ML20063C709
| ML20063C709 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/25/1982 |
| From: | Wittig T CYGNA ENERGY SERVICES |
| To: | |
| Shared Package | |
| ML20063C698 | List: |
| References | |
| NUDOCS 8208270335 | |
| Download: ML20063C709 (49) | |
Text
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ERRATA SHEET O
Replace Pages: With Pages:
Cover sheet Cover sheet i through 11 i through 11 4 through 7 a through 7 14 14 16 16 20 20 23 23
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56 through 73 56 through 73 Table 5-1, 5 pages Table 5-1, 5 pages Appendix A, A-8 Appendix A, A-8 and A-9 Appendix B, Doc. DC-2, Appendix B, Doc. DC-2, 11 pages 11 pages
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Appendix D, PFR No. 009, Appendix D, PFR No. 009, Sheet 3 of 3 Sheet 3 of 3 NOTE: Ab indicates changes from draft report.
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A.
V Project No.: 82026 FINAL PEPORT Independent Design Revie:'
of Grand Gulf Nuclear Station - Unit 1 Prepared for Mississippi Power & Light Milner Building, Suite 320 City Center Plaza North 210 S. La Mar Street Jackson, Mississippi 39201 Prepared by O Cygna Energy Services 141 Battery Street, Suite 400 San Francisco, California 94111 Approved by WM, 8/24./62 Project ifhpager ~Date l
Approved b 6 /25/62-
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nior Review Tea Date August 25, 1982 (q
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() TABLE OF CONTENTS Page 1.0 EXECUTIVE
SUMMARY
l 1.1 Introduction 1 1.2 Project Organization 2 1.3 Summary 4 2.0 DEFINITIONS AND NOTATION 26 2.1 Definitions 26 2.2 Notation 27 3.0 REVIEW APPROACH 28 3.1 Collect Documents 28 3.2 Develop Standards 30 3.2.1 OA standard 30 3.2.2 Technical Standards 32 3.3 Procedures 32 3.3.1 Checklists 33 3.3.2 Observation Record 34 3.3.3 Potential Finding Report 34 3.4 QA and Technical Reviews 42 3.5 Project Review 42 Senior Review Team
/]} 3.6 43 4.0 REVIEW SCOPE 44 4.1 OA Review - Bechtel 48 4.1.1 OA Program Review 49 4.1.2 Implementation Evaluation 50 4.2 OA Review - f1P&L 52 4.3 Review of NRC Inspection Reports 53 4.4 Review of Independent Verification 54 of San Onofre Units 2 and 3 Seismic Design Interim Report 4.5 Piping Stress Analysis 54 4.5.1 Computer Analysis Input Data 54 4.5.2 Piping Model 55 4.5.3 Stress Related Calculations 56 4.5.4 Results and Conclusions 56 4.6 Class 1 Stress Report 58 fg 4.7 Flued Head Analysis 58 4.8 Pipe Support Design 59 4.8.1 Input Data and Load Combinations 58 4.8.2 Design Calculations 59 4.8.3 Drawings 60 4.8.4 Pipe Support Walkdown 60
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5.0
SUMMARY
AND CONCLUSIONS 62 5.1 OA Review - Bechtel 63 5.1.1 OA Program Review 63 Ak 5.1.2 Implementation Evaluation 64 5.2 OA Evaluation - MP&L 65 5.3 Review of NRC Inspection Reports 65 5.4 Review of Independent Verification 66 San Onofre Units 2 and 3 Seismic Design Interim Report 5.5 Review of Piping Stress Analysis 66 5.6 Review of Class 1 Stress Report 70 5.7 Review of Flued Head Analysis 71 5.8 Review of Pipe Support Design 72 5.9 Pipe Support Walkdown 72 Attachments:
Appendix A Material Reviewed Appendix B Review Standards T B1 Quality Assurance Program Matrix B2 Pipe Stress Review Criteria B3 Pipe Support Review Criteria Appendix C Checklists C1 Quality Assurance Checklists C2 Pipe Stress Checklists C3 Pipe Support Checklists Appendix D Potential Finding Reports Appendix E Observation Records and Observation Record Reviews Appendix F Statement of Independency Figures Fig. 1-1 Project Organization Fig. 3-1 Review Process Flowchart Fig. 3-2 Observation Record Forms Fig. 3-3 Observation Log Form O Mississippi Power & Light 11 Grand Gulf Unit 1 Independent Design Review Ldl1 J k A 82026 11111llllllllllllllll1llllllll
review process, a Senior Review Team was formed to review the performance and the findings of the project team. This Senior Review Team was made up of Messrs. B. K. Kacyra, J. E. Ward, and E. F. Trainor. Mr. Kacyra, the Chief Executive Officer of Cygna Corporation, is a recognized expert with significant design experience in the field of structural design and dynamic analysis. Mr. Ward, Chief Executive Officer of Cygna Energy Serivces, is a recognized expert and industry spokesman in the regulatory requirments and systems design. Mr. Trainor, Vice President, Quality Assurance, offers extensive experience in the fields of quality assurance and management controls. This team, with assistance from in-house consultants, reviewed all phases of work performed by the project team and was the final authority within Cygna in the judgement of the safety impact of anylA potential finding.
1.3 Summary The Observation Log in Table 1-1 summarizes the final status of all observations identified during the course of this review. It lists a total of eighty-four observations. Of these eighty-four, twenty-one have been invalidated as a result of further review.
The sixty-three valid observations were categorized as follows:
twenty-four (24) in Quality Assurance, thirty-seven (37) in Pipe Stress, and two (2) in Pipe Supports. Of these sixty-three valid observations, nine were identified as potential findings. All of d the potential findings have been closed out as having no impact upon plant or public safety after undergoing further review by both the Project and the Senior Review Teams. Where necessary, this further review extended to other systems where a similar observation could indicate a generic design error. None were A identified. There are no reportable findings.
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/ The potential findings which were resolved as a result of further review included PFR-001 through and including PFR-009. lA Based on this review, Cygna has reached the following conclusions regarding the design and design control activities on GGNS-1:
e The MP&L and Bechtel QA programs adequately address project commitments related to design control. This included design control activities in the areas of design input, design verification (including testing), drawings, specifications, internal and external interfaces, corrective action, audits and surveillances, e The MP&L and Bechtel QA programs effectively controlled the design of piping and pipe supports in the RHR Train "A" during a period of extensive redesign effort.
- The piping and pipe supports in the Residual Heat Removal System, Train "A" have been designed to perform their intended safety function in accordance with the project commitments, the project design control process and the requirements of the New Loads Adequacy Evaluation Program, e The pipe supports along the main flow path of RHR Train "A" have been physically installed in accordance with the design drawings.
Finally, we believe that this review provides significant assurance that the overall design activities on GGNS-1 have been properly performed. This general conclusion is based upon:
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() 1. The OA and technical review of the design control and implementation process.
- 2. The fact that this review centered upon a complex system which underwent a major redesign effort involving major inter- and intra-organizational interfaces.
- 3. The interaction of the Cygna project team engineers with the GGNS-1 project management and design team.
- 4. Our own experience and engineering judgement.
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O O O Rv 2 classincation Observation Log Date 8/21/82 aM Potential Finding Observation Description Remarks N o.
YES NO YES NO QA-00-001 The thchtel Quality Program is silent X X dosed. All Bechtel calcula-with respect to performing design tions are verified.
verification by spot checking calculations and analyses.
QA-00-002 The Bechtel procedures do not address X X dosed. All designs are the QA Program statement that identical veri fied. The " identical" designs need not be verified. option, which permits verifi-cations to be waived, is not invoked.
QA-00-003 The procedures are silent with respect X X Cl osed. The design reviewer to design reviewer independence. (or checker) is independent in accordance with the requirements of 10CFR50 App. B, Criterion III. b Q A-00-004 The procedures are silent regarding X X Cl osed. Bechtel does not use design verification by testing. testing to verify its designs on GGNS-1.
Q A-00-005 The Bechtel QA Program does not specify X X Closed. Design verification that design verification be completed is performed prior to prior to fuel load. design approval.
Q A-00-006 The Bechtel QA program does not address X
- PFR No. 001. Closed.
corrective action for computer programs developed on-project.
i Mississippi Power & Light
- Further review has shown that this 7 l
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O O O Rev 2 Classification Observation Log Date 8/21/82 aN Potential Finding Observation Description Remarks N o.
YES NO YES NO Q A-01-020 One thchtel Pipe Stress Group X X dosed. The calculation had calculation did not make been revised.
reference to design input data.
Q A-01-021 No referene.e was made to the X X dosed. Documentation has location of verification been revised.
information for three (3) non-standard computer programs.
Q A-01-022 Local stress calculations for X
- PFR No. 009. dosed.
civil group-designed restraints and anchors are not checked.
QA-02-001 All aspects of the MP&L 0QA X X dosed. Middle South Services Program are not audited on an audits the MP&L QA Auditing annual basis. Dept. All remaining elements of the 00A Program are audited by MP&L QA Department.
QA-02-002 MP&L has not audited the Bechtel X X dosed. MP&L has audited calculation program on a Criterion III in sufficient frequent basis, depth to assure proper de-sign control implementation.
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- Further review has shown that this 14 L F:a*.!Lf11 Grand Gulf Unit 1 Independent Design Review potential finding has no impact on lllllll1111111llllllllllll11ll 82026 plant safety.
O O O Rev 2 Classification Observation Log Date 8/21/82 Valid l Potential Finding Observation Description Remarks t N o.
YES NO YES NO GENERAL P I-00-007 There is no evidence that an X X dosed. Flange calculations evaluation of flanges has been made. are maintained separately.
P I-00-008 A discrepancy exists in the use of X
- PFR No. 008. Closed.
Bechtel Program ME101 regarding the keyword "FLX".
PROBLEM NO. 96 PI-01-001 The insulation weight used on X X dosed. Line GBB-19 is a line GBB-19 is 5% higher short piece of piping between than the value in the insulation the RHR head exchangers. A specification. 5% change in the insulation weight does not significantly affect the design.
PI-01-002 A response spectra analysis for X X Cosed. Cygna's check SSE loading is not run; instead, verifies that 2.3 x OBE OBE values are multiplied by a factor envelopes SSE.
of 2.3.
PI-01-003 The mass participation in the X X Qosed. Based upon review x, y and z directions is 45%, of a rerun analysis which 61% and 71%, respectively, which is addressed the effect of the less than the target of 90%. ZPA times the valve weight on system loads, there is negligible impact upon design.
Mississippi Power & Light
- Further review has shown that this 16 p'j ,2,l f j Grand Gul f Unit 1 Independent Design Review potential finding has no impact on ll111$1l1I11llllllI1llll Ill 82026 plant sa fety.
O O O Rev 2 Classification Observat. ion Log Date 8/21/82 Valid Potential Finding Observation Description Remarks N o.
YES NO YES NO Problem No.141 PI-04-001 Several uninsulated lines are X X Cl osed. This added insula-nodeled as insulated. tion weight occurs on short lines near anchors, so the design impact is negligible.
PI-04-002 The direction cosines of lateral X X Cl osed. The design impact is restraint S-22 are input incorrectly. negligible due to the size of the line and the proximity of anchors.
PI-04-003 The bend at data point 760 X X Cl osed. Based upon review is incorrectly modeled. of revised analysis.
PI-04-004 The dynamic analysis for chugging and X X Cl osed. Review of spectra P.S.P.T. are cut off at a indicates no significant frequency of 62.7; no further impact on design.
static analyses are performed.
PI-04-005 Motor operated valve F028A-A is X X Cl osed. Review of revised modeled with too heavy of an analysis shows that the de-operator weight ( 671 vs. 475 lbs.). sign impact is negligible.
PI-04-006 There are several errors in unit weights and wall thicknesses.
X X Closed. Some errors were de-tected in the drawings, but
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were subsequently corrected.
The correct values were used in design. The remaining instances do not signifi-cantly impact design.
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O O O R" 2 massincanon Observation Log Date 8/21/82 Valid Potential Finding Observation Description Remarks No.
YES NO YES NO FLUED EAD REPORT PI-05-001 Primary plus secondary stress X X Cl osed. Further review of intensity exceeds 3 Sm. an alternate linearization technique indicates stresses l2 are within allowables.
PI-05-002 Radial thermal stresses at the X X Cl osed. Stiffness matrix inner surface are compressive formulation used Ec while and large (-22400 PSI). They load vector formulation should approach zero at this used Eh . However, this does surface. not significantly affect stress intensity and does not impact conclusions.
PI-05-003 A. Specification is unclear with X X A. Cl osed. Further review
, regard to where failure loads indicates that the are applied and which load location chosen is combinations are investigated. reasonable.
B. Closed. Further review B. Interpretation of the spec- indicates that analysis ification by NEAT, which are conservatisms envelop any results in load combinations effect from other load inconsistent with possible combinations.
system configurations.
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() e Support and Restraint Types, Locations and Stiffness e Fittings, Nozzles and Valves.
- Mass Point Spacing e Cut-off Frequency / No. of Modes 4.5.3 Stress Related Calculations The following calculations, which are necessary for completion of a piping stress analysis, were reviewed in detail:
e Stress Intensification Factors for Weldolets e Seismic Anchor Movements e Valve Natural Frequency Check e Support, Restraint, Anchor, Penetration, and Equipment Nozzle Load Summaries n
( ,) 4.5.4 Results and Conclusions After the above checks had been completed for each problem, the results and conclusions were reviewed in detail to assure reasonableness, consistency, and compliance with project criteria. The following items were given particular attention, e Displacements, Stresses and Reactions fi e Pipe Stress Code Check e Equipment Nozzle Reactions e Valve Acceleration Check e Mass Participation e Functionality Requirement Check l o Load Combinations l
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The following load combinations were reviewed: Ai
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Primary Normal Operating Condition A. Pressure + Weight Upset Condition B. Pressure + Weight + OBE C. Pressure + Weight + OBE + Relief Valve Open/ Closed Systems + SRV yy + Quencher Water Clearing D. Load Case B + Relief Valve Open/ Closed System +
SRV yy + Quencher Air Clearing E. Load Case B + RV Open/ Closed System + SRVall +
Quencher Water Clearing F. Load Case B + RV Open/ Closed System + SRVi +
Quencher Air Clearing Faulted Condition G. Load Case A + SSE H. Load Case G + SRV yy I. Load Case G + SRV g J.
Load Case A + SRVADS +
ugging2 + SSE2)1/2 K. Load Case A + Poolswell + [(Vent Air Clearing
+ PSPT)2 + SSE2]1/2 L. Load Case A + Fallback + [ Steam Cond./
Chugging 2 + SSE2]If2 M. Load Case A + [SSE2 + AP2]I/2 Secondary:
A. Thermal + SAM Primary & Secondary:
A. Pressure + Weight + Thermal + SAM NOTE: Loads were added by absolute sum except as indicated above.
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4.6 Class 1 Stress Report
(')'i The Nuclear Class 1 Piping Stress Report for the RHR System, Bechtel Document No. 9645-SR42, was reviewed in detail to assure compliance with project criteria and Code requirements for Class 1 piping analysis. This review placed particular emphasis on the following areas of concern for a Class 1 analysis:
e Interpretation of pressure / temperature load histogram for use in thermal transient and fatigue analysis e Piping discontinuity evaluation e Calculation and use of stress indices e Material parameters specific to Class 1 analyses e ASME Code Class 1 acceptability check e Analysis of welded attachments 4.7 Flued Head Analysis
/~3 V
The Nuclear Class 1 Stress Report for RHR Drywell Flued Head No.
313 and 314, Bechtel Document No. NEAT-81-9545-3, was reviewed in detail to assure compliance with project criteria and Code requirements for Class 1 analyses. This review placed particular emphasis on the following areas of concern:
e Interpretation of pressure / temperature load histogram for use in thermal transient and fatigue analysis i e Application of loads due to attached piping l
- Application of pipe failure loads e Use of finite element computer program "ANSYS" e ASME Code Class 1 acceptability check l
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4.8 Pipe Support Design
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The main flow path of RHR Train "A", as shown in Fig. 3-2, contains thirty-five pipe supports. The design of each of these supports was reviewed in detail to assure conformance with project design criteria and normal industry practice. This activity consisted of a review of the following items:
e Input data and load combinations considered e Design calculations e Drawings Each of these items is described in detail below.
4.8.1 Input Data and Load Combinations An in-depth inspection was made of the support guidance
(]) generated by the Bechtel Stress Group for use by the Support Group. This check was performed to assure that the following information was properly transmitted between the two groups:
e Support types and locations e Piping deflections for all essential load cases e Support loads generated for all essential load cases Ah 4.8.2 Design Calculations The following calculations and checks which are required for completion of the design of a pipe support were reviewed in detail:
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e support stiffness
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e Weld calculations e Stress allowables e Vendor allowables for catalog hardware e Proper modeling for computerized calculations e Expansion bolt allowables and baseplate flexibility 4.8.3 Drawings Due to the critical need for correct drawings to be forwarded to the site, a close comparison was made of the support drawings which were produced and the analytical results of the overall piping design process. To accomplish this, the following key elements were checked for each pipe support drawing issued:
o Correct type, orientation, and location
(') e Proper specification of clearances e Sufficient structural and weld data e Correct component sizes 4.8.4 Pipe Support Walkdown To assure that the pipe supports and restraints will perform their intended functions in the installed condition, an as-built review was performed. This task was accomplished considering the overall assembly from a functional vantage point rather than inspecting detailed individual parts and components. Checks were made in the following key areas:
- Approximate location and orientation with respect to the piping system.
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O - Tree, size eaa easueemeae oc co=90aeate such as seriase and snubbers.
- Approximate dimensions of critical members of the support assembly.
- Miscellaneous considerations such as clearance between pipe and restraint steel and gaps between baseplates and concrete surfaces.
In addition, during the course of the walkdown the orientation of the operator was checked for all motor operated valves along the main flow phth.
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5.0
SUMMARY
AND CONCLUSIONS Cygna has completed this independent design review. The review concentrated on the design and design control activities related to redesign of the RHR System, Train "A", to meet the require-ments of the New Loads Adequacy Evaluation Program. Although this review concentrated on the New Loads era, which spanned from January 1978 to date, the piping between the RHR heat exchangers was unaffected by New Loads. That portion of the system design is controlled by seismic loads and was performed between 1975 and 1977. The technical review therefore considered designs developed as early as 1975.
Cygna has concluded that these design and design control activi-ties were performed in accordance with the project commitments and standard practice. There were minor nonconformances, but none of these were determined to af fect the safety of the plant rm
(,) or the public. The results of this review are tabulated below:
OBSERVATIONS
- POTENTIAL FINDINGS Number Valid 63 9 Number Invalid 21 0 Number Open 1 1 Number Closed 83 8 Number Reportable 0 0 Ah TOTAL 84 9
- Includes the Potential Findings e m, v
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" Observations" are any nonconformances to the review criteria.
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" Potential Findings" are those observations identified as having a potential impact on plant safety. After further review, a potential finding may be determined either to have no impact on plant safety or to be reportable under the guidelines the Code of Federal Regulations (10CFR21). The above tabulation shows that of the eighty-four (84) observations, nine (9) were identified as Ak potential findings, none of which are reportable per 10CFR21.
The following subsections address the resolution of each observa-tion identified as a potential finding.
5.1 OA Review - Dechtel 5.1.1 OA Program Review The review to determine the adequacy of the Bechtel OA Pro-gram in addressing the key design control elements as speci-() fled in ANSI-N45.2, and NUREG 75/087, resulted in six obser-vations (OA-00-001 through OA-00-006 - see Appendix E). Of the six, five were satisf actorily resolved through further review and one PFR (PFR-001) was initiated.
PFR-001' The Bechtel OA GGNS-1 Program is silent with respect .to establishing requirements governing the prepara-tion, control, verification and documentation of non-standard computer programs.
The PPR has been closed, as the project provided evidence of satisfactory control over non-standard (project generated) computer programs. This has been accomplished by the project implementing the requirements of Bechtel Corporation Standard Procedure EDP 4.3.7. It is therefore concluded O Mississippi Power & Light 63
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that the Bechtel OA Program as it applies to its GGNS-1 project during the NLAE program adequately addresses those key design control elements to which it has committed.
5.1.2 Implementation Evaluation The review to assess the effectiveness of the implementation of the established Bechtel OA program resulted in the iden-tification of twenty-two (22) observations (OA-01-001 through 0A-01-022 - See Appendix E). All but one (PPR-009) of these were resolved at the observation level. This PFR b is discussed below:
PFR-009 Local stress calculations for restraints and anchors designed by the Civil Group are not checked.
This potential finding applies to 112 restraints and anchors
] in the GGNS-1 safety-related systems. As a result of this finding, Bechtel checked these local stress calculations.
Upon completion of this checking activity, Cygna performed a review of 25% of these calculations. To assure compliance with applicable procedures a technical review of these cal-culations was performed to assure that proper engineering procedures were employed. Included among those calculations reviewed were the problems which had the highest primary stresses, the highest secondary stresses and the highest load to pipe size ratios. These reviews revealed that all calculations were properly checked and that there were no instances in which the stress allowables were exceeded.
Based upon the above, it has been determined that there is no impact upon plant safety.
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O oertas the i=9t emeateetoa eve eetioa or the 8ecate1 o^ ero-gram, certain activities of an administrative nature were noted, which do not impact plant safety, but should never-theless be addressed. These are:
A) Project calculations should be reviewed to assure that references to information or source data are specific to document revisions.
B) A consistent system for tracking of action items gener-ated as a result of trip reports and conference notes should be established.
C) Calculation cover sheets should be revised to accommo-date a listing of all calculation originators and checkers involved in the calculations as identified in calculation sheets.
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5.2 QA Evaluation - MP&L The evaluation of MP&L was concluded to be satisfactory. During the evaluation, two observations were identified (QA-02-001, QA-02-002 - See Appendix E). Both have been resolved.
l 5.3 Review of NRC Inspection Reports t The review of NRC Inspection Reports disclosed that several non-l compliances were identified in the Bechtel design control program l
prior to and during the period of 1978. Of those identified, each was a separate, distinct problem indicating no discernable l trend in the area of design control. Further, during the later
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l part of 1978 through early 1979, all the earlier identified O
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O noacometiences naa beea re otvea to the seeiseectioa or the nac indicating a positive trend of corrective action by Bechtel in improving the design control program. The period of 1978 up to early 1982 disclosed only isolated non-compliances, none of which could be considered a degrading quality trend.
The Cygna review disclosed several observations, two of which were identified as a potential safety impact issue (OA-00-001, CA-01-001) which was subsequently resolved. Considered cumula-tively, the results of this review and previous NRC inspections did not identify any degrative quality trends.
5.4 Review of Independent Verification of San Onofre Units 2 and 3 Seismic Design Interim Report The review of the Torrey Pines Technology Independent Design Review Report on San Onof re Units 2 and 3 disclosed that no po-O tentiet finaines were identified reserdine the nechte1 Desien Control Program. It is therefore concluded that, after the Cygna review, no generic quality problem could be assigned to or inferred with the Bechtel Corporation Quality Program governing design control.
5.5 Review of Piping Stress Analyses The review of the technical design associated with the four piping analyses f rom RHR Train "A" resulted in forty-four obser-vations (PI-00-001 through PI-04-016). As a result of further review, eleven of these observations were invalidated, twenty-six were resolved and closed at the observation level, and seven war-ranted classification as potential findings (PFR). All of the PFRs were subsequently closed as a result of further review and O Mississippi Power & Light 66 Grand Gulf Unit 1 Independent Design Review LN I.D L T A 82026 111111ll1111tll1111ll1ll111111
q corrective actions by Bechtel as needed. In all cases it was b determined that there was no impact upon plant safety. These PFRs are contained in Appendix D and a discussion of each and its associated resolution follows:
PFR-002 Piping restraints were input to the piping analysis using an assumed stiffness value. After the pipe restraints were designed, the piping analysis was not revised to incorporate the actual restraint stiffnesses.
During the course of the pipe support review, the actual restraint stiffnesses for supports along the main flow path for RIIR Train "A" were tabulated and compared to the assumed stiff-ness value. This, in conjunction with a previous Cygna study of the sensitivity of piping system response to changes in support stiffness, led to the determination that the maximum increase in loads and stresses which can be expected is within acceptable limits and the available design margin. Therefore, there is no impact upon plant safety.
PFR-003 The piping analysis used a cutoff frequency of 60 hertz, Since some hydrodynamic loads do not reach their zero period accelerations until nearly 100 hertz, this assumption may be unconservative.
Further review of the piping analyses f rom RIIR Train "A", which are subjected to SRV loading and in which the analysis was cut-off at 60 IIZ or less, indicates that there would not be any sig-nificant increase in loads and stresses due to the inclusion of the higher frequency modes. This is based upon calculations of the percentages of mass participation and strain energy. The latter was based upon the method shown in GE Document NEDE 25250, O
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" Generic. Criteria for High Frequency Cutoff of BWR Equipment",
(Vl As a result, it has been determined that there is January 1980.
no impact upon plant safety.
PFR-004 The method which was used by the Bechtel Stress Group in the calculation of the Stress Intensification Factor (SIF) for a concentric reducer sometimes underestimates the SIF by as much as 100%. This method was employed on all piping systems analyzed for GGNS-1.
Cygna subsequently performed a review of 27% of the high tempera-ture (greater than 350' F) safety related piping problems on GGNS-1. This, coupled with a random samplir.g performed by Bechtel of 10% of the "new loads" piping problems (both hot and cold), indicates that in many instances the increased stress at the reducers became the maximum system stress. However, in no case did this increase cause allowable stresses to be exceeded.
Q Based upon the above it has been determined that there is no impact upon plant safety.
PPR-005 In Problem No. 69C, the piping between the containment penetration and the RHR heat exchanger, a time history analysis was performed to analyze the hydrodynamic ef fects of relief valve blowdown. In developing the load summaries at restraints and anchors, the reactions were taken directly from the computer output which does not fully account for the high frequency response occuring along the line of action of a restraint or anchor. This resulted in an increase in load at one restraint (S28) of 81%.
Subsequently, Cygna performed a review of other systems which require a time history analysis (main steam, main steam bypass, riississippi Power & Light 68 Grand Gulf Unit 1 Independent Design Review L8. . .FJL i 82026 111111111111ll1ll1llllll111lll
and main steam relief valve discharge). This review confirmed that this situation was isolated to the RHR Relief Valve Discharge Piping. In addition, restraint S28 was found to, be able to withstand the increase in load. Therefore, plant safety is not impacted.
PFR-006 The Stress Intensification Factor (SIF) for a weldolet was not considered for the run pipe wherever the ratio of run pipe section modulus to branch pipe section modulus exceeded
- 10. This criteria was applied to all piping systems analyzed for GGNS-1.
Subsequently, Cygna performed a review of 27% of the high temper-ature (greater than 350' F) safety related problems on GGNS-l.
This, coupled with an evaluation of the piping problems for RHR Train "A", indicates that there are no instances in which the increase at a branch connection causes allowables to be exceeded.
O Therefore plant safety is not impacted.
G PPR-007 Inspection, of the output for Problem No. 141 (piping between the drywell and containment), which was rerun due to Observations PI-04-005 and PI-04-008, shows that valve FO37A-A A exceeded the allowable acceleration by 25%. This was the only valve in RHR Train "A" where this problem was noted.
Subsequently, Problem No. 141 was rerun with a revised, less conservative envelope of the SRVA Response Spectra. Review of this rerun analysis showed that the acceleration of valve FO37A-A was below the allowable for both upset and faulted conditions.
Therefore plant safety is not impacted.
Light 69 g Mississippi Power &g g Gulf unit 1 Indepenaent oesign Rev lllllll1ll111lllllll11111111!!
(n V PFR-008 As a result of Observation PI-04-00.3 it was determined-that a discrepancy exists in the documentation' for Bechtel Computer Program "ME101". When using the keyword "FLX" for specifying the flexibility factor for an elbow or bend, the documentation does not indicate that the bend radius must also be specified.
As a result of the additional reviews performed by Cygna during the resolution of PFR-004 and PFR-006 and additional investi-gation performed by Bechtel, it has been determined that the use of this keyword was isolatied to only one piping problem and that there is no impact upon plant safety. Bechtel has issued an internal memorandum to ME101 users providing directions for using the "FLX" key word.
5.6 Review of Class 1 Stress Report (q/ The review of Bechtel's Class 1 Stress Report for the LPCI System, No. 9645-SR-12, Rev. O, resulted in no deficiencies of a nature which warranted a written observation. However, there-were several items where it is felt that a correction or clarifi-cation might aid any future reviewer.
- 1) It is probably not useful to incorporate the entire TRHEAT theoretical manual in the stress report. In terms of balance it would be more useful to describe in general the operation, format, and verification of all computer programs used in the analysis. This would include TRHEAT, ME913,'and any others.
- 2) A more detailed discussion of special functional capability requirements would be helpful.
o O
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3 (vK\ 3) All nomenclature used for complete description of NB3650 i code equations was listed on Page /,viii of the report, yet, code equations were not noted. <
- 4) No mention of type of seismic analysis-' done, computer programs used or USNRC Regulatory guides incor'porated was in I
the report. Similarly, there was no mantion of how building earthquake anchor movements were considered,l</
h ;
- 6) A separate isometric drawn ; specifically for the Class 1 report would have. been much simpler and more understandable than the multipurpose drawing attached to the report. Also, the data point designation on the isometric did not match that of the stress report. There were no clear ASME Class O
G 1/2 boundaries noted. ,
A' 5.7 Review of Flued Head Analysis / >
i The' review of Bechtel's Nuclear Class 1 Stress Report for RHR Drywell Flued Head Nos. 313 and 314, No. NEAT-81,-9645-3, Rev. 1 resulted in seven observations (PI-05-001 through PI-05-007). As
- a rqsult of further review, three of these ojservations were 1 4 .( ,
invalidated and the remaining four were resolveo'. None of these ..
Obse,rvations resulted in a PFR. However, as noted in the Obser-vation< Record Reviews, for at least four of these observations the review could have beer accomplished much more efficiently if the documentation provid'd 's the report had been more detailed. ,
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(]) In addition, a brief review of Bechtel's Nuclear Class 1 Stress Report for Main Steam Flued Head Nos. 5, 6, 7, and 8, No. NEAT-81-9645-17, Rev. 1, was performed to assure that the areas questioned in the RHR Flued Head Review were adequately addressed in the Main Steam Flued Head. This revealed no deficiencies and, as in the case of the RHR Flued Head, resulted in the conclusion that the re is no impact on plant safety.
5.8 Review of Pipe Support Design The review of the technical design associated with the thirty-five pipe supports located along the main flow path of RHR Train "A" resulted in three observations (PS-00-001, PS-08-001, and PS-34-001). As a result of further review, PS-00-001 was invalidated and the remaining two observations were closed due to their insignificant design impact. There were no deficiencies of a nature which warranted a PFR or affected plant safety.
~() In addition, this review noted further conservatism in the pipe support designs due to a 27% margin in fillet weld allowables when compared to the 1980 code.
5.9 Pipe Support Walkdown The as-built verification of the thirty-five pipe supports located along the main flow path of RHR Train "A" is summarized g in Table 5-1. Of the thirty-five, three were inabcessible. The remaining thirty-two were found to be within allowable tolerances and were determined to be acceptable. The model numbers and load ratings of nine Bergen-Patterson spring hangers were partially obscured by stick-on labels showing hot and cold settings. A O Mississippi Power & Light 72 Grand Gulf Unit 1 Independent Design Review LNI9k 11 82026 111ll1lllllllllllll11111111lll
review of controlled documentation provided by MP&L provided acceptable verification for these hangers. In addition, no discrepancies were noted in the orientation of motor operated valves.
O 1
O Mississippi Power & Light 73 Grand Gulf Unit 1 Independent Design Review L*k (.d i 11 82026 11I1I1I1I1I1111I11I11111111111
O O O TABLE 5-1 INDEPENDENT DESIGN REVIEW PIPE SUPPORT WALKDOWN
SUMMARY
Base Plate Manufacture and Hanger / Support Location rimension Angle Weld Hardware Anchor Bolt Remarks QIE12G015 R21 A A A A C -
As-Built Acceptable QIE12G015 H04 A A -
A C -
QIE12G015 R37 A A - A A -
QIE12G015 R01 - - - - - -
Inaccessible QIE12G015 R02 - - - - - -
Inaccessible I
QIE12G015 H01 - - - - - -
Inaccessible QIE12G015 009 A A A A - -
As-Built Acceptable QIE12G015 R03 A A A A - -
As-Built Acceptable QIE12G015 R25 A - - A - -
Mississippi Power & L'ght Page 1 of 5 Grand Gulf Unit 1 Inderandent Design Review
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O O O TABLE 5-1 INDEPENDENT DESIGN REVIEW PIPE SUPPORT WALKDOWN
SUMMARY
Base Plate Manufacture and Hanger / Support Location Dimension Angle Weld Hardware Anchor iblt Remarks QIE12G015 R26 A - - A - -
As-Built Acceptable QIE12G009 R01 A A A - -
A ;
A "
QIE12G009 H01 A - -
C A QIE12G009 R03 A A -
B A -
QIE12G009 H02 A - - B C -
i QIE12G009 R04 A B -
A A -
A "
QIE12G012 H16 A - -
C -
- QIE12G012 R01 A A A A -
A QIE12G012 H15A A A -
A C A 1
l Mississippi Power & Light Page 2 of 5 ra f y 3y, Grand Gulf Unit 1 Independent Design Review
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~11 82026 uZiiit!ii.iiiii:2ililllll i
O O O TABLE 5-1 INDEPENDENT DESIGN REVIEW PIPE SUPPORT WALKDOWN
SUMMARY
Base Plate Manufacture and Hanger / Support Location Dimension Angle Weld Hardware Anchor Bolt Remarks QIE12G012 H01 A A -
A -
A As-Built Acceptable A "
QIE12G012 R02 A A A A -
QIE12G012 R03 A A A - -
B QIE12G012 H02 A A A A C -
QIE12G012 R04 A A -
A A -
A "
QIE12G012 R05 - - -
A A QIE12G012 H03 A A A -
C A QIE12G012 R06 - - -
A -
A QIE12G013 H01 D A -
A - -
lA 1
Mississippi Power & Light Page 3 of 5 l 7 ,=, Grand Gulf Unit 1 Independent Design Review
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- O O O TABLE 5-1 INDEPENDENT DESIGN REVIEW l
PIPE SUPPORT WALKDOWN
SUMMARY
Base Plate i Manufacture and l Hanger / Support Location Dimension Angle Weld Hardware Anchor Bolt Remarks i .
l QIE12G013 H02 A A - A C -
As-Ebilt Acceptable i
QIE12G013 H03 A - . A C -
QIE12G013 R02 D A A A A -
" A i
QIE12G013 R03 A - -
A -
A QIE12G013 R04 A A - A A -
i QIE12G013 R05 A A A A A A QIE12G013 R06 A A - A A -
- QIE12G013 R07 A A -
A A -
I t Mississippi Power & Light Page 4 of 5
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O O O TABLE S-1 ,.
1 INDEPENDENT DESIGN REVIEW PIPE SUPPORT WALKDOWN
SUMMARY
NOTES:
i
( A) As-built agrees with the design or has a minor discrepancy.
( B) Inaccessible. No safety impact due to large design margin. A
( C) Spring hanger. Unable to determine model and rating.
l (D) Inaccessible for exact measurement. A t
- l i
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1 l
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58.0 MP&L Operational Quality Assurance Manual,
()
Title:
Corrective Action, Rev. 2.
59.0 MP&L Operational Quality Assurance Manual,
Title:
Audits, Rev. 2.
60.0 MP&L Internal Procedures Manual, Section 8, Rev. 13.
61.0 Piping and Instrumentation Diagrams - RHR System M-1085 A ,
Rev. 19 and M1085B, Rev. 17.
62.0 Area Piping Composite Drawings (M Drawings).
63.0 GE Drawing No. 794E858, Rev. 1, Class 1 Piping Cycles -
LPCI.
64.0 Bechtel Drawing No. SK-M-2034, Rev. 7, Flued Head Details.
() 65.0 Penetration Schedule and Detail Drawings (C Drawings).
66.0 Vendor Valve Drawings.
67.0 I.E. Bulleton 79-14 Walkdown Checklist for: db QIE12G013H03 QIE12G013H02 QIE12G012H16 QIE12G012H15 QIE12G012H03 OIE12G012H02 QIE12G009H02 QIE12G009H01 QIE12G015H04 f'}
Mississippi Power & Light Grand Gulf Unit 1 Independent Design Review A-8
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68.0 Bechtel Calculations Nos.:
OlB21G022R03 ole 12G018A01 ole 12G013R05 Ah Q1821G023H04 OlG41G016A01 ole 12G013R06 OlB21G024C01 OlP45G812AOl OlB21GO23R05 OlB21G024R14 ole 12G025A03 OlB21G025H01 OlP41G008A02 OlB21G032A01 OlP41G008A03 ole 12G021A01 OlP41G009A03 OlP44G003A01 OlP66G003A01 OlP53G003A02 OlB21G024Rll ole 51G004A02 OlB21G023R20 OlG41G009A01 OlB21G022R13 ole 12G014A01 OlB21G023R04 ole 12G014A02 O
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Mississippi Power & Light Grand Gulf Unit 1 Independent Design Review A-9 Ldb1'ii i 82026 11llllllllll111llllll1111lllll
es Job No. 82026 s Doc. No. DC-2 Rev.1 INDEPENDENT DESIGN REVIEW PIPE SUPPORT DESIGN REVIEW CRITERIA FOR GRAND GULF NUCLEAR STATION UNIT 1 MISSISSIPPI POWER & LIGHT Prepared by /@C d# ML C. Liu D' ate O
Independent Review by '
L. Chiu 'Datt
.L
_ f f[h '('[I2 Approved by _
,y-Hamati Da tie Division Manager CYGNA ENERGY SERVICES 141 Battery Street, Suite 400 San Francisco, CA 94111 August, 1982 O
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g 1.0 SCOPE G) 1.1 This criterion is intended to establish general guidelines for an independent design review of supporting components, hangers, restraints and shock suppressors in the RHR , train "A" piping system.
1.2 Pipe supports shall be capable of supporting a piping system during all conditions of operation by transmitting the loads from the pipe to structural members in the building.
2.0 CODES, STANDARDS AND REFERENCE DOCUMENTS The following codes shall be used for the design review of pipe supports:
2.1 ASME Boiler and Pressure Vessel Code Section III, Sub-s section NF, 1977 edition.
A 2.2 ANSI B31.1, Power Piping Code, 1977.
2.3 American Institute of Steel Construction, Inc., AISC Steel Construction Manual, 8th edition.
2.4 Bergen-Paterson Pipe Supports Catalog No. 66R 3.0 PHYSICAL REQUIREMENTS l
l 3.1 Natural Frequency i
- a. The natural frequency of a seismic restraint with its tributary pipe mass must be greater than 33 Hertz in the l
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() Mississippi Power & Light Grand Gulf Unit 1 2 of 11 l
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pipe's restrained direction. The mass used to calculate the O
s_/ natural frequency shall include the weight of the restraint, restrained pipe, pipe insulation, fluid, pipe attachments, and valves. Any rational analysis may be used to calculate the natural frequency. The natural frequency calculations of pipe restraints do not have to include the flexibility of the building structure.
- b. The natural frequency of a support in its unrestrained direction shall be considered for the purposes of computing loads and stresses. Only the weight of the hanger applied uniformly along its length needs to be considered.
- c. For the purpose of determining the natural frequency of snubbers and their frames, consider the snubber to exhibit stiffness qualities which would make them a rigid link between the pipe and the supporting structure. The supporting structure, from the building 's frame to the
(/ snubber, shall be designed such that the natural frequency is at least 33 Hertz.
3.2 Gaps A gap shall be provided to accommodate radial expansion and construction tolerances. The maximum total gap allowed in the restrained direction is 1/8". In non-restrained directions, the support design shall allow clearance for the most severe thermal i plus seismic movements of the pipe. Proper installation tolerances shall be provided where thermal movement cannot be accommodated within the specified gap minus 1/16".
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() Mississippi Power & Light Grand Gulf Unit 1 3 of 11 LYM [ 13 Design Criteria lll1lllIIl111lllllllllllllll11 D C - 8 2 0 2 6 - 2 ; Rev. 1
3.3 Deviations O
3.3.1 The design location of the supports in a straight run of the pipe may deviate by from the theoretical location i 2 inches for Nuclear Class 1 and i 6 for Nuclear Class 2 Ok and 3.
3.3.2 The distance between centerline of piping and structural attachment may deviate by 10%.
3.4 Spring Supports Spring supports shall be capable of exerting a supporting force equal to the load, as determined by weight-balance calculations, plus the weight of all hanger parts, such as clamps, and rods, that will be supported by a spring at the point of attachment to a pressure-retaining component or to an integral attachment. The design shall be such as to prevent complete release of the
() component load in the event of spring failure or misalignment.
Any variability of a supporting spring force resulting from movement of the component shall be considered in the loadings used in the stress analysis of the component. The spring's available travel will be checked against the thermal and seismic movements.
3.5 Hanger Rods Hanger rods shall be subjected to tensile loading only unless specific gapping instructions are indicated on the drawings. Rod hanger assemblies shall be designed to allow anticipated thermal horizontal movement without subjecting the pipe to extraneous loads. The maximum swing angle due to horizontal pipe movement
() Mississippi Power & Light Grand Gulf Unit 1 4 of 11 L i (tjifd Design Criteria ll11ll1111111ll111111lllllllll DC-8 20 26-2 ; Rev. 1
should be less than 4*. If the swing angle of the rod is in 7s k/ excess of 4* and/or the total movement is in excess of two inches, the hanger shall be of fset two-thirds of the thermal movement towards the direction of movement.
3.6 Snubbers The snubber assembly shall be offset two-thirds of the thermal movement in the cold position if the swing angle exceeds 5*
and/or the total movement of the point of attachment on the pipe is in excess of two inches. The midpoint of thermal travel for snubber strokes shall be set at the midpoint of the total travel with hot and cold settings established accordingly.
3.7 Structural details shall conform to the requirement of the AISC Manual of Steel Construction.
3.8 All seismic supports shall be two way restraints.
(~)'
Regardless of other imposed loads, the pipe must be physically restrained in each direction along the restraining axis.
4.0 RESTRAINT 4.1 The loadings that shall be taken into account in designing a component support are, but not limited to, the following:
- a. Weight of the component, insulation, and normal contents (DL). Pipe and component weights from manufacturer's data.
- b. Loads induced by the actuation of safety / relief valves l associated with automatic depressurization system (SRVADS)*
(s
(_) Mississippi Power & Light 5 of 11
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- c. Loads generated by restrained thermal expansion. These include temperatures at normal operating conditions (TH).
- d. Loads induced by the steam condensing / chugging (SC/CH).
- e. Seismic Loads - Safe Shutdown Earthquake (SSE).
5.0 LOADING COMBINATIONS The following loading combination shall be used for the design review of pipe supports:
DL + TH + SSE + SRVADS + SC/CH This is a faulted loading condition.
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( Mississippi Power & Light 6 of 11
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6.0 ALLOWABLE STRESS LOAD CASE Stress Normal & Upset Faulted Value KSI Tension 0.6 Fy 21.6 Shear 0.4 F y 14.4 Web Crippling 0.75 F y 27.0 Fa per Table 1-36 AISC Bending 0.6 Fy 21.6 As per ASME Appendix F-1370 Bearing 0.9 F y 32.4 O sotte reastoa ^ttowebte reastoa per AISC I
307
- Shear Allowable Shear per AISC Anchor Bolt TABLE A Welds 0.3 Fy 21.0 i (Fillet, Shear (Weld Metal)
! Full or Tension 0.6 F 21.6 Partial (BaseY Metal)
Penetration)
Combined Stress Per AISC Catalog Items Catalog Values Mississippi Power & Light 7 of 11 Grand Gulf Unit 1 l
Li(Fj d Id Design Criteria l
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7- APPENDIX A k' DESIGN (Anchor Bolt)
A.l.0 APPLICATIONS A.l.1 Concrete expansion anchors should not be used indiscriminately. For important work, bolts should preferably be cast-in-place, welded, or grouted in drilled holes or in cast-in-place sleeves. Where those types of installation are for good reason impractical, expansion anchors may be used.
A.l.2 Provisions of this standard shall apply to the shell or stud type expansion anchors.
A.l.3 Anchors must be at least 1/2" diameter when used for structural connections or for anchorage of pipes greater than 2" diameter.
A kJ A.l.4 Embedded length of anchor shall be exclusive of thickness of grout pad or other overlay.
A.2.0 ALLOWABLE LOADS A.2.1 Allowable loads shown in Table A, as modified by the provisions of this standard, shall apply to anchors installed in 1
l ordinary concrete.
1 A.2.2 For concrete strength between 2 ksi and 6 ksi, linear interpolation in Table A may be used. For concrete strength greater than 6 ksi, use 6 ksi allowable values. For sound concrete of unknown strength, use 2 ksi values.
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(j Mississippi Power & Light 8 of 11 Grand Gulf Unit 1 b8IdifdDesignCriteria lll11111111lllllllllllllllllll DC-8 20 26-2 ; Rev. 1 l
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A.2.3 Allowable load values given in this standard shall not be increased because of short duration of loading (e.g., for wind or seismic loads).
A.2.4 For anchors subjected to continuous or frequent (more than 500 times per year) reversal of loading, allowable loads shall be 1/3 of the allowable values given in this standard.
A.2.5 Allowable loads given in this standard are intended for use at " working load" levels. For " ultimate" or " limit" load design purposes, twice these values may be used.
A.2.6 Anchors installed in lightweight aggregate concrete shall have allowable loads equal to those provided for anchors in ordinary concrete with f' = 2 ksi .
A.2.7 If center-to-center spacing of anchors is less than 12 g-) diameters and/or if distance from edges of concrete to center of
\' anchor is less than 6 diameters , the allowable loads shall be reduced in accordance with the following formulae:
P
= 2.25 P^ N+6 E+3 l
S D"
- A E+3 where:
PD= allowable pullout load reduced for edge distance and/or spacing PA= all wable pullout load from Table A SD= allowable shear load reduced for edge distance SA= allowable shear load from Table A
() r ..
Mississippi Power & Light Grand Gulf Unit 1 9 of 11 L'I lij( 11 Design Criteria lllll1111lllllllllllllllllllll DC-8 20 26-2 ; Rev. 1 l
(x
\
N = number of diameters of anchor spacing (6<N<12): if N>l2, use N=12 E = number of diameters of edge distance (3<E<6): if E>6, use E=6 Anchor spacing shall be not less than 6 times nominal diameter of anchor. Edge distance shall be not less than 3 times nominal diameter nor less than 3 inches. If edge of concrete is chamfered, edge distance shall be measured from nearest edge of chamber.
A.2.8 For anchors which will be subjected simultaneously to pullout and shear forces, the allowable load values used must satisfy the following formula:
P S (p c )5/3 + ( g c)5/3 <1 D D where: P D' SD= allowable loads (pullout, shear), reduced for spacing or edge distance if appropriate.
PC' SC= design loads to be used in cases where pullout and shear loads may occur simultaneously.
Note: For convenience in calculation, exponents in the above formula may, conservatively, be reduced to 1.0.
() Mississippi Power & Light Grand Gulf Unit 1 10 of 11 LY ( PJ 2 A1 Design Criteria 1111111llllltlllll11llllllllll DC-8 20 26-2 ; Rev. 1
TABLE A ALLOWABLE LOAD (KIPS) ON EXPANSION ANCHORS NOMINAL CONCRETE STRENGTH, f' DIAMETER 2 ksi 3 ksi 4 ksi 5 ksi 6 ksi (inch) P S P S P S P S P S 1/4 .25 .30 .275 .30 .30 .30 .325 .30 .35 .30 3/8 .40 .54 .50 .60 .60 .67 .70 .73 .80 .80 1/2 .70 .74 .87 .89 1.05 1.04 1.23 1.19 1.40 1.34 5/8 1.20 1.00 1.50 1.25 1.80 1.50 2.10 1.75 2.40 2.00 3/4 1.80 1.50 2.35 1.80 2.90 2.10 3.45 2.40 4.00 2.70 0
7/8 2.50 2.00 3.35 2.35 4.20 2.70 5.05 3.05 5.90 3.40 1 3.30 2.50 4.30 2.90 5.50 3.30 6.60 3.70 7.70 4.10 1-1/4 5.30 3.40 6.65 3.95 8.00 4.50 9.35 5.10 10.70 5.70 NOTE: P, PULLOUT; S, SHEAR For expansion anchors installed in lightweight aggregate concrete, assume F' = 2 ksi. See par. A.2.6.
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() Mississippi Power & Light Grand Gulf Unit 1 11 of 11 bi(si2IdDesignCriteria 111lllll111111llllllllll111111 DC-82026-2; Rev. 1
PFR No. 009 Revision No. 1 C) Potential Finding Report sheet of 3 3 II. Senior Review YES NO Further Review Required Valid Observation b Potential Safety impact U b Comments:
Subsequent to the initial issuance of this Finding, Bechtel checked the local stress calculations for all 112 safety-related supports and anchors which were designed by the [hchtel Civil Group. After the completion of this checking activity, Cygna performed a review of 25% of these calculations. In addition to the QA Review to assure compliance with applicable procedures, a technical review of these calculations was performed to assure that proper engineering procedures were employed.
Included among those calculations which were reviewed were the problems which contained the highest primary stresses, the highest secondary rs stresses and the highest load to pipe size ratios. These reviews
() revealed that all calculations were properly checked and that there were no instances in which the stress allowables were exceeded. Based upon o the above, it has been determined that there is no impact upon plant safety.
Approved b -- A M2345 2.
b CMnt Senior Reviewer '
Date Ill. Project Managor Comments:
None.
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Approved by T UAW 8-25-62 Project Manad Date O Mississippi Power & Light V Grand Gulf Unit 1 Independent Design Review
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