ML18092B485
| ML18092B485 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/30/1987 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N87051, NUDOCS 8704060457 | |
| Download: ML18092B485 (5) | |
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- Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Vice President -
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Nuclear MAR 3 0- 1987 NLR-N87051 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS.
50-272/87-02~ 50-311/87-02 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the three violations noted in the Notice of Violation dated February 25, lg87 regarding design interface, procedural adequacy and ocument control in the area of piping and pipe supports.
Our esponse to the Notice of Viola~ion is provided in the attachment to this letter.
In addition, the cover letter of Inspection Repor~.. Nos.
50-272/87-02 and 50-311/87-02 requested our assessment of apparent weaknesses in design interface and plant configuration control in the mechanical/structural and electrical areas and of the detail of our review of c6ntractor technical reports.
The requirements for design interface and configuration control are addressed in PSE&G Engineering Methods Procedures.
One of*--
the violations noted in the subject Notiqe of Violation was the result of inadequate application of these procedural guidelines.
In order to augment our efforts to comply with stated design interface and configuration control requirements, an engineering analysis checklist and an engineering interface checklist will be issued which will address the program requirements for each discipline.
These measures will be monitored formally on an interim basis to determine their effectiveness in assuring that design interface and configuration control considerations are adequately addressed.
With regard to the detail of review of contractor technical reports, PSE&G has traditionally selected contractors based upon heir expertise and has relied upon the experience and ualif ications of the contractor to provide assurance that 8704060457 870330 PDR ADOCK 05000272 1fol
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MAR 3 0 1987
~ocument Control Desk specified work has been performed accurately and in accordance with appropriate standards and regulations.
This is particularly pertinent to work done in technical specialty areas in which PSE&G does not retain internal expertise.
Contract reports have been reviewed for acceptability by a manager or engineer within the department which has been assigned sponsorship of the project for which the contract work is being performed.
This review has not normally involved a recheck of calculations but has consisted of an overall review of the quality of the contractor document based on the sponsor engineer's level of knowledge of the technical area and the specification to which the work was performed.
Also, this review function has not been documented in the past.
In response to the stated concern, an Engineering Methods Procedure is to be developed by July 31, 1987 to dictate internal review and documentation requirements for consultant reports and other vendor documents.
Attachment C
Mr. D. c. Fischer Licensing Project Manager Mr. T. J. Kenny Senior Resident Inspector Dr. T. E. Murley Regional Administrator NRC Region I Sincerely,
ATTACHMENT
~BLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION UNIT NOS. 1 AND 2 RESPONSE TO. NOTICE OF VIOLATION A.
Contrary to Criterion III of 10 CFR SO, Appendix B, PSE&G Quality Assurance Manual Procedure QAI 3-1, and Section 7.3 of PSE&G Procedure VPN-QAP-01, "Operational Quality Assurance Program," procedures for implementing design interface measures for two piping and support system modifications completed during the 1986 Salem Unit 2 refueling outage were either non-existent or inadequately specified.
This resulted in the failure to update affected safety related structural as-built configuration records and to evaluate the effects of increased mechanical component support loads on the applicable structures.
RESPONSE
PSE&G does not dispute the violation.
The. apparent inadequacy in addressing design interface considerations for the two piping and support system modifications in question was due tb the lack of clear definition.in existing Engineering Methods Procedures of the design interface review and documentation requirements for this particular interdisciplinary interface.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED B.
The structural impact of the pipe support modifications documented in Design Change Requests (DCR) 2EC-01691, 2EC-01692 and JEC-02236 has been reviewed and it has been confirmed that affected structures are capable of supporting the increased mechanical component loads with an adequate margin of safety.
The Engineering Methods Procedure which addresses pipe supports is being revised to identify the interfaces which must be addres~ed with piping and support system modifications.
This procedure will be issued by July 31, 1987.
Contrary to Criterion V of 10 CFR so., Appendix B and Section 7.S of PSE&G Procedure VPN-QAP-01 "Operational Quality Assurance Program," piping and pipe support design activities were not documented and approved criteria for the.
performance of piping stress analysis were not established.
Also, PSE&G Specification S-C-MBOO-MDS-043 for "Design of
Pipe Supports" required the checking of pipe support displacements and rotations under applied loads without providing acceptance criteria for the evaluation of these parameters.
RESPONSE
PSE&G does not dispute the violation.
This violation was the result of two conditions:
(1) the fact that Engineering Methods Procedures did not provide quantitative acceptance criteria with regard to pipe support displacements and rotations under applied loads and (2) that although a procedure governing the conduct of piping stress analysis was in preparation, it had not yet been formally issued.
PSE&G has traditionally regarded stress analysis as a technical specialty to be conducted by professionals with appropriate qualifications and proven experience in this area.
Recent industry trends have pointed to more rigorous internal documentation of methods used.
At the time of the inspection, our procedure to address this documentation of pipe stress analysis methodologies was under development.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A controlled piping stress analysis procedure will be finalized and issued which will formally document.currently
'uaed pipe stre~s analysis methodologies.
Also, the existing pipe support design procedure is being revised to include quantitative acceptance criteria.
Acceptance criteria for pipe support displacements and rotations under applied loads will be included in this procedure.
Both procedures will be issued for use by July 31, 1987.
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Contrary to Criterion VI of 10 CFR 50, Appendix B and Section 7.6 of PSE&G Procedure VPN-QAP-01, "Operational Quality Assurance Program," instructions governing the mechanical standard for determining load capacities of U-bolts was uncontrolled.
Also, the evaluation of local stresses in piping walls at locations of integral attachments was described in Section 10~4 of the criteria for design of pipe supports (Specification S-C-MBOO-MDS-043) using ASME code cases No. N-392 and N-318-1.
However, the evaluation of local stresses in piping at locations of U-bolt components was described in, and performed, using another document which was uncontrolled.
RESPONSE
PSE&G ~oes not dispute the*violation.
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This violation was a result of the inadvertent referencing 6f a non-controlled document in a controlled procedure (Notice of Violation C.l) and the inadvertent omission of design criteria applicable to U-bolt induced local stresses in the procedure nominally governing pipe support local stress calculations (Notice of Violation C.2).
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A directive has been issued to the Stress Group of the PSE&G Engineering department to control the use of the mechanical standard and pipe local stress evaluation for U-bolts.
The controlled pipe support design procedure is being revised to include (1) the mechanical standard for load capacities of U-bolts and straps and (2) the pipe local stress evaluation criteria for U-bolts.
This procedure will be issued for use by July 31, 1987.