ML20211M852

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Impact of Const Deviations on Stress Requalification Program,Comanche Peak Steam Electric Station,Units 1 & 2. Supporting Documentation Encl
ML20211M852
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/15/1986
From: Henderson J, Shah M
STONE & WEBSTER ENGINEERING CORP.
To:
Shared Package
ML20211M821 List:
References
15454-N(C)-010, 15454-N(C)-10, NUDOCS 8702270376
Download: ML20211M852 (46)


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(( TEXAS UTILITIES GENERATING CO.

COMANCHE PEAK STEAM ELECTRIC STATION ~

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IMPACT OF CONSTRUCTION DEVIATIONS ON STRESS

, REQUALIFIC ATION PROGRAM i

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STONE & WEBSTER

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4 J.O.Nas. 15454/15616 Report No. 15454-N(C)-010 )

l Job Book R4.8 ,

1 IMPACT OF CONSTRUCTION DEVIATIONS ON STRESS REQUALIFICATION PROGR.Ut COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 1

Prepared for I Texas Utilities Generating Company l by J. Henderson M. J. Shah December 15, 1986 i

7toject Engineer - Unit I l

84A.

. , Project Engineer - Unit 2 0 EA-Project Manager l Stone & Webster Engineering Corporation Cherry Hill Operations Center Cherry Hill, New Jersey l

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TABLE OF CONTENTS i

Section Title Pm SUt91ARY 11

1.0 INTRODUCTION

1 2.0 PURPOSE 1 3.0 REVIEW METHODS 2 3.1 DEVIATION REPORTS 2 3.2 DETAILS OF THE REVIEW 2 4.0 RESULTS OF TE REVIEW 2 5.0 DISCUSSION OF RESULTS 3

6.0 CONCLUSION

S 6 *

7.0 REFERENCES

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TABLE 1

SUMMARY

OF DEVIATION REPORTS i TABLE 2

SUMMARY

OF ISSUES TABLE 3 LINEAR DIMENSION / LOCATION DEVIATIONS TABLE 4 MAGNITUDES OF PIPING / SUPPORTS LINEAR DIMENSION DEVIATIONS TABLE 5 MAGNITUDES OF SUPPORTS / RESTRAINT LOCATION DEVIATIONS i

ATTACHMENT 1 A TYPICAL DEVIATION REPORT ATTACHMENT 2 LOG OF DRs.

ATTACHMENT 3 EVALUATION SHEET ATTACHMENT 4 RESULTS OF TE REVIEW s

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SUMMARY

Deviation reports (DRs) generated by the Evaluation Research Corporation (ERC) were evaluated by Stone & Webster Engineering Corporation (SWEC) for potential impact on SWEC's Stress Requalification Program (SRP)

(Reference 7.1). Approximately 800 DRs related to the piping systems and supports were reviewed for this effort. The review confirmed the need to address clearances between piping and adjacent components / structures on a plantwide basis, as committed to in Section 7.2 of CPPP-6, Revision 2 (Reference 7.2). It also indicated the need to conduct a Hardware Vali-dation Program (HVP), as recommended in Section 8 of L. S. Wigley's July 1986 report on Assessment of TUGCO's As-Built Documentation for Pip-ing and Pipe Supports (Reference 7.3).

It was concluded that the concerns on clearances and other hardware prob-less do not impact the SWEC requalification program directly, and there is no need to change the stress requalification program or procedures to address the ERC-generated deviation reports on a specific or generic basis.

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1802-1545405-EC4 11

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1.0 INTRODUCTION

y. The Construction Adequacy Program (CAP) is spoc.sored by the Comanche Peak Response Team (CPRT) of Texas Utilities Generating Company (TUGCO) to perform an independent reinspection of safety systems. Evaluation Re-search Corporation (ERC) has been contracted 1 o perform this reinspection 8

of the safety-related components on a sampsing basis (Section 2.2 of

, Reference 7.4).

e Each apparent construction deviation from the design drawing is identi-fied by ERC and documented as a Deviation Report (DR).

, ,. The safety significance of these DRs in relation to reportability in ac-

, cordance with 10CTR50.55(e) is continuously being evaluated by TUGCO. To determine the trends and adequacy of the sample size, ERC is also review-ing the DRs.

e

, Concurrent with SWEC's Stress Requalification Program (SRP), TUGCO re-quested SWEC to evaluate independently the effects of the piping and pipe i ,

supports-related DRs on the SRP. SWEC was requested to develop a program

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to identify trends, if any, and make changes in the procedures, if neces-sary, to'ainimize the impact of these DRs when they are incorporated lat-i

, er into the as-built packages. Details of the SWEC program are as outlined in CPPP-18 (Reference 7.1).

2.0 PURPOSE r *

, The purpose of this report is to describe the results, methods, and con-clusions of SWEC's evaluation of the DRs for possible impact on the SPS.

Deviations are categorized and discussed to identify the actions pro-posed. The review was limited to the ERC-DRs which were generated using following procedures:

QI-019 Reinspection of Small Bore Pipe Supports (SBPS) s a QI-021 Reinspection of Piping System Bolted Joints / Material (PBOM) l .

QI-025 Reinspection of Large Bore Pipe Configuration (LBCO)

,. QI-026 Reinspection of Small Bore Pipe Configuration (SBCO)

QI-027 Inspection Procedures for Large Bore Supports Rigid (LBSR)

QI-029 Inspection Procedures for Large Bore Pipe Supports l Nonrigid (LBSN) l . QI-048 Reinspection of Small Bore Welds / Material (SBWM)

QI-049 Reinspection of Large Bore Piping Weld / Material (LBWM)

QI-051 Reinspection of Whip Restraints (PWRE)

QI-070 Reinspection of Tubing Welds / Material (TUWM) 1802-1545405-HC4 1

l 3.0 REVIEW METHODS

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  • This section describes details of the review methods used to evaluate the DRs for possible impact on the SRP. Section 3.1 addresses generation of the DRs by IRC, while Section 3.2 discusses the details of the review and ,

the manner in which the review resmits were documented.

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j 3.1 DEVIATION REPORTS (DRs)

The inspection procedures listed in Section 2.0 provide a set of criteria for inspection of'various components of construction, defined as popula-tion groups. Inspections were performed om each of the population groups on a sampling basis and DRs were generated when the as-built condities deviated from the requirements of design drawings and specificatioes.M:[*.

A typical DR is shown as Attachment 1 to this report. m from the fol-loving population groups were reviewed to determine the impact oa the ggy

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c LBCO: Large Bore Piping Configuration O. *.j SBCO: Small Bore Piping Configuration LBSR: Large Bore Pipe Supports - Rigid LBSN: Large Bore Pipe Supports - Noarigid PWRE: Pipe Whip Restraints -

8 BPS: Small Bore Pipe Supports PBON: Piping Systen Bolted Joints / Materials Tmet: Tubing Welds / Materials SBWM: Small Bore Piping Welds / Materials

LBWM: Large Bore Piping Welds / Materials -

l 3.2 DETAILS OF TEE REVIEW The DRs for each of the population codea were obtained from ERC and a file was created. A log of all DRs (filed in Job Book R4.25, SWEC Evalm-ation of ERC Deviation Reports) in a population code also was prepared (Attachment 2). Table 1 provides the number of DRs that were reviewed for each population code.

Eaca DR was reviewed and classified as Category A, B, or C. Category A DRs include the deviations that have a potential impact on t.he design of the piping system and/or pipe supports. Category B DRs are hardware-related and thus will not affect the qualification methodology for the piping / pipe supports analysis. Category C DRs are neither design-nor hardware-related and do not require further evaluation for impact on the SRP. A categorization of DRs for each population code is given in Table 1.

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4.0 RESULTS OF THE REVIEW t Results of the review for each DR were documented in a forg shown in 3

Attachment 3. Types of issues identified as a rsault of th& review of DRs for each populaf ion code are summarized in Attachment 4.' eta)'1e 2 provides a summary of issues and the number of DRs for each population code.

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5.0 DISCUSSION OF RESULTS It can be seen from Table 1 that approximately two-thirds of the devia-tions are Category A, while approximately one-third of the deviations are Category B. N number of Category C deviations is insignificant. As explained earlier, Category B deviations are hardward-related and do not affect the input to the SRF. N anjority of Category B deviations are Items 7 through 11 in Table 2 and include missing locking devices, mise-ing washers, paint on spherical bearings, claap halves not parallel, and gaps greater than the smallset shia in rear brackets of snubbers. Sig-nificance of these deviations on the construction adequacy of the piping and pipe support systems has been assessed by the ERC under its Construc-tion Adequacy Program and rec-adations have been made or will be made by IRC to correct these deviations identified as construction deficien-cies. L. 8. Wigley also has recommended a program called Iardware Vali-dation Program (HVP) as a part of the assessesnt of T0000 as-built documentation for piping and pipe supports (Reference 7.3). b refore, Category 3 deviations are not addressed further in this report.

Category A deviations identified in Table 2 as Items 1 th ough 6 and Item 12 are discussed below in detail.

1 Item 1 Locations / Dimensions Out-of-Tolerance hse deviations relate to the linear dimensions of piping / pipe supports and locations of pipe supports. Linear dimensions relate to the configuration / geometry of piping systems and supports and, if signifi-cant, may affect the stress analysis results. Of 136 total deviations for this ites,109 deviations are in the area of linear dwnsions, while i 21 deviations are related to the support locations. N remaining 6 de-i viations are in the area of elevation and bend radii of piping systems.

Details of the number of deviations for linear dimensions, support /

restraint locations, and miscellaneous areas for various population groups are given in Table 3. Tables 4 and 5 provide details on the mas-nitudes of these deviations. Potential impact of these deviations on the stress analysis of piping systems is discussed below.

Linear Dimensions In the piping configuration groups of LBCO and SBCO, 47 deviations out of a total of 50 deviations are less than 12 inches. These deviations in configuration of the piping reprecent small percentage changes in dimen-sions. Effects of these small changes on the stresses in piping systems and support loads would be small. Therefore, no further action is re-quired to address these deviations.

N remaining 3 deviations (1 ft - 4 1/2 in, and 4 ft - 8 3/4 ist: and

, 1 ft - 0 1/2 in.) are isolated cases and will be evaluated in the SRP.

l 1 In the pipe support / restraint population groups of LBSR, LBSN', SBPS, and I PWRE, 50 out of a total of 59 deviations have linear dimension devia11ons of less than 3 in., six deviations (6 out of 59) are in the 3- to 5-in.

range, and the remaining three deviations are between 7 in. , 8 in., and

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and 1 ft - 0 1/16 in. Fifty-six deviations less than 6 in. are related to bolt hole locations, base plate dimensions, pin-to pia dimensions of struts, and geometry of support frame members being out of tolerances.

These deviations represent small percentage changes in dimensions with no appreciable effects on the stress analysis results.

N other three deviations are as follows: 0 ft - 7 in. deviation is related to support I-beam located 7 in. above the required elevation.

This changes the required rod length only and does not affect the design capacity of support components. N 8-ia. deviation is in the required distance of 7 ft - 411/16 in between the centerline of pipe and top of rear bracket of strut. This does not affect the capacity of support com- l ponents adversely and thus is not significant. N remaining deviation '

of I ft - 01/16 in. is in the dimension between the centerline of tube steel support member and the the centerline of base plate. N ERC-SSE l Group has reanalyzed the support with the revised geometry and found the support to be acceptable. Based on the above discussion, it is concluded I

that these deviations are insignificant and changes in the SRP are not required.

Support / Restraint I,ocations l Nine of the 21 DRs in this group are in the area of rupture restraints  ;

and thus do not affect the SRP. N remaining 12 DRs relate to the '

deviations in support locations. Ten of these deviations are less than i 6 in. , and two deviations are 9 in. and 9 1/8 in. Nee deviations are j small and thus have no appreciable effect on the stress analysis of a piping system.

h remaining six deviations were in the areas of pipe elevations and bend radii with no adverse trend. Therefore, no impact on SRP is -

, expected.

Ites 2 Welds Missina. Undersized or Underlecath A tot &1 of 113 deviations in this ites were in the area of supports and restraints as shown in Table 2 and were related to the missing, under-sized, or underlength welds.

i The majority of these deviations were in the area of undersized welds (1/16 in. to 1/8 in.) over a small portion of the total welds length and ,

thus would not reduce the overall strengths of the connections. It should be noted that the recent changes in the acceptance criteria of welds (Reference 7.6) allow 1/16 in. undersized weld for one-fourth of

! the weld length. This is based on computation of the reduced shear area due to undersized welds and limiting the reduction in the shear ares per-centage to reasonable values. Moreover, ERC has performed structural adequacy evaluation of the deviations for as-built veld configuratidha of individual supports / restraints and has concluded that support / restraint capacity is not affected significantly. b refore, these deviations do l not require further evaluation for impact on the stress requalification program. s j 1802-1545405-HC4 4

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i Ites 3 Clearance Violations There were 82 deviations where small bore and large bore piping clearanc-es were less than those required by the piping erection specification. i The clearances are among pipe-to pipe, pipe with wall penetration sleeves, and pipe with hangers, walls, handrails, etc. A final walkdown will be performed by SWEC at the completion of the stress requalific'ation i

effort to verify that sufficient clearance exists between the piping sys-tems and the adjacent structures (Section 7.2 of Reference 7.2). There-fore, no additional action is required.

Ites 4 Anchor Bolt Violations Of a total of 33 deviations in this ites, 10 deviations were related to the depth of embedments being smaller than required, 9 deviations were in the area of minimum spacing requirements, and the remaining 14 were mis-cellaneous deviations. Embedment depths were shorter by a minimum of 0.125 in. for a required embedment of 61/2 in to a maximum of 1.81 in.

for a required esbedeent of 7 1/2 in. Spacing violations ranged free 0.125 in. of a required minimum of 5 5/8 in. to 4.75 in. for a required

, minimum spacing of 14 3/4 in. These violations have been evaluated by l

ERC on an individual basis using the reduced strengths of these bolts for i

smaller and overlapping shear cone capacities and found to be acceptable.

I Additionally, the number of cases is less than 5 percent with no adverse trend. Therefore, additional effort is not required in this area.

Item 5 Gaps in Connections and Supports There were 25 deviations in pipe supports and 36 deviations in rupture restraints where either supports and piping had gaps which did not meet the design requirements or connections were not tight and mating surfaces did not bear at all locations.

A total of 25 DRs in pipe support population groups of LBSR and SBPS have gaps between piping and support frames / restraints which deviate from the requi' red gaps by a minimum of 11/32 in, to a maximum gap of +1/16' and

-1/4 in. As a part of the SRP, the project has redefined the asp re-quirements for box frames and is reshimming the gaps to meet the revised requirements of Attachment 4-11 of CPPP-7 (Reference 7.5). Therefore, no further action is required to address these deviations.

The remaining 36 deviations are in the population group PWRE of rupture restraints. Since these deviations do not relate to the efforts of the SRP, they are not addressed further in this report.

Item 6 Richmond Inserts - Thread Engagement Less Than Minimum l

There were a total of 28 deviations for pipe supports and restFaints where thread engagement in Richmond inserts or of bolts into nuts was less than minimum. A total of 18 deviations in pipe support population groups of LBSR and LBSN and 2 deviations for pipe rupture restraint (PWRE) are for the Richmond inserts where thread engagementA for 1 1/2-in.-diameter inserts are less than minimum of 3 1/8 in. The devia-tions range from 1/16 in. to 1 7/8 in. The remaining 8 deviations in

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pipe rupture restraint population group PWRE have nuts which do not en-1 gage bolts fully. Capacities of these connections with thread engagement less than the 31aisua need to be established through analysis and/or testing. This issue is being addressed under the CPRT program for Issue ISAP V.b - Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports, and testing is planned. After the allowable capacities of these and other similar inserts are established through analysis / testing, structural adequacy of these connections should be evaluated to determine the need for any required modifications. No action is required at this time.

Item 12 Miscellaneous Deviations Thirty-one out of 89 deviations in this category were related to either wrong items installed or missing items. These deviations are hardware-related and thus would be addressed under the HVP. The remaining 54 deviations relate to miscellaneous areas such as gap behind base

' plates (5), gouges due to grinding (4), angularity out of tolerance (4),

gap between pipe and supports greater than tolerance (14), thread engage-l ment in strut rods (9), and other miscellaneous items of specific nature.

These deviations are small in number and do not have any generic implica-tions on the stress requalification program. They also have been ad-dressed by ERC on a specific basis and thus do not require any further action for the SRP. ,

6.0 CONCLUSION

S I

i Based on the discussion in Section 5.0, it is concluded that approximate-i ly one-third of the construction deviations are hardware related and should be corrected under the Hardware Validation Program. The other two-thirds of the deviations are related to six different items.

Item 1 is related to deviations in locations of supports and/or re-

. straints and piping / supports linear dimensions out of specified toleranc- '

es. Magnitudes of deviations were evaluated, and it was concluded that the deviations do not show any trend and are not significant. Therefore, -

generic changes in the SRP are not required. -

Ites 2 is related to missing, undersized, and underlength welds where the majority of deviations were related to welds being undersized from 1/16 in. to 1/8 in, over a small portion of weld lengths. The overall strengths of these welds are not reduced significantly and therefore do not require a generic change in the SRP.

Item 3 is related to clearances between piping to piping and other compo-nents. A final walkdown will be performed by SWEC to resolve this item.

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Ites 4 is related to anchor bolts where the depth of embedments and the l spacing did not meet the design requirements. These deviations have been l evaluated and accepted by ERC using reduced strengths of tihe anchor bolts. There was also no adverse trend. Thus, no change in' the SRP is required.

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Item 5 relates to says in connections and gaps between piping and sup-ports, and is being addressed by TUGC0 as a part of the Hardware Valida-tion Program.

Item 6 relates to inadequate thread engagem'ent for Richmood inserts and is addressed as a part of the CPRT Issue Specific Action Plan (ISAP) V.b, where testing is planned to determine the capacities of inserts with in-adequate thread engagement. No further action can be taken in the SRP at this time.

It is concluded, therefore, that there is no need to change the stress requalification program or procedures to address the ERC generated deviation reports on a specific or generic basis.

7.0 REFERENCES

7.1 Comanche Peak Project Procedura CPPP-18, Procedure for Evaluation of ERC Deviation Reports, Revision 1, dated November 7, 1986 7.2 Comanche Peak Project Procedure CPPP-6, Pipe Stress / Support Requalification Procedure, Revision 2, dated April 18, 1986 7.3 Assessment of TUGC0 As-Built Documentation for Piping and Pipe Sup-ports, Finzl Report, dated July 2, 1986, L. S. Wigley

, 7.4 Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797 Supplement No.13, U.S. Nuclear Regulatory Comunission, dated May 1986 7.5 Comanche Peak Project Procedure CPPP-7, Design Criteria for Pipe Stress and Pipe Supports, Revision 2, dated April 25, 1986

, 7.6 Visual Weld Acceptance Criteria for Structural Welding at Nuclear l Power Plants, Revision 2, May 7, 1985, Nuclear Construction Issues l , Group, Southern Company Services, Birmingham, Alabama l

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TABLE 1

SUMMARY

OF DEVIATION REPORTS Population No. of DRs No. of Catenory

' Code Reviewed Deviations A B C, LBC0 61 74 64 10 0 SBC0 71 79 76 1 2 LBSR 15 4 174 96 67 11

, LBSN 205 208 98 103 7 PWRE 212 225 136 88 1 SBPS 66 70 43 15 12 PBOM 11 11 4 6 1 TIMi 8 8 6 0 2 SBWM 1 1 1 0 0 LBWM 3 3 3 0 0 Total 792 853 527 290 36 l Percent 100 61.8 34.0 4.2 i

1802-1545405-HC4

1 TABLE 2 Sl29tARY OF ISSUES Deviation Mc. of DRs in Population Iesue Cateaory LBCO SBCO .LBSR LBSN PWRE SBPS PROM TIA41 SB646 LBitt Total Percent

1. Locations / dimensions A 23 33 20 20 30 10 0 0 0 0 136 16.0 out of tolerance
2. Welds missing, under- A 0 0 26 34 36 11 0 5 0 1 113 13.2 sized, or underlength
3. Clearance violations A 39 43 0 0 0 0 0 0 0 0 82 9.6
4. Anchor bolt violations A - -

8 13 2 6 0 0 0 0 29 B - -

1 -

2 0 0 0 0 0 3 3.9 C - -

0 -

1 0 0 0 0 0 1

! 5. Gaps in connections and A - -

11 0 36 14 0 0 0 0 i supports 61 7.1 i 4

6. Richmond inserts - A - -

13 5 9 0 0 0 0 0 27 i

Thread engagement less B - - - -

1 0 - - - -

1 3.3 than the minimum '

7. Locking devices B - -

3 14 12 6 0 0 0 0 35 4.1

missing
8. Washers missing or not B - -

0 0 26 0 0 0 0 0 26 3.0 j covering boltholes i 9. Paint in spherical B - -

16 25 0 2 0 0 0 0 43 5.0 bearings for snubbers l

10. Clamp halves not B - -

14 18 0 3 0 0 0 0 35 4.1

parallel I M02A- 1545405-ilC4 I

i Deviation No. of DRs in Population Issue CateRory LBCO SBCO LBSR LBSN PWRE SBPS PROM TIA46 SBWM LBl#6 Total Percent-

11. Caps > smallest shim B - -

14 16 0 0 0 0 0 0 30 for snubber C - - -

1 0 0 0 0 0 0 3*6 1

j 12. Miscellaneous devia- A 2 0 18 26 33 2 4 1 0 3 89

tions B 10 1 19 30 37 4 6 0 0 0 107 26.9 C 0 2 11 6 0 12 1 2 0 0 34 I

TOTAL 74 79 174 208 225 70 11 8 1 3 853 1

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TABLE 3 LINEAR DIMENSION / LOCATION DEVIATIONS No. of Deviations in the Area of

. Population Linear Support / Restraint Pipe Elevation / Total Group Dimensions Locations Bend Radius DRs LBCO 21 0 2 23 SBCO 29 0 4 33 LBSR 16 4 0 20 LBSN 15 5 0 20 PWRE 21 9 0 30 SBPS 7 3 0 10 Subtotal 109 21 6 136 4

Total: 136 i

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1802-1545405-HC4

TABLE 4 MAGNITUDES OF PIPING / SUPPORTS LINEAR DIMENSION DEVIATIONS Maanitudes of Deviations (Inches)

Population Greater Group Total DRs M 3-6 6-9 Than 9 LBCO 21 15 5 1 0 SBCO 29 8 16 0 5 (Deviations of 1 ft - 4 1/2 in.,

1 ft - 0 1/2 in.,

O ft - 10 in.

4 ft - 8 3/4 u.

1 ft - 0 in.)

LBSR 16 12 3 1 0 LBSN 15 11 2 1 1 (Deviation of 1 ft - 0 1/16 in.)

PWRE 21 20 1 0 0 SBPS 7 7 0 0 0 TOTAL 109 73 27 3 6 1802-1545405-HC4

D ,

TABLE 5 MAGNITUDES OF SUPPORTS / RESTRAINT LOCATION DEVIATIONS Maanitudes of Deviations (Inches)

Population Greater Group Total DRs 0-3 3-6 6-9 Than 9 ,

LBCO 0 0 0 0 0 SBCO O O O 0 0 LBSR . 4 3 1 0 0 LBSN 5 1 2 2 (O'-9" 0 PWRE 0'-9 1/8")

9 8 1 0 0 4

SBPS 3 3 0 0 0 TOTAL 21 15 4 2 0 h

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i 1802-1545405-HC4

AT".'ACHMENT 1 l . A TYPICAZ, DEVIATION REPORT Page 1 of 1 l Comanche Peak Response Team ERC Deviation Report (DR)

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AT':'ACHMENT 2

. MG OF DRs peg 3 t og g l .

. COMANCHE PEAK

POPULATION CODE: .

GENERIC CATEGORY TYPE OF DEVIATION . RESOLUTION A B C CODE DESCRIPTION I ITEM REMARKS

. DR. NO.

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ATTACHMENT 3 COMANCHE PEAK STEAM EI.ECTRIC STATION

  • PIPING - PIPE SUPPORTS ERC DEVIATION REPORT (DR)

EVAI,UATION SHEET DR No. System

Reference:

BRP BRH BRML GHH SWEC SRP Stress Problem No.

O Unit 1 C Unit 2 O Coaumon Deviation Type: M- S- C-Deviation Summaary:

Catenorization: (1) Deviation Requires Drawina Chanas? Yes C No O .

(2) Deviation Affects SRP Calculation? Yes a No O Yes on Questions (1) and (2) Catenory A C Yes on Question (2) Only Catesory B C No on Questions (1) and (2) Catenory C C Evaluation (include justification as required) o Evaluated by: (Date)

Reviewed by: (Date) 1802-1545405-HC4

Pass 1 of 10 ATTACHMENT 4 RESULTS OF THE REVIEW Population Code IM-LBCO I.

II. Number and Category of DRs Reviewed 6J Category A 64 Category B 10 Category C 0 Total 74

, III. Issues Identified ,

Ites in Description Numbers Category Table 2

1. Pipe to pipe clearance 18 A 3
2. Linear dimension out of tolerance 10 A 1
3. Out-of-location tolerance 11 A 1
4. Pipe-to-support clearance 10 A 3
5. Pipe-to-conduit or cable tray clearance 5 A 3
6. Pipe-to-sleeve clearance 4 A 3
7. Valve installed backwards 3 B 12
8. Material installed wrong or missing 2 A 12
9. Elevation out of tolerance 2 A 1 i 10. Flow element installed backwards 3 B 12

, 11. ID problems 1 B 12 i

i 12. Expansion joint out of tolerance 1 B 12

13. Missing jaa nut on tie bar 1 B 12
14. Flow arrow on valve missing 1 B 12
15. Pipe-to-wall clearance 2 A 3 1802-1545405-HC4 i

l - - - - - - - - - ---- -

- - - - - - - - - - ~ - -

Pcg2 2 cf 10 ATTACHMENT 4 (Cont)

RESULTS OF THE REVIEW l

I. Population Code IM-SBC0 II. Number and Category of DRs Reviewed 11 Category.A 16 Category B 1 Category C 2 Total 79 III. Issues Identified Item in Description . Numbers Ca tego ry Table 2

1. Pipe-to-pipe clearance 27 A 3
2. Linear piping dimension out of 18 A 1 tolerance
3. Out-of-location tolerance 11 A 1
4. Pipe-to-support clearance 7 A 3
5. Valve clearance 4 A 3
6. Pipe-to-sleeve clearance 3 A 3
7. Elevation out of tolerance 3 A 1
8. Pipe-to-cable tray clearance 2 A 3
9. Valve installed with flow arrow 1 B 12 reversed

, 10. Pipe bend greater than tolerance 1 A 1

11. Conflict in valve identification 1 C 12
12. Missing identification 1 C 12 4

1802-1545405-HC4

Pcga 3 et to ATTACHMENT 4 (Cont)

~

I. Population Code IS-LBSR II. Number.and Category of DRs Reviewed 154 Category A 96 Category B 67 Category C 11 Total 174 III. Issues Identified Item in Description Numbers Catenary Table 2

1. Weld missing, undersized, or under- 26 A 2 length
2. Anchor bolt violations 8 A 4 8
3. Member or plate out of tolerance 16 A 1
4. Paint on spherical bearings 16 B 9
5. Clamp halves out of parallelism 14 8 10 i
6. Miscellaneous deviations 6 A 12 5 8 1 C
7. Gaps between pipe and supports 11 A 5
8. Thread engagement problems (strut 1 A 12 assemblies) and nut threrads 7 8
9. Gap on brackets > smallest shim 14 8 11
10. Mark identification problems 8 C 12
11. Wrong item installed 4 A 12 2 8 2 C
12. Gap behind base plate 4 A 12
13. Locking devices missing or broken 3 8 7
14. Angularity out of tolerance 3 A 12
15. Support locations out of tolerance 4 A 1
16. Cotter pin broken, missing, etc 4 5 -

12

17. Missing items 1 B 12
18. Thread engagement - Richmond inserts 13 A ,

6 1802-1545405-HC4

s P ge 4 et 10 ATTACHMENT 4 (Cont)

I. Population Code IS-LBSN II. Number and Category of DRs Reviewed 205 Category A 98 Category 8 103 Category C 7 Total 208

, III. Issues Identified Ites in Description Numbers Ca tego ry Table 2

1. Weld missing, undersized, or under- 34 A 2 length
2. Paint on spherical bearings 25 B 9
3. Clamp halves out of paralleliss 18 8 10
4. Gaps on bracket of snubber > smallest 16 8 11 shim 1 C
5. Anchor bolt violations 13 A 4 1 B 12 1 C 12
6. Member or plate out of tolerance 15 A 1
7. Miscellaneous deviations 7 A 12 6 B 12
8. Mark identification problems 9 R 12 3 C
9. Wrong item installed 8 A 12 5 8 12 2 C 12
10. Locking devices missing 10 8 7

, 11. Thread engagement problems - Richmond 5 A 6 inserts

12. Missing items 4 A 12 2 B 12
13. Beveled washer missing (slope >1:20) 4 8 7 14 Angularity out of tolerance 1 A 12 3 8
15. Support location out of tolerance 5 A 1
16. Cotter pin broken, missing, etc 4 8 12
17. Thread engagement problems - threaded 6 A 12 rods ~

1802 1545405 HC4

Pag) 5 ef 10 ATTACHNENT 4 (Cont)

I. Population Code IS-PWRE II. Number and Category of DRs Reviewed 212 Category A 131 Category B 88 Category C 1 Total 226 III. Issues Identified Description Item in Numbers Ca tena ry Table 2

1. Welds missing, undersized, or under- 36 A 2 length, wrong type or location
2. Gaps in bolted coanections 26 A 5
3. Members or plate out of tolerance 21 A 1
4. Identification missing 13 3 12
5. Wrong or extra material installed, or 11 A 12 sissing materials 6 B
6. Washers missing or do not cover hole 15 B 8
7. Locking devices missing 12 3 7
8. Gap between pipes and supports > 14 A 12 tolerance
9. Beveled washers missing $1 8 8
10. Lack of full thread engagement 9 A 6 1 5
11. Shine do not cover 100 percent of 10 8 5 nating surfaces
12. Location out of tolerance 10 A 1
13. Miscellaneous deviations 5 A 12 5 5
14. Cotter pin problems 5 3 12
15. Anchor bolt violations 2 A 4 2 8 1 C
16. Shim stacks not welded 3 8 12
17. Gauges due to grinding 2 A 12
18. Cap behind base plate 1 A 12 1802-1545405 HC4

Pas] 6 cf 10 ATTACHMENT 4 (Cont)

I. Population Code IM-S3ps II. Number and Category of DRs Reviewed 66 Category A 41 Category B 15 Category C 12 Total 70 Issues Identified

. III.

Ites in Description Numbers Catenory Table 2

. 1. Gaps at deadweight supports 14 A 5

2. Weld missing, undersized, or under- 11 A 2 length
3. Identification problems 8 C 12
4. Anchor bolt violations 6 A 4
5. Support dimensions > tolersace 6 A 1
6. Material missing or wrong 1 A 12 2 3 2 C
7. Locking devices missing 6 3 7
8. Location of support > tolerance 4 A 1
9. clamp halves out of para 11elise 3 8 10
10. Base plate has 1/4 in.-diameter x 2 C 12 i

1/4 in, holes

11. Spherical bearing is painted 2 8 9
12. Miscellaneous deviations 1 A 12 l 1 a
13. Thread engagement less than the minimum 1 8 12 required (strut assembly) l l .

l 1802-IS45405-HC4 l

L

Peas 7 of 10 ATTACHMF,NT 4 (Cont)

I. Population Code IM-PSOM II. Number and Category of DRs Reviewed 11, Category A 4 Category B 6, Category C 1 Total 11 III. Issues Identified

~

Item in Description Numbers Catesory Table 3

1. Nuts are not tight 5 B

'12

2. Stud is not one thread higher than nut 'A 2 12 - - ,

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3. Capscrews installed instead of stud 1 A 12
4. Gasket wrong color code 1 A 12
5. No idcatification on flange 1 C l2 f.'
6. Gasket does not cover flange 1 B 12

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1802 1545405-HC4

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, P 32 8 of 10

. _ AITACHMENT 4 (Cont)

I. Population Code SBW ec II. Number and Category of DRs Reviewed 1

[ Category A 1 Category B 0, Category C 0 Total 1

{ ,." III. Issues Identified Item in

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Description Numbers Catenory Table 2

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Undersized weld 1 A 2 i ,

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1802-1545405-NC4 14

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, ATTACHMENT 4 (Cent)

I. Population Code IM-TUWM II. Number and Category of DRs Reviewed 8_

Category A 6 Category B 0 Category C 2 Total 8 III. Issues Identified Item in Description Numbers Category Table 2

1. Undercut on welds 3 A 2
2. Wrong identification of weld 2 C 12
3. Undersized welds 2 A 2
4. Gouges due to grinding 1 A 12 w

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1802-1545405-HC4

Pegs 10 of 10 AITACHMENT 4 (Cont)

I. Population Code IM-LBWM II. Number and Category of DRs Reviewed 3 Category A 3 Category B 0 Category C 0 Total 3 III. Issues Identified Item in Description Numbers Category Table 2

1. Rust on stainless steel pipe 1 A 12
2. Gouging due to grinding 1 A 12
3. Weld shrinkage 1 A 12 s

I 1802-1545405-HC4

O' TABLE 1

SUMMARY

OF DEVIATION REPORTS Population No. of DRs No. of Catenory Code Reviewed Deviations A, B C LBCO 61 74 64 10 0 SBCO 71 79 76 1 2 LBSR 154 174 96 67 11 LBSN 205 208 98 103 7 PWRE 212 225 136 88 1 SBPS 66 70 43 15 12 PBOM 11 11 4 6 1 TUWM 8 8 6_ 0 2 SBWM 1 1 1 0 0 LBWM 3 3 3 0 0 Total 792 853 527 290 36 Percent 100 61.8 34.0 4.2 o

l 1802-1545405-HC4

xc J. F. Streeter 4

0 STONE 6 WEBSTER ENGINEERING CORPORATION STONE & WEBSTER ENGINEERING CORPORATION - NEW YORK ONE PENN PLAZA 250 WEST 34TH STREET N EW YOR K, N EW YOR K aconESS ALL CORRESPONCINCE TO PO son 2703 NE W *ORM NE W YORK 10116 CL':.. "*:*:' llU" ;H?

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Mr. John W. Beck June 19, 1986 Vice President Texas Utilities Generating Company J.0. No. 15454 a las Texas h5b y PIPING AND SUPPORT REQUALIFICATION PROGRAM COMANCHE PEAK STEAM ELECTRIC STATION JUN 2012EG

^

Enclosure 1 - CPPP-5 Small Bore Walkdown Report Enclosure 1. describes the results of the walkdown of small bore piping conducted by SWEC in accordance with Project Procedure CPPP-5. SWEC requests that TUCCO respond to this report within 30 days.

With the resolution of the items identified in Attachments 2 and 3 of the report, the as-built documentation is adequate to initiate small bore stress requalification.

. k R. P. Klause Project Manager RPK/CEW:bjf enclosure cc: L. D. Nace (TUGCO) - 1/1 J. C. Finneran (TUGCO) - 1/1 R. L. Cloud (RLCA) - 1/1 T. Snyder (TERA) -

1/1 E. J. Brabazon (ERC) - 1/1 J. Hansel (ERC) -

1/1

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Job No. 15454.05 Page 1 of 4 TEXAS UTILITIES GENERATION C0. (TUGCO).

COMANCHE PEAK STEAM ELECTRIC STATION CPPP-5 SMALL BORE F1 ELD WALKDOWN REPORT 4

Prepared By [ [ 8&.Se/

J. J. Oliver Field Walk Task Leader Reviewed by M R. R. Wrucke Proj t Engineer Approved / . W R. .?. Klause Project Manager 01291-1545405-N1 e

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Page 2 O

INTRODUCTION A sample verification of existing Unit #1 "As-Built" documentation for Small Bore ASME piping systems and supports not subjected to the TUGC0 As-Built Program was performed in accordance with Proj ect Procedure CPPP-5. The purpose of this effort was to establish sufficient confidence in the adequacy of dimensions and functions shown on the documents of record to support the initiation of the small bore pipe stress requalification effort. This report summarizes the findings and conclusions of the verification effort.

Reinspection of hardware within the scope of the QA/QC program is within the scope of the construction adequacy program (Appendix B of Comanche -

Peak Response Plan and Issue-Specific Action Plans). The results of this walkdown ladicate that the program (use of design documents as input to the certification effort) implemented by TUGC0 is adequate to initiate the small bore requalification effort. -

SCOPE Four unique samples were randomly selected to verify the following attributes:

(a) Valve Location (b) Pipe Support Location (c) Pipe Support Function (d) Valve and Support Orientation These attributes were selected because they have the greatest potential for impact on the pipe stress analysis requalification effort. Other less significant attributes exist, but the methods of verifying the above attributes (distance from elbows, tees, valves, supports, etc.)

indirectly verify other attributes (e.g., dimensions and configurations).

f aThe total population and sample size for each attribute is shown on Attachment 1. The sample sizes and accept / reject criteria were determined from SWEC Quality Assurance Directive (QAD) 7.11 Rev. A.

SWEC tolerances (see CPPP-5) were established for each attribute. These tolerances are consistent with tolerances previously used by SWEC on other as-built programs. The tolerances also consider the sensititivity of the data to the pipe stress analyses.

l

SUMMARY

OF RESULTS l

l Approximately 1800 manhours were expended over a period of three weeks to complete the physical walkdown.

l

  • Valve Location - Valve locations are adequately described. One hundred and twenty-four of the 125 valves were found to be within r SWEC tolerances. Valve number 1-8893 (BRP-SI-1-SB-043) was l determined to be outside SWEC required tolerances (see Attachment j 2).

i i

01291-1545405-N1

Page 3

  • Pipe Support Location - Pipe locations support are adequately described. Of the 200 supports sampled, 198 were within SWEC tolerances. Pipe support numbers FW-1-SB-013-002-5 and CH-1-SB-009A-005-3 were determined to be outside SWEC required tolerances (see Attachment 2).
  • Pipe Support Function - Pipe support functions are adequately described. Of the 200 supports sampled, 198 were within SWEC required tolerances. The function of pipe support numbers H-CS-1-AB-215-007-5 ar.d H- AC-X-EC-011-002-5 did not agree with the function depicted on the pipe support drawing. (see Attachment 2.)
  • Valve and Support Orientation - Valve and support orientation are adequately described. Of the 200 valves and support sampled, 199 were found to be within the SWEC required tolerances. Pipe support H-CC-1-RB-051-009-5 was determined to be outside SWEC required tolerances. (See Attachment 2) .

During the walkdown there were 29 items that were inaccessible.

These items were replaced with other items using the same random sample selection process used for the initial sample selection.

CONCLUSIONS The design documents of record are adequate to initiate the small bore requalification effort. Several miscellaneous observations were identified during the walkdown effort. (See miscellaneous observations attachment 3). TUGC0 should expeditiously resolve the observations to minimize their impact on the small bore requalification effort. The more significant observations are as follows:

  • Configuration Control - The configuration of the Class 5 piping that is within the boundary of the ASME stress analysis

, is usually not shown on the BRP drawings. Per conversation with TUGC0 Engineering personnel, routing changes to this piping - are made by CMC or DCA against composite drawings.

These changes are reviewed by the G&H piping group but are not reviewed by the responsible stress analysts. Therefore, there is no assurance that the configuration used in the stress analysis still reflects the present installed configuration.

Consequently, this piping should be documented and controlled to the same degree as the ASME portion of the piping. Note:

The Class 5 support locations are shown on the GHH drawings.

Changes to GHH drawings are required to be reviewed by engineering.

  • Gaps - Cases were identified where the close clearance (2-way) gaps exceed the maximum allowable gap of 3/16" (generally 1/4" was observed). Note: A revision of DCA-22563 has recently been issued by TUGC0 to address the gap concerns on a generic basis.

This DCA will resolve this concern.

01291-1545405-N1

Page 4

  • Document Control - During the package preparation phase of the walkdown effort, drawings were obtained from document control.

However, when the revision level of these drawings were reviewed against ' the revision level per the " HITS" report, several discrepancies were observed for the support location drawings. It appears that there are "CP" revision level drawings that exist but have not been issued through the Document Control system. Per conversation with TUGC0 Engineering, this was the result of an ASME Section XI TUGC0 Operations Procedure. This procedure would not allow the l release of these drawings to the Document Control Center (DCC) until construction was completed. This procedure has been revised and CP drawing revisions are now being issued to DCC before start of construction.

ACTION REQUIRED

\ .

TUGC0 has initiated a review of these concerns and anticipates i resolution within 30 days of the issue of this report. The response to

! this report should identify specific actions taken to resolve the inconsistencies identified in Attachments 2 and 3. It is expected that TUGC0 will evaluate these items for cause, extent of condition and corrective / preventive action in accordance with their QA program.

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01291-1545405-N1

e ATTACEMENT 1 Page 1 of 1 SMALL BORE FIELD WALKDOWN POPULATION AND SAMPLE SIZE / SELECTION

-I. Population / Sample Size TOTAL SAMPLE Source of Accept /

ATTRIBUTE' POPULATION SIZE Total Population Reject Valve Location 2325 125 Note 1 2/3 Support Location 6526 200 Note 2 5/6 Support Function 6526 200 Note 2 5/6 Valve and Support Orientation 6652 200 Note 3 5/6 -

NOTE 1 -

List of valves developed by SWEC from review of BRP Drawings in SWEC Scope. (See Attachment 4)

NOTE 2 -

HITS Report sort titled "SBH-NOX-SPCL-RPT" dated 12/11/85 NOTE 3 -

See Attachment 5 II. Sample Selection The specific samples were selected as follows:

1. Consecutive numbers (from 1 to the population size) were assigned to each item listed in the appropriate index (Notes 1, 2_and 3).
2. Four sets of numbers (one set for each attribute) were taken i

from a random number table.

3. The item (valve or support) corresponding to the random number was selected for the walkdown.

l 01291-1545405-N1

t ATTACHMENT 2 Page 1 of 1 I i 1 l l DlHENSIONS i l ACTUAL l I

I ITEM 70 BE VERIFIED 1 DRAWING NUMBER I REV. I ATTRIBUTE I TO BE I TOLERANCE I DIMENSION l REMARKS I i 1 I I I VERIFIED l i BY SWEC i 1 I l 1 1 1  ! I I I l Valve No. 1-8893 1 Sl-1-SB-043 1 8 I Valve Location I l'-3" l 2 3" l l'~s I/4" i I I I I I I I I I I 1 1 Pipe Support 1 GHH-FW-1-SB-013 1 3 i Support Location i l'-9" l 1 3" l 3'-8 3/4" I i

, 1 FW-1-SB-013-002-5 I I I I I I i l j i l I I I I i i I

I Pipe Support i GHH-CH-1-SB-009A I CP-!  ! Support Location 1 5'-0" 1 2 6"  ! 4'-5 1/2" I i i

l CH-1-SB-009A-005-3 I I 1 I I I I I I I I I I I I I I Pipe Support i H-CC-I-RB-051-009-5 1 1 i Valve and Sup- l 90* 1 1 5* I 77* I I I H-CC-1-RB-051-009-5 I I I port Orientation i 1 1 I i 1 I i i l I i l i i l'ipe Support 1 H-CS-I-AB-215-007-5 plus i 2 1 Support Function I l-Way 1 -

l 2-Way I See Note 1 I l H-CS-1-AB-215-007-5 1 Typical CP-AA-034 l l l Restraint 1 i Restraint 1 1 1 I l i I I I i i g i Pipe Support i H-AC-X-EC-Oll-002-5 1 1 1 Support Function i I I i See Note 2 I I H-AC-I-EC-Oll-002-5 I I I I I I I I I I I I I I I I I Notes 1

1. Support is designed as a one-direction lateral support. A two-direction support is installed. The required gap of 3/4" in - the j unrestrained direction is actually 1/16" per field measurement.

] 2. Support number AC-X-EC-Oll-002-5 does not exist at the location shown on the CHH drawing (i.e., center of tank). However, there are two U-bolt type supports located on either side of the oil separator tank that are acting as axial restraints (and lateral). These

) U-bolts are not identified on the drawings. (Note: The piping was stress-analyzed by Corporate Consulating and Development company LTD [CCL]. The pipe supports were designed by PSE as requested by THE.)

i i

COMPK1-26:1 ,

q A NACHMENT 3 Page 1 of 2 MISCELLANEOUS OBSERVATION FROM

.SMALL BORE WALKDOWN The following conditions outside the scope of CPPP-5 were observed during the walkdown effort.

1. Discrepancy between valve number shown on. BRP . drawing and tag on valve in field. Some examples of this observation are:

A. Valve 2CH-453 per BRP-CH-1-AB-031 Re.v. 12 is tagged as 2CH-458 in field.

B. Valve ICC-043 per BRP-CC-1-AB-049 Rev. 13 is doubled tagged as ICC-043 and ICC-043 in field.

2. Incorrect close clearance gaps were observed.

A. CC-1-EC-020-002-5 Gap = 1/4" B. SW-1-SI-006-014-3 Gap = 1/4" C. CH-X-AB-024-019-3 Gap = 1/4" D. CS-1-RB-013A-024-2 Gap = 1/4" l 3. GH-X-AB-043-003-3 elevation 875'-5" per GHH drawing should be 857'-5".

,4 . GHH-CC-X-AB-013 Rev. 2 -

An unidentified support exists between support 001 and the elbow. This support is not shown on the GHH drawing.

5. BRP-CS-1-SB-063 Rev. 5 -

Piping connection to boron tank TBX-XIMEBS-01 does not agree with field condition. Fittings exist but are not shown on the BRP drawing.

l 6. Pipe support drawing H-GH-X-AB-020-026-5 shows support installed on l the 3/4" line. There is a reducing insert at the tee, consequently

) the location of the support is actually on the 2" portion of the ,

l line.

7. Pipe support FSI-1-2107-01-D-01-1Q2 Rev. CP-1 dated 6/3/85 - design
changes made on Rev. CP-1 have not been installed in the field (previous revision of drawing is installed).
6. GHH-CS-1-AB-215 -

The drain line located below support 007 is supported with a 2-way (box type) support which is not shown on the l GHH drawing.

01291-1545405-N1 1

t Attachment 3 Page 2

9. Discrepancies between the revision level received from Document Control and the revision level shown in the HITS reports were identified. Some examples are:

A. GHH-CC-1-AB-054 Rev. 6 from DCC, Rev. CP-1 Per HITS.

B. GHH-D3-1-DG-003A Rev. 11 fron DCC, Rev. CP-1 per HITS.

C. GHH-DD-1-AB-011 Rev. 5 from DCC, Rev. CP-1 per HITS.

D. GHH-CS-1-AB-227B Rev. 4 from DCC, Rev. CP-1 per HITS.

10. GHH-CC-1-RB-051 -

Line is in contact with cable tray support betweens supports 007 and 008.

11. Configuration Control -

The configuration of the Class 5 piping that is within the boundary of the ASME stress analysis is usually not shown on the BRP drawings. Per conversation with TUGC0 Engineering personnel routing changes to this piping are made by CMC or DCA against composite drawings. These changes are reviewed by the G&H piping group but are not reviewed by the responsible stress analysts. Therefore, there is no assurance that the configuration used in the stress analysis still reflects the present installed configuration. Consequently, this piping should be documented and controlled to tne same degree as the ASME portion of the piping. Note: The Class 5 support locations are shown on I

the GHH drawings . Changes to GHH drawings are required to be reviewed by engineering.

1 i

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l 01291-1545405-N1 i

I . . _ _ _ _ _ _ _ . . _ . , . _ . - - - . - - - . -- - - - - - - - - - = - - - - -

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ATTACHMENT 4 Page 1 of 1 METHOD FOR OBTAINING VALVE LOCATION POPULATION The following method was used to determine total number of small bore valves associated with small bore ASME piping not subjected to the TUGC0 As-Built Program.

1. A list of small bore piping isometrics (BRP drawings) for the piping not subjected to TUGC0 As-Built pregram was generated using the small bore HITS (hanger information tracking system) report.

This was achieved by sorting BRP drawings which at;e not associated with stress problems.

2. The record prints of these BRP drawings sere reviewed. A list of all valves on the small bore piping was generated.
3. SWEC identified that portions of this small bore piping had been subjected to the As-Built program. Small bore valves which were included in the As-Spilt program, were deleted from the list generated in Item 2.

e 9

l l

01291-1545405-N1 l- , _ _ _ ... _ _ _ _ _ - _ - _ _ _ _ _ _ _ _

e ATTACHMENT 5 Page 1 of 1 METHOD TO OBTAIN POPULATION FOR VALVE AND SUPPORT ORIENTATION The following method was used to determine the total population for valve and support orientation attributes.

1. The two previously generated lists, one for support location (HITS Report) and one for valve location (Attachment 4) were used to determine the total population for valve and support orientation attributes.
2. All the valve drawings for the valves in the list generated for valve location attributes were reviewed extended operators.

for valve .

3. A list of valves with extended operators was generated and then combined with the list of all small bore supports.

h 01291-1545405-N1

M STONE 6 WEBSTER ENGINEERING CORPORATION STONE & WEBSTER ENGINEERING CORPORATION - NEW YORK ONE PENN PLAZA 250 WEST 34TH STREET N EW YOR K. N EW YOR K accatss au.<.oaats o @ NEW voaa NE W voan ione c .... . .,

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OCT 141985

  • r'.*:. . . . ..,

. . . - s c e. ~ .c JOHN W. BECK Mr. John W. Beck October 10, 1985 Vice President Texas Utilities Generating Conpany J.0. No. 15454 400 North Olive, L.B. 81 CPO-52 Dallas, Texas 75201 PIPING AND SUPPORT REQUALIFICATION PROGRAM COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 1 Enclosure 1 Large Bore Field Walkdown Report Enclosure 2 Miscellaneous Construction Discrepancies Observed Enclosure 1 describes the results of the walkdown of large bore piping conducted by SWEC in accordance with Project Procedure CPPP-5. The conclusions of this report indicate that generic concerns exist that require consideration by the Comanche Peak Response Team (CPRT) and TUGC0 Quality Assurance (QA). These concerns are summarized as follows:

. The orientation of valves and supports in piping systems are not correctly documented in the as-built documents. Expeditious resolution of this concern is necessary to preclude negative impact on SWEC's stress requalification schedule.

. Some items requiring correction which were identified during the as-built program bave not been resolved.

We believe, with the commitment to resolve the above issues, the as-built program documentation is adequate to initiate stress requalification.

Enclosure 2 describes some construction discrepancies (e.g., loose bolts, strut / pipe lack of clearance) observed by the walkdown team. These discrepancies were not evaluated as part of the walkdown effort, and therefore should be resolved by CPRT and QA.

R&

R. P. Klause Project Manager RPK:bjf attachment cc: J. B. George (TUCCO) - 1/1 R. L. Cloud (RCLA) - 1/1 J. C. Finneran (TUGCO) - 1/1 T. Snyder (TERA) - 1/1

/