ML20039F024
| ML20039F024 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/28/1981 |
| From: | Danielson D, Yin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20039F012 | List: |
| References | |
| 50-440-81-16, 50-441-81-16, NUDOCS 8201110731 | |
| Download: ML20039F024 (11) | |
See also: IR 05000440/1981016
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Reports No. 50-440/81-16; 50-441/81-16
Docket Nos. 50-440; .,0-441
Licenses No. CPPR-148; CPPR-149
Licensee: Cleveland Electric Illuminating Company
Post Office Box 5000
Cleveland, OH 44101
Facility Name: Perry Nuclear Power Plant, Units 1 and 2
Inspection At: Perry Site, Perry, OH
Inspection Conducted: November 17-20, December 10-11 and 15, 1981
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Inspector;
I. T. Yin
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Approved By:
D. H.. anielson, Chief
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Materials and Processes Section
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Inspection Summary
Inspection on November 17-20, December 10-11 and 15, 1981 (Reports
No. 50-440/81-16; 50-441/81-16)
Areas Inspected:
Followup on previously identified unresolved items; review
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of piping suspension system installation and inspection program, QC inspec-
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tion records, and nonconformance reports; inspection of site small bore piping
design activities. This inspection involved a total of 44 inspector-hours
onsite and at the NRC - Region III office by one NRC inspector.
Results: Of the areas inspected, three apparent violations were identified.
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(Inadequate design control for seismic restraints installed on the emergency
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service water pumps - Paragraph 1.a; Inadequate QC inspection for the emergency
service water pu:ap restraints - Paragraph 1.b. ; Inadequate document control on
luaance of small bore design procedures - Paragraph 2.a.(2).)
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DETAILS
Persons Contacted
Site Inspections Conducted on November 17-20 and December 10-11, 1981
Cleveland Electric Illuminating Company (CEI)
- M. Edelman, Manager, Nuclear Engineering
- R. L. Farrell, Manager, QA
E. Riley, General Supervisor, CQS
J. A. Kline, General Supervisor, Engineering
R. P. Jadgchew, Construction Manager
- I. H. Totas , Manager, PPSD
- d. D. Wahath, Quality Engineering Supervisor
- T. G. Swansiger, Quality Engineer
- J. Eppich, Senior Engineer
- S. P. Tulk, CQE Supervisor
- K. Combs, Senior Engineering Aide
M. A. Brown, Lead Construction Auditor
Gilberts Associates, In. (GAI)
- J. W. Mehaffey, QA Program Manager
- K. R. Pech, Assistant Project Manager
- R. F. Williams, Piping Lead Quelity Engineer
- E. F. Parker, Quality Engineer
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D. E. Dietrich, Piping Engineer
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R. Hollenbeck, Lead Auditor
K. Smith, Hanger Designer
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Pullman Power Products (Pullman)
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J. Miller, QA Manager
J. Stelle, AQAM
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R. Hunnicutt, QA Supervisor
C. Thomas, Hanger Engineer
R. Walter, Resident Construction Manager
Kaiser Engineering, Inc. (KEI)
M. E. Noffsinger, Construction Manager
- P. L. Gibson, Project QA Manager
- J. S. Kerr, Supervisor, CQSS
- Denotes those attending the management exit interview on November 20, 1981.
Region III Meeting with Licensee held on Dece3ber 15, 1981
M. Edelman, Manager, Nuclear Engineering
R. L. Farrell, Manager, QA
E. Riley, General Supervisor, CQS
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GAI
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K. - R. Pech, Assistant Project Manager -
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R. F. Williams, Piping Lead Quality Engineer
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E. F. Parker,-Quality Engineer
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USNRC - Region'III-
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C. E. Norelius, Director, Division of Engineerina and Technical Inspection
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.C. C. Williams, Acting Chief, Engineering Inspection Branch
D. H. Danielson, Chief, Materials and Processes Section
L. McGregor, Acting Chief, Projects _ Section
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I. T.~ Yin, Reactor Inspector
Licensee Action on Previous Identified Items
(0 pen) Unresolved Items (440/81-13-01; 441/81-13-01; 440/81-13-02;
441/81-13-02): Questionable QC inspection program. Further discussions were
acid with the licensee representatives. The licensee committed to total up-
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' grading of the subject program.
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(0 pen) Unresolved Item (440/81-13-03; 441/81-13-03):
Control of concrete
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expansion type anchor bolts submerged in water. The inspector reviewed the
GAI letter (PY-K&H/CEI-4697) to CEI, dated November 6, 1981, where it stated
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that there were no cafety-related pipe anchors installed underwater. During
the managment exit meeting the licensee stated that four support brackets
were installed in the water with concrete expansion type anchor bolts. and
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that evaluation for adequacy of the installation had been initiated.
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(Closed) Unresolved Item (440/81-13-04; 441/81-13-04): Control measures to
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upgrade nonsafety-related systems. The inspector reviewed ECN 3945-45-91,
dated February 15, 1980, and ECN 2982-45-58, dated October 3, 1979, relative
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to the augmented QA inspection program for the fire protection system and
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the N-64 off gas system. These requirements vere recommended by NRR Branch
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Technical Positions; however, the systems involved were not required to be
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upgraded to the safety-related system category.
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(Closed) Unresolved Item (440/81-13-05; 441/81-13-05): One ECN was found not
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included in the construction drawing at the work station. 'The inspector
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reviewed the CEI Program Audit Report No. 556, audit of Pullman at the site
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during August 5-18, 1981, and the Pullman Process audit, QA Site Internal
Audit Report No. QASS-2, dated October 1, 1981, and considered the licensee
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measures to be adequate.
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.(Closed) Unresolved Item (440/81-13-06; 441/81-13-06): Specific training
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to be provided for the working level piping suspension system installers.
The inspector revi'ewed training records conducted on October 24, 1981 and
October ~31, 1981 at the site for the foreman, genera 1Eforeman, field engineers,
superintendents, quality engineers. The training was entitled, " Quality,
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Pullman's Promise,.Everyone's Concern." The specific support and restraint
installation instructions were discussed in Session No-. 6, " Pipe. Hangers /
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Support' Indoctrination," and Session No. 7, " Installation / Fabrication of
Piping (including acceptable tolerances)."
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Functional or Program Areas Inspected
1.
Installation of Emergency Service Water (ESW) Pumps
The inspector reviewed installation and inspection records of the
rollowing safety-related reismic restraints installed at the vertical
pumps inside the Emergency Service Water (ESW) Building:
ESW Screen Wash Pumps
Pump P49-C00A
Restraint IP49-H001 (12" dia. at shaft flange)
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Restraint IP49-H002 (12" dia. at shaft flange)
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Pump P49-C002B
Restraint IP49-H003 (12" dia. at shaft flange)
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Restraint 1P49-H004 (12" dia. at shaft flange)
Large ESW Pumps
Pump 1P45-C001A
Restraint IP45-H397 (35" dia. at pump flange)
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Restraint IP45-H398 (34" dia. at pump flange)
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Pump 1P45-C001B
Restraint IP45-H399 (35" dia. at pump flange)
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Restraint IP45-H400 (34" dia. et pump flange)
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Pump 2P45-C001A
Restraint 2P45-H037 (35" dia, at pump flange)
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Restraint 2P45-H038 (34" dia. at pump flange)
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Pump 2P45-C001B
Restraint 2P45-H039 (35" dia. at pump flange)
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Restraint 2P45-H040 (34" dia. at pump flange)
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Small ESW Pumps
Pump 1P45-C002
Restraint IP45-H401 (14.5" dia. at pump flange)
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Restraint IP45-H402 (12.5" dia. at pump flange)
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Pump 2P45-C002
Restraint 2P45-H041 (14.5" dia. at pump flange)
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Restraint 2P45-H042 (12.5" dia. at pump flange)
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All the restraints were inspected and accepted on October 13, 1980
except 2P45-H037 which was accepted on October 30, 1980. The instal-
lation and inspection of these restraints were basad on Pullman Perry
Project Procedure IX-6, " Installation and Inspection of Section III
Pipe Supports," dated. July 25, 1980.
Subsequent to the review, the inspector stated that he had the following
findings:
a.
Inadequate Design Control
(1) The pump installation drawing, GAI No. 4949-22-017-4 (Gould
Pumps Drawing D2326, dated September 14, 1976), showed that
clearance between the pump flanges and the seismic restraints
should be 3/16" all around with tolerance given in Note 3 of
the drawing.
"Telerance on all dimensicas is
1/8"..."
GAI
Field Engineer contacted the Gould Company and revised the
tolerance to i 1/16" and - 3/16" through a Field Question (FQ)
No. 7952, dated June 19, 1980. Neither the Gould or FQ gap
tolerance conformed with the Pullman's Procedure IX-6 require-
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ment of maximum gap on seismic restraints to be 1/8" (in
comparison with maximum of 1/2" per the FQ and maximum of 5/8"
per Gould).
Such deviation was not reviewed and approved by
the GAI design engineering organization.
(2) In review of the installation packages, it was identified that:
(a) carbon steel bolts and studs were installed for underwater
use without material protective coatings,
(b) there was no requirement for installation and QC inq ection
to ensure full thread engagement at the sleeve nuts embedded
into the concrete, and
(c) torquing was not specified for t;.e sleeve nut stud instal-
lations, that were subject to loosening under vibratory
operating and seismic conditions.
This is an apparent violation identified in Appendix.
(440/81-16-01;
441/81-16-01)
b.
Inadequate QC Inspection
The inspector reviewed the QC inspection packages dated October 15,
1980 for the pump seismic restraints and found no detailed inspec-
tion checklists and/or measurements. A subsequent field engineering
inspection for Restraint IP45-H399 conducted on December 3, 1980
measured some of the gap clearances between the pump flange and the
restraint to be in excess of 0.25".
This was in nonconformance with
the Pullman Procedure IX-6, Paragraph 8.4.1.1, which states in part
that, " Clearance dimension for a given restraint direction...to 1/8"
maximum. Any combination adding (up to) 1/8" is permissable for
maximum tolerance."
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This is an spparent violation identified in Appendix.
(440/81-16-02;
441/81-16-02).
c.
Questionable Gould Pump Seismic Analysis
The design SSE loads for the seismic restraints installed on the
Gould pumps were as follows:
2P45-H037 and H039 18,254 lbs.
2P45-H038 and H040 26,836 lbs.
2P45-H041 760 lbs.
2P45-H042 838 lbs.
1P49-H001 and H003 624 ibs.
IP49-H002 and H004 350 lbs.
Sussequent to review s: the Gould stress analysis report, the
inspector had the following questions:
(1) The analysis is based on Gould vertical pump model VIT 20 x 30
BLC 2 stage. The design representation and modeling technique
for all these types of Gould vertical pumps required further
review and evaluation. Further review was conducted at the
site on December 10-11, 1981, where stress reports for all
three different types of pumps were presented to the inspector.
See Paragrapa 3.b. of this report for details.
(2) Paragraph 4.5 of the report stated that, "The pump is analyzed
for 3/16" radial clearance at supports located at Joints 11 and
13," and yet zero displacements were observed in computer output
at these joints. Subsequent review conducted at the site on
December 10-11, 1981, where Report No. ME-454, Loading No. 4
showed one restraint movement of 3/16" and the second restraint
movement of - 3/is".
The inspector stated that the loss of
motion within the restraint gaps was not modeled in the computer
calculation. However, in discussion with the GAI Assistant
Project Mar.ager, he agreed that the restraints will be in-
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spected to verify that the maximum total gaps along a diameter
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should not exceed 3/16".
2.
Site Small Bore Piping Systems Desi_gn
During the November 17-20, 1981 site iuspection, the inspector reviewed
the subject matter and discussed the design criteria and acceptance bases
thraugh telephone discussion with the GAI Projec*. Piping Analyst. The
present site design responsibility was restricted to 2" diameter and
under piping systems 250 F and below design temperature. -Any systems
above 250 F, analyses are to be performed at GAI home office, and the
resulting load summary sheets will then be sent to the site for the
suspension system design and installation.
a.
Design Procedure Review
The following procedures were reviewed by the inspecter:
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(1) GAI Report No. 1962, "Sesimic Support Spacing Criteria,"
Revicion 2, dated May 26, 1981.
Paragraph 4.01, " Piping Design Criteria" in conjunction
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with C.1 series design tables provided maximum spacing,
deadweight, and seismic reaction forces design informa-
tion for various pipe sizes and schedules.
In discussion
with the Project Piping Analyst, it was stated that the
design table included water, insulation and stress
intensification factors, ex.
i = 2.1 for socket weld
joint for 2" and under piping, and that pipe spans were
generated by computer calculations based on response
spectra developed for different building structures.
Thermal stress considerations were provided in Para-
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graph 6.1, " Thermal spacing consideration (for both
C.S. and S.S materials);" Fig.
A-11, " Guided Cantilever
Chart"; and the sample calculations were contained in
Appendix A of the procedure.
No items of noncompliance or deviations were identified.
(2) GAI Attachment Specification SP-208-4549-00, " Technical
Requirements for Furnishing and Installing Hilti Kwik
Bolts," dated June 26, 1978. This is a part of the GAI
SP-44, " Installation of Safety Class Pipe," providing
requirements for installation, inspection, and test re-
quirements for the wedge type concrete expansion type
anchor bolts.
In review of the site procedures developed based on the
above specification, the following two noncompliances were
identified:
Memo from R. R. Brems to Distributien, "Use of Concrete
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Fasteners on Perry," dated December 5,1977, which was
included in the Piping Engineering Department Perry
Project Instruction, Section C - Support Design, had
not been approved for use.
In fact, the whole Section C
was without issuance, review, approval, and revision
control.
Hilti bolt design allowables developed at the site on
March 13, 1980 was without the same type of document
control provision as discussed above.
This is an item of violation identified in Appendix.
(440/81-16-03;
441/81-16-03).
b.
Design Personnel Qualification
The design personnel qualification verification procedure was
provided in GAI Management Policies and Procedures, No. V-04,
Subject: Employee Relations, Title:
" Educational and Employment
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Verification and Security Investigation," dated June 1, 1981.
The inspector reviewed the procedure, some of the employee's
resumes, and PNPP site design team indoctrination and training
records, and had no adverse comments. At the time of the
inspection, there was no contract employee working in the small
bore piping design group at the site.
3.
Meetings on December 10-11, 1981 at the Site
The inspector met with the site responsible staff on December 10-11, 1981
to discuss the problem areas identified during the inspections conducted
during November 17-20, 1981. Specific discussion areas included:
a.
Review of the Upgraded Procedure
The Pullman Power Products piping suspension system installation
and inspection procedure IX-6 was upgraded to provide timely in-
process hanger installation inspection requirements. The inspector
reviewed the draft copy of the procedure and had the following
comments:
(1) Phase II inspection should not be conducted until satisfactory
resolution of all the deficiencies identified in Phase I in-
spection.
Likewise, Phase III inspection should not precede
Phase II inspection deficiency resolution.
(2) Warning tags should be installed on the component assemblies
subsequent to the Phase II inspection acceptance to prevent
alteration and removal.
(3) Permanent identification tags should be installed subsequent
to the Phase III inspection acceptance for future ISI purpose.
(4) Statements should be added stating that no Hilti Drop-In type
concrete expansion anchors will be used in safety-related piping
systems.
(5) Torquing requirements stated in Paragraph 8.5.10 are for Hilti
Kwik bolts only.
(6) Minimum time required to soak the unused anchor bolt holes
before placement of grout should be specified in Paragraph 8.6.2.
(7) Reistive to Paragraph 11.0, " inspection," maximum time frame
should be determined between the completion of the hardware
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installation and the beginning of QC inspection.
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The inspector further commented that consideration should be given
to developing a trend analysis procedure to work in conjunction with
Procedure IX-6.
An overview procedure in accordance with the IEB 79-14 requirements should be in place prior to system turnover for
pre-operational and startup tests.
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b.
Review of Gould Pumps, Inc. (GPI) Reports
The inspector reviewed the following Seismic. Analysis Reports
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provided by GPI for the vertical pumps installed in the emergency
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service water pump house at-Perry site. These reports were pre-
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pared by Mcdonald Engineering Analysis Company, Inc.
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ME-452 for flodel VIT Size 6x8 JLC Three Stage Screen Wash Pumps,
September 12, 1977.
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ME-453 for Model VIT 8x12 JMC-5 stage small service water pumps,
September 16, 1977.
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ME-454 for Model VIT 20x30 BLC-2 stage large service water pumps,
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September 20, 1977.
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In review of ME-454 and in discussion with GAI's Mechanical
Engineer - Seismic Qualification Specialist, the following
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questionable areas were identified:
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In comparison with GPI drawing D2324, dated December 7, 1978,
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where punp weight of 16,875 lbs.
flooded and 12,720 lbs. dry
were stated, the computer input pump wieght model showed
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18,683 lbs., and the output showed pump weight of 14,221 lbs.
The centerline of masses on the pumps and on the motor were
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not shown on the'GPI drawing.
The GAI developed building structural response spectra were
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not attached to the report.
The GPI report showed no documentation on review, verification,
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approval and acceptance of the stress analysis.
Because of the identification of these questionable areas and the
previously discussed problems (in Paragraph 1 of this report) the
inspector requested the following materials for his review:
(1) GAI Specification SP-750-4549-00, Revision 1, dated March 11,
1974, and SP-501-4549-00, Revision 2, Sections 2 and 3, dated
November 11, 1976,which provided the design and acceptance
criteria.
(2) Documentation on GPI review of the Mcdonald reports, and GAI's
acceptance of the report in representation of the licensee.
(3) GAI program procedures, from 1977 to present, established for
the review of vendor equipment seismic analysis reports.
This is considered to be an unresolved item.
(440/81-16-04;
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441/81-16-04)
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c.
Site QA Audit of Nonconformance Report (NR) Closeouts
During site inspection conducted on November 17-20, 1981, it was
brought to the inspector's attention by the Construction Quality
Engineer that some of the Pullman NRs were closed without verifi-
cation that rework or repair had been completed. The problem was
discussed in the site Audit Report No. 543, dated June 18, 1981.
Subsequent to the inspector's visit, site QA organization performed
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another audit from November 30, 1981 to December 3, 1981. Thirty
closed Pullman NRs were chosen for review to determine whether or
not there was documentation and evidence to support the closeouts.
Six Action Requests (ARs) were issued as a result of the audit.
Pullman QA was instructed to review all the previoi+,1y closed NRs
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before January 1, 1982. Followup on lice nsee resolution of the
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subject matter is planned. This is considered to be an unresolved
item.
(440/81-16-05; 441/81-16-05).
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4.
Management Meeting on Decmeber 15, 1981 at the NRJ-Region III Office.
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A meeting was held to discuss the upgrading of the licensee's piping
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suspension systems installation and QC inspection program, and the
licensee's planned actions relative to the resolution of problem areas
identified during this inspection. The agenda for the licensee pre-
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sentation and discussion was as follows:
a.
Plans to upgrade the existing piping support program to include
modified checklists, establish periodic assessment program to
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reverse adverse trends, and provide for prompt action to identify
nonconforming conditions and initiate immediate corrective action.
b.
Plans to improve the QA program as it relates to small bore piping
systems including issuance, review and approval of instructions,
and design basis and acceptance criteria.
Increase technical audits
in this area to assure compliance.
c.
Plans and schedules to:
(1) Reinspect or inspect, as applicable, all safety-related
supports to the upgraded procedures (new checklists, etc.).
(2) Review for design acceptability all previously completed
small bore piping systems that were installed without approved
engineering procedures.
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(3) Perform a joint QA/ Engineering audit of Gould Pumps, Inc. for
design control and stress analysis in February 1982. NRC will
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be in attendance.
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d.
Audit of contractor verification and closeout-of nonconformance
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reports.
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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. 'Two unresolved items disclosed during the inspection are discussed
in Paragraphs 3.b. and 3.c.
Exit Interview
The inspector met'with licensee representative.o at the conclusion of the
inspection. The inspector summarized the scope and findings of the inspection.
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The licensee acknowledged the findings reported herein.
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