IR 05000416/1979021
| ML19257D290 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/31/1979 |
| From: | Bryant J, Wilcox J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19257D273 | List:
|
| References | |
| 50-416-79-21, 50-417-79-21, NUDOCS 8002040033 | |
| Download: ML19257D290 (11) | |
Text
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o IE Special Inspection Report Nos. 50-416/79-21 and 50-417/79-21 SUBJECT: MISSISSIPPI POWER AND LIGHT COMPAhT GRAND GULF NUCLEAR PLANTS, LWITS 1 & 2 ITEMS OF CONCERN REGARDING SYSTEM DESIGN AND MECHANICAL / PIPING QUAL 1TY CONTROL PRACTICES FOR FABRICATION OF SAFETY-RELATED PIPING SYSTEMS Period of Special Inspection: August 21 - September 7, 1979 Inspector:
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/' Reactor Construction and Engineering Support Branch Revieued by:
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p'C T Brypfit', ~Section Chief, RCES Branch Date Signed 1864 125 g00204e08A
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TABLE OF CONTENTS I.
INTRODUCTION II.
SCOPE OF SPECIAL INSPECTION III.
CONCLUSIONS IV.
DETAILS OF SPECIAL INSPECTION A.
Persons Contacted B.
Items of Concern, Discussions and Findings C.
Additional Item Identified During Special Inspection 1864 126
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I.
INTRODUCTION An individual contacted NRC Region II representatives on August 8 & 9, 1979, to express concerns regarding system design and mechanical / piping quality control (QC) practices at Mississippi Power and Light Company's (MP&L) Grand Gulf Nuclear Plants. A special inspection was initiated.
The following specific items of concern were examined:
A.
Somewhere between ene hundred and two hundred feet of the Residual Heat Removal (RHR) system return line is anchored in concrete without any provisions for the rmal expension.
The individual pointed out that provisions for thermal expansion had been made in the RHR inlet lines.
These provisions included expansion loops and pipe supports / restraints.
B.
Safety valves are installed on the suction side of the Control Rod Drive (CRD) pumps.
The individual stated that he did not believe the safety valves were necessary. He was concerned that should the safety valve inadvertently lift, when one CRD pump was out of service for maintenance, the second pump would be destroyed and water would not be available to control the rod drive mechanisms.
C.
Globe valves in the High Pressure Core Spray (HPCS), Low Pressure Core Spray (LPCS) and Residual Heat Removal (RHR) systems were intended to be installed backwards because dif ferential pressure in an accident situation would be reversed from that under normal flow conditions. The individual stated that the HPCS valves were installed properly; however, the LPCS and RHR valves had been installed incorrectly.
He believes that attempts to open these valves during accident conditions would cause valve motor trips, thus preventing opening of these valves electrically.
D.
Hydros have been performed on systems which did not have high point vents. The individual stated that to his knowledge no such hydro had been accepted in that he refused to accept them until vents had been installed and the hydro repeated.
However, the individual is concerned that the licensee may be continuing the practice of hydroing systems which do not have high point vents.
E.
An 18-inch swing-disc checkvalve had been installed upside down.
This error was corrected and the valve was reinstalled properly.
His concern in this case is with the pipe fitters, welders, foreman and superintendents whose attitude would allow such an obvious mistake to occur.
The onsite special inspection at the Grand Gulf site commenced on August 21, 1979 and was completed on September 7, 1979. During the period of August 8, 1979 - September 7, 1979, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and direct observations of hardware.
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-2-The onsite inspection was concluded on September 7,1979 with a rueeting of NRC and MP&L representatives during which the inspector outlined the preliminary results of the special inspection. During the special inspection, one item unrelated to the items of concern was identified on September 7, 1979. The item concerns Field Engineering revising Project Engineering issued drawings. The licensee was informed on September 7, 1979 that this would be identified as Unresolved Item (416/79-21-04 & 417/79-21-01:
Changes to Project Engineering issued drawings).
This item will be inspected at a later date to determine if a procedure existed, at the time of the initial inspection, which allows Field Engineering to revise Project Engineering issued drawings.
This special inspection required a total of 40 man-hours of onsite inspection effort.
II.
SCOPE OF SPECIAL INSPECTION The scope of the special inspection included the following:
A.
Interviews with 19 site personnel including QC and QA representa-tives, welders, pipefitters, engineers, and supervisors.
B.
Review of the following selected diagrams / drawings:
System P&I diagrams, pipe support drawings, system piping isometric drawings and vendor valve drawings.
C.
Review of the following selected records:
Valve and large pipe installation cards, valve and large pipe inspection records, field welding check list, filler metal withdrawal authorizations, certified reports of nondestructive examination and piping system test release forms.
D.
Review of the following selected correspondence:
Instructions and specifications:
quality action requests, notices of reinstal-lation, MP&L and Bechtel internal / external correspondence, Bechtel design specifications, construction performance standards and quality control instructions.
E.
Observation of the as-built conditions of components and piping configuration of all items of concern.
III.
CONCLUSIONS One of the five items of concern was substantiated; three of the items were without substance and one item is under further evaluation.
The inspector identified one infraction, two unresolved items, and one inspector followup item (see paragraphs IV.C.1, IV.C.2, IV.B.3, and IV.B.1).
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IV.
DETAILS OF SPECIAL INSPECTION A.
Persons Contacted In addition to the conver' tion with the concerned individual, the following individuals are contacted.
Mississippi Power and Light Company (MP&L)
T. E. Reaves, Jr. Manager of QA W. J. Hendry, Plant Engineer W. R. Patterson, Plant Engineer W. E. Edge, QA Program & Audit Coordinator B. C. Lee, QA Representative J. C. Fuller, Acting QA Field Supervisor H. D. Morgan, Construction Supervisor D. F. Mahoney, QA Representative M. R. Knight, Technical Support Bechtel Power Corporation (Bechtel)
R. L. Scott, Project QA Manager J. R. Valdez, QA Engineer J. W. Yelverton, QA Engineer P. S. Collings, QA Engineer J. H. McCarty, Project Field QC Engineer C. A. Torell, Project Superintendent T. W. Habermas, Project Field Engineer J. K. Conway, Assistant Project Field QC Engineer W. E. Knight, Welder B.
Items of Concern, Discussions and Findings 1.
Items of Concern Somewhere between one hundred and two hundred feet of the Residual Heat Removal (RHR) system return lines are anchored in concrete without any provisions for thermal expansion.
The individual pointed out that provisions had been made for expansion in the RHR inlet lines.
Discussion The inspector reviewed licensee requirements and observed the as-built condition of this item of concern.
It was determined by the inspector through direct observation and conversations with production and quality control personnel that the above description of the item of concern was in error.
For example, the RHR system is not anchored in concrete and while there are no expansion loops in this system, there are provisions for expansion of the RHR piping.
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-4-However, the stand-by service water system ties into the RHR system, and it is anchored in concrete at the auxiliary building concrete wall.
In addition, the stand-bv trvice water system has expansion loops in the supply ano return lines. From the above justification, the NRC incpector feels that the actual item of concern is that somewhere between one hundred and two hundred feet of the Stand-By Service Water System is anchored in concrete without any provisions for thermal expansion.
It should be noted that the standby service water supplies the RHR system with cooling water.
a.
Requirements The portion of piping which contains expansion loops on the Standby Service Water is installed in accordance with the following system piping isometric drawings:
Loop Identification DWG#
Loop A M-1358 A Rev 15 Loop B M-1358 D Rev 11 In addition these piping configurations are suppcrted with pipe supports and restraints as shown on detail piping support drawings.
Also the piping penetration through the auxiliary building concrete wall is supported and restrained by a pipe support embedment plate as shown on Texas Pipe Bending Company DWG#M-0799R/0 PC NO AP-58A.
b.
Observation The return line for " loop A" and the supply line for
" loop B"
were traced to ensure they complied with DWG#M-1358A, Rev 15 and M-1358D, Rev 11, respectively.
The piping configuration and hanger locations are as shown per the applicable piping isometric drawings and piping support drawings. On the Stand-by Service Water System, the expansion loop for " loop B " DWGM-1358D, Rev 11, is located in the supply line. The NRC inspector requested MP&L to provide input / justification /and clarification to the following items:
1)
Provide rationale as to why the difference in location of the expansion loops.
(The expansion 1864 130
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-5-loop for " Loop B" is located in the supply line and for " Loop A" the return line.)
2)
Determine if the actual as designed location of the loops will have any effect on the operability and safety of the system.
MP&L replied in writing to items (1) and (2) as follows:
(Reply 1&2) Expansion loops have been designed as shown in order to meet piping stress allowables. Pipe configu-rations, branch lines and support locations are dif ferent for the two loops, thus resulting in different require-ments. Piping stress analysis was based on actual pipe configuration, support / anchor locations as shown on the latest isometric drawings, therefore location of the loops has no detrimental effect on the operability and safety of the system.
All stress allowables and GE nozzle allowables (RHR Heat Exchangers) have been met.
The above noted reply is identified on Bechtel's Quality Action request (QAR) identification No. F-153.
Finding The revised item of concern has not been substantiated at this time. The explanation of the above conditions in the form of a reply will be reviewed by the NRC staff during upcoming inspections.
This item is identified as inspector followup item (416/79-21-02) " Expansion Loops on Stand-by Service Water System".
2.
Item of Concern Safety valves are installed on the suctica side of the Control Rod Drive (CRD) pumps. The indi idual stated that he did not believe the safety valves we.e necessary. He was concerned that should the safety valve inadvertently lift when one CRD pump was out of service for maintenance, the second pump would be destroyed and water would not be avail-able to control the rod drive mechanisms.
Discussion The inspector reviewed licensee requirements and justification and observed the as-built conditions in the auxiliary building of Unit #1.
a.
Requirement lbbN l3)
The Control Rod Drive (CRD) system has been designed in accordance with the criteria specified in paragraph 4.2.3.2 of the Preliminary Safety Analysis Report
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-6-(PSAR). The portion of the CRD system that contains the CRD pumps and relief valves is not safety related and failure of these components will not jeopardize the emergency shutdown function of the CRD system.
b.
Observation The portions of the CRD system noted above were examined to ensure that they complied with the applicable system isometric drawings. It should be noted that installation of the entire system is not complete in this area.
Findings The item of concern was not substantiated. No items of noncompliance or deviations were identified.
3.
Item of Concern Globe valves in the HPCS, LPCS and RHR system were intended to be installed backwards because differential pressure in an accident situation would be reversed from that under normal flow conditions.
The concerned individual stated that the HPCS valves were installed properly; however, the LPCS and RHR valves had been installed incorrectly.
He believes that attempts to open these valves during accident conditions would cause valve motor trips, thus preventing opening of these valves electrically.
Discussion The investigator reviewed licensee requirements, reviewed licensee records, and observed the individual motor operated globe valves including location, orientation and flow consider-ations.
a.
Requirements The requirements for the following valves, associated systems and isometric P&I drawings were reviewed by the investigator:
Isometric Drawing Identification Valve #
Size / Type System DWG #
F024A 18" Gate RHR M 1348D F024B 18" Gate RHR H 1348E 1864 132
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-7-F011A 4" Globe RHR M 1348A F021 14" Globe RHR M 1348S F012 14" Globe LPCS M 1350A F023 12" Globe HPCS M 1349A P&I Diagram Identification Valve #
Diagram #
F024A M-1085 A&B Rev 9 F024B M-1085 A&B Rev 9 F011A M-1085 A&B Rev 9 F021 M-1085 A&B Rev 9 F012 M-1086 Rev 10 F023 M-1087 Rev 8 b.
Observation Each of the noted valves was examined to verify orien-tation, direction of flow and compliance with the associated drawings.
The valve installation cards and valve inspection records were reviewed for completeness.
A field note has been added to isometric drawing M-1350A, Rev 17 (Valve F012) and M-1349A, Rev 13 (Valve F023)
which states, " Install valve with packing gland on upstream side of the valve disc."
However, valves liQIE12-F021, QIE21-F012 and QIE12-F011A are installed in the normal installation position with the packing gland on the downstream side of the valve disc.
The NRC inspector requested MP&L to provide input /
justification /and clarification to the following items related to the above noted (3) valves:
1.
Provide rationale by which the above valves were installed in the normal position in lieu of G.E.'s recommended reverse position.
2.
Will the normal valve position have any effect on system safety or adverse effects on surrounding environments?
3.
What is the mechanism for incorporating field revisions on isometric drawings (as noted abeve)?
4.
Provide rationale by which valve F083 was not used.
Valve is shown on Bechdel P&I Diagram M-1085, Rev 9, note 2.
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Determine why the general note on P&I Diagrams was lef t off of the isometric drawings.
6.
Determine why P&ID drawing notes require that valves F024A and F024B (gate valves) are to be installed in reverse position.
This condition implies that valves F0244 and F0243 were intended to be globe valves.
The reply to the above inquiry will be reviewed upon receipt.
Finding This item of concern is substantiated. This item is identified as Unresolved Item (416/79-21-03) " Valve Orientation".
4.
Item of Concern Hydros have been performed on systems which did not have high point vents. The individual stated that, to his know-ledge, no such hydro had been accepted in that he refused to accept them until vents had been installed and the hydro repeated. However, he is concerned that MP&L may be contin-uing the practice of hydroing systems which do not have high point vents.
Discussion The inspector reviewed the following licensee requirements which require installation of vents and drains for hydros:
1)
Bechtel Design Specification No. 9645-M-204.0, paragraphs 5.7.7, 6.3.6, and 6.3.23, and Appendix S, paragraphs 5.1.3, 5.2, 5.3.1 and 5.3.1.2, delineate the design criteria for installation of vents and drains for hydrostatic test.
2)
Bechtel Construction Performance Standard CPS-P-18 Vol. III Rev 0 paragraph 6.11.5 A, " Prerequisites to Testing", requires that adequate vents and drains be installed.
3)
Bechtel Quality Control Instruction No. 9.1-6 Rev 1, paragraph 5.2.1, specifies that testing operations provide for proper venting and filling.
4)
Piping System Test Release Form # CPS-P-18-01 (4/75),
paragraphs 6 & 11, require sign-off by the piping engineer and test engineer which includes verification of sufficient vents and drains.
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Findings All of the test records reviewed for verification of suf-ficient vents and drains were satisfactory.
The above requirements include requirements for high point vents and are adequate for the installation of vents and drains prior to hydrostatic tests. The item of concern was not substan-tiated. No items of noncompliance or deviaticn were identi-fied.
5.
Item of Concern An 18-inch swinging-disc check valve had been installed upside down.
This error was corrected and the valve was reinstalled properly. The individual's concern in this case is with the pipe fitters, welders, foremen and superintendents whose attitude would allow such an obvious mistake to occur.
Discussion After observation of the as-built condition, interviews with production and QC personnel and a review of the reinstallation instruction, it was determined that the valve in question is a 12"
"Y" check valve in the RHR system.
The valve is identified as F050 and is shown on system piping isometric drawing #M-1348E Rev 13.
The inspector reviewed licensee requirements and observed that the valve orientation was correct.
a.
Requirements Check valve F050 was initially installed upside down, thus making it non-operable. The valve was identified as being improperly installed, was cut-out and reinstalled correctly in accordance with the guidelines specified in the Notice of Reinsta11ation IBP-936. After comple-tion of the work, it is a requirement / responsibility for QC Engineering to sign-off Valve Inspection Record Block
- 5 " Correct Valve Orientation". This sign-off requirement identifies such problems as inverted check valves.
This condition was identified by QC and corrected.
Findings Of the individuals interviewed, an adequate concern for QC/QA workmanship was evident. The item of concern was not substantiated. No items of noncompliance or deviations were identified.
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C.
Additional Items Identified During Special Inspection 1.
The motor operated Low Pressure Core Spray (LPCS) system globe valve F012 is not installed in accordance with the applicable P&I diagram #M-1087, Rev 10 (note 2), and piping isometric drawing #M-1350 A, Rev 17. These drawings specified installation of valve F012 with the packing gland on the upstream side of the valve disc.
In addition, the valve inspection record for valve F012 had been signed off by the concerned individual (Q.C.E.) as having correct flow orienta-tion verified. The NRC inspector has determined from direct observation and information radiographs that the valve F012 is installed with the packing gland on the downsteam side of the valve disc. This item will be identified as an Infraction (416/79-21-01) "LPCS" system globe valve F012 incorrectly installed.
2.
It was observed that Field Engineering is adding notes and making changes to isometric drawings.
The isometric is a Project Engineering issued drawing.
No Field Engineering procedure was located which allowed Field Engineering to change Project Engineering's drawings.
The hTC inspector has directed MP&L to provide input / justification /and clari-fication to the following items:
a)
Determines if a procedure exists which allows Field Engineering to revise Project Engineering issued drawings as noted above.
b)
Investigate for similar conditions and determines the extent.
This item is identified as unresolved item (416/79-21-04 &
417/79-21-01) " Change to Project Engineering drawings" The licensee's reply to the above inquiry will be evaluated upon receipt by RII.
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