ML19275A496
| ML19275A496 | |
| Person / Time | |
|---|---|
| Issue date: | 07/23/1979 |
| From: | Glynn J, Peranich M, Reinmuth G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19275A489 | List: |
| References | |
| REF-QA-99900509 NUDOCS 7910040550 | |
| Download: ML19275A496 (27) | |
Text
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P00R ORGINAL U. S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT Report of a Special Inspection Docket No.
99900509/79-03 Company: Stone & Webster Engineering Corp 245 Summer Street Boston, Massachusetts 02107 Inspection Conducted: May 1-4',
1979 Inspectars:
/
7/
- g.,C. Gfyfsf Senior Mechanical Engineer Date v'
Inspection and Enforcement, Headquarters
// h 3:C/C/
- $b f
M. W. Peranich, Senior Electrical Engineer Date Inspection and Enforcement, Headquarters hY WYC Shh Uldis Potapovs, Chief, Vendor Inspection Branch Date Inspection and Enforcement, Region IV Approved by:
s!
k 7/15/ 7'J G. W. Reinmuth, Assistant Director Date Reactor Construction Inspection Inspection and Enforcement, Headquarters Inspection Summary Special Inspection on May 1 thru 4, 1979 (Docket No. 99900509/79-03)
Areas Inspected: Review of procedures and controls adopted by Stone and Webster Engineering Corporation (SWEC) to implement the requirements of 10 CFR Part 21 including the assessment of SWEC compliance with 10 CFR Part 21 for two items identified in IE Bulletins 79-07 (Seismic Stress Analysis of Safety-Related Piping) and 79-02 (Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts). Also reviewed were Quality Assurance measures and their imple-mentation relative to Criterion XVI (Corrective Action) of 10 CFR 50, Appendix B.
Results: The inspection resulted in the identification of one infraction, two deficiencies, and one deviation.
The findings of noncompliance pertain to 10 CFR 21 requirements for:
- 1) evaluation of deviations (infraction), 2) assuring that the Commission is adequately informed (deficiency) and 3) posting of pro-cedures (deficiency). The identified deviation pertains to 10 CFR 50 Appendix B requirements for corrective actior..
In regard to the inspection of seismic and base plate designs, it is apparent that the above items of noncompliance contri-buted to the failure to evaluate these issues under Part 21.
Additional informa-tion concerning these findings is included in the Details Section of the report.
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7910040 7 5 0
2-DETAILS SECTION A.
Persons Contacted SWEC Employees
- V. F. Allen, Jr., Chief Executive Officer
- W. J. L. Kennedy, Vice President, Director of Engineering
- N. E. Cleveland, Vice President, Director of Quality Assurance
- J. A. Erlewine, Vice President, Manager of Projects
- W. H. Leland, Sr. Vice President, Office of President
- R. E. Foley, Ass't to Chief Engineer, EMD W. C. Drotlef f, Ass' t Engineering Manager
- D. T. King, Ass't Engineering Manager
- J.
T. Christian, Consulting Engineer
- J. F. Willet, Supervisor, Pipe Stress, EMD
- D. F. Shave, Supervisor, Pipe Stress, EMD
- R. G. Burns, Chief Engineer QSD
- L. D. Nace, Chief Engineer EAD
- W. M. Eifert, Ass't Chief Engineer, EAD
- R. I. Meissner, Ass't Chief Engineer, EAD
- F. J. Mulligan, Section Head, EAD
- R. B. Kelly, Manager, QA
- F. B. Baldwin, Ass't QA Manager
- S. B. Jacobs, Chief Licensing Engineer
- F. L. Pfischner, Ass't Chief Licensing Engineer G. Harper R. K. Klaus J. Cumisky F. S. Marshall Others W. T. Russel, NRC, Office of Nuclear Reactor Regulation
- Denotes those present at the exit interview.
B.
Introductory Meeting The inspection began on May 1,1979, at 9:00 a.m. with an introductory meeting between the NRC inspectors and Key SWEC personnel.
The inspection objectives were outlined and SWEC policies and procedures for accomplishing their activities in the following areas were discussed:
109830l
. 1.
QA Prcgram 2.
Corrective Action Programs 3.
10 CFR 21 Reporting 4.
Design Control for Computer Codes 5.
Pipe Stress Analysis Computer Code Development at S&W 6.
Pipe Support Base Plate Design at S&W 7.
Chronology of Events Leading to Beaver Valley Shutdown Directive by NRC.
8.
Overview of Control Procedures - For Ongoing Pipe Stress Reevaluation at S&W.
C.
Decuments Fv' mined A summary listing of documents and records reviewed or sampled during the inspection is provided below.
Ref. No.
S&W Document Date/ Description General Orders, W. F. Allen, Jr., President to S&W Corp.
1.
9/14/77 No.328 2.
3/31/78 - No. 338 Interoffice Memorandums (Interim EAP Procedures & Controls) 3.
10/21/77 - S. B. Jacobs to Distribution, Re: Interim Implementation of 10 CFR 21.
4.
10/31/77 - W. J. L. Kennedy to Individuals Listed, Re:
Temporary Guidelines for 10 CFR 21 Evaluations.
5.
4/7/78 - LRN-11-1, Licensing division to: List A, B, &
10; Re: Licensing and Regulation Note 11, Rev.1, 10 CFR 21 - Failure to Comply or Existence of a Defect.
6.
5/12/78 - LRN-11-2, Licensing Division to: Lists A, B, &
10; Division Chief, Nuclear Project Engineers; Nuclear Project Managers, Re: Licensing and Regulation, Note 11, Supplement 2, 10 CFR 21 -
Failure to Comply or Existence of a Defect.
7.
10/31/77 - LRN-064-0, P. A. Staputis to: List A, B, C, and E; Nuclear Project Engineers; Division Chiefs, Re:
Licensing and Regulation Note 64, Rev. O, Basic Component, 10 CFR 21.
1098 30il<
. Ref. No.
S&W Document Date/ Description Interoffice Memorandums (Interim EAP Procedures & Controls) cont'd 8.
11/17/78 - LRN-0064-1, P. A. Staputis, to list A, B, C, and E; Nuclear Project Engineers, Division Chiefs, Re: Licensing Regulations Note 0064, Rev.
1, 10 CFR 21, Applicability to Nonlicensee Suppliers or Commercial Grade Items.
9.
1/9/79 - LRN-0064-2, Licensing Division to: List A, B and C; Nuclear Project Engineers; Di ision Chiefs, Re:
Licensing Regulation Note 0064, Supplement 2, Applicability of 10 CFR 21, to Nuclear Facility Security Systems.
10.
4/30/79 - W. J. L. Kennedy to: Project Engineers, Division Chiefs, Re: Reporting of Significant Problems for Corrective and Preventive Action.
11.
7/5/77 - K. A. McMullin to Distribution, Re: Report of a S&W Problem (CR-50260).
12.
5/23/77 - J. F. Willett to M. H. Pedell, Re: Draft Report of Problems on S&W Unit.
13.
12/7/72 - D. F. Shave to M. H. Pedell and G. L. Woodland, Re:
Natural Frequency & Modal Response Calculations, Nine Mile Point Nuclear Station - Unit 2.
Quality Standards (QS) 14.
9/14/76 - QS-16.1, Rev. O,
Title:
Problem Reports.
15.
8/31/76 - QS-16.2, Rev.0,
Title:
Reporting Deficiencies to the Nuclear Regulatory Commission.
16.
1/6/78 - QS-16.3, Rev.0,
Title:
Reporting Defects and Failures to Comply under 10 CFR 21.
17.
See QS - Procedures of the Quality Standards Manual Manual subject to a limited selective examination included procedures related to:
a.
Project Applicability Matrix b.
Design Control c.
Procurement Document Control d.
Nonconformance Control.
i098 30]$
1 Ref. No.
S&W Document Date/ Description Engineering Assurance Procedures (EAP) 18.
6/27/77 - EAP 16.1, Rev.4 (w/Rev. 4 Change Notice dated 10/30/78),
Title:
Reporting of Significant Problems for Preventive Action (Feedback).
19.
. 5/5/77 - EAP 16.2, Rev.2,
Title:
Reporting Significant Deficiencies to the Client.
20.
3/5/79 - EAP 5.25, Rev.1, Computer Program Docementation and Qualification.
21.
5/12/78 - EAP 15.1, Rev. 3, Handling of Nonconformance and Disposition Reports by Engineering.
22.
See EAP - Procedures of the Quality Assurance Manual Manual subject to a limited selective examination included procedures related to:
a.
Design Control b.
Procurement Document Control, including:
(1) EAP 4.15, para. 2.5.6 (2) Directive for Preparation of Specifications, Appendix S-23, Rev. 0 (invoked via EAP 4.10)
(3) Specification Preparation Manual, Appendix 2.13, Rev. O.
Other Documents & Records 23.
10/17/77 - EMTR-612, Design Procedure for Base Plates, Using drilled in Concrete Anchor Bolts.
24.
10/17/77 - EMD Technical Memo 614, Design Procedure for Base Plates.
25.
3/16/78 - EMTG-0-E, EMD Technical Guidelines.
26.
12/6/76 - EMTG-22-0, Allowable Loads and Design Criteria for Drilled-in-coocrete Anchor Bolts.
27.
5/2/72 List of Calculation Reference for VEPCO North Anna Project, Page Z39.4.
28.
4/24/79 - A. J. Hsi, Computer Program Documentation Review and Approval - SHOCK III.
- 1098304l,
.-. 29.
Qualification Report - K-Factor Code Version 1, Level 0.
30.
Note Book File of Part 21 Records - Located in files controlled by the Licensing Division of S&W.
31.
4/12/79-SWEC Computer Program Qualification, Re:
Shock 3, (ME-023, Version: 03, Level: 03); Prepared By-A. J. Hsi, Checked By - T. Y. Chang and the Computer Program Documentation Review and Approval (Form), Dated 4/24/79.
D.
Coroliance with 10 CFR 21 (M. Peranich) 1.
Inspection Objective To ascertain whether SWEC and appropriate responsible officers had established and implemented procedures and other instructions as required to ensure compliance with 10 CFR 21 requirements relative to the reporting of defects and noncompliance.
Inspector determinations are based on the requirements of 10 CFR 21 as clarified by staff positions in NUREG-0302, Revision 1.
2.
Availability and Status of Adopted Procedures and Other Instructions a.
Summary of Items Subject to Inspection Each organization, such as SWEC, that performs " construction" which involves " basic components" as defined under Part 21 is subject to its regulations. SWEC and its responsible officers must therefore ensure compliance with requirements of Part 21 as specified in Section 21.6, for posting; 21.21(a), for procedures; 21.21(b), for notification and written reports to the Commission; 21.31, for the inclusion of appropriate references in procurement document; and 21.51, for preparation and maintenance of records.
As the means to ensure compliance with 21.21(a) regulations, SWEC must establish procedures to provide for the evaluation of deviations not already corrected in all basic components to which it is applicable when knowledge of the deviation is received (Q/A-22 under NUREG 0302, Revision 1 on page 21.21(a)-9), or informing purchasers of the deviation so the purchaser may evaluate the deviation.
These procedures must also provide for informing a responsible officer within SWEC of any resulting conclusion of a defect or a failure to comply.
To ensure compliance with regulations under: 21.6, 21.21(b),
21.41, and 21.51; SWEC may adopt appropriate controls in the form of procedures or other instructions, as necessary, to ensure that the stated regulatory requirements will be implemented, as appropriate.
098 0jj"
. b.
Avai. ability and Status The inspector was provided a copy of all procedure.' and other instructions (documents) adopted by SWEC for purposes of imple-menting 10 CFR 21 requirements. These documents are listed under Part C of this report, as references 1-10, 14-19, 22 and 30.
In summary, these documents include two general orders issued by W. F. Allen, Jr., President, to the Stone and Webster Engineering Corporation (SWEC). These orders set forth company policy to assure compliance with 10 CFR 21.
This policy was implemented by a series of eight memoranda, applicable to SWEC engineering division personnel, and a Quality Standard procedure (QS-16.3) applicable in part, to all SWEC divisions. The memoranda were issued between the dates of October 21, 1977, and April 30, 1979. The formal procedure QS-16.3 was issued as an effective inscruction on January 6,1978, the date required for procedures to be in effect. Other (non Part 21) procedures, e.g. QS-16.2, are invoked by QS-16.3 and other memoranda, when certain conditions exist.
The inspector found that SWEC had adopted procedures and other instructions which addressed the implementation of 10 CFR 21 regulations, as follows:
(I) ' Sections 21.2, scope, and 21.3, definition requirements, are addressed in QS-16.3 and the Project Applicability Matrix.
(2) Section 21.6 pesting requirements are addressed in the October 21, 1977, memorandum.
(3) Sections 21.21(a) and 21.21(b), notification and procedure requirements, are intended to be implemented by QS-16.3 and by parts of the issued memoranda.
(4) Sectiou 21.31, procurement document requirements, are addressed in certain QA program procedures listed under Part C of this report (i.e. Reference 17c and 22b).
(5) Section 21.51, maintenance of record requirements, are addressed briefly under paragraph 5.6 of QS-16.3.
3.
Adequacy of Procedures and Other Instructions Adopted by SWEC a.
General Comments The majority of the findings of deficiencies in ptacedures and instructions adopted are the result of " alternate nstructions" in QS-16.3 and some of the issued memoranda.
Tb-alternate 09830jhp
. instructions apparently are the result of SWEC interpretations relative to the use of 50.55(e) evaluation and reporting methods as the means to satisfy Part 21 evaluation and reporting requirements.
b.
Findings Relative to 10 CFR 21.21 Requirements SWEC has established instructions and procedures which, it not waived by other " alternate instructions," appear to satisfy the intent of Section 21.21 requirements. A brief summary of these instructicas is provided below.
QS-16.3 includes instructions which provide for evaluation of deviations brought to the attention of a supervisor. The super-visor is allowed to do preliminary screening to determine if the item is a deviation as defined under Part 21 and arrive at an initial conclusion on whether the item is subject to evaluation under Part 21.
A supervisor detensination that a deviation is not reportable under Part 21 is subject to concurrence of the "first reviewer." Following the supervisor's review, QS-16.3 requires a review of the " event" by three skilled members of engineering department management. These are, the Project Engineer, Engineering Division Chief (appropriate discipline) and the Chief Licensing Engineer. These individuals who apparently have ample technical resources to assist in the evaluation, are referred to as the first, second, and third reviewer, respectively. A key responsibility of the second reviewer is to prepare, as part of the evaluation, all information required to adequately inform the Commission.
Following a conclusion by all three qualified reviewers that the event is reportable under Part 21, the responsible officer is notified of all information on the defect or failure to comply. The designated officer is then required to provide for a notification to the Commission within two days unless ne is assured that the Commission has already been ade-quately informed (by an alternate method of reporting).
However, primarily due to the other " alternate instructions" discussed in more detail relative to each finding listed below, the total system of procedures and other instructions adopted by SWEC are not considered to be in compliance with 10 CFR 21.
(1) Certain instructions adopted by SWEC in the October 21, 1971, October 31, 1977, and May 12, 1978, memoranda, and in a note on page 2 of QS-16.3, direct that deviations occurring in the time period between CP (or LWA) to be evaluated only under procedure QS (or EAP)-16.2, established to notify a customer of a potential 10 CFR 50.55(e) item.
This would generally result in all of the deviations brought to the 1098;301l'
9_
attention of a supervisor, or first reviewer, to be evaluated under a procedure, QS-16.2, that has not been prepared to appropriately address 10 CFR 21 evaluation and information requirements.
Therefore, the procedures and other instructions adopted by SWEC do not provide for:
(1) evaluation of deviation as required under 10 CFR 21, and (2) in the case where the item reported under 50.55(e) is also a " defect", all the information required to be reported under 10 CFR 21.21(b)(3).
These instructions also incorrectly assume that once a Limited Work Authorization (LWA, apparently either a LWA-1 or LWA-2) is issued, an applicant would be subject to 10 CFR 50.55(e) regulations and, therefore, all items (i.e.
deviations) should be reviewed and handled in accordance with procedure QA/EAP-16.2 and not as a possible reportable item undar 10 CFR 21.
This interpretation of 50.55(e) applicability to LWA holders may also result in inadequate reporting.
(2) The Project Applicability Matrix (Reference 17a) invokes the use of Part 21 procedure QS-16.3 (Reference 16) on only those projects where S&W holds an active contract with the plant-owner / purchaser. Older facilities, for which prior contracts have been completed, but which still fall within the scope of 10 CFR 21 reuirements for evaluation of deviations are not covered.
Therefore, the procedures and other instructions adopted by SWEC do not provide for evaluation of deviations associated with facilities not currently subject to a contract between SWEC and the facility licensee.
(3) Paragraph 1.2 of QS-16.3 states that this standard is applicable only to deviations in structures, systems and components, etc., which could create a substantial safety hazard (i.e.,
apparently the use of the procedure is applicable only in cases of " reportable deviations").
QS-16.3 does not reference any other acceptable instructions for use by SWEC departments in dispositioning of all known deviations as required under 10 CFR 21.
The above direction under QS-16.3 apparently has a limiting effect on the evaluation of all known deviations identified through the implementation of SWECs QA program for each proj ect.
For example, consistent with applicable QA program requirements (such as would normally be included in SWECs QA program to satisfy 10 CFR 50, Appendix B, Criteria i098301b>
. III, XV, and XVI, requirements relative to handling of QA program identified deviations, nonconformances and significant deficiencies, respectively) it is expected that a SWEC
" supervisor" would eventually be inforced of items identified by the QA program which 'are also a deviation, as defined under 10 CFR 21.
However, as there is no clear evidence based on a sampling of QA procedures (Reference 17b and c, and 22a and c) and the SWEC Part 21 records file that such deviations are subject to a Part 21 evaluation.
Therefore, apparently the procedures and other instructions adopted by SWEC currently do not address and provide for the planned evaluation of a deviation identified by the QA program in a delivered or installed item which is also a " basic component," as required under 10 CFR 21.21(a).
(4) Many of the specific and detailed Part 21 evaluation and reporting procedures applicable to the Engineering Division are in the form of a memorandum which includes temporary guidelines.
For example the October 31, 1977, memorandum includes instructions which state:
"On or before 'sanuary C,1978, an EAP covering the Engineering Department responsibilities in connection with 10 CFR 21 will be issued.
Ia the interia, 10 CFR 21 evaluations will be conducted in accordance with the atte-hed ' Temporary Guidelires' for 10 CFR 21 Evaluations."
Current'.y, the referenced EAP has not been issued and the Chie' L R :nsing Engineer essentially took the position that:
(1) all uamoranda (Reference 3-10) issued to the date of the inspection are in effect at this time, and (2) that the memotsafs are equivalent to procedures which should satisfy 10 !13 21.21(a) procedural requirements.
The procedural status of interim Part 21 memoranda issued by engineering is questioned because:
(1) conflicting instructions currently exist between the October 21, 1977, memorandum and QS-16.3 for supervisor handling of deviations; and (2) where QS-16.3 does discuss the basic responsibilities of the Engineering Department for conducting evaluations (as intended for the EAP), it does not include or reference the s5ecific memoranda instructions pertaining to engineering methods and technical guidance to be followed in conducting Part 21 evaluations. Therefore, without the issuance of the planned EAP, the procedural relationship between instructions in QS-16.3 and existing interim memorandum in effect is not clear.
1 0 9 8 3 0 (',
(5) Engineering Department Memorandum No. 79-07, dated April 30, 1979, appears to provide for the eventual evaluation of deviations considered under QS16.2 (rather than QS16.3),
but such evaluations would apparently be limited to items reported by a licensee under 50.55(e). This is to be accomplished by automatically including such items in the internal feed back Problem Report system (QS16.1). The memorandum apparently interprets that the policy established therein need only apply to future Sk'EC initiated reporting under 10 CFR 50.55(e) and therefore, includes no provisions to also evaluate whether followup under Part 21 is appropriate for 50.55(e) reporting initiated by SkIC since January 6, 1978, as required under 10 CFR 21.21(a).
Further, the " problem report" review system outlined under procedure QS16.1 (Reference 14) apparently would not provide for a Part 21 evaluation of a previously reported deviation under procedure QS16.3 unless the conclusion of the problem report review is that followup under Part 21 is required. This approach, as discussed under 3 above, again appears to limit the use of procedure QS16.3 to only
" reportable deviations."
Therefore, since QS16.1 is not properly referenced by QS-16.3 and also contai:.s no guidance for initiating or conducting a Part 21 evaluation, the procedures and other instructions adopted by SkIC since January 6, 1978, do not provide for evaluation of deviations as required under 10 CFR 21.21(a).
Also, because of the above procedural deficiencies, past SkIC initiated reporting under 50.55(e) may not have served to adequately inform the Commission.
(6) The following discussion relates to QS16.3 instructions that permit the designated responsible officer to return a Part 21 evaluation to the third reviewer and request that a re-evaluation be effected.
In the case of SkIC (an AE organization with ample technical resources available to the reviewers assigned to conduct a Part 21, evaluation of a deviation) the provisions of procedure QS16.3 which allow the designated officer to question and return for re-evaluation the information obtained, pursuant to procedures executed in acccedance with 21.21(a)(2) results in a further and apparently unnecessary delay in completing the Part 21 evaluation of a deviation and is considered contrary to the intent of 21.21(b)(1) requirements placed on the respoasible officer.
Therefore, SWEC and designated responsible officers at the exit interview were advired that in those cases where the 1o98 40
...-. procedural option discussed above would be the cause of delay in informing the Commission as required under 21.21(b((2),
such a delay would be considered an infraction, or a possible violation, of requirements for reporting to the Commission in a timely manner, and, if deemed appropriate, may also result in other Commission sanctions as permitted under 21.61.
The above finding is based on the intent of 10 CFR 21 regulations for assuring the Commission is informed in a timely manner, including applicable staff positions (Q/A 6 and 9 under 21.21(b)(1) and Q/A 3 and 4 under 21.21(b)(2) in NUREG-0302, Revision 1.
c.
Findings Relative to Sections 21.21(b)(1) and 21.21(b)(3) Regulations Refer to findings discussed under (e), below.
d.
Findings Relative to Section 21.31 Regulations Paraphrased, this section requires that SWEC ensure that each procurement document for a " facility" or a " basic component,"
issued on or after Jantary 5,1978, specified that the provisions of 10 CFR 21 apply to the purchase of such items.
SWEC has adopted instructions (Reference 17b) which were sampled by the inspector and are considered sufficient to assure com-pliance with the above requirements.
e.
Findings Relative to Section 21.51 Regulations Generally, Section 21.51 requires that each corporation subject to the regulations of this part to prepare and maintain records of evaluations, notifications to the Commission and other record documents, suf ficient to assure compliance with regulations of this part.
(i) For records of evaluations and notifications paragraph 5.6 of QS-16.3 states - that the engineering department shall be responsible for mairtaining records concerning all " potential defects" and failures to comply, whether ultimately reported to the NRC or not.
If it is intended by the above instruction that the term
" potential defects" include all deviations required to be evaluated under Section 21.21(a) regulations (and all records relative to assuring the Commission is adequately informed pursuant to Section(s) 21.21(b)(1) and 21.21(b)(3)], then the above instruction is considered acceptable. However, it appears as discussed under (2) and 4.b, that further clarification in this regard is necessary.
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.- (2) Although not specifically addressed in QS-16.3, SWEC has records of procedures and other instructions (Reference 1-10, 14-19, 22) apparently established for purposes of assuring compliance with regula* tons of 10 CFR 21.
However, as discussed in this part of the report certain of the instru-tions in the procedures and memoranda adopted by SWEC to assure compliance with 10 CFR 21 are identified as deficient in this regard.
Another significant area where certain SWEC procedures and other instructions are deficient as records under Section 21.51 is relative to Part 21 requirements established to assure the Commission is adequately informed of defects.
These requirements of Part 21 are as follows.
Paraphrased, Section 21.21(b)(1) requires that a director or responsible officer notify the Commission when he obtains information reasonably indicating a failure to comply ce a defect, unless such an individual has actual knowledge that the Commission has been adequately informed.
Paraphrased, Section 21.21(b)(3) lists the information the Commission requires in a written report to be adequately informed of a defect or failure to comply.
Contrary to these requirements, due to the deficiencies in procedures and other instructions adopted by SWEC (i.e., use of QS-16.2 in place of QS-16.3 to evaluate deviations) as discussed in b. (above), SWEC has not established measures to insure that:
(1) a responsible officer will receive all information required to determine if the Commission has been adequately informed of a " defect"; and (2) that written reports initiated by SWEC and submitted to the Commission by a licensee under 50.55(e) would, if necessary, contain all the information required to adequately inform the Commission in those cases where the item being reported under 50.55(e) is also a defect and a separate Part 21 report is not issued.
Also in this regard, the procedures and other instructions adopted by the SWEC do not address the cases:
(1) where it is known that the item is both a "significant deficiency" and a " defect" prior to the submittal of a 50.55(e) report; and (2) the conclusion of the Part 21 evaluation occurs after the reporting of the item under 50.55(c) at which time it is known that the item is also a defect as defined under Part 21.
In the second case, upon receipt of such information the responsible officer is required to provide for a notification and a written report to the Commission within the time limits specified under Section 21.21(b)(2), unless he has actual knowledge at that time that the Commission has been adequately informed by the previously submitted 50.55(e) 109831$.-
. report (if agreed to by each affected licensee) which includes all other information required to adequately inform the Commission of a defect.
4.
Observation of 10 CFR 21 Posting and Records a.
Posting The inpector sampled three locations included in SWEC plans for posting, as required under Part 21.
Each location examined, implemented the poster uttached to the October 21, 1977, memorandum.
One SWEC individual (F. S. Marshall) apparently has the responsibility to ensure that the posting established by the October 21, 1977, memorandum is implemented and not removed, once posted.
The poster adopted by SWEC, however, did not include their established procedures for implementing the specific Part 21 requirements or a description of established procedures and indicate where these procedures could be examined.
b.
Records The file of Part 21 records (QS16.3, paragraph 5.6) is retained by the Licensing Department. The Ass't Chief Licensing Engineer clarified that the file (Reference 30) contained six records of notifications made to the NRC by a licensee following information forwarded to the plantowner by S&W, apparently as required under QS16.2 for reporting of deficiencies. The file apparently does not include any Part 21 records relating to evaluations which did not result in a report to the NRC.
In response to the inspectors question, selected Licensing and QA Managers were not aware of any other specific instructions that are intended to supplement paragraph 5.6 of QS16.3, or of any other location or file, for retention of records of evalua-tions, as required under Part 21.
The QA manager believed that existing QA instructions would provide for a Part 21 evaluation of deviations identified during implementation of the QA program.
However, based on the inspectors sampling of QA procedures (Reference 17b and c and 22a and c) and the Part 21 records file, it appears that QA procedures have not been adequately revised to assure that deviations identified by the QA Program implemented by SWEC for each project were subject to handling and evaluation as required under 10 CFR 21.
SWEC QA Managers indicated that they would review this matter to determine whether revisions to the QA program procedures, or QS16.3 and other instructions, are necessary to assure that deviations identified by the QA program are properly considered, as required under Part 21.
1098 31jll
. E.
Seismic Design and Analysis of Safety Related Piping & Supports (J. Glynn) 1.
Inspection Objectives To discuss with Stone and Webster their seismic design and analysis of nuclear power plant piping and supports, in particular the evolvement in the analytical seismic design methods beginning with their use of algebraic methods for intra-modal summation up to the present require-ments of Regulatory Guide 1.92.
This information was needed to provide in part, a basis for judging Stone and Webster's compliance with Part 21 require =ents, i.e., was Stone and Webster aware at any time since their original seismic design of Beaver Valley up to October,1978 when the SIS lines were reanalysed, that algebraic methods could incorrectly predict seismic loads, or was information readily available to Stone and Webster that would have clearly established this fact?
To facilitate this inspection, an agenda was prepared in conjunction with the Stone and Webster coordinator (R. Foley), and arrangements were made to meet with the appropriate SWEC representatives. A brief description of the relevant information obtained from these discussions is presented in the following sections E.2 thru E.7.
2.
Design' Controls Related to Computer Code Development, Verification and Use Code Qualification Manual and Code Verification - John Christian, a.
D. Shave, and R. Foley (SWEC) and J. Glynn (IE)
The basic engineering quality assurance procedure, EAP 5.25 -
Computer ?rogram Documentation and Qualification (1976), was discussed and a copy of Revision 1 (1979) given to the IE inspector.
In this regard, Stone and Webster explained that all active computer codes meet EAP 5.25 which in turn requires a review and approval by a competent individual not directly affiliated with the intended users or developers of the code.
Stone and Webster stated that their present seismic code, NUPIPE, was qualified in accordance with EAP 5.25 (Version 3 level, July 7,1978) at which time 13 test problems were used for its verification. The verification of the SH0CK II code per EAP 5.25 had never been performed since Stone and Webster placed this code, which had been available for use from 1971-1974, in its inactive category by the time EAP 5.25 became effective.
Verification of SHOCK 0 and 1 codes which had been used during the period January 1968 to October 1971 were not available.
Presumably, documented verifications may not have existed since Stone and Webster's policy dur'ng that time was to have the Project Leader judge whether a, articular code needed to be verified.
10983147-
, Stone and Webster did provide for information a copy of a typical verification report for a code developed prior to EAP 5.25.
The sample report, K-Factor Code, Version 1, Level 0, presented computer calculated results as compared to theoretical and experimentally determined values.
In general, it appears that Stone and Wabster's computer code QA prog:am met the applicable requirements whf.ch were in effect at the time the specific activities ur. der review were performed. The currently applicable standard (EAP 5.24) is responsive to the criteria specified in ANSI 45.2.11 as endorsed by Regulatory Guide 1.64.
b.
Consideration of Engineering Advances / Experimental DG - A. Van Sickel and R. Foley (SWEC) and J. Glynn (IE)
The II inspector was interested in determining if tLere were formal Company procedure' in effect to periodically review the efficacy of those active co;.s available to Stone and Webster engineers. He was informed that no such requirements for re-rev.ews presently exist, and accordingly their policy did not address the need to do so.
St,ne and Webster further stated that th ey did not see the need for such periodic reviews, since the ne.ed to modify a code would be obvious as any new or significant information became available. Stone and Webster stated that their ongoing professional interests in the current technical literature, their participation in technical societies such as ANS and ASME and their involvement in the Regulatory process, provide sufficient opportunity to stay abreast of developments, e.g., engineering data, methodologies, etc., that may have to be factored into their existing codes. Stone and Webster also pointed out that their QA program provides for the verification of all computer codes through the use of a sufficient number and variety of test problems, and assures compliance with the applicable regulatory requirements.
Consideration of As-Built Conditions - D. Shave and R. Foley c.
Stone and Webster reported that the ASME Section III requirements relating to a stress walk and the related analyses plus document-ation for systems differing in their as-built configuration is new Company policy.
Prior to ASME Section III, USA Std. B31.7 was the company standard (North Anna) which was an earlier version also relating to as-built consideration and documentation of analyses which were judged necessary. Prior to B31.7, minor documentation of stress walks coupled with discretionary analyses would seem to represent the industry's norm. The development of these standards shows a progressive improvement beginning with the Project Engineer deciding a the need for re-analyses up to the present requirement for t analysis.
1098 31f
, Accordingly, based on the above information, the risk associated with using data that did act accurately repcesent the actual as-built piping system's geometry and/or dimensions is greater for the older designed plants.
d.
Potential for Errors in Purchased Codes - R. Foley, D. Shave (SWEC) and J. Glynn (IE)
In the course of this discussion which related to Stone i.nd Webrter's policy of QA for computer codes, they stated they were not cettain whether Nuclear Services, Inc., the originator of SWEC present seis=ic code, NiJPIPE, had a contractual obligation to inform Stone and Webster of any changes or corrections that were made or would be made in the code. However, to protect their interests in this regard in the future, SWEC now requires that Part 21 be written into each of its contracts.
IE initiated this discussion to determine if St'ne and Webster could have or should have received informatior '. rom computer code developers concerning the validity of alg.craic summation methods.
It was apparent that there was no reporting systam in effect at that time that would have alerted SWEC to the inadequacies of the algebraic methods.
e.
Algebraic Summation As It Relates to Response Spectra Data -
D. Shave, R. Foley, W. Allen (SWEC), J. Glynn (IE)
Discussions relating to the efficacy of an algebraic technique began during one of Stone and Webster's presentations on May 1.
At that time, IE expressed the opinion that an intramodal algebraic summation was incorrect in theory and could lead to erroneous results. Stone and Webster took exception to this and made it very clear that their position was - - at the time used, algebraic summation techniques were the state-of-art in the evolving field of seismic analysis. Furthermore, Stone and Webster stated - -
the use of algebraic summation techniques in some instances results in designs that are more conservative than SRSS. Finally, Stone and Webster stated - - their overall seismic designs in which algebraic techniques were used are capable of withstanding the postulated seismic events for that particular plant.
In other related discussions subsequent to the May 1 meeting, Stone and Webster personnel expressed similar views to tha?e discussed above.
3.
Listing of Seismic Codes for SWEC Designed Plants - D. Shave and R.
Foley (SWEC) and J. Glynn (IE)
Stone and Webster supplied a summary tabulation for codes SHOCK I, II, III, and NUPIPE. The information discusses the inter and intra modal su=mation methods for each and, the extent to which the codes
)Ohb bl
)
. were used in the design of specific Stone and Webster plants. The chronological development from SHOCK I, which does not address intra modal effects, to NUPIPE which has several options for both intra and inter modal effects, underscores the developmental nature of seismic analysis over the years. The summary table is enclosed as Attachment 1.
4.
Bases for Changing Design Methods from SHOCK II TO SHOCK III -
D. Shave and R. Foley (SWEC), and J. Glynn (IE)
Stone and Webster stated that SHOCK III became their principle seismic computer code because it contained certain improvements and advantages over SEOCK II.
For example:, SHOCK III provided a much more efficient data handling capability in addition to improving the overall seismic analysis by computing the stresses within a mode, and then summing sodal contributicus using an SRSS technique. Stone and Webster contended that these changes were primarily made to take advantage of the latest developments in seimic analysis. Once again, there were no indication: here that Stone and Webster made the switch to SHOCK III because they thought that the algebraic techniques in SH0CK II were in error.
5.
Comparisons and Verifications of NUPIPE, SHOCK III AND ADLPIPE (SHOCK II)-
D. Shave, R. Foley (SWEC), and J. Glynn (IE)
Comparative evaluations of SHOCK III/ADLPIPE AND SH0CK III/NUPIPE were performed by Stone and Webster. Attachment 2 is an internal SWEC memorandum summarizing the results of the comparison of SHOCK III (SRSS)/ADLPIPE (Algebraic). The overall comparison of these codes as reported by Stone and Webster is exce' lent; however, the problem selection made it impossible to generate results that could reflect the differences between algebraic and SRSS intra-modal summations.
Theoretically, ADLPIPE uses an algebraic method, whereas SHOCK III uses an SRSS for intra modal combinations. Unfortunately, the test problem was a one-dimensional earthquake in which intra modal cot.pling does not exist, and therefore the output from the codes could oaly be evaluated on the basis of comparing differences in such parameters as piping natural frequencies, etc.
In discussions with Stone and Webster on this matter, they indicated these comparisons were considered adequate at that time to assure the program's efficacy. We were also informed that the selected test problem was the result of Teledyne, Inc. supplying S&W with an input deck to ADLPIPE for the one-dimensional earthquake (Attachment 2).
Accordingly, it appears that back in 1972 an opportunity to perhaps expose the existence of significant differences in seismic results between algebraic and SRSS methods was not taken advantage of.
\\0
- The comparison of SH0CK III and NUPIPE via EAP 5.25 was then discussed in the context of SWEC's detailed report on this matter (Reference 31).
Since both of these codes contain program routines for similar intra
-modal summations, there was no need for IE to evaluate it in any depth.
6.
Beaver Valley Dynamic Water Hammer Analysis - J. Cummisky, D. King, R. Foley (SWEC), and J. Glynn (IE)
Stone and Webster stated that the water-hammer event which occurred at Beaver Valley several years ago was the result of an improperly sized regulating valve having been installed in the feedwater line.
The event resulted in the failures of a few pipe hangers. On the basis of their water hammer analysis using the NUPIPE code, Stone and Webster determined that the dynamic forces should not have produced pipe hanger failures. Consequently, an investigation showed that the installed hangers and the regulating valve were of smaller size than that required by the original design.
This discussion was initiated by the IE inspector to determine if Stone and Webster could have ascertained during the time of the water hammer analysis whether the piping system was possibly under-designed since SH0CK II had been used in the original design of the piping system.
In this regard, Stone and Webster stated that the actual water hammer loads used in NUPIPE analysis exceeded the seismic loads used in the original SHOCK II design.
Therefore, since NUPIPE did not predict any failures using water hammer input loads greater than the original seismic input loads to SHOCK II, it could be concluded that this event and its subsequent analysis could not have alerted Stone and Webster to a piping design potentially in disagreement with KUPIPE predictions.
7.
Discussion of Beaver Valley Analyses for the SIS-72, 73 Lines -
G. Harper, D. King, R. K. Klaus, R. Coley (SWEC); J. Glynn, M.
Peranich (IE)
In the course of making the modifications to the SIS-72 and 73 lines, Stone and Webster was informed that the original weight of one of the valves in these lines was in error. To account for this information S&W reanalyzed these lines using their present seismic computer code NUPIPE (SRSS). The results of this analysis and a subsequent analysis using the SHOCK-II code (algebraic) showed the lines to be overstressed.
Stone and Webster stated that these lines were originally designed using a hand or chart type calculation, and had not been re-evaluated when the final design was completed and the stress walk was made to confirm the design with the as-built geometry. Stone and Webster further stated that the overstressed condition in these lines was due to the pipe support modeling, e.g., trunnion should have been made 1098311Bi
. a cor.tinuum of the pipe, and not the fact that SHOCK II was the design code. When asked about the large difference between the NUPIPE and SHOCK II results even though both predicted an overstressed condition, S&W said that NUPIPE was more sophisticated and perhaps more sensitive to the effects of the support modeling. They pointed out that the differences in the predicted stresses between the two codes were small once the support modeling was corrected.
Stone and Webster also presented some recent analyses in which the stresses in the SIS piping system were calculated using NUPIPE and SHOCK II as a function of node location. Stone and Webster pointed out that for this case had the piping system been designed to the maximu:n stress predicted by SHOCK II, the system would have been conservatively designed.
In discussing this point, the IE inspector commented that it was commonly agreed that an algebraic technique can be more conservative than SRSS, e.g. in the extreme case the algebraic is equivalent to the absolute sum.
The inspector further stated that any design using algebraic summations may not be able to predict the stress at a specific location, e.g. pipe support and design accordingly without the risk of being in error.
These discussions with Stone and Webster clearly indicatad that the company's basic position is that the techniques inherent to SHOCK II will not result in overall piping system designs that cannot withstand the postulated seismic events.
In summary, Stone and Webster contends that the widespread acceptance of the algebraic techique, the fact that the modifications to the design of the SIS support resulted in a reduction in the stress level to below the allowable using either computer code, and the overall conservatism in their seismic design, should have provided a basis for continued plant operation.
8.
Reportability under 10 CFR 21 The information obtained from discussions with SWEC personnel and our review of related documents, as described in Sections E.1 thru E.7, indicate that up until October 1978 there was co apparett basis for assuming that responsible SWEC individuals believed or should have known that their earlier seismic designs contained potential errors as a result of using the algebraic summatwo method which could create a substantial safety hazard.
Consequently, there is no basis for concluding that prior to October 1978, SWEC activities relative to this problem were in noncompliance with 10 CFR 'l regulations. However, sub:equent to the Duquesne Light Company October 26,1978, LER-78-053/01P and December 6,1978, LER-53/01T-0, apparently the deficiencies in MC Part 21 procedures as discussed in Section D of this report resulted in failure to evaluate this as a matter subject to Part 21.
lOhb
. F.
Corrective Action - Pipe Support Base Plate (U. Potapovs) 1.
Inspection Objectives The objectives of this phase of the inspection were to review the QA measures in effect for the implementation of the requirements of Criterion XVI of 10 CFR 50, Appendix B, " Corrective Action" by examining S&W actions relative to a design problem identified at the VEPC0 North Anna site.
2.
Description of the problem Euring an independent design review performed by Teledyne at North Anna units 1 and 2 during April 1977, a generic pipe support base plate problem was identified. The problem resulted from failure to consider base plate flexibility in calculating the attachment bolt loadings.
S&W in their calculations had assumed the base plate to exhibit rigid behavior whereas it was demonstrated during the independent review that in several cases, depending on the plate configuration, flexible behavior could be expected resulting in significantly higher attachment bolt loadings than calculated using the rigid plate assumption.
3.
Basis for Corrective Action Criterion XVI of 10 CFR 50, Appendix B, requires that measures be established to assure that conditions adverse to quality including deficiencies, deviations and defective material are promptly identified and corrected and the corrective actions taken are documented and reported to appropriate levels of management. Within the S&W QA syster, corrective action for generic problems (common to several projects) is initiated and verified through a problem report system described in Quality Assurance Standard (QS) 16.1 - Problem Reports, and Engineering Assurance Procedure (EAP) 16.1 - Reporting Significant Problems For Preventative Action (Feedback). A problem report is issued when significant hardware related problem is found in one area and personnel in other areas need to be inforned.
EAP 16.7 identifies the following criteria for determining the need to issue a problem report:
(1) Is the problem hardware related?
(2)
Is it significant?
(3) Could others in S&W take worthwhile pre-ventative action?
The problem reports containing a summary of the problem and preferred solution are issued for action to personnel in projects, divisions, 1098 3] Lip
operations centers or departments who are responsible for a discipline or activity which could have a similar problem. The " Action" addressees are responsible for review of the Problem Report to determine whether similar problem exists within their areas of responsibility and describe any action taken in " Problem Report Response" form which is returned to Engineering Assurance. Engineering Assurance, in turn takes appropriate follow-up action to assure the completion of each " Problem Report Response." Preventative actions are verified by audit.
4.
Action Taken by S&W In May 1977, following identification of the base plate design problem at the North Anna Site, the Engineering Mechanics Division prepared and transmitted to Engineering Assurance a " Report of a Problem on S&W Unit."
This report described the problem, concluded it to be generic, described a pteferred solution (developing base plate designs that are rigid) and recommended that active projects review existing base plate designs and make any modifications necessary to insure rigid plate behavior.
In July 1977 Engineering Assurance issued Interoffice Memorandum CR-50260 transmitting the previously referenced " Report of a Problem oa an S&W Unit." The memo requested addressees to initiate corrective action where similar conditions exist and noted that "This problem and solution will be further investigated and, if the problem is significant and warrants development of a preferred solution, a Problem Report will be issued requiring written responses from selected recipients."
No response was required to the EA memo.
In October 1977 S&W issued Engineering Mechanics Division (EMD)
Technical Report-EMTR 612. This report discusses four specific methods of base plate analysis which assume rigid plate behavior and establishes flexibility load factors (derived from a finite element analysis) to be used with each of the four methods to compensate for flexible plate behavior when established parameters fcr rigid behavior are exceeded. The load factors are determined from plate dimensions and atta-hment bolt spacing. The report also defines limiting dimensional parameters o insure rigid plate behavior when analysis methods other than the four specifically addressed in the report are used. At the same cime the Chief Engineer, EMD issued Technical Memorandum 614 to all holders of Technical Guideline Manuals stating that "All new base plate designs utilizing drilled-in-concrete anchor bolts shall be in accordance with the procedures presented in EMTR-612."
The memo did not address correction of existing installations which may not meet the referenced criteria, although the Chief Engineer, EMD stated that he interprets the memo to require all base plate installations 109832l
. in active S&W projects to meet the EMTR-612 guidelines.
It was further assumed (by EMD) that since no requests for deviation from ENTR-612 had been received, all active projects would be in compliance with these guidelines.
A problem report, which would have required formalized and auditable corrective / preventative action as described in Section 3 above, was not issued. According to the Chief Engineer, EHL a problem report was not issued because the problem was not considered to be significant.
Cited among the reasor2 for this conclusion were the results of the finite element analyr,es which were used as a oasis for the EMTR 612 criteria as well as conservative limits for allowable anchor bolt loadings (1/5 of manufacturers reported pull-o'st loads).
A specific evaluation by EMD or EA of the significance of this problem was not documented.
5.
Considerations in Evaluating Cor-ective Action Based on the above, it appears that the corrective action taken by S&W:
1.
Did not clearly identify the extent of rework (if any) necessary since written instructions addressed only new designs.
2.
Did not provide for adequate accountability in that neither specific responses from projects nor follow-up by EA were required.
3.
Did not provide for documented evaluation of the problem significance which was reportedly used as basis for not issuing a problem report (in accordance with EAP 16.1.).
It was not the purpose cf this inspection to evaluate the adequacy of the corrective action prescribed in EMTR-612. The above conclusions are therefore related only to S&W actions relative to the applicable QA measures.
The adequacy of corrective actions for active S&W projects as well as those which have been issued an operating license will be evaluated through the responses to IE Bulletin No. 79-02 which was issued on March 8, 1979, and requires responses from the individual licensees or CP holders.
} oho w/
J
. 6.
Reportability Under 10 CFR 21 SWEC did not evaluate the base plate design problem for reportability under 10 CFR 21.
Failure to do so apparently resulted in part from the previously identified deficiencies in 10 CFR 21 procedures adopted by SWEC which consider 50.55(e) reports as alternate (and preferable) means of inforsing the Commission. This approach, while acceptable in same cases does not always assure that reporting requirements specified in paragraph 21.21b(3) are satisfied.
In the case of the base plate design deficiency, two CP holders did submit 50.55(e) reports to the Commission. These reports while adequately describing the problem for the specific facilities involved, did not provide information concerning other facilities (including operating plants) which may have similar design deficiencies.
G.
Exit Inte rview At the conclusion of the inspection a meeting was held with SWEC representatives identified in Section A to discuss the inspector's findings.
SWEC was informed that, based on evaluation of the information acquired during the inspection, the inspectors did not find evidence which would support a conclusion that a responsible officer of SWEC had received and failed to act on information indicating a defect (as d' fined under Part 21) in either the Seismic Stress Analysis of safety related piping or the design of pipe support base plates.
The inspectors noted, however, that the procedures adopted by SWEC to implement 10 CFR 21 requirements did not fully comply with the intent of those regulations (specific details discussed in the attached Notice of Violation).
It was also pointed out that, while the SWEC problem reporting policy as established by the April 30, 1979, memo did appear to correct scoe of the previously existing procedural deficiencies, it was not clear whether this policy would also be applied to the re-evaluation of previous reports which construction permit holders may have submitted to h'RC based on SWEC-supplied informatica af ter the effective date of Part 21 reporting requirements.
The inspectors also advised SWEC that their corrective action f.n the case of the pipe support base plate design did not comply wit'. the requirements of Criterion XVI of 10 CFR 50, Appendix B, as implemented by SWEC Quality Standard 16.1.
SWEC was advised that the findings of this inspection would be documented in a report and that written responses would be requested from SWEC concerning the specific concerns identified above.
9b
.A.T.T..A.C..llllF.ti! l-f "'
~'
I Inter Intra itemarkn P roj'rnn Uncd on:
R= RIID +i(X"R )")-R Fx:Fxx :Fxy:Fxz:0 Sil0CK 1 I
if0 lininc Yankoe 3*I Surry PASHY
(!!nvy method) l
~
f ~ fxx+f f fx2 Used on:
S110CK II O
2 2
X X/
i irn (Alp,chrnically)
Haine Yankco
~
.I.}
Ir0
\\
Surry i
I:
Denis with incrLia forcea licaver Valley 3 (Navy method) within cach mode PASHY "I!odified SitSS" Uncd on:
Sil0CK III
[
. F : (Fxx +Fy*M Fxy
'" " ^""" /2 a
(E." R.
x U
J:1 Denis with:
Internal foreca and :noments within oncli n. ode.
NUPIPE Optiono:
Options:
Used on:
.,lo'rst caoc of North Anna 1/2 1
, 1.
SRSS 2.
Absoluto t
l, fg=( f x + f
)0f( Fg ify)
A u never $ bs t
- 3. - Grouping" (1.92)
N
- 4. '"10 percent" (1 92)
- 2. Fj(F
+Fxz jz+F L~
2 XX Y
M 5.
"doubic oum" (1.92) 3 Fx=(Fxx*+ Fxy*+Fa*.8
)iDDRORE,,he, Examplo of notacablaturet Exy = rosponno in x direction
m1rnorrict f. rt.'OriANDUP[
kii EU.
12177 4.
SUOJECT CO:9ARISOll OF SHOCK III AllD ADLPIPE DATE Doce:bar 7,1972 FROld D. F. Shavo M H F*d*ll TO cc cenerat riles G. L. Woodland I'
lintural Frequency and Modal Response Calculations
'i[
Ni=e Mile Point liuclear Statien - Unit 2 Niagra Mohawk Power Corporation I: erde= to respc=:1 to certain AE Nine }'ile Poi =f. 2 PS)R questions regerd-ing a, -isca cf ec=puter progre=s utili:ed for pipi=g analysis with other i
7 clic do::ina progra s, ve initiated and have completed a study utilizing 530'I -
-'.GISI?E.
~
SEC ~I.
is the cu rent Sto=e end Webster progran for dyn -4 e analysis of piping systa== subjected to e. seis=ic envirc =ent.
EE. _r5 is a g-- - ' piping e=uysis progra= one function of vhich is calcu-lati g dyr'-* c response to a seis:ic envirc::ent.
ne ; oble= selected for ce=parisen was a production proble: for North Anna 1, and ec=sists of a portion of assulus piping for the Pressurizer Spray Syste=.
He JIJ.JIFE ru= vas =ade by Teledyne l'.sterials Research and the original ec=-
7:ter ;-i=tcut trans=itted to Ste e and Webster as part of the Stress Report.
p 27 deplicating the input to the ME.PI?E progran for SHOCI. III, ve were able to ec: pare resul.s of both progra=s.
p.espense: er each nede (frequency) are cc:bined in SHOOK III utilizing pro-
- cedu es unique to Ste=e a=d Webster.
Therefere, we vere not able to ec=pa e ec=bined =cdal responses.
We vere able to check individual =cdal responses hevever, as cut" ed below.
He ec=pe= iso:s =ade vere as follevs:
l.
Cc::cisen of celeulated natu al Frecueneles (Table 1)
Vad, ce=parisen cf calculated natural frequencies indicates that the dp anic stiffness ani = ass = atrix is being for=ulated correctly, a=d that the Eige:veeter-Eigenvdue,sclutica is cer-
~
rect.
2.
Corea-ison of Calculated Model Internal Ferces and Me:--.ts (Table'2)
Tais indicates the correctness of the static solution due to anplice. tic: of =cda.1 inertia forces, indicates that the response sp'ect u: is being utilized correctly, and that the celculation of the code.1 participctica facter is correct.
Modal inertial forces ce not readily available in ADL?!?E and as such vere not reported here.
Several points were back-calculated however 3
and i=ertie ferees found essent!*y identical.
s P00R BRIGINAL lovs nS
3.
Cn-.nn:-innn or Calculatr r! thin 1 111.,ninecrenta (Tablo 3)
I"h This provides further indication that-tho static solutica is correct and confir=a that unita utilized throughout cro cos-patible.
A e.cpy of both runs is inclosed with this cc=o.
Originals vill ba held in the Pipa Strc:s }.hghcering doction.,
Tcc cvera " cc:perison is considered exceptional, since nu=erical routines 'fer frequen y "d
-da chape (Egenvalues and Eigenvecto:es) solutions cre excep-tic-.7 riccr:us, rc: tiring double precision solution 6 SHOCK III.
Further ec:parisens of SI-:0CK III responses, including ec=bined =odel respe=5es are "ar '-y usi=g 1:U?I?E, the results of e.J.ch vM1 be reported shortl..
f m"ww c
D. F. Shave R
e
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O P00R BRIGINAL im nb
-. ~... _. _ _...
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~-.
--.~
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