ML19246B656

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Forwards IE Circular 79-11, Design/Const Interface Problem. No Action Required
ML19246B656
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/27/1979
From: Seyfrit K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Gary R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 7907180266
Download: ML19246B656 (1)


Text

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UNITED ST ATES

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AR LING ton, T E X AS 76012 June 27, 1979 In Reply Refer To:

RIV Docket Nos.

50-445/IE Circular No. 79-11 53-446/IE Circular No. 79-11 Texas Utilities Generating Company ATTN:

Mr. R. J. Gary, Executive Vice President and General Manager 2001 Bryan Tower Dallas, Texas 75201 Centlemen:

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.

Sinccrely, 2,

Karl V. Seyfrit' Director

Enclosures:

1.

IE Circular No. 79-11 2.

List of IE Circulars Issued in the Last 12 Months

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UNITED STATES NUCLEAR REGULATORY C0:1BIISSION 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 (NSSS),

architect / engineer (A/E) and constructors have resulted in several cases where reacter vessels or the supports have been misoriented.

The misorienta-tion problems appear to occur at cites where dual reactor units are being censtructed and one primary system layout is a mirror image of the other.

In 1975 TVA reported a misorientation pco'olem with the Sequoyah Unit 2 reactor vessel. Westinghouse was the NSSS supplier and TVA provided their cwn A/E s e rvi ce.

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 Utilities Generating Company reported a reactor vessel support system minorientation at Comanche Peak Unit 2.

Westinghouse supplied the NSSS, Gibbs and Hill was the plant em ineer and Brown and Root was the constructor.

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

Corrective prevcative action is recommended for the following reasons:

If the interface control system betweer. the NSSS/AE/ Construction is marginal or ineffective as evidenced by the misorientation of recetor vessels and their supports, it is possible 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 NSSS design information into site construction documents, the A/E may make changes to facilitate construction of the balance of plant. These translations may also introduce errors uhich may not be 7906200176 33/

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 parame'ers so that proper evalua-tion is performed.

It is recognized that there ace effective field construction inspection systema, deficiency reporting systems and as-built check systems to uncover and correct for deviations from design.

However, these are reactive type systems that address the problems af ter the errors occur and that rely on detection of errors and design deviations in the construction phase.

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

The NRC's coacern is that in some instances sufficient checks at the design level are not being performed to preclude design errors discavered at the con-struction site and that the designer may not be aware of other design related changes that affect design and operating 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 contral of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces."

Preventive action at the design level is necessary to minimize the possibility of the apprc.priate parties not being aware of A/E and c,nstruction related design changes and to prevent errors from occurring.

An appropriate preventive action would be to have the NSSS review A/E drtviagr that show the location.

orientation, clearance, etc., for equipment. that the NSSS has functional and/or structural design responsibility.

All holders of construction permits should be aware of the potential problems caused by inadequate communication between the design organization and the construction 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 addicional information regarding i matter, contact the Director of the appropriate NRC Regional Office.

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

AL, AK, CA, FL, GA, LA, MS, SC 78-14 HPCI Turbine Reversing 7/12/78 All Holders of Chamber Hold Down EWR Operating Bolting Licenses (OL) or Construccion Permits (CP) for plants with a HPCI Terry Turbine excepting 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 (OL) or Vertical Position Construction Permits (CP)

Enclosure Page 1 of 3 b 5ll [7 ' _-

IE Circular No. 79-11 June 27, 1979 78-16 Limitorque Valve 7/26/78 All Holders of Actuators Reactor Operating Licenses (OL) or Construction Permits (CP) 78-17 Inadequate Guard 10/13/78 All Holders of Training /Qualifica-and applicants tion and Falsified for Reactor Training Records Operating Licenses (0L) 78-18 Underwriters 11/6/78 All Holdcrs 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 except Material to Humans Teletherapy Medical Licensees and each Radiopharmaceutical Suppliers 79-02 Failure of 120 Volt 1/16/79 All Holders of Vital AC Power Reactor Operating Supplies License (OL) and Construction Permits (CP) 79-03 Inadequate Guard 2/23/79 All Holders of Training - Qualifica-and applicants tion and Falsified for Special Nuclear Training Records Material Licenses in Safeguards Group I 79-04 Loose Locking Nut 3/16/79 All Holders of On Limitorque Valve Reactor Operating Operators Lice.:se (OL) or Construction Permits (CP)

Enclosure Page 2 of 3 3JI r -

IE Circular No. 79-11 June 27, 1979 79-05 Moisture Leakage in 3/20/79 All dolders 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 (CLs)

MG Set Resulted in Reactor or Construction Power Increase Permits (cps) 79-08 Attempted Extortion - Low 5/18/79 All Fuel Facilities and Enriched Uranium Reactors Licensed by NRC 79-09 Occurrences of Split or 0/22/79 All Materials Puncetred Regulator Priority I, Fuel Diaphragms In Certain Cycle and Operating Self Contained Breathing Reactor Licenses (0L)

Apparatus 79-10 Pipefittings Manufactureu 5/26/79 Ali Power Reactor from Unacceptable Material Licensees with a Construction Permit and/or Operating License (OL)

Enclosure Page 3 of 3