IR 05000508/1982001
| ML20050E573 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 03/25/1982 |
| From: | Dangelo A, Dodds R, Haist D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20050E476 | List: |
| References | |
| 50-508-82-01, 50-508-82-1, NUDOCS 8204130328 | |
| Download: ML20050E573 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No. 50-508/82-01 Docket No. 50-508 (C0N)
License No.~CPPR-154 Safeguards Group Licensee: Washington Public Power Supply System P. O. Box 1223 Elma, Washington 98541 Facility Name: WNP-3 Inspection at: WNP-3 Site (Satson)
Inspection conducted: January 11-15, 1982 Inspectors:
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3[24/8 2 D' P. Hais~t,feactor Inspector
/ D6te Signed sGL D6%4 3kK8c A.J.D'Ang610,'RegtorInspector
' Dat6 Signed Approved by:
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R. T. Dodos, Chief, Reactor Projects Section 2
/Date/ Signed Reactor Construction Projects Branch Sumary:
Inspection during the period of January 11-15, 1982 (Recort No. 50-508/82-01)
Areas Inspected: Routine, unannounced inspection by regional-based inspectors of construction activities including review of procedures, observation of work, and review of records for safety related pipe erection and welding and structural steel erection and welding inside the containment building; followup on a
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10 CFR 50.55e construction deficiency; and examination of licensee action on previous items of noncompliance and inspector-followup items.
The inspection involved 64 inspection hours onsite and 13 inspector-hours in-office by two NRC inspectors.
-Results:
No items of noncompliance or deviations were identified.
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8204130328 820325 PDR ADOCK 05000508 G
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DETAILS 1.
Persons Contacted The inspector interviewed various engineering, management,
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inspection and construction personnel of the organizations listed below.
Key personnel, including those who attended the exit interview are specifically identified below:
Washington Public Power Supoly System (WPPSS)
a.
- N. C. Kaufman, Deputy Project Manager
- J. A. Puzauskas, Quality Assurance Engineering Supervisor
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- C. E. Love, Construction Manager
- 0. E. Trapp, Project Quality Assurance Manager
- E. L. Stephens, Quality Assurance Engineer
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Ebasco Services, Inc. (Ebasco)
- A. M. Cutrona, Duality Assurance Manager
- J. P. Sluka,. Project Engineering _ Manager
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- L. A!. Bast, Ouality Assurance Engineering Supervisor
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D. L. Vance, Project Quality Engineer
- R. G. Peck, Project Quality Engineer
.M. Harris, Project. Quality Engineer K. Drinkard, Project Quality Engineer G. Scarfo, Support Design Group Supervisor P. Dimaculangan, Design Engineer G. Bedi, Design Engineer c.
J. A. Jones ' Construction Company (JAJ)
D. Cordaro, Quality Verification Supervisor d.
Peter Kiewit Sons Co. (PKS)
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J. Rhoades, Small Bore Piping Supervisor
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P. Smith, Quality Engineering Supervisor
- Denotes those attending the exit interview on January 15, 1982.
In addition, Mr. W. G. Albert. Senior Resident Inspector attended the exit interview.
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2.
Licensee Action on Previously Identified Enforcement Items a.
(Closed) Noncompliance (50-508/80-12/01) Wallace/ Superior Control of Nonconforming Conditions I
The licensee's actions in response to the noncompliance were examined in IE Inspection Report No. 50-508/81-12. At that time the licensee had completed all commitments specified
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in WPPSS letter nos. G03-80-3239, G03-81-885 and G03-81-1010 except for review of all Wallace/ Superior nonconformance reports provided to the licensee by Wallace/ Superior and review of other contractor's deficiency control systems for problems similar to those experienced by Wallace/ Superior.
During the present inspection the licensee's documentation for review of Wallace/ Superior NCR's was examined.
Five Wallace/
Superior NCR's were also sampled by the inspector for proper disposition by Wallace/ Superior. The licensee also completed the " mini audit" of all site contractor's deficiency control systems.
Audit findings are currently being reviewed by Ebasco for compliance with specifications. This item is closed.
3.
Licensee Action on Previous Followup Items a.
(Closed) Followup Item (50-508/509/80-15/02) - Policy for Documenting and Voiding of Inspection Reports The licensee had committed to review the policies of site contractors with regard to the voiding of quality assurance documents.
The inspector verified that a new Ebasco quality assurance specification No. 860-W,' Revision 3 now requires that contractors establish a system for controlling nonconformance report forms and a process for voiding nonconformance reports or inspection records which may indicate nonconforming conditions.
Requirements include written justification, review by. initiator and signoff for voiding documents.
Ebasco personnel stated that these requirements have been mandated on all safety related contractors
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except contract No. 224 and that contractors are revising their implementing procedures and submitting them for approval. The 224 contractor has agreed to conform his implementing procedures to these requirements.
Based on these actions this item is considered closed.
b.
(Closed) Followup Item (50-508/509/81-10/03) - Employee's Freedom to Express Concerns About Ouality Issues The inspector had expressed concern regarding a memorandum issued by the HVAC contractor (Wallace-Superior) requiring quality concerns to be brought to contractor management attention before taking them to individuals in outside organizations, including the NRC. The basis for the inspector's concern is the possibility that employees may be fearful of approaching their management with a concern.
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_ The licensee forwarded a written " Clarification of Policy" statement issued by the contractor during the week of November 16, 1981 which addresses the inspector's concerns and provides employees the requisite degree of freedom to report quality concerns to outside organizations. Accordingly the licensee does not now plan to address this item formally to NRC Headquarters.
-This item is considered closed.
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c.
(Closed) Followup Item (50-508/509/81-08/25) Use of Curing Compounds The inspector had questioned how inspectors verified that curing compounds are applied and how the coating contractor detennined which curing compound has been applied so that proper removal techniques are used prior to application of safety related coatings.
The inspector verified that quality verification inspectors are required, by procedure, to witness curing compound application.
The inspector also verified that the coating contractor's work plan requires identification and removal of incompatible curing compounds. Surface preparation and removal of incompatible curing compounds is done by sandblasting, which will remove the epoxy-based curing compounds applied by J. A. Jones.
Further, the coating contractor's routine practice is to remove all water soluble and epoxy-based curing compounds applied by J. A. Jones by sandblasting.
Based on the above, this item is considered closed.
4.
Licensee Action on 10 CFR 50.55(e) Construction Deficiencies Pipe Hanger Stiff Clamps a.
Background
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The licensee reported a potential 50.55(e) construction deficiency involving the ITT-Grinnell Figure 215 Stiff Clamps on June 11, 1981.
An interim report was received on July 13, 1981 describing the potential
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problems with the stiff clamps which included bending of the tie rods, torque relaxation, broken straps, and strap edge indications..The interim report also described the approach to the resolution of the problems. A final report was received on December 21, 1981 which described the deficiencies, an analysis of the safety implications, and corrective actions taken.
Following the licensee's submittal of an interim report the NRC received unsolicited comments on the stiff clamp design from an interested consulting engineer.
Certain of these comments were considered to be particularly relevant and were addressed to the licensee for resolution. The licensee's response to these comments were included in the final report.
Regional inspection efforts on this 50.55(e) construction deficiency included a detailed review of licensee's final report focused on the
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-4-materials and metallurgy involved, pipe support design and pipe wall stress, and examination of the defective clamps and failure mechanism. The results of this inspection are presented below. Unresolved issues not addressed in this report include the acceptability of rivets in ASME Section III, NF components (Unresolved Item 50-508/509/81-02/09); clarification of the actual materials, design method, and change controls used by Grinnell (Unresolved Item 50-508/509/81-04/01); and clarification of the effects on the rivets changing the heat treating sequence (Unresolved Item 50-508/81-04/02).
b.
Design Characteristics The licensee's technical specification for pipe supports requires that clamps used as non-integral attachments to piping in a snubber / strut assembly shall have, as a minimum, a spring rate greater than five times the spring rate of the snubbing device.
In response to this requirement ITT-Grinnell designed the Figure 215 Stiff Clamp. The stiff clamp consists of two ferritic stainless steel bands with riveted loops at each end.
One end of the straps is attached by pins to a yoke assembly which bears against the pipe wall. The other end of the straps is attached to tie rod assemblies which are torqued to tighten the straps to obtain the required stiffness.
The initially identified problems of torque relaxation and bending of the tie rods were corrected by modifying the design.
Requalification testing on the aew design was performed to ensure that the changes would act affect the overall design integrity and that the required stiffness characteristics would be met. The requalification test results were examined by the inspector and found to be acceptable.
c.
Resolutiion of Identified Deficiencies The problem of_ strap failures'during shop and site testing was attributed to the original, design.. Load. qualification tests performed on the modified design have resulted in no strap
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failures at the required design load. The design modifications have resulted in lower torque values and a corresponding increase in safety margin between~the required installation torque and the failure torque.
Edge indications in line with the strap holes have been determined to result from cold working of rivet holes.
Certain of the strap rivet holes were produced by the cold working processes of punching followed by a " coined" countersink.
Coining is accomplished by cold impact which moves the material from the countersink area and displaces it outwardly.
The resulting bulge of material at the edge of the straps and subsequent
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-5-edge conditioning was judged to be the source of the edge indications.
Ebasco representatives stated that the edge indications have no' apparent effect on the overall strength or integrity of the straps and that full rated load was attained on tests of four (4) straps. with edge indications.
Straps with visible edge indications, however, will be rejected.
d.
Evaluation of Licensee Submittal The inspectors reviewed data on the stiff clamp materials against the ASME Code Subsection NF requirements.
Strap material was purchased to ASTM-A693 GR.630 in the annealed condition.
ITT-Grinnell performed age hardening operations and recertified the material to SA-564 GR.630 in the H1075 condition.
ITT-Grinnell has taken the position that as a manufacturer,.they can begin with ASME material and recertify the material as a result of the manufacturing processes or procedures as_long as the chemical and mechanical properties reflect ASME material properties following manufacturing.
Ebasco has requested ITT-Grinnell to furnish a code case or interpretation to support this position. This code case will
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be examined with Unresolved Item 50-508/509/81-04/01.
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Thisinspectornotedthattheheattreatmentstrigcharts indicate age hardening at slightly les.s than 1050 F whereag o
the H1075 condition requires heat treatment at 1075 F 115 F for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensee was requested to justify this deviation from specification requirements. This item will be examined with Unresolved Item 50-508/509/81-04/01.
The rivet material specified on ITT-Grinnell design drawings was SA 453 Grade 660. The material received had been annealed and heat treated in accordance with National Aerospace Specifi-cation NAS-1199. Neither the licensee nor Ebasco could explain ITT-Grinnell's deviation from the design drawing.
The NAS material supplied differed from the SA.453 GR660 material in that it was received in the annealed condition and then heat treated in accordance with NAS-1199 requirements.
Corrective action for these deviations from ASME Code material requirements is to submit code cases describing the treatments performed. These
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code areas will be examined with Unresolved Item 50-508/509/81-04/01.
From a pipe support view point, the intent of the stiff clamp is to provide a pipe clamp which will have a low deflection under load.
ITT-Grinnell Load Capacity Data Sheets for the Figure 215 stiff clamp show the following maximum faulted load capacity and spring rate for a given frame size:
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Frame Size Maximum Load (lbs.)
Sprino Rate (lbs./in)
1 11520.
3.25 X 10
11520.
3.25 X 105
11520.
3.25Xlg
26700.
1.0 X 106
26700.
1.0 X 106
26700.
1.0 X 10 The high sprin'g rate for the stiff clamp is achieved by preloading the stiff clamp straps.to a stress level higher than the stress that will develop in the straps due to any pipe reaction load. Therefore, no pipe lift-off from the stiff clamp frame will occur.
It is apparent that any significant amount of relaxation in the straps, strap pins, trunnions, tie rods or frame will reduce the load at which pipe lift-off will occur and therefore lower the spring rate.
The necessary preload force for the stiff clamp design stiffness will apply an intermediate radial load upon the pipe wall. An additional amount of radial load will be applied to the pipe wall when a stiff clamp is used to support stainless steel pipe, due to the difference in the coefficient of thermal expansion of the strap material used in the stiff clamp and the coefficient of thermal expansion of stainless steel. The coefficient of thermal expansion for the strap material,whichisaferriticstaingessstegl,isapproximatelyequal to that of carbon steel (7.33 X 10-in/in/F)6andisgomewhat lower than that of stainless steel (9.87 X 10 in/in/ F). This difference in coefficients will yield an additional load on the pipe wall due to more rapid growth of stainless steel pipe than the stiff clamp straps as the piping system heats up from ambient temperature. The thermal growth effect will also produce an intermediate radial load in addition to the preload force.
These loads, however, do not produce uniform membrane stress within the pipe wall along the circumference due to changes in the stiff clamp-to-pipe contact area. The stiff clamp straps are approximately one and one half (1 1/2") inches wide and conform to the pipe surface for approximately two thirds (2/3) the pipe circumference.
The remaining surface is contacted by the stiff clamp frame which is approximately one quarter (1/4") inch wide for frame sizes 1, 2 and 3 and one half (1/2") inch wide for frame sizes 4, 5 and 6.
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So two thirds (2/3) the circumference of the pipe wall is contacted by a strap which is wide and conforms to the pipe wall.
The remaining one third (1/3) of the pipe wall circumference is contacted by a steel plate one quarter (1/4") or.one half (1/2")
inch wide which does not mold to the pipe wall surface and is not machined to match the pipe wall surface and may achieve only "line" contact with the pipe wall. Also, one frame size accommodates several different pipe diameters. Therefore, the circumference of the pipe wall in. contact with the frame changes as a function of pipe diamete.
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-7-From the above stated observations, a calculation was made to determine the membrane stress within the pipe wall for the local area in contact with the stiff clamp frame. The assumed load was due to thermal growth plus preload. A resultant force of 26700 lbs. was calculated acting on the pipe wall in contact with the frame. Assumptions included a frame size #2 supporting an eight (8") inch stainless steel (TP304) schedule 40 pipe.
Equations for membrane stress were taken from tables 30 and 31 of Formulas for Stress and Strain by Roack and Young. Results, from the above stated problem, yielded membrane stress approaching twice the value of the design stress intensity value, which appears to leave little margin for any additional stresses in the pipe due to other piping reaction loads.
The above calculation is understood to contain several assumptions and simplified methods which yield conservative results.
Assumptions are:
line contact with frame, no radial deformation and asymmetric loading.
ITT-Grinnell is in the process of performing membrane stress calculations, however, the inspector's concern is that even with a rigorous analysis such as an ANSYS approach, membrane stress caused by the stiff clamp frame / pipe wall interaction will leave little, if any margin for additional stresses in the piping element.
Any additional stresses would appear to.make it difficult to remain within code allowable limits.
e.
Conclusions The stiff clamp redesign, in conjunction with successful resolution of ASME code acceptability issues and resolution of the membrane stress issue may render the Figure 215 stiff clamp an acceptable component. The inspectors remain concerned over the ability of the stiff clamp to function effectively for the 40 year design life
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of the plant. These concerns stem from (1) the initial design difficulties which indicate inadequacies in the original design development and testing program; (2) deviations from ASME Code material specifications without any apparent recognition by ITT-Grinnell of the' need to request code cases; (3) the high strap tension values required to achieve the design stiffness factor; (4) the possibility that other mechanisms not considered, such as creep or stress corrosion, could effect the continued operability of the straps; and (5) the need for finite element analysis techniques to evaluate the membrane stress levels induced by the strap and yoke assemblies. The regional staff has requested additional review of This 50.55(e)y the Office of Nuclear Reactor Regulation (NRR).
this design b item will remain open pending the additional review and resolution of the regional concerns expressed elsewhere in this paragraph.
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Containment (Steel Structures and Suoports) - Contract 265 a.
Review of Ouality Assurance Implementing Procedures The inspector reviewed the following work procedures associated with structural steel erection and installation of the upper structures for the steam generator keys and snubbers. The
procedures were reviewed against the requirements of the PSAR, the AISC manual of steel construction, the AWS structural welding code, and appropriate ANSI standards.
Procedure No.
Title WE-SITP-102, Rev. 3 Site inspection and Test Procedure for Welding Inspection WE-SP-107, Rev. 4 Special Process Procedure for Stud Welding WE-WP-18, Rev. 2 Construction Work Procedure for Lift and Installation of D-Ring Upper Stream Generator Supports
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WE-WP-ll, Rev. 3 Construction Work Procedure for Weld Filler Metal Control WE-WP-4, Rev. 3 Handling, Storage and Erecting Structural Steel The inspector noted that procedure No. WE-WP-4, Revision 3 did not contain minimum bolt tension values for SA-193 Grade B7 bolts which are being used on field splice connections on the steam generator upper support steel. The contractor immediately issued an interm procedure change notice to include the tension values being used.
No items of. noncompliance or deviations were identified.
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Observation of Work and Work Activities
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The inspector observed the following work activities on the
south upper' structure for the steam generator keys and snubbers:
turn-of-the-nut tightenin~g of SA-193. field splice connections, stud weld process qualification, replacement of studs removed to
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enable installation of the structure, bend testing of studs, and
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random examination of the shop fabricated portion of the structure against shop' drawings for member size and location, weld
size, shape.and location, stud weld quality and location.
No items of noncompliance or deviations were identified.
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-9-The inspector observed modification of reactor building column base and cap plates in accordance with nonconformance report
No. 265-3352 to allow columns to fit mislocated anchor bolts.
Columns are being modified by either (1) slotting existing holes and adding a new cap plate or (2) slotting existing holes and applying weld buildup opposite the direction of slotting. The inspector examined these modifications for weld sizes, configurations, and edge distances specified in the nonconformance report and examined the process control sheets for adequate control and quality verification hold points.
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No items of noncompliance or deviations were identified.
6.
Management Meeting The inspector met with the licensee and management personnel denoted in paragraph 1 at tne conclusion of the inspection on January 15, 1982.
The inspector discussed the scope and findings of the inspection. The findings were acknowledged by the licensee.
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