ML20215J828
| ML20215J828 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/18/1987 |
| From: | Levin H, Streeter P TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#287-3828 OL, NUDOCS 8706250123 | |
| Download: ML20215J828 (20) | |
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Filedi June 18, 1987 r.o i
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'87 - AN 22 P3 :31 0FFIL1 qp 00N gj "<W UNITED STATES'OF AMERICA.
NUCLEAR REGULATORY COMMISSION
....v before the ATOMIC SAFETY AND' LICENSING BOARD i-l
/
In the Matter of-
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)
Docket Nos. 5C-445-OL-
-TEXAS' UTILITIES ELECTRIC
)
.50-446-OL-h
- COMPANY etLal.
)
)
(Application.for.an (Comanche' Peak Steam Electric
)
' Operating License)-
Station, Units l'and 2)'
)
)
i ANSWERS TO BOARD'S 14 QUESTIONS (Memo;-Proposed Memo of-April-14, 198.6)-
Regarding Action Plan Results Report V.e
-In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak
' Response Team ("CPRT") to the 14 questions posed by the
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Board,-with respect to the Results Report published by the CPRT'in respect of CPRT Action Plan V.e, Installation of Main Steam Piping.
'8706250123 870618 PDR. ADOCK 05000445.
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Opening Request:
, Produce copies of any CPR"J-generated checklists that were used during the conduct of the action plan.
Response
The only checklist used during implementation of l
ISAP V.e was the Visual Evaluation checklist (Attachment 1 -- this is Appendix 2 of Reference 9.46 of the ISAP V.e Results Report).
This was a limited-purpose checklist intended to aid in the engineering evaluation of the disposition of a single Nonconformance Report (NCR) involving approximately sixty pipe / equipment installations.
The checklist was not part of a sampling effort.
Question:
1.
Describe the problem areas addressed in the 7
L report.
Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it discover about the QA/QC documentation for those areas?
How extensive did it believe the problems were?
Response
The problem areas addressed in the ISAP V.e Results Report were the direct result of identified cor.cerns and investigatory actions described in SSER-10 (Reference 9.1 of the Results Report).
These concerns I i
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3-l and actions'are-presented in Sections 1.0 and 2.0'of the Results/ Report.
The following is a summary of these two sections:
An allegation was made that a Unit 1 main
-steam line inside containment.was' installed-incorrectly and then, after flushing, forced-fnto proper position by use of the main polar crane and come-alongs.
Additionally.,
.it was alleged that' vibrations occurring as part of the process of cutting the temporary flushing-line.may have damaged the main steam line..The TRT investigation generally csupported the allegation except that the vibrations could not be confirmed.
The TRT also concluded that a TUEC analysis of the incident was incomplete. 'TRT review of.
applicable specifications and procedures-indicated that there were inadequate requirements and construction' practices involving the temporary supporting of piping and equipment.
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Specific requirements are identified in SSER10, the elements of which are stated below:
1.
Modify applicable specifications and procedures so as to assure that the quality of piping and equipment is not affected during the temporary support
- process, 2.
Perform assessments of two Unit 1 main steam lines, considering all conditions which may have existed during the installation process, and i
1 3.
Perform assessments of other piping and/or equipment which may been involved in similar incidents during the temporary process.
The CPRT review concluded that the method of handling the main steam pipe repositioning and flushing was adequate.
However, the opportunity existed to strengthen associated procedural requirements (refer to Section 5.5 of the ISAP V.e Results Report for further discussion). !
The response to Item (3) resulted in an.
engineering evaluation of the dispositioning of a single NCR involving temporary supporting practices associated with approximately sixty (60) pipe / equipment installations.
The results of the engineering evaluation were that the nonconforming condition (NCR) did not lead to any unacceptable conditions on equipment nozzles.
The engineering evaluation is Reference 9.46 of the ISAP V e Results Report; the checklist presented as part of these responses (Attachment 1) was prepared-to aid in this engineering evaluation.
Also refer to Sections 5.2.1.1 through 5.2.1.4 of the ISAP V.e Results Report for more detailed discussion.
Sampling was not used in this ISAP.
This includes the specific area of NCR review, where all mechanical NCRs were reviewed to identify where there might be a concern related to springing of pipe during the installation process.
QA/QC documentation was not explicitly reviewed j
for adequacy during ISAP V.e.
implemention.
- However, where such documentation was part of this effort (most
)
notably, the NCR review ciscussed above) there were no i
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I-observations of QA/QC procedural inadequacies noted by theithird party.
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Question:
2.
. Provide.any' procedures or.other' internal documents'that are necessary.to understand how-
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the checklists should be interpreted or applied.
Response
Explanation and use of the checklist is described-in Attachment 2.(Sections 2.0 through 4.0 of Reference 1
9.46~of the ISAP V.e Results Report).
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Question:
~3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response
The checklist was used to support a visual evaluation of installed conditions with analytical considerations guiding the.evaluaticn.
The concern initiating the associated engineering evaluation-related to disposition of the NCR, not to QC inspections associated with the piping / equipment.
As such, the checklist did not match or duplicate QC i
inspection checklists or other fabrication / installation checklist documents, nor was it. intended to do so (also refer to discussion in Section 2.0 of Reference 9.46 of ____-_
t r
the ISAP V.e Results Report provided as part of the I
response to Question 2 above).
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Question:
4.
Explain the extent to which the checklists contain-fewer attributes than are required for l
conformance to codes to which Applicants are committed to conform.
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Response
The checklist was not prepared / applied to l
determine conformance to codes or standards.
It was intended specifically to aid in the implementation of the ISAP (also refer to response to Question 3 above).
Question:
5.
(Answer question 5 only if the answer to question 4 is that the checklists do contain fewer l
attributes.)
Explain the engineering basis, if l
any, for believing that the safety margin for i
components (and the plant) has not been degraded I
by using checklists that contain fewer attributes I
than are required for conformance to codes.
Response
1 Not applicable by reason of response to Question 4.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
No changes were made.
Question:
7.
Set forth the duration of training in the use of checklists and a summary of the content of that 4 !.........
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. training, including. field training or other
-practical training.
If the training has changed or retraining occurred, explain the reason for.
the' changes or retraining and-set forth changes-in duration or content.
Response
'The checklist was used only by those who prepared it.
As a; consequence, it was not necessary to conduct a specific training program to apply the checklist'.
m Question:
l 8.
Provide any information in Applicants possession concerning the accuracy of use of the checklists (or the. inter-observer reliability in using the checklists).
Were there any time periods-in which checklists-were used with questionable training or QA/QC supervision?
If applicable, are problems of inter-observer reliability addressed statistically?
Response
Because of the limited use of the checklist and the controlled application (i.e., only the individuals who prepared the' checklist applied it), it was not i
considered necessary to establish the accuracy of checklist application.
It was also not considered necessary to'further establish the reliability of the i
l third-party individuals who applied the checklist, beyond that already established within the CPRT
)
training files.
QA/QC supervision was not required nor considered necessary for checklist application.
Inter-observer l
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reliability was not addressed and'is not an issue.
Question:
9.
' Summarize all audits or supervisory reviews.
-(including reviews by' employees or consultants) of training'or of use of the checklists.
Provide the factual basis for believing that the audit and review activity.was adequate and that eachf concern of the audit and review teams has been resolved in.a way that is consistent with the validity of conclusions.
Response
An' audit.was performed'of the overall implementation of ISAP V.e.
No nonconformances or observations were 1
identified relative.to checklist. preparation or application.
There was a nonconformance indicating that training records for the. individuals who prepared and applied the checklist I
were not available in the work 4.ng files.
The working files were updated, and the auditor, in his audit follow-up, reviewed the files and verified I
that complete'information is now available.
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L Tne audit was performed in accordance with established procedures and was overviewed by a member IL of the overview Quality Team.
Audit guidance is
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provided by the SRT in the Program Plan.
Question:
10.
Report any instances in which draft reports were modified in an important substantive way as the result of management action.
Be sure to explain any change that was objected to (including by an employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present. 4 i
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-Explain what-the earlier drafts:said and'why they were' modified.
Explain how dissenting views were.
. resolved.
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. Response:
No substantive modificati6ns were made as a g
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. result of management action.
- Question.
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11.
Set forth any unexpectec. difficulties that were encountered in completing the work of each task E
force and that would be helpful to.the Board in understanding the process by which conclusions were reached.
How were each of these. unexpected' difficulties resolved?
Response
Analyses and reviews performed as part of ISAP V.e implementation did not result in unexpected difficulties.
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Question:
12.
Explain any ambiguities or open items left in the Results Report.
I
Response
1 The only open item identified in the Results
- Report involved a TUGCO commitment to revise a construction procedure to strengthen existing practices regarding the use of temporary supports (refer to Sections 5.3 and 7.0 of the ISAP V.e Results Report for
-description.and background).
This item has been closed by the issuance of a Design Change Notice (DCN #1) to.
the procedure.
To the best of our knowledge, there are no ambiguities in the ISAP V.e Results Report.
Question:
(
i 13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Response
The only potential conflict of interest was associated with the initial investigatory activitias conducted by R.
L. Cloud Associates, Inc. (RLCA).
While these activities were initiated as a third-party effort, RLCA subsequently assumed responsibilities assisting TUGCO in the area of piping design in mid-1985 (during ISAP V.e implementation).
As a result, all RLCA activities were reviewed in detail by the third-party (TERA) and found to be acceptable.
All other direct TUGCO activities were reviewed by the third-party and found to be acceptable.
Refer to Section 4.3 of the ISAP V.e Results Report for a description of the scope of responsibilities.
Question:
14.
Examine the report to see that it adequately discloses the thinking and analysis used.
If the l
language is ambiguous or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions. -_ - __- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _.
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Response
-The. Issue Coordinator, and.:others who aided in i
the preparation and approval'of the Results Report, l;
L have reviewed and checked the report for clarity and believe that there are no ambiguities.
l Resp fully submitted,
/
Peful Stre6ter Action Plan V.e Issye Coordinator l
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Levin L
Review Team Leader
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The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.
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"TT A C H M EA.fT
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'V!SUAL EVALUAT!ON CHECKL1ST-(fer NCR M-2223LNOZZLE INVESTIGATIONS)
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Room No:
Equipment No:
Nc==le ( Line ) No:-
Sheet of
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No==le Sketch:
Piping. Sketch:
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Area Investigated:
Restrictions:
.=================================================================
Relevant Findings:
' Cracks:
Local Flattening:
Local Buckling:
i Surface Feature Distortion:
Surface Ridges:
' Similarity Differences:
Cracked Paint Other:
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Nonrelevant Findings:
Grinding:
Scratches:
Machining Grooves:
Cold-Lap:
Undercut:
Other:
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Concealment Findings:
Grinding:
Thick Paint:
Filler Added:
Peening Indentations:
Cold-Lap:
Other:
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l Additional Comments:
-=================================================================
Recommendations for Further Investigation:
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==================g=========================g========
Investigation!
By:
Date:
By:
Date:
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[h T rA cMM(UVT b
\\ og 95 2.0 EVALUATION OBJECTIVE AND SCOPE The objective of this evaluation is to develop and review supplemental information (to existing data) for, investigating possible pipe / equipment damage.
Specifically, this involves damage which may be attributed to inadvertant springing resulting from the use of temporary supports during the pipe installation process.
The evaluation is associated with the equipment identified in NCR**' M-2223 (Reference 1) (list of equipment is included in Appendix 1). The results of this evaluation will be used as input to the ISAP V.e results report.
During the first portion of the evaluation, visual methods will be used to identify any pipe / equipment damage.
Evaluation criteria for this portion of the evaluation are included in Section 4.1 below.
The visual techniques used will be aimed at detecting and evaluating surface conditions or gross deformations
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which in particular may have resulted from local yielding due to overstressing during the piping installation process.
In general, the surface of each no::le, including both attachment welds (or flanges) and an inch or more of the adjoining equipment and piping will be investigated.
In the event that cracks or other rejectable discontinuities are suspected or identified, further investigations will be recommended.
Such recommendations may be that NDE methods should be used to examine indications suspected or identified herein.
The recommendations may include methods and specific techniques.
In such cases where NDE is recommended, qualified technicians, procedures, and equipment should be used.
During the second portion of the evaluation, the investigating engineers will review the layouts of the attached piping.
Particular layouts will be identified which potentially might have led to overstressed or overloaded equipment and/or attached piping (even though there might not be visible indication of damage).
Subsequent to this identification, simplified stress analyses will be performed.
Criteria for these analyses are presented in Section 4.2 below.
Conditions of overstressed pipe or overloaded no::les will be noted.
Recommendations may include consideration of more detailed stress analysis at specific locations of concern (e.g.,
no::le-to-shell juncture).
Such recommendations will include applicable criteria.
- ' Abbreviations used in the text of this evaluation are defined
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in 7.2.
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3.0 DESCRIPTION
.0F EVALUATION PROCESS The steps of the evaluation are as f ollows:
Step 1.
Organi:e and review all supplied documents.,
1 Step 2. Request insulation removal in areas considered to have been subjected to the maximum stresses-developed during the pipe installation process.
Step 3. Perform walkdown of the piping and :the associated no::les, reviewing the applicable portions of NCR M-2223 and
.other data as necessary.
Step 4.
Determine the-likelihood and location of potential overstress based on Step 3.
Step 5.
Where necessary, based on Step 4,
determine the amount of surface area. and location of the area to be investigated visually.
Step 6.- Apply the visual' evaluation criteria as described in Section 4.1.
Step.7. Evaluate.and summarize the results of the visual I
investigation using the standard checklist (Appendix 2).
Where indications of overstressing are suspected or i
identified, recommend further investigations.
Step B.
Review layouts (during walkdowns) to determine those which might be most detrimental (even though they might not cause visual damage).
Step 9.
Perform simplified stress analyses of the piping identified in Step 8, using the criteria given in Section 4.2.
Step 10.
Evaluate and summari:e stress analysis results l
including comparisons with no::le allowables.
Where overstressing or overloading are identified, recommend further investigations. i i
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13 c@ 55 r
4.0 EVALUATION CRITERIA The following evaluation criteria will be used to investigate the equipment noz:les, no::le
- welds, and adjoining, piping for possible overstress during piping installation.
4.1 Visual Evaluation Criteria 4.1.1 Cracking 4.1.1.1 When direction of possible overstress is known, cracks and tears will be perpendicular to tensile stress.
Wrinkles and bulges will be perpendicular to compressive stress.
4.1.1.2 Cracks and tears are distinguished from the following other. typical surface features by the noted criteria a) Grinding Marks: Grinding marks run parallel in groups and remose other contour features.
Cracks need not be in groups and can run across contour features.
b)
Machining Grooves Machine grooves run in a
specific rhythmic-pattern.
Crack patterns have at least some randomness.
I c)
Weld Undercut:
Weld undercut by definition exectly follows'the weld edge.
-Cracks seldom follow the undercut, but instead wander.at least 1005 inches into the bottom of the undercut, or up the sides.
Cracks will often run from undercut " gouge" to undercut " gouge".
d) Weld Cold-Lap:
Weld cold-lap is very smooth as it only occurs with automatic or semi-automatic processes.
-Cracks in the Heat Affected Zone (HAZ), when
- visible, are jagged when viewed with 4 X magnification.
e) Scratches: Scratches are not jagged on a
micro scale.
Deep scratches often have upset material at the sides.
Scratches are usually jagged at 4
X or more, and have no upset.
s4.1.2 Deformation, Upseting, Elongation 4.1.2.1 Typical surface
- features, i.e.,
grind or machine marks, sand casting roughness, forging pits or marks, are stretched or compressed in relationship to one another. !
bi FACMMCrW Q
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6 4.1.2 Deformation, Upseting, Elongation (continued)
. ;i 4.1.2.2 Local surfaces appear
- bulged, wrinkled,
- buckled,
]
flattened, or depressed in relationship to the noz:Le axis..
This would appear in the stressed quadrant of the circumference, j
4.1.2.3 Parallel ridges appear at a
constant angle to the direction of compressive or torsional stress.
Compression ridges l
would appear in a stressed quadrant; torsion ridges would appear
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anywhere around the circumference.
1 4.1.2.4 Cracking or spalling of factory paint may warrant addi ti onal investigation.
4.1.3 Similar Nozzles When similar no::les on the same piece of equipment, or similar nozzles on similar equipment, appear to have been manufactured in the same manner, but have different characteristics as described in 4.1.1.2 or 4.1.4, overstress will be suspected.
4.1.4 Concealment of Material Features Concealment of material features described in 4.1.1, 4.1.2, and 4.1.3 may be evidenced by:
I a)
Grinding marks in areas of tensile, compressive, or torsional stress, where the reason for such grinding is not
- apparent, i.e.,
blending of weld
- strikes, weld
- beads, scratches, or abrasions.
b) Paint that is thick enough to mask normal inherent features,'i.e., machining marks, weld contours.
c) Painted areas that have a " dabbed" appearance, indicating I
a filler was applied or a "gla:ed" appearance, indicating a
filler was sanded smooth.
In either case, slight probing with a pick will reveal soft nonmetalic fillers.
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d) Peening indentations.
e) Material features may be masked by an acceptable amount of weld col d-l ap.
f) Suspicion of concealment of overstress features will require further investigation.
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b 4.2 Analysis Criteria 4.2.1 Modelling In all cases, piping models will be based on the assumption that i
the piping as described in the NCR is cantilevered from the no::le in question, even where-the NCR might indicate that a
support -- wire, wood block, etc.
-- is present.
Where stresses and/or no::le loads are excessive, displacements from the cantilever analysis may be reviewed to determine whether it would be logical to assume that such supports might be effective.
If so, reanalysis with support (s) added may be warranted to provide a more credible representation of the conditions involved.
4.2.2 Pipe Stresses Pipe stresses will be considered acceptable if below the-specified minimum yield stress allowables at room temperature.
Yield stress values will be obtained from Appendix I of Section III of the ASME Boiler and Pressure Vessel Code (Reference 19).
4.2.3 Nozzle Loads No::le loads will be consi dered acceptable if below allowables from the applicable equipment specification.
Because of the variety of ways in which no::le allowables are
- defined, the initial review will address Upset condition allowables.
- However, since the concern here involves potential no::le damage, loads will be considered acceptable if yield stress is not exceeded in the no::le.
In some cases, this would allow use of at least Emergency condition allowables.
If higher than Upset condition allowables are used, such will be identified in the evaluation.
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b h(.b b i I mc CERTIFICATE OF SERVICE
'87 JW 22 P 3 :31 -
I, Robert K. Gad III, hereby certify that on June 18, 1987, I madeserviceof"AnswerstoBoard's14Questionkh[M'emo;.l Proposed BiinNw Memo of April 14, 1986) Regarding Action Plan Results Report'V.e" by mailing copies thereof, postage prepaid, to:
Peter B.-Bloch, Esquire-Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission
.j U.S. Nuclear. Regulatory P.O. Box 38
~
Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H. Jordan Ms. Billie Pirne'r Garde Administrative Judge GAP-Midwest Office 881 W.
Outer Drive 104 E. Wisconsin Ave.
-B Oak Ridge,. Tennessee 37830 Appleton, WI
$4911-4897 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing-Appeal' Panel Board Panel U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S.
Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555 a
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Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.. Box 12548, Capitol' Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C,.
20555 Anthony Roisman, Esquire Mr. Lanny A.
Sinkin
-Suite 600 Christic Institute 1401 New York Avenue, N.W.
1324. North Capitol' Street Washington, D.C.
20005 Washington, D.C.
20002 Dr. Kenneth A. McCollom Mr. Robert'D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S._ Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.
Johnson Geary S.
Mizuno, Esq.
Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal. Director P.O.
Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Nancy H. Williams 2121 N. California Blvd.
Suite 390 Walnut Creek, CA 94596
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y R.
K. Gad III
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