ML20054C300
| ML20054C300 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/03/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20054C294 | List: |
| References | |
| NUDOCS 8204200325 | |
| Download: ML20054C300 (42) | |
Text
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N Commonwoolth Edison i / one First NLtiorni Plua, Chicago, Illinois V
Address Reply to: Post Office Box 767 Chicago, Illinois 60690 4
March 3,-1982 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and i
Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Zion Station Units 1 and 2 Response to I.E.
Inspection Report Nos. 50-295/81-28 and 50-304/81-26 NRC Docket Nos. 50-295 and 304 Reference (a):
January 28, 1982, letter from C. E.
Norelius to Cordell Reed.
4 i
Dear Mr. Keppler:
j Reference (a) contained the results o f an inspection 2
conducted by Mr.
I.
T. Yin of your office on December 1-2, 1981, at Stone & Webster Engineering Corporation, New York, N.Y., o f activities pertaining to Zion Station.
During that inspection, i
certain activities appeared to be in noncompliance with NRC requirements.
At Commonwealth Edison's request, meetings were held at our Corporate o ffice on December 8, 1981, and at the NRC Region III Of fice on December 21, 1981, to discuss the items in question.
At those meetings, Commonwealth Edison stated the belief that these items did not constitute violations with respect to the requirements of I.E.Bulletin 79-14.
In addition, Commonwealth Edison agreed to consider what additional measures or analyses could be undertaken to address the NRC's concerns.
That information was related to the NRC 2
in a conference call held on February 1,1982.
This letter provides a summary of Commonwealth Edison's position.
For reference, the NRC's Notice of Violation contained in reference (a) is provided as an attachment to this letter.
4 j
A copy o f this letter was previously transmitted to Mr. D.
Danielson o f your o f fice on March 1,1982.
Slotted Seismic Restraints i
Commonwealth Edison does not believe that the use o f i
slotted seismic restraints constitutes a violation o f NRC l
8204200325 820416 DR ADOCK 05000295 MAR 5 E62 PDR
1 J.
G. Keppler March 3, 1982 requirements.
I.E.Bulletin 79-14 required that the as-built pipe systems be compared to the as-designed systems, and where deviations occurred the as-built condition should be reanalyzed utilizing original design criteria.
Stone and Webster Engineering Corporation has, in accordance with the bulletin, performed reanalysis of safety-related piping systems where the as-built condition did not agree with the as-designed condition.
This reanalysis utilized the original aesign criteria, as estaolished by Sargent and Lundy, as a basis for aetermining pipe and pipe support stresses.
The use o f slotted seismic restraints was provided for in the original design criteria.
Given that all safety related piping systems are to be reanalyzed to reflect the as-built condition, and also given the large safety margin inherent in the original design ano the associated criteria, we believe the original design criteria are adequate.
In order to provide justification for the above statement, Commonwealth Edison requested Sargent and Lundy to provice an assessment of the safety margin inherent in the design o f Category I piping systems.
This assessment is included as Attachment A and provides an approach which demonstrates that a sufficient safety margin exists in safety-related piping, where gaps of up to 5/8 inch are present in the piping system supports.
In addition to this assessment, Commonwealth Edison is performing a study to assess typical subsystems dynamic performance during an earthquake for cases where gapped supports 5/16 inch or more are installed.
Tnis study is being performed in the f ollowing sequence:
1.
Three subsystems will be selected, to represent the entire piping systems with gapped supports, for this assessment.
To ensure that the selected subsystems are representative enough, the selection will take into consiceration:
a.
The selected suosystems will De located in dif ferent plant buildings and on dif ferent elevations.
b.
Each subsystem will contain dif ferent numbers o f gapped supports.
c.
A wice range of pipe sizes as well as gap lengths will be covered in the selected subsystems.
2.
The floor response time histories will De generated from the corresponding response spectra o f the selected subsystems.
a e
J.
G. Keppler March 3, 1982 3.
An assessment will be made to evaluate a more realistic average value for the damping parameter taking into ef fect the friction resistance that accompanies the sliding motion of the support pin through its slot.
This motion is assumed to occur when the piping system responds dynamically to an earthquake.
4.
With the generated floor response time histories and the realistic damping parameter, a non-linear analysis will be performed using the ANSYS program.
The resulting pipe stresses will then be checked against the Code allowables.
Also the piping system support loads will be checked against the maximum support load capacities.
It is expected that by chosing test subsystems in such a way as to adquately envelope the problem, the analysis will show that the piping stresses meet Code allowables and that the pipe supports can carry the loads generated.
These results will then be carefully generalized to include as many of the gapped subsystems as possible and show that these subsystems are acceptable in their present configuration.
The following is a catagorization and summary of the number of gapped subsystems involved in the currant assessment for Zion Station.
Total numoer o f subsystems 408 Total number of subsystems with gapped supports 181 Total number o f cold (less than 2000F) subsystems with gapped supports 98 Total number o f hot (above 2000F) subsystems with gapped supports less than or equal to 1/4 inch 5
Total number o f hot (above 2000F) subsystems with one or two gapped supports that are greater than 1/4 inch 35 Total number o f hot subsystems with three or more gapped supports greater than 1/4 inch 43 This study is currently in progress.
It is anticipated that preliminary results will be available by June 15, 1982, with a final report to be prepared by September 15, 1982.
It should be
a J. G.
Keppler March 3, 1982 emphasized that in undertaking this study, Commonwealth Edison is not acknowledging the NRC's assertion that there is a lack of design oasis for the use of slotted seismic restraints.
Rather, the study will provide additional evidence in support of our contention that the original design criteria provide an adequate basis and justifi-cation.
Also, we restate our belief that the NRC's desire for a re-review of the adequacy of the original design criteria falls outside the scope o f I.E.Bulletin 79-14.
Torque Values on Pipe Clamp Bolts Commonwealtn Edison does not believe that the lack o f documented torque values on pipe clamp bolts presents a safety concern at Zion Station for the following reasons:
1)
Zion Station has an In-Service Inspection Procedure to inspect all components on safety related pipe systems.
This procedure, (see attachment B) At ta chmen t 6, SPPM, Rev.
5, Amendment 0, dated November 1, 1976 requires that a visual inspection be performed to determine the presence of 4
loose parts, debris, abnormal corrosion products, wear, erosion, corrosion and the loss o f integrity at bolted or welded connections.
Examples of recordable indications are i
l loose pipe clamps, loose bolting, etc.
t l
2)
Subsequent to receiving Sargent & Lundy's recommendation regarding their interpretation of pipe clamp torquing requirements as provided to them by ITT-Grinnell, Commonwealth Edison requested Stone & Webster Engineering Corp., the A-E firm perfornsing the 79-14 analysis for Zion Station, to provide their evaluation of the pipe clamp torquing requirements.
At the conclusion of their l
evaluation, S&W stated that ir' the clamp was snug against the pipe, then the clamp could perform its intended function.
j 3)
Given item 2 above and in order to assure ourselves that loose clamps were not a concern on safety-related piping, Zion Station sampled 57 randomly selected clamps.
Results of this sample program have shown that loose clamps are not evident, and that this issue does not present a safety concern for Zion Station.
4 ) Supplement 2 o f Bulletin 79-14 page 2 o f 2 dated September 7,
1979, states that ".... loose bolts are to be treated as nonconformances if they invalidate the seismic analysis; however, torquing of bolts is not required."
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1 J. G. Keppler 5-March 3, 1982 Giyen the above, Commonwealth Edison believes that we have j
adequately addressed the concerns that have been expressed by the NRC regarding pipe clamp bolting.
Therefore, we are not proposing l
any additional action.
4 Please address questions regarding this matter to this i
Very truly yours,
.dA [9 L. O. DelGeorge j
Director of Nuclear Licensing i
Im I
Attachments t
cc:
Zion Resident Inspector SUBSCRIBED an SWORN to befogg me t I 3r-d day of FL/\\ A, _
1982 W
Notary Public 3554N l
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1 ASSESSMENT OF SAFETY. MARGIN INHERENT IN THE DESIGN OF CATEGORY I PIPING SYSTEMS l
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Project No.:
6550-0G Client:
CECO Report No.:
EMD-6550-035-196 Revision:
00 Date:
2/16/82 EMD File:
EMD-035196 i
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I t
r Sargent & Lundy Engineers Chicago, Illinois Page 1
of 22 I
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kN -k Sb-035-19 EP
'O I
REV.00 DATE D2/16/82 PAGE 2 0F 2 'Z.
Assessment f Safety Margin Inherent in the Design of Category I Piping Systems ISSUE
SUMMARY
Remarks Rev.
Date iPrepared n d,1, a-i S AZZ ZY First Issue 00 2/16/82 gy d
Acc. No.
EMD-035196 S. Gibral 1 h (7.T5.
G. T. Kitz I
i, L C.., 0. i...;. u - u n 4. c
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- REP.NO. EMD-6550-035-19 I
REV.00 DATE 02/16/82 PAGE 3 0F 11
~...
Assessment of Safety Margin Inherent in the Design of Category I Piping Systems
Purpose:
The purpose of this report is to demonstrate that despite the fact of using gapped supports to restraint pipi~ng systems for seismic loads, a sufficient safety margin exists in Category I piping resulting from the analytical approach employed in the original piping design of Zion plant.
Because of this inherent -
safety margin, the Zion Category I systems will remain t
operable during the Design Basis Earthquake as defined in the regulations.
Input Data:
- Zion Seismic Response Spectra
- Results of a study conducted on the impact of structural steel and snubber gaps on the dynamic behavior of an actual piping system.
- Results of the assessment of non-category I piping for pro-tection of safety-related components during seismic and pool related events for LaSalle plant.
O M
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Lhb-DaaAve J
gACC.ND.
p KEP.NO. EH0-6550-0 35-19G I
IREV.00 DATE 02/16/82 0F 2Z t.PAGE 4 Table of Contents Page 5
1.0 Introduction........................................
6 2.0 Discussion..........................................
7 2.1 2*OBE Versus DBE Response Spectra..............
2.2 The Effect of Restraint Gap on Piping 11 S tres s and Res traint Load......................
14 2.3 Safety Related Piping Operability..............
2.4 Modeling and Analysis Results of CC-20, 17 SI-ll and 2RC-02 Piping Subsystems.............
20 3.0 Summary and Conclusion..............................
22 4.0 References..........................................
i 4
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REP.NO. EMD-6550-035-196 REV.00 DATE 02/16/82 PAGE 5 0F 12 1.0 Introduction During the NRC audits, conducted in October 1979 and the recent audits held at S&W offices, the NRC raised several concerns rel'ated to the slots contained in the attachment These slots lugs on a number of piping rigid restraints.
were included in the initial design basis to allow thermal pipe movement while restricting the overall seismic displace-ment of the system.
As a result, the NRC questioned whether this inherent limited movement would affect the rigid restraints ability to effectively restrain the pipe during an earthquake event.
The safety margin inherent in Zion piping will be addressed in this report through four different approaches which are related to the methodology utilized in performing the seismic analysis on the Zion Category I piping.
I The four related analytical areas which will be addressed in this report are:
The safety margin inherent in piping as a result of 1.
using the conservative approach of twice the OBE Response Spectra, for most of the systems, instead of the corresponding 1% DBE Response Spectra.
Evaluation of some non-linear analysis showing the 2.
impact of snubber gaps on the dynamic behavior of an actual piping system.
A C C. !i 0. L.. b - L a L i 'i u J
' REP.NO. EMD-6550-035-19s REV.00 DATE 02/16/82 PAGE 6 0F ZZ
(
3.
The ability of unrestrained piping to remain operable during an earthquake as demonstrated by the LaSalle Assessment of Non-Category I Piping performance for an SSE.
4.
A discussion of the modeling and analysis results for the three subsystems (CC-20, SI-ll and 2RC-02) ques-tioned by the NRC during the recent. audit.
2.0 Discussion As outlined previously, there is sufficient safety margin which exists as a result of the conservative analytical approach that was employed in the original design work on Zion plants.
Three related areas will be addressed separately to demonstrate that with the slotted restraints, the operability requirements for Category I systems is satisfied during a Safe Shutdown Earthquake.
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SARGENT & LUNDY (ACC.NO. EMD-03tlib l
ENG8NECRO i REP.NO. 'EN D-65 50-0 25-19(
REY.C0 DATE 02/16/62 J
'5 i PAGE 7 0F 22 2*OBE versus DBE Pesponse Spectra 2.1 f ty A comparison has been made to evaluate the sa e E spectra margin inherent as a result of using 2 x OB On'e response coectrum
'instead of.the exact DBE spectrh.
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of the Reactor Building at elevation 654'-0",to reprenent and one response spectrum of the Reactor Building been Auxiliary Building at elevation 592'-0" have For each of these elevations the 2*OBE selected.
and the exact DBE (with damping f actor of 0.5%),
- 1) are plotted on the same (with damping factor of sheet for the purpose of comparison.
bsystems The results of the comparison based on actual su can be outlined as shown on Table 1.
Table 2.1-l_
Actual Subsyster Average Safety First Modal
(~
Subsystem Margin i fl) _
Period No.
Building Elevation 26 (2) 2RC-02 0.16 sec. 654'-0" 88 Reactor Auxiliary 592'-0" SW-23 0.23 sec.
97 ( (3)
Auxiliary 592'-0" 2BD-02 0.63 sec.
79 J; Auxiliary 592'-0" PR-54.
0.155 sec.
Overal)
SF = 75.5 Avera-Safety Ilargin is defined as:
(1) 9(2*0BE)_ - a(D3E) x 100 g (DBE)
Safety Margin as a result of using 0.51 DBE (2) instead of 1% DBE Safety Margin as a result of using 2*CBE (3) instead of 1% DSE
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ACC.NO. EMD-035196 REP.PO. E M D - 6 5 50 -0 3 5 -19 6
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SARGENT & LUNDY REV.f!O DATE 02/16/82
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PAGE B CF 2 2.
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T$e average safety margin on the above table has been detected from Fig. 2.1.1 and 2.1.2, which show 2*0BE and DBE response' spectra curves for the given locations.
i The analytical results in Table 2.1-1 are based on the latest as-built analyses performed by Ssw and S&L.
For the systems analyzed using the corresponding DBE
~.
there is still safety margin inherent in the
~
- spectra, analysis since the DBE spectra used were based on 0.5%
critical. damping factors instead of the 1% DBE spectra
~
The magnitudes of safety as allowed in the Zion FSAR.
margin inherent in these cases cannot be evaluated without generating a new set of DBE spectra based on the 1% critical damping factor.
the safety margin inherent As the results indicate, in the piping. analysis, due to the conservative approach
(
of using 2*bBE, is significantly high.
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SARGENT & LUNDY REP.NO. LHD-6bbO-03b-19b REV.00 DAT E C2/16/82 E N GlH E ER S PAGE 11 0f 7. 7.
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The Effect of Restraint Gap on Piping Stress and 2.2 Restraint Load The standard Sargent & Lundy piping analysis procedure The piping is based on the rigid restraint assumption.
is assumed fixed in-the direction of restraint at the The effect piping attachment point to the restraint.
The of gap or slack is not included in the analysis.
restraint and the supporting members are assumed to be
~
perfectly rigid.
(
Actual dynamic restraints are not only deformable but, in addition, a certain gap or slack is associated with them.
It has been shown (Ref. 1) that, in general, restraint loads for combined high and low frequency excitation - are computed in a conservative manner, In fact, for certain based on rigid restraint modeling.
(where high frequency content is predomi-loading cases the standard procedure of analysis yields very nant)
Our method of analysis is proved conservative results.
to be conservative in predicting restraint loads even for f
as large as 5/8" gap size for all dynamic restraints o a 12" actual piping system.
it has been shown (Ref. 1) that Regarding piping stress, for gap size within a certain range - about 1/4" - our In fact, for small gap analysis procedure is adequate.
our standard procedure yields conservative size (1/16")
. A C C. fi O. Lav u;.430 f
EMD-6550-035-195 SARGENT & LLJNDY
~ REP.NO.
- REV.00 DATE 02/16/82
- PAGE 12 0F IL
- cmeno, Table 2.2-1 shows a summary of the comparison results.
results of the peak restraint load and pipe stresses between non-linear analysis (Reference-1) and linear (PIPSYS) analysis for different gap sizes.
By examining Table 2.1-1, it is shown that the average safety factor (SP) calculated for the Zion plant (as defined in Table 2.2-1) for a gap up to 1/4" is 0.67.
Larger gap than 1/4" also could be acceptable with some t
margin of safety.
It might be argued that for large say, larger than 3/8", piping stress computed gap size, by non-linear time history analysis could be higher than what we currently predict.
However, such non-linear results are. based on conservative assumptions such as linear contact law during impact for the restraint load, linearity in both the stress-strain and strain-displace-ment relationships as well as small damping values for We feel strongly that if most of the conservatism piping.
inherent in the analysis of Ref. 1 is abandoned, then larger gap size will not cause significant inelastic strain when the current methodologies predict stress around the allowable.
D 5
35-196 i E c
c, c g 1REV.00 DATE 02/16/S2 C HIC AGO Pt.GE 13 0F ZZ Table 2.2-1 Peak Restraint Load and Stress Summary (Subsystem LAS-LP-01)
A.
Standard Sargent and Lundy Analysis Peak Seismic Stress Max. Restraint Load psi lbf Response Spectrum Analysis 2993 7411 Differential Anchor Movement 2735_
1497 Total 5728 8908 B.
Total Peak Stress (PIPSYS) 16262 psi C.
Detailed Analysis using ANSYS Program Restraint Load Pipe Stress (psi){ Fm of Safey (lbf)
(ANSYS)
Tobl MSYS G3P S12 Peak ANSYS ANSYS load Seismic
'Ibtal Required to nake Total PIPSYS (inch)
Ioad S&L Ioad Peak Peak Gap Acceptable 1/32 5342
.6 4149 14683
.51 0.9 1/8 7237
.81 5870 16404
.57 1.0 1/4 9277 1.04 8660 19194
.67 1.18 Variable Gap 1/32 to 5836
.66 5506 16040
.57 0.95 1/8 5/8 10813 1.21 18588 29122 1.023 1.79 1
Peak Total Stress (ANSYS) _,
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Peak Total Stress (PIPSYS) 1.75 i
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P AGE. Its OF 22 Safety Related Pioina Ooerability 2.3 The previous discussion has shown that as a minimum, a gap of 1/4" will have no effect on the existing The following section will show analytical results.
that piping systems with larger gaps upto an unre-strained system will still remain operabic during the Design Basis Earthquake.
- 2) was conducted by S&L to demonstrate A study (Ref.
(
that sufficient design margin exists in Non-Category I piping to accommodate the Design Basis Earthquake and suppression pool related loads on LaSalle Nuclear The results of the study demonstrated that the Plant.
piping and its support system would not fail during the dynamic events, where the piping stress check was For the supporting system, based on faulted allowables.
the f aulted capacity of all the links including the embedment plate was checked.
A comparison between LaSalle and Zion response spectra 2.3.2,
-.has been made, as shown' on Figures 2:.3.1 and
'and the results of this comparison indicate that both
- Thus, response spectra are very much compatible.
LaSalle assessment results can be extended to be applied to Zion.
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, PAGE il
.0F 2. 2.
e Based on the conclus. ion, we can state that for Zion plant piping systems, even with no seismic restraints,
it is not possible for any piping systen, and its supporting system to fail'or collapse during a Design s
As for Category I systems which are Basis Earthquake.-
seismically restraints, partially by slotted restraints, the above conclusion firmly holds with much more confidence.
t 2RC-02 Modeling and Analysis Results of CC-20, SI-ll &
~
2.4 As indicated by S&W the three subsystems selected by NRC during the latest audit are CC-20, SI 11 and 2RC-02.
Each subsystem will be discussed, in the shadow of the f
slotted restraint question, separately as follows:
CC-20:
By examining this part.icular subsys tem, it was 'found r
that the subsystem:
- has no slotted restraint.s.
- wai; analyzed using 0.5% DBE approach for Design
~
Basis Earthquake.
~~
'SI-ll:
However, as This subsystem has six slotted restraints.
shown in Fig.-2.4.1, for the marked-up piping area the i
slotted restraints (SIRS-ll28 and 1129) are always (locked-up) whether the system is hot or cold, j
engaged
~
9
ACC.f.0. EMD-005296 St.RGENT & LUNDY REP.NO. EMD-6550-035-196 cnosuccns REV.00 D ATE 02/16/82
- i-
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- PAGE 28 0F 11 clearly indicated that the piping systen is wF' restrained in either direction along the two restraints
' Such condition does exist in numerous orientation.-
i k
cases of the supp rting systens.
Furthermore, an additional analysis was performed for this subsystem without taking any restraining credits The results of this for the six slotted restraints.
analysis indicata that the piping stresses are still within the Code hilowables, which agrees with the conclusion reached in Paragraph 2.3. The additional analysis was performed by S&W.
2_R_C-0 2 :
This subsystem was originally classified as non-safety However, it was updated to safety related piping.
related piping to ensure the operability of the relief This subsystem has
. valves during an earthcuake event.
only five slotted seismic restraints with maximum slot The rest of slotted restraints are length of 5/16".
installed to protect the piping
" Flailing Restraints",
-in the event of a pipe rupture incident.
~
When the subsystem was analyzed without taking the flailing restraints into consideration,-the piping stresses were found to be within the Code allowables.
. This system is currently being cvaluatcd under the program to better define the dynamic loading "EPRI" due to safety relief valve discharge.
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REV.DD DAT E 02/16/82 cmcao.,
PAGE 20 Of L t Summary and Conclusion 3.0 f
The following sections discussed in detail for areas o.
i conservatism in the analysis which we feel substant ate ill our relief that these systems are indeed safe and w These remain operable during'the Design Basis Earthquake.
can be summarized as:
' Response spectra that are more conservative than those 1.
required by the Zion FSAR were used for analysis of the piping systems.
i d
A non-linear analysis on typical piping systems ind cate 2.
that gap sizes of at least a quarter inch would be acceptable without causing any increase piping stress l
or support load over the initial rigid analysis mode.
- inch,
~ For systems Ubich have gaps larger than a quarter 3.
'it has been demonstrated that the system will. remain di-(;
operable with piping stresses less than the fault con tional modal during the Design Basis Earthquake.
some other factors exist which would.also In addition, d safe and support the conclusion that the systems are indee h
ke, will remain operable during the Safe Shutdown Eart qua these are:
i Actual piping stress allowables based on'the no cert -
l.
fication report would be significantly higher than l
i minimum stress allowables specified by the codes.
e
EP.D-U3519o
. ACC.NO.
SARGENT & LUNDY
- REP.NO. E.MD-6550-035-196 "G
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- j' c,
PAGE 21 Of 21 In a similar fashion, actual support capacities based
. 2.
on analysis are typically larger than those specified 4
in the design handbooks.
As indicated in the discussions in Paragraph. 2.4, in 3.
many cases it is expected that the slotted restraints have been installed such that they will act against each other and effectively restrain the piping system
.~
during the seismic event even though a gap is present.
- (
In (See the discussion on SI-ll for explanation).
addition, in several cases it is expected that the dynamic load will be less than the thermal frce-load cxerted against the slotted restraint and because of this the system will not be free to move.
C In a similar fashion, many of the slotted restraints 1 4.
are de' signed to be bottomed or topped during nor.aal I
operation and consequently the system will be able to This would make move only'in one direction, not both.
~
~
the results obtained in Paragraph 2.2 conservative.
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.ACC.NO. EHO-035196
. REP.NO. EHO-65 5 0-0 35-196
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SARGENT a LUNDT, jREV.00 DATE 02/16/82 g g o g u c e n s.
P 0 F 2. t L.t.GE 11
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References:
TheimpactofRestraintGaponPipingAnal$ sis.
S&L Report 5
File No. EMD-003795.
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AssessmentofNon-Categob*I.PIPngforProtectionof i
2.
Safety Related Components during Seismic and Pool Related S&L Report File No. EMD-0 27211.,
Events.
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1 -
PROCEDURE APPROVAL i
The following procedures, as indicated below, have been reviewed and found to be acceptable for inservice examination of Zion Nuclear Generating Theses procedures meet the intent of ASE Section XI 1974 edition up Station.
to and including Summer of 75 Addendum and ASE Section V, Article 9,1977.
Implementation will be in accordance with the above.
Amendments Procedure No.
Revision & Date
., SPFH Rev. 5 11-1-76 Amend. O Signed:
o /,
M M Date: c9[/f/8/
Title:
&_]
N lff D m ns &
/
Date:
f 27-7/
Signed: _ /
qu
Title:
Mo dA
/
tb 8
Prepared by:
C. G. Silich I.S.I. Coordinator Zion Generating Station I
2 u: u ZION INSERVIE INSPECTION FT10TOURE ATTACifENT 6, SPFN NDT-VI 1.
Objective A.
To establish a standardized method for conducting visual inspections which meet the intent of AST Section XI 1974 edition up to and including Summer of 75 Addendum at Zion Station.
2.
Scope A.
The instructions contain general and specific reouirements for the perfonnance of Visual Inspections 1, 2, 3, and 4.
B.
Only cualified personnel shall perform and interpret visual inspections for final acceptance.
C.
Use of this document shall be dependent upon ASE Section XI 1974 edition up to Summer of 75 Addendum.
3.
Cencral Reauirements' l.
Personnel Qualifications A.
Visual inspections, when required, shall be perfonned by personnel qualified as Level II in accordance with the SPPM.
B.
Inspection personnel shall have an annual eye test per certification requirements.
C.
Visual inspectors shall be trained per the SPPM Training Course.
.. >~
., SPPM NDT-VI The following inspection procedures, methods and documentation may in all or in part, dependent upon the inspection criteria of the system, The different inspections are explained in the following component, or part.
and shall be used accordingly.
Inspection #1 Visual inspection #1 shall be conducted to determine the condition of the Conditions which shall be inspected part, component, or surface inspected.
cracks, wear, corrosion, erosion, and physical damage on the for are:
surfaces of the part or component.
inspection and done by CECO Lev II Visual Inspector.
Examples of Recordable Indications:
- 5) Damaged or worn threads
- 1) Valve stem galling
- 6) Steam cut surfaces
- 2) Weld cracking
- 7) Valve seat erosion
- 3) Corroded studs
- 4) Damaged piping Reouirements:
U 1n Direct visual examination may be performed only when the surface is w Mirrors may
_24 in, and an angle not less than 30 degrees to the surface.
1) be used to improve the angle.
Lighting shall be sufficient to resolve a 1/32 in. line.
2)
Remote visual examination may be substituted for direct by aids that 3) attain the equivalent results.
Recording Criteria:
i The following conditions shall be considered as Recordable Indicat ons, among others:
Any abnormal wear 4)
Any physical damage on the surface
- 1) Any crack or cracking 5)
- 2) Any abnormal corrosion
- 6) Any abnormal weld condition
- 3) Any abnormal erosion Inspection #2 from Visual inspection #2 shall be conducted to locate evidence of leakage ith or pressure retaining components, or abnormal Icakage from componen ssure test without leakage collection systems as required during the syste or functional testing.
when in operation or test.
l I
I
) Ul LL Examples of Recordable Indications:
- 5) Manway leaks l
- 1) Abnormal valve packirg leak
- 6) Elbow leaks
- 2) Boric acid on insulation Water dripping from insulation joints 7)
- 3) Steam leakage
- 4) Flange leaks Due caution should be Steam leaks from components may not be visible.
exercised during the investigation.
Reouirements:
Ligiting shall be sufficient to detect abnormal conditions.
1)
Leakage Test - No hold time required after attaining test pressure and 2) temperature conditions.
Functional f est - Ten minutes holding time reouired after attaining the 3) system operating pressure.
Inservice Test - No holding time required, provided the system has been in 4) operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
liydrostatic Test - Four hours holding time required af 5) minutes for non-insulated systems or components.
Pneumatic Test - Ten minutes holding time required after attaining test 6) pressure.
- 7) "Non-Insulated Components Exandne all accessible exposed surfaces.For external surfaces A) areas, such as the floor area or cauipment surfaces located B) undernea th.
8)
Insulated Components Examine all accessible and exposed surfaces and joints of the A)
Horizontal surfaces of insulation shall be examined at each joint.
insulation.
Vertical surfaces need only be diecked at the lowest point.
B)
Discoloration or residue on surfaces shall be. investigated to C)
D) determine if leakage is present.
Where leakages from components are normally expected and collected the is exam shall be conducted by verifying that the leak collection system 9) operative.
4 of 12 Recording Criteria The following conditions shall be considered as Recordable Indications, among others:
- 1) Any through wall leakage.
(i.e. pipe, pump, valve)
- 2) Significant gasket, valve packing, or pump seal leakage.
- 3) Leakage collection system inoperative.
The detection of boric acid residues on ferritic steel components shall 4) require the location of the leakage source and areas of general corrosion shall be evaluated.
- 5) Any abnormal bulge of calcium silicate insulation.
Abnormal amount of water or boric acid in surrounding areas of accessible 6) components.
Inspection #3 Visual Inspection #3 shall be conducted to determine the ceneral mechanical and structural conditions of components and their supports.
Conditions which shall be examined for are sud1 things as the presence of loose parts, debris, abnomal corrosion products, wear, erosion, corrosion and the loss of integrity at bolted or weld connections. Inspection #3 can be used for all system inspection.
Examples of Recordable Indications:
- 1) Loose support pad bolting 5)
Missing bolting
- 2) Pipe clamp movement
- 6) Abnormal corroded bolting
- 3) Loose anchor bolting
- 7) Abnormal wear areas (bolt holes,
- 4) Broken support welds pump and valve support areas, internals)
Reauirements:
- 1) Lighting shall be sufficient to resolve unusual conditions.
Direct visual exam may be perfomed only when the surface is within 24 2) inches and an angle not less than 30 degrees to the surface.
Mirrors may be used to improve the angle.
For component supports and component interiors, the visual examination may 3) be perforned remotely with or without optical aids to verify the structural integrity of the component.
e Recording Criteria
- tions, The following conditions shall be considered as Recordable Indica among others:
- 1) Loss of integrity
- 2) Abnormal wear
- 3) Abrormal corrosion
- 4) Abnormal erosion Detection of physical displacement 5)
Degraded connections between load carrying structural members 6)
- 7) Loose bolting l exam)
Loose parts, debris, abnormal corrosion or erosion (interna 8)
Degradation of structural adequacy of support elements 9) f
- 10) Loose pipe clamps Inspection #4 l ting Visual Inspection #4 shall be conducted to determine conditions re a to the operability of components or devices.
h ical Inspections will be conducted on components or devices such as m d d hangers, and and hydraulic snubbers, component supports, spring loa eInspect constant weight hangers.
inspection.
l Physical operability tests are covered under Station Technica Specifications, l
Examples of Recordable Indications:
i l
- 5) Loose bolting Bent or damaged support rods 6)
Worn clevis:
Abnormal leaks (hydraulic) 1)2) Empty hydraulic snubber _
7)
- 3) Piston damage 8)
Spring hanger (unloaded or
- 4) Broken or bent springs bottomed out)
(Special Instruction)
- Hydraulic snubbers A) Hydraulic 011 Reservoir Level full.
The Reservoir level generally should be between half full and longer the piston travel the lower the oil level.
l 6 of 12 i,'
)
Fluid type is G.E. SF 1154 Silicone Fluid. Standard reservoirs are transparent plastic and the fluid IcVel may be seen easily.
If the piston is nea'r its fully retracted position, there should still be in the reservoir a sufficient amount of fluid to cover the intake hole to the snubber valve.
If there is any doubt as to the amount of fluid in the reservoir, the reservoir i
should be properly refilled.
B) ljydraulic system Leaks:
Inspect the hydraulic system piping for signs of leakage.
Inspec't f
reservoir piping, snubber valve, hydraulic cylinder and piston seal for any signs of leakage and record major leak locations on data sheets.
Inspector shall evaluate the significance.
C) Hydraulic 011 Reservoir:
Make sure that the oil reservoir is above the main body of the snubber.
(If the reservoir becomes inverted, the fluid will leak out of the vent plug.)
D) Mechanical Integrity:
1)
Pipe clamp - Make sure the pipe clamp is securely attached to the pipe.
Check by grabbing clamp and trying to rotate or slide it.
NOTE The clevis pin bolts should be finger tight.
If the bolts have vibrated loose, finger ticfte-2)
Lock nut - Locate the lock nut on the snubber extension piece and make sure it is ticpt.
3)
Visually check piston rod for any damage (deep scratches, bent, etc.)
and for cleanliness. All dust and dirt must be removed from the piston rod.
Reouirement
- 1) Lighting shall be sufficient to resolve unusual conditions.
Recordino Criteria:
The following conditions shall be considered as Recordable Indications, among others:
- 1) Hydraulic Snubbers A)
Pisten rod damage B)
Abnormal hydraulic leakage from (i.e. reservoir piping, snubber valve, cylinder, or piston seals)
C)
Empty or low level reservoir D)
Inverted reservoir E)
Loose parts (nuts, bolts, seals)
J
o J
A)
B)
Rod damage C)
Loose bolts
- 3) Hanger I
l Bent rod A)
Worn eye nuts and clevis B)
C)
Loose bolt and nuts D)
Unloaded hanger l
- 4) Spring Hanger A)
Spring bottomed out B)
Spring broken C)
Incorrect setting l
Bent rod j
D)
Worn eye nuts and clevis E)
F)
Loose bolts and nuts
- 5) Constant Load Support A)
Incorrect setting B)
Bent rod Worn eye nuts C)
Broken spring or (other)
D)
- 6) Abnormal Corrosion
- 7) Pipe Whip Restraints Evidence of abnormal impact damage Fretting between pipe and restraint A)
B)
Data Sheet The data sheet shall at a minimum have:
ISO number 5)
ASE system classification Inspection Technique 1, 2, 3, or 4 6) 1)
- 7) PID M-print number -
- 2) Station number Unit number 3)
System or sub-system designation 4) d date.
If there are no indications _ found, check NI bor., sign, an
a s.
s I
ill all appropriate If recordable indicat' ions _ are found, check the RI box and f Ine data sheet shall at a minimum have:
information.
Part, component, or device identification numbers.
1) facilitate Locations shall be filled out as accurately as possible to 2) corrective action if recuired.
Record discrepancy accurately.
identify the 3)
Record work reauest and/or djscrepancy report number to repair and/or disposition of the indication.
4)
Sim and date.
5)
SI engineer.
The review of this data sheet shall be performed by and I h t If additional space is required use the Comment Data S ee.
IRO - Irregular Observation definition has Irregular observations are an area in which no cicar cutT ily upon the inspectors ability to evaluate indications w been established.
f the inspector, An Irrecular Observation should be in the judgement _ o ible monitoring indications that need to be noted for future reference and poss rt or a work field.
but do not require immediate action, such as a discrepancy repothe Inspection records should always state jwh NI.
Inspectors the indication to be an irregular observation and not an RI or be an RI reauest.
judgements vary at times and what one inspector notes as judgement.
to another inspector. guide and not as a basis for the inspector to m l
Examples of IR0s.
I Slight amount of boric acid on a valve stem.
1)
Old boric acid on valve stems.
2) i ht.
Paint cracked on a bolting assembly but b'olting still t g 3) ht to moderate rust.
lid 4).
l tight.
Slight scratch on pipe from pipe clamp but clamp is stil 5) t Parts or nuts on floor but unknown location from componen.
6)
Slight oil leak from a hydraulic snubber.
7)
Water stains which are dry on components.
8)
4
\\
1 Loose concrete on floor but unknown location from component.
9)
- 10) Discoloration on components, floors, and walls.
Data Sheet Fill in all appropriate information as with an RI or NI data sheet.
1)
Additionally the data sheet have the reason why it was an IRO.
2)
- 3) Sign and date.
Review of this data sheet shall be performed by an ISI engineer.
4)
If additional space is required, use the Comment Data Sheet.
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't Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-295 Docket No. 50-304 i
As a result of the inspection conducted on July 31, December 1-2, 8, and 21, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion III, states, in part, that " measures shall be established to assure that applicable... design basis for those structures, systems, and components are correctly trans-lat.ed into..
drawings.. ".
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 15, dated January 2, 1981, states in Section 3, "The fundamental vehicle for design control involved multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer'.
immediate supervisor whose authority and responsibility are ident i fied and controlled by written procedures. Also, procedures are established to assure that verified computer codes are certified for use and that their use is specified.", and "These design evaluations or reviews are conducted to written procedures and include consideration of quality standards, quality assurance requirements, materials suitability, i
process suitability, interface control and suitability of analytical or testing requirements as appropriate."
Contrary to the above,- relative to the slotted seismic restraints installed in many safety related small and large bore piping systems, there were apparent lack of original-design basis and justification.
The ASME technical publications provided for the inspector's review showed inconclusive effects due to the mechanical snubber gaps much smaller than what were observed at-the site.
Evaluation for the systems that contained large amounts of the slotted restraints to
~
ensure the actual stress levels are all within the committed code allowables was not conducted by the licensee.
This is a Severity Level V violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed in documented instructions, procedures, or drawings...
and shall be accomplished in accordance with these instructions, procedures, or drawings."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 15, dated
ei. s a:
1 x
Appendix January 2,1981, states in Section 5 that "The quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists. These documents will assist personnel in assuring that important activities have been performed. These docu-ments will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out."
SWEC-NY Procedure ZPP-1, " Pipe Stress and Support Evaluation",
Revision 8, dated July 27, 1981, where Paragraph 4.2.2.3, stated, in part, that "In accordance with construction specification, clamp bolts for skewed snubbers have to be tightened with a specific torque so that a sufficient friction force is developed to assure no slippage between the clamp and the pipe."
l Contrary to the above, the torquing requirements on pipe clamp bolts developed by S&L to assure no slippage between the clamp and the pipe were not properly adopted in the site work procedure.
In fact, the subject matter relative to the torquing of pipe clamp bolts in com-pensation of the lack of shear lugs observed at various piping systems to prevent pipe clamp slippage where axial loading exists during l
adverse conditions had not been reflected in any work implementation procedures.
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to j
l this office within thirty days of the date of this Notice a written state-l ment or explanation in reply, including for each item of noncompliance-(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-j pliance.will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath j
or af firmation. Consideration may be given to extending your response time for good cause shown.
N f Nemb Dated C. E. Norelius, Director Division of Engineering and Technical inspection I
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