ML17194A121
| ML17194A121 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 08/20/1981 |
| From: | Brickley R, Danielson D, Fair J, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17194A119 | List: |
| References | |
| 50-237-81-21, 50-249-81-15, 50-254-81-16, 50-265-81-16, 81-237-81-21, IEB-79-14, NUDOCS 8109040157 | |
| Download: ML17194A121 (11) | |
See also: IR 05000237/1981021
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III*
Reports No. 50-237/81-21; 50-249/81-15;
50-254/81-16; 50-265/81-16
Docket Nos.
50~237; 50-249;
50-254; '50-265.
Licensee:
Commonwealth Edison Company
P . 0. * Box 7 6 7
Chicago, IL
60690
Facility Name:
Dresden Station, Units 2 and 3
Quad-Cities Station, Units l and 2 *
Inspection At:
Nutlear Technology, Inc., San Jose, CA (Nutech)
EDS Nuclear Inc._, San Francisco, CA (EDS)
Inspection Conducted:
July 6~7~ 1981 *at Nutech
July 8-9, 1981 at EDS
Inspectors: L. T.Yin I~
f
~~
~
fvJ. R. Fair
Accompanying Persoruiel:
D. H. Danielson
Approved By:
D. H. Danielson, Chief
Materials & Processes Section
Inspection Summary
t/Jir1
inspection on July 6-.9, 1981 (Reports No. 50-237/81-21; 50-249/81-15;
50-254/81-16; 50~265/81~16
.
Areas Inspected:
Licensee actions relative to IE Bulletin No. 79-14 including
general discussions on NRC requirements, work procedure review and review of
analysis and calculations; review of analysis for Mark I torus LPCI modifica-
tion at Dresden.
The inspection involved 72 inspector-hours at the A-E's
offices by three NRC inspectors.
8109040157 810824
i !
l, ~DR ADOCK 05000~&~
__ !
Results:
Of the areas inspected, one apparent violation was identified
(EDS IEB 79-14 procedures did nbt reflect the latest evaluation criteria
Paragraph 2.b) .
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DETAILS
Persons Contacted
Inspection Conducted_ at Nuclear Technology Inc. (Nutech) on July 6-7,_ 1981
Nu tech
R. K. Keever, President
- N. W. Edwards, Vice President, Engineering
- A. B. Higgl.nbotham, General Manager
- T. N. Vogel, Project Director
- L. V. Sobon, General Manager, Projects
- B. J. Whiteway, Project DI.rector
- W. V. Weber, .Engineering Manager
J. Arterburn, Engineering Manager
- T. J. Victorine, Project Manag~r
G. Wiederstein, Project Engineer
- W. S. Gibbons, .QA Administrator
- J. E. Bonner, QA Specialist
- D. A. Hignite, QA Engineer
U. Potapovs, Chief, Vendor Inspection Branch, RIV
- D. H. Danielson, Chief, Materials and Processes Section, RIII
- J. R. Fair, Senior Mechanical Engineer, IE:HQ
- R. H. Brickley, _Contractor Inspector, RIV
- I. T. Yin, Reactor Inspector, -RIII
-*Denotes those attending the exit interview on July 7, 1981
Inspection Conducted at EDS Nuclear, Inc. (EDS) on July 8-9, 1981
EDS
- B. F. Phipps,* Corporate QA Manager
- T. C. Chen, Regional QA.Manager
- M. J. Scholtens, Manager - Project Managemeht
- B. M. Torsen, Manager, Administration
- G. C. Slagis, Manager, Engineering Di~ision
- R. A. Ayres, Section Manager
- R. A. Hobgood, Western Region QA Manager
- R. A. Fortney, Vice President and'Mana~er
- S. M. Jaffer, Section Manager
- W. F. Tschudi, Section Manager
K. Wong, Assistant Project Manager
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Commonwealth Edison Company (CECO)
M. C. Strait, Engineer
- R. H.
- J. R.
- L T.
- D. H.
Brickley, Conttactor Inspect6r, RIV
Fair, Senior Mechanical Engineer, IE:HQ
Yin, Reactor Inspector, RIII
Danielson, Section Chief, RIII
- Denotes those attending the exit interview on July 9, 1981
Functional or Program Areas Inspected
1.
Inspection at Nutech on Juiy 6-7, 1981 Involing Mark I Torus LPCI
Modification
The inspector reviewed the supporting analyses for the Mark I torus
LPCI modification at Dresden. * This modification consisted -0f an
extension of the LPCI discharge line piping from the ~riginal posi-
tion. above the pool surface to a new position below the pool sur-
face.
A preliminary design had shown lateral supports added to this
line with a subsequent design showing these suppor.ts deleted.
The following.documents were reviewed:
.a.
Letter dated April 23, 1981 from R. F. Petrokes to E. R. Zebus
summarizing the resul,ts at the LPCI analysis .. *
..
b.
Suppression chamber*internal piping fabrication and irrstallation
details; 64.313.0802, 2 sheets., Revision 2, dated Mai;ch 23., 1981,
"LPCI Full Flow Test 'Lines".*
. c.
Computer analysis model and output for the LPCI system inside
the torus;
Subsequent to the review, *the inspector determined that the analysis
is a preliminary analysis to support the recent modification to the
LPCI line inside the toru*s.
The analysis considered the original
seismic design loading condition as well as the newly developed
loading from the Mark I Long Term Program.
The stresses were within
the allowables defined for the Mark I Long Term Program.
This analysis was adequate to support the recent modification inside
the torus for the LPCI discharge line; however, the develbpiilent of
the Mark l Long Term Program loading conditions as well as the torus
structural modeling techniques are subject to final .review and approval
by the NRC when the Dresden Plant Unique Analysis for the Mark I
program is submitted for review.
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2.
Inspection at EDS onJuly 8-9, 1982
a.
.Blume Curve Implementation
The inspector reviewed the EDS procedures for implementing the Blume
Curve Criteria for the IE Bulletin 79-14 evaluation at Dresden 2 & 3
and Quad-Cities 1 & 2.
In review of Project Instructibns 5.0, "Eng-
ineering Criteria/Procedure for the Application of the Blume Curves
Criteria, Revi~iori. 4 and Revision 5, where Bectibn 4.1.1 states that
all spans bet.ween horizontal restraints should meet the rigid span
criteria.
EDS revised Project Instruction 5.0 at the time of the
inspection to*provide a table identifying the maximum span allowed
for each size pipe to meet the rigid sp.ari. criteria. ,EDS further
verified that only four piping runs thus far had been'considered
rigid in accordance with the Blume Criteria and these four runs
were checked for compliance with table presented in the Revision 5
to Project Instructi6n 5.0
The four piping runs were identified to be D2-HDSP-02B, Ql-MS-02B,
Ql:..RHRS-12B, and Ql-SLC-1.0*P.
Further review of these systems was
planned.
This is an unresolved item (237/81-21-01; 249/81-15-01;
254/81-16-01; 265/81-16-01).
b.
Review of EDS IEB-:79-14 Procedures
The inspector reviewed the subject technical Project Instructions
and had the following findings:
Title 1.0 "Engineering Criteria/Procedure for the Review and Resolu-
tion of As-Built Deviations",.Revision 3, dated August 1, 1980.
"Para. 2.0 Definitions"
"6.
Operability Limit - The .stress limit of 0.5 ultimate tensile
strength is considered the stress level at which operability is
no longer justified for operating basis loading conditions."
The operability limit stated in the procedure was, not in accordance
with the NRC criteria of 2.0 Sy for D~E conditions.
Title 2.0 "Administrative Procedure for Processing Bechtel Piping
Walkdown Packages Through Operability Assessment, 0 Revision 2,
dated March 7, 1980.
No adverse comment.
Title 4.0 "Review of As..:Built Package for Potential Nonconformances",
Revision 1, dated March 7, 1980.
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"Paragraph 4.2 Blume Piping."
"For piping that was qualified under the Blume Criteria, the initial
review shall consist of checking the seismic spans of piping.
The
tolerance specified in the Deviation Criteria mentioned in 4.1 is
also applicable for the Blume piping.
For example, the as-built
seismic spans can differ from the Blume Curve spans by the toler-
ances specified in the Deviation Criteria. ,'Pip:lng spans. which
exceed the above require!Ilents shall be identified as pbtential
nontohformances.
the inspector stated th~t the Deviation Criteria is not appli~able
to Blume Curv~ rigid sys tern design crite_ria.
Title 5.0 "Engineering Criteria/Procedure for the Application of the
Blume Curves Criteria", Revision 4,* dated June 6, 1981.
"Para. 4.1.1 Horizontal Direction"
"All spans should meet the rigid span criteria.
Do*not support
the piping in the flexible range."
The inspector found that 611 and 8" pipe curves were not generated for
Dresden 2 and 3.
EDS corrected the situation prior to the comple-
tion of the inspection.
Tables with specific.maximum spans based on
.Blume Curve criteria were established for Dresden 2 & 3, and Quad*
Cities 1 and 2.
Title 6. 0, "Proc.edure for the Computer Reanalysis of Piping, Revision
2, dated October 9, 1980.
No adverse comment.
Title 8. 0 "Pipe Support Engineering Criteria/Procedure for the
Review and Resolution of As-Built Deviations", Revision 2, dated
April 10, 1980.
.
"Para. 2.0 Definitions"
"(6) Operability Limit - The stress limit of 0.5 ultimate tensile
strength is considered the stress level at which operability is no
longer justified for operating basis loading conditions."
"Para. 6.2 Operability Assessment by Analytical Evaluation"
"(2) ... "Detailed evaluations will be required for all portions
of the support design uriless that design is for qualified Blume
Curve piping.
Detailed evaluations are not intended to provide
complete calculated qualification of supports."
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The inspector stated that the operability criteria stated in Para-
graph 2.0(6) was not in accordance with the NRC requirement of 2.0
Sy at DBE c.onditions, and that the intent of Paragraph 6. 2. (2) was
unclear.
Title 10.0 "Thermal Criteria for Blume Piping", Revision 2, dated
October 28, 1980.
No adverse comment.
Title 13.0 "Blume Curve Isometric Procedure", Revision O, 6/12/80.
No adverse comment .
. Title 17.0 "Procedure for Requesting Non-Seismic Piping Information",
Revision 1, September 11, 1980.
No adverse comment ..
Title 2 i. 0 "Procedure for Initial Acceptance Criteria of Piping
Systems", Revision O, dated May 7, 1981.
"Para. 2.3 Nonlinear Analysis".
"Refinements to the above analysis methods will be made on a case
by case basis to include nonlinear effects of the piping system due
to strain handling".
"Para. 3.0 Limits of Stress for tnitial Acceptance Criteria.
A less
stringent criteria can be adopted for stainless steel piping on
a case-by-case basis:
<TfsE + ~+uP*~ 2 .. 2oY
~SE +if&~ 2.0.(ff'
.The inspector stated tha.t the nonlinear analysis had not been
concurred with by the NRC, and the stress limit for stainless
steel pipe was not considered to be acceptable.
This was based
on discussions during previous NRC and licensee meetings."
Title 24.0
"Overlap Procedure for Piping Stress Analysis",
Revision O, -October 3, 1980.
No adverse comment.
Title 26.0
"CECO Nonlinear Pipe Analysis", Revision O, dated
October 24, 1980.
No adverse comment.
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Title 27.0
"Procedure for Checking Reanalyzed Problems", Revision
0, dated December 1, 1980.
"Blume Curve Piping Analysis .Check List."
5.
Have the spans been determined to be rigid, .resonant or flexible?
6.
For flexible spans, ha~ the elevation been consideredT'
The inspettor stated that only Blume Curve rigid span criteria were
considered to be acceptable by the NRC.
Title 28.0, "General Pipe Support Design Engineering Procedures",
Revision O, dated January 21, 1981.
No adverse comment ..
Title 29.0, Procedure for Hand Calculation of Pipe Seismic Stresses
and Support Loads by the Equivalent Static Method", Revision 1, dated
April 6, 1980 ..
No adverse comment.
Subsequent to*the review, the inspector concluded that the proce-
dures contained conflicting requiremen:ts.
The operability criteria
for the evaluation of the installed suspension system component were
not *in accordance with the NRG requirements.
This is an apparent
viOlation identified in Appendix A.
(237/81-21-02; 249/81-15-02;
254/81-16~02; 265/81-16-02).
c.
CRD Design and Analysis
The inspector reviewed the following operability analysis for the
CRD insert and withdrawal lines at Dresden Unit *2 and Quad-Cities
Units 1 and 2:
Calculation Problem 09, "CRDHS Operability Study".
Calculation .Problem Z-001, "Lbad Deflection Data_ for CRDHS
Frames".
Calculation Problem F-103, "Dresden Unit 2 Outside Drywall
Support Qualification".
Drawing No. H-13, Sheet 1 & 2, Revision A, SKB-2-1000-6.
Drawing No. H-14, Sheet 1.£.2, Revision A, SKB-2-1000-7.
Drawing No. DCN #DZ-025, Sheet 3.f.7.
The purpose of the review was to determine whether or not the
licensee had implemented the following NRC meeting conclusions.
Meeting Summary of June 12, 1981 meeting with CECO t-0 discuss
CRD System Reanalysis Criteria, dated June 25, 1981.
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<
'
I
Meeting Summary Of June 30, 1981 meeting with CECO to discuss
results of the operability evaluation for the CRD System.
Subsequent to the review, the inspector concluded.that the CRD
System Operability analysis for Dresde.n 2 a:nd Quali-Cit~es 1 & 2 was
in accordance with the analytical techniques and criteria permitted
in the June 12, and June 30, 1981 meetings between CECO and the NRC.
The acceptability of these supports where the operability criteria
for support stresses (less than yield stress) is exceeded is contin-
_ gent on CECO providing an acceptable schedule for modification of
these supports to within the original operability criteria.
This
schedule for support modifications for Dresden Units 2 & 3 and
Quad .. cities Units 1 & 2 should be provided to Region III by the
middle of August, 1981.
d.
Follow up on Previously Identified Issues
A number of questionable !EB 79-14 evaluation methods were identi-
fied during. a* RIII inspection at EDS in February, 1980 (RIII
Inspection Reports No. 50-237/80-05; 50-249/80-05; 50-254/80-05;
and 50-265/80..,08) and in June, 1980 (RIII Inspection Reports
No.
50-237/~0-10; 50-249/80-14; 50-254/80-14; .arid. 50-265/80-17).
These questionable design issues were discussed and reviewed by
the inspector during this inspection.
The followings is status
of resolution:
(1)
The EDS evaluation was limited to those deficiencies and devia-
tions identified during field veri£ication inspections although
the criteria of evaluation had been upgraded from the original
design considerations.
EDS committed to check restraint lo-
cations to assure pipe spans are within the rigid sides of
the response spectrum curves.
It .is anticipated that EDS will
evaluate the adequacy of the original seismic an;;ilysis and
restraint design for the Dresden.2 & 3 and Quad-Cities 1 ~ 2
systems in light of the apparent lack of instructions avail-
able for the original analyses and designs on how to use the
.Blume Curves.
This item was reviewed.
The findings are documented in Para-
graph 2.a, and 2~b of this report.
(2)
Because of defective restraints identified in the Standby Gas
System 7509-24" line, EDS was requested to re-evaluate all
previous operability evaluations to assure compliance with NRc*
criteria.
For example, EDS calculation No. Ql-HPCI-OIC, dated
June 16, 1980, apparently used the wrong earthquake condition
in the evaluatiori.
The matter including EDS Calculation No.
Ql~HPCI-OlC was
ieviewed by the inspector.
The piping stress analysis sho~s
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-..
that the system is within the current operability stress
limit for the SSE of .2. o Sy.
(3)
Regarding EDS Calculation No. DS-LPCI-03C, Revision O, ques-
tionable methods were used in selecting the horizontal stati~
seismic coefficient to be used in the calculation.
It was stated by the licensee that the center of gravity method
was the original.method used by S&L.
This item is not considered
- to be within the scope of IEB 79-14.
(4)
Safety relief valve discharge forces do not appear to have
been considered in conjunction with the seismic loads.
The
specifiC case involved line No. Ql-RHRS-4858 B-4 and valve
No. RV-1-1001-165B.
The inspector reviewed EDS package Ql"".RHRS-09B to evaluate
safety or relief valve loading conditions.
EDS is following
the original analysis techniques for safety or relief valve
discharge events.
If these events were not part of the original
analysis,.EDS is not generating new loads.
CECO committed to
look into the necessity of generating safety or relief valve
loads if they were not part of the original analysis.
They
will advise RIII of how these loadings will be handled.
This is an unresolved item (237/81-21-03; 249/81-15-03;
254/81-16-03; 265/81-16-03).
(5)
Stress intensification factors are apparently.not being consi-
dered in the system evaluations based .on the Blume Curve design.
Since the licensee has committed to use only the rigid span
criteria of the Blume Curve, this matter is resolved.
(6)
Using the Blume Curves, Quad-Cities piping above elevation
579 ft. used a factor of three to account for amplification
in determining restraint loads.
The conservation of the
factor *of three is questionable.
The CECO document, "Unresolved Items From Previous NRC Audits
of EDS Nuclear" dated January 26, 1981 was forwarded to RIII
.through a CECO letter, dated March 12, 1981.
Relative to the
subject matter, it was stated that, "the factor of 3 is used
in the cookbook approach to piping design to allow for amplified
responses of flexible piping systems at building elevations Bbove
ground level.
This factor is applied to the hanger design load
and seismic deflection.
The span length is not effected, there-
fore, the first model frequencies should remain in the flexible
range." Further review of this area is planned as a result o.f
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.
.. ..
the licensee committing to use the rigid span criteria.
This
is an unresolved .item (237 /81-21-04; 249/81-:-15-04; 254/81-16-04;
265/8i-16-04).
e.
Review of EDS Control of Project Instructions (Pis)
During personnel interview with EDS IEB 79-14 evaluation task
personnel, the inspector found that all the engineers within the
Structural Design Section maintained a copy of controlled Pis,
but this was not required by the engineers within the Piping
Analysis Section, and one out of date PI was identified. It
was stated by the EDS Regional QA Manager that the Pis are
controlled by the Project Engineers (PEs), and the distribution
of Pis are determined by the PEs.
The present EDS QAP 3.9,
"Procedures and Instructions", Revision 3, dated March 7,. 1980,
relative to the Generic Technical _Procedure (GTP), states, "The
respbnsible divisibn shall establish a distribution list for the
procedure manuals issued for use, to ensure that designated
recipients have the current manual issue." Since the Pls are not
considered GTPs, the control was not being applied uniformly.
During the management exit meeting, EDS committed to revise QAP3.9
to include the Pis as a part of the company GTPs and a distribution
list will.be developed for better control.
This .is an unresolved
item (237/81~21~05; 249/81-15-05; 254/81~16~05; 265/81-16-05).
Unresolved Items
Unresolved items are matters about which more information is required in order
to ascertain whether they are acceptable items, items of noncompliance, or
deviations.
Four unresolved items disclosed during the inspection are dis-
cussed in Paragraphs 2.a, 2.d.(4), 2.d.(6), and 2.e.
Exit Interview
The inspector met with licensee representatives at the conclusion of the
inspection.
The inspector sumniarized the scope and findings-of the inspection~
The licensee acknowledged the*findings*:r;eported herein.
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