ML20041F711
| ML20041F711 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/05/1982 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8203170323 | |
| Download: ML20041F711 (10) | |
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March 5, 1982 m 4ce2 Mr. James P. O'Reilly, Regional Adninistrator U. S. Nuclear Regulatory Commission A
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c '((f"! %r,. 0.l 7 7 Re: Catawba Nuclear Station l
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Units 1 and 2
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Docket Nos. 50-413 and -414 fp?.!]Y M D
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Dear Mr. O'Reilly:
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- / l i,4 Pursuant to 10 CFR 50.55e, please find attached Significant Defic ency Report SD 413-414/82-04.
Very truly yours, l/
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6c William O. Parker, Jr RWO/php Attachment cc: Director Mr. Robert Caild, Esq.
Office of Inspection and Enforcement Attorney-at-Law U. S. Nuclear Regulatory Commission 314 Pall Mall Washington, D. C. 20555 Columbia, South Carolina 29201 Mr. P. K. Van Doorn Palmetto Alliance NRC Resident Inspector 2135 Devine Street Catawba Nuclear Station Columbia, South Carolina 29205 OFFICIAL COPY 8203170323 920305 y
PDR ADOCK 05G00413 S
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION Report No.: SD 413-414/82-04 Report Date: March 5, 1982 Facility: Catawba Nuclear Station Units 1 and 2 Identification of Deficiency:
Interpretations of the erection specification (Procedure Requirements for Fabrication and Erection of Hangers, Supports and Seismic Controls, CNS-1206.00-04-0003 Rev. 6) may have been made during construction of piping supports which did not carry out the intent of the design documents.
Component and/or Supp_ lier:
Component supports erected by Duke Power Company on safety related piping throughout the Reactor and Auxiliary Buildings.
Description _of Deficiency:
It was reported via NCI 13841 that various tolerances given for supports may have been inappropriately interpreted by parties involved in design and erection of piping supports.
Twelve items were specifically addressed as areas of misunderstanding. Reference copy of NCI 13841 (attached) for listing of these items. The net effect of this action may have resulted in the use of tolerances or options not fully accounted for or evaluated.
Analysis of Safety Implications:
As stated in the initial report (Re: Telecon report to J. Bryant by W. O. Henry 2/3/82): The safety significance of the problem cannot be determined without the identification of specific piping supports crected outside the intent of the erection specification and an evaluation of the as-erected supports. In general, it is expected that any deviations are minor and of no safety sig-nificance, but due to uncertainty, it must be assumed that there may be an item of safety significance. To date, only a limited sample, approximately 315 supports, have been reviewed for the Catawba Station. Although dis-crepancies have been found which do violate the latest revision of the crection specification, no items which would impair the function of the supported piping have been identified and only limited physical rework of supports is required. Most discrepancies found can be resolved through specification, calculation or drawing revision to the "as-erected" condition.
The review of this nonconformance by organizations responsible for design of other Duke Power Company nuc1 car units has also been performed.
After review of the specific items of the Catawba nonconformance and dis-cussions relating to these items and any other possible concerns, it has
. been determined that tolerance misinterpretation is not a problem for the McGuire Station and no further action is required.
A review for the Oconce Nuclear Station has not identified any specific cases of tolerance specification misinterpretat'ons. If further review turns up any items of nonconformance, these will be handled in accordance with Oconee NCI/NSM procedures.
Corrective Action:
For the Catawba Station, the following corrective actions either have been or are going to be taken. These items serve to complete actions required to close out this item for Catawba.
Specification CNS-1206.00-04-0003 Rev. 7 was issued January 22, 1982 to clarify questions raised as identified by NCI 13841. Upon issuance, design personnel participated in initial training of Construction personnel to ensure that the intention of items addressed by the specification was clear.
Support / Restraint designs for Catawba Units 1 & 2 have been considered in view of tolerances available in Specification CNS-1206.00-04-0003 Rev. 7.
All tolerances given in the specification have been either specifically addressed in the calculations or evaluated as being within the limits and accuracy of design calculations.
Specific actions necessary for final resolution of this non-conforming item are as follow:
(1) All documents pertaining to supports erected and inspected to criteria prior to initiation of this nonconforming item will be reviewed. This review will determine which supports have the potential for violation of criteria established by the revised specification (Procedure Require-ments for Fabrication and Erection of Hangers, Supports and Seismic Controls, CNS-1206.00-04-0003, Rev. 7 or subsequent revisions).
(2) For those supports which have the potential for violation of criteria established by the revised specification, physical inspection of the support will be performed, recording sufficient measured data for the individual support to establish the actual "as-erected" condition. These measurements will be evaluated against criteria established by the revised specification. For those supports which meet applicable criteria, no further action is required.
(3) For those supports which violate applicable criteria, the support will be reworked to meet the criteria whenever practicable.
These supports will be inspected by QC/QA to appropriate inspection procedures.
(4) For those supports for which rework is not practicable, the "as-crected" configuration and any supporting information will be provided to Design Engineering for resolution.
_3 (5) For those supports submitted to Design Engineeering, information pro-vided will be considered in the design.
If such information shows the configuration to be acceptable, the calculations will be reconciled to reflect the "as-erected" configuration and drawings will be revised and reissued to reflect this information. For any supports which are unacceptable "as-erected" a new or revised configuration will be provided by standard means of calculation and drawing issue.
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DUKE POWER COMPANY STATION / PROJECT:
CATAWBA UNIT 1 NONCONFORMING ITEM REPORT SERI AL NO. / 3F#/
SHEET #1 During discussions between Support / Restraint Design Personnel, S/R Technical Support Personnel and others involved in the design, installation and inspection of supports, two general problems or items which require Investigation have been found.
The Support / Restraint Designs may not alwa~ys take into consideration all the tolerances aval lable in spect flcation CNS-1206.00-04-0003.
During the solution of field problems, certain tolerances given in the speci fi-cation were liberally interpreted by Site Design, Charlotte Design, Technical Support, and C raf t personnel.
In addition, QC personnel inspected the supports In accordance with these interpretations.
Based on a preliminary investigation the specific potential problems or items which requi re further investigation include but are not limited to the following:
1)
Supports where the design required a minimum weld length on attachments to embedded plates,but a minimum weld length was not speci fled on the weld symbol, 2
since our program was not set up to calculate the required weld length.
2)
Supports where gaps were required by the design between the piping and the support and the gap was not directly shown.
Our program did not calculate the intended gap and then hold it to the appropriate tolerance.
In addi tion, supports which require gaps of 1/8" or 3/16", since those gaps are not addressed in the specification.
3)
Supports where construction increased the lengths of more than one member in a support by more than the minimum tolerance of + 1/8".
This applies to all "L", "C" and other complex cantilevers.
In addition, any support that is now defined as a f rame but was installed using tolerances greater than 11/8".
This includes frames shown on a single drawing and frames made up of more than one drawing.
Also, trapeze supports where dimensions V, W, or X were not held and/or where the support was Installed utilizing material length or other tolerances.
- 4) Two bolt anchor plates where washer shims were used.
5)
Supports where the pipe clamps do not tightly fit to the pipe and for which a speci fic exemption is not allowed by the new proposed specification.
6)
Supports which have two pipe attachments and where those attachments have been moved or switched by use of the axial tolerance.
7)
Braced cantilever supports where 0, X, and Y were shown on the design sketch and where construction held Y instead of calculating and holding L.
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DUKE POWER COMPANY STATION / PROJECT:
CATAWBA UNIT 1 NONCONFORMING ITEM REPORT SERI AL NO. /364/
SHEET #2
- 8) Unbraced cantilever supports which were lengthened by an amount greater than 2" (from the 13 cantilever tolerance) but were shorter than 20" and thus violated the + 2" material length tolerance.
- 9) Any supports in which filler plates shown on the sketch were increased by more than 1" or where the filler plate tolerance was applied to items such as base plates for which it was not intended.
10)
Supports which use terminology such as cut to fit or mitre to fit.
11)
Supports where the anchor plate overl of embedded plate tc.erance was used on:
A)
Embedded plates other than type 1 or 2 B)
Anchor plates other than 4 bolt.
C)
Anchor plates on class 1, SH or CF supports without contacting Design.
12)
Supports which.speci fy angles (other than braced cantilevers) and where the angle was not held per Par. 7.5.1 of the speci fication.
N Host commonly the installation and inspection practices allowed tolerances up to 13" where 11/8" was intended.
Preliminary indications are that the scope of potential rework is low. However, discussions have Indicated that.a large number of supports will require review.
The scope of this NCI is limited to all supports installed and/or inspected prior to implomantation of Revision 7 of spe.cification CNS 1206.00-04-0003 currently unde r deve lopment. -DosL n-Engineer-ing-wL11 hays-the-new-revis ion-released-to-3 Construction-by and-Cons t-ruc t ion -/QA wi-I-1, imp l e men t-t he-re vi s i on-by-
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Attachment flCS flumber 13841 Page 6 of Specification CilS-1206.00-04-0003 Rev. 7 was issued Jan. 22, 1982 to clarify questions raised as identified by f1CI 13841.* Upon issuance, design personnel participated in initial training of Construction personnel to insure that the intention of items addressed by the specification was clear.
Support / Restraint designs for Catawba Units 1 & 2 have been considered in view of tolerances available in Specification Cf1S-1206.00-04-0003 Rev. 7.
All toler-ances given in the specification have been either specifically addressed in the calculations or evaluated as being within~ the limits and accuracy of design cal-culations.
Specific actions necessary for final resolution of this non-conforming item are as follows:
(1) Construction shall review all documents pertaining to supports erected and inspected to criteria prior to initiation of this non-confoming item.
This review shall detemine which supports have the potential for violation of criteria established by the revised specification (Procedure Requirements For Fabrication and Erection of llangers, Supports and Seismic Controls,CflS-1206.00-04-0003, Rev. 7 or subseqiie~nt revisionsf.
(2) For those supports which have the potential for violation of criteria established by the revised specification, physical inspection of the support will be per-fonned, recording sufficient measured data for the individual support to esta-blish the actual "as-erected" condition. These measurements shall be evaluated against criteria established by the revised specification.
For those supports which meet applicable criteria, no further action is required.
(3) For those supports which violate applicable criteria, Construction will rework the support to meet the criteria whenever practicable.
These supports will be inspected by QC/QA to appropriate inspection procedures.
(4) For those supports which Construction judges rework is not practicable, the "as-erected" configuration and any supporting information will be provided to Design Engineering for resol _ution.
(5)
For those supports submitted to Design Engineering, information provided will be considered in the design.
If such information shows the configuration to be acceptable, the calculations will be reconciled to reflect the "as-erected" configuration and drawings will be revised and reissued to reflect this infor-mation.
For any supports which are unacceptable "as-erected" a new or revised configuration will be provided by standard means of calculation and drawing issue.
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