IR 05000443/1985029

Insp Rept 50-443/85-29 on 851104-08.No Noncompliance Noted. Major Areas Inspected:Program for Qualification of Electrical Raceways by Testing.Unresolved Item Re Cable Trays W/O Axial Bracing Noted

ML20138J133
Person / Time
Site:	Seabrook
Issue date:	12/10/1985
From:	Kamal Manoly, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138J130	List: IR 05000443/1985029 ML20138J125
References
50-443-85-29, NUDOCS 8512170441
Download: ML20138J133 (15)

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O U.S. NUCLEAR REGULATORY COMMISSION

REGION I

' Report N /85-29 Docket N License No. sCPpR-135 Priority --~

Category A Licensee: Public Service of New Hampshire P.O.' Box 330 Manchester, New Hampshire 03105

. Facility Name: Seabrook Station Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: November 4-8, 1985 Inspectors: 4f / /B analy,Lgd(fleactor ineer- date Approved by: 41V [v /d [f7 J. Wiggins, Ct(jAf), Materials Processes date Section Inspection Summary: Special Inspection on November-4-8, 1985 (Report N /85-29)

Areas Inspected: Special announced inspection by a region-based inspector to

. followup on_ licensee activities related to several open items and program for the qualification of electrical raceways by testing. The inspection also included a. review of the licensee's program for the stress reconciliati.on of the Reactor Coolant System piping (RCS) system (ASME Class-1). The inspection'

involved 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> of direct inspection time on sit Results: No items of noncompliance were identifie One unresolved item was noted related to the licensee's plans for qualification of cable trays without axial bracing. One violation (443/82-03-03) and one unresol_ved item (443/81-09-03) were closed. CDR(4.43/81-00-10) remains ope ,

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DETAILS 1. Persons Contacted 1.1 New Hampshire Yankee (NHY)

• J. DeVincentis, Director of Engineering & Licensing

• D. Maidrand, Assistant Project Manager

• G. Mcdonald, Construction QA Manager T. Feigenbaum, Independent Review Team Leader T. Cizauskas, PAPSCOTT Task Team Coordinator

• J. Johnson, Lead Mechanical Engineer

• V. Sanchez, Licensing Engineer J. Wojcik, Senior Engineer R. Boyle, QA Engineer 1.2 United Engineers and Constructors (UE&C)

• M. McKenna, Senior Project Engineering Manager

• A. DuFault, Discipline Manager 1.3 US NRC

• A. Cerne, Senior Resident Inspector

• Ruscitto, Resident Inspector

• Denotes persons present during the exit meeting on November 8, 1985.

2. Licensee Action on Outstanding Open Items 2.1 (Closed) Violation (443/82-03-03) and Unresolved Item (443/81-09-03)

The above violation and unresolved item pertain to the seismic qualification or raceway installations. The two subject items are closely related and have been linked in many licensee responses and subsequent NRC actions and reports. Therefore, they will be addressed jointly in this section. The violation had identified deficiencies in the licensee's QA inspection program for installed Class IE raceways on the basis of the FSAR endorsement of Regulatory Guide 1.30 and the requirement for compliance of safety related systems to IEEE-336, which includes raceways as part of Class IE system The unresolved item and the subsequent followup in NRC Region I Inspection Report 50-443/82-03 had raised concerns relating to the adequacy of the test program for raceways. The concerns included test tray configurations, boundary conditions of test spans, and the effect on the calculated capacity from the biaxial loadin Prior to this inspection, the two subject items were addressed in NRC Inspection Report No. 50-443/85-08, in which several questions were raised as a result of the review of the design and testing reports.

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The inspector reviewed the licensee's response to the questions identified in the above report in addition to the supporting design calculations (Attachment 1) performed by UE&C to substantiate the validity of several~ design assumptions. The calculations reviewed addressed the following concerns:

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axial compressive capacity of cable trays in resisting Euler and torsional - flexural buckling mode ~ frictional capacity of flat washers and Z-clamps used for fastening-cable trays to supporting frame comparison between the equivalent static (pseudo dynamic) and the response spectra analysis approaches in predicting system response, design loads and displacement The licensee's response was found to be adequate for the closeout of the subject violation and unresolved items as related to the seismic qualification of raceway installations in the four completed (closed-out) buildings identified in'Section 3 of this repor .2 (0 pen) Construction Deficiency Report (COR) (443/81-00-10)

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The CDR is'related to the identification of reduced slippage

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capacity of. raceway support bolted strut fittings '(spring nuts).

UE&C submitted four reports to the NRC which addressed the subject item and the action taken to correct it. The hardware deficiency was identified on parts manufactured by UNISTRUT, POWER-STRUT an SUPER-STRUT. The connections affected by the hardware deficiency included one major type attachment (bracket-connection) between vertical frame support members and horizontal members connecting to the building steel and five other minor connection involving various other support member UE&C conducted independent laboratory testing on the fittings of major and minor concern and issued a te3t report which documented their corresponding allowable load Retrofit of cable tray support fittings found to have insufficient capacity started-in 1983 and was curtailed in April 1984 due to the construc-tion shutdown. The retrofit was resumed after restart of construc-tion.in July 198 The inspector was informed th'at the replacement of all identified spring nut parts found to have reduced capacity was almost complete in the closed-out buildings. Retrofit of spring nuts on cable-tray installations in BOP buildings (not closed-out) was terminated since the licensee intends to qualify those installations by a combination of. testing and bounding analysis (Section 3 of this report). This CDR will remain open pending the completion of the as-built verifi-cation program in the BOP buildings and the NRC review of the results from the' testing and bounding analysis being performe _

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3. Review of Cable ~ Tray Seismic Qualification 3.1 Objective The purpose of this review was to evaluate the current status of cable tray installations at Seabrook station, and to develop an understanding of the licensee's intended revised approach to the seismic qualification of the cable tray installations. _The original analysis and design approach, which was based on the licensing commitments in the FSAR, is presently applicable to four buildings in the plant (i.e. those' closed-out). The licensee intends to revise the seismic qualification apprm ch in the balance-of plant (B0P)

buildings (non-closed out) using a combined testing and bounding analysis-type procedure. The NRC review was also intended to identify whether the licensee's revised approach was consistent with acceptable engineering practices-and NRC regulation .2 Overview of Cable Tray Seismic Qualification The review of the seismic qualification of cable tray installations involved several meetings with personnel from the licensee (NHY),.

and the Architect / Engineer (UE&C) in addition to the review of -

. applicable design, installation and testing documents and walkdowns

_of. selected cable tray installations in various building ~

3. Cable Tray Installations Qualified by Analysis and Design Class 1E raceway installations qualified by design are those located in the following areas: Diesel Generator Building, Fuel Building, Service Water Pump House, and .the Service Water Cooling Tower. The

" Specification for General Electrical Installation" governs the-installation of raceways and associated supports. The specification includes a set of drawings identified as the cable tray system notes and typical details which depict the various types of cable tray supporting configurations, connections, bracings, wall mounts, connections to building steel, etc. Since many raceway installations do not conform to the general drawings, specific drawings are pro-vided for all. installation layouts, details, and cross-sections. The specific drawings include all construction and engineering changes <

and provide documentation of as-built configuration In addition, these drawings were utilized by QC for performing a 100% re-inspec-tion of installations in the closed-out areas. The procedure for Installation and Inspection of Cable Tray Supports (FEP-503),

provides specific construction installation requirements applicable to all cable tray and associated supports, including wireways and busducts, as specified on UE&C drawings. The procedure'also provides the requirements for QC inspection (including checklists) of safety related cable tray and seismic support .

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The QC reinspection is preceded by an engineering walkdown veriff-cation effort of raceway configuration / location according to design document The engineering verification effort is performed in accordance with instruction No. ESG-3 which identifies the required verification attributes. The configuration report is forwarded to QC for performance of the final reinspection. All cable tray instal-lations shown on the detailed as-built drawings are qualified by engineering in accordance with the " Technical Guide for the Design and Analysis of Seismic Category 1' Cable Tray. Support Systems".

. The inspector performed a review of applicable procedures identified above and in-Attachment 2 to this report. A walkdown inspection of selected raceway installations in closed-out areas was also ~

conducted. Inspected configurations are identified in Attachment 3 sto this repor .2.2- Cable Tray Installations in B0P Areas Cable tray installations in BOP areas include those in the contain-ment building, control building, electrical tunnel, primary auxiliary building, and main steam /feedwater chase. Cable tray installations in 80P areas are similar to those in the closed-out areas in that-they are installed and inspected according to the requirements in the Specification for General Electric Installations and procedure FEP-503-for installation and inspection of cable tray supports. The significant difference is that the installations in the BOP areas do not have all the axial bracings typically required by the specifi-cation and that they also contain spring strut / nuts with reduced frictional capacity (see Section 2.2).

The licensee plans to qualify the installations on b' asis of the following:

• performance testing of typical configurations

• ' testing of major connections ,

• performing bounding analysis on selected tray / support configurations which should envelope all installations in the B0P area The licensee has completed the testing of four distinct configura-tions which are typically used in tray / support installation This testing occurred at ANCO and was partially witnessed by a member of the NRR Structural Branch staff. The tested configurations considered the following typical supports from the general instal-lation detail drawings (No. 9763-M-300229):

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• Test - A (Configuration T-26): . suspended support (trapeze) with diagonal bracing only Test - B (Configuration T-5): support from floor to ceiling Test - C (Configuration T-9/T-10): v,ertical support with 90 turn Test - C (Configuration T-12/T-38): vertical tray support with embedded stru All tested configurations were investigated for resistance to fatigue loading wherein they were subjected to five consecutive CBE-Test Response Spectra (TRS) excitations followed by one SSE-TR The fatigue test was-followed by a fragility test wherein the test configurations were subjected to incremental TRS using the SSE-TRS shape until the table limit was reache Discussions with licensee engineering personnel indicated that all tested configurations had withstood the fragility test with no major failures. Neither preliminary nor final test reports were available, however, for review by the inspecto Analytical models of tested configurations were developed by Bechtel' power (the licensee's contractor. for this effort). The-intent of this effort was to develop mathematical models which would behave analogous to tested configuration During the inspection, the licensee was performing additional testing of three typical ~(site specific) support connections which are widely used throughout cable tray support-installations. The three tested connections include the vertical strut / boot connection, two-bracket strut connection, and typical intermediate strut-to-strut with bolted angle connections. All tested connections were subjected to:

movement-rotation test to determine the movement resistance as a function of angular rotation and

• . fatigue test to determine the number of cycles to failure at selected angular rotations and corresponding movement resistance as a function of the number of cycles achieve Eventually, the analytical effort will include the development of equivalent spring stiffness values on the basis ~of the above connection testing to simulate the response of the four

. tray / support configurations teste .

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Developed spring valves will be utilized in the bounding analysis of twelve governing cable tray support configuration The governing configurations were determined by the licensee as a result of a walkdown of cable tray installations in the B0P area The engineering verification and QC reinspection of installa-tions is controlled by procedure FEP-503 as indicated earlier with' instructions which were revised from those applicable to-installations in closed-out areas. The specific instructions for engineering verification are specified in procedure ESG-4 for " Engineering As-Constructed Inspection of Cable Tray Supports". The inspector performed a review of several appli-cable procedures and test reports (Attachment 2) in addition to conducting a walkdown of selected cable tray support installa-tions in the BOP areas. Visual verification of several installations was performed to verify their conformance. to the bounding configurations the licensee had selected for analysi Inspected installations are identified in Attachment 3 to this repor .3 ' Review of QA/QC Interface A- review of the QA/QC interface in the fabrication, erection and performance testing can be summarized as follows:

• Test configurations A&B were fabricated on site with the bracing members removed. UE&C QC personnel were responsible for 100% inspection of welding and geomentry verificatio * Configurations tested in test C were fabricated on sit *

Erection of tested configurations was completed at ANC0's testing laborator *

ANC0's QC inspectors were responsible for verification of connection details, calibration of torquing equipment, calibration of accelerometers, torquing of bolts and overall con. figuration verificatio *. Tests A & B were observed by NHY QA personne * Bolted nut connections were torqued to the minimum value of the required torquing range.

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Connections in all test configurations were assembled using a mixture of bolted spring strut / nuts manufactured by Power-strut, Super-strut and Unistrut. The majority of the primary connec-tions (other than the top or bottom frame mounting support con-nections) were assembled using Super-strut spring nuts which had been previously tested and found to provide the lowest fric-tional capacity _ in comparison to other manufacturer's spring

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nut The decision to utilize Super-strut spring nuts was intended to provide a justification for not replacing reduced capacity spring nuts in cable tray installation in B0P areas (see Section 2.2).

3.4 Findings Although no items of non-conformance were identified during this review, the following findings were noted as a result of the review of seismic qualifications of Class IE cable tray installations: The~ licensee is presently performing a retrofit of all primary support boot connections either by utilizing two through bolts or by welding strut members to connecting boots. This action was undertaken as a result of the collapse of the first test configuration at the ANCO laborator . Documentation of as-constructed cable tray and support con-

-figurations in BOP areas has just begun. The necessity for-continuing this effort to completion is further enhanced due to the following:

= the need for the licensee to be.in compliance with its written commitment in response to the NRC-CAT inspection finding * the need to provide final design as-built document drawings-for QC 100*4 reinspection in accordance with procedure FEP-50 ~

a the need to provide direct correlation between the as-built cable

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tray and support installation vs. the analyzed bounding configurations. This correlation will' serve two purposes: to provide a tally to insure that all variations of cable tray and support installations in B0P areas have been addressed by the bounding analysis b, to identify any unique configurations which might have been overlooked or modified during and after the licensee's walkdown in the B0P areas to establish the bounding configurations for analysis. These unique configurations if identi-fied, might require specific analysis due to geometric and/or loading variance . Several questions arose during discussions with the licensee regarding the seismic qualification of cable tray installations by testing and bounding analysis. The questions involved

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several unresolved issues about which the licensee was informed during the inspection. The identified concerns included:

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_the adequacy of the acceptance _ criteria for configurations which the licensee-plans to qualify by bounding analysi *

the adequacy of the acceptance criteria fatigue limits and moment resistance.of connections teste *

the adequacy of the licensee's determination of spring stiffness (translation 'and rotation) to be used in the bounding analysis, and identification of the analytical techniques to be employed in.the computation of displace-ments and internal loads in analyzed configuration * justification to insure that the three selected test con-nections, for-computation of spring stiffnesses, adequately model the response of the analyzed configura-tion The-licensee acknowledged the above concerns. These concerns will be considered unresolved pending NRC review of the licensee's response, the_ final test report and the bounding analysis of cable tray and support configurations in B0P areas (443/85-29-01).

4.0 As-Built Stress. Reconciliation of Westinghouse Analyzed Piping Systems 4.1 General A review of the as-built stress reconciliation. program for Westing-

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house {W)-analyzed piping was performed during this inspection. The objective of the review was to-evaluate the stress reconciliation-activity and verify its conformance to FSAR commitments and NRC reg-ulation The inspector held discussions with the licensee personnel in addi-tion to performing a review of applicable documents (Attachment 4)

addressing'the above activity. Other inspection-related activities involving. review of stress reconciliation packages and verification of as-built installations could not be performed during this inspec-tion since the walkdown effort by.W had not started.'

4.2 Overview of Stress Reconciliation Activities Resulting.from discussions with licensee personnel and review of applicable documents some of which were still in draft stage, the following was identified in relation to the stress reconciliation activity:

• stress reconciliation of W analyzed piping is coordinated by the Piping and Pipe Support Close-Out Task Team (PAPSCOTT) (NRC report 433/85-15).

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W analyzed piping involves twenty-six (26) ASME Class I lines, including Class 2 extensions. The (26) lines are analyzed in thirty-one (31) models involving the RCS, SI, RHR and CVCS system *

As-built walkdown verification is performed by W teams. Each team involves'two people, one surveyor for taking measurements and one lead engineer who is responsible for walking down the particular system in the plant. At least one member of the team is a pipe stress analysis enginee *

Prior to W walkdown, an initial walkdown was completed three weeks before hot functional testing, which was taking place during this NRC inspectio *

All W piping installations are verified by Pullman-Higgins (P-HJfieldengineeringandQCinspector *

Walkdown drawings are prepared from the analysis isometrics, and are included in the stress packag * .W piping stress reconciliation review includes: piping con-figurations, piping supports, pipe properties, loading con-ditions, and interface *

Review of piping configuratfor; includes the followin attributes: general routing of the line, line boundaries, decoupling, segment length, segment orientation, location of fittings, and location of branch correction * Review of pipe supports include: location of' supports,

- restraint direction, support type, support stiffness, support weight, and welded attachment * ' Review of pipe properties includes: pipe size and schedule, weight of pipe (and insulation), pipe material, concentrated weights, valve operator orientation, and stress intensification factor *

Review of loading conditions includes: deadweight, seismic, seismic anchor motion, and LOC *

Stress reconciliation of piping will be performed on site by *

Special evaluation or fatigue analyses of piping will be performed in W corporate offic *

Stress reconciliation of pipe supports is performed by UE& . . ... .. ._ _ _ _ _ . .__ __ .

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The requirement for a second walkdown of W piping will be de-termined based on comparison of data collected from the first

- walkdown and data, acquired as a result of final changes and mod-

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ifications to the syste = ' NHY QC performs surveillance of W walkdown activitie _

. 4.3 Findings No items of non-compliance were identified during this review.

5.0 Unresolved Items-

. Unresolved-items are matters about which information isL required in order

. to ascertain whether they are acceptable items, violations or deviation Items remaining unresolved in this inspection are discussed in Section 3 of this repor .0' Exit Meeting An exit meeting was held on November 8, 1985 with members of the licensee

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staff and contractors as denoted in Section 1 of this report. The inspec-tor discussed the scope and findings of the inspection. At no' time during

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this. inspection-was written material provided to the licensee.by the in-

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ATTACHMENT 1 SEISMIC CABLE TRAY QUALIFICATION ESIGN CALCULATION DOCUMENTS Reviewed a

Calculation No. 9763-SQ-00121-05-2003: Static Equivalent Method Analysis vs. Dynamic Analysis Compariso *

Calculation No. 9763-SQ-00121-05-2421: Cable Tray Hold-down Clamps 9ZB and 9Z *

Calculation No. 9763-SQ-00121-05-Z422: Cable Tray Axial Capacity Determinatio . . -- . . - . - . - . . . . . .-.

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p ATTACHMENT 2 SEISMIC CABLE TRAY QUALIFICATION PROCEDURES REVIEWED

• - Specification No. 9763-006-48-2 for General Electrical Installatio *

Procedure No. FEP-503 for Installation and Inspection of Cable Tray Support *

Drawings _No. 9763-M-300229 for Cable Tray System Noces and Typical Detail *

Instruction No. ESG-3 for Engineering Acceptance Inspection of Cable Tray Support *

Instruction'No. ESG-4 for Engineering As-Constructed Inspection of Cable Tray Support *

Procedure No. FACP-16 for Certification of Engineering Personnel Perform-ing Configuration Verification of Installation *

Technical Guide No. 9763-SQ-00121-3Z025 for Design and Analysis of Seismic Cable Tray. Support Systems.

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'* ANCO Document No. A-000146: -Test Plan for Performance Testing of a

. Typical Cable Tray Configuration (Test Cases A & B).

ANCO Document No. A-000151: Test Plan for Performance Testing of a Typical Cable Tray. Configuration (Test Case C).

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ANC0 Document No. A-000147: -Test Plan for Performance Testing of a Typical Cable Tray Support Connections.

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ATTACHMENT 3 CABLE TRAY INSTALLATIONS WALKDOWN VERIFICATION

.l l Support Designation or Drawing Area i Tray N l l

Control Bldg.(EL.21'-6") 1141VB, 15M1VB, l T31, T27 and T7 Train'B l15MIRB and 15M2RB l Cable Spreading Room' l08TIVA, 2001VA l T5

'(El. 50'-0") l20Q1VA and 20 VIRA l

= Cable Spreading Room l20LIVB, 07XIVB, l T9, T10 connected to T7

=(EL. 50'-0") [07X1RB, 20L1RB andl l20L2RB- l-Primary Aux.81dg;(EL 25) l44S2LA and 4451LA l T28 Diesel Generator Bld l36AILB, 36AIRB cndl T4 Train B (EL 21'-6") 136A1VB l-Cooling Tower Bld Q1VA, 84Q1RA andl --

l84Q1LA l Service Water Pump H'ouse 180XIVA, 80X1RA and[T2'6 (F301147 and F301144/ Details l80X1LA l E2, E3 and E7

. Service Water Pump House ~ l8082LA, 80BILA,

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lT9 and T10 (F301147 and F301145/

18082RD and 80B1VA l Details E33, E33H, E33J and E33K)

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IR SEABROOK 85-29 - 0026. /20/85

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e ATTACHMENT 4 AS-BUILT STRESS RECONCILIATION OF WESTINGHOUSE ANALYZED PIPING DOCUMENTS REVIEWED

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Procedure for the Review of the As-Built Condition of Westinghouse Analyzed Auxiliary Lines (Rev. 0).

Procedure SSP-1: NRC 1EB 79-14 As-Built Reconciliation Walkdown Guidelines for Westinghouse Electric Analysed Lines (Rev. 0).

Procedure TP-37: PAPSCOTT Freeze Level Program (Draft)

Interface Control Agreement Between NHY and Westinghouse for Class 1 Piping As-Built Progra *

Quality Control Procedure QCP-17-5: N-5 Data Report