IR 05000260/1989015
| ML20247M476 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/17/1989 |
| From: | Fair J, Terao D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247M472 | List: |
| References | |
| 50-260-89-15, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8906050049 | |
| Download: ML20247M476 (35) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION TVA PROJECTS DIVISION-Report No.: 50-260/89-15
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Docket No.: 50-260
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-Licensee: Tennessee Valley Authority 6N, 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Facility Name: Browns Ferry Nuclear Plant Unit 2 Inspection At: Stone and Webster Engineering Corporation; Cherry Hill, New Jersey Inspection Conducted: January 23 through February 3, 1989 Inspector: T7 f//?/Sr}
'Date phnR. Fair.TeamLeader Consultants: A.V. duBouchet, R.E. Serb
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Approved by: i 1W81 I u h ed/' $ ze Yb7/h] Date David Terao, Chief j' / Engineering Branch TVA Projects Division Office of Nuclear Reactor Regulation 8906050049 890518 PDR ADOCK 05000260 0 PDC
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BROWNS FERRY NUCLEAR PLANT, UNIT 2 PIPING ANALYSIS CALCULATION PROGRAM INSPECTION REPORT 50-260/89-15 JANUARY 23 THROUGH FEBRUARY 3, 1989 BACKGROUND INFORMATION , The Tennessee' Valley Authority's (TVA's) special program for piping and supports was.. developed to address concerns identified with TVA's past implementation of Inspection and Enforcement Bulletins (IEBs) 79-02 and 79-14. This program involves the inspection and evaluation of all piping systsms covered by the scope of the bulletins'(except torus attached piping) and the identification and_ implementation of required restart modifications. The program also calls for the. completion of allmanalysis and modifications to design criteria by the end of-the next (Cycle 6) refueling outag The TVA's piping and support program was initially described in Section III. of the Browns Ferry Nuclear Plant (BFNP) Nuclear Performance Plan (TVA letter from S.A.' White to L.W. Zech dated August 28, 1980). TVA provided additional details on the proposed program plan'as an enclosure to a TVA letter from R. Gridley dated April 8. 1987. The staff position on the program plan was 4 presented in a March 17, 1988, meeting with TVA (Reference 1). The resolution of issues related to the piping and piping support design methodology was discussed in meetings with TVA in June and September 1988 (References 2, 3, 4, 5). Additional discussions on the implementation of the piping and support -l design methodology were held with TVA in December 1988 and January 1989 1
! (References 6, 7, 8).
The pre-restart portion of TVA's piping and support program will be performed in two parts. The first part involves the completion of the rigorous analysis of 35% of the program scope. The second part involves an evaluation of the remaining 65% of the piping systems for generic attributes identified from the completed rigorous analysis (Reference 10). INSPECTION SCOPE AND OBJECTIVES The purpose of this inspection was to review TVA's implementation of the rigorous piping analysis and support program. .The review included TVA's design criteria documents, quality assurance audit reports, piping and support calculations, and TVA's generic attribute evaluatio , SUMMARY
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During the inspection, 27 items were identified and discussed. One item, ; EMG-011, was resolved and closed during the inspectio The remaining items : i
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. .are considered open, pending review of TVA's corrective actions. Most of the i l
open items identified during the inspection involve issues with TVA's design criteria documents. These design criteria documents had all recently been revised prior.to the inspectio Although the inspection team also reviewed the detailed piping and pipe support ; calculations and generic attribute evaluations, no conclusion on the adequacy- ! d
. of the program implementation could be reached due to the limited number of calculations that had been completed at the time of the inspectio . DETAILED INSPECTION FINDINGS The following paragraphs characterize the inspection findings and conclusions for each area of the review effort. Appendix A contains a listing of all open items identified during this inspection that remain unresolved. During the inspection, TVA's proposed corrective actions were considered adequate to resolve the majority of the items listed in Appendix In addition, corrective actions proposed by TVA during post-inspection followup meetings (References 9, 19) are considered adequate to resolve most of the remaining items. Nonetheless, the items. listed in Appendix A are identified as open, pending the review of the completed corrective action .1 TVA's Program to Regenerate BFNP's General Civil Design Criteria TVA's two-phase program to prepare new BFNP general civil design criteria is summarized in the Item 3.D Attachment to the TVA memorandum entitled Response to CAQR BFT 870 842 (RIMS No. B30 87 1208 401).
During Phase 1 of its program, TVA contracted with Gilbert Connonwealth (G/C) to evaluate all of the documents comprising the design basis for BFNP. G/C ; was to document, but not address, discrepancies, errors, omissions, and criteria deficiencies. G/C used the design basis information from the following sources to prepare drafts of the general civil design criteria: The 22 existing BFNP civil design criteria (with exceptions noted below); , Final Safety Analysis Report (FSAR), Revision No. 4; and The commitment and requirement (C/R) database of 5.165 C/Rs (RIMS Nos. B30-87-0821-002 and 003).
On July 1,1987, TVA issued Revision No. O of the following BFNP general civil design criteria: General Design Criteria No. BFN-50-C-7100, " Design of Civil Structures"; General Design Criteria No. BFN-50-C-7101, " Protection From Wind, Tornado Wind Tornado Depressurization, Tornado Generated Missiles, and External Flooding";
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. General Design Criteria No. BFN-50-C-7102, " Seismic Design"; General Design Criteria No.' BFN-50-C-7103, " Structural Analysis and Qualification of Mechanical and Electrical Systems";
General Design Criteria No. BFN-50-C-7104, " Design of Supports"; and
' f. . General Design Criteria No. BFN-50-C-7105, " Pipe Rupture, Internal Missiles, Internal Flooding, Seismic Equipment Qualification and Vibration Qualification of Piping".
A TVA BFNP Civil Evaluation Team reviewed G/C's Phase 1 effort to ensure that G/C's draft general criteria accurately captured all source document TVA excluded.the following BFNP. design criteria from.G/C's Phase 1 effort, based on' Civil Engineering Branch (CEB) conclusion that these documents did not contain design criteria applicable to the scope of the general design criteria: Design Criteria No. BFN-50-0702, " Determination of Temperature Zones for the March 22, 1975, Fire at the Browns Ferry Nuclear Plant," Revision No. O, dated May 8, 1975; Design Criteria No. BFN-50-D703, " Evaluating Structural' Steel i Components Subjected to the Environmental Effects of the March 22, 1975, Fire," Revision No. 1, dated August 27, 1975; Design Criteria No. BFN-50-D-704, " Evaluating Reinforced Concrete l Structures Subjected to the Environmental Effects of the March 22, 1975, Fire," Revision No. O, dated May 8,1975; and Design Criteria No. BFN-50-D705, " Evaluating Mechanical Piping, HVAC Ducting, Conduit, and Piping Components Subjected to the 1 Environmental Effects of the March 22, 1975, Fire," Revision i No. 3, dated December 17, 197 Ebasco Services implemented Phase 2 of TVA's program to develop the general civil design criteri Ebasco performed a technical evaluation of the Revision No. O general design criteric; the list of errors, omissions, and ) l deficiencies which G/C documented; a TVA criteria evaluation report; TVA's ) l ) g Engineering) randa (DIMS concerning Assurance the(EA) oversight criteria; review and TVA's team Nuclear concerns;Pla Performance design input mem Based i on Ebasco's technical review and TVA's technical evaluation, TVA issued Revision No. 1 of the BFN general design criteria between March 10 and April 13, 198 TVA's Engineering Assurance (EA) overview of its two-phase program to develop l- the BFNP general design criteria is summarized in TVA Engineering Assurance ) Oversight Review Report EA-0R-002, Browns Ferry Nuclear Plant - Unit 2. Design Baseline and Verification Program, which TVA issued on December 14, 198 i i-3-
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. EA's overview of G/C's Phase 1 effort is sumarized in Section 6.8.5.1 of the report. EA prepared 30 action items to document concerns identified during the audit. On February 2, 1989, TVA indicated that action items C-043, C-046, and C-056 remained open. Action item C-043 indicated that design criterion BFN-50-C-7103 did not specify design requirements for Class II (TVA position retention) piping. Similarly, action item C-046 noted that design criteria BFN-50-C-7104 did not specify design criteria for seismic fire protection pipe supports. Action item C-056 is related to action item C-04 I Section 6.8.5.2 of the EA report sumarizes EA's overview of Ebasco's Phase 2 effor EA prepared 17 action items to document concerns identified during its audit. On February 2, 1989, TVA indicated that action items C-052, C-061, C-063, and C-064 remained open. Action item C-052 noted that Ebasco had identified the basis documents and essential calculations required to support Revision No. 1 of the general design criteria, but had not identified comparable documents for the criteria removed from Revision No. O of the general design criteri EA prepared the remaining action items to address concerns about the Revision No.1 general design criteria which an NRC inspection team identified during the period April 18-22,1988 (Reference 11). These action items remain open, pending NRC review and acceptance of TVA's corrective action Since issuing Revision No. 1 of the general design criteria, TVA has issued the following criteria for safety-related piping and supports: General Design Criteria No. BFN-50-C-7103, " Structural Analysis and Qualification of Mechanical and Electrical Systems (Piping and Instrument Tubing)," Revision No. 2, dated January 20, 1989; General Design Criteria No. BFN-50-C-7107, " Design of Class 1 Seismic Pipe and Tubing Suppurts," Revision No. O, dated January 20, 1989; and Detailed Design Criteria No. BFN-50-C-7303, " Operability Criteria for Pipe and Pipe Supports On Class 1 Seismic Piping," Revision No. 1 dated January 20, 198 .1.1 General Design Criteria No. BFN-50-C-7103 TVA's design criteria document BFN-50-C-7103, Rev. 2, contains criteria for the ; structural analysis and qualification of mechanical and electrical rystem l During this inspection, the staff's review effort focused on the criteria used 2 for the rigorous analysis of piping systems within the scope of TVA's IE Bulletin 79-02/79-14 program. As discussed in the previous section, the design criteria were originally developed as part of a two-phase program to prepare new BFNP general civil design criteria that had been overviewed by TVA's EA. Since l l l-4- ,
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TVA's current revisions of the design criteria had occurred subsequent-to this
~ two-phase effort that had been overviewed by EA, the staff requested that TVA provide the status of EA's review of the new design criteria documents (Unresolved Item EMG-018).
The staff review of BFN-50-C-7103, Rev. 2, identified that TVA was using the same equations to determine. allowable stresses for buried piping that were being used for rigorously analyzed piping. The staff requested that TVA provide a listing of materials used in buried piping to ensure that these equations were appropriate for the materia During the inspection at the Cherry Hill, New Jersey, offices of Stone and Webster Engineering Corp. (SWEC), TVA identified that a Condition Adverse to Quality Report (CAQR) was being prepared on vitrified clay pipe in the raw cooling water system. At the exit meeting, the staff stated that this would be considered an open item until TVA determines the proposed corrective action for the CAQR (Unresolved Item EMG-019). In a followup meeting with the staff (Reference 19), TVA stated that the affected safety-related piping would be reroute Attachment A to BFN-50-C-7103 contains the detailed design criteria for rigorous piping analysis. Section 4.0 of this attachment identified that TVA was using code equations from Section III of the 1971 ASME Boiler and Pressure Vessel Code, including the Summer 1973 Addenda and the other analysis parameters from the power piping code USAS B31.1.0-1967. Since USAS B31.1.0-1967 is the piping code specified in the Browns Ferry FSAR, the staff requested that TVA - provide justification for using the ASME Code equations. TVA agreed to provide the staff an evaluation of the requirements of B31.1.0-1967 and ASME 1971 through the Summer 1973 addenda to ensure the appropriateness of the criteri In addition, TVA agreed to provide a comparison of ASME 1971 through the Sunner 1973 addenda with current code requirements to ensure that TVA is not selecting the least conservative set of code e In addition. TVA agreed to modify the stress equation (9U + 10)quation in Table 8.0-1 to eliminate the 20 percent increase on the expansion stress allowable (Sa). The staff did not consider this factor appropriate for use with the ASME stress equations (Unresolved item EMG-013).
Attachment A to BFN-50-C-7103, Rev. 2, added an exclusion of the piping thennal expansion analysis for piping systems between 32*F and 150*F. The staff questioned TVA's basis for excluding the low temperature thermal analysis, since TVA was performing a reanalysis of all large bore safety-related piping (IE Bulletin 79-02/79-14 scope) and the thermal analysis of the piping was an insignificant effort in the analysis. TVA stated it was concerned that the thermal analysis would identify modifications being required for relatively insignificant thermal movements. The staff stated that TVA had the option of performing a more detailed analysis, including support flexibilities, to demonstrate acceptability of those situations. The staff stated further that TVA should use the more detailed modeling assumptions throughout the analysis if it chose that optio This issue remained open at the exit meeting-5- __-___ _ _ _ - - _ - ._ _ _ _
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. (Unresolved Item EMG-020). In a followup meeting to the inspection (Reference 9), the staff identified that TVA's low-temperature exclusion appeared to conflict with the comitted corrective action in Employee Concerns Report Number 21800 which had been recently submitted to the staff (Reference 12).
Attachment A to BFN-50-C-7103, Rev. 2, contained significant revisions to , Section 6.3 on seismic analysis. Some of these revisions incorporated the l criteria that had been agreed to between TVA and the staff in previous meetings !
(References 2, 3, 4). However, the staff did not agree that Section 6.3(c)2 /
conformed with the comitment in Reference 4 for seismic anchor motion (SAM) l evaluations (Unresolved Item ENG-021). TVA agreed to revise this section to i' comply with the previous comitment. In addition, the staff questioned the basis for TVA's relaxation of the requirements for combining SAM and inertia effects from absolute sum to the square root of the sum of the squares (SRSS). TVA's justification for the combination was a staff position stated in NUREG-1061 J (Reference 13). At the exit meeting, the staff stated it would verify the conditions for the implementation of the NUREG-1061 position and provide TVA a position at a later date (Unresolved Item EMG-002). In a followup meeting (Reference 9), the staff provided TVA a position that the SRSS was acceptable only as specified in NUREG-1061 for independent support motion. In addition, the staff stated that the spatial combination for branch connections in Section 6.3(b)2 was not appropriate, since the branch connection spatial move-ments are not uncorrelated. The staff stated that the use of absolute sum fgr the branch connection spatial movements would be an acceptable combinatio : Section 8.2.3 of Attachment A to P;FN-50-C-7103, Rev. 2, contained a provision-for using preload to reduce nozzle allowable loads. The staff requested that TVA provide an explanation of how this provision was being applied in the piping ; analysis. TVA stated that preload was not being used at Browns Ferry, and comitted to delete the previsions for preload from the design criteria (Unresolved Item EMG-022).
Attachment E to BFN-50-C-7103, Rev. 2, contains detailed design criteria for torus attached piping systems. Since torus attached piping was part of a major program associated with the Mark I containment generic issue, this piping had not been included as part of TVA's IE Bulletin 79-02/79-14 program. Also, since this program had recently been evaluated by the NRC staff (References 14,15) the effort was not reviewed during this inspection. However, the recent revision of the design criteria contained changes to the criteria in Attachment E. There-fore, the staf f identified these enanges as open items for further review (Unresolved Item EMG-023).
During the inspection, TVA informed the staff that the criteria for the control rod drive (CRD) hydraulic system was on hold pending further TVA review. The staff stated that this would remain an open item until TVA fonnally submits the designcriteriatothestaffforreview(UnresolvedItemEMG-027). , l
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- 4.1.2 General Design Criteria Ho. BFN-50-C-7107 TVA's design criteria document BFN-50-C-7107. Rev. O, contains criteria for the design of Class I seismic pipe and tubing supports which previously appeared in. General Design Criteria BFN-50-C-7104, Rev. 2. Since the design criteria for BFNP are similar to the criteria used at Sequoyah, a number of issues that had previously been identified during the Sequoyah review were also identified during this inspectio Section 1.4.2.2 of BFN-50-C-7107 contains load combinations and allowable stress values for BFNP pipe supports. The staff questioned TVA's basis for using the one-third increase in allowable stresses for supplementary steel for the hydro-static test condition, since Paragraph I?1.1.2(a) of USAS B31.1.0-1967 does not allow this increase. TVA agreed to delete this provision from the design criteria (Unresolved Item EMG-003). The staff also questioned the allowable limits used by TVA for standard component supports, including snubbers, for.the emergency and faulted condition. This issue was originally identified at Sequoyah (References 76, 17).. The st:f' had found the limits acceptable for restart, but identified the resolution of the issue as an open, post-restart issue. During the inspectio TVA provided the staff a copy of a letter from Pacific Scientific stating pre-NF snubbers had a one-time load rating of twice the nameplate value. The staff requested further clarification of the letter. Instead TVA agreed to reduce the allowable load limits for mechanical snubbers (Unresolved Item EMG-014).
For other standard component supports, SWEC produced Calculation No.139 to justify the allowable limits. This calculation involved the evaluation of a 4 sample of the catalog standard component supports using the allowable stress limit for linear supports. The calculation identified three cases in which the proposed design criteria resulted in exceeding the linear support allowable limit of .9 yiel In addition, the staff provided TVA several comments rele.ted to the calculation. As of the exit meeting, the staff had not accepted TVA's justification for the allowable stress limit TVA has agreed to demonstrate that all standard component supports will meet the linear support allowable limit of .9 yield (Unresolved Item EMG-005).
Another issue that had been identified during the Sequoyah review was the j allowable loads used for U-bolts. The staff had accepted a set of modified allowable loads for Sequoyah restart (Reference 18). During this inspection, the staff requested that TVA provide the documentation for the BFNP U-bolt allowable loads. During the inspection. TVA used test data to develop a set of U-bolt allowable loads based on the criteria in the 1974 edition of the ASME Code through the Winter 1974 addenda (Reference 8). After discussions between the staff and TVA on the appropriate material reduction factors and temperature adjustments. TVA provided the staff with Bechtel Calculation SC-8901 dated January 31, 1989.- The staff review of this report questioned TVA's use of two separate vertical load ratings for the 3/8-inch diameter U-bolt rod. TVA agreed to revise the calculation to use the lowest value for the 3/8-inch diameter U-bolt rod for the vertical direction (Unresolved Item EMG-015).
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Section 1.4.2.4 of BFN-50-C-7107 allows the SRSS of dynamic loads from the two sides of a piping system anchor. The staff requested that TVA justify l the use of SRSS for the rigid body motion zero period acceleration, (ZPA) component of the loads from both sides of the anchor. TVA agreed to mofify the design criteria to use the absolute sum in combining the axial force components in an in-line anchor (Unresolved Item EMG-004).
Section 1.4.4.4 of BFN-50-C-7107 allows rod supports to be used to resist compressive loads if justified by the pipe support calculation. During the inspection, SWEC provided an example calculation to illustrate how the criteria would be applied. This example involved a short rod secured to an angle section which was not free to rotate (Support No. H-249). The staff stated it was concerned with the bending that could be induced in this configuration by lateral pipe movements. The staff also noted that manufacturers do not < recomend using rod hangers in compression. At the exit meeting, the staff's position was that, in order for TVA to use rod hangers to take compressive loads, the rods should be modified to function as sway struts which are the standardindustrysupportsusedtosustaincompressiveforces(UnresolvedItem EMG-006).
Section 1.4.4.5 of BFN-50-C-7107 allows snug tight U-bolts to be evaluated as two-way restraints if the calculated pipe axial movement is less than 1/16-inch. The staff requested that TVA provide a list of all ungapped U-bolts on large bore piping and rigid frames (Unresolved Item EMG-007) and a list of ungapped U-bolts on large bore pipe with temperatures greater than 200'F (Unresolved Item EMG-008). During the inspection TVA only provided partial lists of these U-bolts since the BFNP hanger tracking system was not complete at the time of the inspectio At the exit meeting, the staff stated it would evaluate these applications further during future inspections of the pipe support analysis effort. The staff's concern with this application is that it is standard practice to gap U-bolts on rigid frames. TVA's application of ungapped U-bolts for cases in which the calculated deflection is less than 1/16-inch introduces an additional complication in the interface between the piping and support analyses. In addition, TVA proposed to delete the low-temperature thermal analysis from the design criteria and therefore, will not even compute the thermal deflection for some case Section 1.4.8 of BFN-50-C-7107 contains criteria for the evaluation of integral welded attachment The criteria allows full credit to be taken in the calculation for shear lugs if the gaps are less than 1/32-inch. Standard industry practice is to assume that half of the lugs are effective in the calculations. Although TVA's gap requirement is more stringent than the standard practice of 1/16-inch, the staff expressed concern that equal load sharing would not be possible for double strut and snubber assemblies if the total support stiffness on both sides of the assembly were not equal. TVA agreed to revise the design criteria to require a check of load path flexibility in order to take credit for additional lugs in the analysis (Unresolved Item EMG-009). The staff also requested TVA's criteria for load sharing assumptions fordoublestrutanddoublesnubberassemblies(UnresolvedItemEMG-010).
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, TVA stated that each double strut will be designed for 75 percent of the total
' load and each double snubber will be designed for 60 percent of the total loa The staff had no concerns with these criteri . !
l 4.1.3 General Design Criteria No. BFN-50-C-7303 TVA had originally developed restart criteria for the BFNP piping and pipe supports in Civil Engineering Branch Instruction CEB-CI 21.97, Rev. O dated December 10, 1987. The staff had provided TVA consnents on these criteria in a meeting on the IE Bulletin 79-02/79-14 program (Reference 1). TVA's new restart criteria document, BFN-50-C-7303, Revision 1, dated January 20, 1989 as reviewed during this inspection. The staff noted that the majority of staff casunents that had been made on old criteria document, CEB-CI 21.97, had not been incorporated in the new criteria document. In addition, the new restart criteria document had added additional items which were not included in the original criteria that had been reviewed by the staff. The following paragraphs list the issues identified during the inspectio Section 3.0 of the critoria document allows the secondary stress to exceed the design allowable stresses on a case-by-case basis. Since this criterion would , apply to nomal operating thermal expansion loads and would violate current ASME ! code criterion,.the staff did not consider this criteria appropriate for the BFNP restart criteria (Unresolved Item EMG-012). TVA agreed to delete this provision from the restart design criteri Section 4.2.1 of the criteria document had added a statement which allowed weld stresses to be increased by an amount equal to the corresponding increase in base metal stresses. The staff requested that TVA provide the basis for this ! revision (EMG-011). TVA's basis was the criterion contained in subsection NF in the 1987 Addendum to the ASME Boiler and Pressure Vessel Code. The staff concluded that this reference provided an adequate basis for use as restart i criteria at BFNP and, therefore, this item was closed during the inspectio Section 4.2.2 of the criteria' document added a new allowable for hydraulic snubbers which corresponded to the safety relief valve trip setting. The staff requested that TVA provide a justification for this allowable value, including the accuracy of the safety relief valve trip setting (Unresolved Item EMG-012). 1 TVA agreed to delete this portion of the restart criteria and use the long-term ! design allowable loads for snubber Section 4.2.6 of the criteria document allowed a case-by-case evaluation of a piping run where a support does not meet the restart allowable stress criteri This evaluation allowed the redistribution of loads to the adjacent supports and, if the piping and adjacent supports still met the restart criteria, the piping would be considered adequate for restart. The staff did not consider this criterion to be appropriate for the BFNP restart. At the exit meeting, TVA disagreed with the staff's position (Unresolved Item ENG-012). However, at a subsequent meeting between TVA and the staff. TVA agreed to delete this provision from the restart criteria (Reference 9).
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Section 4.2.7 of the criteria document added a provision for allowing spring hangers to be evaluated for acceptability in a bottomed-out condition. The staff did not consider this provision to be acceptable for BFNP restart. At the exit meeting TVA disagreed with the staff's position (Unresolved Item EMG-012). However, at a subsequent meeting between TVA and the staff. TVA agreed to delete this provision from the restart criteria (Reference 9).
Section 4.2.8.1 of the criteria document contained a provision for using local- ' ized support flexibility in the analysis to reduce themal loads predicted from the analysis. The staff stated that the use of support flexibility was acceptable provided it was used consistently throughout the entire analysis and not just for isolated themal cases. TVA agreed to delete this provision from the criteria (Unresolved Item EMG-012).
Section 4.2.9 of the criteria document allowed deferring modifications for potential thermal interferences if visual monitoring indicates no thermal binding of the restraint has occurred. The staff stated that TVA should also consider other predicted movements, such as seismic, and should reconcile the l measured movements with the piping analysis before using this criterion. TVA agreed to delete this provision from the restart criteria (Unresolved Item EMG-012). , I 4.2 Piping Analysis 4.2.1 Governing Procedures The following project piping procedures were reviewed for implementation of piping design criteria; no open issues were identified through this review: SWEC Walkdown Data Package WDP SWEC-003, Revision 2 " Piping Walkdown Procedure" - Specifies procedure, including attributes and tolerances, for IE Bulletin 79-14 walkdowns; SWEC Project Procedure BFPP 8-0, Revision 0 " Supplemental Design Guidance for the Hanger and Reconciliation Program" - Provides I design guidance which supplements TVA General Design Criteria No. BFN-50-C-7103 and SWEC project procedures; SWEC Project Procedure BFPP 8-8, Revision 0 " Technical Procedure for 79-14/02 Piping and Pipe Support Qualification, Task S012" - Outlines SWEC project activities and subordinate procedures; and SWEC Project Procedures BFPP 8-8.1 through BFPP 8-8.10 (revisions vary) - Procedures subordinate to BFPP 8-8 which describe specific SWEC project activitie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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4.2.2 Calculations Piping calculation number NI-274-1R, Revision 3, was reviewed for implementation of design criteria. Review of problem package attributes which affect extensive infomation such as piping layout geometry was limited to information associated with a specific portion of the problem piping. For these attributes, the piping routed between the structural anchor labeled R66 and the nozzle at residual heat removal (RHR) Heat Exchanger 2C was reviewe The compilation of as-built data in the problem walkdown package was checked for compliance with the current walkdown procedure. At the time the walkdown was performed, the applicable walkdown procedure was BFEP PI 87-51, Revision That procedure has since been superseded. For this review the current walkdown procedure, WDP SWEC 003 Revision 2, was referenced. No open issues regarding t walkdowns were identified during the inspectio Calculation package content and implementation of specific design criteria were checked for analysis problem NI-274-1R. Specific checks included the following: Piping isometric worksketch data including component identification and geometric data per the walkdown isometric as-built data; Listed system operating node conditions and valve data per W Prerequisite Data Package; Seismic load (spectra and ZPA) definition per the criteria sumarized in Reference 4; Piping component stress intensification factors per CEB Report 84-20, dated September 6, 1964 " Stress Intensifi-cation Factors for Browns F P ry, Sequoyah, Watts Bar, and Bellefonte"; and Computer program mathematical model input data, including valve and seismic load specification, from the TPIPE program input listing per the Prerequisite Data Packag Two open items were identified as the result of the piping calculation review and discussion with project personnel. One item involves the use of design information received in an uncontrolled telecopy (Unresolved Item EMG-026).
The second item involves the unjustified reduction of pipe thermal (stress) range (Unresolved Item ENG-020). This specific istue is part of the general concern on thermal expansion discussed in Section 4,1.1 of this repor _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _
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-. . 4.3 Pipe Support Calculations 4.3.1 TVA Design and Operability Criteria and TVA/SWEC Implementing -
Procedures for Pipe Support Calculations SWEC is preparing pipe support calculations for the safety-related pipe supports within the BFN 79-14 Phase II program in accordance with the design and operability criteria detailed in the follcwing TVA specifications: General Design Criteria No. BFN-50-C-7107, " Design of Class I Seismic Pipe and Tubing Supports," Revision No. O, dated January 20, 1989; and Detailed Design Criteria No. BFN-50-C-7303, " Operability Criteria for Pipe and Pipe Supports On Class I Seismic Piping," Revision No. 1, dated January 20, 1989 (issue date August 25,1988).
. During the two-week period of the inspection beginning January 23, 1989, the , staff identified several unresolved items, discussed in Section 4.1 of this report, concerning TVA's design and operability criteria for piping and supports. TVA will re-issue these specifications to incorporate agreed-upon modifications and deletion On January 23, 1989 SWEC provided the TVA design and operability criteria and TVA and SWEC implementing procedures which SWEC uses to walkdown BFNP piping and supports, to prepare pipe support calculations, and to document structural attachment load SWEC uses the following procedures to prepare "as-built" piping drawings: SWEC Project Procedure BFPP 8-8.1 " Technical Procedure for 79-14 Walkdown/ Task S012," Revision No. O, dated December 21, 1987; SWEC Walkdown Data Package (WDP) No. SWEC-003, " Piping Walkdown Procedure," Revision No. 2, dated August 10, 1988; and TVA Project Instruction 8FEP PI 87-51, " Piping Inspection Procedure," Revision No. O, dated October 16, 198 SWEC-003, Section 7.2.12, Support Data, requires that the pipe support number and location be documented on the walkdown drhwing. For the sample of 14 SWEC pipe' support calculations reviewed, it was confirmed that the pipe support locations shown on the piping stress isometric drawings corresponded to the pipe support locations shown on the piping walkdown drawing SWEC uses the following procedures to prepare "as-built" pipe support detail drawings: SWEC Project Procedure BFPP 8-8.1, " Technical Procedure for 79-14 Walkdown/ Task S012," Revision No. O, dated December 21, 1987;
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- . . SWEC Walkdown Data Package (WDP) No. SWEC-005, " Pipe Support Walkdown Procedure," Revision No. 4, dated September 13, 1988; and TVA Project Instruction BFEP PI 87-49, " Pipe Support Verification Program," Revision No. 2, dated December 15, 198 SWEC-005 provides detailed instructions for the preparation of "asebuilt" pipe support detail drawings. SWEC revises existing "as-designed" pipe support detail drawings or generates new "as-built" pipe support detail drawing SWEC-005, Section 6.3, Items Inspected (As Applicable), lists the inspection attributes to be documented on the "as-built" pipe support detail drawing, including pipe support configuration, member sizes, lengths and orientations, gaps, clearances, welds, vendor-supplied components, concrete attachments, abnormalities, and information required for Out of Scope attachments or miscel-laneous steel frames. For the sample of 14 SWEC pipe support cciculations reviewed, it was confirmed that the pipe support orientations and types detailed on the pipe stress isometric drawings corresponded to the pipe support orien-tations and types documented in SWEC's "as-built" pipe support detail drawing SWEC uses the following procedures to prepare pipe support calculations: General Design Criteria No. BFN-50-C-7107, " Design of Class I Seismic Pipe and Tubing Supports," Revision No. O, dated January 20, 1989; Detailed Design Criteria No. BFN-50-C-7303, " Operability Criteria for Pipe and Pipe Supports On Class I Seismic Piping," Revision No. 1, dated January 20, 1989 (issue date August 25,1988); SWEC Project Procedure BFPP 8-0, " Supplemental Design Guidance For The Hanger and Analysis Reconciliation Program," Revision No. O, dated March 15, 198 SWEC Project Procedure BFPP 8-0.1, " Gang Hanger and Support Interface Procedure," Revision No. O, dated May 16, 1988; SWEC Project Procedure BFPP 8-8, " Technical Procedure for 79-14/02 Piping and Pipe Support Qualification Task S012,"
Revision No. O, dated December 9, 1987; I SWEC Project Procedure BFPP 8-8.3, " Technical Evaluation Direction For 79-14/02 Program Phase II Piping and Pipe Support As-Built Verification," Revision No. O, dated February 22, 1988; i SWEC Project Procedure BFPP 8-8.5, " Piping Run and Support l Configuration Control for Large Bore Piping and Supports Task S012.1," Revision No. O, dated March 4,1988;
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- SWEC Project Procedure BFPP 5-1, " Preparation and Control of Calculations," Revision No. 2, dated July 7, 1988; SWEC Project Procedure BFPP 5-4, " Review of Change Documents,"
Revision No. O, dated June 30, 1987; TVA Lead Civil Engineer Instruction BFEP-DI-C1, " Pipe Support Design Handbook " Revision No. O, dated April 7, 1988; - TVA Civil Design Standard DS-C1.7.1, " General Anchorage to Concrete," Revision No. 4. dated July 28, 1987;
. TVA Quality Information Request / Release (QIR) CEB-87-099
"Unistrut Clamp Allowables," Revision No. 3, datsd October 11, 1988; and
< TVA Report No. CEB-85-06, " Browns Ferry Nuclear Plant -
Evaluation Of Standard U-Bolt Pipe Clamps", Revision No. O, dated May 10, 198 SWEC BFPP 8-0 provides detailed design guidance and analytical criteria for the analysis of pipe supports, and addresses thermal gap requirements for rigid frame supports, the design of axial restraints, base plate qualification, evaluation of Unistrut members, welding, integral weld attachments to piping, and evaluation of local stresses in pipe supports. It was confimed that SWEC generally implemented the requirements of BFPP 8-0 for the sample of 14 SWEC pipe support calculations reviewe As noted elsewhere in this report, SWEC's pipe support calculations do not include an evaluation of building steel, embedded plates, supplementary steel, or some pipe support frames for the transmitted pipe support reactions. SWEC transmits the pipe support " footprint" loads to TVA for evaluatio SWEC uses the following procedures to prepare structural attachment loads (SALs) for submittal to TVA: SWEC Project Procedure BFPP 8-8, " Technical Procedure For 79-14/02 Piping And Pipe Support Qualification. Task S012," Revision No. O, dated D?cember 9, 1987; and SWEC Project Procedure BFPP 5-9, " Structural Attachment Load Tracking," Revision No. O, dated December 4, 198 During the period of the inspection, it could not be confirmed that TVA will review the pipe support calculation SALs before restart. The SAL evaluations will be the subject of a future civil / structural inspection.
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4.3.2 SWEC's 79-14 Phase II Pipe Support Calculations Prior to BFNP restart SWEC will evaluate 20 percent of the safety-related piping and supports in TVA's BFN 79-14 program under SWEC Task S012.2, and an additional 15 percent under SWEC Task S012.3A. SWEC will screen the remaining 65 percent of safety-related piping and supports for the generic attributes identified in rigorous analysis performed under SWEC Task S01 On January 23, 1989, SWEC had formally issced 25 of 1,204 pipe support calcu-lations within the scope of SWEC Tasks 5012.2 and S012.3A. On January 25, SWEC withdrew 11 calculations which used an allowable uplift criterion (5/32 - inch maximum) for unidirectional supports which the staff had previously fcund unacceptable (Reference 8).
The remaining 14 SWEC pipe support calculations were reviewed for confomance to TVA's governing design and operational criteria, and SWEC's implementing procedure Calculation N (Sys.) Rev. N Date CD-Q2001-882170 MS) 0 January 18, 1989 CD-Q2001-882171 MS) 1 January 18, 1989 CD-Q2071-882408 RCIC) 0 January 18, 1989 CD-Q2071-882426 RCIC) 0 January 18, 1989 CD-Q2071-882428 (RCIC) 0 January 18, 1989 CD-Q2071-882436 IRCIC) 0 January 19, 1989 CD-Q2071-882437 [RCIC) 0 January 18, 1989 CD-Q2077-882230 (RW) 0 January 19, 1989 CD-Q2077-882231 (RW) 0 January 18, 1989 CD-Q2077-882232 (RW) 0 January 13, 1989 CD-Q2077-882233 (RW) 0 January 19, 1989 CD-Q2077-882234 (RW) 0 January 18, 1989 CD-Q2077-882242 (RW) 0 January 19, 1989 CD-Q2077-882245 (RW) 1 January 18, 1989 The following unresolved items were identified curing the course of this revie SWEC is preparing field sketches of some vendor-supplied pipe support configurations instead of producing "as-builts" with the original vendor pipe support detail drawings. However, the SWEC field sketches lack the original bills of materials which enable confirmation of the component load capacities. SWEC is therefore assigning load ratings of similar Grinnell components to vendor-supplied components which lack a bill of materials. However, the vendor components which lack a documented bill of materials do not meet the material traceability requirements of USAS B31. " Power Piping", the piping code of record for BFNP (Unresolved Item EMG-001).
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. SWEC computed swing angles for a sway brace due to combined offsets an'd thermal movements which exceeded the maximum allowable angular tolerance of +/-6' degrees. SWEC evaluated the field measurements of the installed ]
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sway brace and concluded that the sway brace would not bind under the ) computed thermal movements. However, during the inspection it was con-cluded that the sway brace would bind under the computed thermal movements (UnresolvedItemENG-017).
With these exceptions. SWEC's pipe support calculations appeared programma-tically adequate. and generally addressed TVA's design and operating criteria and SWEC's implementing procedure During the two-week period of the inspection beginning January 23, 1989, the staff identified several unresolved items related to TVA's design and oper-ability criteria for piping and supports. TVA has agreed to re-issue these documents to address the staff's concerns. To confirm conformance to the 4 revised criteria, SWEC should review all pipe support calculations prepared 4 prior to TVA's re-issuance of these criteria . SWEC's pipe support calculations do not include an evaluation of building steel, embedded plates, supplementary steel, or some pipe support frames for the transmitted pipe support reactions. Each SWEC pipe support package documents the pipe support " footprint" loads which SWEC transmits to TVA for evaluatio However, during the period of the inspection, it could not be confirme that TVA has committed to an evaluation of these loads prior to restar .3.3 SWEC's 79-14 Phase II Generic Evaluations of Piping and Supports Prior to BFNP restart SWEC will screen 65 percent of the safety-related piping and supports in TVA's BFN 79-14 program under SWEC Task S012.4A for the generic attributes identified in rigorous analysis performed under SWEC Task S01 On January 23, 1989, SWEC had formally issued horizontal slice evaluation packages for 7 of 95 stress problems within the scope of SWEC Task S012.4 SWEC Project Procedure Nc. BFPP 8-8.10. " Procedure for Prerestart Engineering Evaluation of Generic Implications on the Seismic Class I Piping Systems for 79-14/02 Program Phase II Large Bore Piping and Pipe Support Verification", Revision 2, dated December 14, 1988, governs SWEC's evaluation of safety-related piping and supports within the scope of the horizontal slice progra SWEC is evaluating each pipe stress problem within the scope of the horizontal slice program for the following attributes: Piping: .. Undersized supports near heavy or eccentric mass
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, . Undersized supports adjacent to excessive lateral. span 3.- Undersized axial supports with long adjacent span (s) or heav mass subjected to zero-period acceleration (ZPA) effect 4. . Interface anchor between seismic Class I and non-safety piping .i
i Pipe Supports: ' Support with skewed or asymmetrical structural attachment that can cause out-of-plan moment'in the unreinforced direction
' Support with unbraced cantilever structural attachnent Undersized bolted-strap two-way support for large. bore piping Piping or supports which fail TVA's design criteria but pass operability criteria will be modified post-restart. Piping er supports which also fail operability criteria will be modified prior to restar '
The review of'a portion of the RHR piping system which SWEC screened in
. horizontal slice package No. N1-274-18R identified the following unresolved item The package references a SWEC walkdown drawing which identifies an interference between a 4-inch diameter branch line and a )
l 2-inch diameter strut.. However, this interference was not noted in the horizontal slice package for review and resolution (UnresolvedItemEMG-024, Item 1).
] The' package identified two pipe spans which failed stipulated seismic overspan and ZPA load criteria. However, SWEC did not evaluate the piping-and associated pipe supports in accordance j with Project Procedure 8-8.10 (Unresolved Item EMG-024. Item 2).
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Based on this limited review, it was concluded that SWEC had not prepared the horizontal ~ slice package for stess ' problem No. N1-274-18R in complete accordance-with the requirements of SWEC Project Procedure No. BFPP 8-8.1 .3.4 BFNP Pipe Supports Selected for Review During Staff Walkdowns During walkdowns of BFhP piping and supports conducted during the latter part of 1988, the following supports were selected for additional revie Support N System R-26 High-pressurecoolantinjection(HPCI) H-92, H-95 Residual heat resioval (RHR) RLK-1 Rawcoolingwater(RCW) R-222 Essential Cooling Water (EECW) R-58 RHR R-80 RCW I
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Supports R-26, H-92, and H-95 are installed in piping systems which SWEC will rigorously analyze prior to restart. Support R-58 is installed in torus-attached piping, which is not a part of SWEC's 79-14 Phase II scope of work. Supports RLK-1, R-58,-and R-80 are installed in piping systems which SWEC will evaluate generically prior to restart as part of SWEC's horizontal slice scope of wor Support R-26 was selected for review to confirm that SWEC had evaluated a flame-
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cut slotted hole in the pipe support East baseplate for possible repair. Preli-
. minary SWEC calculation No. CD-02073-882189, Revision No. O, dated August 31, 1988 -
specifies that a washer be added to the baseplate, but does not indicate if the washer thould be welded to the baseplate (Unresolved Item EMG-024).
l Supports H-92 and H-95 were selected for review because the spring hangers for these supports appeared to be bottomed out. Preliminary SWEC calculation No. CD-Q2074-882466 for spring hanger H-92 confirms the adequacy of the installed spring hanger settings. Preliminary SWEC calculation No. 17313.36-GENX-NZ(C)-046 for pipe support H-95, specifies that the spring hanger settings be readjuste These preliminary calculations were found acceptabl Support R-58 was selected for review because the pipe support snubber rear bracket is welded directly to the pipe. The review of SWEC calculation No. CDQ2074883547 Revision No. 5, dated July 19, 1988, confirmed that the calculation addresses the integral welded attachmen Unless SWEC's horizontal slice packages select supports RLK-1, R-58 and R-80 for detailed evaluation, SWEC will not prepare the calculations for these pipe supports until post-restart. Evaluation of SWEC's calculations to qualify these supports may be conducted at a later dat ) 4.4 SWEC's 79-14 Ph~ase II Engineering Assurance Overview SWEC's EA group is auditing SWEC's BFNP technical effort in Decatur, Alabama, and Cherry Hill, New Jersey, in accordance with SWEC Engineering Assurance Procedure EAP 18.1, " Audits," Revision No. 5, dated September 15, 198 By February 2, 1989, SWEC EA had performed nine audits, which SWEC documented in the following reports: SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project - Audit No. 1, Mobilization Phase, July 27 - August 7, 1987," dated August 20, 1987; SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project - Audit No. 2. August 25-31, 1987," dated September 29, 1937,
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. . 'SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project -
Audit No. 3. 0ctober 26, 1987 through November 11, 1987 " dated Dece6er 17, 1987; SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project - Audit No. 4, December 14-23, 1987." dated January 28, 1988; SWEC Engineering Assurance Audit Report, "8rowns Ferry Nuclear Project - Audit No. 5. January 25, 1988 through February 5, 1988," dated February 25, 1988;- SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project - Audit No. 6, April 4-22, 1988," dated May 10, 1988; SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project - Audit No. 7. May 16-31, 1988," dated June 24, 1988; - SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear. Project - 1 Audit,No. 8, June 27 - July 15, 1988," dated August 25, 1988; SWEC Engineering Assurance Audit Report, " Browns Ferry Nuclear Project - Audit No. 9. October 17-28, 1988," dated December 1, 198 ! In order to sample EA's closure of the action items which EA documented in the audit reports, the staff reviewed EA's closure of portions of audit observation 17313-015 which EA prepared during the period May 16-31, 1988
' (Audit No. 7).
Items 2a, 2c, and 2e of the audit observation documented EA's concern that SWEC calculation No. CD-Q2070-88985 did not address the effects of the following differential movements on pipe runs between reactor buildings or' major components within each building: Relative vertical thermal displacements between reactor buildings;
' Relative foundation settlement between reactor buildings; l s
! Relative seismic support displacements between reactor buildings; and l ' Relative seismic support displacements between the penetration attached to the steel containment and the supports attached to the drywell stee j i EA concluded that the reactor building mats, while not monolithic, were founded on rock, and that relative foundation settlement between reactor buildings was not a design concern. EA also indicated that calculation No. CD-Q-2070-886546 had been prepared to address the remaining concern On September 20, 1988 SWEC project issued project memorandum PM-070, which requires that:
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When piping passes between two buildings, the effect of relative movement between the two buildings on piping flexibility shall be f i considered. Reactor buildings for Unit 1. Unit 2, and Unit 3 are j to be considered as three separate and independent building j SWEC EA indicated that relative seismic displacement data for use by SWEC's piping analysts was documented in Bechtel Task Report on TSD-5052.2, " Generation 1 of Acceleration Response Spectra for Reactor Building Drywell and Internals of Browns Ferry Nuclear Plant," dated November 21, 198 It was concluded that EA had closed out Items 2a, 2c, and 2e of audit observa-tion 17313-015 in a satisfactory manne J 5. OPEN ITEMS FROM REVIEW l Specific items identified and discussed during this inspection are charac- l terized as unresolved items. TVA actions related to the individual unresolved items are discussed in the report. For most of the items, TVA's proposed corrective actions were reviewed and agreed to by the staff and the item remains open pending review of the completed action. The status of the review of all unresolved items identified during th inspection is sumarized in Appendix . REVIEW 0F PREVIOUS INSPECTION ITEMS ! During the inspection. SWEC piping analysis studies conducted to resolve open item CSG-23 from Inspection Report 50-260/88-38 were reviewed. The details of the review and closeout of this item will be documented in a followup civil and structural inspection repor . MEETING SUMitARIES AND REFERENCES A summary of attendees at the entrance and exit meetings is provided in Appendix 8. A list of references is provided in Appendix l l l f
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APPENDIX A UNRESOLVED ITEMS
: 10 pen)UnresolvedItemEMG-001,VendorComponentMaterialTraceability .Some SWEC pipe support calculations contain pipe support field sketches which SWEC prepared, instead of revisions to the original vendor pipe support detail . drawings. One example is Calculation No. CD-Q2071-882408, Revision No. O, dated January 18, 1989, for pipe support H23 in the reactor core isolation cooling (RCIC) system. The SWEC field sketches lack the bills of material'
detailed on the original' pipe support detail drawings. The bills of material enable verification of the load capacity of each vendor-supplied component by reference to the vendor's load capacity catalog data. SWEC is instead speci-fying the load capacities of similar Grinnell components for each_ vendor-supplied component portrayed on the SWEC field sketches. Pipe support calculations without the original bills of material do not satisfy the material traceability requirements of the piping code of record for BFNP, USAS B31.1.0 --1967, " Power Piping". Section 121.1.2, Materials and Stresses, requires in part that materials used for pipe support elements meet the standard material test and physical properties tabulated in the cod TVA's plan to address the lack of material traceability for_ some vender-supplied pipe support components installed at BFNP was considered acceptable. TVA will identify the vendors of standard pipe support components installed at BFNP.'and compare vendor catalog load ratings and dimensions to confim the acceptability of_ SWEC's assumption of_ Grinnell load ratings for standard components without a bill of material designation. Unresolved Item EMG-001_ remains open pending review of TVA's submitta (0 pen) Unresolveo Item EMG-002, SRSS of Inertia and SAM Loads Section 6.3(d) of TVA's design criteria document BFN-50-C-7103, Revision 2, dated January 20, 1989 had changed the criteria for the combination of seismic inertia loads and seismic anchor movement loads from absolute sum to SRS TVA's justification for this change was a staff position contained in Section 2.4 of NUREG-1061 which allowed the SRSS of seismic inertia loads and seismic anchor movements for piping system response spectra analysis using the inde-pendent support motion method as specified in NUREG-1061. The staff accepted TVA's implementation of this procedure for the independent support motion method of analysis. However, the staff did not consider the method used for thespatialcombinationforbranchconnectionsspecifiedinSection6.3(b)2of , TVA's design criteria appropriate. This item remains open pending review of
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TVA's revision of the design criteria.
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. . (Ocen) Unresolved Item EMG-003, 1.33 Factor for Hydro Test Section 1.4.2.2 of TVA's design criteria document BFN-50-C-7107 Revision, dated January 20, 1989, allowed a one-third increase in the normal American Institute of Steel Construction (AISC) allowable stresses for pipe supports for the hydrostatic test condition. The criteria was not in conformance with the criteria contained in paragraph 121.1.2(a) of ANSI B31.1.0-1967 which does not allow modification of the allowable stress for supplementary steel design to AISC specifications for hydrostatic conditions. USAS B31.1.0-1967 is the piping code of record for BFNP. TVA agreed to delete the 1/3 increase for hydrostatic test conditions from the pipe support design criteria. This item remains open, pending review of TVA's revision of the design criteri (0 pen) Unresolved Item EMG-004, SRSS of IPA for Interface Anchors Section 1.4.2.4 of TVA's design criteria document BFN-50-C-7107 Revision, dated January 20, 1989, allowed the SRSS of dynamic loads from two sides of a piping system anchor. In order for the SRSS of dynamic loads to be acceptable, the loads should have sufficient randomness in time phasing to ensure that the occurrence of the maximum value (absolute sum) is unlikely. A discussion of SRSS methodology is contained in NUREG-0484, Revision 1. The staff requested that TVA justify the use of SRSS methodology for the rigid axial response of a piping system with an in-line anchor. A SWEC evaluation of a sample piping problem showed that the SRSS value could be exceeded for rigid axial load Therefore. TVA agreed to modify this section of the design criteria document to combine the rigid piping axial loads on the anchor by the ebsolute sum metho This item remains open pending review of TVA's revision of the design criteri (0 pen) Unresolved Item EMG-005, Emergency Condition Allowables Section 1.4.2.2 of TVA's design criteria document BFN-50-C-7107, Revision, dated January 20, 1989 contained an allowable limit of twice the manufacturer's standard component support allowable value for the emergency and faulted load combination The manufacturer's allowable loads are based on criteria contained in MSS-SP-58 which is referenced by the BFNP piping code of record, USAS B31.1.0-1967, and q are specified for normal operating load i l
The staff agreed that higher allowable limits for the low-probability loads I specified in the emergency and faulted load combinations are appropriate and in accord with the BFNP FSAR criteria, as specified in Section C.2.6. However, the staff requested that TVA provide either explicit documentation from the manufacturers or explicit calculations to justify the allowable limits used in the pipe support design criteria document. The staff agreed that the same allow-able stress limits specified for structural steel (i.e., .9 Sy) are appropriate for this evaluation. Stone and Webster Calculation No. 139, reviewed during the inspection, identified three items that exceeded the structural criteria. In addition, several questions were identified with the selection of material yield values, specific allowable stresses used for bolts, and the calculation methods used to determine stresses. TVA agreed to provide additional calculations for i
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. all components used at BFNP which address the staff concerns. This item remains open, pending review of TVA's completed calculation (0 pen) Unresolved Item EMG-006, Rod Hangers in Compression Section 1.4.4.4 of TVA's design criteria document BFN-50-C-7107, Revision 0, dated January 20, 1989, allowed rod hangers to be used to resist compressive loads if justified by the pipe support calculation. The use of rod hangers to support compressive loads is not recommended by the pipe support manufacturer The staff advised TVA that the rod hangers should be modified to function as sway struts in order to use the rod hanger to resist compressive forces. This item remains open, pending review of TVA's implementation of this resolutio (0 pen) Unresolved Item EMG-007, U-bolts on Rigid Supports Section 1.4.4.5 of TVA's design criteria document BFN-50-C-7107. Revision 0, dated January 20, 1989 allowed snug tight U-bolts to be evaluated as two-way restraints if the calculated pipe axial movement is less than 1/16-inc Paragraph 121.1 of USAS B31.1.0-1967 requires supporting elements to be capable of carrying the sum of all concurrently acting loads. A snug tight U-bolt will be subjected to axial forces that are not accounted for in the analysi Standard industry practice, as stated in Welding Research Council Bulletin 300, generally considers deflections of 1/16-inch or less not significant. The staff agrees with the assessment that movements less than 1/16-inch in the axial direction will not have a significant effect on the U-bolt capacity. However, TVA's use of this criteria, in lieu of providing a standard gap, requires an additional level of control and verification during the piping analysis effor The staff considers this an open item to be reviewed during TVA's implementation of the piping analysis effor (0 pen) Unresolved Item EMG-008, U-bolts on piping greater than 200'F Section 1.4.4.5 of TVA's design criteria document BFN-50-C-7107, Revision 0, dated January 20, 1989, allowed ungapped U-bolts on large-diameter piping systems with operating temperatures greater than 200'F. Paragraph 120. requires the design of anchors and guides to take into account the forces and moments at three elements caused by internal pressure and thermal expansio Ungapped U-bolts on high-temperature piping systems can be subjected to thermal loads due to differential expansion of the pipe and the U-bolt. Although there are no specific restrictions preventing this application, the application requires additional interface to ensure an adequate design. Therefore, the staff considers this an open item to be reviewed during TVA's implementation of the piping analysis effor (0 pen) Unresolved Item EMG-009, Lug stress evaluation Section 1.4.8 o' TVA's design criteria document BFN-50-C-7107, Revision 0, dated January 2d,1989, allows credit to be taken for more than half of the A-3 __-__-_______--_-_ --___ _ - . -
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- . 1 axial shear lugs in the piping analysis if the gap is less than 1/32-inc Standard industry practice for the analysis is to assume that half of the shear lugs will be effective in the analysis with a standard gap of 1/16-inc Even if the shear lugs are shinned to a zero or near-zero gap condition, equal load distribution cannot be achieved unless the supporting structure provides equal bearing stiffness. TVA has agreed to modify the design criteria to provide a check on the supporting structure stiffness. This item remains open, pending review of TVA's revision of the design criteria documen (0 pen) Unresolved Item EMG-010. Strut / Snubber Load Sharing Criteria As an adjunct to the review of item EMG-009, the staff requested TVA's criteria for determining design loads for double strut and snubber supports on horizontal pipe runs.. TVA stated that each double snubber would be designed for 60 percent of the total load, and each double strut would be designed for 75 percent of the load. TVA committed to revise design criteria document BFN-50-7107 to add !
the criteria. This item remains open pending review of TVA's revision of the I design criteria dccumen ]
(0 pen) Unresolved Item EMG-012. Restart Criteria The staff provided TVA the following comments on the acceptability cf the BFNP restart criteria, BFN-50-C-7303, Revision 1, dated January 20, 1989: The augumented fatigue evaluation in Section 3.0 was not acceptable; The criteria for hydraulic snubbers in Section 4.2.2 required justification; The criteria for load sharing in Section 4.2.6 was not acceptable; The criteria for spring hangers in a bottomed-out condition in Section 4.2.7 was not acceptable; The criteria for localized support flexibility in Section 4.2. was not acceptable; and- The criteria for themal monitoring in Section 4.2.9 was not acceptabl TVA agreed to revise the restart criteria to reflect the staff's connent This item remains open, pending review of TVA's revision of the restart criteria documen (0 pen) Unresolved Item EMG-013 Code Consistency Section 4.0 of Attachment A to TVA's design criteria document BFN-50-C-7103 references the 1971 edition of Section III to the ASME Code through the Sunner 1973 Addenda for piping analysis code equations. The BFNP design code referenced in the FSAR is USAS B31.1.0-1967. The staff requested that TVA A-4
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provide an ASME NA-1140 evaluation of the use of ASME Code equations combined with USAS B31.1.0-1967 criteria to justify the acceptability of the criteri In addition, the staff requested an evaluation of the TVA's proposed criteria compared with changes made in the 1983 ASME Coe :riteria. This item remains open pending review of the TVA evaluation TVA also used the ASME Code equations with an allowable stress value defined . in Appendix C of the BFNP FSAR of 1.2 (Sa + Sh). Although the allowable stress ! is defined in the BFNP FSAR, the allowable stress value is not defined with the use in ASME Code Equations. TVA tgreed to revise this limit to Sa + 1.2 Sh for use with the ASME Code equations. This item remains open, pending TVA's revision of the design' criteria documen (0 pen) Unresolved Item EMG-014. Pacific Scientific Snubber Load Ratings ! Section 1.4.2.2 of TVA's design criteria document BFN-50-C-7107<contains an allowable value of twice the basic vendor rating for mechanical snubbers in the emergency and faulted load combinations. TVA provided documentation from Pacific Scientific to support these values. The staff requested additional infomation on the basis of Pacific Scientific's allowables. Instead, TVA agreed to revise the design to use the lesser of 1.33 times the basic vendor rating, or the Level C limit for pre-NF snubbers and the Level C limit for post-NF snubbers. The staff accepted these allowables. This item remains open, pending review of the revised criteri (0 pen) Unresolved Item EMG-015 U-bolt Lateral Capacity TVA developed a set of U-bolt allowable loads based on ASME Code Subsection NF criteria. The U-bolt allowables are specified in Bechtel Calculation No. SC-8901 dated January 31, 1989. TVA committed to use these values with a modification to use the lowest vertical value from the Table 1 ratings for the 3/8 inch diameter rod size. The staff accepted this resolution. This item remains open, pending review of TVA's revision of the criteri (0 pen) Unresolved Item EMG-016, Horizontal Slice Package No. N1-274-18R SWEC Project Procedure No. BFPP 8-8.10, " Procedure for Pre-restart Engineering
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Evaluation of Generic Implications on the Seismic Class I Piping Systems for 79-14/02 Program Phase II Large Bore Piping and Pipe Support Verification " Revision 2, dated December.14, 1988, governs SWEC's evaluation of horizontal slice packages. The review included a portion of the RER piping system which is evaluated in horizontal slice package No. N1-274-18R, Revision No. O, dated January 12, 1989. The package references BFNP piping drawing 47W452-298
"N1-274-18R Isometric, Static Thermal. Dynamic Analysis of RHR System,"
Revision No. O, which SWEC prepared "as-built" on October 31, 1988.
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, .< . . The following unresolved items were identified: The referenced SWEC walkdown drawing identifies an interference between a 4-inch diameter branch line which is a part of the RHR system and a 2-inch diameter strut. However, this interference was not noted in Section 5 of the Pre-start Piping Checklist of the package for review and resolution. The relative thermal and seismic displacements between the pipe and the strut might damage the pipe or the strut. The load capacity of tne strut would also be degraded if the pipe imposed a lateral force on the stru The package identified two pipe spans which failed stipulated seismic overspan and ZPA load criteria. However, SWEC did not evaluate the piping and associated pipe supports in accordance with Pr9 ject Procedure 8-8.1 TVA indicated that it will conduct a separate program to evaluaite interferences at BFN Item (1) of. Unresolved Item ENG-016 will be closed when TVA documents the-interference program's use of SWEC's Phase II walkdown drawings to identify interference TVA should revise the horizontal slice package to evaluate the pipe spans and associated supports in accordance with the requirements of the project procedure. Item (2) of Unresolved Item EMG-016 remains open, pending review of the revised horizontai slice packag (0 pen) Unresolved Item EMG-017, Sway Brace Angular Tolerance SWEC Calculation No. CD-Q2071-882436, Revision No. O, dated January 19, 1989, for pipe support R-015 in the RCIC system analyzes a sway brace-frame pipe support configuration. The SWEC field sketch of the sway brace identifies the component as Bergen Patterson part No. RSSA-3. Section 1.4.4.8, Angularity, of General Design Criteria BFN-50-C-7104, " Design of Supports," Revision No. 2, dated August 25, 1988, permits a maximum swing angle which is the lesser of +/-6 degrees and the vendor-specified angular tolerance. The calculation computes swing angles about the local y- and z-axes due to the installed offsets and thermal movements which exceed 6 degrees. The calculation does not document Bergen Patterson's angular tolerance for the sway brace. Based on an evaluation of the field measured offsets of the sway brace, which Attachment No. 3 of the calculation documents, the calculation concludes that the sway brace will not j bind under the imposed thermal movements. During the inspection it was concluded, j however, that the field measurements were incorrectly interpreted and that the sway brace will bind under the imposed thermal movement TVA concurs that the swing angle check documented in the calculation is inadequate, and SWEC will revise the calculation. SWEC's interim calculation indicates that a maximum of 0.02 inches of interference could occur. TVA therefore concludes that the sway brace is acceptable for interim operability and will repair the sway brace post-restart. Unresolved Item EMG-017 remains ,
open, pending review of TVA's revised calculation, l
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, _ - . * ... . . (0 pen) Unresolved Item EMG-018 EA Review TVA's design criteria documents BFN-50-C-7103, Revision 2, and BFN-50-C-7107, Revision 0, were issued on January 20, 1989. TVA's EA had reviewed previous revisions of these design criteria documents as part of its oversight function in the Design Baseline Verification Program. The staff requested that EA provide an assessment of the impact of the new criteria changes. TVA stated that EA would review the new criteria documents. This item is open, pending completion of the EA review effor (0 pen) Unresolved Item EMG-019, Buried Piping Materials TVA's design criteria document BFN-50-C-7103, Revision 2, dated January 20, 1989 contains design criteria for buried piping. During the inspeciion. TVA identi-fled that the RCW system which was part of the discharge path of the EECW system contained vitrified clay pipe. In a followup meeting with.the staff (Reference 19) TVA comitted to reroute the portions of the EECW system dis-charging into the RCW. This item remains open until the proposed corrective actions have been completed and reviewe (0 pen) Unresolved Item EMG-020, Unjustified Reduction of Themal Stress Range The first part of this item involves TVA's general criteria for evaluating thermal stress range. Section 119.2 of USAS B31.1 - 1967, the BFNP piping code of record, requires consideration of stress range defined to include the sum of hot and cold condition thermal expansion and contraction. Consistent with the code requirement, TVA Design Criteria No. BFN-50-C-7103 requires piping design to include consideration of thermal effects including environmental and thermal anchor motion effects. However, Attachment A, Section 6.2 of that criteria was recently revised to exempt rigorous evaluation of pipe expansion due to pipe temperature between 32* and 150" F with the requirement that review be performed to " ensure adequate thennal flexibility." The basis for this exemption was questioned durirg the inspection. In addition, in a followup meeting with TVA (Reference 9) the staff identified that this exemption conflicted with a proposed
' corrective action associated with the employee concerns program (Reference 12).
This item remains open, pending resolution of the employee concerns progran corrective action.
l The second part of this item involves the implementation of the general l criteria for thermal stress range. Stress problem NI-274-1R, Revision 3 l identifies two operating modes which require evaluation for thermal expansio The specified temperatures for these two modes are 276*F and 40*F. Based on review of the piping calculation package and discussion with project personnel, the following observations regarding pipe thermal range were mad Although evaluated in the current piping calculation, the 40 F condition will be deleted from a future problem revision based on the criteria revision which exempts evaluation of 32*F to 150*F pipe temperature condition A-7
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* .. ' The current calculation includes analysis of the 276*F maximum operating condition temperature based on a zero stress condition of 125'F rather than the nonnally assumed zero stress temperature of 70*F. The 125'F temperature is the maximum reactor building environmental temperature specified for the plant nonnal conditio The effect of these two practices is to reduce the thermal range defined for the problem from 236*F (i.e. , 276'140'F) to 151*F (i .e. , 276*il25'F).
The practice of reducing thennal ranges by assuming the null stress condition as the maximum building environmental temperature for the associated plant condition is not considered acceptable.. This practice assumes simple linear thennal expansion of the restraining structure between support attachment point It also assumes the maximum temperature of the applicable plant condition environmental temperature range applies uniformly to the entire, structure and that the structure expands at a rate which offsets concurrert pipe expansion effects. The second part of Unresolved Item ENG-020 is open, pending review of 1 TVA's corrective actio (0 pen) Unresolved Item ENG-021 - SAM Loads Section 6.3(c)2 of Attachment A to TVA's design criteria document BFN-50-C-7103, Revision 2, dated January 20, 1989, states that the seismic anchor movement (SAM) effects in the same building do not need to be evaluated. This is not in compli-ance with TVA's commitments for the re-analysis effort (References 4, 5). TVA agreed to revise the design criteria to s'atisfy its previous commitments. This item remains open, pending review of TVA's revision of the design criteria documen _(0 pen) Unresolved Item ENG-022, Pre-load Section 8.2.3 of Attachment A to design criteria document BFN-50-C-7103, Revision 2, dated January 20, 1989, allows pre-load as a method of reducing nozzle allowable loads. TVA stated that pre-load was not being used at BFNP and connitted to delete this provision from the design criteria. This item remains open, pending review of TVA's revision of the design criteria documen pen)UnresolvedItemEMG-023.TorusCriteriaRevision Attachment E of TVA's design criteria document BFN-50-C-7103, Revision 2 dated January 20, 1989, contains recent revisions to the criteria for torus attached piping. The torus attached piping was not part of this inspection effort. This item was opened for tracking purposes, pending further review of ongoing work on torus attached pipin (0 pen) Unresolved Item ENG-024. Base Plate and Anchor Bolt Configuration Preliminary SWEC Calculation No. CD-Q2073-882189, prepared on August 31, 1988, evaluates, in part, the adequacy of the East base plate and anchor bolts for A-8
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. pipe support R-26 in the HPCI system. TVA originally field-measured the base plate and anchor bolts on November 14, 1985. This data is documented in Attachment 4 of the preliminary calculation. SWEC prepared a field sketch of the base plate configuration on February 26, 1988, which is also documented in the calculation. TVA's field measurements of the 5/8-inch diameter self-drilling (SSD) anchor bolts indicated that the 1-5/8-inch plug depth for anchor bolt B1 exceeded the maximum allowable plug depth of 1-1/2-inch. The '
SWEC field sketch also noted a 3/4-inch by 1-inch flame cut hole at the I location of anchor bolt B1 which the TVA field sketch did not document. The l preliminary calculation recommends that the anchor bolt be re-worked to an acceptable plug depth and that a washer be added. However, the calculation does not indicate that the washer be welded to the base plate. The reviewer was therefore not able to determine whether SWEC had properly evaluated the base plate hole for acceptability. This might require that the washer be welded to the baseplat ' TVA has indicated that when work resumes on the calculation, SWEC will either qualify the base plate for the remaining three anchor bolts, or repair the base plate hole, if necessary, to conform with the specifications of Section 6.2.3 of General Design Criteria BFN-50-C-7104, " Design of Supports," Revision No. 1, dated April 13, 1988. Unresolved Item EMG-024 remains open, pending review of TVA's submittal of the formally issued calculation, gr.n)UnresolvedItemENG-025,ReviewofBFNLERsforC/RDatabase On February 19, 1988, TVA Engineering Assurance drafted Action Item No. C-048 < to document, in part, EA's concern that approximately 50 licensee event reports (LERS) which detailed support failures at BFNP may not have been reviewed for generic implications with respect to TVA's then on-going 79-14 Phase I Progra TVA was asked to confirm that these LERs were reviewed for generic attributes for incorporation into the horizontal slice evaluation of safety-related piping and supports which SWEC is currently performing for TV TVA indicated that these findings were evaluated for possible incorporation into the C/R database which formed the partial basis (along with the FSAR and BFNP's then-existing design criteria) for the development of the current BFNP design criteria. Unresolved Item ENG-025 will be closed upon receipt of docu-mented evidence that TVA reviewed the BFNP LERs which documented pipe support { failures for possible incorporation into the C/R databas j
! (0 pen) Unresolved Item EMG-026 - Uncontrolled Source Document Used for ZPA '
and SAM Loads Seismic load data input used by SWEC for piping analyses are based on a TVA calculation. TVA has provided amplified response spectra for the reactor building outside the drywell in QIRCEBBFN88150, Revision 0. This document does not, however, include zero period acceleration (ZPA) or seismic anchor motion (SAM) values. The source document for ZPA and SAM analysis input is an uncontrolled telecopy from TVA to SWE l
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Pipe problem NI-274-IR, Revision 3, references the TVA reactor building seismic analysis calculation (RIMS No. B30 8809 28 001) for this data instead of the telecopy, the actual data source. Reference to a source document not available for use violates SWEC Engineering Assurance Procedures. In particular, the
" inputs" section of Engineering Assurance Procedure 5.3, Attachnent 3.0, requires review to assure correct reference to source documents and accurate specification of source document det In a letter dated December 12, 1988, SWEC requested that TVA supply a design criteria document which includes the ZPA and SAM for SWEC use and referenc This item remains open, pending review of TVA's response to the SWEC reques (0 pen) Unresolved Item EMG-027 CR0 Design Criteria TVA's design criteria documents BFN-50-C-7103, Revision 2, and BFN-50-C-7107 Revision 0, dated January 20, 1989, contain design criteria fore the control rod drive (CRD) system evaluation. At the inspection TVA stated that this criteria was still under internal review and had not been finalized. This issue remai open, pending TVA's submittal of the final design criteria for revie ,
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APPENDIX B MEETING ATTENDEES B.1 Entrance Meeting - January 23, 1989 Name Organization
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Wayne A. Massie TVA BFNP Site Licensing Jon E. McCord TVA BFNP NE-CEB T.G. Thaxton TVA BFNP CEB James H. Kincaid TVA CEB > Alan W. Chan- SWEC l Eugene M. Gillen TVA CEB/ Pipe Supports Karl S. Seidle TVA/EMG Manager A.V. duBouchet NRC Consultant R.E. Serb NRC Consultant John R. Fair NRC/TVA Special Projects , Edward F. Lewis SWEC Manager - EA Michael Gilman SWEC QA Mg Robert E. Howley SWEC BFNP EA Enginee Sheldon C. Chow SWEC Manager - EMD , E. Evans SWEC Asst. Mgr. - Pipe Supports l Peter D. Burd SWEC Lead Engineer Spencer Lai SWEC Asst. Project Engineer Craig W. Butt SWEC Lead Engineer Steve Genca SWEC Asst. Lead Engineer l l
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. 'B.2 Exit Meeting - February 3, 1989 Nam Organization Wayne A. Massie TVA BFNP Site Licensing Karl S. Seidle TVA EMG Manager
' John R. Fair NRC/TVA Special Projects
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L " D. Terao NRC/NRR R. Pierson NRC/NRR/ADSP A.V. duBouchet NRC Consultant R.E. Serb NRC Consultant H. Roger Gavankar TVA BFNP - Coordinating Project En Patrick Carier TVA BFNP - Site Licensing Mg J.K. McCall- TVA Chief Civil Engineer C.H. Fox TVA g T.G. Thaxton TVA/BFNP CEB L Jon E. McCord TVA/BFN CEB T.C. Cruise TVA/BFN CEB Alan W. Chan SWEC Sheldon C. Chow SWEC Manager - EMD W. Wang SWEC B.G. Schultz SWEC Robert E. Howley SWEC EA E.F. Lewis' SWEC Mgr. - EA E.M. Gillen TVA/CEB Pipe Supports C.S. Lai SWEC-C.E. Cronan SWEC - Sr. Eng. Mg T.A. Folger SWEC - Engineering Mg B. Charlson SWEC - Manager B-2 _____ __- _-__ _ ____-_- - __- _ - _ _ _ -
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APPENDIX C REFERENCES i NRC meeting sumary on Browns Ferry, Unit 2, restart issues, dated
~ March 25. 198 !
2.- NRC meeting sumary on Browns Ferry, Units 1, 2 and 3, pipe and pipe su'pport seismic design methodology, dated June 29, 198 . NRC meeting sumary on Browns Ferry,- Unit 2, pipe and piper support
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criteria, dated July 21, 198 . NRC meeting summary on the resolution of Browns Ferry, Unit 2, pipe and. pipe support restart issues, dated September 19, 198 . TVA. letter on seismic amplified response spectra and pipe and pipe support calculation methods (Gridley to NRC), dated September 28, 198 ! NRC meeting sumary on the Browns Ferry, Unit 2, use of time history analysis for piping, dated February 1, 198 . NRC meeting'sumary of January 5,1989 meeting on Browns Ferry, Unit 2 Civil / Seismic Issues, dated March 22, 198 . NRC meeting sumary of January ~13,1989, meeting on Browns Ferry, Unit 2 Civil / Seismic Open Issues, dated March 22, 198 . NRC meeting sumary of February 17, 1989, meeting on Browns Fc-rry, Unit 2 Seismic. Issues, dated March 22. 198 . NRC letter (Black to Kingsley) on Browns Ferry Programmatic Milestones and Comitments for Addressing IE Bulletins 79-14 and 79-02, dated December 14.-198 . Inspection Report 50-259,260,296/88-07, forwarded by S.D. Richardson, letter dated September 8,198 . TVA letter (Gridley to NRC) transmitting employee concerns reports, dated February 6, 198 . NUREG-1061, Volume 4. " Evaluation of Other Dynamic Loads and Load Combinations," dated December 198 . NRC letter on the Browns Ferry Mark I containment Long-Term Program (Vassallo to Paris), dated May 6,198 C-1 L _ _ - - - - - ---_-----.--_-__--- _ ____
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e * 15. - Inspection Repcrt 50-259, 260, 296/88-19, forwarded by F.R. McCoy, I-letter dated August 29, 198 . NRC meeting sumary on.Sequoyah pipe support criteria, dated September 4, 198 . NUREG-1232 Volume 2. " Safety Evaluation Report on Tennessee Valley Authority: Sequoyah Nuclear Performance Plan," May 198 . Inspection Report 50-327, 328/88-12, forwarded by S.D. Richardson, letter dated June 24, 198 . NRC meeting sumary on the Browns Ferry clay pipe issue, dated April 3, 198 < , C-2 _ _ _ _ _ _ _ - }}