ML20212B743
| ML20212B743 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/18/1986 |
| From: | Danielson D, Fair J, James Gavula, Metrow B, Yin I ILLINOIS, STATE OF, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212B651 | List: |
| References | |
| 50-454-86-27, 50-455-86-44, IEB-79-14, NUDOCS 8612290308 | |
| Download: ML20212B743 (42) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-454/86027(DRS); 50-455/86044(DRS)
Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-60 Licensee: Commonwealth Edison Company Post Office Box 767-Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Station, Byron, Illinois Westinghouse Office, Schaumburg, Illinois Sargent and Lundy Office, Chicago, Illinois Inspection Conducted: September 15-19, 23-25, 30 through Octcber 2, 27-29 and November 6 and 12, 1986, at Byron October 15-16 and 30, 1986, at Westinghouse November 13, 1986, and at Sargent and Lundy Inspectors: J. A..Gavula , /2 - /8'8%
() Date kJ.R. Fair > L//P/Pl>
0 Date M
I. T. Yin Iv/l!ld*4 Date Accompaniment: B. D. Metrow Illinois Department of Nuclear Safety Approved By:
ob74 Y W D. H. Danielson, Chief /2////f4 Materials and Processes Section Date Inspection Summary Inspection from September 15 through November 13, 1986 and a meeting with the State of Illinois on December 17, 1986 (Reports No. 50-454/86027(DRS);
50-455/86044(ORS))
Areas Inspected: Announced special inspection to review licensee action on previously identified items (92702), allegations (99014) and IE Bulletins (92703).
Results: One apparent violation was identified (failure to accomplish safety-related activities in accordance with documented procedures - Paragraph 4).
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DETAILS
- 1. Persons Contacted Commonwealth Edison Company (Ceco)
- P. Donavin, Field Engineering Coordinator D. Elias, Project Engineer Westinghouse Electric Corporation (W) -
- M. D. Pitluk, Site Manager '
& K !f9ty vi' 'Ag Manager L J. W. Du% Mnter Dujtrer ,
t G. Oi-ibdi, field Enginne Nuclear Power Services, Inc. (NPS)
A. Stone, Project Manager R. Kurzeja, Assistant Project Engineer T. Vesley, As-Built Technician M. Pompeo, As-Built Technician W. DePujadas, As-Built Group Leader Sargent and Lundy (S&L)
- R. Netzel, Structural Project Engineer
- P. K. Agrawal, Senior Structural Project Engineer Hunter Corporation (Hunter) t J. Hadick, Quality Control (QC) Supervisor W. Folz, QC Inspector J. Arnold, QC Inspector Illinois Department of Nuclear Safety (IDNS)
- $G. Wright, Chief, Nuclear Reactor Safety
- M. Parker, Chief, Division of Engineering
$"3. Metrow, ASME Code Engineer Nuclear Regulatory Commission (NRC) ,
$C. Paperiello, Chief, Reactor Safety Division
$J. Harrison, Chief, Engineering Branch
- D. Danielson, Chief, Materials and Processes Section
- $R. Lickus, Chief, State and Government Affairs
- Denotes those attending the status meeting held at Springfield, Illinois on September 2, 1986.
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- Denotes those attending the briefing held at the Byron Station on September 17, 1986.
$ Denotes those attending the status meeting held in Region III on October 14, 1986.
- Denotes those attending the exit meetings on November 12 and 13, 1986, at the Byron Site and S&L.
During the course of this inspection, the NRC met and consulted with the State of Illinois' Department of Nuclear Safety representatives, as noted above, regarding CIE's concerns, and NRC's inspection plans, status and conclusions. In addition, a final meeting was held on December 17, 1986, between the NRC and members of the State of Illinois' Governor's office, Commerce Commission, and the Department of Nuclear Safety in Springfield, Illinois. The purpose of the meeting was to brief the State on the final results and conclusions of this special inspection. Attached is a copy of the viewgraphs used during the presentation and a list of meeting attendees.
- 2. Licensee Action on Previous Inspection Findings
- a. (Closed) Violation (454/84051-01; 455/84035-01):
Actual field measurements were obtained by the as-built walkdown crews only when dimensions were questionable or when they had not been previously documented.
The NPS Work Procedure No. 3.0.9 "As-Built Piping Subsystem Preparation" was subsequently revised to clarify the as-built walkdown requirements. Revision F of this document dated June 26, 1985, states in Paragraph 6.5.1:
"As-Built dimensions and rattle points not previously documented by Hunter Q.C. during installation, or a previous S.A.T. letter will be obtained by actual field measurement for all dimensions shown on NPS-H-1000 series drawings."
The procedure is now consistent with the implementation process for as-built walkdowns and no further corrective action is required.
- b. (Closed) Violation (454/84051-02(a); 455/84035-02(a)):
The acceptance criteria bases for piping interaction clearances were r.ot formally established prior to implementation of inspection procedures.
S&L's report, " Statistical Study for Seismic Interaction" EMD-050661,
, dated November 16, 1984, was originally generated to justify the specified minimum clearance requirement. Although inspections utilizing this clearance were performed prior to its issuance, the S&L report gave adequate justification for the specified spacing. No adverse comments were noted by the NRC inspector during the review of this report. No further corrective action is required.
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- c. (Closed) Violation (454/84051-02(b); 455/84035-02(b)):
Possible structural deformation due to rubbing within an Energy Absorbing Material (EAM) enclosure had not been considered in the pipe whip restraint design.
The three pipe whip restraints questioned by the NRC inspector were subsequently modified or deleted. Due to the elimination of arbitrary intermediate pipe breaks, these pipe whip restraints, as well as many others, were no longer required. The following drawings were reviewed:
S-1653-1-BY Revision AG (RestraintMS-R11)
S-1653-2-BY Revision AG (Restraint MS-R11)
S-1654-1-BY Revision AL (Restraint MS-R33)
S-1654-2-BY- Revision AJ (Restraint MS-R33)
S-1655 1-BY Revision AF (Restraint MS-R48)
S-1655-2-BY~ Revision AG (Restraint MS-R48)
This documentation indicated that the concerns relating to the pipe whip restraints in question were adequately addressed.
- d. (Closed) Violation (454/84051-02(c); 455/84035-02(c)):
EAM strength reduction due to excessive height to width ratio and due to stacking were not deterrained during the initial design stages.
The current designs were determined to be acceptable by the NRC Inspector in the original inspection report. In order to eliminate future concerns on this subject, the procedure controlling this work was revised. S&L's design standard SDS-E29.1 " Pipe Whip Restraints" was revised January 31, 1985. Based on the previous test results, the allowable stress levels from the EAM material are now reduced for specified height to width ratios. No further corrective actions are required.
- e. (Closed) Violation (454/84051-02(d); 455/84035-02(d)): 1 The effect of possible interferences between the retaining boxes and the EAM had not been evaluated for acceptance or tested for validation.
Two pipe whip restraints were originally identified as having this concern. Instead of trying to justify the retaining designs in question, the pipe whip restrains were modified to an acceptable configuration. The following drawings were reviewed:
Drawing No. Detail No. Remarks S-1690-1-BY, Revision S RY-5 Side Plates Reduced to "
S-1690-2-BY, Revision U RY-5 Side Plates Eliminated S-1663-1-BY, Revision AL RY-3 Side Plates Reduced to "
S-1663-2-BY, Revision AS RY-3 Side Plate Eliminated 4
/
l l' 1 Based.on'the review of the.above documentation, no further corrective action is required.
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- 3. Licensee Action o'n IE Bulletins (Closed) IE Bulletin No.' 14 (455/79014-B; 455/79014-1B; 455/79014-2B;-
and 455/79014-38)-
As part of'the allegation follow-up; described in Paragraph 4 of'this report,-
a detailed review of as-built dimensions and drawings was performed by the
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NRC ir,spector. Over 500 field dimensions were taken and compared to the as-built data presented on the isometric. drawings. On'one subsystem the as-built piping and pipe support dimensions were also compared to the analytical model~ data. Based on the above review, the review of the controlling as-built procedures and the inspection effort documented in the NRC Inspection Report No. 50-455/86030, this Bulletin is considered closed.
- 4. Follow-up on Allegations (Closed) Allegation (RIII-86-A-0118): As-built piping drawings at Commonwealth Edison's Byron Station Unit 1 have discrepancies and therefore, violate the requirements of IE Bulletin No. 79-14. These discrepancies :
may adversely affect the stress reports for the associated piping systems.
Specific examples of this concern were provided by Mr. S. R. Mitchell of Computerized Interference Elimination, Inc. (CIE) in his letter to the NRC on July.9, 1986.
t
Background
The original involvement of CIE with CECO dates back to 1976. From that time up until approximately 1983 CIE was providing their services to CECO on an trial basis for the detection of potential component interferences in the field. The intent of this service was to identify locations in the plant where, based only on the design drawing dimensions, some type of interference or spatial problem was indicated. This process could identify problems prior to the construction and installation of components which would subsequently require field modification.
!' In 1984 the nature of CIE's work was modified by Ceco from the detection of interferences prior to their occurrence to the detection of l drawing discrepancies for as-built piping systems. Although the same
- procedures were being utilized as before, piping and other components were
.,. already installed and as such could not have any actual interference
! problems. The CIE process used in this manner could only detect as-built drawing discrepancies and would tend to verify the accuracy of the as-built documentation program. This type of work was extensively pursued on
- Byron Unit 2. During this effort, CIE and CECO did not agree on the l significance of the discovered drawing discrepancies nor on the implications
- these discrepancies had on CECO's as-built program. Finally, in January 1936 it was agreed that CIE would review a portion of the Byron Unit 1 containment drawings in order to confirm or refute the validity of CECO's as-built walkdown program.
5 L.._.___._.-- . _ . - _ _ - _ _ _ _ . _ . . _ _ . ~ _ -. _ . _ _ --... _ _ _ .
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After performing their review, five problems were documented by CIE.and
- presented to CECO on June 5,-1986. Commonwealth Edison responded to these five notices on June 30, 1986, concluding that "the discrepancies themselves are of no significance to us from a seismic point of view and they do not compromise the integrity of the "as-built" walkdown program that generated the underlying data." '
Copies of the five problems as well as CECO's response were included in
-Mr. Mitchell's July 9, 1986, letter to the NRC as part of the. allegation.
During telephone interviews, CIE also indicated that in addition to the original five error notices, other discrepancies were discovered by CIE during the course of.their review. On this basis a three man team from NRC Region III visited CIE's Redmond, Washington office and interviewed Mr. Mitchell, (President) and Mr. S. Nicholson, (General Manager) on August 5, 1986. During this interview the original five problems were reviewed in detail with CIE and CIE provided details for an additional nine examples. Further questioning of Mr. Mitchell indicated that, although he suspected that many other discrepancies existed at Byron Unit 1, he did not have-sufficient documentation to prove any others.
Also during this interview, Mr. Mitchell stated that CIE had also performed similar drawing reviews for other utilities at various nuclear plants and had'found similar discrepancies. Although he suspected that many similar
, ' discrepancies existed, he did not have sufficient documentation to support
- . most of his claims. However, for the Seabrook Nuclear Power Station, Mr. Mitchell did have some documentation to identify example discrepancies.
As a result of these statements, the potentially effected NRC Regional l
' Offices were contacted and informed of Mr. Mitchells concerns and were subsequently furnished with a copy of the interview transcript. NRC's 4 Region I was specifically contacted relative to CIE's Seabrook drawing
! discrepancies fo11 0 wing this notification. Region I's technical staff has met with the CIE representatives and reviewed their specific concerns. The results of Region I's inspection, as summarized in their November 17, 1986, letter to CIE, indicated "that the program at Seabrook satisfies the NRC requirements set forth in NRC Bulletin No. 79-14." Additionally, i
this inspection effort is documented in NRC Region I Inspection Report j No. 50-443/86-51.
1 i A portion of the time in Redmond, Washir.gton, was spent discussing the operation.of CIE's interference detection program. As explained by Mr. Mitchell, an arbitrary origin is established and each component is described by assigning beginning and ending points using X, Y, and Z coordinates. The computer then connects these points and reserves space for that component. All of the components such-as piping, pipe supports, cable trays, ventilarion ducts, walls and structural steel can be described in this manner and similarly input into the program. The program then takes all the data in a given area, builds the numerical model and tells when two component systems occupy the same space.
f Using the same principle the program can also determine when a system j does not terminate where it should. This is done by cross-checking with locator points, nozzle locations, wall penetrations, etc. Utilizing this later method, CIE found most of the discrepancies with the Byron Unit 1 drawings.
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'In_ addition'to contacting NRC's Region III Office, Mr. Mitchell also contacted the Illinois Department of Nuclear Safety (IDNS), the Illinois Governor's Office, the'lllinois-Commerce Commission, the NRC Director of.
. Inspection and Enforcement,-and the NRC Chairman's Office. Due to the-broad impi! cations.of this allegation arrangements were made for an NRC-Headquarters piping specialist to participate.in the resolution of
- Mr. Mitchell's concerns. Also, after entering into a working agreement with the NRC, IDNS participated in the NRC inspection.
NRC Review The following steps were?taken to address the CIE concerns: <
- a. Review the five examples of as-built discrepancies provided by CIE, including the CECO response.
- b. Visit CIE in Redmond, Washington to interview Mr. Mitchell and his staff to gather facts and understand his company's methodology and specific concerns. Attempt to gather information on any other examples of drawing discrepancies.
- c. Evaluate the existing as-built / reconciliation programs for Byron Unit 1 to determine if it adequately addresses IE Bulletin No. 79-14.
- d. Inspect the five examples plus all other Byron 1 examples obtained during the interview.
- e. Obtain an additional sample of as-built piping dimensions on a random basis from Unit 1 and Unit 2 containment and auxiliary buildings.
- f. Evaluate the results from Items d and e by comparing walkdown-
'information with as-built information.
- g. Compare as-built information with stress ant. lysis input and reconcile any deviations cisclosed during walkdowns, if necessary.
- h. Evaluate overall results to determined acceptability of the CECO as-built and reconciliation program.
The discrepancies provided by CIE can ba divided into the following categories:
I
- a. Chain Dimension Problems The types of problems seen with chain dimensions are both direct and indirect problems. Direct problems occur when one series of chain dimensions conflicts with an overall length dimension or another series of chain dimensions. This type of discrepancy was documented four times by CIE. ,
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Indirect chain dimension problems occur when linear dimensions used in combination with penetration locations, nozzle locations, etc.,
conflict with other equipment or_ attachment dimensions. CIE documented one instance of this type of discrepancy.
- b. Angular Orientation Problems These problems occur when the relative angle between one pipe segment and another pipe segment is inconsistent with other available information. These inconsistencies indicate that pipes would not be attached to tanks or would penetrate solid walls. This type of problem occurred in three of CIE's error notices.
- c. Reference Dimension Problems These problems occur when conflicting locator information is presented on the as-built drawings. Locator information is typically given in global coordinates relative to the centerline of the containment building or other monument point. Centerline elevations also fall into this category. Typically this information is used during construction or for general location in the plant.
Since this type of information is not usually input into the stress analysis, it is generally not considered as significant to design.
However, many of these types of dimensions were as-built during the construction of the plant and design significant problems could occur if this reference information is somenow used in the stress analyses.
As later confirmed in this report, these reference dimensions were not used in the stress analyses. Eight examples of this type of discrepancy were documented by CIE.
Based on the discussions with Mr. Mitchell as well as the detailed review of the affected isometrics, it was determined that 26 dimensions were potentially affected by the discrepancies discovered by CIE. Eight of these dimensions, however, could not be verified during reactor operation due to radiological restrictions. A further review of drawings and analyses for the eight dimensions determined that all of these discrepancies were related to reference type dimensions, were not used in the stress analyses and as such were not safety significant.
The as-built inspection walkdowns were conducted between September 17, and October 2, 1986. The survey team (s) utilized during these walkdowns consisted of a Hunter QC Inspector, a Nuclear Power Services (NPS)
As-built Technician, a Data Taker, an NRC Inspector and/or an Illinois Department of Nuclear Safety (IDNS) representative. In scme instances the later two individuals functioned as data takers. All dimensions were measured by the QC Inspector and As-built Technician and independently recorded by the data taker.
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i During the Unit 1 containment walkdown, two survey teams were utilized to expedite the completion of the work. All of the accessible CIE related dimensions inside containment were resurveyed during this walkdown. In addition, a random sample of approximately 60 design significant dimensions were taken during the containment entry. (A design significant dimension is any dimension used in the stress' analyses.) Isor.atrics which were partially reviewed are listed in Table 1.
One of the 14 CIE discrepancies was located in the Unit 1 Auxiliary Building just outside the containment wall. This dimension as well as an additional 275 design significant dimensions were taken on a random basis in the Unit 1 Auxiliary Building. Isometrics which were reviewed in total or in part are listed in Table 1.
Due to the inaccessibility of certain systems in Unit 1, a large sample of Unit 2 dimensions was taken in both the auxiliary and containment buildings. The sampling process was a combination of a random selection of isometrics which were inaccessible in Unit 1 as well as a selection of subsystems in the field on a random basis. Using this technique approximately 550 additional dimensions were obtained. Isometrics which were reviewed in total or in part are listed in Table 1.
TABLE 1 Isometrics Reviewed During As-Built Verification Inspection Unit 1 Containment Unit 1 Auxiliary Unit 2 Iso. No. Revision Iso. No. Revision Iso. No. Revision SI-04 10A CV-1 19R SX-21 8H CC-46 7P CV-2 11G SX-110-129 10 CC-42 15C CV-3 228 SD-001-239 2 CC-37 12L CV-12 6H SD-001-204 2C WO-1 6E SI-11 ISK SD-001-203 28 SX-36 10D SI-13 2F SX-19 185 SI-12 11C SI-100-32 4B SX-45 4G SI-15 10H PW-4 9G RY-13 3J FW-13 8N RY-7 3E RC-19 1C SI-001-8 18J FW-47 0A RC-13 2C SI-001-23 4B FW-51 10H SX-100-132 2D SI-001-41 SF AF-11 12F SX-100-126 18 CC-40 18N SX-56 6A SX-353 2G RY-6 4D CD-15 58 RE-17 1C SI-9 10N FC-25 IL SI-14 16Q AF-100-28 1B RH-5 13J AF-14 8K FW-5 8A RE-13 3B CC-14 10H AF-29 7E CC-6 12F RC-12 25 RC-14 3F SI-32 2J CV-44 2P RC-001-219 3C 9
l A total of 912 design significant dimensions were taken during the as-built verification inspection. These dimensions were then compared to the as-built information given on the isometric drawings and correlated to the tolerances given in S&L's Project Instruction " Procedure for Preparation and Submittal of Piping "As-built" Information" PI-BB-26, Revision 4, dated August 20, 1984. These tolerances specify acceptable measurement deviations from the as-built condition. On this basis, the accuracy of the as-built documentation program, was within the specified
, measurement tolerance 94.5% of the time. This measurement accuracy is relatively restrictive at il inch for measurements up to 9.9 feet. By comparison, the lower end of the reconciliation tolerances are typically i one pipe diameter. These tolerances specify the acceptable analytical deviation from the as-built design. In no case was the measurement deviation outside the reconciliation tolerance for any critical-to-design linear dimensions. Therefore, none of the limited dimensional discrepancies were significant enough to affect the design basis of the piping systems.
There were, however, five instances where the difference between the indicated angular orientation and the reverified angular orientation exceeded the allowable angular reconciliation tolerance for the pipe segments. It was noted that in all of these cases, the angular orientation was not indicated as being as-built on the drawings. Although bent pipe and cut-to-suit elbow angles were consistently indicated as as-built on the drawings, very few of the relative. pipe leg orientations were indicated as as-built. This is contrary to the procedural requirements given in Sargent and Lundy's Project Instruction No. PI-BB-26 which controls this work. Failure to follow the procedure is a violation of 10 CFR 50, Appendix B, Criterion V (454/86027-01; 455/86044-01).
In order to address the concerns relative to the angular orientation of the pipe segments, Ceco presented documentation for the construction of piping spool pieces. The intent of this presentation was to provide adequate assurance that in the majority of cases the angular orientation of the pipe segments was determined and verified in the shop during the initial spool piece fabrication process. Using this Quality Control type of documentation, the angular orientation would therefore be confirmed.
As indicated on the as-built isometric drawings, each spool piece is uniquely identified tf its spool piece number and is shown where it is field welded to the next spool piece. This field weld symbol, shown as "F.W." next to a joint in the pipe, typically occurs at standard fittings but may also occur in straight lengths of pipe. The overall intent of the shop fabricated spool pieces was to minimize the number of required field welds while still allowing for convenient installation.
Using this approach the angular orientation of the pipe will be confirmed in all cases except where (1) spool pieces were modified in the field and (2) spool pieces are field welded on a riser. Since the horizontal orientation of piping is assured for field welds on any horizontal piping, this portion of the angular orientation question need not be considered.
It is only in those instances where a riser field weld is used that the 10
m _
angular orientation of the horizontal pipe above and below could potentially be misoriented in the field.
The following isometrics were reviewed to determine the potential angular orientation problem as a result of field welds on risers:
1-CY-38, Revision 76 1-CV-41, Revision 6D 1-CV-40, Revision -
1-CV-24, Revision -
1-CV-23, Revision 13F 2-CV-51, Revision 35 1-CC-12, Revision 14K 1-CS-5, Revision 12K 2-SI-25, Revision 3L 1-SI-05, Revision 9A
. 1-5I-04, Revision 10A 1-SI-02, Revision 9M 1-SI-01, Revision 11A 1-SX-36, Revision 10D 1-WO-1, Revision, 6E For cases where riser field welds occurred, several geometric restrictions were used to limit the potential variability in angular orientation. The primary restriction involved the containment or missile barrier wall penetrations as well as equipment and nozzle attachment points. Using these fixed orientation conditions, the majority of the arbitrary angular orientations were eliminated.
However, for riser field welds which do not occur on an attachment or penetration spool, the angular orientation of the pipe segment can potentially be determined by using information from the pipe support drawit.gs. Specifically, for any snubber attached to a riser, the drawing indicated the angular orientation of the horizontal leg of pipe relative to the direction of action for the snubber. This method was used in several instances during the review to verify angular orientation.
If the above two methods could not be used, then in some cases an overall geometric restriction was applied to limit the arbitrary angular orientation of the pipe. In a given situation where three riser field
, welds exist without any intermediate orientation restriction, a linkage l effect potentially exists. Although the angles and lengths are l interrelated, there is a potential for an arbitrary angular orientation.
However, if the linear distance between riser field welds is relatively large the displacement of one end of the pipe segment relative to the designed location will become fairly obvious. For a twenty foot horizontal distance between riser field welds, the 5 angular accuracy would allow a 21 inch lateral displacement. This size of a deviation would very likely cause other problems during construction.
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In response to these piping orientation concerns, CECO decided to remeasure the angles associated with riser field welds inside_the Unit 1 and 2 containment and auxiliary buildings. This effort took place between November 1, 1986, and November 14, 1986. A total of 105 field weld riser angles were reverified, 62 in the Unit 1 containment and auxiliary buildings and 41 in the Unit 2 containment building. The walkdown packages for all the Unit 1 riser angles were reviewed by the NRC inspector. The results indicated that angular orientation was within the specified tolerance of 15* 94.3% of the time. Of the limited number that exceeded this tolerance, none were outside the established reconciliation tolerance of 10 . Based on this documentation, the piping angular orientations have been adequately verified.
In order to assure that this type of problem does not recur, CECO issued
-the NPS Work Procedure No. 3.0.9, Revision G, dated November 19, 1986.
Exhibits 3.54 and 3.40 of this procedure were revised to specifically identify pipe orientations and angular offsets as a separate category of as-built dimensions as well as an individual line item on the as-built package checklist. Based on the above action and the fact that the significant drawing discrepancies will be corrected by CECO, no additional corrective action is required at this time.
The other aspect of the angular orientation that required confirmation was that any modification to a spool piece in the field was documented and shown on the isometric drawings. Any field changes made would have been done by Hunter Corporation and as such would require the same level of Quality Control as the originai S ' vest Fabricating and Welding spool pieces.
A review was conducted of Site Implementation Procedure (SIP) No. 2.201
" Design Control", Revision 13, dated June 11, 1984. Section 4.3.1 of this procedure states that " Class 1, 2 and 3 ASME piping shall not be field routed but can be relocated by the Production Supervisor up to one inch without a Job Traveler Package (JTP) revision. If changes beyond this tolerance are necessary then the JTP will be revised to reflect the necessary change if it is within the tolerance specified on Drawing M-535 Note 52. Any change greater than that tolerance will require a design change from the Architect / Engineer (A/E) and will result in a design drawing revision, and the initiation of an ECN, FCN, or FCR."
Drawing M-535. Revision AK, was reviewed by the NRC Inspector. Note 52 gave the following tolerances:
w/o Engr w/ Contractor A/E Size / Type Approval Engr. Concurrence Approval Reg'd Large Bore Class A, B, C, G 11 13" on O' - 10' 13' on O' - 10' 16" on > 10' 16" on > 10' Small Bore N/A N/A 13" on O' - 10' 16" on > 10' 12
Based on the review of.the above procedures and the multiple examples of Hunter Corporation spool piece rework drawings, it was determined that adequate control of field modified spool pieces had taken place.
In order to determine if any piping analyses were adversely affected by the angular discrepancies or the discrepant reference information, the piping as-built reconciliation process was reviewed. Although none of the analyses in question were performed by S&L, their Project Instructica No. PI-BB-27 " Receipt, Review, Re-analysis, Redesign and "As-Built" Piping Reconciliation", Revision 4, dated March 18, 1985, was examined. The reconciliation tolerances associated with piping configurations were stated as follows:
-Dimensions for fittings From 0 to 10 feet 16 inches including branches, flanges From 11 to 15 feet 19 inches valves. . . and other inline From 16 to 20 feet 112 inches components From 21 to 25 feet il5 inches
-Angular orientation 110 degrees of pipe legs
-Support Locations il pipe diameter on straight pipe or 12 inches whichever is greater By comparison, the Westinghouse Reconciliation tolerances, documented in their Procedures and Guidelines Manual BY/PG-2, Revision 0, Dated September 1984 were found to be as follows:
-Piping Segment From 0 to 5 feet, 16 inches Lengths Greater than 5 feet 110 %
-Branch Line Locations Pipe diameter less than 3" 13 inches or Support Locations Diameters Greater than 3" But less than 18" 1 Pipe Diameter Diameters Greater than 18" 118 inches
-Pipe Segment Orientation 15 Degrees As a result of the discrepancies found during this inspection, Westinghouse presented information indicating that an angular orientation reconciliation tolerance of 110 degrees was acceptable. Justification for this tolerance was based on an internal Position Paper showing minimal frequency effects due to angular deviations. Additional justification was provided through a comparison to other Westinghouse Project reconciliation tolerances. Using this as a basis, any angular deviation less than 10 degrees was reconciled on an engineering judgement basis.
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The following isometrics and. associated piping analysis were reviewed by ,
the NRC inspector and/or the Headquarter's piping specialist.- These 4
included examples provided by CIE and other isometrics selected at random.
'* Isometric SI-04 Subsystem ISI-03 Microfiche APGIOMK 1/18/83 APGIO3Q 1/19/83 Use Count #67 Angular orientation of the horizontal. leg below the accumulation tank is shown as 33' South of East ~on the as-built drawing. Field measurement shows this angle as 33* North of East for an angular discrepancy of 66*. This discrepancy was found by CIE.. The review of the piping analysis for this subsystem revealed that,'although the angle _was shown in error on the drawing, the analytical model was correct. Additionally, the snubber on ,
the segment of pipe' (No.1S103041) was shown to be perpendicular to the pipe with the proper orientation.
,As an explanation for the difference between the as-built drawing and the analytical model, the licensee stated that the mode 1~was based on design-input from sources of as-built information other than the isometric i drawing. In this case information from the pipe support drawing indicated that the~as-built isometric was in error. After confirmation was obtained from the field, the analytical model was changed to match the pipe support information. No documentation was available to substantiate this
- explanation other than the pipe support drawing. Although this is one example where a field modification to a spool' piece was not picked up on the isometric drawing, no other instances were discovered during this irespection.
Isometric CC-46 Subsystem 10C-27 Microfiche CCUP0QM CCZ70BL >
9/8/86 9/8/86
- Use Count #45 Angular orientation of the pipe segment at wall penetration 1RB303 was originally shown and modeled at 45* from the actual piping configuration.
This discrepancy was identified by CIE.
Since being informed about this discrepancy, Westinghouse performed a reconciliation calculation as documented in their letter CAW-9781. In addition, the model was modified to the proper configuration and re-anlayzed. The results showed that all pipe stresses stayed the same or decreased. All support loads decreased except for support No. 015 which had a 5% load increase. The current load of 400 lbs. on this strut is well below the 1200 lbs allowable load. This information was dccumented in Support Calculation Five No. 100/2050 Revision 2, June 9, 1984.
Isometric CC-37 Subsystem ICC-21 and 22 The overall linear as-built dimension 11' - 3k" differs from the 14
inspected dimension of 12" - 2" by 10 3/4". The overall linear as-built dimension 38' - 7 7/8" differs from the inspected dimension of 24' - 4 1/8" by 14' - 3 3/4". The as-built bend angle of 3 differs from the parallel as-built angle on Isometric CC-40 by 30 . These discrepancies were discovered by CIE.
The review of the analysis of the subsystem indicated that the first segment of pipe was modeled as 12.6' and the 11' - 3 " dimension was not used. As additional verification the 10 3/4" deviation is within the reconciliation tolerance for this segment length and therefore would have been acceptable if used. The 38' - 7 7/8" dimension was not used in the analysis and the overall segment length actually used was within 5 5/8" of the 33'-4" measured length. This is well within the reconciliation tolerance for this segment length.
The 3 as-built angle was actually input as 33 in the analytical model.
No reconciliation was required since the analysis matched the field configuration.
Isometric SI-01 Subsystem ISI-01 Reference APGI0AT December 12, 1983 CHAN0TA January 19, 1983 Vertical segment of pipe into accumulator tank was analyzed as 9.58 feet long. The spool piece rework drawing SI-1-10 shows this length as 7'- 4". This discrepancy was discovered by the NRC inspector during the documentation review for the angular orientation concern. Subsequent field walkdowns indicated that the actual length was 7'- 7 5/8". The l'- 11 3/8" difference was reconciled by Westinghouse subsequent to its disclosure. The re-analysis of the piping system indicated that all seismic stresses stayed the same. All support loads stayed the same or decreased except for four supports. In these cases the increase was less than 2% or 10 pounds. The accumulator tank nozzle loads increased by less than IL These are well within engineering tolerances.
Isometric CC-42 Subsystem 10C-39 Use Count No. 14 The angular orientation of the 11'- 7 1/4" pipe segment at elevation 421'- 6" is not indicated on the isometric drawing. The reverification walkdown indicated that this segment was perpendicular to the 7'- 2 7/8" pipe segment at elevation 417'- 9". This discrepancy was discovered by CIE. The review of the piping analysis indicated that both segments as well as all adjacent pipe segments were modeled correctly for angular orientation and segment length.
Isometric WO-1 Subsystem 1WO-02 Use Count No. 60 The 17'- 0" as-built segment straddling column line F was originally questioned by CIE. This length was measured during the reverification walkdowns as 17'- 11". This exceeded the as-built measurement accuracy tolerance by 9". The review of the stress analysis indicated that this 15
segment was originally modeled as 17'- 11 1/8" long, within 1/8" of being exact. However, since the "as-built"' measurement was well within tha 10%
reconciliation tolerance for this length, no reconciliation was required.
Isometric SX-36 Subsystem ISX-07A and 07B Use Count No. 85 and 68 The pipe segment with support 1SX07009 was originally questioned by CIE.
This 20'- 7 3/8" as-built dimension was measured during the reverification walkdowns as 19'- 8".
This exceeded the as-built measurement accuracy tolerance by 9 3/8". The review of the stress analysis indicated that this segment was originally modeled as 19'- 7 3/8", within 5/8" of being exact. However, since the as-built information was well within the 22" reconciliation tolerance for this segment, no reconciliation was required. Again the analysis was correct but the as-built drawing was incorrect.
Isometrics SI-12 and SI-15 Subsystem ISI-21 The chain dimensions for the pipe segment with Check Valve No. 1SI8815, disagree with the overall length given for the same segment by 8 7/8".
This discrepancy was discovered by CIE. The reverified measurement for this 13' - 1 1/8" segment came within 1 1/8" of the as-built chain dimensions, well within the measurement accuracy required for as-built dimensions. The overall "ac-built" length indicated was in error. The discrepancy was potentially caused by dimensioning to the wrong point on the penetration assembly. The review of the analysis indicated that this segment was modeled within 3 1/2" of the reverified length. On that basis no reconciliation was required. If the incorrect overall dimension would have been used it also would have been within the reconciliation tolerance for this segment.
Isometric WO-40 Subsystem 1WO-2 Use Count No. 60 The as-built dimension 3'- 2 3/4" shown from floor elevation 401' - 0" to branch line IW006AD-3" will cause the branch line above it to interfere with the floor above. This discrepancy was discovered by CIE, but was inaccessible during power operation. The analysis was reviewed to determine if the reference dimension was used in the piping model. The overall segment length and branch line spacing indicated that it was properly modeled.
Isometric RC-7 Subsystem 1RC-13 l
Use Count No. 145 l
The "as-built" reference dimension giving 29'- 5" from an elbow to the centerline of the containment building contradicts the verified location of line IRC02AD-31". This discrepancy was discovered by CIE. A review of the analysis indicated that the as-built chain dimensions were 16
utilized in the model and neither'as-built reference dimension was used.
Isometric.SI-001-23 Subsystem ISI-17 Angular orientation of horizontal legs shown as 97* between pipe segments. The inspection measurement was made at 104*. The review of the analysis indicated that the model: utilized the as-built drawing dimension and did not account for the 7* deviation. This exceeded the reconciliation tolerance by 2 . A review of the analysis results showed
. that piping stresses were a maximum of 40% of allowables. Three supports ~
in the immediate vicinity (No.-021, No. 034, and No. 018) all had stress margins less than-50% of allowables. Based on the Westinghouse internal.
Position Paper tolerance, this discrepancy is acceptable.
Isometric CC-40 Subsystem 10C-19 Angular orientation of horizontal legs is shown as 117 between pipe
~
segments. The inspection measurement of this angle was made at 124*.
The review of the analysis indicated that the model utilized the as-built drawing dimension and did not account for the 7 deviation.
This exceeded the reconciliation tolerance by 2". A review of the analysis results showed that piping stresses were less than 30% of the allowables. Three supports in the immediate vicinity of the discrepancy "ere reviewed for stress margins as discussed below.
The following calculations were reviewed:
File No. 100-205E Support CC1900G, Revision 3, May 8, 1984 Limiting condition was weld to tube steel at 77% of allowable.
File No. 100-205E Support CC19017, Revision 2, May 8, 1984 Snubber Load was 33% of allowable Bending stress was 60% of allowable File No. 100-205E Support-CC190018, Revision 2, May 8, 1984 Snubber Load was 93% of allowable Shear Stress was 93% of allowable Due to the conservatisms in the existing seismic analysis without consideration for the increased damping and based on the Westinghouse internal Position Paper tolerance, this discrepancy is acceptable.
Isometrics CV-12, CV3 Subsystem 1CV-08
' No significant discrepancies were observed between the drawing as-built dimensions and the inspection dimensions. The overall reconciliation l process was reviewed for accuracy. As a result of several support location l changes, four spans of piping were reconciled against the original design analysis using the as-built dimensions. The reconciliation methodology utilized in this process was appropriate and well documented. No adverse 7
comments were made relative to the calculation.
l i
i 17 i
-4 . _, _ - _ _ _ _ _ . _ , _ , _ _ _ _ _ _ _ _ _ _ _ _ . _ _ , . . _ _ . _ _ _ __.
Isometric CD-001-203, 204, 239 Subsystem 25D-02 No significant discrepancies were observed between the drawing as-built dimensions and the inspection dimensions. No reconciliation-calculations were required. No adverse comments were made relative to the analysis.
As part of this portion of the inspection effort, confirmation was obtained that the discrepant as-built reference information was not utilized in the analyses. A review of the input process for Westinghouse's WESTDYN computer program was conducted. As described by the piping analysts, -the basic input format for their program is the definition of pipe segments using overall pipe lengths and angular orientations. Typically pipe segments are defined from elbow to elbow or elbow to attachment point. Starting at an anchor point, the entire piping configuration is input in this manner.
Valves are input as lumped masses along the pipe segments with short segments tied into the center of gravity of the valve. Pipe supports are located along each segment by defining the attachment point relative to one end of the segment or the other.
Although the program does have the capability of inputting global offset coordinates, according to the analysts, this is rarely if ever used. The
-program also is capable of providing the global location of each point in space if an accurate starting point coordinate is provided. While this is convenient es an indication of the model accuracy, this global closure check is typicM1y not utilized by the analyst for checking. Computer plots are avaliable which give an accurate pictorial view of the piping configuration. No evidence was found where locator points or elevations were utilized as input to determine design dimensions.
The global coordinate capability inherent in WESTDYN is similar to the process used by CIE in their interference detection program. Further discussions with Westinghouse indicated that they also have the same interference detection capability as CIE. An additional advantage offered by Westinghouse over CIE was that the piping input data already existed in the pipe analysis files and as such world not need to be re-input.
Commonwealth Edison, however, determined that the existing construction and as-built procedures were more economical than either interference detection system.
Based on the above review, the discrepant reference information found on the as-built isometrics was not utilized in the design analyses and is not considered relevant to any of the safety concerns.
Conclusions The allegation that as-built drawings at Byron Unit 1 have discrepcncies was substantiated during this inspection. A variety of examples discovered by CIE, as well as findings by the NRC Inspector, indicate that some information presented on the as-built drawings is incorrect. Several instances were discovered where apparently significant differences exist between the "as-built" information and the actual piping configuration.
Also, exampies were found where as-built dimensions directly contradicted other as-built information. Furthermore, a programmatic concern relative 18
to the as-built angular orientation of pipe segments was identified.
~Although specified in the controlling Project Instruction, the angular measurement for relative pipe leg orientations was not indicated on the
,-built drawings as required.
However, in order to evaluate the effectiveness of Ceco's As-Built Program, the overall significance of the various discrepancies needs to be considered. For any discrepancy discovered to date, in no instance did these "as-built" problems cause a component to exceed the code allowable stress limit or require any modification to meet this limit. In only two cases did an "as-built" discrepancy exceed the reconciliation tolerance and require any additional re-analysis to justify code stress compliance. In both cases the resulting stresses were well below allowable stress limits.
Although approximately 5% of the dimensions appear to exceed the specified measurement tolerance, 99.8% of the time these deviations were within the reconciliation tolerance and therefore had no design significance.
The one area identified during the inspection as a potential programmatic deficiency dealt with the angular orientation of pipe segments. No indication was given on the as-built drawings that certain pipe segment orientations were confirmed during construction. This was cited as a violation of their procedures. Without this confirmation, the validity of the stress analysis could be questioned. A substantial effort was subsequently performed by CECO in order to evaluate the extent and significance of this deficiency.
The results of this effort indicated that the vast majority of the angles were confirmed using Quality Control procedures but were never " Boxed-In" on the as-built drawings. For the angles where no documentation was provided sufficient geometric restrictions were cited that limited the magnitude of any variation. This position was additionally substantiated by CECO using a statistical sample of all the effected angles. Although five instances were found where the angle exceeded the measurement accuracy tolerance, none of these angles exceeded the updated reconciliation tolerances.
Based on the above evaluations and reviews, Commonwealth Edison's As-built / Reconciliation Programs for Byron Unit 1 satisfy the objective of IE Bulletin No. 79-14. These programs show evidence of being effectively implemented by Commonwealth Edison. The nature of the discrepancies identified by CIE and by the NRC inspector which exceeded the approved reconciliation tolerances appear to be isolated instances of human errors as opposed to a general breakdown of the overall as-built system.
The basis for the allegation submitted by CIE appears to be derived from their interpretation of IE Bulletin No. 79-14 requirements. The intent of IE Bulletin No. 79-14 is to provide adequate assurance that input information used in seismic analysis of piping systems is sufficiently accurate to demonstrate the systems meet the appropriate design criteria.
This objective is contained in General Design Criterion 1 of Appendix A to 10 CFR Part 50. Examples of the types of deficiencies which led to the 19
issuance of the bulletin were cited in Appendix A of the bulletin. These deficiencies resulted in plant modifications being required to demonstrate compliance with design criteria. The August 15, 1979, Supplement to IE Bulletin No. 79-14 provides guidance on the intended accuracy of the program.
Item 2 of this supplement states that, "The licensee is expected to use measuring techniques of sufficient accuracy to demonstrate that acceptance criteria are met." These acceptance criteria are based on the piping system design criteria. Therefore, the overall objective of IE Bulletin No. 79-14 is to provide adequate assurance that the "as-built" piping system meets the design criteria.
Of the original five problems identified by CIE and the other nine potential problems they also identified, only one dimension was used in an analysis that caused the system to be outside of the design criteria tolerance for dimensions. After re-analysis, the piping configuration continued to meet all code stress requirements without any modifications or changes. The rest of the discrepancies identified by CIE were either never used in any analysis or were well within the design criteria tolerance.
Of the other 1000 dimensions reverified during this inspection (900 by the NRC and 100 by Ceco), only one more was outside the design criteria tolerance for dimensions. Again, the re-analysis of the system demonstrated that the piping continued to meet all code stress requirements without any modifications or changes.
While as-built drawings are required and they should be accurate, it is the degree of accuracy that is in question here. CIE has stated that they could find the same type of errors in any nuclear plant in the country. On the oasis of this inspection this cannot be disputed. However, if the only errors are non-significant errors, then to require an overall upgrade of all as-built drawings to the standards suggested by CIE would not be warranted. The magnitude of the inaccuracies discovered by CIE or the NRC are all, except for two, within the tolerance levels specified by the engineers. These two instances, although relatively large, resulted in minor stress variations. If errors were prevalent throughout the system it would not be considered acceptable. However, due to the extensive nature of this inspection and the limited number of these types of errors, the overall as-built program defined by Commonwealth Edison appears to have been effectively implemented at Byron Units 1 and 2.
The results of previous independent efforts by the NRC and a Ceco contractor further support the conclusions of this report. Since May of 1983, five separate and independent efforts have addressed the adequacy of Byron Station's as-built program. These inspection include the following:
a Integrated Design Inspection No. 50-454/83-32, performed by NRC Headquarters in May and June of 1983.
- b. Independent Design Review of the Byron Station performed by Bechtel during 1984 (examined by the NRC).
- c. Routine Safety Inspection No. 50-454/84051; 50-455/84035 performed by Regional NRC Inspectors from August 1984 through February 1985.
20
- d. Construction Appraisal Team Inspection No. 50-455/85027 performed by NRC Headquarters and Regional Inspectors during August and September 1985.
- e. Routine Safety Inspection No. 50-454/86036; 50-455/86030 performed by Regional NRC Inspectors during September and October 1986.
Portions of these inspections included as-built walkdowns and evaluation of Ceco's response to actions set forth in IE Bulletin No. 79-14. The overall results of the above efforts indicdted that Byron's as-built program met the objective of IE Bulletin 79-14.
- 5. Exit Interview Exit interviews with licensee representatives (denoted in Paragraph 1) were conducted on Novenicer 12 and 13,1986 at the conclusion of the inspection. The inspector summarized the purpose and findings of the inspection. The licensee representatives acknowledged this information.
The inspector also discussed the likely information content of the inspection report with regards to documents or processes reviewed during the inspection. The licensee representatives did not identify any such documents / processes as proprietary.
21
ATTACHMENT NRC/ STATE OF ILLIN0IS MEETING ATTENDEES DECEMBER 17, 1986 NAME ORGANIZATION TITLE A. B. Davis NRC - Region III Deputy Regional Administrator C. J. Paperiello NRC - Region III Director, Division of Reactor Safety J. J. Harrison' NRC - Region III Chief, Engineering Branch D. H. Danielson NRC - Region III Chief, Materials and Processes Section {
J. A. Gavula NRC - Region III Reactor Inspector, Materials and Processes Section Gretchen Bonfert Governor's Office Assistant for Natural Resources Terry Lash IDNS Director Gary Wright IDNS Manager, Nuclear Facility Safety S. J. England IDNS Chief, Legal Counsel Roy Wight IDNS Chief, Division of Operations B. D. Metrow IDNS ASME Code Engineer Bob Lane IL Commerce Commission ProjectManager, Utilities Divsion 22
l
- - I BRIEFING FOR TE STATE OF ILLINDIS E_ tCARING ALLEGATI.0NS OF AS-BUILT DRAWING PROBLEMS AT TE_B.Y_f0N STATION AGENDA INTRODUCTION A, B. DAVIS GENERAL REFARKS C. J. PAPERIELLO INSRCTION SCOR, FINDINGS AND CONCLUSIONS J. J,liARRISON DISCUSSION ALL CLOSING REMARKS A,B, DAVIS b
GEERAL INF0WATION PLANT NAK: BYRON STATION LOCATION: OGLE COUNTY, ILLIN0IS, 17 MILES SOUTHWEST OF ROCKFORD,ILLINDIS LICENSEE: C0mDf6EALTH EDIS0N COEANY TY REACTOR: TWO 1130 EGAWAIT (ELECTRICAL) WESTINGHOUSE PRESSURIZED WATER REACTORS, J
ARCHITECT-ENGINEER: SARGENT AND LUNDY LICENSE ISSUED: UNIT 1 - FEBRUARY 14,1985, FULL POWER UNIT 2 - NOVEMBER 6, 1986, LOW POWER rv v ,-------------.-----.,_-a-,_ .
BAGGOVW ALLEGATION:
- STRESS REPORTS MAY BE AFFECTED SOURCE:
- C0lfuTERIZED INTERFERENCE ELIMINATION, INC, (CIE)
FR. SCHUYLER NITCHELL
KEY DATES:
- JULY 1986 NRC NOTIFIED BY CIE (NLPEROUS CONTACTS)
- NRC DEVELOPED ALLEGATION REVIEW PLAN
- STATE OF ILLIN0IS CONTACTED BY CIE
- AUGUST 4,1986 - NRC INTERVIEWED CIE (TRANSCRIBED)
SEPTENER 2, 1986 - IDNS MEETING WITH CIE IDNS MEETING WITH NRC SEPTEMBER 12, 1986 - PROTOCOL AGREEE NT: NRC/IDNS SEPTEMBER 14, 1986 - INSRCTION STARTED SEPTEMBER 19, 1986 - NOTIFIED OTHER NRC REGIONS (TRANSCRIPT)
OCTOBER 14, 1986 - K ETING WITH IDNS TO DISCUSS STATUS NOVEMBER 13, 1986 - INSPECTION C0FPLETED JANUARY, 1987 - NRC PLANS TO K ET WITH CIE
i CIE'S SYSTEM
- COW UTERIZED SYSTEM
- EACH PLANT COWONENT IS NLPERICALLY INPUTTED INTO THE SYSTEM t- USING X, Y, AND Z COORDINATES FOR A GIVEN PLANT SPACE b
v t
4
DEFINITIONS:
- DESIGN - IS THE PROCESS BY WHICH PIPING SYSTEM COWONENTS AE SELECTED, LOCATED, 0RIENTED, CONFIGURED, AND ANALYZED TO SATISFY CONDITIONS SET FORTH IN TE PIPING DESIGN SPECIFICATIONS.
- STRESS / DESIGN REPORT - CONSISTS OF THE DESIGN CALCULATIONS AND STESS ANALYSIS PERF0WED TO SHOW TE ADEQUACY OF DESIGN,
- DESIGN SIGNIFICANT DIENSIONS - DIENSIONS USED TO ANALYZE TE PIPING CONFIGURATIONS
- AS-BUILT - ACTUAL. INSTALLED CONDITION OF PIPING SYSTEMS ,
I
- ECONCILIATION - RESOLUTION OF SIGNIFICANT DIFFERENCES BETWEEN AS-BUILT AND DESIGN
- WALKDOWNS (INSPECTIONS) - PERFORMED TO VERIFY AS-BUILT EETS THE DESIGN AND TO IDEhTIFY DIFFERENCES OR DISCREPANCIES BEMEN DESIGN AND INSTALLATION FOR TEIR IWACT ON PIPING SYSTEM STESS ANALYSIS. KASUPE OF ASSURANCE THAT THE DESIGN WAS ET.
O w-. . . . _ . . - . , -- - - - - . .
DIFFEENCES:
- MINOR DIFFEENCES "USE-AS-IS"
- SIGNIFICANT DIFFERENCES
- ENGINEERING JUDGEE NTS E-ANALYZE
~
- MDDIFICATION/ REWORK IE BULLETIN 79-1Li
- VERIFICATION 'DOES THE AS-BUILT CONDITION E ET THE DESIGN?
TOLERANCES INSTALLATION - ACCEPTABLE DEPARTURE FROM NOMINAL DIENSIONS WITHIN
, PRACTICAL LIMITATIONS ECONCILIATION - MAXIMLN ALLOWABLE DEPARTURE BEINEEN AS-BUILT AND
, AS ANALYZED DIENSIONS
I EI_E IDENTIFIED DISCREPANCIES:
- ON 60 DRAWINGS LOCATED IN 1 QUADRANT OF UNIT 1 CONTAlffENT
- CHAIN DIENSIONS - 4
- ANGULAR ORIENTATIONS - 3
- REFERENCE DIE NSIONS - 8
- TOTAL OF 15 PROBLEMS RELATED TO 26 DIMENSIONS s
4
f.
IRC AL_LE.GATION EVIEW PLAN:
- RRFORi WALKDOWNS - OBSERVE ACTUAL EASUREFENTS
- EVIEW ECONCILIATION PROCESS; AS-BUILT TO DESIGN 6
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l---------------------------------------------NRC REVIEW--------------------------------------------------------------
I (1)I l (la) l UNIT 1 1 (2a) l----I WALxD0wNS l---l l l CIE SPECIFIC i 1 NRC CECO l l EXAMPLES I l l l l l l 1 1 I i l i j i (1)l I l l PRELIMINARY l W OR Sarl TO I
- I l UNIT 1 l l l EVALUATION OF l
- EVALUATE AS l
- 1----I RANDOM l---l----l AS-BUILT DRAWINGS l--- L-l REQUIRED FOR l j l l SAMPLE l l l TO IDENTIFY SIGNI- 1 I OPERA 8ILITY OF l
) l I l l l FICANT DEVIATIONS l l UNIT 1 l i l 1 I I I i 1 i I I i i l i i 1211 1 1 l l l UNIT 1 l l 3 l----I Aux. BLDC. I---l I I l COMMON SYSTEMS I l l CIE l l RANDON SAMPLE l l
, I (MR. MITCHELLI --I i l l
, 1 ALLEGATIONS l I I (5) 1 I I i 1
1 (311 1 I I I 4
I I UNIT 2 l l COMPILE l COMPARE l 1 l----l AUX. BLDG. ---l----l RESULTS OF l-------I AS-8UILT ------------
l l RANDOM SAMPLE l l ALL MRC l 1 FINDINGS TO l l l l WALMDOWNS l l ANALYSIS 1 1 I I I I I I I I I (4)I I I J l l UNIT 2 l l l l----l CONTAlleMENT l---l i
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! SCOPE:
I -400-600 DIMENS109tS
-PIPING LENGTH, ANGLES, SUPPORT LOCATIONS
(#1 NUM8ERS IN PARENTHESIS REPRESENT SEQUENCE OF EVENTS.
(la) AND (2a) ARE PRELIMINARY DIMENSIONAL COMPAdlSONS WITH AS-BUILT DRAWilIGS TO ASSESS a
IF OPERABILITY EVALUATIONS ARE REQUIRED FOR THE CONTINUED OPERATION OF UNIT 1.
CIE ALLEGATICII REVIEW FLOW CHART
1----------------------- - -----------------------l------------------
i 4
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I MINOR PF08LEMS l (6) OK NO FURTHER .
l l---- ACTloss -----------------------------------------------------------------I pC l l l q
l 1 1 I I I I 1 EVALUATE THE I l l 4 ---l ACCEPTABILITY l----------l l t I I Or AS-nulLT l l (7) I i I l PROGRan i I I j l l 1 l l
. l l 1 I l l j i l i s 1 . I I I i l l 1 ruRTHER REVIEW l I i l l NOTI REQUIRED TO ENSURE l l 4 I l----l CRITICAL DIMENSIOIIS l---l l 1 OK I WERE TRA80SFERRED l l l l 1 TO DRAh NG l l l
--l 1 l 1 (10) (11) I i 1 I l t
i 1 1 1 1 1 1 1 SU8MIT PLAN 1 l CECO CORRECTIVE l l 1 8 l---- TO NRC FOR l-----l ACT10se IMPLE- l-----l l l l l COSICURRENCE l l MENTED l l l i i I l l l 1 l l 1 I i l (8) NOT l DEVELOP A STATISTICAL l l l l SAMPLING PLAN (95/95)l---l l l I l----I
! l NRC 10x i 1 1 i 1 l l 4 1 l l l 1 l l DETERMINE THE I l l----I i l l ACCEPTA81LITY OF THE l l l
, l--1 CECO PROGRAM FOR I---l (9) I i
l REC 000CILIIGG THE l l l l ANALYSES TO THE AS- 1 l l l BUILT CoeIDIT1000S I l l l l 1 I l l----l NO FunTHER ACT1088 l-------------------------------------------------------------I J
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INSPECTION SLM SRY:
SAPPLED RANDOM DIPENSIONS UNIT 1 CONTAllfENT 80
- UNIT 1 AUXILIARY BUILDING 279
- UNIT 2 CONTAIPPENT AND AUXILIARY BUILDING 5H TOTAL 912 DIPENSIONS SELECTED WERE CRITICAL-TO-DESIGN (SIGNIFICANT)
- 8 REFERENCE DIPENSIONS WERE INACCESSABLE; WERE EVALUATED, NOT USED IN THE ANALYSES
ESULTS:
- LIEAR DIENSIONS
- 1 DIENSION EXCEEDED ECONCILIATION TOLERANCES (NRC)
ERROR WAS CONSERVATIVE
- ANGULAR DIENSIONS SOE WEE NOT AMiOTATED ON TE DRAWINGS 1 WAS OUTSIDE RECONCILIATION TOLERANCES
- WAS ESOLVEli111 ROUGH E-ANALYSIS AND
- ET ASE CODE STESS ALLOWABLES
- NRC PLANS TO ISSUE A PROCEDURAL VIOLATION ON THIS ANGULAR PROBLEM
- CEC 0's ESPONSE TO NRC's FINDING PERFORED DESIGN DOClfENT REVIEhs AS-BUILT REVIEWS REVERIFICATIONS - 105 DIENSIONS ALL ANGLES HEE Will11N ECONCILIATION TOLERANCES
- NRC REVIEWED CEC 0's ACTION - ACCEPTABLE
CIE SlM%RY:
- CIE HAD IDENTIFIED 5 ORIGINAL AND 10 ADDITIONAL POTENTIAL PROBLEPS 1 WAS OUTSIDE THE ECONCILIATION TOLERANCES E-ANALYSIS FOUND THIS 1 TO EET ASE CODE STESS ALLOWABLES a
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_CONCLUSIM:
- DRAWING DISCK PANCIES DID EXIST i
- DEGREE OF ACCURACY l
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- CEC 0'S OVERALL AS-BUILT PROGRAM WAS EFFECTIVELY IPPLEPENTED l
- NRC IEB 79 OVERALL OBJECTIVE WAS ET
- AS-BUILT PIPING SYSTEM PET TE DESIGN s
- ALL PIPING STESSES ET THE ASE CODE F
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ADDITIONAL COWIDENCE - PRNIDED BY;
- BYRON /BRAIDWOG)
- OTHER ROUTIE-NRC INSKCTIONS
- CEC 0 REVIEWS / INSPECTIONS OTHER EGION I INSPECTION AT SEABROOK (CIE ALLEGATION) SAE BASIC CONCLUSION l
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---------------------------------IIRC FINAL REVIEW-------------------------------l
- BYRON : : CECO :
- IDR BY : : Q.C. INSP./ :
- BECHTEL : : WALKDOhMS :
- BRAIDWOOD : : : BYRON : : : BYRON 90RC : *
- UNIT 1 : : : IDI : : : CAT TEAM :
- INSPECTIONS: : : NRC : : : INSPECT 1001 : '
- 86-32 AIIO : : : 83-32 : : : 85-27 :-
! 86-40 : : ! : : : :
- BYRON : : : BYRON :
- UNIT 1 : : : UNIT 2 :
- INSPECTION : : : INSPECTION :
- 84-51 : : : 86-30 :
1 I lADOITIONAL ASSURAIICE OFl l AS-B' JILT QUALITY l l l
- NRC :
- FINAL REVIEW :
----------------------------------------: AND CLOSURE :
- 86-27 :
(12) _ . _ _ - ____ _}}