ML20002A681
| ML20002A681 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/22/1980 |
| From: | Watts T COMMONWEALTH EDISON CO. |
| To: | Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8011210248 | |
| Download: ML20002A681 (9) | |
Text
Commonwealth Edison N
\\ one First National Plan Chicago, Illinoss o-Address Reply to: Post Offico Box 767 N-CNeago, Illinois 60690 October 2 2, 1 9 8 0 :~ ~.a
- i z
Mr. I.T. Yin United States Nuclear Regulatory Commission ich I.E.,
Region III 799 Roosevelt Road
'~
~S d#
Glen Ellyn, Illinois 60137 u
Mr. Yin:
Attached is the first be-weekly report for LaSalle County Station Unit 1 as requested in Section 4 of your report nos.
50-373/80-40; 50-374/80-26.
Although this report is inclusive, it is our intention to only include the previous two week activities in our future report Sections b, c, d, and e.
Section a, with schedule and totals, will be repeated in its entirety.
If you have any questions or suggestions on this matter, please do not hesitate to call me on (312) 294-2828.
Sincerely,
~ 2 E kl.ci2$$~
T.E. Watts BA/bmb/7556A Attachment cc:
B.R. Shelton T.E. Watts L.0. DelGeorge W.H. Donaldson/M. Lohman T.E. Quaka
- 8. Annis GCT 2 4 E80 E011pyg.2 9r
4a.
Schedule Milestone for 2" and under Item Original Proposed Submit 1st subsystem packages to S&L 9-15-80 9-9-80*
Receive 1st subsystem package from S&L 9-29-80 10- 6-80*
25% of subsystems complete by S&L 10-20-80 11-10-80 50% of subsystems complete by S&L 11-10-80 11-24-80 75% of subsystems complete by S&L 12-1-80 12-15-80 4
100% of subsystems complete by S&L 12-22-80 1-5-80
- actual date Note:
184 of 524 subsystems have been submitted to S&L 19 subsystems have been completed and returned by S&L 4b.
During the past two week reporting period, the design was completed on-the 19 subsystems-listed below:
DG:
70, 71, 73, 74, 75, 76, 78 00:
29, 30, 31, 32, 33, 34 FC:
69 LP:
73, 74 RI:
85 TE:
60, 61 4c.
No subsystems have beenLinstalled and QC inspected.
4d.
The following QA Audits and Surveillances were performed by CECO, with respect to small bore piping:
On S&L:
- 80-467, 9-12-80
- 80-508, 9-26-80
- 80-511, 9-26-80
- 80-577, 10-17-80 On MCCo:
- 80-565, 9-22-80
- 80-568, 10-3-80
- 80-569, 10-8-80
- 1-80-73, 10-15-80 On NSC:
- 80-512, 9-26-80
- 80-524, 10-2-80 NSC offsite audit, 9-30-80 4e.
NCR 454 found calculations were not kept by MCCo.
The calculations were reviewed and approved by S&L 10-3-00 and the NCR was approved by CECO. Engineering 10-14-80.
No other NCR is open on this subject.
The only open audit or surveillance findings are from the NSC offsite audit.
The audit report is attached.
ATTAC*@IENT A Findinc #1:
6 Contrary to 10CFR50 Appendix B Criterion III, NSC Q.A. Manual section 3 3 and Project Specification SAR-0303 section 1.3.1, NSC has not adequately
. cccounted for self-weight excitation in pipe support design.
-Discussion:
1UCFR50 Appendix B Criterion III states in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instruc-tiens",
and
" Measures shall also be established for the selection and rsview for suitability of application of materials, parts, equipment and pro-c.osses that are essential to the safety-related functions of the structures, systems and components".
The NSC Q.A. Manual section 3.3 states in part, " Design input is required fo,r items to be designed, and for design services to be provided (e.g.,
analysis, design verification).
Design input shall be specified and docu-mented on a timely basis and provide consistent bases for making design desicions, accomplishing design verification, and evaluating design changes."-
" Design input shall include the following to the extent applicable:
Design criteria and reouirements urovided by the client".
Project Specific'ation: SAR-D303 for LaSalle County Units 1 and 2 requires that "Self-weight excitatian for all Class A, B, and C pipe supports and warping effect shall be considered in the design of all pipe supports."
At the time of the audit, NSC was using.5@4 of pipe support component weights (excluding pipe clamp) in the analysis of pipe supports.
Full com-bined weights of pipe clamp and support components must be used in the support analysis.
Any pipe clamp and support component weights inputed into the PIPSYS piping analysis program is used only for pipe stresses.
These inputed weights are not reflected into pipe support attachment loadings,
as originally assumed by NSC.
Findine #2:
Contrary to paragraph 2.4.7 of the NSC Q.A. Program, the project p'lan issued for the LaSalle project does not describe which Engineering procedures are applicable for the LaSalle project.
Discussion:
Paragraph 2.4.7 of the NSC Q.A. program states that " Prior to the per-formance of client project activities, the person assigned responsibility
.for technical control of the project shall document those activities in project plans.. Project p1rins will include, as appropriate to the scope of ths project:
A.
A project manual or other form of overall plan cf project activities,
- and, B.
Detailed plans of related activities (e.g., design, procurement testing),
as necessary to control quality achievement, quality assurance and Q.A.
records."
Engineering procedure 8.1 describes the corrective action to be taken in respect of significant conditions adverse to quality.
However, at the time of the audit, the project personnel were unable to show a document which indicates that this Engineerine crocedure is apolicable to the LaSalle oro.iec;
Findinc #3 Attachment i
Contrary to specification SAR-0303 for LaSallo County Station Units and 2 section 1.3.1, NSC has not reviewed expansion anchors in accordance 1
with LS-CEA.
Discussion:
SAR '0303.Rev. 5, section 1 3.1 states that NSC shall review pipe sup' port base msmo dated 2/ plates in accordance with Form LS-CEA and the S&L interoffice 11/80 on expansion anchor allowablef.
LS-C2A Rev. 5 section
- 2.1.10 recuires that review of edge distance dimensions be conducted for compliance to minimum allowed distances from embeded plates, concrete edges, and steel lined openings.
At the time of the audit, NSC was not performing such reviews for concrete expansion anchor plates within its scope of work._,_
Finding #4:
2 Contrary to SAR-0303, certain aspects of laSalle Station pipe support design work has not been performed 'in accordance with PI-LS-16 in the area
of support tolerance considerations.
Discussion:
SAR-0303 Rev. 5 page 3 item f, lists PI-LS-16, Rev. 3 as a standard to -
be employed for design.
PI-LS-16 Rev. 3 Appendix 0 pages 7-12 states that installation tolerances such as lateral structural steel misalign=ents, vertical structural steel misalignments and location tolerances must bo considered in the pipe support design.
This consideration may be done by exact analysis of these tolerances or may be accounted for the use of a "$" factor for allowable stress reduction in the interaction equation ~.
At the time of the audit, neither technique was being employed by NSC.
=--
- -.. = ---- =.
==-
Finding #5:
Contrary to 10CFR50 Appendix B Criterion III and NSC Q.A. Manual seczion 3.2.2, interface documents for the NSC-S&L interface do not in-clut.e what measures will be taken when design criteria changes during the course of the LaSalle project.
Discussion:
10CFR50 Appendix B Criterion III states in part, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations.
These measures shall.
tions for the review, approval, release. distribution, and revisio uments involving design interfaces."
The NSC Q.A. Manual section 3.2.2 states, " Methods shall beestablished for activities across external and internal design interfaces. communicatin shall include decision making; resolution of problems; These methods provision and review of information; and preparation, review, approval, distribution and revision of documents when more than one organization or ' Group is involved."
At the time of the audit criteria for piping sysuem ana, lysis, including PI-LS-16, had been revisedsevera by S&L during the course of the LaSalle project.
The interface documents between NSC and S&L did not include provisions for the revision of design criteria during the course of the project including the disposition of cal-culaflons made previous to the design criteria revision.
Attachment
' Disciissicn (C,ontinu;d)
In enlculation MC9-PC01-101GS, the review of.a support extension tube enalysis indicated that criteria used for the analysis had since been super-ccded.
In calculation M09-FC30-1069 pg. 79,.the base olate stress check was based upon charts in PI-LS-16 (app K page 62) that 12ad been superceded by S&L since the calculation was performed.
At the time of the audit, no previsions had been made for the review of these calculations and other enlculations that have been performed previous to design criteria revisions.
'~
~
Findine #6i -
Contrary to 10CFR50 appendix B criteria III and VI and the NSC Q.A.
Manual ucction 3.3 re. visions to design criteria made by S&L have not been incorporatid into NSC design standards and instructions.
Discussion:
10CFR50 apoendix B criterion III states in part," Measures shall be established to assure that applicable regulatory requirements and the design-basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, ' drawings, - procedures, and instruc-tions."
Criteria VI states in part,
" Measures'shall be-. established't6 c'66tr'ol the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting' quality.
These measures shall assure that~
documents, including changes, are reviewed, for adequacy and approved for release by authorized ~ personnel and are distributed to and used at the loca-tion where the prescribed activity is performed."
The NSC Q.A. Manual section 3 3 states in part, " Design input is required for items to be designed, and for design services to be provided (e.g.,
analysis, design verification).
Design input shall be specified and docu-mented on a timely basis and provide consistent bases for making design decisions, accomplishing design verification, and evaluating design changes. _
Design input shall include the following to the extent applicable:
Design criteria and requirements provided by the client."
At the time of the audit the following revisions to PI-LS-16 had not been incorporated into NSC Ouad Guidelines".
7-79-027 " Pipe support Procedures and 1
Pages 60 and 62 had been deleted in PI-LS-16 Rev. 3 appendix K.
These pages were.still in CUAD 7-79-027 Rev. 3 section 4.B.
2 The revision levels of drawing M-1100 sheets 19-23 were Rev. C, in PI-LS
~16 Rev. 3 Appendix 0.
The revision levels of these sheets in QUAD 7-79-027 Rev. 3 section 4.A were Rev. A.
In addition, PI-LS-16 Rev. 3 appendix-O had sheets 24 and 25 of drawing M-1100 and these sheets were absent in QUAD 7-79
-027 Rev. 3 section 4A.
D
Findinc #7:
Attachment Contrary to 100FR50 Appendix B Criterion III and NSC Q. A. Manual scetion 3.3, design criteria has not been correctly translated into the d0 sign.
Discussion:
10CFR50 Appendix B Criterion III states in part, " Measures shall be established to assure that applicable regulatory requirements and the de-Gign basis, as defined in 50.2 and as specified in the license application for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures and instructions."
" Measures shall also be established.for the selection and review for suit-obility of application of materials; parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components."
/
a The NSC Q.A. Manual section 3.3 states in part, " Design input is required for items to be designed, and for design services to be provided (e.g.
analysis, design verification).
' Design' input shall be specified and docu-mented on a timely baJis and provide consistent bases for making design decisions, accomplishing design verification, and evaluating design changes."
" Design input shall include the following the extent applicable:
Design criteria and requirements provided by the, client."
Contrary to the above requirea2nts, lhe following items were observed.
1 In calculation PC01-1800S a K factor of 1.2 was employed in the analysis.
This factor is not correct.for the end-conditions of the support and must be increased.
In calculation RO1--1i3 INS' chart #3 was employed for CEA bolt analysis.
2 This chart was incorrectly employed since it is for existing installa-tions only and the support had not yet been installed.
3.
In calculation FC-28-1805x the designer employed SSE allowable forces for CEA analysis.
The governing condition for this case should be OBE allowable forces.
J 4
In calculation FC-28-1808x an amplification factor for the analysis of the CEA baseplate is required per S&L's Design Criteria for Mechanical Component Support members dated 2/12/80.
No amplification factor was used in the calculation.
5.
In calculations M09-FC30-1079X and M09-FC30-1084 interaction equations were not employed for combined stress analysis as required by PI-LS-16 Rev. 3 appendix 0 pages 7-12.
6.
In calculation M09-PC01-1018V, the weld of BOM items #16 to #3 was spec-ified as a fillet weld when only a groove weld could be physically in-stalled.
This is not in compliance with SAR P2.3, where a check of welding feasability-is required.
7.
In calculation M09-FC3-1063X an incorrect member property for BOM item
- 1 was inputed into the computer program for a pipe support frame analy-sis resulting in an incorrect output.
e
,Pind[inc #82 Attachment s
Contrary to 10CFR50 Appandix B Critorion III and NSC Q.A. Manual section 3.3 design calculations have nct been adequately documented.
Discussion:
10CFR50 Appendix B Criterion III states in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures and instruc-tiens."
" Measures shall also be established for the selection and review for suita-bility of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components."
l The NSC Q. A. Manual sect' on 3.3 states in part, " Design input-is re-i ouired for items to be designed,' and for design services to be provided (e.g. analysis, design verification).
Design input shall be specified and documented on a timely basis and provide consistent bases for making design decisions, accomplishing design verification, and evaluating design changes."
" Design input shall include the following to the extent applicable:
Design criteria and requirements provided by the client."
Contrary to the above requirements the following items were founii where calculations do not adequately document how design criteria were implemented.
1 In calculation M09-PC01-1017S, BOM item 8 was classified as a shim plate and not analyzed.
However when the lateral support is in tension item
- 8 is a load (tension) carrying-member. and.. requires analysis.
2.
In 'calculati6n FC01-1800s a 3/16" weld all around was specified on a weld to BOM Item 8.
The chart referenced, 5.2.1, from QUAD 7-79-024, lists a 1/4" weld on two sides.
There were no additional calculations to justify the smaller weld size.
It was noted that the weld was veri-fled as acceptalbe during the audit.
In the same calculation, the welds of BOM items #6 to #8 were not analyzed since the des'igner felt that the stresses were negligible.
Is is not clear by observation that the stresse are negligible and that the calculations are not required.
3.
In calculation M09-FC30-1079X the weld between BOM items 3 and 2 were not analyzed since the designer felt the load was negligible.
'The 1200 lb.
faulted Icad was not obviously negligible by observation.
It was noted that this item was verified as acceptable during the audit.
4.
In calculation MC9-PC01-1018V, the shear forces due to torsion were.
regarded as small in the analysis of welds between BOM items 11,12, and 13 to item 2.
It was not obvious by observation that these forces were negligable and that the forces should not be included in the analysis, l
It was noted that the welds were verified as acceptable during the audit.
5.
In calculation M09-FC30-1069 stiffner plate attachment welds were not analyzed since involved stresses were considered to be small.
It is not obvious by observation that these stresses are small enough-to-make the calculations unwarrented.
6 In calculation M09-FC30-1084 no analysis of stiffner plates or their attachment welds was performed.
It is not-obvious by observation that 1
the stresses involved are small enough to make the calculations unwarrentei
~.
1 y
v
yf
.~.,,,.... -- - _... - -...
. An_cuppor calculo uun ruv -.usso a v..
2 - u._
2,
/.. t0.be, was checked using tablo 6.6-2 in QUAD 7-79-024, Safety-Related Pips Support Design Manual.
Neither this table nor any additional y
~
calculations tolok into account seismic forces causing bending in the g
- o..
=
extensa.on.
In support calculation M09-FC30-1079X BOM item 7, a' pipe support exten- @
8 sion tube was analyzed using tables 6.6-2 and 6.6-4 in QUAD 7-79-024.
=.
- Neither these tables nor additional calculations took into account seis-mic forces causing bending in the support extension.
o Findine #9:
Contrary to,10CFR50 Appendix B Criterion III and NSC Q.A. Manual section 3.5.31, inadequate design review has been performed.
Discussion:
10CFR50 Appendix B Criterion III states in. part, "The desigs control 7
measures shall ' provide for verifying or ch,ecking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performanc,e of a suitable test-ing program."
states, " Design reviews shall be suffi-The NSC Q.A. Manual section 3.5 3 1 ciently thorough to:
a.
Verify, the appropriateness of the design input, including assumptions, -
design bases, and applicable regulations, codes and standards. -
b.
Verify that the design is adequate for the intended applic,ation of the
}
design.
Ensure that design characteristics can be controlled in fabrication or c.
construction and verified by inspection, testing or other suitable means.
d.- Ensure that acceptance criteria for. inspection' or testing,are defined.."
Contrary to the requirements listed above, NSC failed to perform adequate design review to identify the deficiencies noted in previous findings numbers 8 thru 16 inclusive.
f.
y e p-m.
,e
~
I
- e 8Pe m.m.
e
+
D fP P D
P
~
O W9 n
! W 1
, CoSannt #1 :
Thero is no LaSalle project procedure describing the format require-ments for ECN's.
The following problems were noticed.
1.
The description of the actual problem is not beingshown on the ECN.
It is being shown as "R'> vision of supports and Restraints" & one has to go through the various attachments to discover what the actual change is.
2.
Many attachments are being enclosed with the ECN.
But no reference to the attachments is being provided in the ECN itself.
3.
The sequential page number of the ECN, project number etc. are not being indicated on the attachments.
4 The names of the commentors and their signatures are not being included on the ECN Form.
5.
The distribution of the ECN is not being show on the ECN.
Some examples of the ECN's examined are:
a.
ECN-NSC-501 approved on 8/25/80 b.
ECN-NSC-629 approved on 9/2/80 c.
ECN-NSC-285 approved on 6/19/80 Comment #2:
On support calculation PC01-1800S the design sheets were not numbered correctly.
References between sheets were not correct.
Comment #3:
Any corrective action for conditions adverse to quality discovered during design work should include an evaluation of previous calculations for effects of said conditions.
B O
e
%.em.