IR 05000443/1986043
| ML20204H472 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/30/1986 |
| From: | Kamal Manoly, Mcbrearty R, Varela A, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20204H449 | List: |
| References | |
| 50-443-86-43, IEB-79-14, NUDOCS 8608080125 | |
| Download: ML20204H472 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-443/86-43 Docket N License No. CPPR-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: July 7-11, 1986 Inspectors: [Mnoly,[#~/ Lead-Reac or Engineer 7/8db date
. , , %1 % Esd A. Varela, lead Reactor Engineer date l AWW/ 5 cBrearty, Reactor Engineer 1/1o // 6 date Approved by: ) Nh N [/36 6 J. p gg~ ins, i ' dat Section,DRgf,MaterialsandProcesses Inspection Summary: Routine Inspection on July 7-11, 1986 (Report No. 50-443/86-43).
Areas Inspected: Routine unannounced inspection, by three region-based inspectors, of licensee activities in the following areas:
l As-built program and qualification of cable tray and support systems
I.E. Bulletin 79-14 for seismic analyses of as-built safety related piping systems
Pre-Service Inspection program including review of code relief requests i and PSI data The inspection also included a followup on licensee activities related to several outstanding unresolved itemsa 'nd construction deficiency report.
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l 8608080125 860301 PDR ADOCK 05000443 G PDR
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Results: No itemt of noncompliance were identified. One unresolved item was noted in the area of cable tray qualification and two items in the area of PSI.
- Unresolved itens 85-15-04, 85-15-05, 85-29-01 and 84-12-01 were closed. CDR 81-00-10 remains open.
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DETAILS 1. Persons Contacted 1.1 New Hampshire Yankee (NHY)
- G. Mcdonald, Construction QA Manager J. Singleton, Assistant QA Manager V. Sanchez, Site Licensing Supervisor D. Johnson, Senior Engineer, Mechanical Group
- R. Gregory, Licensing Engineer
- R. White, Supervisor, Mechanical / Structural Engineering
- R. Jeffrey, PSI Supervisor
- D. Icing, NDE Level III 1.2 United Engineers and Constructors (UE&C)
- A. DuFault, Supervisor, Electrical Support Group 0. Kalani, Supervisor, Piping Support Group 1.3 Teledyne Engineering Services (TES)
J. Rivard, Senior Engineer U.S. Nuclear Regulatory Commission (NRC)
- A. Cerne, Senior Resident Inspector D. Ruscitto, Resident Inspector
- Denotes persons present during the exit meeting on July 11, 1986.
2. Licensee Action on Outstanding Open Items 2.1 (Closed) Unresolved Item (443/85-29-01)
This item was related to the approach identified by the licensee for the seismic qualification of cable tray and support system installa-tions by testing and bounding analyses. The item included four specific questions regarding the acceptance criteria and analytical assumptions in the licensee's approach. Further, a review of the final test reports by ANCO Laboratories for configuration and connec-tion testing was required for NRC's evaluation in this are The inspector reviewed NHY's report of March 1986 for Cable Tray Support Qualification Program and transmittal No. SBN-989 to the NRC which addressed the identified concerns. Details related to the licensee's current qualification approach are provided in Section 3.0 of this repor Summary of the response to the questions raised in this item is provided below:
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Acceptance criteria for configurations qualified by representa-tive analyses were found to be addressed in Section 5.4 and of NHY's repor The acceptance criteria for fatigue limits and moment resis-tance of connections tested were addressed in Section 4.2.2 of NHY's report and Section 4 of Volume 5 of ANC0's report on con-nection testin *
The adequacy of the spring stiffnesses determined from connec-tion testing in the predication of system response (i.e. resul-tant reactions and displacements) was addressed in sections 4.1.3 and 6.3 of the NHY's report. It should be noted that joint stiffnesses used in the analytical models represented the linear portion of the Force / Displacement or Movement / Rotation curves from connection testing. The assumption was found to be acceptable since system displacements were limited by means of axial and lateral bracing *
Justification to insure that the three selected test connections for computation of spring stiffnesses, were sufficient for pre-dicting model responses was addressed in Section 4.2.3 of the report in the correlation analysis of test san:ple Four of the five test reports by ANCO were not available for review by the inspecto NRC evaluation of the test reports will De tracked with unresolved item 443/86-43-01 which is addressed - Section 3.0 of this report. This item is therefore close .2 (0 pen) Construction Deficiency Report (CDR) (443/81-00-10)
This CDR is related to the identified reduced slippage capacity of
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raceway support bolted strut nut fittings. The resolution of the CDR was addressed in NRC inspection report No. 443/85-29 and was open pending completion of the as-built verification program in the Balance of Plant (BOP) building The inspector reviewed the licensee's corrective action in the BOP buildings which are qualified by a combination of testing and analyses. The corrective action included:
Replacement of all strut / nut slip fittings in all primary over-head and floor-to-ceiling connections by either welded or positive bolted connection *
Bracing and wall mounted connections in system qualified by representative analyses were evaluated using the reduced slippage capacity of the strut / nut fittings determined by UE&C and Franklin Institute testin Reaction loads which exceeded the allowable joint capacity were modified using stiffened brackets or Unistrut nut .
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Secondary connection joints in tray support systems containing some strut / nut fittings with reduced capacity were qualified on the basis of configuration testing performed by ANC0 labora-toric The licensee's overall approach for resolution of the CDR was found to be acceptable. However, this item will remain open pending NRC review of the final close-out report of the CDR by the license .3 { Closed) Violations (443/85-15-04 and 85-15-05)
ASME Section III, Subsecticn 3624.1(c) requires that pipe hangers and supports be designed to permit expansion and contraction of the piping between anchors. However cn one RHR support a zero clearance was specified betweer. the piping and the top member of the support structure (85-15-04). The licensee response of November 14, 1985 to this violation was reviewed and discussed with UE&C's assistant project engineering manager and, additional documentation was obtained and reviewe This violation is interrelated and affected by Violation No. 85-15-05, - where pipe supports were found to be installed with zero clearance. This resulted from different inter-pretations by UE&C during fit-up and QC inspection of in process and completed support installations. The licensee response identified above provided appropriate corrective actions for both violation Specifico ly hey consist of the following:
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Violation No. 85-15-04 was corrected by revision to the Pipe Support Design Guidelines and the re-evaluation of the 56 supports that reinspection identified as having zero clearanc Measurements of As-built gaps for safety-related pipe supports and evaluation of their effects on the piping analysis and support designs is a part of the PAPSCOTT program. The 56 supports were redesigned with 1/16" gap and were specifically noted for monitoring of thermal movements during hot functional testin The design agency and installation contractor both initiated an Interim procedure revision to clarify design criteria and installation requirements in the installation and inspection of pipe hanger Installation and control personnel were trained in the Interim Procedure JS-IX- Based on the inspe: tor's review of the above corrective actions and his discussions and evaluation of additional support records, the licensee responses are considered adequate to close violations 443/85-15-04 and 443/85-15-0 +
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2.4 (Closed) Unresolved Item (443/84-12-01): Effect of Changes In Groundwater Chemistry on Rebar The identified concrete wall cracks in the waste process building and detected leakage into the building was resolved by special repairs that were undertaken to prevent excess leakage of ground water as reported in IR #84-1 However the then detected non-saline condi-tion of the ground water might change when the Unit #1 dewatering was terminated. Thr inspector expressed his concern that salt water infiltration - ,nt cause excess rusting of the steel reinforcing bars and affect * concrete as wel Dewatering of Unit #1 is essentially ended. Studies undertaken May 30, 1986 by the licensee of ground water chemistry show the water at Seabrook is of fresh potable quality with a pH of 8.6. The licensee reports that no change in salinity of the ground water is expected in the future when Unit #2 dewatering is terminated and the water table returns to normal. The additional information reviewed by the NRC inspector indicated that no significant corrosion of the rebar or attendant damage of the concrete is expected due to changes in ground water cher..istry. This item is resolve . Review of Cable Tray Seismic Qualification 3.1 Objective The purpose of this review was to followup on the licensee's activities regarding implementation of the as-built program for cable tray and support installation The review was also intended to assess the final approach selected by the licensee for the qualification of system installations in the Balance-of-Plant (B0P) by means other than analysis as described in the FSAR (before ammendment) and implemented by UE&C in the Closed-out-Buildings (COB). To achieve this objective the inspector re-viewed the status of the as-built program and qualification activ-ities with the cognizant licensee representative and performed a walkdown for verification of the as-built conffguration of selected system installation Further, a review of some qualification pack-ages of installations verified during the walkdown was also performed during this inspectio Since the QA/QC interface in the as-built effort was evaluated during a recent NRC inspection (443/86-36) as part of the close-out of the CAT violation No. 443/84-07-01, it was not addressed during this inspection.
i 3.2 Overview of Cable Tray System Qualification The licensee activities in this area were reviewed in several NRC inspections. Inspection Report No. 443/85-29 provided details of the licensee's approach and status of activities at that tim During that inspection, several questions were raised regarding l
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the licensee's proposed approach for qualification of cable tray installations and were subsequently addressed in the resolution to unresolved item 443/85-29-0 The licensee adopted any of the following approaches for the quali-fication of cable tray system installation in B0P buildings in conjunction with the as-built program which depicted the as-constructed configuration of all system installations
Correlation to system configurations tested by ANC0 Labora-torie Correlation to any of the twenty-six (26) representative con-figurations analyzed by Bechte Specific analyses of system configurations which could not be directly correlated to testing or representative model Typical analyses similar to that employed by UE&C for the qualification of system installations in the CO Qualification of system installations was performed by different organizations depending on the type of approach (or approaches)
adopted for that purpose. Teledyne Engineering provided qualifica-tion of tray installations using combination of the first and second approaches in the following plant areas:
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Reactor building at elevation O'-0" (Trays supported from floor at elevation 25'-0")
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Electrical tunnel (A train) at elevation O'-0"
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Primary Auxiliary Building (PAB) at elevation 53'-0" north of column line # Containment Enclosur Cable tray and support system installations in the control buildyng were qualified by EQE Inc. using specific analyses. The qualifica-tion involved performing dynamic (modal) analyses of the systems
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using the amplified response spectra as input. Four models were developed for installation at elevation 21'-6" and one model for installation at elevation 50'-0" of the control buildin Installations qualified by UE&C using the original analysis approach described in the FSAR included the Control Building at elevation 75'-0" and elevation 50'-0" (Column lines 4-5), the Reactor Building at elevation 25'-0" and the Main Steam / Feed Water pipe chas The major changes in the. licensee's activities in this area can be summarized as follows:
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8 All installations are currently qualified with some pro-vision of axial bracing (along tray longitudinal axis).
This was necessitated in order to limit system displace-ments which would otherwise exceed tolerances available between safety related installations. To accomplish this design change, many of the support frames which were designed for vertical and transverse loadings (in plane),
were reevaluated to accommodate the contribution of axial
, loads transmitted by tray system . Reliance on rotational stiffness of primary connections was no longer required to insure system stabilit . Some modifications were required to accommodate additional loads on supports which are providing the primary load path or axial bracing of tray systems. The modification involved replacement of primary strut / nut connections and/or providing stiffened angle brackets. Tray system installations which did not contain supports capable of providing axial restraint (i.e. horizontal runs with no bends), such as tray installa-tions crossing adjacent buildings with seismic separation, were provided with cross bracing to satisfy axial restraint requirements. The cross bracing nodifications were performed for tray systems in the pad walkway and Containment Building below elevations 0" - 0" and 25" - 0". The approach for qualification, of tray systems using bound-ing analyses was no longer valid. Representative models were developed in place of the bounding analyses approac Variations in loading or geometry, between actual configur-ations and models selected for comparison, were evaluated in the qualification package .~ Utilization of modal response spectra analysis of install-ations qualified by EQE Inc. as described above.
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The status of activities related to the cable tray qualification
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Walkdown and documentation of the as-constructed configuration of installations of raceways and supports was complet Documentation of support evaluations is complete except for minor modification changes which were not yet completed by construction and QC, I
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Evaluation of embedded plates with tray support attachments in
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3.3 Verification of As-built Installations and Seismic Qualification Documentation Verification of As-built system configuration was performed during this review by conducting a walkdown inspection and performing physical measurements of selected installations to insure their conformance to applicable drawings and procedure Systems were selected from installations in the Reactor Building, Main Steam /
Feed Water Chase, Electrical Tunnel, Containment Enclosure Ventilation, Control Building and Primary Auxiliary Building. The selected systems were qualified by the three contractors involved in this activit The walkdown and documentation of the as-constructed configurations were performed by UE&C. The inspector utilized the as-constructed drawings of those selected installations in addition to the applicable installation and inspection procedures for the purpose of this review. The procedures used werc:
Procedure No. FEP-503 for Installation and Inspection of Cable Tray support *
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 Installations verified during this inspection are identified in Attachment 1 to this repor In addition to the as-built verification, the inspector perfonaed a review of the evaluation criteria and selected support system qualification packages prepared by Teledyne Engineering and E0E In Documents reviewed are identified in Attachment 2 to this repor .4 Observations and Findings l Based on the sampling inspection of the cable tray qualification program the inspector concluded that the as-built program has reasonably addressed its intended purpose in depicting the as-constructed configuration of cable tray system installations. The qualification oackages reviewed were also found to be detailed and comprehensive except for one finding which is addressed belo Summary of observations and findings is provided belo . Qualification of installations performed by Teledyne was based on the breakdown of areas containing common configurations of tray and support systems (i.e. trapeze, wall-to-ceiling, etc.)
! which would closely resemble one of the twenty-six representa-I tive models established and analyzed by Bechtel. Parameters
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requiring evaluation for the proper selection of test or rep-I resentative configuration were identified in specific check
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lists and included in the engineering evaluation procedure.
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s Tray loadings were based on the "CASP Tray Loading and Voltage Drop Check Program" reports developed by UE& . Reoresentative models developed by Bechtel were analyzed using brc:dened ( 20%) floor amplified response spectra curves based on 20% of critical dampin . Documentation of installations qualified by Teledyne and EQE focused on the evaluation of the primary, wall and bracing connection capacities in addition to the evaluation of slenderness ratio of frame members. Structural integrity of members and secondary connections was not evaluated based on results from testing and/or analysis of representative model . Specific evaluation of system displacements in configurations qualified by Teledyne was not provided to the inspector. The acceptance of tolerances between some cable tray systems and other structures during the seismic interaction review, was based on licensee judgment regarding the limited extent of dis-placements of tray systems. Determination of anticipated system d'splacements is required to insure the adequacy of these toler-ances. This item is unresolved pending licensee evaluation and NRC review of cable tray system displacements for installations qualified by tasting and/or representative analysis (443/86-43-01).
This unresolved item will also include the review of ANCO testing reports which were not available during this inspection (carry over from unresolved item 85-29-01).
No violations were identifie . Closecut of I.E. Bulletin 79-14 - Seismic Analysis For As-Built Safety Related Piping Systems The licensee's administrative controls in assuring quality in construction and quality control of ASME pipe supports consists initially of in process surveillance of construction activities. Surveillance reports of in-process work observed by NHY were reviewed. Craft construction activ-ities were observed to be in compliance with engineering design and construction requirements. The reports provide assurance of craft quali-fications for unique features of construction and indicate engineering approval of field changes, the acceptability of engineering design changes and, resolution / corrective actions and closecut of identified non-conforming conditions observed and reported by licensee's QA inspectors. These surveillance reports of ASME pipe supports pertain to work performed by Pullman and by UE&C. They cover the period from December 1982 through July 1986. QA inspectors used check lists based on ANSI N 45.2, revision l
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Additional administrative controls by the licensee's NHY QA inspectors covered the PAPSCOTT As-Constructed Verification Program. UE&C performed an audit of the PAPSCOTT program for the first six months of 1986. The NRC inspector's review observed thoroughness and effective licensee involvement in the pipe support As-built verification program. The NHY division performed two audits in 1986 of UE&C to verify compliance to, and the adequacy of, the pipe support close-out task team (PAPSCOTT) and the team's implementing procedures. Both audits found deficiencie Responses to these findings and the corrective actions were reviewed by the NRC inspecto Summary and Conclusion Based on the above administrative controls and the NRC independent inspec-tion efforts identified in inspection reports number 85-15 and 86-14 for pipe systems in the RHR, SSW and CCW systems, NRC/IE BU 79-14 is con-sidered to be closed. The NRC report number 85-29 provides further review of the as-built stress reconciliation of Westinghouse analyzed piping systems for its conformance to FSAR commitments and NRC regulation . Preservice Inspection PSI Program Review The inspector reviewed the licensee's PSI Program to ascertain that ASME Section XI requirements and regulatory requirements were me The following were included in the inspector's review:
Document No. 80A8980, Revision 2, " Balance of Plant Preservice Inspection Program Plan General Reference Text For Seabrook Nuclear Power Station, Unit 1"
Document No. 80A8982, Revision 3, Feedwater System PSI Program The program at Seabrook complies with the ASME Code Section CI, 1977 Edition up to and including the Summer 1978 Addenda. The licensee is permitted by 10 CFR 50.55a (b)(2) to use the PSI requirements of Section XI, 1971 Edition through Summer 1972 Addenda, but has elected to invoke the requireraents of the 1977 edition, which is permitted by 10 CFR 50.55 The inspector's review disclosed that weld number 1-FW-4606-03-10 is iist-ed in the feedwater system program as the 18" penetration X-5 process pipe to pipe weld and also as a pipe forging to pipe weld. The weld is identified on the UE&C drawing number 9763-D-804606 ISI and on the NES drawing number B-01 as the X-5 penetration weld, and on the UE&C drawing 9763-F-202396 ISI and the NES sketch B-05 as the pipe forging to pipe weld. The X-5 penetration and the pipe forging to pipe weld are located at opposite ends of the pipe ru In addition, the NES Data Log identifies the X-5 pene-tration weld as weld number 1-FW-4606-03-01. Examination data are avail-able for both weld numbers, but the data are not clear as to which weld is represente , _ - _ - _ _
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The inspector determined that the licensee is aware of the problem and has initiated action to resolve the discrepancie The inspector informed the licensee that confirmation is required that each weld has been subjected to the code required examinations in addition to correcting the applicable paperwork. The item is considered unresolved pending completion of the licensee's action and subsequent NRC review (443/86-43-02).
No violations were identifie .1 PSI Data Review The inspector reviewed selected PSI data to ascertain that the data were complete and accurate, and that ASME Code and regulatory requirraents were met. Data related to the following welds were included in the inspector's review:
Feedwater system weld 1-FW-4608-04-01,18" x 16" reducer to pipe Feedwater system weld 1-FW-4606-04-20,16" pipe to feedwater nozzl Pr_imary Loop Piping Cast Stainless Steel Welds a
Loop 2, welds 5-1-3, 5-1-4 and 4-1-2 The feedwater system welds were examined by Nuclear Energy Services (NES) personnel, and the cast stainless steel welds were uxamined by personnel employed by the Westinghouse Electric Corporatio Using the licensee's data, the inspector re plotted ultrasonic indications to ascertain the accuracy of the indication locations as depicted on the data sheet The feedwater system data were found to be complete, indications were accurately plotted, and each data sheet was reviewed by NES, the licensee and by the ANII.
i Examination data associated with the cast stainless steel welds showed no evidence (by signature) of review by Westinghouse, the licensee or by the ANI In addition the inspector found that the plots were inaccurate in that angle beam and straight beam indica-tions which were plotted at the same point on the inside surface and did not agree with information recorded on the data sheets, nor did the plotted beam exit point and beam angle agree with that in formation. Indications were attributed to the counterbore, but it was unclear from the data precisely where the counterbore was located in each weld. To make this determination the inspector measured the location of the counterbore in accessible primary piping in unit The inspector found that the shape of the slope varied from pipe to pipe, buc that the measured length of the counterbore was essentially uniform in each pipe. The inspector's measurements coafirmed that reported straight beam indications were attributable to the counter-bor ._
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i The inspector was advised that Westinghouse, the licensee and the ANII had reviewed the data as a package. Additionally, the licensee stated that the apparent plotting discrepancies noted by the in-spector were attributed to material characteristics such as beam redirection (wave guiding) and velocity changes in the cast material, and although a refracted longitudinal wave was used to minimize the problems caused by the material characteristics, it
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could not completely eliminate them. The inspector was further i
advised by the licensee that his concerns would be addressed in the final repor This item will remain unresolved pending the avail-ability of the final report and subsequent review by the NRC (443/86-43-03).
5.2 Requests For Relief From Preservice Inspection Requirements The inspector reviewed the licensee's requests for relief from ASME Code requirements which are considered by the licensee to be impractical to meet to ascertain that the request accurately described the condition which rendered the requirements impractica Relief Request PR-7 regarding the RHR Heat Exchanger nozzle to shell welds states that the weld geometry involved is of a configuration which cannot be examined with currently available ultrasonic exam-ination techniques. The inspector found that the welds in the unit I heat exchangers were not accessible to visual observation, but that the unit 2 components were of the same design, and were accessible to the inspector's observation. The configuration was found to be as described by the licensee in its request for relie The welds received volumetric examination by radiography and surface examination during fabrication in accordance with ASME Section II Those examinations were used to meet the preservice inspection re-quirements, and the licensee has committed to develop ultrasonic examination techniques such that maximum coverage of the welds will be achieved at the first refueling outag No violations were identifie . Unresolved Items Unresolved items are mattert about which more information is required in order to ascertain whether they are acceptabl9, violations or deviation Unresolved items are discussed in paragraphs 3.4, 5, and 5.1 of this repor . Exit Meeting The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on July 11, 1986. The inspectors summarized the purpose and the scope of the inspection and the finding At no time during this inspection was written material provided by the inspector to the license . . - ... - ,.--- , -- - --
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ATTACHMENT NO. 1 CABLE TRAY AND SUPPORT SYSTEM INSTALLATION INSPECTION As-Constructed Area Drawing N Sheet N Notes Primary Auxiliary 9763-6-370134 31 & 31A Plan & Section N-17 Bldg. (E1. 53'-0")
Control Bld L-370128 5, 5A, 58, Plan and Section (El. 75'-0") 7, 7A, 21 N-1, N-3 and N-16 and 21A Control Bld L-370128 25, 25A, 258 Plan, Section S-15, (El . 75'-0") 25C, 26, 26A, S-ISA and S-20 31 and 31A Control Bld L-370101 5, 5A &5AA Plan, Section NW-10 (E1. 50'-0") and Details Control Bld L-370101 9, 9A, 9AA SW-11 and sections (El . 21'-6") and 9AA-1 Control Bld L-370108 5, 5A, 58, Plan, section NW-2 (el. 21'-6") SC and SD and details MS/FWC 9763-L-370150 16, 16A, 16B Plans, Section 50 (El . O'-0") 16C MS/FWC 9763-L-370131 51, 51A & 51B Plan, section and (E1. 3'-0") details Containment 9763-L-370152 11, 11A and Plan, section S-29 Enclosure 11B and details Ventilation Area (El . 25'-0")
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. l l ATTACHMENT NO. 2 CABLE TRAY PROCEDURES AND QUALIFICATION REVIEW Representative Models: Description, Isometric Drawings and Summary of Analyses (26 models) by Bechte . Procedure to Evaluate the Adequacy of the As-Built Configuration of Seismic Category I Cable Tray Supports (EP-2-058) By Teledyne Engineering Service . Evaluation of Seabrook 1 Unit Cable Tray Supports. Documents No. CI-143,
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CI-144, CEVA-152, MSFW "A" - 150 and PAB-13 . Cable Tray Evaluation Criteria - Switchgear Room (8224-04-CRT-01) By EQE In . Seismic Analysis of Safety Related Cable Tray Supports In Longitudinal Director Inside Switchgear Room, N-W Quadrant.
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