ML19329E420
| ML19329E420 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/31/1978 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| HOWE-86-78, NUDOCS 8006120769 | |
| Download: ML19329E420 (15) | |
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Cum an Vice Presedent General Offices 212 West ulchigan Avenue. Jackson, Michigan 49201 May 31, 1978 Howe-86-78 Mr J. G. Keppler, Regional Director Office of Inspection & Enforcement THIS DOCUMENT CONTAINS Region III US Nuclear Regulatory Cc==1ssion P00R QUAUTY PAGES 799 Roosevelt Road 3
Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT -
UNIT NO. 1, DOCKET NO. 50-329 UNIT NO. 2, DOCKET NO. 50-330 PIPE SUPPORP FILLET WELDS
Reference:
- 1) Letter, S. H. Howell to J. G. Keppler, Midland Nuclear Plant -
Unit No.1, Docket No. 50-329; Unit No. 2, Docket No. 50-330; Pipe Support Fillet Welds, Serial Hove-197.-77, dated November 21, 1977
- 2) Letter, S. H. Howell to J. G. Keppler, Midland Nuclear Plant -
Unit No. 1, Docket No. 50-329; Unit No. 2, Docket No. 50-330; Pipe Support Fillet Welds, Serial Howe-214-77, dated December 22, 1977
- 3) Letter, S. H. Howell to J. G. Keppler, Midland Nuclear Plant -
Unit No. 1, Docket No. 50-329; Unit No. 2, Docket No. 50-330; Pipe Support Fillet Welds, Serial Howe-ll-78, dated February 10, 1978
- 4) Letter, S. H. Howell to J. G. Keppler, Midland Nuclear Plant -
Unit No. 1, Docket No. 50-329; Unit No. 2, Docket No. 50-330; Pipe Support Fillet Welds, Serial Hove-36-78, dated March 30, 1978 The referenced letters vere interim reports. This letter is also an interim report.
Enclosures 1 and 2 provide Bechtel Associates' Interim Report No. 5 and the Final Report to MCAR-18 dealing with underspecified fillet velds on pipe supports. The final report concludes that a safety problem does not exist and recommends that the velds be used "as is".
Enclosures 3 and h provide Bechtel Associates' Interim Report No. 5 and the Final Report to MCAR-19 dealing with underfabricated shop fillet velds on pipe supports. The final report concludes a safety problem does not exist and recor=:tends that hangers with existing discrepent shop velds be used "as is".
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Howe-86-78 Enclosure No 5 provides Bechtel Associates' Interim Report No 1 to MCAR-21 dealing with underfabricated field fillet velds.
As received from Bechtel, enclosures 2 and 4 had es attachments two ITT Grinnell reports and a document entitled, " Review of Underspecified Fillet Weld Callouts". We are not forwarding these attachments to you at this time as they are undergoing minor revisions to accommodate CPCo comments.
These reports and the Bechtel final report for MCAR-1 Report No 21 vill be provided as part of our final 50 55(e) report.
A final, or another interim, report will be sent on or before July lo,1978.
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Enclosures:
- 1) Interim Report No. 5 dated March 27, 1978, MCAR-18
- 2) Letter P. A. Martinez to G. S. Keeley, MCAR-18 Final Report, Apparent Undersized Hanger Welds, BLC-5935; with MCAR-18 Final Report attached.
- 3) Interim Report No. 5 dated March 27, 15Tf8, MCAR-19
- 4) Letter, P. A. Martinez to G. S. Keeley, MCAR-19 Final Report, Undersized Hanger Welds Per Vendor Drawing Requirements, BLC-5936, dated May 9,1978; with MCAR-19 Final Report attached.
- 5) Interim Report No. 1 dated March 24,1978, MCAR-21 CC: Dr Ernst Volgenau, USNRC (15)
Director, Office of Management Information and Program Control, USNRC (1) e
Encloxure 1
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How2-86-78
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' BECHTEL ASSOCIATES Fr.aSIO3AL CORPORATION Attcchmint to BLC-5
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SUBJECT:
MCAR #
18 (I'ssuce' 10/2'8/77)
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p INTERIM REPORT #
5 DATE; March 27. 1978 PROJECT: ' Consumers Powe:. Company Midland Plant Units 1 & 2
- Bechtel Job 7220 r
. Sta'tus of Corrective Action and Investigation The preliminary draf t of Grinnell's report on justifying.their. weld designs
. to the ASME code committee and other jurisdictional authorities has been received and is currently being reviewed.
The three additional test re-ports noted in Interim Report 4, were not included in this preliminary draft.
Bechtel will confer with Grinnell i: Providence, R.I. during the week of March 27, 1978 to' resolve B.echtel comments on the Grinnell report.
Bechtel completed the survey of underspecified fillet weld 'callouts on ASME '
. hangers designed prior to June 1977.
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Forecast D' ate on Corrective Action F'
The final draft of Grinnell's report on justifying their weld design callouts i
will be submitted after the Bechtcl/Grinnell meeting which will take place in Providence, R.I. during the week of March 27, 1978.
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May 9, 1978 BLC-5935 Consumers Power Company Mr. G. S. Keeley, Project Manager 1945 West Parnall Road Jackson, Michigan 49201
-Hidland Units 1 and 2 Consumers Power Company Bechtel Job 7220 NCAR-18 FINAL REPORT APPARENT UNDERSIZED IIANGER WELDS j
Files 2417/2801
Dear Mr. Keeley:
Attached 'is the Final Report covering the deficiency described in MCAR-18.
The Final Report includes a description of the deficiency with a review of underspecified hanger fillet weld callouts, a statement of cafety implications, corrective actions to prevent repetition; conclusions, and recon:mendations.
Although the design differs from the e, ode requirements,Grinncil has demon-strated that the welds are adequate to support the design loads and that a safety problem does not exist. This deficiency is now considered nonreportable.
This Final Report is responsive to the five recommended actions included in HCAR-18, modified as follows:
Item I-3:
In lieu of~ a 1 percent sample of hangers, a completc
- survey, i.e., 100 percent, of Grinnell detail drawings was performed.
Results of this survey which identified approxir:stely 330 under-specified welds, are included in the Report.
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,BLC-5935 Bechtel Power Corporation Consumers Power Company May 9, 1978 g.. '
Page 2 Item I-4: The inspection of some hangers to compare actual versus design weld size was done.
Results of this reinspection are included in MCAR-19.
This Report completes all scheduled action on the subject liCAR.
Very truly yours,
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- lld!M<b4-Icr P. A. Martine:
Project Manager PAM/WCM/pp
' Attachments (1) Final Report by Bechtel, May' 3,1978.
(2) Review of, Underspecified Fillet Weld Callouts o_n ASME Pipe Suooort Drawings Desirrned by ITT Grinnell, Jan. 1978.
n (3) ITT Grinnell's Report of Investination g Fillet Welds b Hanger Assemblies, Report No. 2035, dated April 20, 1978.
s cc: Mr. R. C. Bauman w/o m.
Mr. W. R. Bird w/16 W
Mr. J. L. Corley w/o Mr. B. W. Marguglio w/o, i
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SUBJECT:
MCAR #18 (Issued 10/28/77) h) / FINAL REPORT DATE:
5/3/78 i
PROJECT: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Description of Discrepancy
/
Approximately 330 of a group of 2,500 ASME pipe support designs supplied by ITT-Grinnell had underspecified fillet weld call' outs when compared to the ASME Table XVII-2452.1-1, Appendix XVII of Section III, Subsection NA, cs required by ASME,Section III, Subsection NF, Paragraphs NF3292, NF3392, and NF3400.
A summary of Bechtel's review of Grinnell hanger designs is attached to this report.
Paragraph XVII-2452.1 of Subsection NA states that the minimum size design r?quirements of fillet velds for joining linear members are to be in complitnce with Table XVII-2452.1-1.
This, paragraph also' states
" weld size is determined by the thicker of the two parts joined, except that the weld size need not exceed the thickness of the thinner part unless a' larger size is required by calculated stress." The discrepancy is the result of Grinnell's interpreting the phrase "...the weld size need not exceed the thickness-of the thinner part joined..." as permitting) cny size fillet weld, properly stressed, that does not " exceed" thickness of the thinner part joined. As a result of this interpretation, Grinnell designed all fillet welds for linear members in terms of the code allowable weld stress levels. This fillet weld sizing procedure is identical to the code requirements for the more stringent plate and shell classified pipe supports. An informal request was made for a code clarification of Paragraph XVII-2452.1 at the ASME code committee meeting of November 1, 1977. The code committee chairperson stated that if a formal inquiry were presented, he would support a code interpretation that the minimum fillet weld size nust be at least the thickness of the thinnest member joined where the code minimum weld size Table XVII-2452.1-1 calls for a fillet veld equal cr greater than the thickness of the thinner member. Based on this 1 response by the ASME committee, a formal code clarification of Paragraph XVII 2452.1 will not be pursued. Safety Implications Initially, this discrepancy was considered a potentially reportable discrepancy because a safety problem could exist if a Q-listed pipe support should fail because of a fillet veld being underspecified. However, based on the results of followup analysis, the design conservatism (5) - e
~ T: CAR.-Report #18 / Pag? 2 ,/ 3 cf the support designs that has been established, and the results of the full size destructive tests (details of which are attached to this r port), we conclude a safety problem does not exist. Grinnell states that although some of the fillet veld sizes do not meet tha requirements of Table XVII-2452.1-1, there is not a safety problem b:cause all the welds were sized according to the calcul: 3ed weld stress livels and utilized weld stress allowables of only half that allowed by th3 codes. Ta confirm Grinnell's contention that no safety problem o.xists because Cf noncompliance with Table XVII-2452.1-1, Grinnell performed full size dastructive loading tests on hanger designs with the " worst case" deviations fr:m the requirements of Table XVII-2452.1-1. On December 12 and 13, 1977 Grinnell corducted the initial full size destructive loading tests on two " worst case" and one control hanger (one without discrepant velds) with observers from Consumers Power Company and Bechtel in attendance. Grinnell subsequently repeated the tests with the nonconforming fillet wsids being further reduced in size by 1/16-inch. The results of all thn testing indicate that the minimua resulting veld safety factor was -6.38. The complete details of the testing are set forth in Grinnell's Rwport of Investication of Fillet Welds in Hancer Assemblies. Midland Units 1 & 2, Concurers Power Company, dated April 20, 1978, which is cn attachment te this report. The full size destructive load testing of the " worst case" deviations frrm Tabic XVII-2452.1-1 confirm the analytical conservatism of the hinger designs and the safety of the plant operation is not jeopardized by the weld callouts on existing designs. This deficiency is now considered a nonreportable deficiency. ' Corrective Action While most of Grinnell's designs complied with Table XVII-2452.1-1 breause of conservative design practices, Grinnell has, since May 1977, c:nformed to the ASME code committee's clarification of the requirements cf Paragraph XVII-2452.1, Appendix XVII of Section III, Subsection NA. Grinnell's compliance with Paragraph XVII-2452.1 has been confirmed by the review of subsequent hanger designs. d 's
. ' y.-., MCAR Repnrt #18 P ge 3 ? 0 4 / Conclusions and Recommendations The results of Grinnell's analysis, the results of the " worst case" full cize destructive load tests, and the established design conservatism c:nfirm that no safety problem exists because of underspecified fillet valds cited under this MCAR. The plant safety is not jeopardi cd by the discrepant fillet weld designs on existing hangers. It is recommended that the hangers and their designs having discrepant fillet weld callout bn used "as is." JsM Submitted by g , Y Approved by M ??:Bl8,6b d /4 ![) Concurrence by RNT/ cap 5/3/5 Attachments:
- 1) Review of undersp,ecified fillet weld callouts,' January, 1978
- 2) Report of investigation of fillet velds in hanger assemblies, O.,
Midland Units 1 & 2 Consumers Power Company (Report 2035) April 20, 1978. 9 9 9 e 6
g .< Attachment to BLC-57 a m. A ~ * ' {., - Encl dure 3 ~ Howa-86-78
SUBJECT:
MCAR # 19 (Iscurd 11/7/77 ) .s t a, ~ INTERIM REPORT d 5 DATE: - March 27. 1978 PROJECT: Consumers Power Company Midland Plant Units 1 & 2 ~,. .Bechtel Job 7220 ye . Status of Corrective Action and Investigation On March 17, 1978, Bechtel completed its review of Grinnell's axialytical cnalysis report on underfabricated shop welds with comments on items requiring further analysis, justification, and development. There will be a Bechtel/Grinnell meeting in Providence, RI during the'veek of March 27, 1978 to resolve Bechcci comments on the report; Bechtel completed the estiv ~ the number of underfabricated shop welds i i .ex st ng on ASME hangers r sy Grinnell to the jobsite through August 1977. The estimate was cern to CPCo on March 7, 1978. - s Forecast Date on Corrective Action The report on the analytical analysis of underfabricated shop fillet velds will be submitted af ter the Bechtel/Grinnell meeting in Providence, RI, which is to be held during the week of March 27, 1978. g e. p Submitted by: M/ h Approved by,* p N. UK~[.:w. ~ Concurrence by: t$ m/h (
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,3 Encle ure h Howe-86-78 Bechtel Power Corporation m 777 East Eisenhower Parkway d Ann Arbor, Michigan Ma#AWWess: P.O. Box 1000, Ann Arbor, Michigan 4810G May 9, 1978 BLC-5936 Consumers Power Company Mr. G. S. Keeley, Project Manager 1945 West Parnall Road Jackson, Michigan 49201 Midland Units 1 and 2 Consumers Power Company Bechtel Job 7220 _MCAR-19 FINAL REPORT _ UNDERSIZED HANGER VELDS PER VENDOR DRAWING REOUIRDfENTS h Files 2417/2801
Dear Mr. Keeley:
Attached is the Final Report covering the deficiency described in MCAR-19. The Final Report includes a description of the discrepancy, a statement of the c,afety implications, corrective actions to prevent repetition; conclusions, and recommendations. The analysis of the discrepar.t shop velds, the results of the destructive
- loading tests, and the established conservatism of Grinnell's designs confirm that no safety problem exists. This deficiency is now considered nonreportabic.
MCAR-19 item 3a required site inspectica of the Grinnell hangers shipped on October 31, 1977. The inspection perforned found this lot of hangers acceptable. This Final Report completes scheduled action on MCAR-19. -Very truly yours, <75>h;c6.. 6< w. s J P. A. Martinez PAM/WQI/pp Project Manager Attachments (1) Final Report by Bechtel, May 3, 1978. Or (2) ITT Grinnell's Field Surveyed Wolds Stress Analysis For ~ Bechtel Associates Professional Corp., April 20, 1978. cc: Mr. R. C. Bauman w/o Mr. J. L. Corley v/o Mr. W. R. Bird v/16 Mr. B. W. Marguglio v/o 7. f
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SUBJECT:
MCAR 419 (Issued 11/7/77) k FINAL REPORT DATE: 5/3/78 PROJECT: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Description of Discrepancy Shop welds for various pipe hanger assemblies designed and fabricated by ITT-Grinnell were noted as underfabricated when compared to the sizes required on the design drawings. A sample size of 125 shop welds was celected as representative of the total group of shop welds on the cssembles supplied by Grinnell. All 125 shop welds werc examined; from review, 54 welds (i.e. 43%) were identified as underfabricated in sisc. Generally, this discrepant condition was 1/16-inch or less undersize. Paragraph K-1310 of Appendix K, ASME Section III, Subsection.NA, which cupplements Article NF-4000 of Subsection NF on the fabrication and installation of component supports, states that the recommended maximum tolerances for weld sizes is "plus only, no undersize permitted." The reason for the discrepancy appears to be three-fold; s ({) 1) Crinnell's internal weld inspection procedure was a visual technique which allowed shop fillet velds in any single continuoss weld to have an underrun from the nominal fillet weld size required by 1/16 inch without correction, provided the underrun did not exceed 10% of the weld length. This is an accepted industrial standard for welded structural members. 2) Only shop welds that visually appeared suspect were inspected with a gage. 3) Ambiguous and inconsistent cr$teria for measuring and sizing obtuse angle fillet veld in Grinnell's written procedures., Safety Implications Initially, this deficiency was considered a potentially reportable discrepancy because a safety problem could exist if a Q-listed pipe cupport should fail due to an underfabricated shop weld. However, based cn the results of follow-up analysis which established the design conservatism of the support designs, and the results of the full size destructive loading tests with both underspecified and underfabricated welds (reference MCAR #18), we conclude a safety problem does not exist. s
s. ,MCAR #19 PJga 2 Grinnell states that although some of the shop wclds are underfabricated ~ from the wcld sizes specified on the hanger drawings, there is no safety prob 1cm as the welds were sized using allowable wcld stress icvels that were conservative when compared to the Code. To confirm Grinnell's contention that no safety problem exists, Grinnell performed a reanalysis of the 54 discrepant shop welds of the 125 shop welds noted above. The results indicate that the underfabricated shop volds reanalysized had wcld stress levels less than the mai:imum permitted by the ASME, Section III, Subsection NF Code. The complete details of the reanalysis is set forth in Grinnell's report entitled " Field Surveyed Welds Stress Analysis for Bechtel Associate Professional Corporation," dated April 19, 1978, which is attached to this report. The reanalysis of the discrepant shop welds, the results of the full size destructive loading tests conducted on underspecified and underfabri-cated welds associated with MCAR #18, and the established conservatism of Grinnell's designs, confirm that the safety of the plant operation is not jeopardized by underfabricated shop welds. This deficiency is now considered a nonreportable deficiency. Corrective Action To prevent the reoccurrence of underfabricated shop welds Grinnell has: 1) Revised its QA/QC procedures 02A001 " Dimensional Tolerance Standard for Component Supports" and 02A006 " Visual and Dimensional Acceptance Critoria for Welds" to conform to Paragraph K-1310 of Appendix K, ASME, Section III, Subsection NA. 2) Initiated additional in-house training sessions for its weld inspectors. 3) Initiated a 100% weld inspection program. An incoming inspection of all hangers at the jobsite has' confirmed the effectiveness of Grinnell's corrective actions to date. Conclusions and Recommendations The results of Grinnell's reanalysis on underf abricated shop welds, the results on the full size destructive loading tests conducted on under-specified and underfabricated welds associated with MCAR #18, and the established conservatism of Grinnell's design confirm that no safety prob 1cm exists due to an underfabricated shop weld. It is recommended that hangers with existing discrepant shop welds be se "as-is." Submitted by: h Approved by: .h #710&dd [ Concurrence y: RNT/jp 5/3/7
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SUBJECT:
MCAR # 21 (Issued 2/28/78) ~ Field weld size discrepancies associated with hanger fabrication ~ INTERIM REPORT # l-DATE: 3/24/78' PROJECT: Consumers Power Company ~ Midlaid Plant Units 1 & 2 ~ Bechtel Job 7220 ~ ' Description of Discrepancy ~ An inspection at the Midland jobsite, using a weld fillet gage,, was conducted by Quality Control of a sa=ple of 80 completed hangers consisting of 300 field welds. This sample represents 10% of the Q-listed hangers with field fillet welds installed to date. The inspection was to deter-mine the actual field weld size compared to Grinnell design and sketches. It was discovered that contrary to the specified field weld size required by Grinnell drawings, the actual field weld size for 26 hangers, repre-sentjng 49 field welds, were undersize. This deficiency was discovered during the investigation of MCARs 18 and 19 which, identified similar . weld size deficiencies in Grinnell's shop welds. Probable Cause 1. The field weld sizes shown on the Grinnell drawings do not specify a weld size tolerance. The craft welders produced field welds which were undersized compared to drawing requirements. 2. The principal reason for QC overlooking several undersize fillet welds was apparently a misinterpretation of the QC instructions regarding inspection technique. The instructions require the OCE to visually examine to detect the worst condition, (e.g., smallest veld size, take a measurement to verify acceptance, and visually . compare the.other items based on this measurement. Instead of the worst case, the QCE used the most representative case, and by applying past practical experience and judgment, ignored what he believed were minor and insignificant variations from the normal. .e 0 e O e
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, continu d V Corrective Action _ 1. The craf t velders and fic1d veld engineers have been instructed thct there is no undersize tolerance for field welds. Welds as deposited must meet the drawing requirements. / 2., For all field welds subsequent to the identification of this defi-ciency, the QCEs through further trainin;; and monitoring by QC supervision, have instituted a more rigorous. application of the QCI instructions. They are no longer modifying the stated inspection tec,hnique by applying qualifying judgment and practical experience. Instead, all undersize welds, no matter what the extent of.the undersize condition or for huv short a. length, are being sought and classified as' unacceptable. 3. The adequacy of all field welds existing prior to the identification of this-deficiency will be determined in conjunction with the resolution of MCARs 18 and 19. , ' Potential Safety Implication A potential safety problem could exist if a structural failure should cccur in a Q-listed hanger due to the veld size being less than specified, ne. acceptability of undersized "as-built" welds is currently being investigated by Grinnell in connection with MCARs 18 and 19.
- Grinnell has stated that they believe the results of their' investigation will indicate that no safety problems exist since the initial design loadings
". had substantial safety margins. However, until a final analysis confirms' the acceptability of the existing welds, this deficiency must.be considered potentially reportable. Forecast Date on Corrective Action Final resolution of this MCAR is contingent upon resolution of MCARs 18 cnd 19. A final report will be submitted after resolution of those MCARs, durrently forecasted for mid-1978. ~ 9 6 %nf. M9/2c submittca by: I M, M e q / A,. ? /: 9/tb Approved by: Concurrence by j-3 so/7p t. - I 4 4 g .n O n
N REGULATORY INFORMATION DISTRIBUTION GYSTEM (RIDS) DISTRIBUTION FOR INCOMING MATERIAL sO-32* 3S0 REC: KEPPLER J G ORG: HOWELL S H DOCDATE: 05/31/78 NRC CONSUMERS PWR DATE RCVD: 06/14/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED
SUBJECT:
LTR 1 ENCL 1 FORWARIDNO APPLICANT"S INTERIM REPTS (AS LISTED) CONCERNING DEFICIENCY IN THE PIPE SUPPORT FILLET WELDS. PLANT NAME: MIDLAND - UNIT 1 REVIEWER INITIAL: XJM MIDLAND - UNIT 2 DISTRIBUTER INITIAL: 5xq oco**o*********** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ****************** CONSTRUCTION DEFICIENCY REPORT (10CFR50.55E) (DISTRIBUTION CODE B019) FOR ACTION: ASST DIR VASSALLO**W/ ENCL BR CHIEF LWR #4 BC**W/ ENCL PROJ MGR HOOD **W/ ENCL LIC ASST SERVICE **W/ ENCL INTERNAL: G
- W/ ENCL NRC PDR**W/ ENCL A e h**W/2 ENCL OELD**W/ ENCL GOSSICK & STAFF **W/ ENCL MIPC**W/ ENCL DIRECTOR DPM**W/ ENCL DEPUTY DIR DPM**W/ ENCL QABN*W/ ENCL DIRECTOR DSS **W/ ENCL AD FOR ENG**W/ ENCL AD FOR REAC SFTY**W/ ENCL AD FOR PLANT SYSTEMS **W/ ENCL AD FOR OPER TECH **W/ ENCL SD**W/ ENCL K SEYFRIT/IE**W/ ENCL FERD DREHER/IE**W/ ENCL EXTERNAL-IPDR'S MIDLAND. MI4*W/ ENCL TIC **W/ ENCL NSIC**W/ ENCL ACRS CAT A**W/16 ENCL DISTRIDUTION:
LTR 41 ENCL 41 CONTROL NCR: 781660014 SIZE: 2P&12P /g LL cooo******************************* THE END
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