ML19329E833

Interim Deficiency Rept Re Status of Undersized Fillet Welds on Pipe Supports.Welds Will Be Repaired & Insp Procedures Revised.Next Report Expected by 771230

ML19329E833
Person / Time
Site:	Midland
Issue date:	11/21/1977
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
References
HOWE-197-77, NUDOCS 8006180622
Download: ML19329E833 (14)

Text

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W 7... 7 is"i" M03 37. ' Pa'il N CODSumerS M power Oe';,eL";" - " Nib / Q.g,g ,c.m.,, d(2' . ,; -

C0mp2Hy General Offices: 212 West Michtgen Avenue. Jackson. Micnigen 49201 November 21, 1977 1 Hove-197-77

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Mr J. G. Keppler, Regional Director -

i C' Office of Inspection and Enforcement US Nuclear Regulatory Commission

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Region III '

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799 Roosevelt Road '

Glen Ellyn, IL 60137 7 MIDLAND NUCLEAR PLANT - THIS DOCUMENT CONTAINS UNIT No. 1, DoCleT No. 50-329 UNIT NO. 2, DOCKET NO. 50-330 ' P00R QUAUTY PAGES PIPE SUPPORT FILLET WELDS In accordance with the requirements of 10 CFR So.55(e), this letter constitute's' an interim report of the status of shop and field fillet velds on pipe supports designed and fabricated by ITT Grinnell, Warren, Ohio. Fillet velds on linear pipe supports have been found undersized. The following Table provides a brief description of the conditions:

. Nonconformance Reporting Item Condition Documents

1. Grinnell designs appear to specify velds MCAR-18 vhich do not meet minimum sise requirements as called for in NA 2452.1 of Appendix XVII of the ASIG Boiler and Pressure Vessel Code.

2. Site inspection of a sample of 112 hanger shop Interim Report #1 fillet velds revealed that 27 of the velds are, (in response to in the vorst case, up to 1/8" smaller than MCAR-18) required by the Grinnell desi 6n drawings and sketches. MCAR-19 3 Site inspection of a sample of 44 field NCR QF-201 (installation) fillet velds revealed that 4 such velds were smaller (by up to 1/16")tban required by the Grinnell design drawings and sketches.

The corrective action plans, for the above conditions, are documented in the attach =ents to this letter. The timing of this report precluded including the specific corrective action for NCR QF-201 which is presently being evaluated.

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.2 Howe-197-77 The defects reported in NCR QF-201 represent at most a condition e'q'u'al in seriousness to the defects reported in MCAR-19 and the final hardware disposition for MCAR-19 vill be applicable to NCR QF-201. It is anticipated that the final result of analysis and testing vill be that rework vill not be required . -

Another report, either interim or final, vill be sent on or before December 30, 1977

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-Attachments: 1) Quality Assurance Program, Mana5ement Corrective Action Report, MCAR-1, Report No. 18

2) Interim Report #1, dated November 14, 1977, MCAR-18.

3) Letter (WRB47-77),W.R.BirdtoSecretaryASMEB&PV

• Committee, Subject - Code Inquiries on Applicable Paragraphs for Subsection NF Fillet Weld Sizing, dated October 28, 1977

4) Letter, R. E. Weber to W. R. Bird, Subject - ASME File

1. NI-77-kO6, dated November 11, 1977

5) Quality Assurance Program, Management Corrective Action Report, MCAR-1, Report No. 19

6) Statement of Corrective Action Progress, MCAR-19, dated November 16, 1977

7) Consumers Power Company None'onformance Report, NCR QF-201.

J CC: Dr Ernst Volgenau, USNRC (15)

Director, Office of Management Information and Program Control, USNRC (1) -

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m IE4 e Attschment 1 OlsAllTY ASSURANCE PROGRAE[

'[ MANAGEMENT CORRECTIVE ACTION REPORT ' ,

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REPORT NO- 18

- . P.O. 7220-H-106 Yari0t83 DATE October 28, 1977 JOD NO. 7220 O NO.

1 'OESCRIPTION (including references): . - -

EQAM Section III, Number 9, paragraph 3.1.1 states in part, " Engineering precedures shall provide for review and acceptance criteria to detemine completeness and adequacy of supplier documents forwarded to Project Engineering." Contrary to this require' cent, designs prepared by the hanger design and fabrication vendor appear to specify tecids which do not meet ASIE Section III Code minimum size requirc=ent. The apparent code violation is in the design of fillet uelds joining linear nc=bers of hangers and scismic restraints as specified in AS!Z Section III-1E 3392 and Appendix XVII - NA 2452.1. -

' RECOMMENDED ACTION (Optional)

1. Obtain formal justification of vendor position on Coda. interpretation. l

2. Seek Code clarification from ASME Code Cornittee.

3. Preparc a detailed analysis of a 1% sample of hangers not meeting Table 2452.1-1 of Code Appendix XVII-NA 2452.1.

4. QA/QC to reinspect a sample of 25 installed hangers and 15 hangers in the trarc-house. Tabulate actual s eld size vs. size specified on the drat.ings. ,

5. Prepare an interim report and issue to the Project Manager within 15 days containing all available information, together with a statencnt as to .uhen a co:nplate report will be issued. -

REFERRED TO X ENGINEERING CONSTRUCTION QA MANAGEt.iENT

• Potentially Rcportable Pendins Results of Investigation ISSUED BN,..:2E.b. / /.

hW4 ' 'b cieCg yneer 10/27/77 Il REPORTABLE DISCREPANCY ' N IFIED CLIENT NO l YES N

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%*N'a O Li OCT 3 J.1977 QU51.iiT idhUild.M l AUTHORIZED BY Date OtST RIBUTION:

reni.ci usaao- J. B. Violette FORMAL REPORT TO CLIENT

. (tf Section 11 Appliell Date const.uct.on Man c,.c T. M. Leveretto e nola.,.g,u.a

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, g G. L. Richardson CORRECTIVE ACTION IMPLEMENTED ca..er w ocin ..., J. 1.maral (Caithersburg)

CA s'[c'.o '"*""*"'"* " J. E. Bashore ,(Norvalk) VERIFIED BY

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Hows-197-77

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- BECHTEL POWER CORPORATION

SUBJECT:

MCAR /6 (Issued /O-2.8-77) .

INTERIK REPORT / .

DATE: ))-] 4-77 PROJECT: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job No. 7220 Description of Discrepancy There is an apparent ASME Section III Code violation involving design of

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fillet welds joining linear type welded supports and component standard supports as specified by the hanger supplier. These welds do not meet the minimum size specified in ASME Section III-NF 3392, NF-3400, and Appendix XVII-NA 2452.1. .

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Potential Safety Implication A potential safety problem could exist if a structural. failure should occur in a Q-listed hanger due to an undersized weld. A sample of the question-able welds was analytically checked, and results show that welds as designed will carry the design loads. Based on the samples analyzed, there is no safety problem due to underspecif'ied weld size.

Corrective Action and Investigation Bechtel requested an informal code interpretation at the ASME Code committee meeting November 1, 1977. The code committee chairman stated, if a formal inquiry were presented, he would support a Code interpretation that minimum fillet weld size must be at least the thickness of the thinnest member joined where the Code minimum weld size table calls for a weld equal to or greater than the thickness of the thinner member.

Grinnell has been requested to clarify their position on code compliance.

We anticipate their reply to be that, even though they didn' t meet the above exact interpretation of the Code, they met the intent.

Grinnell has committed to conducting a program to substantiate weld integ-rity, including an analytical approach and destructive testing, and to submit a report justifying the adequacy of the questioned welds.

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4; ' .MCAR 18 INIERIM REPORT 1 BECHTEL POWER CORPORATION

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Crinnell has been rsqutsted to gubmit for rzview an outline of the invrati-gation test procedure including:

1.. Purpose of proof test report and how results will be used

2. Justification of sample size used in proof test, indi~cating how the samples are sufficiently large and representative to support an'y con-clusion to the satisfaction of the jurisdictional authoritius'

3. Detail steps of proof test 4 .' Verification of test equipment calibration

5. Schedule It is anticipated that Bechtel and CPCo will review test procedures prior to start of test,' and will witness test.

It is also anticipated that results of the investigation will have to be accepted by both the owner and the ASME Code jurisdiction.

Bechtel checking of a random sample of 650 earlier sketches indicates 110 of

-these sketches have linear welds that do not meet minimum size specified by the Code as follows:

41 welds were specified as 3/16 when the Code requires 1/4 41 welds were specified as 3/16 when the Code requires 5/16 .

2 welds were specified as 3/16 when the Code requires 3/8

• 24 welds were specified as 1/4 when the Code requires 5/16 2 welds were specified as 1/4 when the Code requires 3/8 A detailed analysis of 80 of the random sample sketches not meeting minimum weld size indicates that all welds on the sketches are theoretically of adequate size for the specified loading. Emergency loading conditions were-x, utilized in calculating weld stresses. Allowable stresses on the weld were

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3 .det,e,rmined from ASHE Code material allowable stress for normal conditions.

Results show that allowable stress equals 18 KSI and calculated

' maximum stresses in samples analyzed ranged from,less than 0.1 to 12.3 KSI.

Grinnell has stated that they have been following the Code table for minimum size weld since April 1977. A sample check by Bechtel of 95 recently submitted hanger sketphes, including 73 hangers with linear welds, shows that 4 hangers do not meet Code.

Random measurement at the jobsite of actual weld size was conducted by Bechtel QA/QC on 112 shop welds selected from various stages of installation t

and from the warehouse. This inspection resulted in the following findings:

1 85 welds meet or exceed drawing requirements.

27 welds did not meet drawing requirements.

Of these, 17 welds were undersized by 1/16 inch or less over less than 15% of the veld length, 6 welds were undersized by 1/16 inch or less for more than 15%

of the weld length, and 4 welds were undersized by 1/8 inch for more than 15% of the weld length. .

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'*. MCAR-18 INTERIM REPORT 1 - BECHTEL POWER CORPORATION

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Resolution of these undersi=ed welds will be add' essed r in MCAR 19; however, l Grinnell has stated that they have been inspecting 1007,of shop welds since July 1977. .

Forecast Date on Corrective Action .. I 1

It is expected that the results of the test program will not be received

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- until January or February 1978. Program results will then have to be accepted by the Owner and the Code jurisdictional. authority. A final report would then follow.

Submitthd by: #

Approved by: 'rHLfittc+$d[uL Concurrence by: f. 4/ /effh BECHTEL POWER C0kPORA/ ION 9

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• A,.. coa. e 7 7es-osso October 28, 1977 ,

WEB 47-77 American Society of Mechanical Engineers Att: Secretary, ASME E&PV Committee United Engineering Center 345 East 47th Street New York, NY 10017

SUBJECT:

CODE INQ,UIRIES, ASME CODE SECTION III, SUBSECTION NF y Please provide an interpretation of the following questions to the writer:

1. Table NP-3132.l(b)-1 and Para 6raph NF-3292.

If Class 1 linear supports are designed by " experimental stress ,

analysis" or by " load rating," does paragraph NF-3292 apply?

2. Paragraph NF-3292 and Para 6raph XVII-2450.

When paragraph NF-3292 applies, must all fillet velds comply with the minimum size requirements of paragraph XVII-2452 and Table XVII 2452.1-1 when the analysis shows a smaller veld size to be satisfactory?

We are of the opinion that a clear definition of requirements in needed in the Code with respect to the above inquiries. ,

k k W. R. Bird Section Head Quality Assurance Engineering t

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Tho Arncrican aociety of Mcchanical Eiiginocrs il

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United Engineering Center /345 E. 47th St., New York, N.Y. 10017/2p 644-7722

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Attachment 4 Howe-197-TT ,

Consumers Power Company ,

212. West Michigan Avenue Jackson, MI 49201 DATE: November 11, 197'7 ATTENTION: W. R. Bird .

SUBJECT:

ASME File # NI-77-406 ..

Centlemen:

We have your letter of October 28, 1977', and we are referring -it to the Chairman of the Subco=mittee concerned.

We will advise you when we have heard from him.' .

. If you have any cause to contact this office on this inquiry please be sure -

to reference the ASME file number given above.

Yours truly, .

by. d. 6hA;z /<..c_. .

. Ray E. Weber .

Nuclear Engineering Adininistrator Ti . . . .

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NOV .I. 4,1977 SbUTYASStjBf,h'CE s, 4

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Hove-LbT(-T*l l QUALITY ASSURANCE PROGRAM l

, f MANAGEMENT CORRECTIVE ACTION REPORT

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MCAR.1 ,

% 10' P.O. 7220-M-106 REPORT NO.

JOB NO. 7220 0NO.Various DATE November A , 1977 l I *0ESCRIPTION (including references):

A weld siu inspection using.a weld fillet gauge was conducted of a representative sacple of pipe hangers to detcrmine the actual veld size cocpared to Grinnell design drawings and sketches. This was done to fully assess all conditions associated with MCAR 918 involving the 1.ack of Grinnell use of weld sizes from Table 2452.1-1 of Code Appendi:: XVII - NA 2552.1. It was discovered that from a sample of 23 hanscrs installed and 9 hangers fren the warehouse, representing 112 velds, 22.T of the welds were under the specified size required by Grinnell drawings. Contrary to Purchase:

Specification M-106, Isaragraph 10.1, Grinnell has not assured the compliance with draufno. rt'cuirenents.

• RECO.*.tMENDED ACTION (Optionau

1. Establish hou the deviation occurred at Grinnell.

a. Determine the cause of the deviation,

b. Determine the inspection technique and acceptance criteria utilized by Grinnell. Specifically, determine the percentage of welds measured for dimensional cc=pliance.

2. Qualify existing veld size.

a. Provide for undersi=e variance in the scope of the worst case condition by ,

using calculations and proof-testing by Grinnell to preclude rework of ,

undersize welds from Grinnell drawings.

REFERRED TO X ENGINEERING CONSTRUCTION QA MANAGEMENT

• Potentially Reportable Pending g ,. ,

Results of Investigation ISSUED B ** J a.e b *wA U' N/? . ~'

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11 REPORTA0LE DISCREPANCY NOTIFIED CLIENT 's*0"c-W r 3 - IO NO I YES f'oiect W^. dTM c?u!W Pr Manager Gate ,-

111 CAUSE #

CORRECTIVE ACTION TAKEN

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$Al3))Rggy AUTHORIZED BY oate castnieuriom J. B. Violette Protect Manance coni.. e . n u n ae, T. t.I. Levcrcttc FO,,RMAL g 3,,,,,,RE,,POTIT 3 py,,,, T,O CLIENT g,,, ,

' j af;',*'al,,M,,*a***' G. L. Richardr.on

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,,,,,,,. J. Amaral (Caithernburg) CORRECTIVE ACTION IMPLEMENTED .

u. J. E. Banhore G!orvalk) ci ... e. nn: e n

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gspr--- . A. G. Ilorner VERIFIED RY

'Dewnf.* eri mere twieried and etesch reference dnrurwnf. Proscet GA Engineer Date

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Management Corrective Action Rcqucst Pate 2- _

Report No. 19 . ..

Date Novenber 4. 1977 I. RhCO':t!EI'DED ACTION (' Cont'd.)

b. Review the above proef-cest procedure for Grinnc11's test-to-failure tests including scrple size and scope of investigation.

c. Obtain s,chedule for cocpicting tests and date of submittal of test and analytical results.

3. Establish contrair for hangers not installed or in manufacture.

a.- Perforn :n inspection of the lot of hangers shipped 10/31/77.

b. Based on the chove, if the lot is acceptabic:

(1) establish a PSQR nonitoring program to assure that the current veld quality is nciatained, (2) verify that Grinnell's inspection procedures provide and doce=ent sufficient inspection to assure that all uelds comply with centrcctual requirencats.

c. If the lot is not acceptabic: ,

(1) inspect all new hangers at the Site based on an AQL of 1% of .

the lot size until controls are established at the source, (2) tighten procedures with Grinnell to assure acceptcbility.

d. Identify the quclity status with respect to welding on all hangers.

4. Inspect en additicnal senple of installed hengers to detconine if there are any velds with dirensions less than the worse case condition.

Identify discrepant velds and' coordinate further corrective action uith Grinnc11.

5. Have PSQR increase surveillance and reject undersized velds prior to shipment. ,

-' 6. Determine reportability under 10 CPR 50, Section 50.55(e). Preparc an interta report and issue to the Project Manager uithin 15 days containing all availabic information. together with a statccent as to when a -

completc report will be issued.

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Attschment 6 November 16, 1977 Howe-15TT-77 J

STATDE2iT OF CORRECTIVE ACTION PROGRESS MCAR-19 . . .

1. Bechtel has communicated all the items on MCAR-19 to Grinnell where 4-

, Grinnell has specific action to perform.

2. A meeting was held at Midland on November 16, 1977 with Bechtel, Consumers Power, and Grinnell in attendance at which Grinnell committed to revise their inspection procedure (02A006 - Visual end Dimensional Acceptance Criteria for Welds) to provide maximum and minimum tolerances and other specifics. A target date for a released revision is mid-December.

3 Bechtel has implemented an inspection of veld size for all new hangers received at the Midland site based on an AQT of 1% (Mil Q lO5D).

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r)' AttIchment 7 How's-197-77

. At+=n5---at A Routa To tis Ccer For /' - File 16.3.6

}{.ggrglay draewgen[., .j Issue Dace Mounmb w is. 1o77

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BW!arguglio RHermeNton SHHowell k'

DATaggart DRJohnson CMC 2D PJW File 'Citle NCR'W on Machtn1 GSKeeley quality control JMKlacking IIonconfor=ance PAMartinez Report No 0F-201 4

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21h IIonconfc-ece Report la Issued To: Prepared By Yld 86U~~, ( Date /h6 77 C. L. Richardson Approved By 6 be A7 ate D M W 77 Bechtel Lead Quality Assurance Engineer Written Reply Requested By Date 11-30-77

- ConectiveActionRedstedByDate 12-16-77 who is resconsible for conective ection.

Uonconformance Description and Supporting Det": , . . . , - - ,

q kI See Attachment. Ef,'h .J,0d U (h'jy '

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,....n-Q)],di: l .'. w ndNE AIC Reportable Yes No @ See Precedure 9 (for Nucles: Projects Caly)

Stop h*ork necessary Yes $o X .ee Precedure 16 - Stop Work Ho "No Hold Tags Applied" -

Rec = = ended Cerective Action:

1. Repair welds to meet required drawing specifications or justify existing condicion.

2. Detarn'.ne why une!crsize and visual condition was not iden-ified during Bechte]

QC inspection and take corrective action to preclude repetition.

3. Provide assurance that all existing field welds are satisfactory.

1 Co r ective Action Taken:

berificationofConectiveActionRequired Yes no O b'ethod of Veri"ication:

I nonconfer=ance Closure Confi:=ed By Date 1 lb be ec=pleted'at ti=e of closure by Consu=ers Power QA Services.

Page 1 of 2 e

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File 16.3.6

- ' Issue Date November 15, 1977 Project Midland 1 & 2 File Title NCR's on Bechtel Quality Control Attachment to Report No QF-201 Nonconformance Description and Supporting Det' ails:

As a result of dimensional and visual inspection of hanger fillet welds, the following nonconforming conditions were documented:

Item #1 - Auxiliary Building, Room 28, Hanger 4-2HCB-20-H1, Sketch 2-613-3-6, weld attaching -Item #2 (sway strut assembly) to e'xisting U 21 x 55 beam.at Elevation 582'-3" requires a 1/4" fillet weld.

Contrary to the above one area of the fillet weld is undersize.

Item #2 - Auxiliary Building, Room 25, Hanger 6-lCCB-18-H7, Sketch 1-612-4-16, weld attaching Item #1 (sway strut assembly) to Item #2 (4" M-beam) at Elevation 570'9" requires a 5/16" fillet weld.

. Contrary to the above one area of the fillet weld is undersize.

Item #3 - Auxiliary Building, Room 217, Hanger 2 1/2-2CCB-12-H3, Sketch 2-604-713,

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_ weld attaching Item #1 (3/S" x 10" x 10" carbon steel plate) to wall embedment at Elevation 605'9" requires a 3/16" fillet weld.

, Contrary to the above the following condition exists. Item #1 is bowed away from the embedment with a resulting gap of approximately

.075 in. (1.88mm). This results in an effective fillet leg of approximately 1/8 in. on the plate, which is below the required 3/16" fillet.

Item !4 - Auxiliary Building, Room 28, Hanger 8-2GBC-16-H2, Sketch 2-613-3-13, '

I weld attaching Item #1 (4" M-beam) to existing W 21 x 82 beam at Elevation 582'3" requires a 1/4" fillet weld.

Contrary to the above the weld fails to-meet acceptable visual require-ments. - Excessive overlap results in most of the weld material being

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deposited on the. hanger (Item #1) and very little weld deposition on

.the existing beam.

-All of the above discrepancies are on field welds. Bechtel has subsequently issued NCR's on the above items.

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U.S. N4CLEAH 0%U4.ATO::V COMM4SSION- 00 etM l pal - '

3 Jo NBC DISTRIBUTION pon PART 50 DOCKET MATERIAL I TO- . FROM: CATE CP occuuENT Consumers Power Company 11/21/77 Mr. J. G. Keppler Jackson, Michigan o,7, ,,c,3 y g o l

Stephen H. Howell 11/28/77 27.sTTEM CNOTOMIZED PMCP INPUT PORM NUMBER OF CCPtES MEC2tVED Cona:NAL -2f> Net.AssipiEo W' }m .

casCMIPTION ENCLOSU ME Consists of an interim report of the status of shop and field fillet welds on pipe supports designed and fabricated by ITT Grinnell, Warren Ohio.....

PLXi'r NAME : Midland Units 1 & 2 RJL 11/29/77 (2-P) (1-P)+(10-P) 16 BAKt, gApr-v FOR ACTION /INFORMATION ENVIRONMENTAL

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