ML19208A043
| ML19208A043 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/12/1979 |
| From: | Fiorelli G, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19208A039 | List: |
| References | |
| 50-373-79-24, 50-374-79-17, NUDOCS 7909120452 | |
| Download: ML19208A043 (8) | |
See also: IR 05000373/1979024
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U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-373/79-24; 50-374/79-17
Docket No. 50-375; 50-374
License No. CPPR-99; CPPR-100
Licensee: Commonwealth Edison Company (CECO)
P. O. Box 767
Chicago, Illinois 60690
Facility Name: La Salle County Station, Units 1 and 2
Inspection At: La Salle Site, Marseilles, Illinois, and
Corporation Of fices , Chicago, Illinois
Inspection Conducted: May 30 and 31, and June 4, 1979
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Inspector:
C. C.
illiams To
7/11/77.
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Approved by:
G. Fiorelli, Chief
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Reactor Construction and
Engineering Support Branch
Investigation Sumary
Investigation on May 30-31, and June 4, 1979, (Report No. 50-373/79-24;
50-374/79-17)
Areas Investigated:
Investigation conducted in response to anonymous
allegction that ASME required data reports misrepresented the status of
certified stress analysis reports for piping systems.
Investigation
involved review of procedures, records, discussion with licensee and
contracted personnel relative to establishment of Far= No. N-5 data
reports for field installation of Nuclear power plant components and
appurtenances.
This investigation involved a total of 11 inspector hours
on site by one inspector.
Results: The allegation is considered confirmed in that a feedwater
piping subassembly N-5 data report documented the existence of a Certified
Stress Analysis Report, when in fact, certification of the stress report
did not exist. One item of noncompliance was identified.
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DETAILS
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Principal Persons Contacted
Site (May 30 and 31, 1979)
T. E. Quaka, Site Quality Assurance Supervisor (Ceco)
B. J. McAndrew, Station Construction (CECO)
R. C. Schulz, Quality Control Supervisor (Morr? son Construction Company)
S. Damle, Quality Assurance Manager (Morrison Construction Company)
A. Pathak, Authorized Inspector (Continental Insurance Company)
Corporate Offices (June 4,1979)
- E. J. Hemty, Senior Staff Engineer (CECO)
- R. L. Scott, Principle Engineer (Ceco)
- T. Watts, Project Engineer (CECO)
- Denotes those present at exit interview on June 4, 1979.
NOTE:
On June 5, 1979, W. J. Shewski, CECO Quality Assurance Manager was
contacted by telecon regarding this issue.
1.
Alleged Misrepresentation of Feedwater Piping System ASME N-5 Data Form
On May 22, 1979, NRC:RIII received an anonymous allegation which
stated in context that Commonwealth Edison Company had knowingly
issued a false certification for the Unit 1 feedwater piping subassembly.
The alleged falsification was manifested as follows:
The applicable ASME code requires the establishment of an "N-5"
a.
data report for the feedwater piping subassembly.
(ASME Section
III, Division 1, 1974 edition, NA 8416).
b.
The feedwater system "N-5" report certified by Commonwealth
Edison on March 14, 1979, under Certificate of Authorization
No. N-2020, certifies the existance of a Certified Stress
Analysis Report; as provided by the Architect Engineer (Sargent
and Lundy (S&L)) and certified by their (S&L) Agent R. J. Mazza
(Engineering Registration No. 62-21850).
The allegation stated that the above referenced Certified
c.
Stress Analysis Report does not exist. Moreover, the alleger
contends in context that CECO was aware of this om/ission prior
to certifying the status of the feedwater stress report.
2.
In response to the above allegation NRC:RIII initiated ao investigation
at the La Salle site on May 30 and finished this portion of the
investigation on June 4,1979, at the Ceco Corporate offices.
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3.
In summary, it was established by the inspector and confirmed by
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CECO Corporate office personnel (identified in the persons contacted
section of this report) that the allegatien is substantive in that
on June 4, 1979, it was concluded that a Certified Stress Analysis
Report for the La Salle Unit I feedwater piping subassembly had not
been established by their Architect Engineer, Sargent and Lundy.
Conclusive determination relative to the licensee's knowledge of the
uncertified status of the required stress report prior to certifying
it's existence on March 14, 1979, has not been established as yet.
This vatter will be the subject of a subsequent investigation.
4.
At the close of this portion of the investigation on June 4, 1979,
the licensee's representatives made the following corrective action
coccitments :
a.
Initiate inauiry with the ASME Boiler and Pressure vessel code
relative to ambiguities in the licensee's understandios of the
applicability of N-5 data form requirements for piping subassemblies.
b.
Stop-work ra #,ive to processing piping subassembly N-5 data
reports until further ASME code clarification is reached and/or
certified stress reports are completed, as required.
Stop any work on piping subassemblies wherein the existence of
c.
a conforming N-5 data report is a prerequisite,
d.
Verify the accuracy of all existing N-5 data reports.
(NOTE:
Not more than six (6) N-5 data reports had been issued at the
time of this investigation.)
5.
The Summary in paragraphs 3 and 4 above is based on the following
investigation activities at the plant site and discussions at the
Ceco Corporate offices (Chicago).
The inspector examined the scheme being developed by the Morrison
a.
Construction Company (piping installer) for controlling and
documenting ASME Code data reports. This system is presently
described by flow charts and is under development. The installer's
authorized inspection agency and the licensee are participating
in its development. Documented procedures fully reflecting
this process have not been developed as yet. This matter is
considered unresolved and will be examined during subsequent
inspections (373/79-24-01; 373/79-17-01).
b.
The inspector examined four ASME Code required N-$., data reports
on piping systems identified as follows:
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(1) Reactor Recirculation, Unit 1
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(2) Feedwater, Unit 1
(Note: N-5 Data Report Attached as
Exhibit A)
(3) Condensate Storage, Unit 1
(4) Reactor Building, Closed Cooling Water, Unit 1
The above N-5 data forms were in various stages of completion.
None were complete.
c.
The inspector examined the details of the Unit I feedwater
system N-5 data report.
In response to questioning, the Morrison
Company representative indicated that be signed this N-5 data
report although he had no documented assurance that the Feedwater
System Stress Report was complete and certified.
It is understood
that Morrison relies on CECO to verify the veracity of such
statements,
d.
Subsequent to the above activity (c.) the inspector contacted
the CECO Quality Assurance Supervisor relative to the availability
of any information which could be construed as providing documentary
evidence that the feedwater N-5 data report was correct in
reporting the availability of a Certified Stress Analysis
Report for this piping system.
In response to this concern,
the CE Quality Assurance Supervisor directed the inspector to
the CE Field Engineer (B. McAndrew) responsible for surveillance
of piping installation. This principal site engineer indicated
that questions regarding the feedwater system N-5 data report
would be best addressed by the CE Station Nuclear Engineering
Department (SNED).
Subsequent to the above, on May 31, 1979, Mr. R. Scott of
e.
CECO-SNED was contacted by telephone from the plant site.
In
response to questioning he indicated that a Certified Stress
Analysis Report for the feedwater system is not available.
However, he had been assured by the Architect Engineer (Sargent
and Lundy) that sufficient stress data vas available to support
the feedwater piping fabrication and installation. At the
conclusion of this conversation the inspector pointed out that
the feedwater N-5 data report indicates that a Certified Stress
Report was existent, whereas that is not the case. Further
this investigation would continue on Monday June 4, 1979, at
CECO Corporate Offices.
f.
On Monday June 4, 1979, the inspector met with the 1icensee's
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representatives (see Persons Contacted) and discussed the
following:
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The licensee's representative re-confirmed the conclusion that
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a Certified Stress Analysis Report has not been established for
the Unit I feedwater system. Further, these representatives
indicated that CE is not certain of the ASME Code's intent and
purpose in specifying requirements for N-5 data forns for
piping subassemblies, or exactly when such data forms are to be
completed.
The inspector expressed his conclusion that while there may be
some ambiguity in the licensee's understanding of the ASME
Code's requirement for N-5 data reports for piping subassemblies,
failure to identify and document these circumstances to preclude
erroneous certification of the existence of a Certified Stress
Analysis Report for the feedwater system piping subassemblies,
constitutes an item of noncompliance to NRC regulations and
raises serious questions relative to the integrity of the
licensee's certified statements.
In response to these statements, the licensee representative
stated that while some confusion on their part does exist
relative to the implementation of the N-5 data reports this
occurrence was inadvertent and based on their best information
from their Architect Engineer Sargent and Lundy.
This matter will be the subject of further investigation. See
paragraph 4 for interim actions to be taken by the licensee.
6.
As a result of all of the above the following item of noncompliance
was identified:
10 CFR Part 50, Appendix B, Criterion XVI, states in part, that
"Meesures shall be established to assure that conditions adverse to
quality such as .
. deficiencies
. and nonconformances are
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promptly identified and corrected." Further, the CECO topical report
CE-1A dated January, 1976, and CECO QA manual quality requirement
16, commit to the establishment of measures for identification and
corrective action regarding nonconformances.
The applicable CECO Station Nuclear Engineering Department Procedure
No. Q-34 issued December 1, 1977 (". . . method for processing data
report form N-5 . . ."} among other requirements, specifies in
paragraph 3.2.3, that the Project Engineer " Reviews N-5 form with
supporting documents for correctness.
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Contrary to the above, on March 14, 1979, the licensee's representatives
established a Certificate of Compliance (N-5 data repor)) which
indicated that a Certified Stress Analysis Report had been established
by the Architect Engineer (Sargent and Lundy) for Unit 1 Feedwater
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System, whereas, on June 4, 1979, it was confirmed that a Certified
Stress Analysis Report for the Unit 1 Feedwater System has not been
established. The control systems were apparently not implemented.
(373/79-24-02; 374/79-17-02).
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. Unresolved items disclosed daring this investigation are
discussed in paragraph 5.a of this report.
Exit Interview
The inspector met with the CECO corporate representatives (denoted under
persons contacted) at the conclusion of the investigation and also contacted
the CECO QA Manager Mr. W. Shewski. The inspector summarized the purpose
and findings of the investigation. The licensee acknowledged the findings
reported.
Attachment: Exhibit A
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Page 1 of 9
MODIFIED FO2M N-5 REPORT FOR INSTAL!ATION OF NUCLEAR POWER PLANT
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COMPONENTS, COMPONENT $UPPORTS, AND APPURTINANCES*
As Required by the Provisions of the ASMC Code, fection 111, Division 1
1.
Installed by MORRISON CONSTRUCTICN . COMPANY.1834 Summer St..Hommond, Indiana
(Nonic & AdJren of installer of cewponent, component sq9erts, appurtenances)
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2.
Installed for Commonwealth Edison Company, LoSolle Co. Nuclear Sto. ,Seneco, Illinois
(Norne and t ionf Addicu of Pershosat or O.mer)
Commonwealth Edison Company
61360
3.
N Certificate Helder having overall Responsibility 72 West Adams St.,Chicoco, Illinois
60690
(Name ord Addica)
Years
4 System Identification Feedwater - Unit #1
Not'I. Bd. No. N/A
insto!!ed 1975-1979
5.
Nuclear Components and Appurtenances Installed (List each item and ottoch copies of Wnufacturers'
Data Reports and Manufacturers' (Partiol) Dato Reporis).
.(o) Coep.or Appurt.4) Cor p. or Appurf No.{c) Nome of Mfgr.
(d) M'or's.Seiiol %.
&) Nt'l.Bd.Nr.. (f) Year Built
See Index - Page 2
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Pipino Installatien
fa) Piping Subanembly
. b) Nome of Mfgr.
(e) Mfgr.Seric! NcAork %.
(f) Yxt Buitt
See Index - Page 2
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Component Support installation
(o) Comp. Support No,'
y) Nome of Migr.
(c) Mf r.5 rial No/Mork N.
4f) Year Built
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See index - Page 2
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Additiono! Material Excluding Welding M,oterial
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(a) l'em Description @) Mfgr. SerioVMork %. (c) Name of Mfor.
(d)S cir tics &) SpooVlocotton (T) yr. Sviit
See Index - Page 2
6.
(a) Installation in Accordance with
Procedure or Drowing Nos.
Prtpored By
P&lD M-57 Rev. G
Sarnent & Lundv
psi ab Temp. 5750F
$) Hydrostatic Test
3375
psi System Working Pressure 2150
Hydrostatic Test
1563
psi System Working Pressure 1150
psi and Temp. 575 F
Hydrostatic Test \\
/ psi System Working Pressure N
/ pst and Terrp. \\
/
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Hydrostatic Test
\\/
psi System Working Pressure
\\/
pst and Temp.
V
Hydrostatic Test
/\\
ps1 System Working Pressure
/\\
ps! cod Temp.
/\\
Hydrostatic Test /
\\ psi System Working Fressure /
\\ psi and Temp. /
\\
- Supplemental sheet. in foims of lists, sketches, or drawings moy be used provided (1) size is 83 x 11,
p) Information in items I through 4 on this dato report is included on coch sheet, and (3) each sheet
is numbered and the number of sheets is recorded of the top of this form.
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Desi n Specification ceriilled by (i)
R. J. Mazzo
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Rec.No42-2185L
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Stress Analysis Repoit ecrtified by (1) _ % P J Mozza
PE State _ lll.
3ea.No42-2iS5d 1
Design Conditions of Pressuie riping
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2600
psi Temp.
575
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Desion Conditions of Pressurs Piping
B00
psi Temp.
575 0F.
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Desi n Conditions of Pressure Pipino
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2250
psi Temp.
575 of.
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Design Coe,ditions of Pressure Piping N
/ pil Ternp. A
fof.
Design Conditions of Pressure Piping
X
psi Tenv.
X
of.
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Design Conditions of Prenure PipinD [
\\_ psl Temp. /
\\oF.
O) sionature not required. List name enfy.
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CERTIFICATE OF INSTALLATION COMPLIANCE
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We certify t!ct the slotoments mode in this report cre correct and that this Imto!!ation conforms to
the rules of construction of the ASME Code for Nu leor Power Plcnt Components, Sectior, III,
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Division 1,
1974 Edition. AJJend i Date: No Addenda
Code Case No. None
Classes 1,2
and was rerfonned in occc.rdance with
the downente listed in /FoT>ove.
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Our ASME Certificates cf Authorization No.N-1621-Ito use the
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Symtel egires
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Jan. 7, 1980.
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Date 3/06/79
SignedMorrison Construction Co. by
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(cerr;ticore Hoteer)
Quality Control SupeiviMr *
CERTIFICATE OF INSTALLATION INSPECTION
I, the undersigned homing a valid commission issued by the Notic,no! Board of Boiler rad Pres
Vessel inspectors and the State or Province of _ lllinoIS
and errplcyed by
Centine,tel Insumnce Companies
of New York, N.Y.
have in<pected the
imtellation of the items described In this Dota Report on
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and state thct
to the best of rey knewkd;;e end belici, the Ceilir. cote of Aviho/06/,1979 ,
rization Holder has performed this
installotion in accordonce with the ASME Code for Nuclear Power riant Components.
By signing this certificate, neither the Inspector nor his ernployer moke ony worronty, egr
implied, concernini; the installation described in this Datu Report.Furthennore, neither the
inspector nor his ernpleyer sholt be lioble in any menner for ony personal injury or p
or o loss of ony Lind arising from or conr.ccted with thi:
nspection.
Do'e
3/06/ 1979
. Signe .
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missions IL 1 13
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(Not 1. ca. srM,w. r. to L
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CERTIFICITE OF COMPLIANCE
following completion of the cbove, the Certificate of Authorization holder accepting overall
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responsibility for the piping system shall complete the following statement.
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We certify the stotcments. rnode by this report are correct end that the piping system confo:m: to
the rules of the comiruction of the ASME Code Section ill, Division 1.
Certificate of Authorizction Egires f .5 c9/ Certificate of Auth rization No./y- 202O,
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SignedCommonwealth Edison Co. by [ofj,,un7 MuN
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(Cerimcore lloider)
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CERTIFICATE OF INSTECTION U
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I, the undersiDned holding a vo11d pominission issued by the National Board of Boiler and Pressure
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Vessel Irupretors end the State or Province of lIlinois
and employed by
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Hartford Insurance Company of Connecticut
have Irepected the piping system
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described in this Data P.eport on
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and stole that to the best of rny know-
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ledge and belief, the N Certificotc of Authorization Holder hos const.ucted this pipiro system in
accordance with the AStd Code for Nuclear Power Ploi.! Components.
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By si ning this certificate, neither the inspector nor his employer make any warranty, egress or
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implied, conceining the piping system dcreribed in this Data Report. Furthermore, neither th:
Inspector nor his enployer >Ioll be liabic in ony menner >*or ony personal injury or property domoge
or a loss of ony Lind crisisg from or connestcJ with this inspection.
Date
19
Siuned
Comminions
CrycW
(Not'i. ed statetrov. & No.)
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P00RORIGNAl