IR 05000424/1986044
| ML20213G453 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/03/1986 |
| From: | Blake J, Novak T, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20213G441 | List: |
| References | |
| 50-424-86-44, NUDOCS 8611180129 | |
| Download: ML20213G453 (40) | |
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Report No: 50-424/86-44 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 Construction Permit No.: CPPR-108 Facility Name: Vogtle 1 Module: No. 11, Pipe Stress and Supports l
Reviews Conducted: March 25, 1986 - June 20, 1986 On-Site Inspections Conducted: May 5-9 1986; May 27 - June 5, 1986 NRC Offices Participating in Inspections / Reviews:
Region II, Atlanta, GA Office of Nuclear Reactor Regulation (NRR), Bethesda, MD Office of Inspection and Enforcement (IE), Bethesda, MD Inspectors: Steven J. Vias, Reactor Inspector, Region II Gregory K. Miller, Consultant, Region II (EG&G Idaho)
Reviewer: Gar a er, NR Approved by:
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Date Signed M erials an Process Section ivision of ctor Safety, Region II
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B G, T. Novak, Deputy Dir4ctor Date Signed Division of PWR Licensing A Office of Nuclear Reactor Regulation (NRR)
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CONTENTS Topic Page Summary iii Scope of Review
Methodology
Evaluations
Findings
Conclusions
References
Tables
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE 11 PIPE STRESS AND SUPPORTS SUMMARY Georgia Power Company (GPC) is conducting the Readiness Review Program to assure that all design, construction, and operational commitments have been properly identified and implemented at the Vogtle Electric Generating Plant (VEGP) Unit 1.
Module 11, which was submitted on February 28, 1986, presents an assessment of compliance with licensing commitments of pipe stress analyses and pipe supports for American Society of Mechanical Engineers (ASME) Classes 1, 2 and 3 and Seismic Category II/I piping systems.
The evaluation described in this report was conducted to determine whether the results of the Readiness Review Program review of pipe stress and pipe supports presented in Module 11 represent an accurate assessment of the requirements, that the requirements were properly
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implemented, and that the resolutions to findings were appropriate.
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The evaluation was performed by NRC inspectors from Region II, along with reviewers from the Office of Nuclear Reactor Regulations (NRR).
An additional evaluation of the Independent Design Review (IDR) will be performed by the Office of Inspection and Enforcement (IE).
The NRC Region II and NRR evaluation was accomplished through a detailed examination of all sections of Module 11 by:
1.
Verifying that commitments related to pipe stress and pipe supports were identified in accordance with the FSAR and other commitment sources, 2.
Verifying that a sample of these commitments were~ implemented in design and construction procedures, specifications, and design criteria, 3.
Checking a representative sample of the documents reviewed by Readiness Review personnel and an independent sample of documents selected by the NRC
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inspectors, 4.
Inspecting a representative sample of pipe supports currently installed in
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Unit 1, and supporting quality control (QC) documentation,
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Reviewing results from previous NRC inspections at Vogtle' Unit 1 pertaining to Module 11, 6.
Reviewing Module 11 findings and their resolutions.
During this evaluation, it was apparent to the NRC Region II inspectors that GPC management supported the Readiness Review program by active participation in the development and implementation of the program.
This evaluation also indicates that the applicant's program review was comprehensive and provides adequate iii
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assurance that, except for several findings identified by the NRC Region II inspectors, pipe stress and pipe supports for the Vogtle plant are in accordance with NRC requirements and FSAR commitments.
The findings are subject to continuing review until proper resolution has been reached.
The findings identified during this evaluation are summarized in the eight items listed below:
Deficiency - Omission of two design commitments from the Commitment Matrix, (IFI 424/86-62-01),
Deficiency - Three unresolved questions on commitment implementation, (UNR 424/86-62-02),
Deficiency - Inadequate construction procedures for installation and inspection of spring supports and installation and inspection of clamps and clamp bolts for mechanical shock arrestors, (VIOL 424/86-62-03),
Deficiency - Discrepancies in design documentation, (VIOL 424/86-62-04),
Deficiency - Unclear use of the word "typ" in weld callouts, (UNR 424/
86-62-05),
Deficiency - Discrepancies between the pipe support installations and associated documentation, (VIOL 424/86-62-06),
Deficiency - Two hardware deficiencies, (IFI 424/86-62-07),
Deficiency - Inadequate review by Readiness Review of installation and
inspection of spring supports, (DI 424/86-62-08).
The foregoing do not appear to represent significant programmatic weaknesses.
This conclusion is reached under the condition that these open items for VEGP Unit I can be satisfactorily closed.
Resolutions to all open items will be handled during future NRC Region II inspections.
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e V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE 11 PIPE STRESS AND SUPPORTS 1.
Scope of Review This review consisted of an examination of each section of the module and was performed by inspectors from Region II along with reviewers from the Office of Nuclear Reactor Regulation (NRR).
An additional review of Section 7, Independent Design Review, will be performed later by the Office of Inspection and Enforcement (IE).
The Region II review was assisted by one employee from EG&G Idaho, Inc., a prime contractor to the U.S. Depart-ment of Energy at the Idaho National Engineering Laboratory.
Module 11, Sections 1.0, 2.0, 4.0, 5.0, and 8.0, presented data on module organization, project organization, program description, audits and special investiga-tions, and conclusions.
These did not require as extensive a review as Sections 3.0, 6.0, and 7.0, which covered commitments, program verification, and independent design review.
The latter three sections contain the more significant aspects of the program relating to licensing commitments. These include commitment identification, commitment implementation into the design and construction programs, and technical adequacy of the design in meeting the commitments.
The evaluation of these three sections included an examination of content, review of findings and conclusions, review of a sample of items previously reviewed in the Readiness Review Program, and review of an independently selected sample of documents and field construction.
The methodology used and an evaluation of each section are presented in the following paragraphs.
2.
Methodology a.
Region II Review The NRC review performed by the Region II inspectors was concerned with all sections of the report except Section 7, but focused on Subsections 3.5, 6.1, and 6.2.
The entire Module was read and reviewed for organization and content after its receipt in February 1986. This was supplemented by a presentation of a summary of the Readiness Review Program for Module 11 made by Georgia Power Company (GPC) at Region II offices on March 25, 1986.
The Region II inspectors further reviewed Module 11 by conducting two on-site inspections at Vogtle Electric Generating Plant (VEGP) Unit 1.
The first inspection, documented in Inspection Report 50-424/86-35, was made during May 5-9, 1986, which involved the following activities:
Reviewing the description of the Readiness Review program and establishing organizational responsibilities for Module 11 Verifying Module 11 review boundaries
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Evaluating Sections 3 and 6 of the Final Safety Analysis Report (FSAR) for proper identification of licensing and project commitments
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Selecting a sample of commitments to be used as a basis for verifying implementation of licensing and project commitments into the design and construction procedures and design criteria Selecting a sample of piping isometrics to be used in the assess-ments of Subsections 6.1 and 6.2 of the Module 11 report Assessing three Level I findings reported in the Module 11 report A sample of 11 piping isometrics having 50 associated pipe supports were selected to form a basis for the detailed assessment of the Design and Construction Verification Programs, Subsections 6.1 and 6.2, of Module 11.
The isometrics chosen represent a diversity of pipe systems, sizes, locations, and pipe class. Readiness Review personnel were requested to have available for the second site inspection all pertinent design and construction documentation relative to the selected piping isometrics and supports.
A sample of 41 commitments were selected from among those listed in Subsection 3.4 of the Module 11 report to form a basis for verification of commitment implementation into the design and construction programs.
The comitments chosen represent a range of commitment categories embracing the significant aspects of Module 11. These commitments were selected to verify that they were properly transferred from commitment source documents to the first-order implementation documents listed in Subsection 3.5 of Module 11.
Sections 3. and 6. of the FSAR were reviewed to evaluate whether the commitments pertaining to pipe stress and pipe supports, contained therein, were accurately identified in the commitment matrix in Subsection 3.4 of Module 11.
Questions raised as a result of this evaluation were discussed in interviews with Readiness Review personnel.
Finally, an assessment was made on three of the Level I findings resulting from Readiness Review's Design and Construction Program Verifications.
Questions raised on two of these findings were responded to by Readiness Review personnel during the second site visit.
The second on-site inspection documented in Inspection Report No. 50-424/86-62, was conducted during May 27 to June 6,1986, which included the following activities:
Completing verification of commitment implementation into design and construction programs Accomplishing general Module 11 review activities
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Performing a Design Program Verification review
Performing a Construction Program Verification review
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y Each of the commitments in the 41 commitment sample was traced for implementation into the first-order documents listed in the implemen-tation matrix of Module 11.
Eighteen of these commitments were also traced for implementation into second-order documents (calculations, drawings, etc.) or field installation.
General review activities included an assessment of the information presented in Sections 1, 2, 4, 5 and 8 of Module 11.
Questions concerning these sections of the Module were discussed with Readiness Review personnel.
An evaluation of the Design Program Verification was made by reviewing a portion of the stress calculations for the eleven selected piping isometrics and their 50 associated pipe supports.
These calculations and related design criteria, drawings, and change documentation were reviewed for adequacy of design control, adherence to criteria and procedures, and design integrity.
An evaluation of the Construction Program Verification was made by performing a field inspection of all piping installation and pipe supports included in the selected sample of eleven piping isometrics
and 50 pipe supports.
In addition to this field inspection, all of the Pullman Power Products (PPP) Quality Control (QC) documents associated j
with the 50 pipe supports were reviewed for conformance to specifica-i tions and procedures, and for compliance with design drawings.
b.
NRR Review The NRR review of Vogtle Readiness Review Module 11, Pipe Stress and Supports, was initiated by a review of the commitment matrix (Section 3.4.).
The review consisted of a comparison of the commit-ments listed in Section 3.4 and with the guidance contained in the Standard Review Plan (SRP) and other regulatory documents (SER, FSAR and Generic Letters).
The staff also reviewed the commitments to ensure that all commitments necessitated by the Standard Review Plan were included in the Readiness Review Program (all modules).
In addition, the commitment matrix was reviewed to see if it contained commitments made by the applicant in response to NRC questions developed for the SER and its following supplements (SSER 1 and 2).
c.
IE Review The review to be performed by IE will focus on the Independent Design Review (IDR) reported in Section 7.0 of the Module and will be com-pleted and addressed in Readiness Review Module 22, Independent Design Review.
Section 7.0 will be read for general content, coherence, and completeness. The IDR findings and corrective actions will be reviewed to verify validity and implementation.
Specific design calculations will be selected and independently reviewed for technical adequacy.
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Selected construction drawings will also be examined for correct trans-
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fer of design information to the drawings.
3.
Evaluations The evaluation of each Module section is provided below in the section-by-section format used in the Module 11 report. Included are a description of the section, subject matter reviewed, basis for acceptance, and statement of required followup or evaluaticn.
a.
Section 1.0--Introduction (1) Review Introduction and Section Examination.
This section pre-I sents the scope of Module 11, lists the key hardware end work activities included, outlines the Module organization, and reports the project status. The section was examined by the NRC Region II inspectors for appropriateness of scope and for background infor-mation.
Additionally, the Module boundaries were clarified and project status was assessed.
(2) Boundary Definition.
Table 1.1-1 of Module 11 lists the hardware and associated work activities for modules that have mechanical i
aspects. Module 11 included those activities (stress analyses and pipe support design) for ASME Code Section III, Class 1, 2 and 3 piping within the scope of Bechtel Power Corporation (BPC) and Vogtle Structural Analysis Mobile Unit (V-SAMU). A review of this information showed that Module 4 included construction and fabri-cation of American Society of Mechanical Engineers (ASME) Code Section III Class 1, 2, and 3 piping and mechanical equipment. At the time of verification, Westinghouse was responsible for the complete Class 1 stress analyses for 4-inch and larger piping and for the fatigue analysis for all other Class 1 piping.
The Westinghouse work activity was excluded from the scope of Module 11.
The design and construction of piping systems in the Nuclear Steam Supply System (NSSS) were included in Module 16.
Also contained in Module 11 were stress analyses of nonsafety related piping that must meet Seismic Category I requirements for protection of safety-related components.
Module 11 also included design and construction of pipe supports for all piping systems mentioned above. Also contained in Module 11 was the construction of pipe whip restraints, but the design of these restraints lay within Module 8.
The attachment of pipe supports to embedments cast into Category I concrete were included in Module 11 while the embedments themselves belonged to Module 8.
The NRC Region II inspectors found the description of Module 11 boundaries to be acceptable.
(3) Project Status.
Subsection 1.3 of Module 11 presents the project status for design and construction of small-bore and large-bore pipe supports.
Percentages of completion were quoted as of
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August 1, 1985.
These percentages were revised as of April 4, 1986, to show 100% completion for design of small-bore and
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large-bore pipe supports, 81% completion for construction of small-bore supports, and 96% completion for construction of large-bore supports.
The status for design of piping itself is reported in Module 4.
The NRC Region II inspectors determined that the project status indicated significant progress in the pipe
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support program.
b.
Section 2.0--Organization and Division of Responsibility This section describes the organizations involved in design and construction for Module 11.
It explains what personnel are responsible for specific design and construction activities, and presents the matrix organization used by the architect / engineering contractor on the project.
This section was reviewed by NRC Region II inspectors for content and accuracy.
In the process of this review, the responsi-bilities of the various organizations and personnel within the i
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organizations were clarified.
The NRC Region II inspectors had no findings in this section.
c.
Section 3.0--Commitments
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(1) Review Introduction and Section Examination.
This section contains listings of comitments and implementing documents, which are displayed in two matrices.
The first matrix, entitled
"Comitment Matrix," identifies all of the Module 11 commitments and their source documents.
The second matrix, entitled "Implementa-tion Matrix," lists the document or plant feature for each comitment, ac discussed in the source document, and the project document in which the comm.itment is implemented.
The NRR review of the comitment matrix was directed toward assuring that all regulatory requirements relating to pipe stress and pipe supports withir. the scope of Module 11 were included and properly identified. The NRC Region II review was directed toward verifying the proper implementation of the listed comitments.
The latter was accom-plished by selecting a sample of 41 commitments representing the range of commitment topics.
Each sample commitment was examined by reviewing the commitment source document for the precise requirement and the listed implementation document (in the Implementation Matrix) for accurate carry through of the require-ment.
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(2)
Identification Review.
The NRC Region II inspectors' review of FSAR Sections 3.0 and 6.0 and the Module 11 Commitment Matrix initially indicated that several GPC commitments had been omitted from the commitment matrix.
In most such instances, Readiness Review's explanation was that the commitment had been identified but was more appropriately placed in another module.
In other cases, the commitment was actually the statement of a condition ensuing from adherence to a more general commitment.
Two comitments contained in FSAR Paragraph 3.9.B.3.1.6.2.B and
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3.9.B.3.1.6.2.C pertaining to permissible pressure in the upset and emergency conditions were, however, inadvertently omitted from the commitment matrix.
Readiness Review personnel will add these commitments to the matrices in Module 11 Subsections 3.4 and 3.5.
The omission of two commitments is identified as Finding #1 in Section 4.0 of this report.
(3)
Implementation Review.
The NRC Region II inspection consisted of a review cf Subsections 3.1, 3.2, and 3.3 for content and an evaluation of 41 commitments (among the 100 listed in Subsection 3.4) for commitment implementation.
The commitments selected represented the range of commitment topics and commitment sources presented in Module 11.
The examination of the sample consisted of:
Verifying that Subsection 3.4 of the Commitment Matrix corre-lates with the Subsection 3.E, Implementation Matrix for each commitment in the sample Reviewing the source document referenced in the commitment matrix for a clear statement of requirement for each commitment Verifying that the document listed in the implementation matrix properly implements the requirement as stated in the source document for each commitment The sample of commitments reviewed and the review results are listed in Table 1 of this report.
Three questions raised during the review of commitment implementa-tion are yet to be resolved.
These are discussed in Paragraph 3.g(2)(a) of this report since they relate to Design Program Verification.
(4) NRR Review.
Applying the review methodology described in Paragraph 2.b, the staff concluded that the commitment matrix included most of the regulatory guidance and staff positions for j
the scope of the review.
In the course of the review, the staff developed questions regarding possible omitted commitments which
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could be appropriate to the subject of Module 11.
Approximately 20 apparent omissions and corrections were initially identified by the NRR staff (Reference 3).
The applicant responded to these questions (Reference 4) and we have reviewed the responses and determined that they adequately address our concerns.
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j following is a brief discussion of these items:
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(a) Many of the documents concerned potentially missing commitments which are actually covered within the scope of other commitments within Module 11.
In some cases, FSAR Sections (or other documents) contribute no additional commitment information.
In other cases, the FSAR (or other)
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information is not included so as not to repeat commitments within the module.
(b) Some commitments are included in other Modules (3A, 4, 8, and Appendix J) and are redundant (see Commitments:
256, 259, 322, 324, through 331, 951, 952, 954, 961, and 2170 in Module 4; 3223 through 3228 and 3230 through 3232 in Module 3A; and 1101 in Module 8 and Appendix J).
These Commitments do not need to be included in Module 11.
(c) During the earlier review of Module 4, Mechanical Equipment, Piping and Other Components, there were several commitments identified which were to be included in Module 11 (see Commitments:
1640, 1660, 1689, 4238, 4239, 4992, 4993, 5031, 5032, in Module 11). We have verified that these Commitments are included.
(d) Some of the piping systems which have a safety function, such as the non-ASME Code class safety and relief valve discharge piping are not included in the Commitment Matrix, since these are outside the scope of Module 11.
d.
Section 4.0--Program Description (1) Review Introduction and Section Examination.
This section describes procedures and program control for design; equipment and material; site materials; fabrication, installation, and inspection; and ASME Section III, Subsection NA stamping.
The section was examined by the NRC Region II inspectors for content and background information.
Some of the background was useful in the review of later sections in the Module, especially Section 6.0, Program Verification.
(2) Design.
Subsection 4.1 divides a description of the design program into several categories including the pipe stress and pipe support design process; applicable design criteria, drawings and documentation supporting the design, controls and approvals; and the design change control process. This subsection describes the design program from its earliest phase of design criteria development to its final phase of design program verification.
The NRC Region II review of this subsection revealed that the information presented therein gave a descriptive accounting of the design process and defined the division of responsibility between Bechtel Power Corporation and Westinghouse in pipe stress analysis activities.
It also explained the interfaces between engineering groups involved in the design effort.
The information proved useful for developing an understanding of the design program, but did not lend itself to a detailed review.
The NRC Region II
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inspectors identified no deficiencies in the design program
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described in this subsection.
Results from the review of Section 6 of Module 11 were used to determine how effectively the program actually functioned.
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(3) Equipment and Material.
Subsection 4.2 describes the process for procuring safety-relating piping supports and components or the material used to fabricate these items.
GPC serves as the purchasing agent for these items and supplies them to the contractors for installation. This subsection refers to Module 21 Appendices C and E for a detailed description of the procurement process. These appendices were not examined in detail in this NRC Region 11 review, but several procurement documents were inspected in the review of the Construction Program Verification described in Paragraph 3.h of this report.
No deficiencies were identified in the procurement process.
(4) Site Material Control.
Subsection 4.3 describes the responsi-bilities of the pipe support installers relative to receipt, inspection, and control of ASME Boiler and Pressure Vessel Code material within the scope of Module 11. This subsection describes the requisiticn process used by the responsible contractor, Pullman Power Products (PPP), to obtain the construction materials.
It also explains receipt inspection procedures, review of ASME Code Section III documentation, and material storage methods.
NRC Region II did not perform a detailed examination of this subsection since the material contained was largely descriptive and not in the nature of an assessment.
The description does give indication of a well-controlled materials receipt program for ASME Code Section III materials.
The NRC Region II inspectors had no findings in this subsection.
(5)
Fabrication, Installation, and Inspection. Subsection 4.4 describes site fabrication and installation activities for pipe supports and pipe whip restraints.
It also references documents that control the inspection of these items, such as Codes, specifications, and implementation procedures.
As indicated in this subsection, the fabrication and installation of pipe supports and pipe racks was performed in accordance with Bechtel Power Corporation's Specification X4AZ01.
Pipe whip restraints were installed to Specification X2AP01.
The subsection lists numerous PPP procedures that implement quality assurance criteria of 10 CFR 50 Appendix B and ASME Code Section III Subsection NCA 4134.
It also describes the preparation of the principal documents used by PPP for site fabrication, installation and inspection of pipe supports and pipe whip restraints.
The material in this subsection is generally descriptive and was not assessed in detail by the NRC Region II inspectors. The material presented does indicate that the basic installation program addresses project requirements.
Results from the review of Module 11, Section 6.0 were used to determine how effectively the program actually functioned.
The NRC Region II inspectors had no findings relative to the description of this program.
(6) ASME Code NA Stamping.
Subsection 4.5 presents the proposed work activities and governing procedures for ASME Boiler and Pressure Vessel Code NA stamping relative to Module 11.
As of July 22, 1985, the NA stamping program was yet to be implemented at Plant
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Several of the procedures were in the process of preparation or modification at the time of Module 11 printing, and were therefore not included in Readiness Review's evaluations.
the NRC Region II inspectors did not perform a review of the governing procedures for NA stamping since these were only listed in the Module 11 report.
The proposed work activities were, however, deemed to represent a logical approach to NA stamping.
The NRC Region II inspectors had no findings in this subsection.
e.
Section 5.0--Audits and Special Investigations This section discusses quality assurance audits ana evaluations that have been performed by GPC, Bechtel Power Corporation. Southern Company Services, and the Institute of Nuclear Power Operations addressing pipe stress analysis and pipe supports.
It also describes inspections and special evaluations conducted by the NRC.
Section 5.0 discusses findings resulting from these audits relative to the design and construction programs.
The section also presents five design and construction problems considered significant enough by GPC that the NRC was informed of their potential reportability pursuant to criteria of 10 CFR 21 and 10 CFR 50.55 (e).
The findings resulting from design program audits occurred in the areas of design criteria, calculations, drawings, design documentation, and design changes.
All of these phases of design activity were given detailed evaluation in Readiness Review's verification of the design program in Module 11, Subsection 6.1.
The findings resulting from construction audits were all evaluated for importance by the Readiness Review Team.
The Construction Program Verification in Module 11, Subsection 6.2, was designed to include all areas where findings of high or moderate importance occurred.
In addition, the NRC Region II inspectors determined that all items related to Module 11 in past NRC findings were included in the Readiness Review Team data base for Audits and Special Investigations.
The NRC Region II inspectors concluded that findings from previous audits and investigations were thoroughly considered in the Readiness Review Team's assessnents for Module 11.
The NRC Region II inspectors had no findings in this section.
f.
Section 6.0--Program Verifgation This section of the Module 11 Report describes activities undertaken to ascertain whether design and construction work processes were adequately controlied to ensure implementation of licensing commitments and conformance with project procedures and design requirements.
The section is divided into two subsections covering Design Program Verifi-cation and Construction Program Verification.
The NRC Region II inspectors performed detailed evaluations of both subsections, which are described under the following two headings in this report.
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Subsection 6.1--Design Program Verification (1) Review Introduction. The Design Program Verification performed by the Readiness Review Team focused on the programmatic aspects of design.
It included an assessment of design processes and a review of design documents for implementation of licensing commit-ments.
The Readiness Review Team's review was performed in two parts.
Part I consisted of verifying implementation of all technical commitments within Module 11. Source documents (such as the FSAR) were reviewed to identify project commitments regarding pipe stress and pipe support design activities.
Design criteria documents were then reviewed for implementation of these commit-ments. A selected sample of commitments were further reviewed for implementation into second-level design documents such as calculations and drawings.
Part II consisted of a review of design criteria and second-order design documents for conformance to project procedures and quality assurance requirements. Empha-sis was placed on the areas of design control, internal and external design coordination, adherence to design criteria, procedural compliance, and design documentation.
(2) Part I Examination The NRC Region II examination of Part I of the Design Program Verification began with a selection of 41 commitments from the 100 listed in Subsection 3.4 of Module 11.
The commitment selection was as described in Paragraph 3.c(3) of this report.
The sampling contained 39 of the 95 design-related commitments identified in Subsection 3.4 of the Commitment Matrix. The commit-ment sample and results of the review are listed in Table 1 of this report.
Also included in the table are two commitments inadvertently omitted from Subsection 3.4 of the Commitment Matrix (refer to Paragraph 3.c(2) of this report).
(a)
First-Order Commitment Implementation For 36 of the 41 commitments selected for review, the commit-ments were readily found to be implemented in the documents identified in Subsection 3.5 of the Implementation Matrix.
These 36 commitment verifications required at most only minor clarification from Readiness Review personnel. The remaining five required some form of further clarification to show that the implementation was consistent with the commitment requirement. Questions on three of these commitments are yet to be resolved.
On commitment 1565, which identifies accepted ASME Code Cases, the Code Case N-397 was listed as accepted in the Design Criteria DC-1017 but was not listed in the FSAR.
Correspondence from B. J. Youngblood, NRC, to D. O. Foster, GPC, dated December 26, 1985, however, approves use of Code Case N-397 and indicates that use of this Code Case will be documented in a future amendment to the FSAR. Thus, the NRC
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Region II inspectors found commitment 1565 acceptable.
On commitment 1657, which pertains to functional capability of components in emergency and faulted conditions, the NRC Region II inspectors determined that the words " functional capability" should be added to the commitment subject. This omission does not amount to a discrepancy or deficiency, so the commitment was considered acceptable.
The Region II inspectors had the following questions on first-order commitment implementation that are yet to be resolved:
Commitment 1569--This commitment pertains to materials ASME Code Case acceptability.
It is not clear as to why Section 2.3 of the Design Criteria DC-1017 was identified in Module 11, Section 3.5 of the Implementation Matrix for impleme1tation of this commitment. Readiness Review has been raquested to provide further clarification.
Comitment 1640--This commitment pertains to computer programs used in the analysis of Seismic Category I piping systems.
The program ME-150 is listed in Design Criteria DC-1017 as a program for use in piping analysis but is not listed in the FSAR.
Readiness Review has been requested to provide further clarification.
Commitment 4992--This commitment specifies the use of two documents for the analytical determination ot jet impingement effects resulting from postulated pipe breaks.
One of these documents, an American Society of Civil Engineers (ASCE) paper of December 1973, was not mentioned in the implementing Design Criteria DC-1018.
Readiness Review has been requested to explain why the ASCE paper was not included in the criteria.
These three commitment questions are identified as Finding #2 in Section 4.0 of this report.
(b) Second-Order Commitment Implementation Of the 41 commitments in the review sample, eighteen were evaluated for implementation into second-order documents (design calculations, construction procedur es, etc.).
The results of these evaluations are contained in Table 1 of this report.
In all cases, the NRC Region II inspectors deter-mined that the commitments were properly implemented in the second-order document reviewed.
The second-order document listed in Table 1 for each of these eighteen commitments represents only one instance of implementation for that commitment.
Numerous other implementation documents could exist.
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Readiness Review's verification of commitment implementation into second-order documents is summarized in table 6.1-5 in the Readiness Review's Module 11 Report.
The table contains 35 different commitments corresponding to 24 general commit-ment subjects.
The 35 commitments in the table include thirteen of those in the NRC Region II commitment sample.
The NRC Region II inspectors traced implementation of ten of these thirteen commitments to second-order documentation, though not necessarily to the same documents as did the Readiness Review Team.
The implementations for all ten of these commitments were found to be acceptable by the NRC Region II inspectors.
From the results obtained in verifying eighteen commitments to second-order documents, of which ten were included in Readiness Review's assessments, the NRC Region II inspectors concluded that the second-order commitment verification program was acceptable.
(3) Part II Examination Documents included in the Readiness Review Team's Part II review and results of the review were divided into the following major categories:
Pipe Stress Calculations Pipe Support Calculations Pipe Support Drawings Design Change and Nonconformance Documents Findings The NRC Region II inspectors examined all of the foregoing topics in their review.
The approach used by the inspectors in their examination was directed toward evaluating the same equipment from the beginning of design to the completion of construction.
This was accomplished by first selecting a set of eleven piping isometrics to form a basis for an assessment of both the Design and Construction Program Verifications.
The piping isometrics
i were chosen to obtain a diversity of pipe sizes, pipe classes,
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locations, and systems.
Seven of the eleven piping isometrics selected were also included in Readiness Review's program.
The eleven isometrics chosen had a total of 50 associated pipe f
supports.
Included in this support sample were miscellaneous steel supports, pipe straps, snubbers, struts, and spring supports.
Of these 50 supports, seven were within Readiness Review's program.
The piping isometrics and pipe supports selected for evaluation are listed in Table 2 of this report. All of the isometrics and pipe supports were evaluated in NRC Region II's review of the Construction Program Verification, and a
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portion of the design documents associated with th(se isometrics were examined in the review of the Design Program Verification.
The design documents examined by NRC Region II are indicated in l
Table 2.
The NRC Region II assessment of design documentation is reported as follows:
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(a) Pipe Stress Calculations
The following calculation packages were examined for completeness, interdiscipline coordination, conformance to design criteria and project requirements, consistency with drawings and installation, and technical adequacy:
X4CP-7024 Rev 0 Piping Isometric 1K3-1217-176-01 X4CP-7125 Rev 2 Piping Isometric 1K4-1202-001-01
X4CP-7009 Piping Isometric 1K3-1204-028-01
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Observations made relative to the X4CP-7024 review include:
The piping configuration used in the analysis was i
consistent with the isometric and the installation.
Stress limits used were in accordance with ASME Section III Class 2 criteria for the Class 2 piping.
Damping values used were in accordance with Regulatory Guide 1.61.
Observations made relative to the X4CP-7125 review include:
The piping configuration used in the analysis was consistent with the isometric and installation except that pipe support V1-1202-001-H004 was located 101/2 inches from its actual field location.
The design tolerance for this support location is 8 inches.
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This deficiency is identified in Finding #4 in
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Section 4.0 of this report.
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Damping valves used were in accordance with Regulatory Guide 1.61.
A containment cooling unit was included in the struc-tural model to account for its flexibility.
This is representative of proper analytical methodology.
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Load combinations used were in accordance with Design Criteria DC-1017 and NUREG-0484.
Stresses for the faulted condition were within allowances specified in ASME Code Case 1606-1.
The program WESTDYN was used to perform the analysis,
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which is listed in the FSAR as acceptable.
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Observations made relative to the X4CP-7009 review include:
The piping configuration and locations of all components in the line were consistent with the piping isometric and installation The valve weights and orientations used in the analysis were consistent with the drawings and installation The design temperature and pressure, operating temper-ature and pressure, and pipe material were consistent with parameters given in the Line Designation List load combinations used were in accordance with Design Criteria DC-1017 and NUREG-0484 The seismic response spectra used in the analysis corresponded to the proper building and elevation The nozzle loads acting on a pump in the line were within manufacturer's allowables The calculations for thermal anchor movements were correct and the movements were incorporated in the analysis The calculated stresses were within ASME Section III Class 2 allowances and deflections at support locations were less than the 0.04 inch allowed for large piping The examination of pipe stress calculations disclosed only one deficiency in a pipe support location.
This has been included in the findings in Section 4 of this report.
(b) Pipe Support Calculations The following pipe support calculation packages were examined for completeness, interdiscipline coordination, conformance to design criteria and project requirements, consistency with drawings and installation, and technical acequacy.
All of these pipe supports are contained in the piping isometrics reviewed in Paragraph 3.g(3)(a) above.
V1-1217-176-H001, -H004, -H007 V1-1202-001-H003, -H004 V1-1204-014-H008 V1-1204-028-H003, -H004, -H005, -H006, -H008, -H026 4dMF46+75% mM E MWW raiggrdWi# m em eymm-w a em.
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Observations made relative to these pipe support calculations include:
In Calculation V1-1204-028-H026, a dimension used in the analysis was consistent with the drawing but not the installation. This dimension extends from the bottom of the horizontal wide flange beam to the top of the embed plate.
This dimension is used in calculating the bending moment on the weld pattern of the tube steel to embed plate.
For other details see Paragraph 3.h(2)(c),
Item 7.
This deficiency is identified in Finding #4 in Section 4 of this report.
On the Calculation Packages V1-1204-028-H004, -H005,
-H006, two blocks are provided for approval signatures.
Only one approval signature was required if signed by an engineer, but two signatures were required if the first was that of a technician.
In several situations the second block was left blank, which hindered verification of proper signoff.
The second block should have been marked "Not Applicable" or other notation, if the first signature was that of an engineer.
The omission of a notation in the second block is identified as Finding #4 in Section 4 of this report.
Design loads and displacements were correctly trans-ferred from the pipe stress calculations to the pipe support calculations A friction load was included whenever the thermal movement at a support exceeded 1/16 inch The structural members used in the analyses corresponded ir size and material with the drawings and installation The program PIPSAN was used to perform pipe support analyses and is listed in the FSAR as an acceptable program The calculated stresses in miscellaneous steel were within allowances of the American Institute of Steel Construction, and stresses in ASME Section III Subsection NF components were within NF allowances The examination of pipe support calculations disclosed two deficiencies, an erroneous dimension in calculation V1-1204-028-H026 and the generic problem with approval signatures.
The dimension error is detailed in Paragraph 3.h(2)(c), Item 7, of this report.
Both concerns are included in the findings in Section 4.0 of this repor _____ __ ___
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(c)
Pipe Support Drawings The examination of pipe support drawings was performed in conjunction with the review of pipe support calculations and the evaluation of the Construction Program Verification.
Therefore, all of the pipe supports listed in Table 2 were included in the pipe support drawing review.
The drawings were reviewed for completeness, appropriate approvals, drafting clarity, and consistency with project requirements.
The only deficiency identified in the drawing review was that welding symbol callouts on drawings differed from the installation in numerous instances.
The differences noted were aside from the alternate weld patterns allowed by PPP Procedure IX-50. The unrestricted use of the word " typical" in the callouts has been confusing to craft personnel, field engineers, and QC inspectors, which has resulted in erroneous welds.
The lack of clarity resulted in differing weld patterns in all cases where a discrepancy was noted.
This was also shown by the issuing of Document Change Notices-Resident (DCN-Rs) to clarify the weld symbols.
Examples of supports where confusing callouts occurred are listed in Paragraph 3.h(2)(c), Item 8. of this report. The deficiency is identified in Finding #5 in Section 4.0 of this report.
(d) Design Change and Nonconformance Documents Based on the information presented in Table 2 of this report, a total of 16 Mechanical Field Change Requests (MFCRBs),
31 DCN-Rs, and 7 Deviation Reports (DRs) were included in the 50 pipe support packages for the eleven piping isometrics evaluated by the NRC Region II inspectors.
None of these documents were included in Readiness Review's evaluations.
l These design change documents were examined by the NRC Region II inspectors for the following attributes:
Proper disposition and approval Appropriate technical justification Correct incorporation into drawings l
l Verification errors were not found during the examination of the sample design change documentation.
(e)
Findings Subsection 6.1.4 of the Module 11 Report presents 29 findings disclosed by the Readiness Review Team in the Design Program Verification.
Among these findings were two Level I, eleven Level II, and sixteen Level III findings.
The NRC Region II inspectors performed a detailed evaluation on the two Level I Findings (11-70 and 11-74).
They also investigated the four exer :m e
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findings listed in Table 6.1-1 associated with calculation X4CP-7125, Rev. 1 (11-53, 11-59, 11-61, and 11-71). The NRC Region II inspectors also noted a similarity between a deficiency identified in their review and Readiness Review Finding 11-75. NRC Region II's evaluation of these Readiness Review Findings is described below:
Finding 11-70 -- This finding noted that a pipe stress calculation did not account for a removable spool piece.
The NRC inspectors determined that this was an isolated case and that the calculation was under revision.
Finding 11-74 -- This finding noted that pipe stress and pipe support as-built procedures were inadequate.
The NRC inspectors found that a program has since been implemented that tracks status of all pipe stress calculations and pipe supports until 100% completion is achieved.
The inspectors concluded that all changes would be properly incorporated in the documentation under this program.
Finding 11-53 -- This finding noted that concentrated loads due to component supports were not addressed in pipe stress analyses.
The NRC inspectors determined that the weights of such components would be a small percentage of pipe weights (less than 5%) based on information in suppliers' catalogs.
The corrective action taken by the project was sufticient.
Findings 11-59, 11-61, 11-71 -- The NRC inspectors determined that the corrective actions taken by the project on these findings were appropriate.
The NRC Region II inspectors did not identify a recurrence of these findings in their review of pipe stress calculations.
Finding 11-75 -- This finding noted that installation tolerances for supports were not consistently addressed in support calculations.
The project response was that Design Criteria DC-1017 would be revised to reflect the appropriate requirements, which is an acceptable resolution.
The NRC Region II inspectors found several cases in their review of pipe support calculations where tolerances were incorporated.
The NRC Region II inspectors did identify a finding related to this Readiness Review Finding. As described in Paragraph 3.g (3)(b), a dimensional discrepancy that exceeded tolerance was identified on a support drawing. This is included in the findings in Section 4.0 of this report.
The examination of the Readiness Review Findings in the Design Program Verification disclosed no verification errors, i
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h.
Subsection 6.2--Construction Program Verification (1) Review Introduction and Subsection Examination.
The Construction Program Verification performed by the Readiness Review Team consisted of an evaluation of completed pipe supports, associated documentation, procedures, specifications, vendor instructions, and installation of pipe whip restraints.
The program had the objective of determining whether the construction control process functioned effectively and whether it ensured acceptable pipe support installations.
(2) Program Examination. The assessments made and conclusions reached in Readiness Review's verification program were divided into the following major categories:
Commitment Implementation Construction Programs and Procedures Hardware and Associated Documentation Pipe Whip Restraint Installation Findings All of the foregoing topics were examined in the NRC Region 11 review and are reported as follows:
(a) Commitment Implementation The NRC Region II inspectors performed verification of commitment implementation on four of the nine construction-related commitments listed in the Commitment Matrix of Module 11.
The commitments verified were 331, 880, 1825, and 1927. The results of this effort are included in Table 1 of this report.
As indicated, commitments 880 and 1825 were verified for implementation into both first-and second-order documents.
The NRC Region II inspectors identified no deficiencies in the verifications of these four commitments.
(b) Construction Programs and Procedures The Readiness Review Teara made an assessment of the following four PPP construction procedures:
IX-50, Pipe Support Field Installation and Fabrication IX-32, Installation of Mechanical Shock Arrestors IX-86, Installation of Bergen-Paterson Struts IX-1, Installation and Inspection of Concrete Anchors l
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The Readiness. Review Team found that vendor requirements and specification. requirements were adequately reflected in 'these construction procedsres.
The NRC Region II inspectors reviewed ~ portions of these prccedures in their evaluations of 50 pipe supports described in Paragraph 3.h(2)(c) below. The NRC Region 11 inspectors found that these portions of the construction procedures adequately reflect project require-ments with two exceptions.
The NRC' Region II inspectors determined that the installation and inspection procedures
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- for spring supports showed a major det'iciency in detail relative to procedures for mechanical Jihock arrestors (snubbers) an'd Bergen-Paterson Strut installation. >The procedures should be' expanded to include such items as:-
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Traceability of small connecting parts Proper installation and inspection of connecting
component h rdware A
Installatiort and identification of clamp and clamp s
bolting material
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, Verification of installation of required spring support iravel stops during construction
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A second exception was that the procedures for installation of'oechanical shock arrestors did not properly allow for identification or traceability of the clamps or' the clamp bolts.
Verifications af proper clamp and bolt installation and of the materials used in these~ pieces have r.ot been
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addressed in support inspections conducted at the < time of
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snubber installation.
The PPP Procedure 1X-32 shculd be
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expanded to include these verifications. The NRC Region II e
inspectors concluded that these findings should have been identified in the Readiness Review Team's assessment and are a
identified as Finding #3 in Section 4 of this report.
(c) kHardware and Associated Documenthtion
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5s discussed in Paragraph 3.g(3) of this report, the NRC
Region II inspectors selected ele (en piping isometrics with s
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50' associated pipe supports to formL a basis for evaluating the Design and Construction Program Verificaticns.
The
piping isometrics and pipe supports. examined are listed in s
Table 2.
As shown in the table, seven Of these-isometrics pad seven of the pipe supports Wsre also reviewed by the Readiness Review Team. The_NRC Region II inspectors examined v
the construction aspects of all 50 pipe supports by first i
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performing a field inspection on the pipe isometrics and pipe supports.
During this inipection, the follcwing. information was recorded:
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Pipe dimensions, component locations and orientation,
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Support dimensions and support locations Support configuration Weld size and type Support materials NF component heat numbers Clearances between pipe and support Snubber NPT Code data plate information, cold set, traceability markings on connecting hardware Spring hanger NPT Code data plate information, travel stop installation, traceability markings on connecting hardware
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The information recorded during the field inspections was then reviewed against the Line Designation List (LDL), Piping
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and Instrumentation Diagrams (P& ids), pipe isometrics and support drawings, all associated documents in the PPP QC document packages, and other miscellaneous documents.
The documents included in the PPP QC packages were Process Sheets, MFCRBs, Authorizations to Continue Work (ATCWs), ors, DCN-Rs, Snubber and Strut Checklists, Weld Process Sheets, and Weld Rod Requisition Tickets. Among other miscellaneous construction documents reviewed were Requests for Support Removal, Liquid Penetrant Examination Records, Material Inspection Reports, Maintenance Work Orders, Grout Requests, Core Drill Requests, Certificates of Compliance, and Certified Mill Test Reports. Based on the inspection of pipe
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supports and associated documentation, the NRC Region II inspectors found that the pipe support installations were generally consistent with the documentation and in accordance
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with project requirements.
This assessment is consistent with the basic conclusion reached by the Readiness Review
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Team.
The NRC Region II inspectors did, however, identify several deficiencies in the construction program, which are described as follows:
j 1.
The location dimensions shown on the drawings for four supports differed from the measured dimension by more than 1/4 inch.
According to PPP Procedure IX-50 these should not have been accepted by the PPP QC inspectcrs.
All the dimensions in question were within design tolerance.
Thus, this has no impact on design but has some impact on the accuracy of as-built drawings.
The affected supports were V1-1202-405-H033, V1-1202-405-H036, V1-1302-022-H002, and V1-1302-025-H001, (Finding #6).
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The flare bevel welds on two supports were of insufficient length.
On support V1-1202-405-H036, a bevel weld to the embed plate measured 91/2 inches versus 10 inches per the drawing.
On support V1-1302-025-H002,= the bevel weld to the embed plate at the bottom right of the support measured 5 5/8 inches versus 6 inches per the drawing, (Finding #6).
3.
The plate designated item "1" on support V1-1202-001-H004 was undersized beyond the tolerance allowed by
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PPP IX-50. The plate measured 3/8" x 2" x 5 1/2" versus 3/8" x 2 3/8" x 5 3/8" per the drawing.
Since a
. tolerance of 1/8 inch in the 2 3/8-inch dimension was exceeded, this should have been referred back for design evaluation.
There was, however, some difficulty in obtaining an accurate measurement on this dimension, (Finding #6).
4.
The clearances between support and pipe were insufficient in three cases.
Specific cases were the clearance in the E-W direction for support V1-1202-001-H008, the clearance inLthe E-W direction for support Vl-1217-176-H007, and the clearance in the N-S direction for support V1-1205-007-H043.
The total clearance in
.each case was zero, (Finding #6).
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5.
Welds were installed on both sides of the web on both ends of the brace in support V1-1203-034-H009.
These four weld increments were not specified on. the support drawing,(Finding #6).
6.
The orientation of the south strut in support V1-1203-034-H010 was not in accordance with the drawing.
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The dimension from the connection at the wall to the pipe centerline was measured to be 2'9", while the drawing specified 2'3", (Finding #6).
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7.
A discrepancy between the pipe support drawing and installation was noted in a dimension in support V1-1204-028-H026.
The dimension from the bottom of the horizontal wide flange to the top of the embed plate was measured to be 5 inches and shown on the drawing (b),
to be 1 inch; for other details see Paragraph 3.g(3)
(Findings #4 and #6).
8.
The weld symbol callouts on several drawings differed
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from installation.
These differences were aside from the alternate weld patterns allowed by PPP Procedure
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IX-50.
The unrestricted use of the word " typical" has misled craft personnel, field engineers, and QC inspec-tors, resulting in different weld patterns in numerous instances. The lack of clarity was further evidenced by
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the issuance of DCN-Rs to clarify weld symbols.
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Specific supports where confusing weld symbols occurred were V1-1203-034-H011, V1-1204-014-H008, V1-1204-028-
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H006, V1-1205-007-H033, and V1-1205-007-H043, (Findings #5 and #6).
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9.
A number of discrepancies or inadequacies were noted in the LDL, P& ids, and pipe isometric drawings.
The
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isometric drawings 1K3-1203-034-05 and 1K3-1205-007-02
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showed incorrect P&ID numbers, while the LDL showed the correct numbers.
Conversely, the isometric drawings IK3-1205-010-03 and 1K5-1302-022-01 showed correct P&ID numbers, while the LOL showed incorrect numbers.
The s
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P&ID 1X4DB121 'showed lines 1204-128-3/4" and 1204-129-3/4" as pipe class LLO while the LDL showed these as LLI.
(This is similar to a finding in the NRC Region II. Report for Readiness Review Module 4, identi-fied as IFI 424/85-35-08, Maximum Design Pressure Discrepancy.)
This P&ID was also unclear in showing
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that a 3/4-inch tap line to relief valve PSV8853A has line number 1204-128-3/4".
On isometric 1K3-1205-i 010-03, the location of support V1-1204-201-H007
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(node 705) was shown on the wrong side of the pipe field weld 201-W-02.
Also, the isometric drawings contained uncontrolled information, such as insta11er's notes and required QA signature.
Also, the Hanger Field Process Sheet was lacking a QA signature and was missing a PPP QC signature for operation 7.
On support V1-1205-007-H501, a Bergen-Paterson Strut Inspection Check Sheet was not completed though the package had been accepted by both QC and Quality Assurance (QA).
These approvals should not have been given without completion of the check sheet.
On support V1-1205-010-H015, the Requests for Support Removal, ATCW, DCN-R, and drawing were not t
coherent, leaving a non-traceable document path, (Finding #6).
10. Several inadequacies were noted in the documents included in the PPP QC packages.
On support V1-1203-034-H007, the original ATCW differed from DCN-2 in that
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there were two less weld on DCN-2. The ATCW was changed in the field without prior engineering approval for the weld pattern change.
This has no impact on this
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installation, but does constitute a violation against PPP Procedure s III-4 and GPC Procedure DCA-03.
On support V1-1204-028-H006, a pull sheet for a Weld Rod Requisition Ticket had not received a required QA signature.
Also, the Hanger Field Process Sheet was lacking a QA signature and was missing a PPP QC signature for operation 7.
On support V1-1205-007-H601, a Bergen-Paterson Strut Inspection Check Sheet was not
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completed though the package had been accepted by both
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QC and Quality Assurance (QA).
These approvals should not have been given without completion of the check sheet.
On support V1-1205-010-H015, the Requests for Support Removal, ATCW, DCN-R, and drawing were not coherent, leaving a non-traceable document path, (Finding #6)
11.
The required travel stops for spring hangers V1-1302-025-H001 and V1-1205-010-H018 were not in place.
Additionally, the procedures for the installation and inspection of spring supports were found to be insuffi-cient as described in Paragraph 3.h(2)(b) of this report, (Finding #3 and #8).
12.
Verification of traceability on the bolts for the snubber clamp in support V1-1205-010-H017 was not possible.
The procedures for installation of snubbers were found to be inadequate regarding verification of traceability and installation of clamps and bolts as described in Paragraph 3.h(2)(b) of this report, (Finding #3).
13.
Two hardware deficiencies were noted during the walkdown inspection.
The identification tag on the south strut in support V1-1203-034-H010 was missing. A pipe cap was missing on a 1-inch tap line near valve 1203-034-X120, (Finding #7).
All of the deficiencies listed above are included in the findings in Section 4 of this report.
(d) Pipe Whip Restraint Installation A review of the installation of pipe whip restraints was not performed during this inspection partially due to ongoing NRC Region II inspections in this area.
These separate inspec-tions were being cone'ccted as a result of questions involved with intermediate pipe break locations and associated pipe whip restraints, resulting from the NRC Region II examination of Module 4.
Further rationale existed for omission of whip restraints from.he examination of Module 11 since the number of such restraints is limited (approximately 100) and the activities involved are similar to pipe support installation activities.
(e)
Findings Subsection 6.2 of the Module 11 Report presents thirteen findings disclosed by the Readiness Review Team in the Construction Program Verification. Of these findings, eleven resulted from walkdowns of pipe supports and reviews of associated documentation, and two resulted from assessment of pipe whip restraints. Two of the findings were classified as
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Level I.
The NRC Region II inspectors performed a detailed evaluation on one Level I finding (11-12).
They also selected Readiness Review Finding 11-6 for evaluation in their review of pipe support packages.
NRC Region II's evaluation of these Readiness Review Finoings is described below:
Finding 11-12 -- This finding noted that a shim plate was found to have incorrect size.
The NRC Region II inspectors found that the project has now instituted a program whereby piping analyses that change due to the 75% Reconciliation Program will be investigated for changes in thermal movement at support locations. Where the thermal movement changes at a support location, the support will be inspected for existence of a shim plate.
If a shim plate exists, a calculation will be made for sufficient plate size.
The NRC Region II inspectors concluded that this program satisfactorily resolves this issue.
Finding 11-6 -- This finding noted that the pipe location on one cantilevered beam support was outside the allowable 4-irch tolerance.
The NRC Region II inspectors determined that the pipe locations on all cantilevered beams in their review sample were within the 4-inch tolerance. Additionally, interviews with PPP QC inspectors indicated that they were conscious of this tolerance during their pipe support inspections. Thus, the NRC Region II inspectors concurred with the Readiness Review Team's conclusion that this was an isolated event.
The examination of the Readiness Review Findings in the Construction Progra.w Verification disclosed no verification errors.
i.
Section 7.0--Independent Design Review
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(1) Review Introduction.
This section describes the Independent Design Review (IDR) of design criteria, calculations, specifica-tions, and drawings that was performed by Stone and Webster Engineering Corporation. The intent of the IDR was to ensure that proper design requirements were considered and that implementation of design commitments was technically acceptable. This required a
[
detailed technical review of pipe stress analyses and transfer of information from the analyses to drawings.
(
(2)
IDR Examination.
The IE examination of the IDR will focus on
determining whether a thorough review had been performed and whether conclusions were appropriate relative to the findings
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i reported.
This will be accomplished during the review of Module 22, " Independent Design Review."
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Section 8.0--Program Assessment / Conclusions
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This section presents a summary of open corrective actions on Readiness Review findings, several certifications and acceptances of the Module, and brief resumes for the Readiness Review Team members.
The section does not contain any introductory explanations as to the significance of the information presented, which is somewnat contrary to the previous sections of the Module.
The NRC Region II inspectors' review of this section included reading for content and background information.
The open corrective actions identified therein were evaluated for completeness and consistency with the finding descriptions given in Module 11, Section 6.
No findings were identified in the corrective actions.
4.
Findings The following eight findings were identified during the NRC evaluation of Module 11.
All of the deficiencies noted are considered to have potential safety significance at this point of review and should be evaluated further to preclude safety problems. These have been identified as Unresolved Items (UNR), Inspector Followup Items (IFI), Violations (VIOL), or Deficiency Items (DI) depending on the nature of the followup action required. These will also be addressed by the NRC during the routine inspection program.
1.
Deficiency - (IFI 424/86-62-01) - Omission of Design Commitments -
Omission of two design commitments from the Commitment Matrix. Details for this provided in Section 3.c(2) of this report.
2.
Deficiency - (UNR 424/86-62-02) - Unresolved Questions on Commitment Implementation - Three unresolved questions on commitment implementa-tion.
Details for this are provided in Section 3.g(2)(a) of this report.
3.
Deficiency - (VIOL 424/86-62-03) - Inadequate Construction Procedures For Installation and Inspection of Spring Supports and Clamps -
Inadequate construction procedures for installation and inspection of spring supports and installation and inspection of clamps and clamp bolts for mechanical shock arresters. Details for this are provided in Sections 3.h(2)(b) and 3.h(2)(c), Items 11 and 12, of this report.
4.
Deficiency - (VIOL 424/86-62-04) - Discrepancies in Design Documenta-tion - Discrepancies both in design calculations and lack of signatures in both blocks for approval signatures. Details for these are provided in Sections 3.g(3)(a) and 3.g(3)(b) of this report.
5.
Deficiency - (UNR 424/86-62-05) - Unclear Use of " Typical" in Welding Symbol Callouts - Five supports have unclear use of the word " Typical" in weld callouts causing confusion both in field and design.
Details for this are provided in Sections 3.h(2)(c), Item 8, and 3.g(3)(c)
of this repor __
r
..
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.
6.
Deficiency - (VIOL 424/86-62-06) - Discrepancies Between Pipe Supports, Design Documentation and QC Documentation - Many examples of discre-pancies between the pipe support installations and associated documentation.
Details for these are provided in Section 3.h(2)(c),
Items 1 through 10, of this report.
7.
Deficiency - (IFI 424/86-62-07) - Discrepancies in Walkdown of Supports - Two hardware discrepancies were noted during the walkdown of the supports.
Details for these are provided in Section 3.h(2)(c),
Item 13, of this report.
8.
Deficiency - (DI 424/86-62-08) - Inadequate Review of Procedures for Spring Supports by Readiness Review--Readiness Review did not identify major deficiencies in the installation and inspection procedures for spring supports.
Details for this are provided in Sections 3.h(2)(b)
and 3.h(2)(c), Item 11, of this report.
5.
Conclusions Based upon the review within the scope of this module, the NRC has reached the following conclusions for pipe stress and supports for Vogtle Unit 1.
a.
Summary of Specific Conclusions With the exceptions of those items / areas discussed earlier the following has been determined to be acceptable.
(1) Boundaries - The content of Module 11 and the boundaries between other modules as given in Section 1.0 were reviewed and found to be complete and definitive.
(2) Organization - The description of the organization and responsi-bilities for project activities as given in Section 2 was reviewed and found to be accurate and to include the pertinent activities for design and field construction.
(3) Commitments - The commitments as given in Section 3.0 were reviewed and determined to be complete.
With exception of deficiencies identified in Section 4.0 for Commitments 1569, 1640, and 4992, and two commitments not identified from the FSAR by Readiness Review, the licensing commitments and implement documents were determined to be in compliance with the FSAR, the
!
SRP, Regulatory Guides, and Industry Codes and Standards.
!
(4) Program - The description of the program as given in Section 4.0
'
was reviewed. The following areas were examined:
-
Design
-
Equipment and Material
-
Site Material Control Fabrication, Installation and Inspection
-
-
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The program description was determined to be generally correct and in agreement with FSAR and requirements.
(5) Audits and Special Investigations - Section 5.0 on audits was reviewed and determined to be an accurate presentation of the audit process and previously identified construction problems and NRC inspection results.
(6) Program Verification - GPC performed a program verification in two parts:
a design program verification and a construction program verification.
Construction verification included a walkdown of pipe and supports within the scope of Module 11 and a review of the project docunwntation with respect to pipe supports.
ihe design process verification examined the implementation within the design documents of all licensing commitments which were identified as having design cognizance. This was completed in two parts.
Part I includes verification of all commitments into
,
project design criteria or other procedures considered as first l
order design documents.
A selected portion was further reviewed for implementation into specific second order design documents including calculations and drawings.
Part II consisted of the examination of selected second order design documents for conform-ance with project procedures and quality assurance requirements.
The desi.gn verification identified three findings which were categorized on the basis of their individual significance and cumulative programmatic effects.
The construction program verification consisted of an evaluation of completed pipe supports and was completed in three parts.
Part I consisted of an examination of the implementation of all licensing commitments which were identified as having construction cognizance.
Part II was a review of construction program and procedures.
Part III consisted of a field walkdown of eleven piping isometrics with 50 associated pipe supports, to verify their conformance with appropriate design drawings, construction specifications, and installation procedures and accuracy of construction quality assurance documentation.
Four findings were identified during the construction program verification shown in Section 4 of this report.
These were categorized on the basis of their individual and programmatic signiticance.
.
(7)
Independent Design Review - GPC contracted an outside organiza-tion, Stone and Webster Engineering Corporation, to perform an Independent Design Review (IDR) for Module 11.
This review was performed to assess the technical adequacy of the Module 11 related design for Vogtle 1.
The IE examination of the IDR will focus on determining whether a thorough review had been performed and whether conclusions were appropriate relative to the findings reported.
This will be accomplished during the review of Module 22, " Independent Design Review."
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,
(8) Program, Assessment / Conclusions - This section presents a summary of open corrective actions on Readiness Review findings. several certifications and acceptances of the Module, and brief resumes for the Readiness Review Team members.
The section does not contain any introductory explanations as to the significance of the information presented, which is somewhat contrary to the previous sections of the Module.
the NRC Region II inspectors' review of this section included reading for content and background information. The open correc-tive actions identified therein were evaluated for completeness and consistency with the finding descriptions given in Module 11, Section 6.
No findings were identified in the corrective actions.
b.
General Conclusions The examination performed by NRC indicated that this module presents an adequate assessment of the GPC process for design, fabrication, installation and inspection of pipe stress and pipe supports for Vogtle 1.
'
GPC's management supported the Readiness Review by active participation and adequate resources.
There was no evidence of coercion or attempt to dilute either the effort or the findings.
The Readiness Review Staff displayed the requisite competence and professionalism for a review of this nature.
The review performed by the Readiness Review Staff us3 determined to be sufficiently comprehen:ive in :ccpc and aepth to identify problem areas, and the dispositions of findings determined to be adequate. The procedures for design, engineering, construction, and quality control for the applicant's program were comprehensive and provide adequate assurance that activities associated with pipe stress and pipe supports were determined to be consistent with commitments and are acceptable.
Based on the review of this module, it appears that construction was performed in accordance with the appropriate procedures and that records reflect the quality of that construction. This specific conclusion can also be supported by performance of the Construction Inspection Program (IE Manual, Chapter 2512) by Region II Inspectors.
This program required observation of work and work activities of the applicants' personnel regarding the performance of their duties during construction of the facility.
With exception of the eight deficiencies reported in Section 4, the NRC tindings appear to have minor significance and do not appear to represent significant programmatic weaknesses.
The deficiencies must be further evaluated to determine their significance and need for any subsequent corrective actions.
Pending resolution of the findings identified above, the NRC concludes that the Vogtle program for pipe stress and pipe support complies with NRC requirements and FSAR commitments.
This conclusion is based on information currently available to the inspectors and reviewers.
Should subsequent contradictory information become available, it will be evaluated to determine what effect it may have on the above conclusion.
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6.
References
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1.
Vogtle Electric Generating Piant Unit 1, Readiness Review, Module 11 -
Pipe Stress and Supports.
2.
Letter from D. O. Foster, Vice President and Project General Manager, Vogtle Project, Georgia Power Company, forwarding Module 11 for NRC
.
'
evaluation, Frbruary 28, 1986.
3.
Letter to J. N. Grace, RII from D. O. Foster, GPC, Subject: Readiness Revicw Module No. 11, Interim Review Questions, dated June 24, 1986.
.
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ACRONYMS AISC American Institute of Steel Construction ANSI American National Standards Institute ASCE American Society of Civil Engineers ASME American Society of Mechanical Engineers ATCW Authorization to Continue Work AWS American Welding Society BPC Bechtel Power Company CD Civil Deviation Report CMTR Certified Materials Test Report C0C Certificate of Compliance DBE Design Basis Earthquake DC Design Criteria (Bechtel)
DCN-R Drawing Change Notice-Resident DR Deviation Report FSAR Final Safety Analysis Report GDC General Design Criteria GPC Georgia Power Company IDR Independent Design Review IE Office of Inspection and Enforcement IEB Inspection and Enforcement Bulletin INP0 Institute of Nuclear Power Operations LDL Line Designation List MFCR Mechanical Field Change Request MWO Maintenance Work Order NDE Non-Destructive Examination NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSSS Nuclear Steam Supply System OBE Operational Basis Earthquake P&ID Piping and Instrumentation Diagram PPP Pullman Power Products PQR Procedure Qualification Record PWR Pipe Whip Restraint
,
QA Quality Assurance
<
l QC Quality Control l
RRF Readiness Review Finding i
RRT Readiness Review Team l
SER Safety Evaluation Report SRP Safety Review Plan SSER Supplement Safety Evaluation Report VEGP Vogtle Electric Generating Plant V-SAMU Vogtle Structural Analysis Mobile Unit VWAC Visual Weld Acceptance Criteria WPS Welding Procedure Specification
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TABLE 1 COP 911 TENT VERIFICATION (Note 1)
Verified First
. ified Second Reference Consnitment Connitment Order Document Order Document Number Source Section Comnitment Sub. ject Document Feature (Note 7)
(Note 8)
331 FSAR 6.1.1.1.2 ESF Construction Materials--
ASE 111 and IX Yes
--
Weld Material Qualification 448 FSAR 10.4.7.2.2.1 Main Feedwater Piping Between BTP E B 3-1 Yes
--
Containment Penetration and Restraint Upstream of MSIV 715 FSAR 1.9.92 Combining Modal Responses and RG 1.92, Rev.1, 2/76 Yes Yes Spatial Components in Seismic Pipe Stress Calc.
Response Analysis X4CP-7125 Rev 2 880 FSAR 3.2.2-1 Principal Construction Code ASE Ill, Classes 1, 2 Yes Yes for Table 3.2.2-1 3 or MC, NF or CS Pipe Support Calc.
VI-1204-028-HUU1 950 FSAR 3.6. 2.1.1 A High Energy Break Locations ASE, Div. 1. Class 1 Yes
--
(Class I)
1565 FSAR 1.9.84 Design and Fabrication Code RG 1.84, Rev. 20,11/82 Yes Yes N
Case Acceptance ASE III, Pipe Stress Calc.
Div. 1 X4CP-7125 Rev 2 1569 FSAR 1.9.85 Material Code Case Acceptance RG 1.85, Rev. 20, 11/82 Yes (Note 2)
--
ASE Ill, Div.1 1588 FSAR 1.9.130 Service Limits and Loading RG 1.130, Rev. 1, 10/78 Yes
--
Combinations for Class 1 Plate-and-Shell Type Component Supports j
1616 FSAR 3.7.B.3.2 Determination of Number of BP-TOP-1, Section 6.2 Yes
--
Earthquake Cycles j
l l
1618 FSAR 3.7.B.3.4 Basis for Selection of BP-TOP-1, Section 2 Yes
--
j Frequencies of Piping Systems
!
1620 FSAR 3.7 B.3.6 Three Components of Earthquake BP-TUP-1, Section 5.1 Yes Yes Motion in Piping Systems Pipe Stress Calc.
j X4CP-7125 Rev 2 1623 FSAR 3.7.B.3.8 Analytical Procedures for BP-TOP-1, Sections 2.0, Yes Yes
!
Piping Systems 3.3, and 4.0 Pipe Stress Calc.
!
X4CP-1125 Rev 2 l
1625 FSAR 3.7.B.3.11 Torsional Effects of Eccentric BP-TOP-1, Section 3.2 Yes
--
Masses in Seismic Piping Analysis 1626 FSAR 3.1.B.3.12 Buried Seismic Category 1 BP-TOP-4A, Section 6.0 Yes
--
Piping Systems j
g.
.
.,
TABLE I (continued)
.
Verified First Verified Second Reference Comitment Comitment Order Document Order Document Number Source Section Comitment Subject Document Feature (Note 7)
(Note 8)
1632 FSAR 3.7.B.3.15 Analysis Procedure to Account bP-TOP-1, Section 2.4 Yes
-
for Damping of Category 1 Piping Systems 1640 FSAR 3.9.B.1.2.1 Computer Programs Used in Secion llI pp. B, Yes (Note 3)
Yes 10 CFR 50 A Analysis--Seismic Category 1 Pipe Stress Calc.
Piping Systems Other than N5SS X4CP-7175 Rev 2 1645 FSAR 3.9.B.1.4.2 Consideration for Evaluation ASE 111, App. F, Yes
--
of Faulted Condition--Limits Paragraph F-1323 of Elastic Range 1656 FSAR 3.9.B.3.1 Load Combinations, Design NUREG-0484, Rev.1 Yes Yes Transients, and Stress Pipe Stress Calc.
Limits--Methodology for 14CP-7125 Rev 2 Combining Responses 1657 FSAR 3.9.B.3.1 Load Combinations. Design NED0-21985, 9/78 Yes (Note 4)
Yes Transients, and Stress Limits Pipe Stress Calc.
X4CP-7125 Rev 2 1660 FSAR 3.9.B.3-1 Load Combinations for ASE III, Load Combinations Yes Yes N
Classes I, 2, and 3 Components Pipe Stress Calc.
and Suoports X4CP-7125 Rev 2 1661 FSAR 3.9.B.3-2 ASE III, Classes I, 2, and 3 Stress Criteria--Piping Yes Yes Component Stress Limits Pipe Stress Calc.
X4CP-7125 Rev 2 i
i 1672 FSAR 3.9.8.3.1.6.2D ASE Code Classes 2 and 3 Permissible Pressure Yes
--
t Piping Stress Limits--Faulted Less than or Equal to
'
Condition 2.0 Times Design j
Pressure (P) of Equation (4) of
,
)
NC-3641.1 I
1685 FSAR 3.9.B.3.3
!
Crit!nandInstallation ASE 111 and Vill Yes
--
Dest ria for Pressure j
Relieving Devices
!
1689 FSAR 3.9.B.3.3.1 Pressure Relieving Device--
Dynamic Load Factor =
Yes
--
i Dynamic Amplification 2.0 I
j 1690 FSAR 3.9.B.3.4.2.1 Snubbers Used as Component ASE III, Subsection NF Yes Yes Supports Pipe Support Calc.
Vl-1205-010-Hol6
.
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1693 FSAR 3.9.B.3.4.2.1 Snubbers Used as Component RG 1.124 Yes Yes Supports--Service Limits and Pipe Support Calc.
Loading Combinations VI-1205-010-Hol6
- - - - _ _ _
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TABLE 1 (continued)
i Verified First Verified Second Reference Conunitment Commitment Order Document Order Document-
,
]
Number Source Section Consnitment Subject Document Feature (Note 7)
(Note 8)
1825 1.E.B C-79/12/28 Piping Support Base Plate
"A Report on Pipe Yes Yes Correspondence Designs Using Concrete Support Base Plate Pipe Support Calc.
l Expansion Anchor Bolts Designs Using Concrete V I-1202-405-H030
Expansion Anchor Bolts,
Response of 12/28/79 1997 FSAR 3.8.3.2.1 Containment Internal ASE 111, Subsection NF, Yes
--
j Structures, Codes and Standards 1977, including Winter j
(Component Supports)
1977 Addenda
,
2058 FSAR 6. 2. 4.3.H Containment Isolation System, Containment Isolation Yes
--
Design Evaluation System is Designed in
,
Accordance with Seismic q
Category i Requirenents i
2517 FSAR 6. 2.4. 2. 2 Design Requirements of BTP-K B 3-1 Yes
--
Containment Penetration N
'
'
4238 NRC Question Q 210.42 Stress Limits and Calculation ASE 111, NS-3650 Yes
--
Correspondence Method for Class 1 Piping
4241 FSAR 3.9.B.3.4.2.1D Snubbers Used as Component Frictional Resistance Yes Yes Supports--Acceleration Limiting Due to Normal Thermal PPP Procedure
.
!
Snubbers Movement Does Not Exceed IX-32 1% or 5 lb, Whichever is
{
Greater I
4243 FSAR 3.9. B.3.4. 2.1 E Snubbers Used as Component Total Movement During Yes
!
Supports Cyclic Loading Does Not
--
'
Exceed 0.% Inch 4246 NRC Question Q 210.45B Component Supports /
ASE II, SA-36 or Yes Yes Correspondence Supplementary Steel--Design and Equivalent ASTM Type PPP Procedure
'
Construction Bases Material 1X-50
,
!
4253 NRC Question Q 210.45B Component Supports Friction Friction Load Considered Yes Yes
!
Correspondence Load if Thermal Movement Pipe Support Calc.
I Larger than 1/16 inch VI-1204-028-H004 l
4255 NRC Question Q 210.45D Component Supports--Deflection Maximum Deflection of Yes Yes Correspondence 0.04 Inch in Each Pipe Support Calc.
Restraint Direction, VI-1204-028-H005
Except for Small Piping
,
(Diameter Less Than or Equal to 2.0 inch) Where Maximum Deflection is l
0.0625 Inch
!
!
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,
(
.
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TABLE 1 (continued)
Verified First Verified Second
Reference Commitment Commitment Order Document Order Document Number Source Section Commitment Subject Document Feature (Note 7)
(Note 8)
4258 NRC Question Q 210.45-3 Allowable Axial Stress for Variation of A110wable Yes
--
Correspondence Different KL/R Ratios Axial Stresses for KL/R Ratios 4370 F SAR 3.7.B.1-1 Damping Values for Fixed Base Seismic Percent of Yes
--
Structures and Components Critical Damping Per Mode 4678 1.E.B.
C-79/10/ 29 Seismic Analysis for As-Built Seismic Analysis Will Be Yes Yes Correspondence Safety-Related Piping System Performed Using As-Built Pipe Stress Calc.
Information X4LP-7125 Rev 2 4992 FSAR 3.6.2.3.1 Determination of Jet Impingement Analytical Methods of Yes (Note 5)
--
Ef fects Resulting From BN-TOP-2 and ASCE Postulated Pipe Breaks in Non-Paper of 12/73 RCL Piping 5031 NRC Question Q 210.28 Jet Thrust Rise Time for Dynamic Initial Pulse Rise Time Yes
--
Correspondence Analysis of Pipe Break Reaction is 1 ms Loads
--
F SAR 3.9.B.3.1.6.2.B ASME Code Class 2 and 3 Piping Permissable Pressure (Note 6)
--
Stress Limits - Upset Condition Shall Be Less Than or
Equal to 1.1 Times De-sign Pressure (P) of Equation (9) of NC-3650
--
FSAR 3.9.B.3.1.6.2.C ASME Code Class 2 and 3 Piping Permissable Pressure (Note 6)
--
Stress Limits - Emergency Shall Not Exceed 1.5 Condition Times Design Pressure (P) of Equation (4) of NC-3641.1 NOTES:
1.
The first five columns of this table are from the Section 3.4 coniitment matrix.
2.
It is not yet clear as to why Section 2.3 of the Design Criteria DC-1017 was identified for implementation of this commitment in the Section 3.5 comitment matrix.
3.
The program ME-150 was listed in DC-1017 as a computer program used in analysis but is not listed in the FSAR.
4.
The commitment subject should be expanded to include the words " functional capability".
5.
It is not yet clear as to why Reference 5 (an ASCE paper) of the FSAR is not mentioned in the implementation document, DC-1018.
6.
This commitrent was omitted in the Readiness Review Tean's preparation of the commitment matrix.
7.
"Yes" in the sixth column means that commitment was vertfled in the documents listed in the Section 3.5 implementation matrix.
8.
"Yes" in the seventh column means that commitment was verified in the document listed.
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