 for analysis, assuming high strength bolting (SA 325) in all supports.
Furthermore, the length of the bolts specified on these drawings did not appear to provide positive connection. As an example, for a 1" diameter pipe clamp, the specified bolt is SA-325, 5/8" diameter, 2h" in length. A detailed review of these drawings shows that if the support is fabricated and installed properly, the total thickness of the two clamp plates (" ears") with maximum allowable gap of 1/8" will be 7/8".
Because a 2 " long SA 307 standard bolt has a thread length of 1h" and SA 325 has 1 ", in both the cases the bolt shoulder will be protruding out of the plane of the lower half clamp surface.
Therefore, no compressive force can be applied to the clamp unless washers are used to shim the clamp surface. An NRC field inspection verified that a substantial number of support clamps are installed without washers. Therefore, these supports may not fulfill their intended function. The NRC inspection identified that Detail 600 clamps modified in the field to meet SPA 1312 design have suffered distortion due to welding.
This is a violation of 10 CFR 50, Appendix B, Criterion III (82-31-01).
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b.
Bechtel engineering developed a fix based on shims which provide a four point contact between the pipe and the clamp. However, no analysis was furnished to justify such an approach, especially, the increased stress intensity on the pipe wall due to two point load in case of bending stresses in "x" or "y" directic,. Also, Detail 600 permitted higher allowable loads ca these suppo-ts than permitted by SPA 600. Therefore, a question remains as to tne proper sizing and pipe span limitation of the supports installed according to Detail 600. This item is unresolved pending further review of the analysis of the fix and its acceptability to function properly (82-31-02).
3.
Control of Approved Documents The inspector reveiwed the system of document control, and distribution of properly approved and current documents to users and their availability at the work location. The inspector determined that a design change resulted in the issuance of drawing SPA 600 in December, 1981, which superseded the detail drawing 600. However, this new drawing (SPA 600)
apparently was not transmitted to the field and installation and inspection of this type of support continued to be done in accordance with the superseded Detail 600 until July, 1982.
The failure to distribute revised drawings to the field is a violation of 10 CFR 50, Appendix B, Criterion VI (82-31-03).
4.
Adequacy of "As-Built" Verification and Final QC Inspections i..
The inspector discussed the inspection of small bore pipe hangers with Bechtel Field Engineering (FE) and QC personnel and reviewed selected QC inspection reports. The inspector was informed that hanger detail drawings prepared by FE were issued to construction for installation of the hangers. Upon completion of the work, FE performed an inspection and prepared as-built drawings.
Following revision for changes identified by FE, the as-built drawings (hanger details) are reviewed by QC for final inspection.
Drawings are revised as necessary by FE and final as-built hanger details together with piping isometrics are sent to Project Engineering (PE) for reconciliation with calculations. Any revisions following QC inspec-tion are returned for reinspection by QC.
A stress walkdown is performed by PE when as-built drawings are accepted.
The inspector reviewed the QC inspection reports (QCIR) shown below and discussed as-built inspections of small bore pipe hangers with Bechtel field engineers (FE), resident engineers (RE), and FQC.
QCIR 183B-M213-SP-HCC-135-4 (1A&B) for Hanger H1000.
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QCIR 183B-M213-SP-HCC-136-2 (2A&B) for Hanger H1001.
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QCIR 1838-M213-SP-HCC-136-3 (2A&B) and SP-HCCC-136-3 (3) for
Hanger H1002.
QCIR 183B-M213-SP-HCC-136-1 (6) for Hanger H1003.
- QCIR 183B-M213-SP-HCC-137-3 (A&B), SP-HCC-137-3 (9) and SP HCC
137-3 (9) for Hanger H5 QCIR 1838-M213-SP-HCC-137-2 (9) for Hanger H15.
- These inspection reports showed all of the above hangers to have been accepted by QC although four of the hangers were found to be nonconforming.
The inspector was informed that QC inspected each of the hangers to the hanger detail, a copy of which was attached to the QCIR.
However, the hanger details lacked dimensional tolerances for installation of the pipe clamps.. These dimensions were shown on " Detail 600" which was used for fabrication of the clamps and was referenced on the hanger detail but was not used by QC for inspection of the installed hangers. This item is unresolved pending revision of the QCIR to reflect the'se inspection attributes (82-31-04).
b.
As discussed in paragraph a. above, QC had not properly verified the installation of the clamps for dimensional tolerance and proper erection due to lack of such information on the support drawings.
The QC management informed the inspectors that in pipe support inspection, shop fabricated items were not verified because these items were considered as component / equipment. They are verified and accepted by receipt inspection at the time of delivery.
Although shop fabricated items are verified at the time of receipt, this verification / inspection is limited to the items conformance to the fabrication requirements and tolerances. When such " components /
equipment" are installed as an integral part of a pipe support, proper installation must be verified to assure the proper functioning of supports.
If the shop fabricated clamps are not verified for proper installation, the extent of this problem may affect a sub-stantial number of pipe support using shop fabricated clamps. This item is unresolved pending further information on the extent of such practices by the QC (81-31-05).
c.
As discussed in paragraph a above, the small bore pipe support design and installation had been inspected by Bechtel quality control and subsequently by field engineers performing an "as-built" verifi-cation program. The NRC inspection which identified the design and installation problems was conducted after the licensee inspections.
Licensee personnel accompanied NRC inspectors during the NRC inspec-tio.
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As a result of the identification of unacceptable support installation,
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PP&L initiated a follow-up verification consisting of 100% inspection to determine the acceptability of these supports. ~ Reinspection by the NRC of one such anchor (SP-HCC-137-2-15) was found to be a deficient installation. The improper inspection in this instance appears to be inadequate inspection criteria for inspection or inadequate training of the inspectors.
This is a violation of 10 CFR 50, Appendix B, Criterion II (82-31-06).
5.
Adequacy of Large Pipe Clamps with Trimmed Flanges (" Ears")
In simple pipe clamps, the flanges on the ends of the clamp are dimens'aned to satisfy the strength requirements for any particular application of this clamp. The length and width of the flange must be sufficient to resist the maximum bearing and tearing stresses ever expected in the clamp through the bolt hole.
The bearing failure of the clamp occurs in
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the x-direction and tearing in the y-direction. Therefore, sufficient material must be available around the bolt hole to withstand such stresses.
During a walk-through inspection, the inspector identified one clamp dttached to a shock suppressor (HBC-101-14-210) in containment on MSRV discharge line with flanges trimmed to avoid interference. The inspectors were informed that this incident had been identified and properly documented in the as-built drawings.
The inspectors requested the detailed evaluation documenting the adequacy of the installed clamp to determine the validity of such an analysis. No documented evaluation was furnished to the inspector.
This item remains unresolved pending further review of analysis and evaluation by the licensee of the extent of this practice (82-31-07).
6.
Pipe Supports Attached to Containment Wall During a walk-through inspection, the following supports were found attached to the containment wall with subsequent supports attached to reactor building floor:
(a) SP-HCB-105-1-H2039, Containment SP-HCB-105-1-H2041, Reactor Building l
(b) SP-HCB-133-H8 & H10, Containment SP-HCB-133-H11, Reactor Building (c) SP-HCB-126-H2021, Containment SP-HCB-126-H2024, Reactor Building This item is unresolved pending review of the analysis of the above support to determine the acceptability of above arrangement (82-31-08).
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Shock Suppressors on MSIV Air-Line The inspector identified two shock suppressors (snubbers) attached to suoport SP-HCC-136-H2003. The snubbers were attached to a floor mounted c
support, which in turn was attached, through the floor grating, to the structural steel framing of the floor. The inspector determined that the i
bottom section of the built-up support was a piece of 'I-beam' which could be easily moved in the transverse direction of the web of the beam.
This item is unresolved pending review of the design and installation of the above support for adequacy to fulfill its intended function (82-31-09).
8.
Adequacy of Structural Steel Floor Frames to Support Piping Loads On Elevation 749, area 26T, the inspector visually examined the structural steel floor frames for any obvious signs of damage, excessive deflection, warpage due to welding, and/or any indication of flange or web distress in structural beams used to attach pipe supports. The inspector determined that no such indications were apparent in the beams examined, and no violation was identified.
9.
Pipe Supports in Suppression Pool The inspector reivewed the following pipe isometric drawings and the associated supports.
SP-JCD-115-9 SP-JCD-115-10 SP-JCD-115-11 SP-JCD-115-12 SP-JCD-115-13 The above drawings were applicable to the following pipe restraints in suppression pool:
SP-JCD-115-H2 SP-JCD-115-H6 SP-JCD-115-H10 SP-JCD-115-H13 SP-JCD-115-H17 The inspector determined from the drawings that the above restraints and the associated systems were shown to be non-seismic and non-safety-related.
10. Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during the inspection are discussed in paragraphs 2, 4, 5, 6, and 7 of this report.
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d 11. Exit Interview The inspectors met with the licensee management (denoted * in paragraph 1) at the conclusion of the inspection. The meeting was held on July 28, 1982, at NRC, Region I offices in King of Prussia, Pennsylvania. The inspectors summarized the scope of inspection and discussed the inspection findings. A subsequent meeting with licensee was also held on July 30, 1982, at NRC Region I to discuss the licensees' proposed actions in
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i response to the above findings. The summary of meeting notes and the list of attendees are attached to this report.
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Attachment 1
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NOTICE OF EXIT MEETING WITH LICENSEE Name of Licensee:
Pennsylvania Power and Light Company Name of Facility:
Susquehanna Steam Electric Station, Unit 1
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Docket Number:
50-387 Date of Exit Meeting:
July 28,1982 Location of Exit Meeting:
NRC, Region I, 631 Park Avenue, King of Prussia, Pennsylvania Purpose of Meeting:
To discuss the findings of inspection conducted during the week of July 19-23, 1982 NRC Attnedees:
T. T. Martin, Director, Division of Engineering and Technical Programs, Region I S. D. Ebneter, Chief, Engineering Programs Branch S. K. Chaudhary, Reactor Inspector, EPB Licensee Attendees:
Note: Attendance by NRC personnel at this NRC/ Licensee meeting should be made known by July 27, 1982, via telephone call to S. Chaudhary, Region I, at FTS - 8-488-1266.
Prepared b :
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U K. Chaudhary Distribution:
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Attachm:nt 2
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SUMMARY OF MEETING
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Docket No. & Licensee:
50-387 -- Pennsylvania Power and Light Company I
Date and Time of the Meeting:
July 28, 1982 - 1:30 p.m.
Purpose of the Meeting:
To discuss the findings of inspections con-
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ducted during the week of July 19-23, 1982 A.
Following Items were discussed in the' Meeting:
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I 1.
Inadequate design and installation of clamps used as anchor on small
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bore pipes.
2.
Use of sueprseded design drawings for installation and inspection of these clamps.
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3.
The adequacy of the as-built verification program, and QC inspection.
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The licensee's follow-up inspection program.
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5.
Trimming of clamp flanges and their adequacy to function properly.
6.
QC inspection of shop fabricated components for pipe support during and after installation.
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B.
The NRC management informed the licensee of their concerns in these areas, and that there are several apparent noncompliances that will be categorized l
upon completion of the NRC inspection. The licensee was informed that reso-i lution of the above concerns is necessary before a significant core power history can be permitted to develop.
Enforcement options available to
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the NRC were also discussed.
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C.
The licensee acknowledged the above findings and informed NRC of his i
on going activities in this area to resolve the above concerns. The licensee j
also committed to develop a comprehensive plan to investigate the cause(s)
and effect(s), and the extent of this problem in the pipe support system.
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The licensee committed to meet with Region I to discuss the plan as soon as possible and would notifs T. T. Martin by telephone of the date and time.
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Attachment 3
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EXIT MEETING FOR 50-387/82-31 ATTENDEES Nuclear Regulatory Commission J. M. Allan, Deputy Regional Administrator S. K. Chaudhary, Reactor Inspector J. P. Durr, Chief, Materials and Processes Section, EPB S. D. Ebneter, Chief, Engineering Programs Branch R. R. Keimig, Chief, Project & Resident Programs Branch T. T. Martin, Director, Division of Engineering and Technical Programs E. C. McCabe, Chief, Reactor Projects Section 2B Pennsylvania Power and Light Comnany
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R. G. Byram, Supervisor of Maintenance
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T. M. Crimmins, Manager, Nuclear Plant Engineering N. W. Curtis, Vice President, Engineering & Construction S. L. Denson, Project Construction Manager B. D. Kenyon, Vice President, Nuclear Operations R. A. Lengel, Mechanical Maintenance Engineer R. A. Schwan, Assistant Manager, NQA
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Attachment 4
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NOTICE OF SIGNIFICANT LICENSEE MEETING Name of Licensee:
Pennsylvania Power and Light Company Decket Number:
50-387 Date and Time of Meeting:
July 30, 1982 -- 1:00 p.m.
Location of Meeting:
NRC, Region I; 631 Park Avenue, King of Prussia, Pennsylvania Purpose of Meeting:
Management Meeting to discuss proposed corrective actions for Small Bore Pipe Support Problems NRC Attendees:
J. Allen, Deputy Regional Administrator T. T. Martin, Director, Division of Engineering and Technical Programs S. D. Ebneter, Chief, Engineering Programs Branch R. R. Keimig, Chief, Projects Branch #2 J. P. Durr, Chief, Material and Processes Section, EPB E. C. McCabe, Chief, Project Section #2B S. K. Chaudhary, Reactor Engineering Inspector, MAPS R. Perch, Project Manager, NRR Licensee Attendees:
N. W. Curtis, Vice President, Engineering and Construction - Nuclear B. D. Kenyon, Vice President, Nuclear Operations and Staff NOTE: Attendance by NRC personnel at this NRC/ Licensee meeting should be made known by July 29, 1982 via telephone to S. K. Chaudhary, Region I at FTS-8-488-1266.
Prepared b : <[. M_uk/e>
gK.Chaudhary Distribution William J. Dircks, Executive Director for Operations Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements Richard C. DeYoung, Director, Office of Inspection and Enforcement James Lieberman, Acting Director, Enforcement Staff, IE James P. Murray, Director, Rulemaking and Enforcement Division, ELD Attendees
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Attachm:nt 5
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MEETING SUMMARY Licensee: Pennsylvania Power and Light Company Docket No: 50-387 Facility: Susquehanna Unit 1 Date: July 30, 1982 Purpose: The purpose of the meeting was to discuss the licensee's plan of action to correct the small bore piping design deficiencies identified in an allegation made to the NRC.
Summary:
1.
The licensee presented flow diagrams of the proposed action plan and identified major events critical to the resolution of NRC concerns.
2.
The NRC Staff answered technical questions related to the findings presented during the July 28, 1982, meeting.
3.
The licensee will submit details of the action plan to the NRC for review as they are developed.
4.
The licensee plans to meet with the NRC on or about August 16, 1982, to discuss plan status.
5.
Technical problems must be sufficiently identified and evaluated on or before August 25, 1982, to permit NRC review and still support the projected criticality schedule.
Attendees:
Attachment 6-a
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ATTENDANCE LIST Ju13 30,1982 Pennsylvania Power and Light Company W. E. Barberich, Manager, Nuclear Licensing T. M. Crimmins, Manager, Nuclear Plant Engineering N. W. Curtis, Vice President, Engineering and Construction - Nuclear R. A. Schwan, Assistant Manager, NQA Nuclear Regulatory Commission J. M. Allan, Deputy Regional Administrator S. K. Chaudhary, Reactor Inspector J. P. Durr, Chief, M&PS R. C. Haynes, Regional Administrator T. T. Martin, Director, DETP E. C. McCabe, Chief, RPS 2B L. Narrow, Reactor Inspector R. L. Perch, Licensing Project Manager, NRR