ML20040F554
| ML20040F554 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20040F550 | List: |
| References | |
| REF-QA-99900525 NUDOCS 8202090337 | |
| Download: ML20040F554 (3) | |
Text
Gilbert / Commonwealth Docket No. 99900525/81-03 APPENDIX A NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on October 13-16, 1981, it appears that certain of your activitics were not conducted in full compliance with you commitments as indicated telow:
A.
Gilbert / Commonwealth 10 CFR Part 21 report to NRC (Reportable Defect -
Containment Penetrations Anchor Plates) dated April 28, 1981, states in part, "... anchor and barrier plates, which attach piping to the Class MC containment penetration sleeves, were not impact tested or normalized (depending on thickness) as required by the ASME Code,Section III, Subsection NE, paragraph 4431... Specification SP-527-4549-00 has been revised (Revision XI, dated April 8, 1981) to specifically address the material requirements for the assemblies...."
Contrary to the above, Revision XI of Specification SP-527-4549-00 does not specifically address the material requirements for the assemblies as committed, in that Section 2.05.4 of Revision XI states that containment piping penetration anchor plates and barrier plates shall be furnished in accordance with Section III, Subsections NC and NF, respectively, neither of which specifically require meeting paragraph 4431 of Subsection NE of the code as required for items which are permanently attached by welding to pressure retaining material (the containment penetration sleeves).
B.
Sections 3.1 and 3.2 of committed standard ANSI N45.2.11-1974 state in part, " Applicable design inputs, such as design bases, regulatory requirements, codes and standards, shall be identified, documented, and their selection reviewed and approved... the design input shall include... design conditions such as pressure... environmental conditions anticipated during storage, construction and operation...
operational requirements under various conditions, such as... system abnormal or emergency operation... (and) material processes, parts and equipment suitable for applications...."
Contrary to the above, certain design specifications did not include as design input, design conditions such as pressure, environmental conditions anticipated during construction and operation, operational requirements under various conditions such as system abnormal or emergency operation, or material processes, parts and the suitability of the equipment for application.
Specific examples of this nonconformance are as follows:
8202090337 B20122 PDR GA999 EECQB AS 99900525 PDR
ll L
e
+-;
Gilbert / Commonwealth 2
Docket No. 99900525/81-01 1.
Specification 597-044461-00, used to procure the sodium hydroxide liquid storage tank for V. C. Summer, Unit 1, did not identify as design input that the design pressure conditions included operation under a negative pressure differential (vacuum) during system abnormal or emergency operation.
Furthermore, the revised design operating pressure range for the installed storage tank, as defined in the current revision (Revision 1 dated April 21, 1981) of Specification 597-044461-00, is not within the range of:
(1) the design pressure limitations defined in the ASME Code (ND-3821.1);
(2) the pressures certified in the manufacturer's data report (ND-3812); and (3) "N" stamping of the tank itself (NA-8000).
2.
Specification 592-044461-00, used to procure the vacuum relief valves for the above sodium hydroxide liquid storage tank, did not identify as design input, that: (1) the valves must withstand and remain functional under the anticipated range of outdoor environmental conditions; (2) the valves must remain operational for system abnormal or emergency operation after a design basis seismic event.
3.
Revisions 0 through XI of specification 527-4549-00, used to procure certain piping spool pieces with integral anchor and barrier plates which subsequently are welded to ASME B&PV Code Class MC containment penetration sleeves of the Perry Nuclear Power Plant, Units 1 and 2, did not identify as design input that; a.
The mechanical penetration primary barriers are to be designed, fabricated, tested, and inspected in accordance with ASME Code,Section III, Class MC (Subsection NE) as committed in paragraphs 3.8.2.L 6.a.8 of the PSAR and 3.8.2.1.6.a.7 of the FSAR.
1 b.
The material selected for fabrication of containment penetration anchor and barrier plates must be required to be impact tested or normalized in accordance with paragraph NE-4431 of the ASME Code in order to be considered suitable for its intended application.
c.
Criterion 51 of Appendix A to 10 CFR Part 50 was applicable to the containment penetration and anchor plates and their weldments.
i C.
Criterion V of Appendix B to 10 CFR Part 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acc'eptance criteria for determining that important" activities have been satsifactorily accomplished."
,3 i
Gilbert /Commonweatlh 3
Docket No. 99900525/81-03 Nonconformances from these requirements follow.
1.
-Tennessee. Valley Authority procedures CEB-SQN-100 (Guidelines for Design of Component Supports for TVA Classes A through D), SQN-DC-V-13.3 (Detailed Design Criteria for Detailed Analysis of Category One Systems),
and the Sequoyah Nuclear Power Plant Checking Procedure I, provide detailed criteria for the design, analysis, and checking of safety-related piping systems for Sequoyah 2.
These procedures require that the stress analyst identify and note on the system stress isometric drawing, and that the checker verify the presence of the note, when the spatial orientation of the local coordinate system actually used for the piping stress analysis / calculation at an individual piping node point is different from the conventional method for orienting local coordinate systems.
Contrary to the above, the analyst did not identify nor note on the affected piping system stress isometric drawing 47K-406-128, that the positive direction of the X-axis of the local coordinate system (used in calculation number 0600154-08-17) was reversed from the conveniional direction on stress isometric drawings..Further, the checker failed to detect and record the absence of the note on the drawing during the required check of the system design and analysis.
2.
Section 4.1.4 of the V. C. Summer Design Control Program Procedure 4.2.1 (Revision 5 dated March 1, 1977) states in_part that, "the analysis / calculation shall note information scch that the verifier can understand the analysis and verify its results without recourse to the originator.
Such information includes... purpose or objective...
design inputs and their sources...."
Contrary to the above, Mechanical Department Calculation _13.19 dated June 11, 1981, did not note the specific purpose or objective of the calculation; i.e., to confirm that the as-built' sodium hydroxide liquid storage tank for V. C. Summer, Unit 1, could withstand a nominal. negative three PSIA pressure differential, nor note the source of certain design inputs; i.e., the source of the three. PSIA ~ pressure differential and the range of atmospheric pressure-variation, that'were used in the calculacion.
w O
v