ML18033A580
| ML18033A580 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/26/1987 |
| From: | Peters A TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 22000, 22000-V02-R03, 22000-V2-R3, NUDOCS 8902150214 | |
| Download: ML18033A580 (90) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLTE2 ENGINEERING CATEGORY SUBCATEGORY REPORT 22000 SUPPORT DESIGN GENUG.
UPDATED TVA NUCLEAR POWER.'
.p)0.g-0 iA p>rr( ~70 PDR
't."C
ADoci'5000 P
~O
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE.
SUBCATEGORIII REPORT FOR ENGINEERING TITLE:
SUPPORT OESIGN GENERAL REPORT NUMBER:
22000 REVISION NUMBER: 3 Page 1 of 30 ON OR R VISION:
l.
Revised to incorporate SRP and TAS comments.
2.
Revised to incorporate Bellefonte corrective action plans and SRP comments.
3.
Revised text and Attachment 8 to incorporate SRP and TAS comments and added Attachment C (References).
R ARA N
N R
ro/s e7 OA P
R V
W OMM
/o-p-87 lo-zz-87 CONCURREN S
SIGNATUR CEG-H:
SRP ro-z~ -~g 5
GNATUR DADD APPROV D BY ECSP MANAGER 0 TE MANAGER OF NUCLEAR POWER OATE CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
~I
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page ES-1 of 1
EXECUTIVE
SUMMARY
The concerns of Subcategory Report
- 22000, Support Oesign General, deal mainly with the design adequacy of pipe supports.
Other related issues in this subcategory report include design change control, technical decisions made by Construction, and technical review by Engineering.
The findings confirm that the only issue of. major significance is the adequacy of pipe support design.
The evaluation team examined both the design criteria and individual pipe support calculations.
The pipe support design criteria for all four plants were found to adequately address the necessary seismic design requirements, with the exception of one Browns Ferry criterion, which did not include the deflection/rigidity requirement.
This requirement will be implemented'in the individual pipe support calculations under the Browns Ferry calculation verification review program, and the criterion will be revised to include the requirement.
The pipe supports reviewed by the evaluation team for all four plants were found to be adequately designed based on applicable design criteria, with the exception of four (of 28 reviewed)
Watts Bar pipe supports that did not meet code stress allowables.
Some calculation documentation was found to be incomplete or irretrievable, or contained minor discrepancies and inadequate documentation of engineering judgment.
The rest of the related issues were found to be either technically insignificant or invalid.
Significant technical or safety problems are not apparent from this evaluation for Sequoyah, Browns Ferry, or Bellefonte.
- However, TVA has identified the need for better documentation (of analysis, engineering judgment, test data, etc.) in the area of pipe support design, and has initiated corrective action to improve the documentation.
In addition, an extensive effort is underway at Watts Bar, Browns Ferry, and Sequoyah to locate or reperform the pipe support calculations that were irretrievable.
The four Watts Bar supports that do not meet code allowables are of technical significance.
However, Watts Bar has committed to reevaluate and, if I
necessary, modify these supports.
All Watts Bar calculations for engineered pipe supports will be reevaluated under the Hanger and Analysis Update Program.
The corrective action plans provided by TVA are found to be acceptable by the evaluation team to resolve the negative findings.
The causes identified and other evaluation results are being examined from a wider perspective in the Engineering Category evaluation.
2670D-R13 (10/07/87)
0 0
0
'Preface, Glossary.
and List of hcronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUNSER PAGES, REVISED REASON FOR CURRENT REVISION To clarify that one or more attachments will help the reader find where. a particular concern
'is evaluated
~ ~ ~
~
~
~~
4 lr tl
~
TVh BtPLOYEE CONCERNS SPECldL PRQGBdN REPORT NIAtBEL
'2/)00'RONT HATTER REV:
3 PhGE i QF viii Preface This subcategory repoct, is one of 'a Ser'les of, repocts prepaced foc'the Employee Concecns Special Program (ECSP) of the Tennessee Valley huthority (TVh).
The ECSP and the organisation which caciried out the pcog',ram,
'the Employee Concerns Task Group (ECTG),
vec'B established by TVh's Nanagec of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February',
1986.
Concerns filed aftec t'hat date are handled by the ongoing ONP Pmploy'ee Concecns Program (ECP).
'he ECSP addressed over 5800 employee c'oncerns.
Each of the concerns'as a
formal, vritten, description oC a circumstance oc circumstances that an employee thought vas unsafe, unjust,~iniefficient, or inappropriate.
The mission, of t'e Employee Concecns Special P'rogram was to thoroughly'nvestigate all issues presented in the',concerns and to report the cesul;ts of those lnvestigcitions in a form iacdesisible to OMP employees, the
- NRC, and the general public.
The results df the'ae inles'cigations are communicated by fouc levels of ECSP reports:
- element, subcategory, category,',
add 'Cidal.
Element reports, t:he lowest reporting level, vill be published bnlII t'oc'those concerns ditectly affecting 'th* rhst'act of Sequoyah Nuclear Plant's reactor unit 2.
hn element consists of one oc'ore closely related issues.
dn issue is a potential.
pc'oblem identified by ECTG ducing the evaluation process as having been raiised in one oc more concerns.
Fdc efficient handling what appeared to be similac concerns wore grouped into elements ear!Ly in the program, but issue deflniItions emerged Crim She evaluation process itself'.
Consequently some elements did inc!Ludle only one issue, but often the ECTG evaluation found raoce than one issue pec element.
Subcategory repiocts surmaacizo the evaluiation of a number.
of eleven'ts.
- However, the subcategory report does more than collect element
!Level evaluations.
The subcatogocy. level ovorviev of element findings leeds to
'n integration of infociaation that cannot take place at the element level.'his integration of information ce'veals'h'e c'ixti'ant to vhich problelms overlap more than one element and will hherefoce require corrective action'oc underlying causes not fully appac'only at t'.he'l'erne'int level.
To mako the subcategory reports easilr ito undecIsta'nd, three ite6s ha0e 6ee'n placed at thai front of each report':
'a jproface, a glossary of the termino!Logy unique to ECSP repocts',,
and' list of 'acronyms.
hdditiona11y, at the ond of each s'ubr'atogocy report wil'1 be: a Subcategory
'ummacy Table that includes the co'ncdrn'u'mb6cs',
iderLtifies othI.r subcategories that share a concern';
)os]gnatos. nuclear safety-rklatek, safety significant, oc non-safety re at)d co)ceIcns,';
designates genera,c applicabixity; and briefly states ea h concern.,
Either I'.ho Subcatogor Su mmary Ta o
o t
i enabI e the r<Iader to i find i
c th s
i edb
.th e concern i.s evaluated.
TVk ENPLOYEE CONCERNS SPECZhL PROGKià REPORT NUNBER:
22000 FRONT NhTTER RE%:
2 PhGE ii OP viii 0
The subcategories are themselves summarized in a series of eight category
.reports.
Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction material control operations quality assurance/quality control welding engineering h separate report on employee concerns dealing with specific conte'ntions of intimidation, harassment, and wrongdoing will be released by the TVh Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in, all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
h final report will integrate and assess the information collected by all of the lower level reports prepared for the
- ECSP, including,the Inspector General's report.
For more detail on the methods by which ECTG empl'oyee concerns were evaluated and reported, consult the Tennessee Valley huthority Employee Concerns Task Group Program Nanual.
The Nanual spells out the program's objectives,
- scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and closeout of the issues raised by employee concerns.
TVk ENPLOYEE CONCERNS SPECIhl>
PROGRkPI REPORT NUNBER:
22000 FRONT NETTER REV:
2 PAGE iii OF vii,i ECSP Gi.OSShRY OF REPORT TERMS~
classification of evaluated issues the hvalua'tion of an issue leads to one of the following deteaninations:
Class h:
Issue cannot be verifidd. ks fac'tuel Class B:
Class C:
Issue i.s factually accdraL'e,'u't what, is described is not a
problem (i.e., not a condjition requiring corrective kction)
Issue's factual and identifies a problem, but corrective 'action for the problem was initiated before the evaluation 6f She'ssue was undertaken Class 0:
Issue is factual
<<nd pr'eilnts a prob'Rem for which correl tive',
action has beenor's
- being, taken as a result of a6 ekaluak.ioh Class E:
h problem requiring corrective action, which was not'. iden'tified by an employee
- concern, but was revealed durihg the ECTO>
evaluation of an issue raisid by an employee concern.l collective
~si nificance an analysis which determines the importance and;'onsequences of the findings in a particular ECSP report by puktidg thyrse findings in the proper perspective.
concern (see "employee concern"}
corrective action steps taken to fix,specific deficiencies or disc&ep'anc'iek revealed by a negati.ve findi,ng an'd,
'wh/an 'necessary, to correct causes i,n order to prevent recurrence.
k
'uality which ONP imposes on itself (see also "requirement" ).
element or element r~e ort; an optional level of ECSP;report, below
('.he subcategory level, that deals with one or more'is'sues.
circumstances that an employee thini.s (sns'afk, Janj'ust,
'inefficient or inappropriate; usually documented'n a K-form or a form equi.valent to the'-form.,
TVh EMPLOYEE CONCERNS SPECZhL PROGRhN REPORT NUNBER:
22000 PRQNT lGlTTER REV:
2 PhGE iv OP viii evaluator(s) the individual(s) assigned the responsibility to assess a specific grouping of employee concerns.
~findin s
includes both statements of fact and the judtments made about those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation
- process, raised in one or more concerns.
K-form (see "employee concern")
evaluation judgment or decision may be based.
root cause the underlying reason for a problem.
>Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Nanual (e.ges generic, specific, nuclear safety-related, unreviewed safety-significant question).
~.
~
~
+
'mW<<s<<<<
~
~ ~,u ~ <<&W4w<<
r' a
TVA El1'PLOYEE CONCERNS SPEC'IAL PROGRAM REPORT, NUNBER '2000 PRONT IlL1TER REV:
2 IO PAGE v OF viii hcronyms AI A!SC Administrative Instruction American Institute of Steel Construction ALARA hs Low hs Reasonahly Achievable ANSI ASNE'STN AMS CAQ CAR CATD CCTS CEG-H CFR CI CFTR COC OCR DNC hmecican Nucleac Society American National Standardls Institute American Society of 1'biochemical Engineers American Society foc Testing and Naterials American 01olding Society Browses Forcy Nuclear Plant.
Bollofonte Nuclear Plant Condition Adverse to Quality Corroctivo Acti'on Report Corroctivo Action Tracking Document Corporate Commitmont Tracking System Catogory Evaluation Group Head Code of'odot al Regulations Concornod Individual Cortifiod Natorial Tost" Report Cortificato of ConformancelCompliance Design Change Request.
Division of'ucloar Construct;ion (see also NU CON) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAN REPORT NUMBER:
22000 FRONT NATTER REV:
2 PAGE vi OF viii ONE DNQA DNT DPO DR ECP ECP'-SR ECSP EEOC ENRT EN DES ERT FSAR FY HCI HVAC INPO IRN Division of Nuclear Engineering Division of Nuclear Quality Assurance Division of Nuclear Training Department of Energy Division Personnel Officer Discrepancy Report or Deviation R'aport Engineering Change Notice Employee Concerns Program Employee Concerns Program-Site Representative Employee Concerns Special Program Employee Concerns Task Group Equal Employment Opportunity Commission Environmental Qualification Emergency Hedical Response Team Engineering Design Employee
Response
Team or Emergency
Response
Team Field Change Request Final Safety Analysis Report Fiscal Year General Employee Training Hazard Control Instruction Heating, Ventilating, Air Conditioning, Installation Instruction Institute of Nuclear Power Operations Inspection Re)ection Notice
TWA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
'2400'RONT MATTER REV:
2 PAGE vii OF viii, L/R M&AI MI MSPB NCR NOE NPP NPS NQAM NRC NSB Labor Relations Staff, Modifications and Additions Instruction Maintenance I:nstruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual.
Nuclear Regulatory Commission Nuclear Services Branch NSRS NU CON NUMARC OSHA ONP Nuclear Safety Review Staff Division of; Nuclear Construction (obsolete abbreviatibn,'de INC)
Nuclear Utility Management and Resources, Committee Occupational Safety and Health Administration (or Act')
Office of Nucl'ear Power O'MCP PHR PT Office of ldorkers Compensation Program Personal History Record Liquid Penetrant Testing QAP Quality Assurance Quality Assurance Procedures QC QCI Quality Control Quality Control Instruction
TVA EHPLOYEE CONCERNS SPECIAL PROGRAH REPORT NUHBER:
22000 FRONT HATTER REV:
2 PME, viii OF viii QCP QTC RIF RT SQN SI SOP SRP S'MEC TAS T&L Quality Control Procedure Quality Technology Company Reduction in Force Radiographic Testing Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedure Senior Reviev Panel Stone and'obster Engineering, Corporation Technical Assistance Staff Trades and Labor TVTLC MBECSP WBN WR Tennessee Valley Authority Tennessee Valley Trades and Labor Council Ultrasonic Testing Visual Testing Watts Bar -Employee 'Concern Special Program Watts Bar Nuclear Plant Work Request or Work Rules Morkplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER~
2l2060 REVISION NUMBER:
age 2 of 30 Section Executive Summary Preface Glossary of 1 erms Acronyms CONTENTS Paqe ES-1 1.
Introduction 2.
Summary of Issues/Generic Applicability 3.
Evaluation Process 4.
Finding.s 5.
Corrective Actions 6.
Causes 7.
Collective Si gnificance Glossary Supplement for the Engineering Category Attachments A
Employee Concerns for Subcateqory 22000 B
Summary of Issues,
- Findings, and Corrective Actions for Subcategory 22000 C
References 12 17 18 20 28 A-1 B-l C-1 TABLES Table 1
Classification of,Findings and Cori ec'tiVe Action 2
Findings Summary 3
Matrix of Elements, Corrective Actions, and C'aus'ds'aae 22 24 25 26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000
,REVISION NUMBER:
3 Page 3 of 30 1.
INTROOUCTION This subcategory report summarizes and evaluates the results of the ECSP element evaluations prepared under Engineering Subcategory
- 22000, Support Oesign General.
It deals mainly with the design adequacy of pipe supports.
Other related'ssues include design change control, technical decisions made by construction, and technical review by enqineerinq.
The evaluations are summarized in the balance of this report as follows:
o Section 2 summarizes, by element, the issues stated or implied in the employee concerns and their generic applicability o
Section 3 outlines the process followed for the element and subcategory evaluations and cites documents reviewed o
Section 4 summarizes, by element, the findinqs and identifies the negative findings that must be resolved o
Section 5 highlights the corrective actions required for resolution of the negative findings cited in Section 4 and relates them to element and to plant site o
Section 6 identifies causes of the negative findings o
Section 7 assesses the significance of the negative findinqs o
Attachment A lists, by element, each employee concern evaluated in the subcategory.
The concern's number is given along with notation of any other element or category with which the concern is
- shared, the plant sites to wnich it could be applicable are noted, the concern is quoted as received by TVA, and. is characterized as safety related, not safety related, or safety siqnificant.
o Attachment B contains a sutmnary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions.
The reader may trace a concern from Attachment A to an issue in Attachment B by using the element number and applicable plant.
The reader may relate a corrective action description in Attachment B to causes and significance in Table 3 by using the CATO number which appears in Attachment B in parentheses at the end of the corrective action description.
The term "Peripheral finding" in the issue col'umn refers to a
finding that occurred during the course of evaluating a concern but did not stem directly from a employee concern.
These are classified as "E" in Tables 1
and 2 of this report.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM f>EPORT'UMBER:
22000 ftEVISION NUMBER:
3 Page 4 of'13 o
Attachment C contains the references cited in the text.
The employee concerns providinq the basis for'he element evaluations are listed by element number in Attachment A.
The plant location where the concern was original'ly identified and the concern applicability are also identified.
2".
SUMMARY
OF ISSUES/GENERIC APPLICABILITY, The employee concerns listed in AttaChment A haVe been examined for each element and the potential problems raisIid by the concerns have been identified as issues in Attachment B.
Some of these
'is~ues were evaluated for more than one plant when deemed generically applicable in accordance to ECTG Program Manual M.l, Section 7.3.
Investigation of these issues constitutes the element evaluations.
2.1
~Summer of Issues Summaries of the issues evaluated under this subcategory for eaCh element are listed below..
220.1
"'As Series Hanqer Dr a ings and 0-50,NOtes" - The 47AO'iO series Brav<lnig notes are con using, open to lnMerpretation, anid al'low rejected hangers to be accepted.
NRC wrote viollations aqainst the 47A050 notes because they did not satisfy inspection criteria.
o 220.3~0es~iin of Pipe Supports" - Pipe suppor ts are designed inadequatelly.seismic pipe'support criteria are nonexistent; Seismic pipe supports are too'igid.
1 nadeq~uaMte ly controlTed and have aS many as 100 revisions.
o 220.7~In! tallation-related Technica'I Decisions"r afts assume
~
too much respons7FiTi'ty or oriasnaitsnq Bessqn.
EnqineerinIq reviises the drawings to reflect as-built caindition without review and approval.
o 220.9~0versizi~nof Pipe Support Steel and Slick Grindinq of ll a -r m:
.a !~T sl'ick grindin1g welds is unnecessary.
o 220.1iD~"Replacement Iianqers" - Insta'iled pipe supports have often been modified or removed.
2670D-RT4 (110/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 5 of 30 o
220. 11 "Temperature Variation Consideration"
- Thermal expansion is not considered in the pipe support calculations.
o 220. 12 "Technical Review" - Technical review is not performed after the chec er s review o a pipe support calculation.
The issues.
suamarized above deal mainly with presumed deficiencies or inadequacies in the design of pipe supports.
Other related issues deal with the quality and use of the support installation tolerance notes (220. 1),
technical decisions made by Construction (220. 7),.and technical review by Engineering (220.12).
A complete statement of each issue investigated in the element evaluation is provided in Attachment B.
This attachment also lists findings and corrective
- actions, which will be. discussed in Sections 4 and 5 of this report.
Three of the above summarized issues were found to be valid and require corrective action (elements 220. 1, 220.3, 220. 11).
On the basis of the findings, only the issues of inadequately designed pipe supports (element 220.3) are technically significant with respect to design adequacy.
2.2 Generic Applicabilit of Emplo ee Concerns The qeneric applicability of the employee concerns was determined as follows:
o 220.
1 "'A'eries Han er Orawinqs and 0-50 Notes" WBN - All eight concerns of this element are applicable.
SQN - Only Concern IN-85-024-001 was applied to SQN.
Since all concerns for this element originated at WBN, many of them made direct or inferred references to WBN, making the concern plant-specific to WBN.
Concerns IN-85-052-001, IN-85-932-001, and IN-85-445-013 contained specific references to WBN documents.
Concern IN-85-010-002 inferred it was specific to WBN because of the reference to an NRC violation.
In addition, Concerns IN-85-415-001 and IN-86-249-001 implied the notes were vaguely written; however, the notes at SQN (and BLN) were found to be clear and concise.
Therefore, these concerns are also plant-specific to WBN.
The last concern, PH-85-006-001, was found not to be valid at WBN.
Since field change request procedures similar to WBN's exist at SQN (and BLN), no further evaluation is required.
2670D-R14 (10/08/87)
TVA EMPLOYEE CONCERNS.
SPECIAL PROGiRAM REPORT NUMBER:
'2000'EYISION NUMBER;,
3 Page 6 of 30 BFN - The element is not applicable because no such notens (oH similar notes) exist at BFN; BLN - The original,TYA determination was that the concern of this element was not applicable.
Howevler, through the evaluation of element 220.3 f'r BLN, it was found that notes
'imilar to SQN/WBN 47A050 notes (Ref.a.
1 and 2) existed't'L'N as 36A0059 notes (Ref. 3).
'IFhe issue stemming from Conkerln IN-8!5-024-00'I that. the not,es may be misinterpreted was applied to Bl N.
The concern also deals with "A"'eries hanger drawings; however, they, or similar drawings, do not exist at BLN.
o 220.~3 "Design of Pipe Supports" - The concerns of'his elestent are
~app icable to all four plants.
WBN - The concern of this element is applicable and f'ound not to be valid.
18, 20, and
- 21) reviewed in e'lement 220.3 for these. three plants does not indicate that pipe.support drawing".
were excessively revised.
Hence,~this
~
.clIncern does not require further evaluation.
o 220.~7" Instal1 at.ion - Relatled 'Tedhnica'1 0ec lsi'ons;"
WBN - The concern of this element is applicable and found not to be valid.
SON; BFN, BLN' Chancjes required by construction are initiated through field change.requests which. aire approved by Engineerihg
'efore the physicail change is made.
Since document change'rocedures s',imilar to WBN's also exis,t for these three plants, this concern does not require further evaluation.
o 220.9, "-Oversizin2 of P~i e
Su ortts Steel'and Slick Grindin
'of,'e~s WBN - The concern of this element is applicable and found not to be valid.
26700 R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 7 of 30
\\
18,.20, and
- 21) reviewed in element 220.3 for these three plants does not indicate that the pipe supports were oversized.
Slick grinding of welds is an unnecessary procedure
- and, when properly performed does not impact the technical adequacy of the supports.
Hence, the concern does not require further evaluation.
220.10 "Re lacement Han ers" WBN - The concern of this element is applicable and found not to be valid.
- SON, BFN',
BLN - Changes in hanger type and location changes are common during the design/construction process.
These changes are considered and documented in the piping and support analyses.
- Hence, the concern does not require further evaluation.
220.11, "Temperature Variation Consideration" - The concern of this element is applicable to all four plants.
220.12, "Technical Review" WBN - The concern of this element is applicable and found not to be valid.
- SON, BFN, BLN - From the WBN evaluation, it was found that 10 CFR 50, Appendix 8 (Ref. 4) and ANSI N45.2.11-1974 (Ref.
5) specify that verification or checking shall be performed by any competent individual or groups other than those who performed the original design.
No additional verification or checking is required after the competent individual (or group) has checked or reviewed the calculations.
Since these documents also apply to these three plants, the concern does not require further evaluation.
3.
EVALUATION PROCESS This subcategory report is based on the information contained in the applicable element evaluations addressing the specific. employee concerns related to the issues summarized in Section 2.
3.1 Element'valuation Process The evaluation process for each element is as given below.
2670D-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:'
22'000 REVISION NUMBElt:
3 Page 8 of 30 3..1.1
"'A,'eries Hanger Orawings and 0-50 Notes" - Element 22Cl.l
~Seaaa ah.
a.
Reviewed the 47A050 notes (Ref.
- 1) to determine if these notes were contradiIctory to hanger drawings (Ref.
9) and other installation doc:uments (Refs.
6 and 7).
b.
Reviewed the 47A050 notes to determ'ine if they can be misinterpreted.
c.
Reviewed TVA's corrective action plan for CATO 220 Ol SQN Ol.
Watts Bar.
.a.
b.
C ~
d.
e.
Reviewed applicable NSRS investiIjation reports (Ref. 8).
Reviewed thie 47A050 notes to establish whether these notes were contradictory to "A" series hanger drawings (Ref.. 10).
Reviewed thie 47Ai050 notes to determine whether they can be misinterpreted.
Interviewed Site perSonnel'o determine if interpretational confllicts exist'(R'ef.'l).
Reviewed the 47A050 notes to determine whether revisions. to the notes allowi, rejected supports 'to'be'Ccepted.
Reviewed a sample of calculations (Ref'.
- 12) for justification of
'pecific note..
f.
Reviewed TVA's-corrective action plan for CATO 220 01 WBN 01.
3.1.2 a.
b.
"Oesign of Pipe Supports."'
Element 220.3 (All Plants)
Reviewed NSRS report (Ref.
13) tO dietermine'he scope of the employee concern.
Reviewed applicable pipe suppOrt desiqin criteria (Refs.
14, 15, 16, and 17) and a random sample of support, calculations (Refs.
- 1I8, 19,,
20, and
- 21) from various safety-related systemis to verify seismic'esign adequacy (excluding the r0quirements for base plate and anchor bolts, as they are examined in Construction Subcategory Report 10400, Ref. 53).
2670D-R14 (10/08/87)
F
TVA EMPLOYEE CONCERNS ~
REPORT NUMBER:
22000 SPECIAL PROGRAM REVISION NUMBER:
3 Page 9 of 30 c ~
d.
e.
go Reviewed seismic support criteria (Refs, 14, 15, 16, and
- 17) to determine rigidity requirements.
Reviewed sample of pipe support drawings (Refs.
22 and 23) for constructibility (for SON, WBN only - based on the evaluations for SgN and WBN element 220.3, and evaluations for element 222.3 fall four plants]; this sten was determined to.be unnecessary for BFN and BLN).
Performed study calculations (Refs.
24 and
- 25) to support evaluations, made engineering judgments as necessary, and conducted site interviews (BLN only, Ref. 25).
It was determined that BLN had similar notes (3GA0059 series) to the SQN/WBN 47A050 notes.
Evaluation of the 3GA0059 series (Ref. 3) notes was performed under element 220.3 as an additional finding.
h.
Reviewed 3GA0059 notes, to determine if they can be misinterpreted.
1 ~
3.1.3 a.
Reviewed TVA's corrective action plans for CATDs.220 03 SgN 01, 220 03 WBN Ol, 220 03 BFN01, 220 03 BLN Ol,,and 220 03 NPS 01.
"Revisions to Hanger Design" - Element 220.6 (Watts Bar)
Reviewed pipe support desiqn manual (Ref.
- 26) to verify the method of numbering hanger drawing revisions.
b.
Reviewed TVA procedures (Ref.
- 27) for revising vendor drawings.
c ~
Reviewed WBN hanger tracking program report (Ref.
- 28) to verify the maximum number of revisions for a hanger drawing.
3.1.4 a.
"Installation-related Technical Decisions" - Element 220.7 (Watts Bar)
Reviewed the applicable procedures (Ref.
- 29) to determine the extent tO WhiCh TVA might permit the crafts to participate in the design process.
b.
Reviewed these same procedures to ascertain the degree of control of the FCR process in preventing hanqers from being redesigned and installed without documented engineering approval.
26700-R14 (10/08/87)
'TVA EMPLOYEErCONCERNS SPECIAL PROGRAM REPORT 1'IUMBER:
22000'EVISION NUMBER'3 Pa.ge 10 of 30 3.1.5 "Overs izing. of Pipe Support Steel'and Slick Grinding of Welds"-
Element, 220.9 (Watts Bar) a.
Reviewed
'TVA IOM (Ref. 30) regarding Employee Concern IN-85-316-062.
b.
Reviewed
'TVA's General Construction Specification G-29C, Rev.
9 c.
.Reviewed
'TVA's General 'Construction Specification G-43, Rev. 8.
d.
Reviewed TVA's typical small pi'pe'standard drawings and general notes for Category I supports
('rawings 47A053-62, 47A053-62A through
- 62E, 4i'A053-63,,
47A053w63A, and 47A050-1P) for braced and
'nbraced cantilevers.
3.1.6 a.
"Replacement Hangers" - E'iement, 220.10 (Watts Bar)
Reviewed documents (Ref.
31) and procedures (Ref. 32) relating to practices adopted for modifying the pipe supports that have already been installed (including deletions).
b.
3.1.7 Reviewed ten sets of piping analysis'alculations (Ref. 33),
including stress isometric drawings, and the respective engineer.ing change notices (ECNs)/fie'Id change requests (FCRs) causing the pipe support modifications (including deletions).
"Temperature Variation Consideration~'
Element 220;ll
~Seauo ah.
a.
b.
C ~
Reviewed design criteria (Ref. 34) and applicable codes (Ref! 35) to verify if consideration of'emperature variations is required in the design of structural members ott pipel supports.
Reviewed design criteria to verify if therma'I expansion of pipin'g is considered in the piping analysis and if loads imposed by this expansion are considered in the pipe su'pport'design.
Oetermined if SgN adequately ad'dressed the WBN problem identification report (Ref..36) on this subject.
d.
Reviewed I'VA's corr'ective action plan for CATO. 220 ll SgN 01.'atts Bar.
a.
Reviewed design criteria (Ref.
37) and applicable codes (Ref.
- 38) to verify if consideration of t~~mpersiture variai;ioins is required in the l
design of structural members of pipe supportr.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page ll of 30 b.
Reviewed design criteria to verify if thermal expansion of piping is considered in the piping analysis and if loads imposed by this expansion are considered in the pipe support design.
c.
Reviewed TVA's corrective action plan for CATO 220 11 SgN 01.
a.
Reviewed design criteria (Ref.
16) and applicable codes (Ref.
- 35) to verify if consideration of temperature variations is required in the design of structural members of pipe supports.
b.
Reviewed design criteria to verify if thermal expansion of piping is considered in the piping analysis and if loads imposed by this expansion are considered in the pipe support design.
c.
Oetermined whether BFN adequately addressed the WBN problem identification report (Ref.
36) on this subject.
d.
Held discussions with BFN Engineerinq Oesiqn (EN OES) personnel, as required (Ref. 39).
e.
Reviewed (for adequacy) the criteria (Ref.
- 40) for evaluating structural steel components and piping subjected to the effects of the March 22, 1975 fire.
Be 1 1 efonte.
a.
Requested TVA (BLN) to provide the following documents related to the consideration of thermal stresses in the design of pipe supports and pipinq analysis:
o Oesign criteria (pipinq and pipe suoports)
(Refs.
17 and 41) o List of affected drawings (Ref. 42) o Results of TVA evaluation (Ref.
43) o Sample drawings (Ref.
44) b.
Reviewed design criteria, list of affected drawings, sample
- drawings, and written explanations received from TVA (BLN) in order to establish whether the concerned individual's claim that thermal stresses are not considered in the design of pipe supports has any impact on the safety of BLN.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22500 REVISION NUMBER:
~3 Page 12 of 30 c.
Reviewed corrective action plan provided by PIR BLN CEB 8512 (Ref. 55).
3.1.8 "Technical Review" - Element 200.12 ~(Watts Bar) a.
Reviewed licensing. commitments (Refs.
4, 5, 45) and TVA procedures (Re~F.
- 46) for design calculation 'verification.
b.
Reviewed pipe support calculations (Ref. 47) to verify the compliance with licensing c(mmitments and TVA procedures.
C ~
Reviewed documentation pertaining to pipe support technical audit reports (Ref. 48).
3.2 Subcateqo~r Evaluation Pr ocess The eValuatiOn prOCeS.; fOr thiS SubCatleqOry repOrt WaS aSs fOllOWS:
a.
Tabulated
- issues, findings, and cbrHective actions from the element evaluations in a plant-by-plant a'rratng5meht
'(see Attachment 5).
b.
Ca Prepared Tables 1,
I!, and 3 to permit comparison and identification of common and unique issues,
-f'indingis, and corrective action's a'mor'>q
'he four plants.
ClaslsiFied the findings and corrective actions from the. elemient evalluations using the ECSP defini'tio'ns.',
- d. -
On the basis os ECSP quideline4',
hnalyzedl th'e collective significance and causes of the findings from.the element evaluations,.
e.
Evaluated defined corrective actions to determine if addit',ional'ctions are i equiredl aS a resullt of causes found in step d.
f.
Provided= additional judgment'r" ihfo'rmatibn 'that may not be 'apparent at the element level.
4.
PI GOINGS The findings from each of the. element evaluations for this subcateqory are contained in Attachment.B.
They are listed by elemerit number and by plan't.
'he findings f'r eaich element are summarized in the followinq par aqHaphs.
26700-R14
( 10/08/87) 0
. ~.,4 a
~ ~
2
~
~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 13 of 30
- 4. 1
"'A'eries Han er Orawinas and 0-50 Notes" - Element 220. 1 The purpose of the notes is to provide Construction with as much flexibility as.possible for hanger installation, and to provide guidelines for unforeseen situations and generic installation difficulties.
The notes allow a larger number of pipe, supports to meet acceptance inspections that otherwise would have required field change requests (FCRs) or would have been rejected by inspection rejection notices (IRNs);
For Sequoyah, the 47A050 series drawing notes were found to be neither confusing nor open to interpretation.
However, minor discrepancies were found between a construction specification and an operations maintenance instruction.
For Watts Bar, the 47A050 notes were, in some cases, found to be confusing and contained conflicting or unnecessary instructions;
- however, they were revised in. September 1985 to resolve conflicts and. for clarification.
Evaluation team interviews with site personnel (Construction and guality Control) reveal'ed that there were interpretational differences.
There are Watts Bar programs in place to resolve the differences, such as inspection rejection notice
( IRN) trend analysis, guality Assurance (gA) training, and ONE/DNC biweekly meeting (see Attachment B).
No NRC violations against the 47A050 notes were identified.
However, it was found in a Nuclear Safety Review Staff (NSRS) reoort I-85-157-WBN (Ref. 8) and by the evaluation team that changes made to the 47A050 notes did not always have complete documented justification.
In addition, although the concerns'were specifically directed at the 47A050 notes, similar notes were found at Bellefonte during investigation for element 220.3.
These notes, 3GA0059 series
- drawings, were found to be reasonable and clear.
- However, some 3GA0059 notes did not have complete documented justification.
Browns Ferry.does not have any notes similar to the 47A050 notes.
4.2 "Oesi n of Pi e
Su orts"- Element 220.3 The pipe supports reviewed by the evaluation team were found to be adequately designed for Sequoyah, Browns Ferry, and Bellefonte, but the calculation documentation was incomplete, or contained minor discrepancies.
For Watts Bar, the above remarks apply in general.
In addition, four Watts Bar pipe supports (1-74-11, 47A060-'-23, 47A060-70-27, and 1-63-404) did not meet code stress allowables because incorrect loads or load combinations had been applied.
The Sequoyah calculations for nine supports (2-MSH-315, 2-MSH-348, 'l-AFOH-328, 1-CVCH-100, 1-RCH-302, 1-UHIH-130, 2-SGBH-290, 2-RHR-449, 2-CSH-5) provided justification of changes to the supports, but no analysis was included for the 26700-R14 (10/08/87)
TVA, EMPLOYEE CONCERNS SPECIAI PROCiRAM REPORT NUMBER:
'22000'EVISION NUMBER;.
3 Page 14 of 30 I
original designs.,
I;rom a general review (based on support configuration and
- size, and design loads) of these nine supports,
)he,evalqation team determined, that eight were adequatelly designed for the, specified loads (Ref. 24).
The adequacy of the remaining support, 2-CSH~5, could not be easily verified because of the complexit>r of the structure, its relationship with common
- supports, and the magnitude of the load.,
Complete reanalysis would be
- required, which 'is covered in the corrective action plan (CAP) for CATO 220 03 SON 01.
Under this CAP the adequacy of support 2-CSH-5 would be established, and modifications would be provided if necessary.;
With the exception of Browns Ferry's General Oesi,gn Cri.teria for the Lbng-Term Torus Integrity Program (LTTIP) BFN-50-0706 (Ref~ 16), the pipe support design criteria for Sequoyah, Watts Bar, Browns Ferry, and Bellefonte were found'o adequately address the necessary seismic 'design requirements.
The criteria for the Browns Ferrv plant-specific LTTIP lack deflection/rigidity requirements.
Browins Ferry supports designed under these criteria are to be reevaluated under the Brown;s Ferry instrdcttion for the, calculation verification program (Ref'. 49).
Browns Ferry has not completed its commitment to issue criteria for box anchors and a pipe support handbook.
In addition, the punching shear requirement for tube-to-tube connections was not indluded in the pipe support design criteria for the four ~plants, contrary to TVA policy memorandum PM 86-()4 (Ref. 50).
Bellefonte design loads and allowable stresses were found to deviate from the ASME Section III-1974 NF code (Ref. 51); however, these deviations were reviewed and approved by the Nuclear Regulatory Commission.
In additidn, it was found that, a section of the Bellefonte Final Safety Analysis Report, (FSAR)
(Ref.
52) was missing some provisions for one load condition due to an oversight by TVA..
This 1load condition is included in,the design criteria and considered in design.
An additional finding was made concerning the lack of'omplete documented just'ification for,some of the 3GA0959 series drawing notes.
(See summarized findings for element 220. 1.)
The findings for element 220.3 for all four plants do not include review of specific requirements for base plates and anchorage bolts (e.g.,
base plate flexibility, anchorage, bolt safety factor, construction tolerance);
as these reauirements are addressed in Construction Subcategory Report 10400 (Ref. 53).
Rigidity is a ma;jor factor in determining the design loads.
Since the riqidity of supports
-is considered in the analysis of seismic piping, and, therefore, reflected in the resulting suPpoi t deslign loads, the supports are sufficiently designed to prevent them from breaking loose during a seismic event.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 15 of 30 4.3 "Revision to Hanger Oesians" - Element 220.6 Pipe support revisions are adequately controlled in accordance with applicable procedures.
In the review, of Watts Bar unit 1 pipe supports,. the evaluation team observed only three support drawings (out of the listing of 11,300 supports from TVA's Hanger Tracking Program Report, Ref. 28) that were revised a maximum of 11 times.
The average number of revisions of all supports was noted as four, which is reasonable.
4.4 "Installation-related Technical Oecisions" - Element 220.7 There is no indication that the crafts or any other TVA Construction personnel assumed responsibilities beyond those called for in the applicable FCR procedure, or that Engineering revised design drawings without required analysis or evaluation.
4.'5 "Oversizinq of Pipe Su port Steel and Slick Grindin of Welds"-
ement It is possible that a pipe support member may have appeared to be o'versized for the load; however, there are other design requirements, such as deflection/rigidity, that'need to be met.
Although a properly performed slick-ground weld is not an undesirable condition, the practice of slick grinding is unnecessary and has been discontinued by TVA.
4.6 "Re lacement Hanoers" - Element 220. 10 TVA has a quality control procedure (gCP) (Ref. 32) which requires verification that the pipe supports are installed within specified tolei ances.
Any changes (out of tolerance, replacement, or deletion) ar e evaluated and documented by field change requests (FCRs) and engineering chanqe notices (ECNs).
4.7 "Temperature Variation Consideration" - Element 220. 11 Additional loading due to the thermal expansion of structural members restrained between two rigid points was not considered at Sequoyah, Watts Bar, Browns Ferry, and Bellefonte because it was not a code requirement.
- However, if the temperature variation is considerable, a support configuration that is thermally restrained could experience considerable thermal 'loading.
Watts Bar has since addressed this condition in its corrective action for Problem Identification Report (PIR)
WBN CEB8536.
There is no indication that this restraint condition exists at Browns Ferry.
Bellefonte has addressed this thermal restraint condition in its corrective action for PIR BLN CEB8512.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPOR'T NUMBER:
22000 REVISION NUMBER:
3 Page 16 of 30 Pipe expansion imposed loads on the supports ar'e considered at Sequoyah, Watts Bar,, Browns Ferry, and Bellefonte and are addressed in the applicable pipe stress analysis and support criteria.
4.8 "Technica'I Review" - Element 220. 12 Technical review after the checkeir' review is not required by applicable TVA procedures.
These procedures meet the licensing coneitments far design calculation verification required by 10 CFR 50 (Ref. 4) and ANSI N45.2.11-1974 (Ref. 5).
In addition TYA (civil engineering branch chief) had conducted an independent review of lIiBN pipe support calculations to verify technical adequacy and compliance with pertinent controlling documents and procedures
~
(Ref. 48).
4.9
~Sumnar of Subcata~or~findintis The classified findings aire sunimarized in Table ll Class A and B findihgsI
.indicate that there is no problem and that corrective actibn is not requiredh Class C, 0, and E findings require corrective actions.
The corrective action
- class, defined in the Glossary Supplement<
iis idehtified in the table by the numeral combined with the finding class.
For element 220.3, some of the issues wer'e found to be invalid, alt'hough corrective action was still required for the documentation and/or procedures.
These findings requiring corrective action were classified as "E"; however, they cannot be genuinely classified as peripheral because of the inte'gral relationship with the stated issue.
~ In addition, for element 220mll, Issue "c" was klasslfied as "B" because Browns'erry took immediate corrective action after 1975 and no further action was required.
The summary of findings, by classification is given in Table 2.
Where more than one finding/corrective action classifichtion is listed
'in Table 1 for a single issue/finding, Table 2 counts on'ly'the c'ladsific'ati'on that has the
'reater impact on the Emp'loyee Concerns Pr'ogi am.
Thus for element 220.3, ithe "0" classification would be chosen over the O'C" anid the'E" classification'ver the "A."
Therefore, Table 2 identifies only one f'inding/corrective action classification f'r each issue evaluated.
For Table 2 it can be seen tlhat the majority'f'ssues were not valid.
Aporoximately hialf of the issues, requiring carr'ective acti'on have corre~:tive action plans thiat were initiated by TVA before the ECTG evaluation.
This is i
an indication that TVA is responsive in acting 'to 'correCt known deficiencies.
The most important finding, that Watts Bar'id hot mIbet'ode stress allowables, resulted from the ECTG evaluation.
26700-R14 (10/08/87) 41
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM'EPORT NUMBER:
22000 REVISION NUMBER:
3 Page 17 of 30
(-SOUTH-)ngs requiring corrective action resulting from peripheral issues occurrvnq at Sequoyah, Browns Ferry, and Bellefonte dealt basically with design documentation.
Although the supports were found to be adequately
- designed, the design calculation documentation was not. always complete and/or contained minor discrepancies.
In addition, the subject of irretrievable calculations is addressed in Subcategory Reports 21200 and 22100.
(This subcategory report L220003 deals mainly with technical, not documentation issues.)
5.
CORRECTIVE ACTIONS The corrective actions for Sequoyah, Watts Bar, Browns Ferry, and Bellefonte along with their finding/corrective action classifications, are summarized in Table 3.
The corrective action descriptions in the table are a condensation of the more detailed corrective action information provided in Attachment B.
The table indicates the plant or plants to which a corrective action is applicable by the Corrective Action Tracking Document (CATD) column, where the apolicable plant is identified by the CATO number.
The corrective action plans are summarized in the following paragraphs.
- 5. 1 "'A'eries Han er Orawin s and 0-50 Notes" - Element 220.
1 For Sequoyah, the differences between the construction specification and operations maintenance instruction will be reconciled.
For Watts Bar, calculations for justification of the WBN 47A050 notes will be provided; and WBN Engineering (ONE) will reinform Construction (DNC) and guality Control (ONOC) by memo of the programs in place to help resolve 47A050 note interpretational differences.
5.2 "Desi n of Pi e
Su orts" - Element 220.3 For Sequoyah, calculations wi 11 be performed for the nine pipe supports.
For Watts Bar, code stress allowables will be met, and engineering judgment will be properly documented for all engineered pipe supports under its unit 1
Hanqer and Analysis Update Program (Ref.
54) and a similar program for unit 2.
The four Watts Bar pipe supports not meeting code stress allowables will be reevaluated.
For Browns,Ferry, the Box. Anchor Criteria and Pipe Support Handbook are to be issued.
The Long-Term Torus Integr'ity Program criteria are to be revised to include deflection/rigidity and punching shear requirements.
The Browns Ferry pipe support calculation lacking analysis for the critical base plate is to be revised.
For Bellefonte, FSAR Table 3.9.3-37 (Ref.
- 52) will be revised to include load and allowable stress for the upset (primary plus secondary) condition.
The computer output for the eight identified Bellefonte calculations will be retrieved by. ITT Grinnell.
26700-R14 (10/08/87)
.EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
'22600'EVISION NUMBER:
3 Page 18 of,.30 Complete documented justification will be provided for the 3GA0059 series notes.
Two-sided welds on tubing at Bellefonte will be. evaluated and modified~
if required.
The punching shear requirerhent Will be incorporated into Civi1I Oesiqn Standard. i)S-C1.6el (Ref. 55), which covers all plants and applicable~
design criteria..
Generic evaluations we<'e performed on previously genhralted calculations f'r punching shear.
5.3 "Temperature Variat.ion Cons'ideration" Element 220.11 For Sequoyah, steel supports with the ident'ified condition that restrains thermal growth will be evaluated and modified as necessary.
For Watts Bar, corrective act ion for this restraint conditjlon i0 pf ov'idt5d by PIR WBN CEB8536 (Ref. 36), which includes the activities'as'de'scribed for Sequoyah.
For Browns Ferry, no correct.ive action is required.
'For BellefOnte, corrective action for this restraini: condition is pr'ovided by PIR BLN CEB8512 (Ref. 56).
5.4
~Sussear of !iubcat~eo~r Corrective Actions From the Finding/Corrective Action ClassifiCationi column 'of Table 3, it can be seen that all seven corrective actions jdentif'ied require some type of~
documentation remedy.
In addition, the CATO cblumn of the table shows that, in most cases, a particu1lar corrective action is applicable to only a single olant.
The element requiring the most correct'ive actions is 220.3, Oesign of Pipe Supports.
There is a potential for the correctivie actions for the Element 220.3 to result i,n physical (hardware) modification of supports.
'inally, with respect to corrective aetio'ns,',
T'abl'e 3 shows that, of the eiight elements in this subcategory, five require rIo corrective action (namely, 220.6, 220.7, 220.9, 220.10,,
220.12).
The corrective action plans provided by TVA are found to be acceptable by the evaluation team to resolve the negative findings.
6.
CAUSES Table 3 identifies one or more causes for each negative finding requiring'orrective action.
For each corrective actions the most important cause is
'dentified;,however in many instances it was felt that the prOblem Wa< the
'esult of, a combination of causes, each o~f WhiCh ~should be identified.
In those cases, more than one cause is identified for some of the corrective~
actions.
The bases for identifying specific causes for each corrective action description in Table 3 and the linkage with the findings are described in the followinq paragraphs.
26700-R14 (10/08/87) 0
~ ~
'e v ~
~.g
~ r
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 19.of 30 Series Han ers and 0-50 Notes" - Element 220.1 The differences between Sequoyah M5AI-ll and General Construction Specification G-43 (applicable to all plants) are caused by lack of comparability between the two documents.
The subject Watts Bar calculation for the justification of the 47A050 notes is specified as an "Inadequate Calculation" in Table 3
because the necessary analysis was not performed, and engineering
- judgment, as well as test. data and reference material, were not properly documented.
o 47A050 note interpretational differences at Watts Bar are a result of " Inadequate 9-training" and "Inadequate Communication."
Personnel are not fully aware of the programs in place to resolve these differences in interpretation.
6.2 "Oesion of Pipe Supports" - Element 220.3 o
The subject Sequoyah pipe supports calculations are "Inadequate Calculations" because procedures were not followed, engineering judgments were not properly documented, and.there was an overall lack of completeness.
o Calculations at Watts Bar are "Inadequate Calculations" because engineering judgments were not being properly documented and design procedures were not being followed.
o The four Watts Bar pipe supports do not meet code stress allowables because design procedures were not being followed and engineering judqments were not properly documented.
o The punching shear requirement for tube steel is not included in the design criteria of all four plants.
The cause is specified (in Table 3) as "Inadequate Procedure" although the requirement is not a
code commitment.
o Browns Ferry is to complete its commitment to issue the Box Anchor Oesign Criteria and Pipe Support Handbook.
In this case, it is normal handling of documentation.
Browns Ferry will revise criteria BFN-50-0706 to include the deflection/rigidity requirement.
These criteria were inconsistent with other Browns Ferry pipe support criteria (which included this requirement).
- However, on the basis of industry standards during plant, construction, a
deflection/rigidity evaluation was not a code requirement.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NOMBERl 3
le Page 20 of 30 o
The calculation for Browns Ferry support RHR-159, unit 3, is'an'Inadequ'ate Calculation" because it lac'ked the analysis for Critical base plates and assumptions on which engineering judgments are Based~
o The design load and allowable stress for the upset, (primary plus secondary) condlit.ion were inadvertently left off Bellefonte FSAR Table 3.9,.3-37 but were. included.in the design criteria.
o The eight Bellefonte pipe support calculations, whose computer output is with ITl'rinnell, cannot be considered complete.
Justification f'r some of the 3GAC)059 notes may have been qualified by engineering judgments but not documented.
o At Bellefonte, the slhorter flat (installedl) length of weld t0 tube steel's not considered in the design calculations.
It is possible that designers were not aware of this site practice.
6.3 "Temperature Variation Consideration"-
Element 220. 11 o
The ident.ified restrained thermal condition for pipe supports at all four plants was not considere'd because it was not a
requirement'pecified in the design criteria.
The cause is noted as "Inadequate Procedure" although thi.s requirement is not a code coranitment.
S.a
~Surnnar of Subcateuo~r Causes In summary, considering the significance of the findings and corrective actions, it would appear that 'the most important cause would be "'Inadequate
'alculations."
The "Inadequate Calculations" are also a result; of procedures not being followed and failure to document e'ngineeri'ng'judgment.
These causes
'oint to an overall lack of'ttention paid to the adequate documentation of calculations required to demonstrate adherence to design commitments.
i 7.
COLLECTIV'E SIGN IF ICANCE The concerns expressed by TVA employees ahd 'coVered 'in 'this subcategory resulted in approximately a third of the 42 findings (from Table 2) requiring corrective actions.
Corrective action for approxima'tel'y half af these findings had been initiated by TVA before'h'e ECTG evaluation.
The findings for Sequoyah and Watts Bar 47A050'notes',
and'Bellefonte 3G'A0059'otes and FSAR require only documentation'orrective action.
They do not directly impact the design of pipe supports, and, therefore, are of relativeiiy minor significance.
26700-R14 (10/08/87) 0
~
1 ~
s 7
a s
TVA EMPLOYEE CONCERNS
'SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 21, of 30 Also of minor significance are the findings for punching shear and thermal considerations.
Consideration of punching shear on support design has little effect on the overall member.
stresses because of the nature (configuration and size) of pipe supports.
Thermal loads (due to environmental temperature) also have little impact on the overall. member stresses provided that the configuration of the support structure is such that thermal stresses are self-relieving (i.e., structural members are allowed, to a degree, to thermally expand without restraint or undergo local yielding/distortion to relieve these stresses).
In the cases where the support structure is restrained from thermal expansion (e.g.,
member between two concrete walls), there is the possibility of member overstress.
- However, TVA has committed to evaluate and modify, if necessary, such cases.
In addition, for Browns Ferry, although deflection/rigidity must be considered in the design of seismic pipe supports, this requirement in general is not the governing design factor.
The pipe supports reviewed by the evaluation team were adequately designed to applicable design criteria, with the exception of four Watts Bar pipe supports.
The calculations were not always properly documented.
Failure to document engineering judgment, analysis, or other related data (test data, memorandums, reports, etc.)
was the most prevalent cause of the calculational deficiencies.
It was observed that the items most frequently not documented were relatively minor and had little impact on the overall analysis of the supports.
Therefore, pipe support design does not represent a significant technical or safety problem for Sequoyah, Browns Ferry, and Bellefonte.
- However, TVA is aware of the need for proper documentation in the area of pipe support design, and has initiated corrective action to improve the quality of the documentation.
Of technical significance are the four Watts Bar supports that do not meet code stress allowables.
It was evident that design procedures were not properly followed, and thus design commitments were not met.
However,.Watts Bar had committed to reevaluating these support and providing hardware modifications if necessary.
In addition, Watts Bar's commitment under its Hanqer and Analysis Update Program (and similar program for unit 2) extends to all enqineered pipe supports.
Under this program, TVA will identify and
'orrect document deficiencies, and if required, provide hardware modifications.
On the basis of these conclusions, the subject matter of this subcategory report does not require specific treatment in the TVA Nuclear Performance Plan.
The. results of this subcategory report are being combined with the other subcategory reports and reassessed in the Engineering category evaluation.
26700-R14 (10/08/87)
TVA,EMPLOYEE CONCERINS SPECIAL PROGRAM REPORT NUMBER:
'2000'EVISION NUMBER;,
3 Page 22 of 30
.TABLE 1
CLASSIFICATION OF FINDINGS AND CORRECTIVE ACTIONS Element FIinding/Corrective Issue/
Action Class*
~Findin ~ ~H WEH t)7N~BL 220.1 "A" Series Drawing and 0-50 Notes b
c d
ef
'A'3 A~
C2 C2',
A, A
A A
220.3 Design of'ipe Supports 220.6 Revisions to Hanger Designs 220. 7 Instal 1 ation-rel ated Technical Diecisions 220.9 Oversizing of Pipe Support Steiel and Slick Grinding of'elds 220. 10 Replacement Hangers b
d e
a b
E5 A
A A
C2 C3 05 A
A A
,A, A
'A
'A B
A E2 A
L2 A
E2 I.:5 A
A E2 E3 E5 A
A A
E3 0
Explanation of classes is on the next page.
Defined for each plant in Attachment
'B.'670D R14 (10/08/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3
'Page 23 of 30 TABLE.
1 (Continued)
Element 220. 11 Temperature Variation Consideration 220.12 Technical Review Issue/
~Findin ~
a b
c C5 A
Finding/Corrective Action Class*
WN BN CS A
A A
8 A
BLN C5 A
- Classification of Findin s
and Corrective Actions A.
Issue not valid.
No corrective action required.
B.
Issue valid but consequences acceptable.
No corrective action required.
C.
Issue valid.
Corrective action ini.tiated. before.ECTG evaluation.
O.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
E.
Peripher al issue uncovered during. ECTG evaluation.
Corrective action required.
- 1. Hardware
- 2. Procedure
- 3. Oocumentation,
- 4. Training
- 5. Analysis
- 6. Evaluation
- 7. Other
- Oefined for each plant in Attachment B.
26700-R14 (10/08/87)
TVA EMPLOYEE CONCERINS SPEC',IA4 PROGRAM REPORT NUMBER: '22000',
REVISION NUMBER.'.
'3 Page 24 of 30 TABLE 2 FINDINGS
SUMMARY
Plant Classification of Findin~s BLN Total A.
Issue not valid.
No corrective action required.
B.
Issue valid but consequences acceptablel.
No corrective action required.
C.
Issue valid.
Corrective action initiated bef'ore ECTG evaluation.
D.
Issue valid.
Corrective action take6 as a result of I.=CTG evaluation.
E.
Peripheral issue uncovered during ECTG evaluation.
Corrective action required.
Total 7
13 3
4 0
~
l~
1 0
2
'0 0 0' 1
0 3
2 10 18>>
7 7
27 4:2 0 Note:
This tab'le suatmarizes information extracted from Table l.
2670D-R14 (10/08/87)
TABLE 3 HATRIX Of ELEHENTS, COARECTIVE ACTIONS, AND CAUSES SUBCATEGORZ c2000 REVISION INHBER: 3 PAGE 2SOf 30 HANAGEHENT EffECIIVENESS CAUS S OF NEGATIVE FINDlk DESIGN PROC SS EfFECTIVTa SS TECHNICAL ADE CZ I
2 6
6 7
10 11 12 13 14 15 16 IT flNOING/
CORRECT IVE ACTION ELEH CLASS.ee CORRECTIVE ACTION frag- )
acntcd Ina4c-Organ-quate Isa-I q-t lan Inade-quate Proce-dures Procc-Inadc-durcs quate Not Con Fol-(nunl- [
lo ed cation un-Inade-tlacly Lect quate Rcs ofiof Hgt(Design Issues Atten Bases Ina4c-quatc Cele Lect of Design Detail Inade-quate As-bit Recon-I cil.
Eagrg Judgnt not Oocu-uent 4
Des lga Crit/
Cowelt NoL He lasuf.
Verlf Docu-acnta-tlon Stds Not Fol-Engrg Vendor lowed Error Error Slgnlfl-cance of Corrective Ill 0
H N
220.l C2 Differences between SON HLAI-Il and G-43 will bc rcconcllc4 SON Ol C3 Calculatloas for Justlf Ica-tion of the NBN 4TAOso antes will be coepletcd as part of thc corrective actloa of SCR MBN CEBB531 NBN Ol NBN ONE will Issue a neao to relnfora ONC and DNUC of the prograas In place to he'Ip resolve a/AOSO note latcr-pretatlonal differences KBN Ol 220,3 ES SON will parforn calculatloas for the observations notc4 In aine pipe supports identified la thc SON Elcncnt Report 220.3 SON Ol A
P I'3 NBN will ensure through its unit I Hanger Analysis Update Pfograa.(and
~ slnllar progran for unit 2) that code stress
~1louablcs will be wct ~ and cnglnccrlng Judgncnt properly doc~ntcd for all cnglnccrcd pipe supports.
NBN Ol A
P P
four MN pipe supports noL aCCtlng COde Strata. allOu-ablcs will bc rc-cvaluatcd and aodl fled lf rcquirc4.
NBN Ol A
A P
Punching shear rcqulreacnts will bC InCOrpOrated IntO the appropriate pipe support deslga criteria of ~II four plants.
NPS 01 BfN Ol
~
Defined In the GIOSSary Supplenent.
Defined In Table I.
ut TAXLE 3 HATRIX OF ELEHENIS ~ CORRECTIVE ACTIONS AXO CAUSES SUSCATEGORV 22000 REVISION IRIHOERI 3 PAGE 26 OF 30 S OF NEGATIVE FiNDINGS U HANAGEHENT EFFECTIVENESS DESIGN PROC SS EFF C11 VENESS TECHNICAL ADE V
2'
~
S 6
7' 10
)2 13 I~
IS 16 17 FINDING/
CORRECTIVE ACTION ELEH CLASS.UU CORRECT I VE ACTION frag-jncntcd lnadc-Inadc-jOrgan-quatC quatC jlac-j 0-jfrocc-I IAA II rsu durst Procc-Inadc-durct quatC Not Con-Fol jnunl rAIIAsl ls r4 Un-tlee ly Lack Rcs ofjof Hgt Ittust Attss lnade-ouate Ocslga astst Inadc-jquatc lnade-As-hit quate Rccon-tslrt r1l lack of Design ns ~ AII Engrg Design Insuf.
tudgnt Crit/ Vcrlf not Canal t Oocu Oocu-Not ncnta-
~ I
~ ss v
~
Stds Nnt Fo'I-Engrg Vendor S ignifI-canto of Cerreet Ive uu n
v I v vvn 1 Uvv U
~
A a
~ ~
V UVA I@Nut V%A Ius Criteria and Pipe Support Handoook viii oa issued 08/31/87.
RFN-50-0706 vill hc rcvisc4 to lnclu4c dcf lect Ion/r l el dltv rcqul resents.
UVU ttt VA A
P I I'I ES Calculation for gfN support cuo lgo Alt \\
II'I hAc revised to Include analysis foi tritical hase platet an4 assuaptlons used to qualify ShCar fOrte on the anchor holt st NFN Ol X
X RLN fSAR Tahla 3.9.3-37 vill he reVISed tO InClude IOad
~U
~ 11
~ 1 I
~ ~
~ s vsr upset prlnary plus'secondary condt tlont RLN Ol.
5 k
E3 Ctuputcr output for tha Clght ldcatlflcd OLN supports vill hc rctricvcd fron ITT Grlaell.
Adcouatcly docNcntcd Justification for Iha 3GA0069 Serist UOICS vail ha provided In the corrective act:on for ue 8LF 870:26.
RLN Ol ES TUO-S14Cd veldt On tuhlng at RLN vill hc cvaluatc4 and nOdlf IC4, If nCCOSSarys thrOugh COrrcttlvc action for CA(II 8Lf 870098.-
8LN Ol Ajpj Defined In the-Giossai~ SuppicaÃt-
~ U Defined In Tahoe 1.
2~ jIO/07/87)
TASLE 3 HATRIR Of ELEHENIS, CORRECTIVE ACTIONS, ANO CAUSES SUSCAfEGORV 22000 REVISION MVISERt 3 PAGE 23 Of 30 HANAGEHENT EFFECTIVENESS CAUS S OF NEGATIVE FINOINGS a OESIGN PROCESS Eff CTIVENESS TECHNICAL ADE V
.2 3
4 5
8 9
10 I
12 15 6
F I RUING/
CORRECTIVE ACTION ELEH CLASS.aa CORRECTIVE ACTIUN CATO frag-nentcd Organ-( ize-t lon Inade-Ina4c-quatc quito tI-
/Procc-dure Pfoce iaido 4urCS quitC Not Con-FoI-
[nunl-loved cation Un-tlncly Lack Rcs oflof Hgt Issues Atten Inadeq-uatee Ocslgn Site Inade-quate Calcs
/ Inadc-quate Lack As-bit of Recon-Ocslgn c l.
Uet Il Engrg tudgnt no\\
Oocu-
~ent 4
Oc sign Crit/
Coaalt Not He lnsuf.
Vcrlf Oocu-ncnta t 0 Stds Not foI-Engrg lou d Error Vendor E'rror Slgnlfl-cancc of Correct lvc Act lonsa 0
H H
220+ II CS TVA ulll 14cntlfy, evaluate, and nodlfy, lf necessary, SON
~
steel structures vsth design features that restrain theme I grouth, Corrective action for HSN provldcd by PIR HSN CESS536 and ECTO tracking by CATO 220 Il NSN Ol.
SON 01 NSN 01 Corrcctivc <<tlon and adequate tracking for SLN provided by PIR SLN CESSSI2.
None TOTALS I
5
~
oaf lncd ln thc Glossary Supplanent.
Oaflnc4 ln Table 1.
26)10-Rl1 (10/03/Sl)
TVA EMPLOYEE CONCERNS SPECIAI PROGRAM REPOPT NUMBER:
- 22000, REVISION, NUMBER;,
3 Page 28 of 30 GLOSSARY SUPPLEMENT FOIE THE ENGINEERIN(3'ATEGORY Causes of Neoative Findin~s - the causes for findings that require corrective I
1.
Fraqmented o~ranization - Lines of'uthority, resj)onsibilityl, and accountaaaRity were not c'learly defined.
2.
Inadequate gualit~(}) traininq - Personnel were not fully trained sn the procedures estatilished iior design process control and in the maintenance of design documents, including audits.
3.
Inad~euate~rocedures
- Design'and modification control methods and procedures were deficient in establishi'ng requirements and did not ensuire an effective design control program in some -areas.
4.
Procedures not followed - Existing procedures controlling 'the design process were not fully adhered
~to>
5.
Inadequate communications - Communic'ati'on coordination, and cooperatiion were not fully effective'n supplying needed information within plants, between plants and organizations (e.g'.,
Engineering, Construction, Licensing, and Operations),,and between interorganizational disciplines and departments.
0 6.
Untime'I~resolution of issues - Problems were not resolved in a
Timely manner, ani3 tKeiir
>i esolution was riot aggressively pursued.
7.
Lack of manaoement attention - Thi!re was a lack of management attention in ensuring that programs required for an effective d'esi'gn proces.
were established and iiiiplemented.
8.
Inadequate desi~n bases
- Design bases were lacking, vague, or incompletieMor design execution and verification and for design change evaluation.
9.
Inadl~euate calculations - Design calculations were incomplete, used incorrect input or assumptions, ot otherwise failed to fully'emonstrate compliance with des'ign requirements or support design output doicuments.
10.
Inad~e uate as-bui.lt reconciliation -'econciliation of design and
~icensing documents with plant asibuh lti condition was lacking or incompletie.
26700-R14 (10/08/87)
~.
~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
3 Page 29 of 30 11.
Lack of desi n detail - Detail in design.output documents was
~nsu icient to ensure compliance with design requirements.
12.
Failure to document enqineerin
'ud ments - Documentation justifying engsneering judgments used in the design process was lacking or incomplete.
13.
Desi n criteria/commitments not met - Design criteria or licensing commitments were not met.
14.
Insufficient ver ification documentation
- Documentation (0) was snsu resent to au ~t t e a equacy o
design and installation.
- 15.
Standards not followed - Code or industry standards and practices were not comp
~ed with.
16.
En ineerin error - There were errors or oversights in the
,assumptions, methodology, or judgments used in the design process.
17.
Vendor error - Vendor design or supplied items were deficient for the intended purpose.
Classification of Corrective Actions - corrective actions are classified as belonging to one or more of the following groups:
1.
.Hardware - physical plant changes 2.
Procedure
- changed or generated a procedure 3.
Documentation
- affected 0A records 4.
~Trainin
- required personnel education 5.
~Anal sis - required design calculations, etcrs to resolve 6.
Evaluation - initial corrective action plan indicated a need to
~eva uate the issue before a definitive plan could be established.
Therefore, all hardware, procedure, etc.,
changes are not yet known gs Other - items not listed above Peri heral Findin Issue) - A negative finding that does not result directly rom an emp oyee concern but that was uncovered during the process of evaluating an employee concern.
By definition, peripheral findings (issues) require corrective action.
,v s'6700-R14 (10/08/87)
~
~
~
~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER.
i 22000 REVISION NUMBER:
3 Page 30 of 30 Si nificance of Corrective 'Actions - ThelevalUation'eam's judgment as to the siqni
>cance o7 the corrective actions listed inlTable 3 is indicated in the last three columns of the tab1Ie.
Significance is rated in accordance with the type or types of changes that may be expected to result from the corrective action.
Changes are categorized as:
o Oocumentation change (0) - 1'his is a change to any design input or
- output document (e.g.,
drawing, specif ication, calculation, or procedure) that does not result in a significant reduction in design margin.
o Change i'n design margin (M) - This is a change in design interpretation (minimum requirement vs actual capability) that results in a significant (outside'ormal limits of expected accuracy) change in the design'margi'n.ll
'designs include margins to allow for eirror arid unforeseeable events.'hanges in design margins are a normal and acceptable Ipaitt of 'the design and constructior'i process as long a0 the fihal'esign margins satIisfly regulatory requirements and apglikable codes and standards.
~
o Change of,hardware (H) - This is a phySical change to an existing plant structure or component, that'esults from a change in the design basis, or that is required to cOrrect an initially inadequate design or design error,.
If the change resulting from the corrective action is judged to be significant, either an "A" for actual or "Pt'or poten'tial is entered tnt'o i'.he'opropriate column of Table 3.
Actual i4 distin)uished from potential because corrective actions are not complete
- and, cohsequkntly,~ the scope of required changes may not be known,.
Corrective actions are judged to be signifiCant if the resultant changes affect the overall quality, performance, or margin of a safety-related structure.,
system,,
or. component.
0 2670D-R14 (10/08/87) hl
~
~
~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER: 3 Page A-1 of 4 ATTACHMENT A EMPLOYEE CONCERNS FOR 'SUBCATEGORY 22000 Attachment A lists, by element, each employee concern evaluated in the subcategory.
The concern's number is given along with notation of. any other element or category with which the concern is shared, the plant sites to which it could be applicable are noted, the concern is quoted as received by TVA and characterized as safety related, not safety related, or safety significant.
0107A-R36 (10/01/87)
CONCERN ELEHENT NUNUER ATTACHHENT A LMPLUYEE CUNCERNS FOR SUUCATEGORY 22000 PLANT
- APPL ICAUILITY CONCERN UESCRIPTIOH4 REVISION NUHUERY 3
PAGE A-2 OF 4 220. I-IN-US-OIU-OU2
.NUN "Hanger Quality Control U-50 notes (Evaluations) did not satisfy Inspection criteria.
There was an HRC violation written against Q.C.
nnrtnininn fn this IID r/I ln n
~ I 1
n Iki r
~
~
~ ~
4
~ ~ D
~ svno vl D
~IUD rl cV IvuDIy cxillcDDcv cll ~ D cvln cl II cv
- IHPO, HRC and NSRS.
C/I would not provide any additional info. to ERT because C/i feels it would be a waste of time to Investiqate this since he has previously reported it to INPO,NRC,HSRS."
(SR)
IH-85-024-UOI NUH X
X
"'A'eries hanger drawings and 0-50 notes are contradictory and allo~
hangers or box anchors or structural features to be acceptable, even when they do not conform to thD I enlulirD4nntc nf lilavinnc dntaiic Yhe 0-50 notes are misinterpreted by all those who utilize them."
(sR)
IH-'85-052-UUI IH-85-4I3-UUI IN-u5-932-uul IN Ub 249 OOI IN-85-445-013 NUH NUH nUNI NUN "Urawlng series A-0-50 notes are written to cover up problems during thc 84ngCI inst4i lutioil 4ilu iiiSpectioA 4Ctlvltles ~ 'Iui example UAit I 6 2 system 68, A202 [SIC] degrees, k 40'-6".
Hanger f4?A455-3-52
[sic]o
'(SR)
Hanger "050'otes are routinely written and utilized to override inspection rejections of hangers, and are so vaouely written that they provide what amounts.to an "open door" to hanger construction discreoancies YhD IAIDrnrntahilitv of "A5A" nntnc rncuitc In frequent disagreements between Construction and inspection, which causes fl Ict lon Dnv dc ~ Dys ln constl wet ion ~
ibis Is 4 'gencl II concern.
Individual was unable to provide specifics, or any further ll 4
lrnc del4 I I's ~
tDII/
IOSOI notes are too numerous and too lax - have too much latitude on acceptance criteria.
Some notes appear to conflict (EG f30 and PIOO).
Notes are too open to interpretation.
Ease of engineering overridino or re lection based on aonarent Conflict between notes 30 and 100." Uetails known to ERT, withheld due to confidentiality.
C/I hac rn r rthnn Infnn Dlin 4
Icoi v
Iv
~ u
~III ~
~ ~ ~ ~ vl NDLlvl~ ~
CDAI "Tiie 050 fiotes Shuuld bc dlsCOAtii1ued anid thiosi neXCeiitloiis" listed OA applicable control lid inspection check lists.
Construction dept.
concern.
Ci has no further information.n (NU)
"Urawing notes in tne "4?-AOS" series. are hard to uSe:
They are hard to interpret, too numerous, and are still being revised (...EG FCk-I-2394 just ciianged notes to allow clear support length of 6'9" tnead zf prev)ousIy atiowed 5'6" on rondulit supnortsi CI hac no more information.
Construction department concern."
(Sk)
Sk/NU/ss indicates satety related, by TVA beiuru
'evaluations.
5?II 2 I IJ?/22/id? I nut safety reiuteu, ur Safety Sigiiifican1, per deteriuinalion crit<<ria in the LCTG Progi ain manuaI and appiied
CONCERN ELEHEHT HUHBER ATTACSSHENT A EHPLOYEE CONCERNS FUR SUKATEGORY 22000 PLANT APPL ICABILITY LOCATIUN
~S N
MUN BFN BLN CONCERN UESCRIPT ION>>
REVISION INHBER:
PAGE A-3 OF 4 220.1 PH-85-006-001 (Cont'd) 220.2 220.3 OM-85-007-006 00-85-005-008 MUH UELE TEU X
X "Hanger Inspector utilize a locally generated hand book by management called 0-50 notes.
These notes authorize variations to banners from the original design/drawing prior to the submission of the FCR.
The FCR is submitted and approved then a change is submitted to the 0-50 notes."
(SR)
"Seismic supports were designed improperly.
They are rigid and will fail during a seismic event and will damage other components."
(SR)
"Sequoyah seismic supports are not designed properly.
They are rigid and will break loose during a seismic event and will fall down and damage other equipment, as well as failing to support their respective components.
Cl has no further information.
Construction Oepartment Concern,"
(SS)
PH-85-003-005 MUN
~ IN-85-UUb-UUI MUN (shared <<1th 20)00 and 204UU)
X X
X "Supports are not properly designed throughout Matts Bar."
(SR)
"TVA designs were not developed well enough to be constructible I) Uesign changes are still being Instituted in areas where there should have been minimal changes especially in area of conflicts between 1'VA and Vendor Drawings.
- 2) Engineering design criteria is often nonexistent, particularly for Seismic Hanger design.
Hany design criteria or acceptance criteria are still being changed.
This is generic concern.
Any further Information would divulge confidentiality.
Construction dept. concern.
CI has no further information."
(SR) 220.5 220.6 IH-85-ON-UU2 MUN UELETEU "Some hanger designs have as many as 100 revisions.
Concerned they are not adequately controlled in addition concerned with excess cost.
CI wants to be contacted on site during lunch time by ER'I Investigator At that time, CI will provide additional information and will show ERT specific examples in the plant.'SR) 220.7 III-85-091-015 MUN (shared with 204UO)
"TVA leaves too many tecnnical decisions up to the crafts'iscretion, e.g. craft design the hanger and then engineering does the as-constructed drawing.
CI has no further information.
Construction Oept. concern."
(SR) sH/No/ss indicates safety related, not safety related, or safety significant per determination criteria in the ECTG Program manual and applied by TVA before evaluations.
28570-2 (07/22'/87)
ELEIIEIT CONCERN NONHER ATTACHHENT A ENPLOYEE CONCERNS FOR SUBCATEGORY 22000 PLANT APPL ICANILITY CONCERN DESCRIPTIOHQ REV IS !OH NOHOER:
3 PAGE A-4 OF 4 s
E
~
I 220.8 220.9 IN-85-316-002 WUN 220. 10 IN-85-672-004 NHN (shared <<ith iiiOOj DELE TEO "TVA DADIADDrc nvnl'IDcEnn tnn Is A.
c I
cn..cn..s ln1
~ Q
~
D J
~
~IIU
~ IUT U<<QI Us QAQTQts IQQ ~
u AQ A I/C Luue steel is used to hold up a I" diameter pipe; also the former practice of sl1ck grinding weids (in ITO through IOO) ~
CI has no further information.
Const. Dept. concern."
(NO)
"Replacement hangers often differ from the oriEIina!
Some hannDrS arD removed but not replaced:
depending on the engineer.
CI declines to provide further Information Q
ISR}
220. 11 IN-85-103-002 HHH Q ~~ El CDvD Al DDCDC tnnlnnnst n
s I stI, s
ID D
~
~
res sssu
~ e vnl EQs
~ UAQ <<Ql C
~IUQ
~ UTIQ IUQI QU III pipe/hanger calculationssfor thermal stress.
No further information QVQ ~ 1Qble IA fIlc ~
CAAstruct lou department concern.=
(SRj I
5 220, 12 220. 13 220.14 18 85 ln3 I003 (shared <<itn 20400)
IllsSl DUE ~
STA DELE TEO DELETED
"-For Pipe/iianger calculations, no technical.review is performed after cneckers have reviewed them.
(Ko further information in file)"
INO) s
~
~
1 I
'I I
s SR/HO/SS IAdicates safety relateu, Aot safety-related, or safety significant per determination criteria by TVA before evaluationS.
570-2 (01/22/87) in the ECIG Program manual and applied
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER: 3 Page B-l of 24 ATTACHMENT 8
SUMMARY
OF ISSUES,
- FINOINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 Attachment 8 contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions.
The reader may trace a concern from Attachment A to an issue in Attachment 8 by using the element number and applicable plant.
The reader may relate a corrective action description in Attachment 8 to causes and significance in Table 3 by using the CATO number which appears in Attachment 8 in parentheses at the end of the corrective action description.
The term "Peripheral finding" in the issue column refers to a finding that occurred during the course of evaluating an concern but did not stem directly from a employee concern.
These are classified as "E" in Tables 1
and 2 of this report.
0107A-R34 (09/29/87)
Issues ATTACHHENT 8 SUHHARZ OF
- ISSUES, FINDINGS, ANU CORRECTIVE ACTIONS'FOR SUBCATEGORY 22000 Findings REVISION HUHBER:
3 Page 8-2 of 24 Corrective Actions AAAAA*AAAAAAAAAAAA Element 220.1
- 'A'eries Hanger Orawlngs ana 0-50 Notes AAAAAAAAAAAAAAAAAA SQN 47AOSO.notes are contraalctory to
'A'eries hanger drawings.
They allo~
banners bns ancnnrs and structural shapes to be accepted even though they nn nt
~ n fn n tn tna nav'I
'VV
~IUa I UII~ Ul al IV ~IIV VIt ~ ljl~
requirements.
SQH a.
The 47AOSO notes (Ref.
- 1) were founa not to be contradictory to the sample of "A" series drawings (Ref gl IevIevea by tbe evaluattnn
- team, Tbe primary purpose of the 47A05U notes Is to allow fieriblllty
~
~ ct 11 ctlnn ann
~Ianna final nl 1 Itn ln anl antenna
~ n
~ ~Itan ~ ~ a ~ ~ Ul~ ~
UIIU In In U ~
~ I I ~ U ~ ~
~ vf
~ n UvvarvWIUI Inspection.
SQN a.
Ho corrective action Is required.
b.
47AOSO notes are written ln such a way that they can be misinterpreted.
b.
The evaluation team reviewed the 47AOSO notes to aetermlne If they can be misinte'rpretea.
These notes vere fauna tn be cnnctse clear AnII easv tn internret.
b.
Ho corrective action ls required.
lr~
tL al
~
k t..
d1khsh Incf 4 dl 4 vldl I cIIOUI ~ut Udtuccll llnvvv notes and other installation documents.
Tn a vl" t lan taca a Ialnan tlla lnctal1 at Inn. hnnlvlantc I ~
~ IIV Vva ~ uav
~ Ul~
~I aaI \\ nWU I ~ ~I U
~ IIV
~
v n \\
~
~
-COnStruCtiOn SpeClfldatIOn G-43 (Ref. 6) ana HOalfiCatlOn and Aaditions instruction istAI-Il (Ref. 7).
No conflicts were faund betWeen the 47A050 nOteS and theSe dOCumentS.
Ho~ever, G-43 and HSAI-1) have some differences ln specifying pipe supnort location tolerances.
~
III ltc I nl nant IUa antlnn alan Ifdnl fnl CATO 220 Ol SQN O'I (TCAS-015, 11/26/86),
IVA ls cUI rent ly I ev IL'wing HaulfIcdL lun and Adaltlons Instructions (IcAls) under the speci flcat 1 on improvement plan.
HLAI-ll and Construction Specification G-43 are included in this review.
The dlffoleneoc botwoen l4SAI 11 anil 0-43 wtll be reconciled.
acean lc&lDIA11 dtDVV
~1+Us vl I
ATTACNHENT U
'UHHARY OF ISSUES, FINDINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 REVISION NUHBER; 3
Page 8-3 of 24 Issues Findinqs Corrective Actions
~
Element 220.1 - NBN I
a.
NRC wrote violations aqainst the 47A050 notes that these notes did not satisfy the inspection criteria as stated In Concern IN-85-010-002.
HUN
- a. Based on NSRS investiqations (NSRS report IN-85-010-002, Ref. 8), no NHC violations aqainst tne 47AU50 notes were identified.
However it was found that prior to 09/85 some of tne 47A050 notes did not nave adequately documented justification.
EN UES calculation NBP 830914230 for tne note cnanges before 10/83 does not provide adequately documented justification for all the notes.
TVA has identified the need to provide detailed calculations for th'e chanqes to the notes (after 09/85)
(Ref. 57),
and to adequately document engineering judgment (Ref. 58).
No definite coeeitments were made by TVA concerning documentation of justification for changes made prior to 09/85.
Revie<< of six calculations generated after 09/85 (Ref.
- 12) fOund them tO be COeplete and adequately documented.
NBN a.
In Its corrective action plan for CATO 22U 01 MBN 01 (TCAB-253 03/11/87),
TVA regards the calculations for justification of the 47AOSU notes as part of the missinq or partial calculations to be addressed in significant condition report (SCR)
SCRHBNCEBB531 (revision 1, Ol/14/86).
In implementinq action for the
- SCR, each note <<ill be reviewed for the existence of adequate documented justification (reference TVA/Bechtel telecon IOH 742, 03/05/87).
For consistency and ease of future revision, each 47A050 note is to have an Individual calculation package (CATO 220 01 HBN 01).
If no analysis is required, it will be so stated in the calculation.+
It is noted that SCRNBNCEB8531 Pertains to Unit 1 calculations; however, since the notes are comen to both Units 1 and 2,
a separate revie~ for Unit 2 is not required.
An existinq note which Is found unjustifiable or unacceptable will be documented as a Condition Adverse to I)uality (cA4) and will be resolved by applicable procedures.
Notes qenerated or revised after September 1985 have calculations that contain adequate documented justification.
This demdnStrateS adherence to the requirements of Nuclear Enqineering Procedure NEP-3.1 (07/01/86) formerly UEP-07 (Ref. 59), thus preventinq recurrence of this deficiency.
24599-14 (09/28/87)
Issues ATTACIPIENT 8 SUIUUNY OF
- ISSUES, F INUINGS, ANU CORRECTIVE ACTIOHS
. FOR SUKATEGORY 22000' lnatngs REVISION NUIIBER:
3 Paqe 8-4 of 24 Corrective Actions Element 220.1 - NBN (Conttnuea) b.
47AOSO notes are written ln such a
way that they are contradictory to
'A'eries dra<<lngs, and can be misinterpreted as stated ln Concerns IH-85-024-001, IN-85-932-001, 1¹85-413-001 ana IH-A5-445 n13 Some notes appear to conflict; e ~9.,
notes 30 ana 00, cltea ln COAcern IN-85-932-001.
The interpretability of the "050<< notes causes conflicts bet<<een Construction and Inspection as stated ln Concern IN-'85-413-001.
c.
47A050 notes are too numerous ana have
~imudr let itudu on hanger acceptance criteria as statea ln Concern 1N-85-932-001 and IH-US-445L 013 b.
The 47AOSO notes (Ref. 2) were founa not be contradictory to the sample of 'A" series arawlngs (Ref. 10)'evte<<ed by the evaluation team.
A general revision was maae to the 47A050 note series ura<<ings ln 09/85, to clarify ambtquous notes, resolve conflicttng notes (including llotes 30 and 100) ana
~ eITmve any tiiat were uAAecessary.
Altnough TYA has a training program (Ref. 60)-ln place to ensure consistent understanding ana interpretation of the nutes, It was founa through sttu interviews (Ref.
11) that there are still interpretational aifferences between Construction and Ouality Control C.
The 47A050 SerteS arawlngS COnSOllaate and Organtae supplementary notes for various types of supports Into one convenient set of aocuments.
Because of the broad scope coverea, the 47A050 notes are not too numerous.
b.
'In addition to its 1}A tralninq program, TYA has several other programs establlshea to help resolve 47AOSO note interpretational differences.
These include IRN trend analysts, ONE/DNC biweekly meetings which have been hela for almost 2 years (memorandum L. Rodaye to Project Files, ll/20/8&)(Ref. 61), ana the presence of an onsite eooineerloo team.
.To make personnel ln the Olvislon P
~ j atul Qa1%
Qvlllol sill nf Hat law Rs ~alii u Acc a >non Ihaodl the Division of Nuclear Construction (BNc) further aware of these proqrells, the Olvtston of Nuclear Enqlneerlnq (OHE) has coiettted in the CAP for CATO 220,01 NBN 01 (TCAB-253) to issue a memorandum so stating.
For new personnel beqlnnlnq work In ONAA or ONC(HORS)/ONC ana work ln an area related to the 47A050 notes, lt ls standard plactlce for them to be indoctrinated to the notes.
c.
Ho corrective action,is required.
Further I&Ie ~
SraTm nates prior tu thle 09/05.geAel 4 l revision may have had too much latitude on acceptance criteria, but nave been revtsed, ana are now reasonable and acceptable.
Hence.
from the engineerlnq/aeslgn standpoint,-the notes currently ao not have too much latitude on acceotaoce critel Ia 24590-14 8/87)-
0
ATTACINENT 8 SWART OF ISSUES, FINDINGS, ANU CORRECTIVE ACTIONS FOR SUUCATEGORZ 22000 REVISION NUMBER 3
Page 8-.5 of 24 Issues Findings Corrective Actions Element 220.l - NBN (Continued) d.
47A050 notes are routinely changed and ut1lized to override rejection of unaccepted hangers during installa-tion and inspection actIvitIes; (e.g., the hanger cited In Concern IN-85-052-001).
This issue is also stated in Concerns IN-85-024-001, IN-85-413-001, and IN-85-445-013.
FCR-I-2394 changed notes to allow a greater support length as cIted in Concern IN-85-445-013.
I e.
The 47A050 notes should be discontinued and the design tolerances should be specified in tne controlled inspection checklists, as stated 1n Concern IN-86-249-00l.
f.
In some cases, 47A050 notes authorIze changes to design drawings prior to generation of a FCR, as stated
'Sn Concern PSS-85-006-001.
d ~
e.
The primary. purpose of the 47AUSU notes is to allo~
flexibility In installation, and hence, flexibility Sn acceptance SnspectSun.
Houifications to the notes are Initiated when deemed necessary by Construction (via an FCR) and/or Engineering.
The notes are amended for various reasons, such as to provide resolution for a generic installation difficulty, thuS reducing the number of future FCRs for a certaIn condItion and the possibility of rejections by IRNs.
In the specific situation of the acceptance of pipe supports 2U-68-A46513-32 and 10-68-A465-3-"48, which were Incorrectly referenced in concern IN-85-05-001 (actual support number is 47A 465-3-52, Ref. 64), the oversized welds were found to be within the tolerances of 47A050 note 50 and specification G-29C.
A conflict between note 50 and SIC Procedure S)CP 4.13 was found (Ref. 8:
NSRS report IN-85-532-006);
This conf)ict was resolved and note 50 governs (Ref. 62).
S)CP 4.13 will be revIsed to state that the Engineering Drawing (47A050) governs over G-29C (change document NBN RR-403).
FCR 1-2394 (Ref. 63) (referenced in concern IN 85-445-013) does not pertain to conduit clear support lengths or the 47A050 notes.
TZA was unable to locate an FCR that addresses the Specific change in the length bet~ceo conduit supports.
The 47A050 notes are a single document created by Engineering for the use of different groups under Construction (fabrication, installation, and Inspection).
The evaluation team feels that diSCOntinuanCe Of theSe nOteS would CauSe 1neffICSenCieS In terms of implementing a generic change.
Furthermore, at this stage of plant development, It Is not prudent or beneficial to discontinue the notes.
If a given deviation/tolerance/change is already allowed by the 47AU50 nutes, then no additiunal FCR Is required because the notes are supplements to the design drawings.
N585 Repurt I-85-14U-wUN (Ref. 8), which addresses concern PN-85-006-OUI states
- that, Sn some instances, the 47AU50 notes are revised via FCRs when Constructidn requires changes to resolve generic difficulties Sn Installation.
The FCRs are approved by Engineering before they are usuu for QC inspection of hangerS.
The changeS are Performed in accordance with applicable design change procedures.
d.
No corrective action Is requIred.
e.
No corrective action 1s required.
f.
No corrective action is required.
24590-14 (09/28/87)
Issues ATTACIIHENT U SUtpfARY OF ISSUES, FIMDIMGS, ANU CORRECTIVE ACTIONS
'OR SUBCATEGORY.22000 F Inaings RE VISIOH NUMBER:
3 Page 8-6 of 24 Corrective Actions Element 220.1 - BFH I
(H/A)
SLN See BLH Element 22Ae3 perfphoral "e'or 3GA0059 series L ~ ~ICSC
~IOLCS SCI Te tele LITIIC as the SI)N/NSN 4)AUSU notes.)
ffndfng c
~ eee Loo ~
purpose a.
Seismic supports are designed inadequately.
~
11111*11111*11*111 Element 220.3
-'Oesfgn of PIpe Supports 1*11111**111111111 SFN (H/A)
BLN SijN a.
The S(N pipe support design criteria (Ref.
- 14) aaequateiy address the seismic desian reauircments.
Some calculations (Ref. 18) for sefsmic supports were observea tO be fnCOmniete (they Wore cuipplements tn tno Oi.fgfnal calculations),
and some calculations lacked documentation Of Cngl<<lCCI Ing Judg0%l<<t used'he Sl<<ppvrLS lr<<LN Cumpiete calculatIons were-found to be aaequately aesfgnea for seismic design requirements.
BFM (N/A)
BLN IIIIIIl
<<elm<<
SliN In fts correctIve action plan for CATO 22A U3 sAN Al /Tran-A35 12/ln/ASi)
TVA coenfts to perform calculations for ihe observations noted fn riiinc pipe supports faent1f fed fn the Element Report.
These caiculai fons will aemonsirate thai ihe seismic design criteria have been properly implemented fn Si)N pipe support designs.
Punohfng shear support aesign bee oc no 1 r r re Iree-ere ~ ncl ~
renufrements are nat fnoluaoa fn tho nine criteria (reference:
Policy Memorandum co<<
vvr ~
Cnrroctlvo actfnn ic nrnviaoe<<bee tho rap for CATO 220 03 HPS Ol (TCAB-641,
-nnencenTI I
n
~ I r r
I- -
a nnn VVIVVIVIt ~
aee uel leIVIILe eleIPLIIL LLVeo~
Uesign requiremenis for base piaies and anchorage boiis (base plate flerfbfifty, marimum unnormal ized load, and construction tolerances) were not specifically aadressed In this report because the reauIrements are within the scope of and addressed by Construction Subcategory Ponce t 10aOn For appiicabie corrective action see Construction Subcategory Report 10400.
~ ~
I...a.....
24590-+pe/28i87)
Issues ATTACSSMUIT 8
SUMMARY
OF
- ISSUES, FIHDIHGS, AHU CORRECTIVE. ACTIONS FOR SUBCATEGORY 22UUO Findings REVISION NUMBER:
3 Page 8-7 of 24 Corrective Actions Element 220.3 -
SS)N (Continued) b.
The supports are too rIgid and will break loose during a seismic event and will fall on other equipment and damage it.
- b. The Issue that seismIc supports are too rigid has been addressed In NSRS Report Ho. I-u6-131-SqN (Ref. 13).
ThIs repurt states that:
"In seismic analysis uf pIping systems, supports (Including snubbers) are assumed to be absolutely rigid (zero deflectIun under load).
The support loads are developed based on an amplified response of the flerible piping.
As long as supports are 'more rigid'have higher frequencies) than the piping or the dominant seismic frequencies, the zero deflectIon assumption In the analysis does not cause a
significant error in support load calculations....
(The supports are designed taking Into account the above described support load,] and the flexibilityof the support Is maintained by limiting support deflection to I/16 inch under the design load."
The HSRS report concluded that seismic pipe supports are designed to carry Toads based on piping analysis that assumes the supports are rigid.
Furthermore, the supports are sufficiently designed to prevent them from breaking loose during a seismic event.
The evaluation team concurs with the NSRS report.
Rigidity/deflection requirements are properly addressed In the seismic pipe support design criteria.
b.
Ho corrective action Is required.
c.
Ko corrective action is required.
c.
Pipe support deSigns are not constructible.
C ~
Two likely conditions that affect the constructibility of support designs are:
o Installation Interference with other coeeoditles and plant features o
Incomplete drawings Issued to Construction (the Issue of Incomplete'drawings Is addressed in detail in element evaluation 222,3)
It Is possible that some supports could not be Installed during construction becauSe of Interference with other conmodities.
Such Interference problems are coauen during the course of the design and construction of nuClear pOwer plantS.
MOdifiCatiOn Of a Suppart deSign caused by interferences does not Indicate a lack of constructibility In the Initial design.
24590-14 (09/28/87)
Issues 1
Elenent 220.3 - SI)H (Contlnuea)
I I
d.
Seismic support aeslgn criteria are hhhhcfcthnt D aa WOII a.
The pipe supports are not deslqnea adequately.
ATTACNtfENT 8 SUfufARY OF
- ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 F fnafnqs The evaluation team revleweu a sample of pipe supports arawfnqs to verify If they were complete.
The support drawings (Ref. 22) were examlnea for the presence of correct weld symbols, bill.of. materials, sufficient almenslonai Information, ana clear deslqn aetalls, etc.
The drawings reviewed were founa to be basfcally
- complete, and therefore, constructlole.
a.
Si)H seismic support aeslgn criteria nave existed since 4....
~
1 ~I1C huafuat lblpt ifdN
- a. In the evaluation team's,review-of calculations for 28 nloe sunnorts (Ref. 19).
24 suooorts were found to be adequately designed based on applicable wUN deslqn
~ tn it anti etc h
th
~
- 1. ~ t ~
t 4
\\ ~
~ tpa
~ P ~
naaaaayt Ip Vy tlap PVQ ~ opt alla ~
~ CPah Vl
~ Vul supports (47A060-'3-23, 47A060-70-27,
'1-63-404, ana 1-74-llj was required because of the application of Incoriect loads and load sign combfnatfonst As a result, these four supports were found to nave overstressed member~ base plates, we!as, and:anchor bolts ~edtng the fnaxfmum Interaction value.
Some of the calculation documentation for the sample of 28 pipe supports
<<as founa to be Incomplete and/or to ontaffi fnfno afs fepanc os (mtssf g nocux ntatfof foh consideration of punchlnq siiear, spring top out/bottom outa slflng 4ngle, member stresses, etc. j.
Fffidiriqs xin AISC minimum weld requirements '(Ref. 65) ana ~eldlng on twO OppOSlte SldeS Of tubfnq are aaareSSea in WBN evaluations for elements
?22.6(A) ana 221.7(A).
REVISION NUHBERt 3
Paqe 8-8 of 24 Corrective Actions d.
No corrective action Is required.
a.
TVA will re-evaluate the designs of the fOIIr pioe Sunnartd not ov etfno Code stress allowables ln an effort to Vial UPCI afICl II IV \\ 444Ca Ul LIICII deficiencies.
If warranted, the causes are to be referenced ln the WBH Pipe Support Oeslqn Hanual (Ref. 26) for future avoidance.
TVA will perform any nilvsfoal madifloatfnn renuired ta ov et code stress allowables for the four
~
t Tkt tf c tt t ~
Pufafavl ta ~
~ II ~ 4 favl t IUI~ Ul tllC \\ Ul I Ca t ~ vg action will be Initiated and tracked by Problem iaentification Report PIR'BN,WBP 873'I (02/18/87).
In fts corrective action olan for CATO 220 03 wBN 01 (TCA8-213, 02/25/87),
TVA Will"nncaaa.n that Cnaih ct ~ Pcc allnutblnc are met for all enqfneered pipe supports tiiioiigii life Uiiit I N4ngef 4na Alio lysis Upaate Proqram.
The SCOpe Of this program also includes completion of missing documentation.
Unit 2 pipe supports are to be evaluated later under a similar program (also trackea bv CATO 220 03 wBN O'I).
ONE policy fnemorandum PN 86-04 (Ref. 50) requires that englneerinq judgment <<ill be properly documented.
24590-~/28/87)
Issues ATTACNNENT 8 SUHrORY OF ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS
~ FOR SUBCATEGORY 22000 F indIngs
'EVISION NUHBER:
3 Page 8-9 of 24 "Corrective Actions Element 220.3 - wBN (Continued)
Oesign requirements for base plates and anchorage bolts (base plate flexibility maximum unnormalized load, and constructIon tolerancesf were not specifically addressed In thIs report because the requirements are within the scope of and addressed by Construction Subcategory Report 10400.
Punching shear requirements are not Included In the pipe support design criteria (reference:
Policy Nemorandum PH 86-04).
For applicable correctIve action, see Construction Subcategory Report 10400.
Corrective action Is provided by the CAP for CATO 220 03 NPS Ol (TCAB-641, 08/06/87).
See Bellefonte element 220.3.
b.
Seismic supports are too rigid and will break loose during a seismic event and will fall on other equipment and damage It.
- b. The issue that seismic supports are too rigid has been b.
No corrective action Is required.
addressed In NSRS Report I-86-)3I-SON.
This report states that:
"In seismic analysIs of piping systems, supports (Including snubbers) are assumed to be absolutely rigid (zero deflection under load).
The support loads are developed based on an amplified response of the flexible piping.
As long as supports are
'more riqid'have higher frequencies) than the piping or the dominant seismic frequencies, the zero deflection assumption In the analysis does not cause a
significant error in support load calculations....
(The supports are designed taking into account the above descrIbed support load,] and the flexibilityof the support Is maintained by 11miting support deflection to 1/16 Inch under the design load."
The NSRS report concluded that seismic pipe supports are designed to carry loads based on piping analysis that assumes the supports are rigid.
Furthermore, the supports are sufficiently designed to prevent them from breaking loose during a seismic event.
The evaluation team concurs <<Ith 'the NSRS report.
Rigidity/deflection requirements are properly addressed In tne seismic pipe support desiqn criteria.
24590-15 (09/28/87)
Issues ATTACHHENT 8 SUHHARY OF
- ISSUES, FINDINGS, ANU i'.URRECTIVE ACTIONS FOR'SUBCATEGORY 22000 Findings REVISION NUHBER:
3 Page,8-10 of 24 Corrective Actions Eleeent 220.3 - NBN (Continued) c.
Pipe support designs are not constructible.
c.
Two IIKe)y conditions that affect the constructibility of support designs are:
o Installation interference with other coaeodities and as Iat 4a>C
~ at c V I UII a
~ ~ 8 cU ~ 4 c o
incoayieie drawings issued to Construction (the issue of Incoatplete drawings Is addressed in detail in eleeent evaluation 222.3) c.
No corrective action Is required.
d.
SeISimIC Suapai.t deSign criteria.are nonexistent.
It is possible that some supports could not. be installed dlllrIng constlUctioil vecaUsc of Intel feience with other coaeodlties.
Such interference problems are comnon during tne course of the design and construction of nuclear pawer plantS.
HOdlfiCatiOn Of a Suppart deSign caused by interferences does not indicate a lacK of constructibility in the initial aesian, d
UattC Bar 5DISalic ceuhPOrt dettian C~ isar la I cua
- e. Ittad since August 1975.
d ~
iqo corrective 4ct ion is requivedI 24590 ~/28/82)
Issues ATTACH<<ENT 8 SUNQRZ OF
- ISSUES, FINUIMGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 F fndfngs REVISION NUNBERt 3
Page 8-11 of 24 Corrective ActIons Element 220.3 - BFH BFN BFN a.
Seismic pipe support desiqn criteria
- a. Seismic desiqn criteria for engineered pipe supports dfd are nonexistent.
(Concern IM-85-886-001) not exist for BFN prior to 1980.
Supports were designed usfnq Industry standards.
The present BFN crfterIa BFN-50-724 (Ref.
- 16) adequately address seismic pipe support desiqn criteria.
TVA has not complete'd its coamfteent to fssue criteria for box anchors and a pIpe support handbook.
a.
In fts corrective action plan for CATO 220 03 BFM 01 (TCAB 441 ~ 07/18/87 ) i TVA conmfts to issue BFN Box Anchor Oesign
~
Criteria and Pipe Support Qesiqn Handbook by 08/31/87.
The handbook wi11 address deflectIon/rfgIdfty and punching shear requirements.
l b.
Sefsmic pipe supports are too rigfd and
<<fll break loose durIng a seismIc event and <<111 fall on other equipment and damage ft.
(Concern 00-85-005-008)
D. The Issue that seismic supports are too rfqfd has been addressed fn NSRS Report I-86-131-5(N.
This reports states that:
"In seismic analysis of pipfnq systems, supports (Including snubbers) are assumed to be absolutely rigid (ZerO defleCtiOn under IOad).
The SuppOrt 1OadS are developed based on an amplfffed response of the flexible piping.
As lonq as supports are
'more rfqId'have hfqher frequencIes) than the piping or the dominant seismic frequencies, the zero deflect1on assumption In the analysis does not cause a
Significant error fn support load calculations....
(The supports are desfqned taking into account the above described support load,] and the flexfbl)ftyof the support is maintaIned by Ifmftinq support deflection to I/16 Inch under the design load."
The NSRS report concluded that seismic pipe supports are designed to carry 1oads based on piping analysis that assumes the supports are rigid.
Furthermore, the supports are sufficiently designed to prevent then from breaking loose durIng a seismic event.
The evaluation team concurs with the NSRS report.
Rigidity/deflection requirements are properly addressed in tne seismic pipe support design criterIa.
Because of the absence of deflection/rigidity requirements fn key design criteria (BFN-50-706); seismic pipe supports may have been designed nut "rigid" enough to validate pipe stress analysis riqfdfty assumptions.
(Tnfs condition nas also been identified by a SCR BFN CEB 8608 and an NRC finding, Ref. 66.)
b.
TVA also coamfts (under CAP for CATO 220 03 BFN 01, TCAB-441) to revise BFN-50-706, 'General Oesiqn Criteria for the Torus Inteqrfty Long-Term Proqram,'o include deflection/rfgIdity and punching shear requIrements.
BFN has also initiated the Calculation Verification Review Program (Ref. 49) to review pIpe support calculations.
(This program documents corrective action for several Conditions Adverse to l}ualfty, cAOs, scRs; and PIRs.
The program Is tracked by these documents.)
If required, pipe supports will be modified.
Under this revie~, the pipe supports (including RCIC H62 unit 3 and RCIC R51 unit 2) <<111 be evaluated for punching 'shear and deflection/riqfdity requirements.
Revision of criteria BFN-50-U706 and issuance of the Pipe Support Design Handbook will prevent recurrence.
24590-14 (09/28/87)
Issues ATTACNENT 8 MNHANY Ut ISSUEb.
FINOINGS, ANU CORRECIIVE ACTIONS FUR SUBCATEGORY 22000 F Indings REVISION NUMBERI 3
Page 8-12 of 24 Corrective Actions k)ement 220.3 - BFN BFN Seismic pipe supports except those under the LTTIP will be evaluated for deflection/riqidlty requirements specified in BFN-50-/24 under the IEB 79-02//9-)4 program tRef. 6/).
Currently LTTIP criteria contain no oipe support deflection/rigidity requirements.
BFN CEB has COdniltted tn oyaluato I TTIP nlno cunnnrt'slrlll stinn fnvr BFN-bU-/24 deflection/rigidity requirement under its internal calculatiun yerlflcitioA review program.
This
<<Ill establish the validity of the pipe stress analysis riqidity,assumptions and accuracy of the pipe support loads ~
c.
Seismic pioe suooorts are designed inadequately.
(Concern 00-85-U05-008) c From the oydludtldn todmIc reyioW nf Calr uistlnnc fnr 31 pipe supports from tnls element (Refs.
20 and 2)) and
)U f
t lrst Ja1
~ Ul S
1
~
na1 1
i
~ ~ srr suuiasayul j ta.Ivu svI aIaamIli ca I ~ I ~ suyIIuI is Wara found to be adequate for the specified loads.
Although tne pipe supports were found to be adequate, their associated calculations were found to be Inconp)ete and/or contained minor discrepancies (punchlnq shear is not considered for tube-to-tube connections, and baseplate flexibilityis not considered In the evaluation bO)tsl Ihe Ca)ru)atIOA-fur SOPrndrt RILSI lt)QU unit 3 did not state the. basis for-the assumption used to qualify the Shear -furee OA the anChOr ~) tS, and -did-AOt provide analyses for the critical baseplates.
r Tud UIII vnv tea tt n l sir llstinn fnv nina
~
~
~ ~ ~
~ U ~ ttv
~ Hl
'bU ~l U ~ U ~ ~ Ull
~ Ul It ~ Il~
support RIM Rlb9 unit 3 to provide iAalysis for the critlcil bise plites in sections A40b and 840b of the drawinq and to incorporate all applicable assumptions used to qualify the shear force on the anchor bolts (CAP TCAB-44) for CAIU 220 U3 BFN Ul)i Ihe evaluation teimlS fIndinqS are COAWIstent with findings from various NHC. reports (Ref. 66),
an NSRS report (Ref. -68),
SCRs- (Ref. 69),
and PIRs (Ref. -69)-.
In
- addition, tnese documents also state there is a lack of adequate checkIAg.
BaSeplate flexibilityand anchoraqe bolt requirements
<<ill be addressed in Construction Subciteqory Report
)040ut Rl.
BFN his comnltted to Imo)ement corrective action for these Identified deficiencies tn I it Icu 'ln n'attn 1s 8
ilnuuyu
~ ts
~ su tsvvcf ts-Ia IlluyIaal alla Its instruction for the calculation verification review program (for LTTii'.j.
For applicable corrective action, see Construction Subcategory Report IU4UO.
24b9U-~/28/8/I
Issues ATTACNHENT 8 SUHHARY OF ISSUES, FINDINGS, AHO CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 Findings REVISION NUHSER:
3 Paqe 8-.13 of 24 Corrective Actions Element 220.3 - SFN (Continued) d.
Pipe support deslqns are not construct lble.
(Concern IH-85-886-001) a.
TwO likely COndltlOnS that affeCt tne COnStruCtlblllty Of d.
NO CarreCtiVe aCtlOn IS required.
support designs are:
o Installation Interference with otner coaeodities ana plant features o
Incomplete drawlnqs Issued to Construction (the Issue of incomplete drawlnqs is aaaressea ln detail ln subcategory report 25500 for element 222.3.
t BLN l
a.
Seismic pipe supports are designed inadequately.
It Is possible that some supports could not be lnstallea aurlng construction because of interference witn other coaeodltles.
Such interference problems are coamon during the course of the design ana construction of nuclear power plants.
Hodlflcation of a support design causea by lnterferences does not lnalcate a lack of constructlbility ln the lnltlal design.
BLN a.
In the evaluation team's review of calculations for 22 pipe supports (Ref. 21), the supports were found to be aaequately deslgnea In accordance with applicable SLN pipe support design criteria. It was found that BLN Criteria ana FSAR SpeClf led deSlgn lOaaS ana allOwable stresses devlatea from the ASHE Section III-1974 NF code (Ref. 51).
These deviations were Identified and aaaressea by NCR BLN CE88110 (Ref. 70).
The final report for HCR BLH CE88110 was transmitted to the NRC for review.
The NRC reviewed and approved the deslqn loads ana allo~able stresses ln this fina'I report (Ref. 71).
lt was notea that provision for upset primary plus secondary were inadvertently left off FSAR Table 3.9.3-37.
Ho~ever, these provisions are included ln BLN pipe support criteria, ana hence (TYA states that) this condition ls considered In the pipe support design.
BLN a.
In Its corrective action plan (TCAB-638, 08/06/87) for CATO 220 03 SLH 01, TVA coenits to revise FSAR Table 3.9.3-37 (Amenament
- 24) ln the annual FSAR update to include deslqn load and allowable stress for upset primary p'lus secondary.
It is noted that this Information was lncluaed on the revision of the table before Amendment 24.
24590-15 (09/28/87)
Issues ATTACHMEilT 8 SUMMARV OF ISSUES, FINDINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 Findings REVISION NUMBER:
3 Page 8-14 of 24 Corrective Actions Element 220.3 - BLN (Continued)
The aOCumentatSOn Of the CalCulatiOnS fOr the Sas<sple Of 22 pipe supports were found to be Incomplete and/or contained minor alscrepancies.
Lack of corputer Input/output data was a consistent observations TVA-also co<<<<Sts to retrieve the computer output from ITT Grinell for the eight subject pipe supports (via procurement renuest M-1937)
Tva ~ 4
< nntras t n20732 with ITT Grinell, states that the vendor
<<Tt<.. ~ s's o
s
's
.. ~
Ls os ~
<<s s< wss s
russ<sr<
a cess usaL<on t << e ~
Including computer'output five years after shipment of the final item on the contract or two years after coaeercial operation, whichever Is later.
ICATU 220 n3 e N nit A aesinn dof <cioncv vas nbsos vod fos tho oln o~<s split<~
between Item 1 and item 3 for pipe support lou unur nMo rs...
<o o s
's
~ v..
s a
~ws=rossv=vvvns
~ ssu Wusv vchsgss
<c<sgl<<
USeu sss
<<su calculation is greater than the actual Installed weld which was performed according to normal site practice.
In addition, a procedural,deficiency In the'calculation fdr pspC Siippart OSA-MPiiG-0073 WaS ObServed due tO tne lack of continuity and clarity of status for the sheets; ThlS iS adareSSea in SubCategOry 24600'far BellefOnte element 205.I.
r o<
os o
ov sv o ~ os s
vvs
~ uvre <V<'vo svss su<
Lssu sssass
< s <uu
<se<<<
conaltlon between Item 1 and item 3 for pipe support 10N-MpiiG-0054 will be provldea by Condition Adverse to equality Report CAI)R BLF 810098
[RIMS 805 8706I2 318].
This CAI)R initiates action to laentify, review, and modify If necessary, tuho steol ~rs with this weld condition.
For applicable corrective action see Subcategory Report 24@0.
24590~9/28/87)
Issues ATTACttttENT 8 SUSQRY OF ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS
. FOR SUBCATEliORY 22000 Fina inqs REVISION NUttBERt 3
Page B-)5 of 24 Corrective Actions Element 220.3 - BLN (Continuea)
Design requirements for base plates and anchorage bolts (base plate flexibilIty,ltUL, and construCtion taieranCeS) were nOt SpeCifiCally addreSSed In thiS report as ttie requiremerits are within the scape of and adaressed by Construction Subcategory Report 10400.
PunchIng shear
<<as not considerea In the pIpe support calculation for all four plants.
This requirement was generally not Incluaea in the aesign criteria.
For applicable corrective action see Construction Subcategory Report l0400.
In the CAP for CATO 220 03 NPS 01 (TCAB-641, 08/06/87),
TVA coamits to Incluae the punching shear requirement In Civil Oesign standara OS-C1.6.1 which covers all plants and applicable design criteria.
This action <<ill prevent recurrence.
A generic evaluation, covering all
- plants, was performed
( In accordance with TVA memorandum Ol/31/86, RIHs 841 860131 018) to review previously generated calculations for punching shear.
The results Indicated that in some areas punching shear was not COnSidered.
CAt}RS Were written tO address the problem areas.
b.
Seismic pipe supports are too tIgid ana <<Q1 break loose auring a seismic event ana will fall on other equipment and damage It.
b.
Tne Issue tnat seismic supports are too rigid has.been '.
No corrective action Is required.
aaaressea In NSRS Report I-86-131-St}N.
Tnis report states that:
"In seismic analysis of piping systems, supports (Including snubbers) are assumed to be absolutely rigid (zero aef lection unaer load).
The support loaas are developed basea on an amplifiea response of the flexible piping.
As lonq as supports are
'more riqia'nave higher frequencies) than the pipinq or the dominant seismic frequencies, ttte zero deflection assumption In tne analysis aoes not cause a
significant error In support load calculations....
(The supports are aesiqned taking Into account the above described support load,J ana the flexibilityof the support Is maintainea by 11mitinq support deflection to 1/16 Inch under the aesiqn load."
24590-14 (09/28/87)
I*
Issues
'ATTACtlMENT U SIP%HART OF. ISSUESF INUINOS, ANO CORRECl'I VE ACTIONS FOR SUUCATEGORZ 22000 Findings REVISION NUMBER:
3 Page S-)6 of 24 Corrective Actions
)
Element 220.3 - BLN (Continued) c.
Seismic pipe support designs are not constructible.
Tne NSRS report c'oncludeo that seismic pipe supports are deslqned to carry loads based on'piping analysis that'ssumes the supports are riqid.
Furtnermore, the supports are sufficiently desiuned to prevent them from breakinq-loose during a seismic event.
Tne evaluation ID>lh tllnl'lire with tns. Nape itint, 0 Eila(t laiflaitii
~
9 j ~
% pMI ~
A ~ j ~ ll ~ ty/%CO
~ VAI~ MI~
requirements are properly addressed In tne seismic,pipe Suppdl t,deSIgn cl ltel lan c.
Tuo likely conditions,that affect tne constructibillty of, suppoit designs are:
c.
No corrective action 1s required.
d.
Seismic pipe support design.criterla-hii 'Eitiit OI 6
~IVII4 \\ ~ 4 i%
~ ~i ~
o installation Inta rference ultn other*conuodit les and plant. features o
Incomplete drawings issued to Construction (the issue oi Incerpiete draulnqs ls addressed in'detail in subcateqory report 25500 for element 222.3)
It Is possible that some supports could not be installed during construction becauSe of Interference with otner coFiiOItles ~,Suctr-Interferencw prob)e is -4A cocwN
during.tne course of tne design and construction of nuclear. power planets.
Hddiflcacion or a support design caused-by Interferences does not Indicate
- a. lack of constructibIIIty in the Initial'design.
d.
ULN seismic support design criteria nave existed since 3036.'.
No corrective action ls required.
24590-~/2U/Ul )
ATTACIIHENT 8 SUHHARY OF ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS
'OR SUBCATEGORY 22000 REVISION NUHBER:
3 Page 8-17 of 24 Issues F Indinqs Corrective Actions Element 220.3 - BLN (Continued) e.
Peripheral finding - (same as 220.3 issue "b") BLN field option and tolerance notes (3GA0059 serIes) can be misinterpreted.
.e.
Tne 3GAUU59 series drawings (Ref. 3) were found to conta1n reasonable and clear field option and tolerance notes.
Some notes did not have adequately documented justification.
e.
TVA has initiated corrective action through CARR BLF 870126 (RIHS 805 870714 303] is part of CAP for CATO 220 03 BLN Ol.
ONE coaeits to rev1ew the 3GA0059 series notes and provide calculations and/or technical juStifiCatiOn fOr thOSe nateS whiCh haVe no documented technical justification.
1A011IS1*II1SAAA11 Element 220.6
- Revisions to Hanger Uesiqn
- ato*0101*110AI110 (N/A)
NBN a.
Pipe support designs are inadequately controlled and nave as many as 100 i revisions.
SIJN (N/A)
HBN
- a. watts Bar folio~ed "900-Series" for numberInq tne revisIons of pI pe support drawinqs.
First revision made by watts Bar after takinq over the desiqn respons1bility from the contractor (Bergen Paterson or EDS) are numbered 901 and so on.
Uuring the revie~ of approrlmately ll,300 pipe support deSign drawinqS, frOm WBN'S hanqer traCking prOblem report (Ref. 26), three supports were observed with ll revisions and fIve <<Ith 10 revIsions and another'itn 7
revisions.
No p1pe support desiqn dra~ing had anywhere near a current revision number approaching a magnitude of 100.
SUN (N/A)
HBN a
Ko corrective action is required All pipe support desiqn drawinq revisions were either the result of an Engineerinq Change Notice (ECN),
a Field Cnange Request (FCR), or other justifiable reasons suc6 as changes in design loads or chanqes in location plan dimensions.
All revisions reviewed snow evidence tnat they were adequately controlled through microfllming.
24590-14 (09/28/87)
Issues ATTAClNENT 8 SUHHARY OF
- ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 Fina lngs REVISION NUHSER:
3 Page 8-18 of 24 Corrective Actions Elonent 220.6 - SFN (H/A)
BLN SFN (H/A) eLN BFH (N/A)
(H/A)
(NIAl
/
111111111111111111 Element 220.7
- Installation-relatea Technical Ueclsions III U IILII (N/A)
SQN (N/A)
NBN a.
The crafts-assume too much responsibility for originating aesign.
b.
Engineering follows up on these designs by revising the affectea design drawing per the as-built condition, without engineering review ana approval.
RFII (H/A)
SLN
~
(N/A)
SQN (N/A)
NBH a.
There ls no evidence that the crafts or anyone else ln TVA's Construction organization has assumed responslbilltles bIyond those called for ln the applicable FCR procedure (Ref.. 29).
- b. There is no evlaence that-Engineering llmltea its activity to simply revising the design drawing without applying the requlrea analysis or review of the suooort redesign.
(N/A)
(N/A)
SQH (N/A)
NBH a.
Ho corrective. action ls reauired, b.
No corrective action ls required.
U L' 1m (H/A)
SLN (N/A) 2459~09/28/87)
Issues ATTACHMENT U SUNWNY OF
- ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 Findings REVISION NUNUER:
3 Paqe B-19 of 24 Corrective ActIons 1*1*ISA****ONINA10 Element 220.9
- Over-,sizing of Pipe Support Steel and Slick Grinding of welds 0141*AN1O>tOI11010 SQH (N/A)
NBN a.
Economy Is not consIdered In the sizing of pipe support frame members during the design process.
b.
The former practice of slick qrInding welds Is unnecessary.
BFN (H/A)
BLN (N/A)
(H/A) wUH a.
To keep tne designs
- simple, TYA's small pipe standards (Ref. 72) have, at times, specified uiing larqer structural members instead of makinq unique designs.
This practice nas been found to be economical In that It saves a great deal of valuable time In design and analysis..
Furtnermore, TVA provides guidelines that allow Construction to make substitutions for structural members shown on design drawings, depending upon tne availability of material or for any other valid reason.
Such a
substitution may result In a larqer member than would Oe required If a unique calculation were performed for this partIcular situation.
- b. with regard to the former practice of slick qrindinq of
- welds, a TVA Interoffice memorandum (Ref. 30) acknowledqed that tnis practice "has been an area of confuiIon In the past and this practice has not been required by Engineerinq, but has been performed by Construction at wUH because of the misconceptions of requirements."
BFN (N/A)
ULN (N/A)
SQH (N/A) wUN a.
Ho corrective action is required.
b.
Ho corrective action Is requIred.
UFN (N/A)
BLN (N/A) 24590-)4 (09/28/87)
ATTACHMENT 8 sIPuIARY UF IsSUEs, FINUIHOs, AHU coRREcTIYE AGTIQNs FOR SUNCATEGORY 2?000 REVISION NUNBER:
3 Page 8-20 of 24 Issues F lndlnqs Corrective Acttons nooooo*ooo*ooooo**
Element 220.10
- Replacement Hangers
- OOOOAO*O~ O*OOOOOO SQN (N/A1 on Won Inca\\
gntn>
wuN (N/A) wBN a.
The 1nstalled pipe-supports have often been xodlfied and ln some cases deleted (renoved but not replaced).
8FN (H/A) 8LN luzot gntnt a.
TYA has a procedure (Quality control Procedure OCP 4-23 3 nof 321 tthat cnortftoc tho tncnoott documentation requirements of the location. and ol Iel tat lonof pipe supports.
This procedure verifies that the pipe supports are installed within the-llxits of ine specified tolerances.
The evaluation team, selected and examined,ten examples of Safotw rolated ntnlnn nrnhlomc IRef 331 rhea o c nor changes occurred (including deletions).
In all nstonces
~he P IPc suPPort changes were just Ifled by FCRs/ECHs.
8FN (H/Ai Otw ln ~ c \\
Snfnt a.
No corrective action ls required.
(N/A) aaoawoawooaawxaaaa Element 220.11
- Temperature Variation ConsiderationS ooooooonoooooooooo
~
'QN SQN SQN a.
The expansion of structural aeaberS reStra1ned between two rigid points (such as concrete surfaces) will cause add!tldnal lnadlng Oh members a.
The lack of consideration for temperature varlatlon ln the SQN pipe support desiqn would cause additional loadlnq on members res w
t o I ld olnts.
The propncod SQH correc adequately address the pipe suppol t des Iqn ~
a.
In its corrective action plan for CATO 220 11 SQH Ol (TCA8-003, 11/07/86),
TVA will ident!fy Steel structures w1th I.
7459 gi28i8/)
Issues ATTACUHENT 8 SUNDRY OF ISSUES, FINDINGS, AHU CORRECTIVE ACTIONS
~
FOR SUBCATEGORY 22000 Findings REVISION HUHBER:
3 Page 8-2I of 24 Corrective Actions Eleeent 220.ll-SI)H (Continued)
The steel structure is overstressed and th1s overstre'ssing cannot be Just Ified.
b.
The therual expansion of p1pe will Iepose loads on the pipe supports.
NBN a.
The expansion of structural xeebers restrained between two rigid po1nts (such as concrete surfaces) will cause additional loading on eeebers.
b.
The thermal expansion of pipe will iapose loads on the pipe supports.
BFN a.
The expansion of structural eeebers restrained between two r iqid points (such as concrete surfaces) <<ill cause additional loading on eeebers.
b.
The pipe expansion Ieposed loads on pipe supports are cons1dered 1n the S(N pipe support design.
NUN a.
The lack of consideration for teeperature variation in the ~atts Bar pipe support design would cause additional loading on eenbers restrained between two rigid points.
The proposed corrective action plan to Matts Bar problen identifiCat1On repOrt PIR MUHCEB8536 (Ref. 36) will adequately address the teeperature variation 1ssue for pipe support des1gn.
b.
Tne pipe expansion Imposed loads on pipe supports are considered in the watts Bar pipe support design.
UFN
- a. Although the ASHE code does not require evaluation of thermal stress in p1pe support structural eeebers, the evaluation team considers it prudent to evaluate thermal stress 1n any support structural eeeber that is attached at both ends to a concrete surface.
- However, no eeebers (pipe support or otherw1se) of this nature were found at BFH, based on evaluat1ons performed by both TvA and the evaluation team.
b.
No corrective action is required.
NUN a.
Ho additional corrective action is required beyond the corrective action plan to PIR NBN CEB 8536.
CATO 220 ll wUN Ol is provided only for ECTG tracking of the corrective action of PIR QBH CEU 8536.
b.
Ho corrective act1on 1s required.
UFN a.
No corrective action is required.
24590-)5 (09/28/BT)
ATTACIIHEHT 8 SNHARY OF ISSUES, FIHDIHSS, AHU CORRECTIVE ACTIONS FOR SUBCATEGORY 22000 REVISION NUHSER:
3 Page 8-22 of 24 Issues F lna lngs Corrective Actions Element 220.11 - SFN,(Continued) b.
The thermal expansion of pipe <<ill impose loads on the pfpe supports.
I NOTE:
Althougn the folio<<ing 1ccue ic nnt df ~ ect1v relatnn in the statement of concern, wnlcn was orlglnaica at Naiis Bar, the evaluation team conslaerea it appropriate to address lt within the context of applying tne concern to Browns'erry.
SLN c.
A aetalled Inspection and aesign l
revle<< ls requIrea for all pipe supports subjectea to elevatea temperature effects resulting fron the Narch 22,
)975 fire at SFN;
- b. The pipe expanSfan-fmpOSea 1OadS On,pipe SuppartS are COnSlderea in the SFN pipe SuppOrt aeSlgn.
c.
1'ne criteria (UFN-50-0/03 ana UFN-50-0705, Ref.
- 16) for evaluaiing siruciural sieel components and piping subjectea to tne 03/22/15 fire are aaequate to establish wnlch structural members (inclualng pipe support framing)
'ave been damaaea because of a hfan-temnerature environment and were,, therefore, suoject to replacement.
SLN b.
No corrective action ls required.
c.
Ho corrective action is required.
SLH a.
The expansion of structural members restrained between two rigid points (such as concrete surfaces) will cause adds tfonal lnadfnn nn Innnbee c b.
Ttie thereal expansion of pipe will impose loaas on the pipe supports.
a.
SLH has coaoftted to evaluate ihe embeaments for thereal a.
No additional corrective action is expansion loaas.
Ho<<ever, 'to aate, this task has not required beyond the-corrective action been completed.
plan to PIR SLN CES 8512 (Ref 55) o.
Tne pipe supporis-are aaequaiely aesignea for the loads b.
Ho corrective action ls required.
from the piping thermal analysis.
24590
/2b/Bl )
issues ATTACNHENT 8 SUGARY OF ISSUES'lNUIHGS, AND CORRECTiVE ACTlONS FOR SUUCATEGORY 22000 Findings REVlS10N NUHRER:
~ 3 Page 8-23 of 24 Corrective Actions 10**iHtHi*i0I0**
Element 220.12
- Technical Rev1ew AiiittfitliAAaiNA*
SQN (N/A) a.
Technical revie~ ls not performed after checkers have rev1ewed pipe support calculations.
SQH (N/A) wUN
- a. ln response to issue "a," the evaluation team determined the following:
o TVA des1gn calculations procedure EN UES-EP 3.03 (Ref. 46) and office of Engineering Procedure 0EP-10 (Ref. 46) require the section supervisor, by signing at the "submitted" block of the calculation cover
- sheet, to attest that the calculations are performed and checked by technically qualified persons.
Additional technical review after the checker's review is not mandated by these procedures.
o TVA procedures EN OES-EP 3.03 and OEP-10 meet the requirements for design verificat1on as specif1ed by 10 CFR 50, Appendix 8 (Ref. 4) and ANSl K45.2.1)-1974 (Ref. 5).
o ln add1tion, the TVA (civil engineering branch chief) had conducted independent technical revie~ (Ref. 48) of pipe support calculations to verify technical adequacy and compliance with pertinent controlling documents/procedures.
o The evaluation team reviewed 20 randomly selected pipe support calculations (Ref. 4l) from safety-related p1ping systems from both units and determined that they comply with the requirements of procedures EN OES-EP 3.03 and UEP-10.
SQN (N/A) a.
No corrective action 1s required.
2459D-15 (09/28/87)
Issues ATTACMNEMT B
SUMMARY
OF ISSUES, FIMUINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22000
'F Innings REVISION NUMBER:
3 Paqe B-24 of 24 Corrective Actions Eleeent 220.12 - BFN (N/A)
(N/A)
BFN (N/A)
ULN (M/A)
BFN (N/A)
BLN (N/A) 24590-~/28/81)
TVA EMPLOYEE CONCERNS
'SPECIAL PROGRAM REPORT 'NUMBER:
22000 REVISION NUMBER:
0 Page C-1 of 18 ATTACHMENT C REFERENCES 1.
SQN 47A050 series.notes, Orawings 47A050-1
, Hanger Orawing General Notes" 47A050-1/R2'hrough 7
47A050-1A/RO 47A050-2/RO through 6
47A050-2A/RO and 1
47A050-2B/RO 47A050-3/R2 through 6
47A050-4/R5 47A050>>5/R 47A050-6/RB 47A050-6A/Rl 47A050-6B/RO 47A050-7/RO, 1,
3 through 6
47A050-8/RO 47A050-9/R6 47A050-10/RO'7A050-11/Rl 47A050-12/Rl 47A050-13/Rl through 23A, "Mechanical 47A050-14/Rl 47A050.-15/Rl 47A050-16/Rl 47A050-16A/Rl 47A050-17/RO 47A050-18/RO 47A050-19/RO 47A050-,19A/RO 47A050-198/RO 47A050-20/RO 47A050-21 /RO 47A050-22/RO 47A050-23/RO 47A050-23A/RO 2.
WBN 47A050 series
- notes, Orawings 47A050-1 thorough lVl, "Mechanical Hanger Orawing General Notes" 47A050-1/R8 47A050-1A/R6 47A050-1A1/R5 47A050-,18/R9 47A050-181/R2 47A050-182/R3 47A050-183/R3 47A050-1B4/R2 47A050-lc/R9 47A050-lcl/R3 47A050-10/R14 47A050-1E/R15 47A050-1F/R10 47A050-1G/R9'7A050-1H/R7 47A050-1H1/Rl 47A050-1J/R12 47A050-1M4/R3 47A050-1M5/R3 47A050-1M6/R2 47A050-1M7/Rl 47A050-1M8/Rl 47A050-1N/R9 47A050-1N1/Rl 47A050-1N2/R3 47A050-1P/R5 47A050-1Q/R7 47A050-1Q1/R3 47A050-1Q2/R4 47A050-1Q3/R2 47A050-1Q4/R3 47A050-1Q5/R2 47A050.-1Q6/R 1 47A050'-1Q7/R3 37740-R4 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGIRAM REPORT NUMBER: '2000
'EVISIOhl NUMBER:
0 Page C-2 of 18 47A050-1J'1/R2 47A050-1J3/R2 47A050-1K/R10 47A050-1K1/R2 47A050-1K2/Rl 47A050-1L/R10 47A050-1L1/Rl 47A050-1M/R9 47A050-1M'1/Rl 47A050-1M3/R3 47A050-1 i)8/R3 47A050-1 l)9/R3 47A050i-1 Cil0/R5
- 47A050-1R/R5 47A050-1S/R4 47A056-1SlfR1 47A050-1S2/Rl
'47A050-1U/R6 47A050-lU3/R2 47A050-1V/RB 47A050-1Vl/Rl 3.
BLN "3GA0059" series notes:
Orawings 3GA0059-00-1 tlhrough -41, "(BLN]
Notes for Field Fabrication and Installation of Pipe Supports in
~
Category I Structures" 3GA0059-O'0-01/F!15 3GA0059-00-1A/RO 3GA0059-00-18/RO 3GA0059-00-1C/RO 3GA0059-00-02/Rll 3GA0059-0i0.-03/R6 3GA0059<<00-04/R12 3GA0059-00-04A/RO 3GA0059-00-048/RO 3GA0059-00-05/F!14 3GA0059-00-06/R12 3GA0059-00-06Aj'Rl 3GA0059-00-6B/RO 3GA0059-00-CI7/R9 3GA0059-00-CIB/R9 3GA0059-00<<'CI9/R7 3GA0059-00-10/R9 3GA0059-00-10A/RO 3GA0059-00-11/R6 3GA0059-00-12/R5 3GA0059-00-13/R7 3GA0059-00-13A/RO 3GA0059-00-14/R12 3GA0059-00-14A/Rl 3GA0059-00-15/R9 3GA0059-00-16/RB 3GA0059-00-17/R5 3GA0059-00-18/R7 3GA00!)9-00-19/R9 3GA0059-00-20fRB 3GA0059-00-21/R4 3GA0059-00-22/R2 3GA0059-00-23/R2 3GA0059-00-24/R2 3GA005)9-00-24A/R'3 3GAOO!)9-00-25/R3 3GA0059-00-25A/RO 3GA005)9-00-26/R3 3GA0059-00-26A/RO 3GA0059-00-27/R2
'3GA0059-00-28/R4 3GAQ059-00-28A/RO i3GA0059-00-29/Rl 3GA0059-00-30/R3
'3GA0059-00-30A/RO 3GA0059-00-30B/RO
'3GA0059-00<<'31/Rl 3GA0059-00-32/Rl 3GA0059-00"33/Rl
'3GA0059-00-34/R2 3GA0059-00 35/RO 3GA0059-00-'36fRO
~3GA0059-00-37/Rl 3GA0059-00-'38/R2'GA0059-00-39/Rl 3GA0059-00-40/RO 3GAOO!5)9-00-41/R 1 0
4.
Nuclear Regulatory C'omsission - Regulations 10 CFFt 50, Appendix B',
37740-R4
( 10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C-3 of 18 5.
6.
7.
8.
9.
ANSI N45.2.1.1-1974, "Quality Assurance Requirements for the Design of Nuclear Power Plants" General Construction Specification G-43, for support and installation of piping systems in Category 1 structures, Rev.
8, (08/08/85)
SQN Modification and Additions Instruction, M&AI-ll.for fabrication, installation, and documentation of seismic supports and supports attached to seismic Category 1 structures, Rev.
12, (03/14/86)
NSRS Reports for Concerns in WBN Element 220.1:
NSRS,Report I-85-1,24-WBN, ERT Item IN-85-052-001.,
"47A050 Drawing Notes,"
(07/03/85)
NSRS Report I-85-148-WBN, ERT Item PH-85-006-001, "Fuel Load-47A050 Notes," (08/09/85)
NSRS Report I-85-157-WBN, Employee Concern IN-85-010-002, "Hanger Quality Control 47A050 Notes (EvaIuations)
Did Not Satisfy Inspection Criteria,"
(11/22/85)
NSRS Report I-85-234-WBN, ERT'tem IN-85-532-006 - "47A050 Notes,"
(08/16/85)
NSRS Report I-85-160-WBN, ERT Item IN-85-413-001, "47A050 Notes -
Fuel'oad,"
(08/09/85)
NSRS Report I-85-374-WBN, Employee Concern IN-85-445-013, "Drawing Notes in the 47-A050 Series are Hard to Use," (10/10/85)
NSRS Report I-85-110-WBN, "Employee Concern IN-85-024-001," (07/01/85)
SQN Pipe suppo)t drawings:
1-MSH-165/R4 1-MSM-300/R905 1-AFDH-369/R906 1-FDH-45/Rl'-VHIH-144/R902 2-SGBH-70/Rl 2-CCH-372/R2 1-CSH-44/R904 2-CSH-14/R906 1-FPCH-527/R2 1-RCH-136/R4 1-S IH-365/R2.
1-CH-78/R2 2-CVCH-614/R904 2-CVCH-813/RO 37740-R4 (10/08/87)
'TVA EMPLOYEE CONCERNS SPECIAL PROGRAM 10.
WBN Pipe Support Orawings:.
~I REPORT NUMBER:
22000'EVISION NUMBER!
'0 Page C-4 of 18 47A463-2-38/R 1 47A400-6-85/RO 47A060-63-39/RO 47A435-10-21/R3 47A400-6-101/Rl 47A400-6'1'9/Rl 47A060-70-27/R3 47A427-8 38/Rl 47A437>>2 22/Rl 47A400-1-32/Rl 11.
IOM 1891 (09/23/87)
WBN Site Interviews Conducted by Bechtel.
12.
Calculations for the selected WBN 47A050 notest Note. Number Calculation Rev.
Ca.lculation RIMS Number 50 128 132 165 165 227 0
0 1
3 0
B41 860616 900
,'B41 860909 900 84~1 851230 904 B41 860707 902 841 861002 900 841 860311 916 13.
NSRS Report 1-86-131-SQN, "SeiSmic Supports
'ArE. NOt Oesigned Properly Because They Are Rigid.," (10/28/85) 14.
SQN Pipe Support Oesign Criter.ia:
Oetailed Oesign Criteria SQN-OC-V-24.1$ "Loc'ation'n'd Oesign of Piping Supports and Supplemental Steel in Category il Structures,"
Rev.
0, (6/23/86)
CEB-SQN-100(CEB-80-75),,
"Guidelines fo& Ohsign
'of'omponent Supports for TVA Class A through 0," Rev.
3, (01/19/81),
Rev. 0, (03/10/75)
Oetailed Oesign Criteria SQN-OC-V-2.~14, "Pip'inc) Sist'em Anchors Installed in Category I Structures,"
Rev. 0, ('06/30/86')
15.
WBN Pipe Suppoi t Oesign Criter'ia:
WB-OC-40-31.9, "Oetailed Oesign Crit'eria for'ocation and Oesig'n of
'iping Supports and Supplemental Steel in Category I Structures,"
[ESB 840411 20!3], Rev. 0,.(08/29/75);
Rev,. 5, (04/09/84)
WB-OC-40-31.15 "Detai'led Oesign Criteria for Piping System Arrchors Installed in Category I Structa>res,"
[ECB 841226 502j, Rev. 0, (01/27/77);
Rev.
3, (12/14/84) 0 37740-R4 (10/08/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:,
0'age C-5 of 18 16.
17.
WB-OC-40-31.7, "Detailed Design Criteria for Analysis of Category I and I(L) Piping Systems,"
[B42 870129 501], Rev.
0, (Ol/30/76); R7, (01/21/86)
WB-OC-40-31.3, "Detailed Design Criteria for the Assignment of Responsibility for Analyses,
- Support, and Fabrication of Piping Systems,"
[ESB 841012 201], Rev. 0, (09/25/75); Rev.
2, (10/04/84)
BFN Pipe Support Design Criteria:
BFN-50-0706, "General Design Criteria for the Torus Integrity Long-Term Program,"
[ESB 840621 205], Rev. 0, (07/24/80),
Rev.
1, (06/20/84)
BFN-50-0707, "Detailed Design Criteria for Analysis of As-Built Piping
'Systems,"
[B42 850501 501], Rev.
0, (08/11/80);
Rev.
3, (04/17/75)
BFN-50-0711, "Detailed Design Criteria for Analysis of Torus Attached Piping (Long-Term Torus Integrity Program),"
[B42 850719 502], Rev.
0, (07/27/82);
Rev. 2, (07/12/85)
BFN-50-724, "Detailed Design Criteria for Class 1 Seismic Pipe Support Design,"
[B05 861002 500], (09/26/86)
Design Criteria BFN-50-754, "Miscellaneous Steel components for Class I
and II Structures,"
[B05 861110 503], (ll/10/86)
BLN Pipe Support Design Criteria:
N4-50-0711
[BLN] "General Design Criteria for Detailed Analysis and Seismic gualification of Category I and I(L) Piping Systems,"
[B42 851112 524], Rev. 0, (08/08/75);
Rev.
3, (10/17/85)
N4-50-0717
[BLN] "General Design Criteria for Design of Safety-Related Piping Supports and Supplemental'teel,"
[842 851112 525], Rev.
0 (06/10/76);
Rev. 4, (10/22/85)
N4-50-0725
[BLN] "General Design Criteria for Assignment of Responsibility for Analys'is, Support, and Fabrication of Piping Systems,"
[ESB 831115 217], Rev. 0, (01/27/76);
Rev.
1,. (11/19/83)
N4-50-0730 [BLN] "Detailed Design Criteria for Piping System Anchors Installed in Category I Structures,"
[B42 850501 504], Rev. 0, (04/13/78);
Rev.
1, (04/19/85) 37740-R4 (10/08/87)
TVA EMPLOYEE'ONCERINS SPECIAL PROGiRAM REPORT NUMBER:
22000 REVISION 'NUMBER a 0
Page C-6 of 18 18.
SQN Pipe Support'rawings and Calculations:
%PUNT;..
7aTc,.
Sheet No
.Nark No.
'iev.
Reev YZ~F) 2-.H1-348 1-H10-511 1-H20-451 1-H3-367 1-H3-'69 1-H34-100' 2-H36-302 1-H45-130 2-H47-290 2-H50-6 2-H63-449 1-H47-262 1-H36-106
'2-H21-5 2 M% 3T!~
2-MSH-348
'I-CCH-470
'I -S IH-437'I
-AFOH-,3(?8 1-AFOH-329
'I-CVCH-100 2-RiCH-30(?
1-UHIHI-130
',?-SIGBH-290.
(?-F.IP CHI-6
(?-RHR-449,
'I-SGBH,-262 1-RICH-106
(?-CSH-5 903 0
902 0
909 0
7 0
906 0
906 0
901 0
905 0
908 0
904 0
0 904 1
903' 909 4
908' 19.'BN Pipe Support: Orawings and Calculations:
Support 47A437-2-22 47A427-8-38 67-1 ERCW-R2'12
- 47A400-6-97 47A400-6-,361
'47A400-6-.96-63-1SIS-'V132 47A465-2-,38 47A400-1-,32 47A400-6'-:333 1-03A-586 1-03A-.587 1-62A-328 1-63-033 1-63-320 1-68-131 1-,70-005
- Rev, 1
1 902 1
0 0
1 1
1 0
901 1
1 903
'2 904 1
Calc.
Rev.
1 1
'2
1 0
1 0
0 0
00.
1 1
2 0
Calc.
RIMS No.
B41 860807 854 B41 850827 802 WBP 840329 013 WBP.840510 016 B41 850509 967 WBP 831027 085 CEB 850228 956 CEB 850126 833 841 850417 953 B41 850509 955 WBP 841109 006 WBP 841109 005 WBP 841114 115
.WBP 841105. 062 WBP 841108 -005 WBP 841109 025 WBP 841029
- 403, 0
37740-R4 (10/08/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C-7 of 18
~Su orb Rev.
Calc. Rev.
Calc.
RIMS No.
1-87-068 47A400-11-30 1-03A-471 47A400-1-1 1-74-11 47A060-3-23 47A060-70-27 1-63-404 2-70-804 47A435-10-21 1-70-867 906 2
906 1
907 2
3 904 901 3
0 3
0 2
1 1
1 2
0 0
3 0
WBP 840725 019 WBP 840202 075 CEB 850205 920 CEB 850119 809 WBP 840124 027 841 850927 807 MBP 840417 010 WBP 840110 044 B41 860213 954 WBP 841123 001 WBP 841123 002 20.
BFN Pipe Support Orawings and Calculations:
Suppor t Number Orawing Number Rev..
Calculation No.
Number.
Rev.
RIMS uo.
Number RHR H4 RHR R93 RHR H343 RHR H328 RHR R159 RHR R58 478452-67 2
TOPC20106 R93 3
BWP 840425 102 478452-159 1
TOPC20105 H343 2
BWP 840425 103 478452-102 0
TOPC20536 H328 1
BWP 831110 110 478452-134 47B452-405 1
TOPC20466 R159 0
1 BWP 831215 109 478452-133 2
TOPC20465 R58 2
BWP 831220 116 47B451-182 0
BWPC20841 H4 0.
BMP 830825 118 Core Spray H23 478458-91 Core Spray H56 478458-50 0
BWPC30100 H23 1
BWP 840404 112 1
TOPC20305 H56 2
BWP 840710 11'7
-Core Spray R43 478458-150 0
BWPC30109 R43' BWP 830919 113 Core Spray H69 478458-433 5
BWPC30400 H69 5
822 860718 108 RCIC H62 RCIC R46 RCIC R51 47A456-304 2
TOPC20558 H62 1
BWP 831108 107 47B456-106 0
BWPC30363 R46 0
BWP 840404 106 478456-80 5
TOPC20600 R51 3
822 860117 124 I
k I
3774O-R4 (10/08/87)
TVA EMPLOYEE CONICERNS SPECIAL PROGRAÃ
'RI=.PORT NUMBER:
22II30CI Rl.:VISICIN NUMBER: '0
'age C<<8 of 18 Support Nubber HPCI H16913 HPIC. R91 HPIC H186 Orywell and Torus Purge R32
'Orywel 1 and Torus'urge RS RWCU'2 Unit 1
RWCU R2 Unit 3
'HPCI 'R86 Or.'asiing Number.
Rev.
No.
47A455i-3;?08 1
Ca 1 cu 1 at ion Rev.
R IMS Number No.
Number TOPC20256 H1698';
BFP 850129 108 478455i-58 478455i-51 1
TDPC20507 R91 1,
BWP 840706 101 1
TOPC20243 H186
'l.
BFP 850129
'106 478'920-39 2
TOP C20342 R5 478920-79'.
47A406-2 2
BWPC30283"R2 2
417A406-.1'4 1
BWAC304()7 R2 l
-1 BWP 831215
'I07
.BFP"'84!l065 )04 822'85IOSO2
)14'78455-52!
,5'OIPC20445 R86 3
822 8567Cil 302 47A'920-52 0
'WPC20787 R32 '0 BWP 830620
'I12
~Suu ort Nulmbl.r Orawinlg RevI!sion Nurixbev
'21. 'BLN Pipe Support Orawings arid Calcul a'ti on:
Calculation Revision
'Nu4ber Calculation
'R IMS Number 4l 1CA-MPHG-0225 2CA-MPHG-CI050 2CF-MPHG-CI239 2CR-MPHG-CI107 SHT 1
2CR-MPHG-CI107 SIHT 2 1GN-MPHG-CI054 1KC-MPHG-'0036 SIHT 1
2KC-MPHG-0322 SIHT 2
'2KC-MPHG-0>381I 2KC-MPHG-0391I 1KC-MPHG-0884 2NO-MPHG-0549 901' 4
0 0
0
- 902, 1
6 6
0 1'
0 0
0 0
1
0 0
l 0 821 850730,228
.844 860204 452 844,.860228 464 844 860302 453'44 85121,2 478
'821 '85060,5, 402 BLP 850128 266 844 860306.476 844 860306 474 844.860324 462
,821..87040!3 200 844 86(I619 480 37740<<R4 (10/08/87)
>>e>>.'>>l
~ hie>>>> Av e.
~rr t'>>
r ~ ~ ',-
I er ~
. r ur. r~
~ r r>>
~
~
>>..r uue,'le'. ~ '
J 4r~
ee
'>>>>% '>>reer' 1>>J4lNeseNeeellrreubacwvMJsvaQ
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C-9 of 18 Su ort Number 1ND-MPHG-0580 SHT 2 1ND-MPHG-0580 SHT 3 ONM-MPHG-0517 2NS-MPHG-0004 1RK-MPHG-0026 SHT 2 OSA-MPHG-0073 1SM-MPHG-0281 1SM-MPHG-0285 OWD-MPHG-0040 1WD-MPHG-0420 SHT 1
Drawing Revision Number 901 901 904 4
3 902 6
901 901 1
Calculation Revision Number Calculation R IMS Number BLP 840914 209 MEB 820816 922 BLP 840829 221 844 860507 476 MEB 830308 471 B21 850426 229 844 850918 474 821 860716 242 MEB 830523 496 B44 851214 473 22.
SgN Pipe Support Drawings, Revision 0:
2-SGBH-70 (2-H47-70) 2-CCH-374 (2-H10-374) 1-FPCH-527 (1-H50-527) 1-SGBH-72 (2-H47-72) 1-CVCH-813 (2H34-813) 23.
WBN Pipe Support Drawings:
Su oort Revision 0
47A060-63-39 47A400-1-21 47A400-6-69 47A400-6-72 47A400-6-85 47A400-6-94 47A400-6-281 47A400-6-308 47A400-6-376 47A400-7-17 47A400-13-1 47A400-13-9 47A400-'3-21 3774D-R4 (10/08/87)
TVA EMPLOYEE. CONCERNS
,'SPECIAL PROGRAM
~I R'EPORT NUMBER:
2200CI REVISION NUMBElt.:
0 Page C-10 of 18 24.
Bechtel Study Calculations (Job No. 16985-026) to support evaluations.'QN Calculation P0-220-33 Rev.
0 (09/23/87)
Supports 2-NSH-315 2-NSH-348'-AFOH-328 1-CVCH-100 2-RCH-302 1-UHIH-130 2-SGBH-290 2-RHR 449 2-CSH-5 WBN Calculation PO-220-18 Rev.
0 (08/20/87)
Support 47A060-3-23 PO-22CI-19 Rev.
0 (08/20/87)
SuppcIrt 1-74-11 PO-220-20 Rev.
0 (08/20/87)
Supp(Irt 47A060-70-27
'O-22CI-21 Rev., 0 (08/20/87)'upport 1-63-404 PD-22CI-22 Rev.
0 (08/20/87 Support 47A400-'11-30 BFN Calculatia!n f'0-220-23 Rev.
0 (O'B/24/87) Support RHR R159 Unit 3'LN Calculation PO-220-24 PO-220-25 f'0-220-26 f'0-220-27 f'0-220-28 f>0-220-'29 PD-220-30 PO-220-31 R!ev.
Rev.
R!ev.
R!ev.
R!ev.
Rev.
Rev.
R!ev.
0 (08/24/87) 0 (O'B/24/87-)
0 (08/24/87) 0 (08/24/87) 0 (08/24/87) 0 (08/24/87) 0 (08/24/87) 0 (08/24/87)
Support Support Support Support Support Support Support Support OSA-NPHG-0073 2ND-NPHG-0549 2RK-NPHG-0026, Sheet 2
2NS-NPHG-0004 2KC-NPHG-0391 2KC-'NPHG-0381 1KC-NPHG-0036, Sheet 1
2CF-NPHG-0054 25.
Bechtel Study Callculation (Job No. 16985~026)
'to 'Support Evaluations.
Includes BLN site interview information on welding (>f two sides of tube steel.
Calcul at ion PO-220-32 Rev.,0 (08/24/87)
Support 1GN-MPHG-0054 26.
WBN Pipe Support Design Manual, Vol.
1 to 4, (05/18/82);
Rev.
5, (02/24/86) 27.
Engineer;ing Procedure EN OES-EP 4.03 for field change requests in>ti~ated
'y construction
[.ECB 841203 502], Rev.
11, (11/21/84),
Rev. 0, (09/28/73)
Engineering Proc'!dure EN OES-EP 4.35 f!or Revising Vendor Drawings~,
[ESS 811207 206],, Rev.
1, ('12/14/81); fley. 0, (09/Oc"./80) 28.
Office. of Engineering/Watts.
Bar Eng'ineering Project (OE/WBEP)
Hanger Tracking Program Report for'nits 1 and 2, (run date 03/06/86) 37740-R4 (10/08/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C ll of 18 29.
30..
31.
32.
33.
TVA Office of Engineering (OE) Procedures Manual: OEP-ll, "Change Control," (04/26/85)
TVA Office of Construction WBN Quality Control Instruction: QCI-1.13, "Preparation and Oocumentation of Field Change Requests,"
(06/17/80),
Rev.
14 (10/25/85)
TVA Office of Construction WBN Quality Control Procedure:
QCP-4.23-8, "Support Final Inspection,"
Rev.
0 (07/10/82); Rev.
7 (01/30/85)
TVA Office of Engineering (OE)
WBN Project Procedure:
WBEP-EP 43.03, "Field Change Requests,"
Rev. 0, (09/27/83)
TVA Oivision of Engineering Oesign (EN OES) Engineering, Procedure':
EN OES-EP 4.03, "Field Change Requests Initiated by CONST,," Rev.
0 (09/28/73);
Rev.
11 (ll/12/84)
TVA IOM from R.
W. Cantrell to W. H. Thompson, "Employee Concern Program" IN-85-316-002,l'01/24/86)
TVA, Piping Analysis and Hanger Oesign Meeting,
[C24 851106 600],
( 11/06/85)
TVA, Quality Control Procedure QCP-4.23-3, Support Location and Orientation, Rev.
5, (08/30/85)
WBN Calculation N3-78-5A TVA drawing 85 M 47W454-203, R4 TVA drawing 85 M 47W454-203, R5 TVA drawing 85 M 478454-360, R2 TVA drawing 85 M 478454;360, R3 TVA ECN 3213, 01/17/83 TVA NCR WBNSWP8252 Rl TVA NCR WBNSWP4164 R
WBN Calculation N3-61-1R TVA drawing 85 M 47W462-100, R5 TVA drawing 85 M 47W462-100, R6 TVA drawing 85 M 478462-102, Rl TVA drawing 85 M 478462-102, R2 TVA ECN 3608, 03/25/83 TVA NCR WBNCEB8221, R2, 01/27/87 3774D-R4 (10/08/87)
~
~
4
~
TVA EMPLOYEE CONCERNS SPECIAL PROBRAN REPORT NUMBER:
22000 REVISION NUMBER;,
0 Page C-'l2 of 18 WBN Cal cul at'.ion N3-62-!lA WBN Calculat,ion N3-67-6R TVA drawing 85 M 47WI450-241, Rl TVA drawing 85 N 47W450-241, R2 TVA drawing 85 M 478450-573, RO TVA drawing 85 N 478450-573, Rl TVA ECN 2756, 10/14/81 TVA ECN 3049, 01/22/82 TVA ECN 3217, 01/22/82 WBN Calculat,ion N3-72-Ã TVA drawi:ng. 85 M 47W437-200, R6 TVA drawing 85 M 478437-376, RO TVA drawing 85 N 478437-376, Rl TVA ECN 3482, 08/11/82 WBN Calculation 200-04-01 TVA drawiing 85 M 47W464-248, RO TVA drawiing 85 M 478464-655, Rl TVA drawing 85 M 478464-621, RO TVA drawing 85 M 47B464-621, Rl EDS drawing 0600200-04-01,,
R2 TVA ECN 3792, 08/16/83 WBN Calculation 200-07-04 TVA drawing TVA drawing TVA drawing TVA drawing TVA drawing TVA drawing TVA drawing TVA ECN 3371 TVA ECN 3481 TVA ECN 3621 85 M 47W40CI-2'll, R2 85 M 47840CI-384, RO 85 M 478400-384, Rl 85 M 478400-385, RO 85 M 47840CI-385, Rl 85 M 47B400-391, RO 85 M 47B400-391, Rl
, 08/20/82
, 11/22/82
, 01/26/83 TVA drawing 85 47W555-203, R',3 TVA drawing 85 47W555-203, R4 TVA drawing 85 M 478555-434, RO TVA drawing 85 M 478555-434, Rl TVA FCR H-7CI62,, 05/26/82 TVA ECN 3088, '!0/22/82 37740-R4 (10/08/87) 0' 4 vk ~ ~ ~
~'t s ea
~
+' '4s'a '>>il'
" 4 4>>
~ st';&kwlkv
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C-13 of 18 WBN Cal cul at ion "200-8-10 TVA drawing 47W406-328, RO TVA drawing 478406-611, RO EDS drawing 0600200-08-10, R5 TVA ECN 3474, 06/07/82 WBN Calculation 200-09-05 TVA drawing 85 M 478435-469, R2 TVA drawing 85 M 478435-469, R3 TVA drawing 85 M 478435-563, Rl TVA drawing 85 M 47W435-217, R9 TVA ECN 3614, 05/14/84 WBN Calculation 200-13-06 TVA drawing 85 M 47W465-203, R3 TVA drawing 85 M 47B465-370, Rl TVA drawing 85 M 47B465-370, R2 TVA ECN 4153, 10/03/83 34.
Design Criteria - SQN-OC-V-1.3.3.1, "General Oesign Criteria for Additions after November 14, 1979 - Reinforced
- Concrete, Structural, and Miscellaneous Steel,"
[ESB 840918 209] Rev.
4 (09/4/84),
Rev.
0, (08/11/80)
Oesign Criteria - SQN-OC-V-24.1, "Location and Oesign of Piping Supports and Supplemental Steel in Category I Structures,"
[805 860703 501] Rev.
0 (06/23/86)
Oesign Criteria CEB 76-5, "Alternate Criteria for Piping Analysis and Support,"
[CEB 830613 026] Rev.
0 (12/15/81);
Rev.
3 (06/13/83)
- Nuclear, Performance Plan (NPP),
Volume II, Revision 1; [L44 860714 800],
(07/14/86) 35.
ASME BEPV Code Section III, Division 1, Subsection NF, 1983 edition, "Components Supports" 36.
Problem Identification Report No.
PIR WBNCEB8536,
[841 851112 026],
(10/31/85) 37740-R4 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM RIEPORT NUMBER:
22506 REVISION NUMBER:
~0
~
Page C-14 of 18 37.
Oesign Criteria WB-.OC-20-1.1, "General Oesign Criteria for Additions after July 23,,
1979 - Reinforced Concrete, Structural, and Miscellaneous
'teel,"
Rev.
6, (07/24/85) 38.
ASME B&PV Code Section III, Oivision 1, 197'1 edition up to and including summer of 1973 addenda, Subsection NF, 1974 edition, entitled "Component Supports,"
[no RIMS number]
39.
Telecon between TVA and Bechtel, (08/21/87),
(IOM 784)
Telecon between TVA and Bechtel, (03/31/87),
(IOM 886)
Telecon between TVA and Bechtel, (04/06/87)i (IOM 887) 40.
Oesign Criteria BFN-50-0703, "Evaluating Structural Steel Components Subjected to the Environmental Effects of the March 22, 1975 Fire,'"
(05/08/7!5, Rev.
0)
[ESS 810617 206], Rev.
1,, (08/27/75)
Oesign Criteria BFN-50-0705, "Evaluating MeChanical 'Piping, HVAC Oucting,
- Conduit, and P'iping Components Subjected to the Environmental Lffects of the March 22, 1975 Fire," (05/08/75)
Rev., 0,,
[ESS 8110617 208], Rev.
3, (12/17/75) 41.
Oesign Specification BLNP-05-1915-2992'-00, "BLP Units 1
and 2 ASME Section III and 831. 1 Seismic Support,"
[53 820732] (04/11/78)
Engineering Procedure BLEP-06, Component Supports - Analysis, Oesign, Procurement, Fabric, ation,,
and Insta'llation,~'ESB 831019 205], Rev.
3, (11/01/83) 42.
BLN List of Orawings Identified for'IR BLN 'EB851 2 (06/05/87) 43.
Policy Memorandum PM-86-11 (CEB), "All Nuclear Plants-Oesign/Reevaluation of Stee'i Structures for Normal Operating Thermal Loads,"
[B41 860627 003],, (06/27/86) 44.
BLN Support Oiawiings - showing structural'ember end restraints:
OKE-MPIHG-0460, R6 ONM-MPIHG-0531, R3.
OVK-MPIHG-0370 R3 1 CR MPIHG 0257 ~
R 1 1NP-MPIHG-101 7, R3
.1SM-MPIHG-0002, RB 45.
8) 37740-R4 (10/08/87)
~<<wee ~ae,
. a+ ~.
~ <<....~ <<<<. <<..~
~..
r.
% ~ s <<) "
- r. ~
y'<< ~isJaa ~~~saSsaa4t
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C-15 of 18 46'.
47.
EN DES-EP 3.03, -"Design Calculations,"
[ESB 840426 210], Rev.
8, (04/24/84);
Rev.
0, (08/22/74)
Office of Engineering Procedure (OEP) 10,
[no RIMS number],
Rev.
0, (04/26/85)
Support Calculations:
47A450-21-128, R2 47A437-3-1, R3 47A437-2-22, Rl 47A427-8-38, Rl 47A400-6-361, RO'7A400-6-97, Rl 72-1CS-R116)
Rl 1-87-68, R3 47A400-1-1, Rl 47A400-11-30, RO 67-1ERCW-R212, R2 1-01A-309, R2 1-03A-471, R2 63,1S1S>>V132, RO 47A400-6-333, RO 1-03A-586, RO 1-62A-328, RO 1-63-033, Rl 1-68-131, R2 1-63-320, Rl 48.
49.
50.
51.
Documentation Pertaining to WBN Technical Audit:
TVA (WBN) letter to Gilbert, "Design Review for Piping Analysis and Pipe Supports,"
[841 851121 031], (ll/18/85)
Gi-lbert response to TVA (WBN) letter 85-127,
[826 851213. 010], (12/ll/85)
Impell response to TVA (WBN) letter 85-119, "Analysis and Support Design Review Responses,"
(08/26/85)
Impell response to TVA (WBN) letter 85-126, "Analysis and Support Design Review Responses,"
(11/18/85)
Letter from R. 0. Hernandez to T.
C. Cruise, "Impell's Comments on TVA's Review of Their Pipe Support Designs,"
(10/23/85)
Letter from R. 0. Hernandez to R.
G. Pratt, "Design Review of Unit 2 Impell Pipe Supports,"
(01/26/86)
BFN Proposed Instruction for the Calculation Verification Review Program
[no RIMS number], (ll/86); Rev.
1, (03/31/87)
TVA memo from W. C. Orotleff (DNE) to Those Listed, "Pol.icy Memorandum PM86-04 (DNE) - Engineeri'ng Judgment,"
[B20 860424 '001], (04/25/86)
American Society of Mechanical Engineering (ASME) Boiler, and Pressure Vessel Code,Section III - Division 1, "Rules for Constructiorf of Nuclear Power Plant Components - Subsection NF - Component Supports,"
1974 edition through 1976 summer addenda.,
37740-R4 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBERS 0
Page C-'l6 of 18 52.
53.
54, 55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
BLN Final Safety Analysis Report (FSAR) through Amendment 27, Seckio'5 3.9, "Mechanical Systems and ComponeintS," (06/20/86)'ncluding Table 9.9.3-37 TVA memo from W. R. Brown to J. L. McAr>ally, "Traissmittal of ECSP Repor'ts'nd Corrective Action Tracking Documents - (CATDs) Watts Bar Nuclear Plant Subcategory - Construction - Embeds - RO," (Construction Subcategory Report
- 10400, ROi),- [T25 '870210 8'61.I, (02/10/87)
Preliminary Copy of WBN Project Proc'edure'WBEP-SEP 86-02, "Unit 1 Hanger and Analysis Update Program,"
(02/09/87)
TVA Civil Design Standard OS-C1.6.
1 "General Design Information -
'tructural Steel IDesign Scope,'" current revision Ftev.
1 (06/08/81)
[ESS 810608 227]
Problem Identification Report (PIR)
BLN CEB8512',,
[841 851 118 010];
(11/05/85)
TVA memo from J.
C. Standifer (WBN Project Manager) to R.
G.
Domer (Acting Director of Engineering Projects Nuclear),,
"Employee Concern IN-85-052-001,'" [no RIP'IS number],
(12/23/85)'VA memo from W. C. Orotleff tai. Those L'istted'q "Policy Memorandum PM86-04 (ONE) - Engineering Judgment,"
[820 860424 001], (04/25/86)
Nuclear Engineering Procedure NEP-3.
1 (formerly OEP-07), "Calculations-All Nuclear Plants,"
Rev.
0 (07/01/86)
Training records for "Watts 13ar Nuclear Pl'ant - guality Assurance Training (in the practical application of the 47A050 notes),'"
(09/19/85)
TVA memo from L. C.
M. Roddye, (WBN Principal Engi'neer Support Qesigi, Section
- 3) to Watts 'I3ar Engineering l'roject Files, "Watts Bar Nuclear Plant -
SCR WBN,CEB 8569 - Additional Justifiication for Non Generiic Determination,"
[822 861120 016], (ll/2~0/86)
TVA memo f'rom G. Wadewitz (WBN Projeot Man'ager)'o'.'Cottle (WI3N Acting Site Director), "Watts Bar Nuclear Plant-Request for Investigation/Evaluation (for concerA IN-'85-532~006)," RFI WBN-288'g ['no
'IMS number],,
(12/19/85)
FCR I-2394,
[B26 850927 019] (08/05/85')
Pipe Support Drawing Rev.
1 and Ca'Iculat'ionI, Rev.
1, for 47A465-:3-52,
[B41 850711 811], (calculati()n date 58/)0/85) 0 3774D-R4 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22000 REVISION NUMBER:
0 Page C-17 of 18 65.
66.
67.
68.
69.
American Institute of Steel Construction (AISC), Manual of Steel (TRDl Letter from D. M. Verrelli (NRC) to H. G. Parris (TVA) "Reports Nos.
50-259/85-21, 50-260/85-21, and 50-296/85-21,"
[A02 850502 003],
(04/26/85)
EN DES SEP 81-02, "Special Engineering Procedure, Implementation of NRC OIE Bulletin 79-14 for [BFN]," (CEB 811221 014], (12/21/81)
BFEP-PI 85-01, "Implementation of NRC-OIE Bulletins 79-02/79-14,"
[822 870129 301], (01/06/86);
Rev.
1, (01/28/87)
BFEP-PI 86-05, "NRC-OIE Bulletin 79-02/79-14 Program Document for'rowns Ferry Nuclear Plant," [822 860805 011], (07/29/86)
NSRS Report I-84-33-BFN, "Investigation of Browns Ferry Nuclear Plant Piping and Support Design,"
[001 850607 051], (06/07/85)
BFN Significant Condition Reports (SCR):
SCR No.
SCR BFN CEB 8511 SCR BFN CEB 8512 SCR BFN CEB 8607 RO SCR BFN CEB 8609 RO SCR BFN CEB 8610 RO SCR BFN CEB 8612 RO SCR BFN CEB 8619 SCR BFN CEB 8621 RO RIMS B41 850905 027 841 860905 021 841 860218 006 841 860213 006 B41 860218 008 841 860221 015 B41 860408 006 841 860421 007 Date 08/29/85 08/29/85 02/10/86 02/10/86 02/18/86 02/21/86 03/31/86 04/26/86 BFN Problem Identification Reports (PIRs):
PIR No.
PIR BFN CEB 8713 RO PIR BFN CEB 8716 RO RIMS B22 870306 037 822 870317 010 Date 03/06/87 03/16/87 70.
71.
TVA memo from R. 0. Barnett to R.
M. Hodges, "Bellefonte Nuclear Pl.ant-Allowable Stresses for Pipe Support Design -
NCR BLNCEB8110, Rev. 2,"
[CEB 830701 014], (07/01/83)
TVA letter from L. M. Mills (TVA Manager, Nuclear Licensing) to J.
P.
O'Reilly (NRC Regional Administrator), "Bellefonte Nuclear Plants Units 1
and 2 - Allowable Stresses for Pipe Support Design. - BLRD-50-43/81-77, BLRF-50-439/81-76-Final Report," [A27 821216 005], (12/16/82) 3774D-R4 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PRO(RAID REPORT NUMBER:
22000 REVISION NUMBER':
"0 Page C-18 of 18 NRC letter from D. M. Verrellli (NRC Ch'ief, Reactor Projects Branch 1
Division. of Reactor Projects); to H.'. P'arris (TVA Manager of Power and Engineering),
"Report Nos. 50-438/84-26 a'nd '50-439/84-,26,"
[L44 850125 314], (01/23/85) 72.
WBN Typical Small P',ipe Standard GraWings '47A053-62, 47A053-62A through 62E, 47A053-63, and 47A053-63A 0
3774D-R4 (10/08/87)