IR 05000424/1986062
| ML20215N106 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/14/1986 |
| From: | Blake J, Vias S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215N102 | List: |
| References | |
| 50-424-86-62, NUDOCS 8611040278 | |
| Download: ML20215N106 (29) | |
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UNITED STATES
[$3Kffu[D NUCLEAR REGULATORY COMMISSION o
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REGION 11 n
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,,j 101 MARIETTA STREET, N.W.
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ATLANTA. GEORGI A 30323
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.u-Report No.: 50-424/86-62 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.:
50-424-License No.: CPPR-108 Facility Name: Vogtle 1 Inspection Conducted: May 27 - June 5, 1986 Inspector:
O lb B6 S. J. Vias Date Signed
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Accompanyin s nn 1-G K. Miller, EG&G, Idaho, Inc.
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Approved by:
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Date Signed
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late, Section Chief
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En i ering Branch D i ion of Reactor Safety SUMMARY Scope:
This special',. ~ announced inspection,- on site, involved the areas of safety-related supports (Unit 1), and Readiness Review Module 11, Pipe Stress and Supports (Unit 1).
Results: Three violations were identified:
1)
Discrepancies in design documentation, see paragraphs 5.c.6).a.(3).(a). and
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5.c.6).a.(3).(b).-
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Inadequate construction procedures for installation and inspection of spring supports and installation and inspection of clamps and clamp bolts for mechanical shock arrestors, see paragraph 5.c.6).b.(2).(b).
3)
Discrepancies between the pipe support installations and associated documentation, see paragraph 5.c.6).(b).(2).(c).
8611040278 861027 PDR ADOCK 0500
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. E. Conway, Senior Vice President (VP)
- D. O. Foster, Vice President and Project Support Manager
- C. E. Bellflower, Quality Assurance (QA) Manager - Operations
- C. W. Hayes, Quality Assurance Manager
- M. H. Googe, Project Construction Manager
- H. W. Swain, Manager Quality Control (QC)
- W. C. Gabbard, Regulatory Specialist - Operations
- J. J. Gilmartin, Mechanical Field Engineering Supervisor
- E. D. Groover, QA Site Manager - Construction
- G. A. McCarley, Project Compliance Coordinator
- R. W. McManus, Readiness Review (RR) Assistant Pro.iect Manager Other licensee employees contacted included construction craftsmen, engineers, technicians, mechanics, and office personnel.
Other Organizations
- 0. Batum, Southern Company Services (SCS), Deputy to VP Engineering
- A. J. Ayoob, Westinghouse /VSAMU, Manager VSAMU
- D. L. Carlson, Bechtel Power Corporation (BPC)
- S. T. Cloyd, VSAMU, Mechanical Engineer
- J. E. Miller, Pullman Power Products (PPP), General QA/QC Manager
- F. B. Marsh, BPC, Project Engineering Manager
- W. C. Ramsey, SCS, Manager Readiness Review
- D. W. Strohman, BPC, Project QA
- R. C. Summerfeld, BPC, Team Leader, RR NRC Resident Inspectors
- H. Livermore, Senior Resident Inspector - Construction J. Rogge, Senior Resident Inspector - Operations R. Schepens, Resident Inspector - Operations
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on June 5, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the license.
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Inspector Followup Item 424/86-62-01, Omission of Design Commitments -
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paragraph 5.c.3).b.
l Unresolved Item 424/86-62-02, Unresolved Questions on Commitment i
Implementation paragraph 5.c.3).c.(1).
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Violation 424/86-62-03,- Inadequate Construction Procedures for
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Installation and Inspection of Spring Supports and Clamps paragraph 5.c.6).b.(2).(b).
Violation 424/86-62-04, Discrepancies in Design Documentation -
paragraphs 5.c.6).(a) (3).(a) and 5.c.6).a.(3).(b).
Unresolved Item 424/86-62-05, Unclear Use of " Typical" in Welding Symbol Ca11 outs paragraph 5.c.6) a.(3).(c).
Violation 424/86-62-06, Discrepancies Between Pipe Supports, Design Documentation and Q.C. Documentation paragraph 5.c.6) (b).(2).(c),
Jtems [1] thru [10].
Inspector Followup Item 424/86-62-07, Discrepancies in Walkdown of Supports paragraph 5.c.6).b.(2).(c), Item [11].
The licensee did not identify as proprietary materials various documents for review by the inspector during this inspection, but no proprietary informa-tion is contained in this report.
3.
Licensee Action on Previous Enforcement Matters
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This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they area acceptable or may involve violations or deviations. Two new unresolved items identified during this inspection are discussed in paragraph 5.C.3).c.(1) and 5.C.6).a.(3).(c).
5.
Review of Readiness Review Module 11, Pipe Stress and Supports (Unit 1)
(50090)
A.
Scope of Review
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This review consisted of an examination of GPC's Readiness Review I
Module ~11, Pipe Stress and Supports. Sections 1.0, 2.0, 4.0, 5.0, and
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8.0, presented data on module organization, project organization, l
program description,- audits and special investigations, 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 l
licensing commitments.
These include commitment identification, i
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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 construc-tion.
The methodology used and an evaluation of_ each section are presented in paragraphs S.A and 5.B.
B.
Methodology The NRC review performed 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:
o Reviewing the description of the Readiness Review program and establishing organizational responsibilities for Module 11, o
Verifying Module 11 review boundaries, o
Evaluating Sections 3 and 6 of the Final Safety Analysis Report (FSAR) for proper identification of licensing and project commitments, o
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 1and design criteria, o
Selecting a sample of piping isometrics to be used in the assessments of Subsections 6.1 and 6.2 of the Module 11 report, o
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 clas _..
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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 commitments chosen represent a range of commitment categories
embracing the significant aspects of Module 11. These commitments were j
selected to verify that they were properly transferred from commitment
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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
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commitments pertaining to pipe stress and pipe supports, contained i
therein, were accurately identified in the commitment matrix in Subsection 3.4 of Module-11.
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Finally, an assessment was made on three of the Level I findings i
resulting from Readiness Review's Design and Construction Program
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Verifications.
The second on-site inspection documented in this report was conducted during May 27 to June 5, 1986, which included the following activities:
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Completing verification of commitiment implementation into design o
and construction programs, o
Accomplishing general Module 11 review activities, o
Performing a Design Program Verification review, (
o Performing a Construction Program Verification review.
Each of the commitments in the 41 commitment sample was traced for impler..entation into the first-order documents listed in the implemen-l tation matrix of Module 11.
Eighteen of these commitments were also
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traced for impleme'ntation into second-order documents (calculations,
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drawings, etc.) or field installation.
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General review activities included an assessment of the information presented in Sections 1, 2, 4, 5 and 8 of Module 11.
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An evaluation of the Design Program Verification was made by reviewing
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a portion of the stress calculations for the eleven selected piping i
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isometrics and their 50 associated pipe supports. These calculations and related design criteria, drawings, and change -documentation were
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reviewed for adequacy of design control, adherence to criteria and procedures, and design integrity.
g An evaluation of the Construction Program Verification was made by j
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
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Pullman Power Products (PPP) Quality Control (QC) documents associated
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with the 50 pipe supports were reviewed for conformance to specifica-tions and procedures, and for compliance with design drawings.
C.
Evaluation
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The evaluation of each Module section is provided below in the
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section-by-section format used in the Module 11 report. Included are a l
description of the section, subject matter reviewed, basis for j
acceptance, and statement of required followup or evaluation.
1)
Section 1.0--Introduction
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a.
Review Introduction and'Section Examination.
This section presents the scope of Module 11, lists the key hardware and
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work activities included, outlines the Module organization,
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and reports the project status. The section was examined by the NRC Region II inspectors for appropriateness of scope and i
for background information.
Additionally, the Module boundaries were clarified and project status was assessed.
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b.
Boundary Definition.
Table 1.1-1 of Module 11 lists the hardware and associated work activities for modules that have mechanical 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 l
Bechtel Power Corporation (BPC) and Vogtle Structural l
Analysis Mobile Unit (V-SAMU). A review of this information j
showed that Module 4 included construction and fabrication of j
American Society of Mechanical Engineers' (ASME) Code
Section III ' Class 1, 2,. and 3 piping and mechanical equip-l ment.
At the time of verification, Westinghouse was
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responsible for the complete Class 1 stress analyses for 4-inch and larger piping and for the fatigue analysis for all other Class I piping.
The Westinghouse work activity was
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excluded frc.n the scope of Module 11.
The design and construction of piping systems in the Nuclear Steam Supply
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System (NSSS) were included in Module 16. Also contained in l
Module 11 were stress analyses of nonsafety related piping -
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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
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restraints lay within Module 8.
The attachment of pipe
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supports to embedments cast into Category I concrete were included in Module 11 while the embedments themselves
belonged to Module 8.
i The NRC Region II inspectors found the description of
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Module 11 boundaries to be acceptable.
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c.
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 August 1, 1985. These percentages were revised as of April 4,1986, to show 100% completion for design of small-bore and 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 support program.
2)
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 responsibilities of the various organizations and personnel within the organizations were clarified.
The NRC Region II inspectors had no findings in this section.
3)
Section 3.0--Commitments a.
Review Introduction and Section Examination.
This section contains listings of commitments and implementing documents, which are displayed in two matrices.
The first matrix, entitled " Commitments," identifies all of the Module 11 commitments and their source documents. The second matrix, entitled " Implementation," lists the document or plant feature for each commitment, as discussed in the source document,.and the project document in which the commitment is
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implemented.
The NRC Region II review was directed toward
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verifying the proper implementation of the listed commit-ments.
This was accomplished by selecting a sample of 41 commitments representing the range of commitment topics.
Each sample commitment was examined by reviewing the
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commitment source document for the precise requirement and the listed implementation document (in the implementation matrix) for accurate carry through of the requirement, b.
Identification Review.
The NRC Region II inspectors' review of FSAR Sections 3 and 6 and the Module 11 commitment matrix
initially indicated that several GPC commitments I.ad been omitted from the commitment matrix. In most such instances, Readiness Reviev's explanation was that the commitment had been identified but was more appropriately placed in another
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module.
In other cases, the. commitment was actually the statement of a condition ensuing from adherence to a more general commitment.
Two commitments contained in FSAR Paragraphs 3.9.B.3.1.6.2.B and 3.9.B.3.1.6.2.C pertaining to permissible pressure in the upset and emergency conditions were, however, 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 Inspector Followup Itera, IFI 424/86-62-01 - Omission of Design Commitments.
c.
Implementation Review.
The NRC Region II inspection consisted of a. review of Subsections 3.1, 3.2 and 3.3 for con.ent 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:
o Verifying that the Subsection 3.4 commitment matrix correlates with the Subsection 3.5' implementation matrix for each commitment in the sample, o
Reviewing the source document referenced in the commitment matrix for a clear statement of requirement for each commitment, o
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 are listed in Inspection Report 50-424/86-44, Table 1.
(1) First-Order Commitment Implementation For 36 of the 41 commitments selected for review, the commitments were readily found to be implemented in the documents identified in the Subsection 3.5 implemen-tation 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.
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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 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 g:ommit-ment 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:
o 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 the Module 11 Sub-section 3.5 matrix for implementation of this commitment. Readiness Review has been requested to provide further clarification.
o Commitment 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.
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c Commitment 4992--This commitment specifies the use of. two documents for the analytical determination of 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 imple-menting Design Criteria DC-1018. Readiness Review has been requested to explain why the ASCE paper was not included in the criteria.
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i These three commitment questions are identified as Unresolved Item, UNR 424/86-62-02 - Unresolved Questions on Commitment Implementation.
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(2) Second-Order Commitment Implementation Of the 41 commitments in the review sample, eighteen were evaluated for implementation into second-order documents (design calculations, construction procedures,
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In all cases, the NRC Region II inspectors determined that the commitments were properly. imple-mented in the second order document reviewed.
The second-order document for each of these eighteen commitments represents only one instance of implementa-tion for'that commitment. Numerous other implementation documents could exist.
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 commitinent 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,
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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 commit-
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ments 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.
4)
Section 4.0--Program Description a.
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.
b.
Design.
Subsection 4.1 divides a description of the design
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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 cefined 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 inspectors identified no deficiencies in the design program described in this subsection.
Results from the review of Section 6 of Module 11 were used to determine how effectively the program actually functioned.
c.
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 II review, but several procure-ment documents were inspected in the review of the Construction Program Verification Section.
No deficiencies were identified in the procurement process.
d.
Site Material Control.
Subsection 4.3 describes the responsibilities of the pipe support installers relative to receipt, inspection, and control of ASME Boiler and Pressure l
Vessel Code material within the scope of Module 11.
This subsection describes the requisition process used by the
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responsible contractor, Pullman Power Products (PPP), to (
obtain the construction materials. It also explains receipt inspection procedures, review of ASME Code Section III
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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.
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e.
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 installa-tion of pipe supports and pipe racks was performed in l-
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accordance with Bechtel Power Corporation's Specification X4AZ01.
Pipe whip restraints were installed to Specifica-tion 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
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this program.
f.
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 Vogtle. 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.
5)
Section 5.0--Audits and Special Investigations This section discusses quality assurance audits and 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 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 cccurred 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
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for importance by the Readiness Review. Team. The Construction Program Verification in Module 11, Subsection 6.2, was designed to
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include all areas where f t.ndings of high or moderate importance occurred.
In addition, the NRC Region II inspectors determined that all items related to Module 11 and 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 assessments fo'r Module 11.
The NRC
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Region.II inspectors had no findings in this section.
6)
Section 6.0--Program Verificatio'n This section of the Module 11 Report describes activities undertaken to ascertain whether design and construction work processes were adequately controlled to ensure implementation of licensing commitments and conformance with project procedures and design requirements. The section is divided into two subsections
covering Design Program Verification 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.
a.
Subsection 6.1--Design Program Verification (1) Review Introduction The Design Program Verification performed by the l
Readiness Review Team focused on the programmatic
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aspects of design. It included an assessment of design
processes and a review of~ design documents for-implementation of licensing commitments. The Readiness I
Review Team's review was performed in two parts. Part I l
consisted of verifying implementation of all technical commitments within Module 11. Source documents.(such as l
the FSAR) were. reviewed to identify project commitments l
regarding pipe stress and pipe support design activities.
Design criteria. documents were then reviewed for implementation of these commitments.
A selected sample of commitments were further reviewed for implementation into second-level design documents such l
as calculations and drawings.
Part II consisted of a l
review of design. criteria and second-order design L
documents for conformance to project procedures and
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quality assurance requirements.
Emphasis was placed on the areas of design control, internal 'and external design coordination, adherence to design criteria, procedural compliance, and design documentation.
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(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 5.C.3).c of this report.
The sampling contained 39 of the 95 design related commitments identified-in the Subsection 3.4 commitment matrix.
(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:
o Pipe Stress Calculations, o
Pipe Support Calculations, o
Pipe Support Drawings, Design Change and Nonconformance Documents, o
o 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 l
piping isometrics were chosen to obtain a diversity of pipe sizes, pipe classes, 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 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 Inspection Report 424/86-44, Table 2.
All of the isometrics and pipe supports were evaluated in NRC Region II's review of the Construction Program Verification, and a portion of the design documents associated with these isometrics were examined in the review of the Design Program Verification. The design documents examined by NRC Region II are indicated I
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in Inspection Report 424/86-44, Table 2.
The NRC
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Regien II assessment of design documentation is reported as follows:
(a) Pipe Stress Calculations The following calculation packages were examined for completeness, interdiscipline coordination,
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conformance to design criteria and project requirements, consistency with drawings and
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installation, and technical adequacy:
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X4CP-7024 Rev 0 Piping Isometric IK3-1217-176-01 X4CP-7125 Rev 2 Piping Isometric 1K4-1202-001-01 X4CP-7009 Piping. Isometric.1K3-1204-028-01 Observations made relative to the X4CP-7024 review include:
The piping configuration used in the analysis o
was consistent with the isometric and the installation.
o Stress limits used were in accordance with ASME Section III Class 2 criteria for the Class 2 piping.
o Damping values used were in accordance with Regulatory Guide 1.61.
Observations made relative to the X4CP-7125 review.
include:
o Damping valves used were in accordance with Regulatory Guide 1.61.
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o A containment cooling unit was included in the structural model to account for its flexi-bility.
This is representative of proper analytical methodology.
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o Load combinations used were in accordance with Design Criteria DC-1017 and NUREG-0484.
o Stresses for the faulted condition were within allowances specified in ASME Code Case 1606-1.
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o The program WESTDYN was used to perform the analysis, which is listed in the FSAR as
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acceptable.
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o The piping configurat: 1n used in the analysis was consistent with the isometric and installation except that pipe support VI-1202-001-H004 was located 10 1/2 inches from its actual field location.
The design tolerance for this support location is 8 inches. This deficiency is considered to be a violation of the requirements of 10 CFR 50, Appendix B, Criterion III, and is identified as Violation 424/86-62-04 - Discrepancies in Design Documentation, for other examples see paragraph 5.C.6).a.(3).(b)
Observations made relative to the X4CP-7009 review include:
o The piping configuration and locations of all components in the line were consistent with the piping isometric and installation.
o The valve weights and orientations used in the analysis were consistent with the drawings and installation.
o The design temperature and pressure, operating temperature and pressure, and pipe material were consistent with. parameters given in the
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Line Designation List.
o Load combinations used were in accordance with Design Criteria DC-1017 and NUREG-0484.
o The seismic response spectra used in the analysis corresponded to the proper building and elevation.
o The nozzle loads acting on a pump in the line were within manufacturer's allowables.
o The calculations for thermal anchor movements were correct and the movements were incorporated in the analysis.
o-The calculated stresses were within AbnE Section III Class 2 allowances and deflections at support locations were less than the:
0.04 inch allowed for large' piping.
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(b) Pipe Support Calculations
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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 adequacy. All of these pipe supports are contained in the piping isometrics reviewed in the paragraphs above.
o V1-1217-176-H001, -H004, -H007, o
V1-1202-001-H003, -H004, o
V1-1204-014-H008,
.V1-1204-020-H003, -H004, -H005, -H006, -H008, o-H026.
Observations made relative to these pipe support calculations include:
In calculation V1-1204-028-H026, a dimension o
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. The drawing showed the dimension to be one inch and in the field it measures five inches, the calculation used one inch. This deficiency is considered to be a violation of the violation of the requirements of 10 CFR 50, Appendix S, Criterion III, and is arother example of Violation 424/86-62-04, Discrepancies in Design Documentation, discussed in paragraphs 5.C.6).a.(3) (a)
and 5.C.6).b.(2).(c).,
Item [7].
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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 l
blank, which hindered verification of proper
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signoff.
The second block should have been l
marked "Not Applicable" or other notation, if
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the first signature was that of an engineer.
The omission of a notation in the second block is identified to be a violation of the requirements of 10 CFR 50, Appendix B, Criterion III, and is identified as another example of Violation 424/86-62-04
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Discrepancies in Design Documentation.
o Design loads and-displacements were correctly transferred from the pipe stress calculations to the pipe support calculations.
o A friction load was included whenever the.
thermal movement at a support exceeded 1/16 inch.
o The structural members used in the analyses corresponded in size and material with the drawings and installation.
o The program PIPSAN was used to perform pipe support analyses and is listed in the FSAR as an acceptable program, o
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.
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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 Inspection Report 50-424/86-44, 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
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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 5.c.6).b.(2).(c),
Item [8].
This discrepancy in weld callouts is identified as Unresolved Item 424/86-62-05 - Unclear.Use of
" Typical" in Welding Symbol Callouts.
(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.
These design change documents were examined by the NRC Region II inspectors for the following attributes:
Proper disposition and approval, o
Appropriate technical justification, o
Correct incorporation into drawings.
o Verification errors were not found during the examination of the ' sample design change documenta-tion.
(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 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 l
between a deficiency identified in their review and l
Readiness Review Finding 11-75.
NRC Region II's l
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evaluation of these Readiness Review Findings is described below:
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o 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.
o 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, o
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 sufficient.
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o 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 i
these findings in their review of pipe stress calculations.
o Finding 11-75 -- This finding noted that
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l installation tolerances for supports were not consistently addressed in support calcula-tions.
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 Findir.g.
As described
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in Paragraph 5.C.6).a.(3).(b), a dimensional discrepancy that exceeded. tolerance ~ was
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identified on a. support drawing.
This is
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included in the findings in Section 4 of this report.
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The examination of the-Readiness Review Findings in the Design Program Verification
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disclosed no verification errors, b.
-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,
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procedures, specifications, vendor instructions, and installation of pipe whip restraints. The program had
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i 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:
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o Commitment Implementation,
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Construction Programs and Procedures, o
o Hardware and Associated Documentation,
o Pipe Whip Restraint Installation,.
o Findings.
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All of the foregoing topics were examined in the NRC
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t Region II 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
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verified were 331, 880, 1825, and 1927.
The
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results of this effort are included in Inspection Report 424/86-44, Table 1.
As indicated, commit-ments 880 and 1825 were verified for implementation into both first-and second-order documents. The
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NRC Region II inspectors identified no deficiencies in the verifications of these four commitments.
(b) Construction Programs and Procedures The Readiness Review Team made an assessment of the following four PPP construction procedures:
o IX-50, Pipe Support Field Installation and Fabrication, o
IX-32, Installation _of Mechanical Shock Arrestors, IX-8'6, Installation of Bergen-Paterson Struts, o
o IX-1, Installation and Inspection.of Concrete Anchors.
The Readiness Review Team found that vendor requirements and~ specification requirements were adequately reflected in these construction procedures. The NRC Region II inspectors reviewed portions of these procedures in their evaluations of 50 pipe supports described in the following section (c) below.
The NRC Region II inspectors found that these portions of the construction procedures adequately reflect project requirements with two exceptions. The NRC Region II inspectors determined that the installation and inspection procedures for spring supports showed a major deficiency in detail relative to procedures for mechanical shock arrestors (snubbers)
and
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Bergen-Paterson Strut installation.
The PPP l
Procedure IX-50 should be expanded to include such
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items as:
o Traceability and identification of small connecting parts,
o Proper installation and inspection of connecting component hardware, o
Installation and identification of clamp and I
clamp bolting material, o
Verification of installation of required spring support travel stops during construc-l tion.
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The required travel stops for spring hangers VI-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 insufficient as described above.
A second exception was that the procedures for installation of mechanical shock arrestors, PPP Procedure IX-32, did not properly allow for identification or traceability of the clamps or the clamp bolts.
Verifications of proper clamp and bolt installation and of the materials used in these pieces have not been addressed in support inspections conducted at the time of snubber installation.
The. PPP Procedure IX-32 should be expanded to include these verifications.
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 above.
The two examples for the inadequate PPP Procedures IX-50 and IX-32 used for QC inspection are a violation of-10 CFR 50, Appendix B, Criterion V, and is identified as Violation 424/86-62-03 -
Inadequate Construction Procedures f.or Installation and Inspection of Spring Supports and Clamps.
l (c) Hardware and Associated Documentation As discussed in Paragraph 3.g.(3) of this report, the NRC Region II inspectors selected eleven piping isometrics with 50 associated pipe supports to form a basis for evaluating the Design and Construction Program Verificat. ions.
The piping isometrics and pipe supports examined are listed in Table 2.
As shown in the table, seven of these isometrics and seven of the pipe supports were also reviewed by the Readiness Review Team.
The NRC Region II inspectors examined the construction aspects of all 50 pipe supports by first performing a field inspection on the pipe isometrics and pipe supports.
During this inspection, the following information was recorded:
o Pipe dimensions, component locations and orientation,
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o Support dimensions and support locations, o
Support configuration, o
Weld size and type, o
Support materials, o
NF component heat numbers, o'
Clearances between pipe and support, o
Snubber NPT Code Data Plate information, cold set, traceability markings on connecting hardware, o
Spring hanger NPT Code Data Plate informa-tion, travel stop installation, traceability markings on connecting hardware.
The information recorded during the field inspections was then reviewed against the Line Designation List.(LDL), Piping 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
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. packages were Drocess Sheets, MFCRBs, Authoriza-tions to. Continue Work (ATCWs), DRs, DCN-Rs, Snubber and Strut Checklists, Weld Process Sheets, and Weld Rod Requisition Tickets.
Among other miscellaneous construction documents reviewed were
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l-Requests for Support Removal, Liquid Penetrant
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Examination Records, Material Inspection Reports, l
Maintenance Work Orders, Grout Requests, Core Drill
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Requests, Certificates of Compliance, and Certified Mill Test Reports.
Based on the inspection of pipe supports and associated. documentation, the NRC Region II inspectors found that the pipe support installa-tions were generally consistent with the documentation and in accordance. with project requirements. This assessment is consistent with
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the basic conclusion reached by the Readiness l
Review Team.
The NRC Region II inspectors did,
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however, identify several deficiencies in the construction program, which are described as follows:
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[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 inspectors. 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
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V1-1202-405-H033, V1-1202-405-H036 V1-1302-022-H002, and V1-1302-025-H'001.
[2] 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.
[3] The plate designated item "1" on support V1-1202-001-H004 was undersized beyond the tolerance allowed by PPP Procedure IX-50. The
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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.
[4] The clearances between support and pipe were insufficient in three cases.
Specific cases i
were the clearance in the E-W direction for
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support V1-1202-001-H008, the clearance in the E-W direction for support VI-1217-176-H007, l
and the clearance in the N-S direction for
support V1-1205-007-H043. The total clearance l
in each case was zero.
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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.
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[6] The orientation of the south strut in support V1-1203-034-H010 was not in accordance with the drawing.
The dimension from the connection at the wall to the pipe centerline was measured to be 2'9", while the drawing
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specified 2'3".
[7] A discrepancy between the pipe support drawing-a' d installation was noted in a dimension in n
support V1-1204-028-H026. The dimension from the bottom of the horizontal wide flange beam to the top of the embed plate was measured to be 5 inches and shown on the drawing to be 1 inch; for other details see Pa'ragraph 5.C.6).a.(3) (b) of this report.
[8] The weld symbol callouts on several drawings differed from installation. These differences were aside from the alternate weld patterns allowed by PPP Procedure IX-50.
The unrestricted use of the word " typical" has misled craft personnel, field engineers, and QC inspectors, resulting in different weld patterns in numerous-instances. The lack of clarity was further evidenced by the issuance of DCN-Rs to clarify weld symbols.
Specific supports where confusing weld symbols occurred were V1-1203-034-H011, V1-1204-014-H008, V1-1204-028-H006, V1-1205-007-H033, and V1-1205-007-H043, for other details see l
paragraph 5.C.6).a.(3).(c) of this report.
[9] A number of discrepancies or inadequacies were noted in the LDL, P& ids, and pipe isometric drawings.
The isometric drawings 1K3-1203-034-05 and 1K3-1205-007-02 showed incorrect P&ID numbers, while the LDL showed the correct numbers.
Conversely, the isometric drawings IK3-1205-010-03 and IK5-1302-022-01 showed correct P&ID numbers, while the LDL showed incorrect numbers. The 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
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finding in the NRC Region II Report for Readiness Review Module 4, identified as -IFI 424/85-35-08, Maximum Design Pressure Discrepancy.) This P&ID was also unclear in showing that a 3/4-inch tap line to relief valve PSV8853A has line number 1204-128-3/4".
On isometric IK3-1205-010-03, the location of support V1-1204-201-H007 (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 installer's notes and details in information blocks, that should either be controlled for accuracy or eliminated from the drawings.
[10] Several inadequacies were noted in the documents included in the PPP QC packages. On support VI-1203-034-H007, the original ATCW differed from DCN-2 in that 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 installation, but does constitute a violation against PPP Procedure III-4 and GPC Procedure DCA-03. On support VI-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 completed though the package had been accepted by both-QC and Quality Assurance (QA).
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approvals should not have been given without
completion of the check sheet.
On support
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V1-1205-010-H015, the Requests for Support Removal, ATCW, DCN-R, and drawing were not coherent, leaving a non-traceable document path.
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The discrepancies, in the above ten items l
between support
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I information, construction documentation and QC l
documentation is a violation of 10 CFR 50, l
Appendix B, Criterion X, and is identified as Violation 424/86-62-06 Discrepancies Between
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[11] 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.
Pending review and evaluation by the licensee and further NRC inspection, this matter is identified as Inspector Followup Item 424/86-62-07 - Discrepancies in Walkdown of Supports.
(d) 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 documenta-tion, and two resulted from assessment of pipe whip restraints. Two of the findings were classified as 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 Findings is described below:
o 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 l
locations. Where the thermal movement changes l'
at a support -location, the support will be j
inspected for existence of a shim plate. If a
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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.
o Finding 11-6 -- This finding noted that the pipe location on one cantilevered beam support was outside the allowable 4-inch 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
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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
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Team's conclusion that this was an isolated event.
The examination of the Readiness Review Findings in the Construction Program Verification disclosed no verification errors.
7)
Section 8.0--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 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.