ML19225A084

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Forwards IE Circular 79-11, Design/Const Interface Problem. No Action Required
ML19225A084
Person / Time
Site: Black Fox
Issue date: 06/27/1979
From: Seyfrit K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Lindburg M
PUBLIC SERVICE CO. OF OKLAHOMA
References
NUDOCS 7907180269
Download: ML19225A084 (1)


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UN!TED STATES 1]Q@d y y,'3,([( h NUCLEAR REGULATORY COMMISSION GJ' " -' W - c REGION IV 0, 52h [ <[

611 RYAN PLAZA DRIVE, SUITE 1000 k

ARLINGTON, TE NAS 7G012 9 +....

June 27, 1979 In Reply Refer fo:

RIV Docket Nos.

50-556/lE Circular No. 79-11 50-557/IE Circular No. 79-11 Public Service Company of Okitacma ATTN:

Mr. M. J. Lindburg Vice President, Power Generation Box 201 Tulsa, Oklahu.aa 74102 Cenc.Lemen:

The enclosed Circular 79-11, is forwarded to you for information.

No written response to this Circular is required.

If you require additional information regarding this subject, please contact this office.

Sincerely, 4,44

-l' '

r Karl V. Seyfri Director

Enclosures:

1.

IE Circular No. 79-11 2.

List of IE Circulars Issued in the Last 12 Months 32h

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UNITED STATES NUCLEAR REGUIATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.

20555 IE Circular No. 79-11 Date: June 27, 1979 Page 1 of 2 DESIGN / CONSTRUCTION INTERFACE PROBLEM Description of Circumstances:

Apparent inadequate communication between nuclear steam supply system (N# 1),

architect / engineer (A/E) and constructors have resulted in several case.

where reactor vessels or the supports have been misoriented. The misorienta-tion problems appear to occur at sites where dual reactor units are being constructed and one primary system layout is a mirror image of the other.

In 1975 TVA reported a misorientation problem with the Sequoyah Unit I reactor vessel. Westinghouse was the NSSS supplier and TVA provided their own A/E service.

In 1977 the Southern California Edison Company reported a reactor vessel misorientation at San Onofre Unit 2.

Combustion Engineering was the NSSS supplier and Bechtel provided the A/E service.

In 1979 the Texas 'Jt.lities Generating Company reported a reactor vessel support system misorientation at Comanche Peah Unit 2.

Westinghouse supplied the NSSS, Gibbs and fill was the plant engineer and Brown and Root was the

~ constructor.

Even though there appears to be minimal safety iruplications associated with the particular raisorientation problems mentioned, repetition of the same type of errors suggests breakdowns in the design / construction interface relation-ships that could in turn lead to more significant safety problems.

Corrective preventive action is recommended for the following reasons:

If the interface control systera between the NSSS/AE/ Construction is marginal or ineffective as evidenced by the misorientation of reactor vessels and their supports, it is possib e that other safety related equipment may also be misoriented and/or mislocated.

In some cases the errors may not be as obvious as a misoriented reactor vessel.

This type of error can and has resulted in hardware modifications and could cause functional and/or structural changes that affect design and operating parameters.

In translating MSSS design information into site construction do.:uments, the A/E may make changes to facilitate construction of the balance of pla t.t.

These translations may also introduce errors which may not be pO0 3[] 3hi d

IE Circular No. 79-11 June 27, 1979 Page 2 of 2 recognized as errors by the A/E's review system. The organization responsible for function and/or structural design must be made aware of changes affecting design and operating parameters so that proper evalua-tion is performed.

It is recognized that there are effective field construction inspection systems, deficiency reporting systems and as-built check systems to uncover and correct for deviatir-n from design. However, these are reactive type systems that address the problems after the errors occur and that rely on detection of errors and design deviations in the construct ion phase.

The detection of certain other errors and design deviations may only be recogniz-able at the design level.

The NRC's concern is that in some instances sufficient checks at the design level are not being performed to preclude design errors discovered at the con-struction site and that the designer may not be aware of other design related changes that affect design and operacing parameters. The 10 CFR 50, Appendix B requirement that addresses this concern is contained in Criteria III which states in part:

" Measures shall be established for the identification and control of design interfaces and for coordination among ps-ticipating deeign organizations. These measures shall include the establishment of procedures among participating design organizations for the revicu, approval, release, distribution, and revision of documents involving design interfaces."

Preventive action at the design level is necessary to minimize the possibility of the appropriate parties not being aware of A/E and construction related design changes and to prevent errors from occurring. An appropriate preventive action would be to have the NSSS review A/E drawings that show the location, orientation, clea rance, etc., for equipment that the NESS has functional and/or structural design responsibility.

All holders of construction permits should be aware of the potential problems caused by inadequatm communication between the design organization and the constructica organization and should take appropriate action to assure them-selves that adequate interface controls are established and implemented.

No written response to this circular is required.

If you require additional information regarding this matter, contact the Director of the appropriate NRC Regional Office.

329 360

IE Circular No. 79-11 June 27, 1979 LISTING OF IE CIRCULARS ISSUED IN LAST TWELVE MONTHS 78-12 HPCI Turbine Control 6/30/78 all Holders of Valve Lift Rod BWR Operating Bending Licenses (OL) or Construc t ion Permits (CP) with Similar IfPCI Design 78-13 Inoperability of 7/10/78 All Holders of Service Water Pumps Reactor Operating Licenses (OL) or Construction Permits (CP) except for plants located in:

AL, AK, CA, FL, GA, LA, MS, SC 78-14 HPCI Turbine Reversing 7/12/78 All Helders of Chamber Hold Down BWR Operating Bolting Licenses (OL) or Construction Permits (CP) fir idants with o IIPCI Terry Turbine exceptiag Duane Arnold and Monticello 78-15 Tilting Disc Check 7/20/78 All Holders of Valves Fail to Close Reactor Operating With Gravity in Licenses (0L) or Vertical Position Construction Permits (CP)

Enclosure Page 1 of 3 X90

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IE Circular No. 79-11 June 27, 1979 78-16 Limitorque Valve 7/26/78 All Holders of Actuators Reactor Operating Licences (OL) or Construction Permits (CP) 78-17 Inadequate Guard 10/13/78 All Holders of Training /Qualifica-and applicants tion and Falsified for Reactor Tcsining Records Operating Licenses (OL) 78-18 Underwriters 11/6/78 All Holders of Laboratory Fire Reactor Operating Test Licenses (OL) or Construction Permits (CP) 78-19 Manual Override 12/29/78 All Holders of (Bypass) of Safety Reactor Construction Actuation Signals Permits (CP) 79-01 Administration of 1/12/79 All Medical Unauthorized Byproduct Licensees excent Meterial to Humans Teletherap,; }fedical Licensees and each Radioph,rmaceutical Suppliers 79-02 t'ailure of 120 Volt 1/16/79 All Holders of Vital AC Power Reactor Operating Suppl.ies License (OL) and Constructi.n Permits (CP) 79-03 Inadequate Guard 2/23/79 All Holders of Training - Qualifica-and applicants tion and Falsified for Special Nuc1 car Training Records

'faterial Licenses in Safeguards Group I 79-04 Loose Locking Nut 3/16/79 All Holders of On Limitorque Valve Reactor Operating Operators License (OL) or Construction Pe rmits (CP)

Enclosure Page 2 of 3 329 347

IE Circular No. 79-11 June 27, 1979 79-05 Moisture Leakage in 3/20/?'

All Holders of Stranded Wire Conductors Reactor Operating License (OL) or Construction Permits (CP) 79-06 Failure to Use Syringe 4/19/79 All Holders of and Battle Shields in Medical Licensees Nuclear Medicine except teletherapy licensees 79-07 Unexpected Speed Increase 5/2/79 All Holders of BWR of Reactor Recirculation Operating Licenses (OLs)

MG Set Resulted in Reactor or Construction Power Increase Permits (cps) 79-06 Attempted Extortion - Low 5/18/79 All Fuel Facilities and Enriched Uranium Reactors Licensed by NRC 79-09 Occurrences of Split or 6/22/79 All Materials Pur.ctured Regalator Priority I, Fuel Diaphragns In Certain Cycle and Operating Self Contained Breathing Reactor Licenses (OL)

Apparatus 79-10 Pipefittings Manufactured 6/26/79 All Power Reactor from Unacceptable Material Licensees with a Construction Permit and/or Operating License (0L)

Enclosure Page 3 of 3 o

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