ML20092P340

Final Deficiency Rept Re Cold Pulling of Mechanical Pipe. Initially Reported on 821110.Pullman-Higgins Installation Procedures Revised.Item Determined Not Reportable Per 10CFR50.55(e)

ML20092P340
Person / Time
Site:	Seabrook
Issue date:	06/11/1984
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
SBN-666, NUDOCS 8407060183
Download: ML20092P340 (5)

Text

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IPUBLIC Ccsmpanyof New SERVICE Hampshere 1671 Worcester Road Framinchom. Massachusetts 01701 (6171 - 872 8100 June 11, 1984 SBN 666 T.F. Q2.2.2 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs

References:

(a) Construction Permits CPPR-35 and CPPR-36, Docket Nos. 50-443 and 50-444 (b) Telecon of November 10, 1982, A. L. Legendre (YAEC) to Eugene Kelley (NRC Region I)

(c) PSNH Letter, dated December 14, 1982, " Interim 10CFR50.55(e) Report; Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki (d).PSNH Letter, dated July 15, 1983, " Interim 10CFR50.55(e)

- Report; Cold Pulling of Pipe", J. DeVincentis to R. W. Staros tecki (e) PSNH Letter, dated December 15, 1983, " Interim 10CFR50.55(e) Report; Cold Pulling of Pipe", J. DeVincentis to R. W. S tarostecki (f) PSNH Letter, dated March 2,1984, " Interim 10CFR50.55(e)

Report; Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki

Subject:

Final 10CFR50.55(e) Report; Cold Pulling of Pipe

Dear Sir:

On November 10, 1982, we reported a potential 10CFR50.55(e) item regarding an isolated incident of violation of UE&C Specification for Assembly and Erection of Piping and Mechanical Equipment, No. 9763-006-248-51, Paragraph 3.5.8.

A. Description of Deficiency We have found that a misalignment greater than that permitted by the piping erection specification existed prior to the fitup of the Main Steam Piping (Line MS-4007-01-B1-30") field welds F0105 "A" and F0106 "B" of Dravo fabricated spools E2937-1982 and E2937-1981, respectively. This was discovered when the area superintendent requested that the restraints holding the pipe in place for welding be removed to allow a check of the fitup of the pipe. l (Pullman-Higgins Non-Conformance Report No. B0749) l h, O S IEJ} i

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United States Nuclear Regulatory Commission June 11, 1984 Attention: Mr. Richard W. Starostecki, Direc tor Page 2 This item is in violation of the specification for Assembly and Erection of Piping and Mechanical Equipment, No. 9763-006-248-51, Paragraph 3.5.8.

A further investigation of a possible generic problem with the use of mechanical clamps that could possibly pull a pipe more than the specified 1/8" was performed.

C. Analysis of Safety Implications If excessive misalignments existed in the fitup of Code piping, safety-related components (piping, valves, supports, etc.) could possibly be overstressed.

C. Corrective Action In order to preclude the possibility that safety-related piping is overstressed due to excessive cold pull, the f ollowing corrective action was undertaken.

1. The nonconformance report was dispositioned to " rework" the piping following an analysis of the piping and in accordance with installation procedures.

2. In order to assure proper installation in the future, Specification 9763-006-248-51, Revision 10 was issued to add the following:

a. Paragraph 3.5.8.4 Installation procedures shall establish a hold point at the installation of the final spool piece. Adjacent piping shall be verified as to being in the design configuration, as shown on the drawings, spool piece shall be fit into position as verification that the requirements of Paragraph 3.5.8 are not violated,

b. Paragraph 3.5.8.5 When tooling clamps are used, as permitted by Paragraph 3.5.8.1, on the final closure weld of any system, or portion thereof, verification of having met the requirements of Paragraph 3.5.8 shall be performed prior to making the weld.

In conjunction with Items a and b above, Pullman-liiggins has revised l their installation procedure and has conducted retraining of pipe I

fitters, supervinors, Level I QC and Level II QC personnel, l acco rdingly . The implementation date f or these activities was January 1, 1983.

United States Nuclear Regulatory Commission June 11, 1984 Attention: Mr. Richard W. Starostecki, Director Page 3 a

D. Additional Studies and Analysis The evaluation of the piping proceeded on the premise that installation of the supports / restraints af ter the completion of final closure weld would assure that the effect of any cold pull that may have been introduced would be miniuml. It was verified that the supports /re-traints were installed after tha final closure weld, therefore, also permitting the elimination of a review of the support designs with regard to any unaccounted for loads attributable to cold pull. All ASME piping installed prior to January 1,1983, where the final closure weld of a system or subsystem was completed, was considered suspect and reviewed with respect to the potential effects of cold pull.

The above review encompassed approximately seventy (70) subsystems, with a subsystem defined as that portion of the piping connecting two points of relative fixity (i.e. , anchors, branch connections, equipment nozzles, etc.).

Pumps with flanged connections had the piping disconnected and misalignments were minimized to assure that no operation problems would result from pump / motor coupling misalignments. Since no nonconformances were generated indicating misalignments in excess of those allowed by Specification 9763-006-248-51 (1/8"), it can be concluded that for these systems, no cold pull had been introduced.

Further studies and investigations were initiated in order to further assure that cold pull overstren?ing was not introduced into the subsystems. The sensitivity study intentionally selected relatively stif f piping configurations so as to yield conservatively high stresses.

From these analyses, a stress per unit of cold pull displacement due to nisalignc ant was developed. Based on the margin left in the Code allowable stresses, an allowable displacement for misalignment was calculated for each subsystem.

The maximum misalignment due to cold pull was taken as 1 1/4". This misalignment is the maximum misalignment accepted by the clamps which are used to align the pipe for welding. In order to exceed this misalignment, application of an external mechanical force would be necessary which would have resulted in a nonconformance report.

For most of the 70 subsystems, the allowable displacement limit for misalignment was greater than the maximum displacement due to cold pull. Subsystems which had an allowable displacement limit below 1 1/4" were analyzed on a case-by-case basis. Individual analysis of these subsystems produced an allowable displacement for misalignment of greater than 1 1/4".

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- United States Nuclear Regulatory Commission . June 11, 1984 Attention: Mr. Richard W. Staros tecki, . Director Page 4 in conclusion, the results of our evaluations, studies, and investigations indicate that if cold pull had been inadvertently introduced and left undetected,-it would not be of sufficient magnitude to cause detrimental effects within the piping. In light of this conclusion, we consider this item.not to meet the reportability criteria of.10CFR50.55(e).

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY 4/ x2

• J. DeVincentis Engineering Manager cc: Atomic Safety and Licensing Board Service List Director, Office of Inspection and Enforcement

.U.S. Nuclear Regulatory Commission Washington, DC 20555 f

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• William S. Jordan, III, Esquire Brentwood Board of Selectmen Harmon & Weiss RED Dalton Road 1725 1 Street, N.W. Suite 506 Brentwood, New Hampshire 03833 Washington, DC 20006 Roy P. Lessy, Jr., Esquire Office of-the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representative of Washington, DC 20555 the Town of Rye 155 Washington Road Robert A. Backus. Esquire Rye, NH 03870 116 Lowell Street P.O. Box 516 Calvin A. Canney Mancehster, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Department of the Attorney General Augusta, ME 04333 Dana Bisbee, Esquire Assistant Attorney General Mr. 'ohn B. Tanzer Office of the Attorney General Designated Representative of 208 State House Annex the Town of Hampton Concord, NH 03301 5 Morningside Drive Hampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Pevear Town Hall Designated Representative of South Hampton, NH 03842 the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Hampton Falls, NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Gavutis Rye, NH 03670 Designated Representative of the Town of Kensington Carole F. Kagan, Esq.

RFD 1 East Kingston, NH 03827 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Esquire '

Assistant Attorney General Mr. Angie Machiros Environmental Protection Bureau Chairman of the Board of Selectmen Department of the Attorney General Town of Newbury One Ashburton Place, 19th Floor Newbury, MA 01950 Boston, MA 02108 Town Manager's Office Senator Gordon J. Humphrey Town Hall - Friend Street U.S. Senate Amesbury, Ma. 01913 Washington, DC 20510 (Attn: Tom Burack) Senator Gordon J. Humphrey 1 Pillsbury Street Diana P. Randall Concord, NH 03301 70 Collins Street (Attn: Herb Boynton)

SEabrook, NH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport. MA 01950 Town of Exeter 10 Front Street Exeter, NH 03833