ML17261A574
| ML17261A574 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/30/1987 |
| From: | Gregg H, Varela A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A572 | List: |
| References | |
| 50-244-87-11, IEB-79-02, IEB-79-14, IEB-79-2, IEIN-86-094, IEIN-86-94, NUDOCS 8708060250 | |
| Download: ML17261A574 (46) | |
See also: IR 05000244/1987011
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244/87-11
Docket No.
50-244
License
No.
Priority
Category
C
Licensee:
Rochester
Gas
and Electric Cor oration
49 East
Avenue
Rochester
Facility Name:
R.
E. Ginna Nuclear
Power Plant
Inspection At:
Rochester
and Ontario
Inspection
Conducted:
Ma
5-8
1987
Inspectors: '
Yarela,
Lea
Reactor
Engineer
~/ 30 /f87
dat
signed
NRC Contract Personnel:
M.
E. Nitzel,
EG & G Idaho,
Inc.
M. J. Russell,
EG L G Idaho,
Inc.
Approved by
H. I. Gregg, Acti g Chief, Materials
and
Processess
Sectio
,
EB,
aL,
~~ /0'~7
date
signed
Ins ection
Summar
Inspection
on May 5-8,
1987 (Inspection
Report
No. 50-244/87-11
Areas Ins ected:
A special
announced
inspection
by a regional-based
inspector
and two contractor
personnel
was conducted at the licensee's
engineering office
and the
R.
E. Ginna plant site.
The inspection
encompassed
review of licensee
actions
in response
to NRC/IE Bulletins 79-02,
Pipe Support
Base Plate
Designs
Using Expansion
Anchor Bolts; 79-14,
Seismic Analysis for As-Built Safety-
Related Piping Systems;
and review of design analysis
and work performed in
modifications affected
by these bulletins.
Results:
Two deviations
were identified.
87080b0250
870730
ADOCK 05000244
6
DETAILS
Persons
Contacted
Rochester
Gas
and Electric Corporation
(RGE)
- R. Davis,
QA Engineer,
Design
"A. G. Goetz,
Manager Construction
Engineering
"J. Hotchkiss,
Construction
Engineer
- M. Lilley, Mechanical
Engineer
"R.
C. Mecredy, Director Engineering
Services
- B. A. Snow, Superintendent
Nuclear Production
- R. E. Smith, Chief Engineer
"LE Sucheski,
Senior Mechanical
Engineer
- E. Voci, Senior Mechanical
Engineer
- G. Wrobel, Senior Nuclear Engineer
C.
R. Anderson,
Manager Quality Assurance
+J.
C. Bodine,
Nuclear Assurance
Manager
+N. L. Goodenough,
Engineer'T.
Marlow, Manager Maintenance
D. Morgan, Mechanical
Engineer
J.
C. Hutton,
Manager Mechanical
Engineering
+K. Nassauer,
QC Super visor
G. St. Martin, Liaison Engineer
J.
A. Widay, Technical
Manager
Ginna
+P.
C.
Wi lkens,
Manager Nuclear Engineering
+S. Spector,
Superintendent
Ginna Production
Bell Power
+J. Gashlin, Quality Assurance
Manager
NRC Contractor
EGEG Idaho
Inc.
"M. E. Nitzel, Engineering Specialist
- M. J. Russell,
Engineering Specialist
- Attendees
at exit meeting
on May 8,
1987.
+ Attendees
at plant meeting
on May 7,
1987.
Ins ection Pur ose
And Sco
e
The purpose of this inspection
was to review at the corporate office and
the plant the completeness
of the licensees
responses
to 'NRC/IE,Bulletin 79-02,
Pipe Support
Base Plate
Designs
Using Expansion
Anchor Bolts,
and
Seismic Analysis for As-Built Safety Related
Piping
. Systems.
The scope of the inspection
included
a review of engineering
design
and quality assurance
documentation
relating to inspection,
testing,
analysis'and
modifications satisfying requirements
and licensee
0
commitments with respect
to the= bulletins.
A walkdown inspection of the
plant verified the acceptability of repairs and/or modifications relating
to the bulletins.
Review Criteria
R.G.E.'s
responses
to the bulletins identify licensee
commitments to
requirements
of IEB 79-02
and 79-14.
These
responses
are listed in
Table
1.
Additional confirmation of licensee
commitments is found in
Table
2 where documentation
of licensee
actions relating to the bulletins
confirm his intent to comply with the
NRC initiative for plant safety
identified in the bulletins.
In addition,
PRC Temporary Instructions
(TI) 2515/28
and 2515/29 were
used to further define inspection
criteria.
Review Of Licensee
Res
onses
The inspection
team reviewed bulletin responses
available
from NRC files
prior to the inspection.
These
responses
included reports addressing
the
reevaluation
methodology,
acceptance
criteria, field inspection
and
testing information, nonconformance
information,
proposed modifications
plans,
and modification schedules.
Table
1 lists those
documents
reviewed
prior to the inspection.
Any items requiring further discussion
were
noted
as items to be addressed
while at the corporate office or plant
site.
guestions
relating to licensee
responses
were forwarded to licensee
in advance of the inspection
as preliminary agenda for discussion.
These
are identified in Table 6.
The inspection
team reviewed additional
material
provided by the licensee
during the inspection.
This material
consisted
of engineering
procedures
used to control various aspects
of
engineering
and plant modification work, piping system
seismic analysis
results, as-built drawings of piping system
geometry
and pipe supports,
nonconformance
report
(NCR) disposition documentation,
concrete
anchor
bolt inspection
and testing records,
maintenance
work orders associated
with piping support maintenance
work, and construction
work package
documentation
for piping support modifications.
The pertinent
documents
reviewed are listed in Tables 2, 3, 4,
and 5.
~Findin
s
Two deviations
were identified,
as described
below:
Supplement
Number
1 to Revision
1 of Bulletin 79-02 allowed interim plant
operation if two conditions were met.
These were:
. a.
For the pipe support
as
a unit, the factor of, safety
compared to
ultimate strength is equal
to or greater
than two.
For the anchor bolts, the factor of safety is equal
to or greater
than two,
and for the support steel
the original design factor of
safety
compared
to ultimate strength is met.
This supplement further
specified that "Any support not satisfying the criteria should
be
considered
as inoperable
and the Technical Specification action
statement met....."
and, additionally required that the affected
systems
be returned to the required margins of safety
as identified
in the Tech Specs.
Action Item 2 of Revision
2 repeated
Revision
1
requirements
that the licensee verify that the concrete
anchor bolts
have
minimum factors of safety of 4.0 for wedge type anchors
and 5.0
for shell
type anchors.
These safety factors will ensure
acceptable
margins of safety for continued operations
During the inspection it was found that the licensee's
"Calculation
Procedure
For IE Bulletin 79-02" (developed
by their consultant,
Gilbert/Commonwealth)
stated
in Section I that "No calculations to
determine bolt factors of safety were performed unless
a modification
to the support
such
as bolt relocation
was made."
Further, it was
found that actual
loads
were not
known or determined
for all sup-
ports.
Accurate
load information is required data for the determi-
nation of the concrete
anchor bolt factor of safety calculations.
By
not determining
accurate
support
loads which would enable
the cal-
culation of accurate
concrete
anchor bolt loads,
the appropriate
factors of safety for all anchor bolts could not be
known.
This
situation resulted in plant operation for extended
periods of time
with systems
subject to bulletin action not demonstrated
to be in
compliance with bulletin requirements.
RGE committed to the bulletin. and its revisions in the July 6,
26
and December
7,
1979 responses.
In these
responses
the licensee
committed to address
the Bulletin action items
as part of their
seismic
upgr'ade
program.
However, during this inspection it was
determined that certain
systems
subject to bulletin action were not
included in the seismic
upgrade
program.
The licensee
could not
determine
whether accurate
factors of safety were calculated for all
anchor bolts in the systems
not included in the seismic
upgrade
program.
Thus,
the licensee did not satisfy,
per their commitment,
the actions required in IEB 79-02 Action'tem 2.
Since all anchor
bolt factors of safety were not known, the licensee
could not have
known if technical
specification action statements
should
have
been
followed.
The above situation is
a deviation from the licensee's
commitments in response
to Bulletin 79-02 (50-244/87-11-01).
Action Item 4 of IEB 79-02 requires that each concrete. anchor bolt
used in piping system
supports
must be inspected
to veri.fy:the
correct installation unless it can
be established
that tension
loads
do not exist.
The inspection
team found that
some supports with
concrete
anchor bolts were not inspected
due to
a compression-only
load situation.
However, it was identified that due to modifications
subsequently
performed
on the service water screen
house
and the
standby
aux feedwater piping systems
some of these
compression-only
supports
had load changes
such that tension
loads could
now be
possible.
The licensee
was asked to provide the following
information:
a
~
A review of the supports
on all systems
subject to IEB 79-02
which discloses
the identity of all supports that originally
were not inspected
but which are
now subject to tension loading
and
have not been further modified and evaluated
as part of the
seismic
upgrade
program.
b.
Document'ary evidence
showing the completion of the required
inspections
to verify proper installation of anchor bolts.
In
a telephone'onversation
on
May 22,
1987,
the licensee
confirmed
that five supports
were found to have
been modified so as to be
subjected
to tension
loads
and
had not had the concrete
anchor bolt
inspections
as required
by bulletin 79-02.
The licensee's
original
bulletin response
action of omitting the bolt inspections
for these
five supports
was acceptable
per the
IEB 79-02 requirements if the
anchor bolts were subject to compression-loads
only. It was also
observed
that" the licensee's
procedures
governing installation
and
inspection of Seismic Category I pipe supports
require inspection of
anchor bolts when
a
new support is installed or an existing support
is modified.
The inspectors'eview
disclosed that these particular
supports
were not modified, only their loads
changed
dus to the
piping system reanalysis
and modification of other supports
on the
systems.
However, bulletin compliance
must
be maintained if the
systems
subject to bulletin action are later modified.
This was
committed by the licensee
in his response
of July
6 and
December
7,
1979.
The failure to inspect the concrete
anchor bolts in these
supports
subsequent
to the -system reanalysis
and modifications which
the licensee
performed
as part of their seismic
upgrade
program is
a
deviation from the licensee's
commitments
made in regard to
IEB 79-02 Action Item 4 (50-244/87-11-02).
5.
Verification Walkdown Ins ection
A physical
inspection of a sample of piping systems
and supports
subject
to bulletin action
was conducted.
The piping and supports
shown in Tables
4 and
5 were examined.
Walkdown activities concentrat'ed'n
verifying that
the as-built conditions of the
sampled piping and supports
reasonably
matched
those
data
shown in the licensee's
walkdown results
and
used in
the reevaluation
calculations.
Examples of those
items spot checked for
IEB 79-14 duripg the walkdown include overall piping system dimensions,
valve location, orientation of valve operators,
support locations,
boundary conditions (support type, action direction and anchor effective-
ness),
and any attached
equipment
such
as instrumentation,
etc.
Examples
of those
items spot checked for IEB 79-02 during the walkdown include base
plate size, bolt pattern
symmetry, correct bolt size,
proper thread
engagement,
proper bolt installation,
and support geometry (action
direc-'ion,
member sizes,
weld sizes, etc.).
Findings:
No violations or unresolved
items were identified.
6.
Licensee Administrative Controls
and Assurance
of ualit
An inspection
was performed of licensee'
administrative
controls
and
'assurance
of quality in his activities relating to NRC/IE Bulletins 79-02,
Pipe Support
Base Plate
Designs
Using Expansion
Anchor Bolts and 79-14,
Seismic Analysis for As-Built Safety Related Piping Systems.
The
pertinent
documents
reviewed
and discussed
with cognizant licensee
per-
sonnel
are listed in Table 7.
Based
on the above examination
and review,
the inspector
concluded that the licensee
had not audited
the engineering
activities affected
by IEB 79-02.
Based
on criteria identified in the
bulletin such
an audit could have prevented
the deviations previously
addressed.
The licensee's
QA Manual
and
QA Procedures
Manual could be
improved in the area of addressing
requirements
imposed
by NRC/IE
bulletins.
7.
Conclusion
Based
on, the results of this inspection
and pending the licensee
response
to the two deviations in thi s report,
and 79-14 remain open.
An exit meeting
was conducted
on May 8,
1987 by the
NRC inspector.
At-
tendees
at the meeting
are listed in paragraph
1.
The
NRC inspector
summarized
the inspection findings and the licensee
acknowledged
these
comments.
Subsequent
to this meeting, after further review of documenta-
tion obtained during this inspection,
the licensee
was notified of the
revised inspection findingq in telephone
communication
of May 22,
1987.
No written material
other than that described
in paragraph
4 (preliminary
agenda for discussion)
was furnished to licensee
personnel.
Table
1 - DOCUMENTATION,REVIEWED PRIOR
TO INSPECTION
Document
Descri tion
EWR 2512
EWR-2441/2512A
Gilbert/Commonwealth
(G/C) Report For IE Bulletin 79-02.
Report dated
7-10-80.
r
L. White, Rochester
Gas
8 Electric (RGEE), letter to
B. Greir (USNRC, RI) dated 7-6-79 regarding
response
to IEB 79-02.
L. White letter to B. Greir dated
7-26-79 providing
additional
information regarding
L. White letter to B. Greir dated
12-7-79 providing
additional
response
to IEB 79-02.
B. Bell (G/C) letter to M. Lilley (RG5E) providing revised
pages
to G/C report
on IEB 79-02 covering untested
supports
in the spent resin tank room.
RGEE Design Criteria Ginna Station Seismic
Upgrade
Program,
Revision 2, dated 8-10-81.
L. White letter to B. Greir dated
7-31-79 providing 30 day
response
to IEB 79-14.
L. White letter to B. Greir dated 8-31-79 providing 60 day
response
to IEB 79-14.
L. White letter to B. Greir dated
10-30-79 providing
120 day response
to IEB 79-14.
L. White letter to B. Greir dated 8-25-80 providing
additional
information regarding
L. White letter to B. Greir dated 8-25-80 providing updated
listing of nonconformance
and evaluations
related to
previously submitted
LER 79-015/01T-0 regarding
RGEE 79-02/79-14 Inspection
and Repair
Program,
Revision 0,
dated 8-27-79 (addresses
"A" motor driven auxiliary
pump).
Table
1 - DOCUMENTATION REVIEWED PRIOR
TO INSPECTION (Cont'd)
Document
NRC/IE
NRC/IE
NRC/IE
NRC/IE
NRC/IE
NRC/I E
Descri tion
RGE QA Manual
Inspection
Report ¹50-244/83-18/IEBU 79-02 and 79-14
Inspection
Report ¹50-244/85-99/SALP
Inspection
Report ¹50-244/87-04
Inspection
Report ¹50-244/79-12
Inspection
Report ¹50-244/79-13
Inspection
Report ¹50-244/79-16
Table
2
DOCUMENTATION REVIEWED DURING INSPECTION
Document
Descri tion
NRC to
RGE letter dated 8-16-79 regarding
a
summary of
a meeting
held
on 7-24-79 to discuss
the licensee's
seismic
upgrade
program.
QAM
RGE Quality Assurance
Manual, Appendix A.
ME-129
RGE procedure
(dated 9-5-79) for the inspection of
wedge type concrete
anchors.
NDE-600-1
QE-302
RGE procedure
for the ultrasonic inspection of
ferritic pressure
piping.
RGE engineering
procedure for the preparation,
review
and approval of design analysis.
QE-301
QE-310
QE-311
QE-314
QE-1501
PT-PAE-570
RGE engineering
procedure for the preparation,
review,
and approval of design input documents.
RGE engineering
procedure
for 'design interface
control.
RGE engineering
procedure for the preparation,
review,
and approval of safety analysis.
RGE engineering
procedure for the review and approval
of A/E or consultant
prepared
design
documents.
RGE engineering
procedure for the engineering
review
of nonconforming material, parts,
or components.
0.
Meeuwis (Westinghouse)
letter to M. Lilley (RGE)
dated 9-27-84 regarding
the reconciliation of as-built
support information to piping analysis
models.
RGE internal
memo dated
3-31-87 regarding
NRC IE
Information Notice 86-94 regarding revised Hilti
Kwik-Bolt allowable loads.
Gilbert/Commonwealth "Calculation, Procedure
For IE
. ~
Bulletin 79-02" dated 5-7-79.
SDTAR-80-05-043
piping analysis report for main feedwater
problem
FW-300 '
0
Table
2 DOCUMENTATION REVIEWED DURING INSPECTION (Cont'd)
Document
SDTAR-80-05-044
SDTAR-80-05-056
SDTAR-80-05-071
81-27: RD
G-79-90
G-79-56
G-80-08
G-79-119
83-13:RD
180075
180077
GAI Report
No.
2078
Descri tion
piping analysis report for main feedwater
problem
FW-301.
piping analysis report for component
cooling water system
problem CC-100.
piping analysis report for component
cooling water system
problem CC-200.
RGE
QA audit report dated
10-21-80 regarding audit of
piping design
and analysis activities.
RGE pipe support tracking table (developed
by
J. Hotchkiss) dated 5-9-80.
Tabulated
status
of
IEB 79-02 activities in piping supports.
RGE nonconformance
report
(NCR) on
RHR system pipe
support
RH-16
~
RGE
NCR dated 7-19-79 regarding insufficient bol,t
length
on support
AFW-9.
RGE
NCR dated
1-11-80 regarding
anchor bolt shell
protrusion
on support
SWAH-38A.
Load Capacity
Data Sheet for Corner 5 Lada
Co. rigid
sway strut assembly.
RGE
NCR regarding
several
IEB 79-14 pipe system
geometry discrepancies
and their
dispositions'GE
QA audit report dated 5-13-83 regarding audit of
technical
service activities.
Ultrasonic examination
record (dated
2-13-87) of pipe
wall thickness
performed
as part of RGE in service
inspection (ISI) program.
I
Ultrasonic examination
record (dated 2-'13-87) of pipe
wall thickness
performed
as part of RGE in service
inspection (ISI) program.
GAI ( Final)
Summary of Evaluation of Piping Systems
and Supports,
Response
to IEB 79-14.
Table
2
DOCUMENTATION REVIEWED DURING INSPECTION (Cont'd)
Document
QE 1801
Report
Manual
EWR 3092
Descri tion
RGE Engineering
Procedure
Response
to Audits.
Hilti '," KWIKBOLT Concrete
Expansio'n'Anchor Bolt
Performance
Test at Ginna January
1987.
RGE Quality Assurance
Procedures.
June
12,
1986 Design Criteria Boric Acid Piping.
NRC letter to
RGE dated 3-24-87, Subject:
Safety
Evaluation Report
on the Structural
Upgrade
Program.
.RGE letter to
NRC dated
May 26,
1987,
Response
to
NRC
Comments
on the Structural
Upgrade
Program.
NRC Letter to
RGE Dated 01-29-82,
Subject:
Safety Topics III-6 and III-ll.
Table
3 - CALCULATI(H PACKAGES
REVIEWEO
~Ssters
CC
CC
~Su
or t
MK-CCU-143
MK-CCU-150
MK-CCU-89
MK-CCU-90
MK-FWU-22
MK-FWU-16
MK-FWU-42
Comment
Problem
CC-100
Problem
CC-100
Problem
CC-100
Problem
CC-100
Problem
FW-300
Problem
FW-300
Problem
FW-300
Note that piping support drawings
from thirteen different stress.
problems
were
examined
on
a cursory basis.
The samples listed above were chosen
from these
drawings for more detailed examination.
The selection
process
was based
on the
details of the individual supports
and relied
upon the analytical
and field
experience
of the inspectors.
Table
4
PIPING SYSTEMS
FIELD VERIFIED
~Sstem
<<
Analysis
Probl em
NS-300
FW-300
FW-301
AFW-100
AFW-500
AFM-200
RHR-400
SW-1010
CC-100
SW-1000
CC-200
SW-1120
Location
Intermediate
Bldg.
Intermediate
Bldg. and
Facade
Turbine Bldg.
Intermediate
Bldg.
Intermediate
Bldg.
Intermediate
Bldg.
Auxi 1 iary Bldg.
Auxi 1 iary Bldg.
Auxiliary Bldg.
Auxiliary Bldg.
Auxiliary Bldg.
Auxiliary Bldg.
Table
5 - PIPING
SUPPORTS
FIELD VERIFIED
~Sstem
SW
CC
MS
~Su
or t
MK-RHU-48
MK-SWU-195
MK-SWU-198
MK-CCU-143
MK-MSU-40
MK-CCU-150
MK-CCU-90
MK-MSU-39
MK-MSU-36
MK-FWU-49
MK-FWU-27
MK-AFU-30
MK-AFU-72
MK-AFU-62
MK-AFU-108
MK-AFU-123
MK-AFU-105
Analysi s
Problem
RHR-400
SW-1000
SW-1000
CC-200
MS-300
CC-200
CC-100
MS-300
MS-300
FW-300
FW-301
AFW-100
AFW-200
AFW-200
AFW-500
AFW-500
AFW-500
Table
6 - Re uest for Information
The following is
a list of preliminary requests
for information pertinent to
actions
taken in response
to the subject bulletin. It is planned that the
responses
to these
requests will be reviewed
and discussed
during the
inspection.
General
uestions
A
licable To Both Bulletins
1.
How was the overall engineering effort for response
to bulletin
requirements
organized,
coordinated,
and directed?
2.
How was
QA/QC involved in the overall effort to satisfy bulletin
requirements?
3.
What AE consultant firms (if any) were used to develop bulletin responses?
What was the extent of their involvement (scope of work)?
4.
What personnel
qualifications and/or special training was provided (or
required) for licensee
and/or consultant
personnel
involved in bulletin
response
work?
Provide documentation
of QA oversight/audits
of all contract organizations
involved in bulletin actions.
6.
What document or procedure
was
used to identify systems
subject to
bulletin action?
Provide
a copy for review.
7.
What procedure
was
used to define inspection
elements
and control walkdown
activities for each bulletin?
Provide
a copy for review.
8.
Describe
the acceptable
tolerances
that were used (e.g.
system
geometry,
support location, etc. for 79-14; weld size, bolt pattern
symmetry, etc.
for 79-02).
9.
Information regarding piping systems
(79-14)
and supports
using concrete
anchor bolts (79-02) from all systems
subject to bulletin action should
be readily available;
however
due to the large
number it is expected that
a sample will be audited.
The following systems
have
been
chosen
as the
preliminary candidates
for audit:
(SW)
(AFW)
Residual
Heat
Removal
(RHR)
(MS)
Feed Water
(FW)
Component Cooling Water
(CCW)
For the subject piping and supports
from the systems
above provide the
following information:
a.
Marked
up "walkdown sheets"
or other first generation
documentation
showing the results of the field inspections,
b.
Current as-built piping isometrics
and current as-built support
drawings (all supports,
no limited those
using concrete
anchor
bolts),
c.
Piping analysis of the
systems listed above,
d.
Structural analysis (including base plate
and anchor, bolt
calculations) of the subject
supports
(79-02)
from the
systems
listed above,
e.
Modification oackages
(where applicable).
Modification packages
should include all stress
calculations,
design/construction
drawings,
gC documentation
and
any other pertinent information such
as
nonconformance
reports
(NCR's)
and their dispositions that
may exist.
Note that the inspectors
reserve
the option to add other
systems
to those
listed above.
This will be done during the inspection
as conditions
dictate.
10.
What procedure is used to control
and perform calculations?
Provide
a
copy for review.
11.
Describe
the procedure(s)
used to control additions to or changes
in the
configurations of the piping systems
and supports
subject to bulletin
action.
Provide copies for review.
12.
What procedure
was used to control
nonconformances?
Provide
a copy for
review.
13.
List all computer
codes
used
in the reevaluations
or reanalysis.
Also,
identify which groups or organizations
used
them.
14.
Were all computer
codes
used
"benchmarked?"
If so, provide documentation.
15.
What procedure(s)
were
used to assure
that computer
codes
were used
properly to obtain accurate
results?
Provide copies for review.
16.
How many modifications were required to meet all bulletin action items?
Provide
a breakdown for each bulletin.
17.
When did the
RGE quality assurance
(gA) program formally adopt the
provisions of 10 CFR 50, Appendix
B?
18.
How was the response
to these,two bulletins integrated with activities
required
by the Systematic
Evaluation
Program?
0
i
19.
Provide
a copy of the governing engineering
procedures
in effect at the
time of the bulletin response activity.
These
are for reference
use
during the inspection.
uestions
Dealin
Primari 1
.With Bulletin 79-02:
20.
What procedure
was
used to define base plate flexibility?
How was this
incorporated
into the support analysis?
Provide
a copy of the procedure
for review.
21.
Were procedures
ISI-9, Rev.
5,
and ISI-9, Rev. 3, the only ones
used to
define
and control the anchor bolt testing
program?
If not, provide
a
copy of all other applicable
procedures
for review.
22.
Provide
a samples of the results of the anchor bolt tests.
Samples
should
be taken from the previously listed systems.
23.
Apparently, all anchor bolts were not tested.
What was the statistical
basis of the anchor bolt testing
program?
Provide
a table
showing
how
many concrete
anchor bolts were located in each subject
system
and
how
many in each
system
were tested.
24.
How many supports
were determined
to reside
in each category
below?
F.S.
< 2.0
2.0
< F.S.
< 4.0
F.S.
> 4.0
25.
For those
supports
using concrete
anchor bolts directly in rolled steel
shapes
without base plates,
provide:
a.
A list of the systems
involved,
b.
The number of such supports
in each
system (include support mark or
identification and drawing),
c.
Type of anchor bolts used in each
case,
d.
Detailed description of the procedures
and methodology
used for the
evaluation of the structural
adequacy of the supports.
26.
Provide
samples of nonconformances
that resulted
from bulletin activity.
The related dispositions
should also
be provided.
Samples
should
be taken
from the systems listed above if possible.
27.
EWR-2441/2512A (79-02/79-14 Inspection
and Repair Program),
Rev.
0, dated
8-27-79 refers to
an attached list of supports
which includes
a status
column (inspect/repair/evaluate).
No reference
is made to an inspection
procedure
such
as ISI-9.
What procedure
and/or process
was
used to
determine
the status
of the supports
shown
on the list?
This document
r
appears
to be Written specifically for the "A" Motor Driven
AFW piping.
Was
a similar document
prepared
for each
system subject to bulletin
action?
If not, what special'onditions
required it for this system?
guestions
28 through
36 refer to the Gilbert/Commonwealth
"Report For IE
Bulletin 79-02" dated 7-10-80.
28.
In section 2.0 it is stated that "All shell type anchors
were replaced
with Hilti wedge type bolts of equal
or greater capacity."
However,
section
3.0 proceeds
to describe
the testing of shell type anchors
and
section
4.0 implies that shell
type anchors
were found acceptable
and
left in place.
a.
Clarify whether all shell type anchors
were replaced
as stated
in
section 2.0.
b.
If shell type anchors
remain installed,
confirm that
a minimum factor
of safety of 5.0 is maintained.
29.
Provide the "trouble card procedure"
referred to in section 4.0.
30.
Section 5.0 states
that "Those supports with deficiencies
found during
testing
were submitted for engineering
evaluations
"
Does this mean that
all supports
were not evaluated
to ascertain
that the required factors of
safety are present?
31.
Section 5.0 states
"For supports with only one load given, that load was
used to calculate
the factor of safety.
If no loads
on
a support were
available,
a unit load was applied in all applicable directions."
a.
Clarify how a support could be installed in
a piping system with no
known (or available)
load.
b.
Clarify how using only one load or a unit load assures
adequate
margin to achieve
the required factors of safety
when other loads are
~
applied.
c.
Justify the acceptability of these
approaches.
Why weren't the
calculated
loads for the individual supports
used to determine
the
actual
factors of safety for all supports.
32.
Provide
RGEE Mechanical Specification
ME-129
33.
Provide
RGEE
NDE procedure
NDE-600-1.
34.
Section 3.0 states
that "Tension testi'ng for shell type was accomplished
for the most part by di rect pull utilizing a load cell and coupling
hardware."
This section further states
that torque testing
was used in
areas
where anchor accessibility precluded
the
use of the load cell
equipment.
Procedure
ISI-9. 1,
Rev. 3, does
not provide details regarding
the load cell equipment.
(
~
'3
a.
Clarify the extent of direct pull testing versus
torque testing.
b.
Describe in detail
the load cell equipment
used.
c.
Provide the procedure
governing the field use of this equipment.
35.
Procedure
ISI-9. 1,
Rev.
3, requires that
a
gC inspector
be
a part of the
test
team (see
section 3.0 of procedure)'.
Procedure
ISI-9,
Rev.
5, does
not have this requirement.
Why not?
Describe
the
gC measures
applied to
the actual field testing
done under procedure
ISI-9,
Rev,
5.
36.
Section 6.0 states
that
556 supports
required
no testing.
Does this mean
that these
supports
do not use concrete
anchor bolts?
If these
556
supports
do contain concrete
anchor bolts, clarify the basis for not
testing
them.
37.
Section
2.e of the 7-6-79 White
Greir letter states
that "Verification
of the factor of safety for all Seismic Category
I support anchor bolts
will be established
through the reanalysis
program described
above."
(the
program
was the seismic reevaluation
program)
Have all concrete
expansion
anchor bolts been
shown to have the required factors of safety using the
latest
support
loads
and accounting for base plate flexibility?
38.
Section 4.d of the 7-6-79 White Greir letter states
that following
installation the replacement
anchor bolts will be tested with increased
loads
due to base plate flexibility.
Provide
samples
of documentation
showing successful
completion of such tests.
39.
Table
1 in the 7-26-79 White - Greir letter provides
a sample of
calculated factors of safety for 10 "typical" supports.
Support
SWAH-19
was chosen
as
a spot check of this table.
The sketch of this support
attached
to the subject letter indicates that 0.75 inch nominal size Hilti
Kwik-Bolts with five inches
(minimum) embedment
are used.
Table
1 lists
bolt capacities
of 26880
pounds for both tension
and shear
and
a resulting
factor of safety of 5.8 assuming
a rigid base plate.
Consultation to a
1981 Hilti catalog indicated that average
ultimate capacities
for a
0.75 inch Kwik-Bolt with five inches
embedment
in 4000 psi concrete
were
16500 lb in tension
and
17133 lb
in shear.
Using the loads
shown in
Table
1 and the Hilti catalog values gives
a factor of safety of 3.63
(linear interaction formula) not the 5.8 value calculated
by the licensee.
Increasing
the given loads by 24% to account for the
maximum probable
prying effects
as discussed
in the licensee's
7-6-79 submittal
would yield
a factor of safety of 2.93.
Both of these
values are below the required
factor of safety of 4.0 for wedge type anchors.
e
a.
Clarify the interaction relationship
used in the reevaluations
of the
supports
subject to bulletin action.
b.
Clarify the origin of the bolt capacity values
used for all types
and
sizes of concrete
anchor bolts
and justify their applicability.
~
c
~
ss
~
40.
The 12-7-79 White - Greir letter states
that four supports
were found
attached
to concrete
masonry walls'rovide documentation
showing the
original (as-found) configuration
and the as-modified configurations of
these
four supports.
41.
Action Item
7 of IEB 79-02 required reanalysis
of supports
to include base
plate flexibility and appropriate
factors of safety to be completed
by
November
15,
1979.
The licensee's
7-6-79,
and 12-7-79 submittals
do not
indicate that
a complete effort was accomplished.
Was
a formal agreement
with the
NRC established
that allowed
a schedule
extension?
If so,
provide documentation.
uestions
Dealin
Primaril
With Bulletin 79-14:
42.
Was visual approximation
used in the walkdown/as-built effort? If so, to
what extent?
43.
Item 1.d in the 8-31-79 White Greir letter states
that "Attachment
2
describes
the methods of inspection,
evaluation,
and nonconformance
control
used for piping inside containment."
What procedures
and methods
were
used for piping outside
containment?
How do these differ from those
used inside containment?
44.
Referring to section 2.2.c of Attachment
2 to the 8-31-79 White - Greir
letter - were the support drawings for the supports
described
in this
section
changed
to the as-built condition?
List examples for review.
45.
Provide
samples of nonconformances
that resulted
from bulletin activity.
The related dispositions'should
also
be provided.
Samples
should
be taken
from the
systems listed above.
In particular,
provide information on the
following NCRs:
NCR-G-79-119-1
-2
-5
-6
"7
-90
-119-11
,-12
-14
-21
~Sst em
RCL
RCL
SI
Cont.
Spray
'
l
46.
Provide the
NCRs and disposition information covering the following
supports
as listed in Section
2.
of= the 10-30-79 White - Greir letter:
~Su
ort
~Sstem
MS-136
SIH-34
SIH-75
S IH-100
SIH-3
ACH-52
ACH-38
SIH-28
749A
???
ACH-115
SWAH-33
???
FWH-52
MS
SI
SI
RHR
Cont.
Spray
CCW (valve 749A)
CCW (pipe routing not per design
see
page
8 in letter)
SW (See
page
13 - three
ACH supports
on
guestions
47 through
52 refer to
EWR 2512,
Rev.
2, "Design Criteria. Ginna
Station Seisimic
Upgrade
Program" dated 8-10-81
'7.
What is meant
by "appropriate distance
and/or
number of supports"
in
section
1.2. 1.6.27.
48.
In section
6. 1.2 it appears
that the licensee
is attempting to utilize a
later code version without also utilizing certain
more stringent stress
intensification factors.
This "bes. of both worlds" approach
has not been
acceptable
in the past.
Did the
NRC specifically review and approve this
section
and approach?
If so, provide documentation clearly showing
such
approval.
49.
Section 7.0 refers to the "Analysis and Design Conditions Documents."
Provide these
documents
for review and reference.
50.
Section
31. 1.3 states
that damping values
are in conformance with
however,
section 8. 1.4 states
that
4% damping will
be
used
used for the large pipe
SSE load case.
4% damping is not in
agreement with RG 1.61.
Justify the use of this higher damping value.
51.
How were support
loads
combined - absolute
sum, algebraically,
or another
method?
52.
Provide copies of the response
spectra
curves
used in the reanalysis for
reference
during the inspection.
C
Tabl e
7
RGE Audits of Plant Modifications Activities b
Contractor
Bell/Sch'neider
Date
May 1979
~Re art Ro.
79-18:CA
~Sco
e
Quality Controls for
conducting modification
activities.
May 1980
February
1981
80-25:CA
81-04:RD
Verification of modification
procedures.
Turnover of modifications
and
implementation of plant
procedures.
May 1981
81-13: RD
Observations
of activities
in progress.
Examination of
completed work, review of
documents
and records.
December
1981
May 1982
81-35: RD
82-12: RD
Indoctrination
and training,
modification package
revision
and turnover, material
control, records,
QA program
review, corrective actions.
Station modification
procedure
preparation,
drawings
and document
control, construction
and
material control.
August
1982
82-28:RD
PORC review,
SM procedure
completion, Modification
turnover, Modification
activities by B/S during
Refueling Outage.
April - July 1983
83-29:RD
Activities in progress
during
Plant Outage.
November
1983
83-45:RD
Of Modification activities,
accomplished
in accordance
with established
procedures
and,
QAP Response
to
NRC
inspection findings.
C c'
Table
7
RGE Audits of Plant Modifications
Cont'd
Date
~Re ort
No
~Sco
e
Apr i 1
June
1984
84-18: RD
Modification Activities:
Installation,
Turnover, Test
Control, Nonconformance
Resolution/Implementation
of
Six Point Modification
Improvement
Program.
1984
84-52:RD
Minor modi fi c at ion desi gn
activity control s.
1985 Outage'5-17:RD
Modification controls.
RGE Audits of Partici atin
Technical
Services
Com anies
8
Westin
house
8
Gilbert/Commonwealth
June
1980
80-26:KE
October
1981
81-27: RD
March 1983
83-13: RD
November
1985
85-54
RD
September
1979
March 1980
August
1981
September
1983
September
1986
79-21: KE
80-13: KE
81-22:RD
83-32:RD
86-47:RD