IR 05000456/1985041

Safety Insp Repts 50-456/85-41 & 50-457/85-40 on 850819-23, 1007-10 & 17.Violation Noted:Failure to Control Design Changes to Pipe Support Drawings

ML20198A836
Person / Time
Site:	Braidwood
Issue date:	11/01/1985
From:	Danielson D, Kaufman P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198A796	List: IR 05000456/1985041 IR 05000819/2010017 ML20198A791
References
50-456-85-41, 50-457-85-40, NUDOCS 8511060194
Download: ML20198A836 (6)

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-U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/85041(DRS)'; 50-457/85040(DRS)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago,' IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: August 19-23 and October 7-10, 17, 1985 Inspector: b P. D. Kaufman s

N[3//65 Date D. H. Danielson, Chief H '

Approved By:

Materials and Processes Date Section Inspection Summary Inspection on August 19-23 and October 7-10, 17, 1985 (Reports ,

No. 50-456/85041(DRS); 50-457/85040(ORS))

Areas Inspected: Routine, announced safety inspection of safety-related pipe supports and a new trial pipe support installation / fabrication and modification program.- The inspection involved a total of 80 inspector-hours onsite by one NRC inspecto Results: Of the areas inspected, one violation was identified (failure to control design changes to pipe. support drawings - Paragraph 2.b).

8511060194 851101 PDR

.G - ADOCK 05000456 PDR

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DETAILS 1.~ Persons Contacted Commonwealth Edison Company (CECO)

• Vahle, Project Engineering Manager M. Curinka, Construction Field Engineer M. Lohmann, Assistant Construction Manager

• J. Wallace, Project Manager

• D. Shamblin, Construction Superintendent

• G. Fitzpatrick, Assistant Manager, Quality Assurances Corporate

• C. Schroeder, Licensing and Compliance Superintendent

• T. Quaka, Quality Control Supervisor

• L. Kline, Licensing and Compliance Supervisor

• E. Wendof, Project Engineering

• J. Dierbeck, Project Construction Field Engineer

• D. Skoza, Engineering Supervisor Sargent & Lundy Engineers (S&L)

K. Fus, Mechanical Project Engineer M. Flynn, Mechanical Project Engineer Phillips, Getschow Company (PG)

M. Galloway, Assistant Project Engineer

~ Johnson, Group Supervisor / Hanger Engineering R. Whittington, Lead Field Engineer / Hangers C. Hannold, Welder D. Downs, Fitter C. Greer, Foreman K. McNeeley, Area General Foreman The inspector also contacted and interviewed other licensee and contractor employee * Denotes those attending the final exit interview on October 17, 198 . Review of Component Support Installation and Verification Program New methods for controlling installation and inspection of piping component supports / restraints have been initiated by the licensee because of the

. interference problems encountered during the installation process and the long turnaround time associated with the proposed redesign by the architect engineer (A/E). These new methods which are referred to as the Tack-In-Place (TIP) method and the Weld-In-Place (WIP) method were both reviewed by the NRC inspecto .

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Tack-In-Place Method

• This method of installation allows for the support installation process to continue, with restrictions relative to weld ou Weld-In-Place Method

• This method allows the installation process to be completed, including weld ou Both of these concepts permit supplemental design changes by the A/E Field Engineer prior to A/E design verification. The required changes to design documents is provided under the A/E Field Engineers' technical direction, by either marking up the proposed changes directly on the controlled production drawing and/or by providing a supplemental sketch on a separate form (PG/QA-5-110).

On the basis of engineering judgement, initial design, and the A/E Field Engineers signature /date, construction may continue with the understanding that the proposed design change is subject to final design review and approval and that rework may be required. This type of authorization is referred to as " approval of the design for installation."

Wnile both these methods improve the timeliness of the installation /

inspection process for component supports, they do not reduce in any way the level of review, verification, and approval of the final as-installed design configuratio Review of Procedures, Instructions and Guidelines To assess the overall TIP/WIP program adequacy, the NRC inspector reviewed the following documentation:

• Phillips, Getschow Company (PG) Quality Control Procedure (QCP)

B23, " Installation and Inspection of Componert Supports,"

Revision 13, dated September 18, 198 * PG Construction Procedure (PGCP) 1.2, " Control of Component Support Engineering Change Notices (ECN), Field Change Requests (FCR), and Field Problem Reports (FPR)," Revision 2, dated September 27, 198 * Sargent & Lundy (S&L) Project Instruction PI-BB-28, " Activities of the Byron /Braidwood Station Mechanical Engineering, Piping Design, Support Design, and Analysis Field Personnel," Revision 4, dated September 20, 198 * S&L Guidelines, "TIP/WIP Advance Concurrence," Revision 2, dated September 26, 198 * S&L Quality Assurance Manual, GQ-3.08, " Design Calculations,"

Revision 5, dated January 31, 1985, with Notification No. 084, dated July 31, 198 _ -

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e' PG Construction Procedure-(PGCP) 1, " Control of Field Change Orders," Revision 14, dated November 1, 198 * PG Work Instruction (PGWI) 6, " Implementation of Advanced Hanger ECN (AECN) Field Action," Revision 2, dated July 8, 198 While conducting this review it appeared that procedures PGCP 1.2, Paragraph 5.5 and PGWI-6, Paragraph 4.2.1.1 were inconsistent with respect to the individual marking-up of the component support drawing to reflect the actual Tacked-In-Place (TIP) condition and statu Procedure PGCP 1.2 specifies that the Superintendent performs this function, while procedure PGWI-6 stipulates that it is the craft

. foreman who is conducting this functio The licensee referred the NRC inspector to Paragraph 4.7 of procedure PGCP 1.2, which is titled " Delegation of Authority." This paragraph enables individuals to delegate the authority for the execution of prescribed actions and functions to individuals whom they direct, as indicated by lines of direction on an Organization Chart. In essence the actual individual marking up a component support drawing, which depicts a (TIP) condition, could be a craft person. The licensee stated that they would evaluate the above procedure and work instruc-tion and clarify who is actually performing these (TIP) mark-ups since formal documented training to the appropriate TIP/WIP procedures stops at.the foreman level and it could be a problem if the actual craft is performing these TIP mark-up No violations or deviations were identifie Observation of Pipe Support / Restraint Installation Activities The~ inspector conducted field walkdowns of the following piping component supports / restraints to ensure that the new procedures werc adequate for controlling support / restraint installations and inspec-

.tion In conjunction with the in process work activity observations

. associated with these components, the NRC inspector reviewed the installation / inspection documentation contained in the controlled production component support data package (TIP) Supports Reviewed

• M-2SX50001V Revision B, ECN D-01122, TIP No. 608

-* M-1SX07099A Revision B, ECN 0-04712, TIP No. 616

• M-1FWO5016S Revision C, TIP No. 447

• - M-2AF03008X Revision C, ECN 0-03714, TIP No. 393

• M-1FWO3016S Revision B, ECN 0-05065, TIP No. 553

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WIP Supports Reviewed

• M-1FW95A008T Revision A, WIP No. 988

• M-1FW95A007T Revision A, WIP No. 989

• M-20022008G Revision B, WIP No. 740 l * M-20022007G Revision C, WIP No. 737

• M-1FP13003X Revision D, WIP No. 514 l

• M-1FT4265100T Revision B, WIP No. 1265

• M-1CV51023R Revision D, WIP No. 1179

• M-1FW95A017T Revision A, WIP No. 1180

• M-1FW95G017T Revision A, WIP No. 1181

• M-1SI30115G Revision C, WIP No. 986

• M-20022010G Revision B, WIP No. 738

• M-2002205G Revision B, WIP No. 735

• M-1PI1195002T Revision A, WIP No. 1264 As a result of the above observations, the NRC inspector concluded that in general, the component support / restraint installations and inspections relative to the TIP and WIP procedures were adequat However, while reviewing the new WIP and TIP program, the NRC inspector also examined additional safety-related piping component supports which were installed or being installed, to the previous support installation /

inspection procedures and requirements. The previous support installa-tion provisions required either a formal Engineering Change Notice (ECN), Advance Engineering Change Notice (AECN), or revised design drawing be issued before the craft personnel could continue working on a support if interferences were encountered that required a support modificatio While conductinC a field walkdown, the NRC inspector observed and inspected safety-related, Class B, pipe supports 1M5050075, 1M5060075, IMS07006S, and 1MS08007S, on Main Steam lines inside the Containment Building. As these particular supports were still in the construction installation process, the NRC inspector reviewed the controlled produc-tion component support data package During the review the NRC inspector noted that the piping contractor, Phillips, Getschow Company (PG), was installing and adding gusset plates to vendor (ITT Grinnell)

supplied Hanger Standard (HS-40) Type-A Riser Clamps, without approval from either the vendor or A/E (Sargent & Lundy). PG issued installation / fabrication design drawings based on dimensions taken from the vendors' catalog. PG was adding these gusset plates to

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the riser clamps because the clamps that were supplied by ITT Grinnell

.(receipt inspected onsite) did not correspond to the S&L design drawings, which specified HS-40 Type-B Riser. Clamps. The Type-B riser

. clamp does have gusset plates on the clamp drawing shown in the vendors catalog.

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. Upon furtiher checking by the NRC inspector it was determined that the supplied HS-40 Riser Clamps Type A were previously re-analyzed by ITT Grinnell in Special-Analysis to be capable of withstanding the design loads and meet ASME Section III Subsection NF, Article NF-3231 allcwable stresses, without.the gusset plates. The Special Analysis numbers' are denoted on the' vendor Packing Lists for CECO's appropriate

purchase orders. Thus, the gusset plates which were being added pe PGs drawings were not required. Even though the gusset plates, if l installed properly, can only add to the torsional rigidity and hence strengthen the clamp, the fact remains that PG was performing a design function when they issued supplemental drawings to Sargent & Lundys'

design drawings modifying vendor supplied support components without l

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. involving and or being directed by the A/E. Failure to control design changes,. including field changes to design documents by.the responsible-design organization is a violation of Criterion III of 10 CFR 50, Appendix B, (456/85041-01; 457/85040-01). Exit Interview

! !The inspector met with licensee representatives-(denoted in Paragraph 1)

.on October:17, 1985, and discussed the scope and findings of this inspec-tion. The inspector also discussed the likely informational content of the i ins in@pection sctor duringreport thewith regard toThe inspection.- documents or processes licensee did not identifyreviewed any such by the

documents / processes as proprietary.

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