ML20080S875

Comments on Pipe Support Design Noncompliance W/Fsar. Summary of 830627 Meeting W/S&W Re List of 20 Unacceptable Supports Submitted on 830103 Discussed

ML20080S875
Person / Time
Site:	FitzPatrick
Issue date:	06/30/1983
From:	Dainora J TARGET TECHNOLOGY, LTD.
To:	Guaguil L POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20080S869	List: ML20080S875
References
FOIA-83-461 NUDOCS 8310180538
Download: ML20080S875 (5)

Text

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s TARGET TECHNOLOGY LTD.

222 WEST LANCAsTER AVENUE e PAOLI. PENNSYLVANIA 19301 (2151296J340 l

1. "USYE -

June 30, 1983 ,

Mr. Leon Guaquil ,

Director, Project Engineering-BWR New York Power Authority 123 Main Street .

White Plains, New York 10601 .

Subject:

James A. FitzPatrick Nuclear Power Plant Design Non-Compliance with Final Safety

' Analysis Report (FSAR) 0:ar Leon: '

l My initial letter to the Authority (Reference 1) dated 9/3/80 was motivated by the fact that the activity for compliance with the requirements of .I&E Bulletins 79-02, 79-07 and 79-14 to an~ Interim Criteria (normal / upset loads + seismic) was coming to a close and therefore it appeared timely to close-out the overall activity by bringing the pipe supports to compliance with FSAR comitments and Code require-ments before disbanding the asse61ed project team. I also wanted to make sure that the Authority clearly understood, because of safety implications, that the task was incomplete and additional effort would be required to corplete it. l After a couple of years of waiting for a response to my initial letter, I sent -

a follow-up letter dated 12/20/82 (Reference 2) addressed to you. My concerns at the time of the Record for 348 s\second tipports in letter the were plant based which on hadthe fact that wepackages calculational were the that Engineers-of-we consider to be incomplete from the standpoint of industry practice, as well as Code and NRC requirements. We wanted to be absolutely sure that in the event of a /

post-accident inquiry that at least the work that we had performed was complete and represented our best efforts.

j At your request, we telecopied to you on 1/3/83 the following list of 20 l supports which had an earthquake loading. component less than 33 percent.of the total load, and therefore have the potential of not meeting the Code allowable l limits for the normal loading condition. .

MSK 114U H10-522 MSK 137G H46-1A MSK 116C Hil-2 MSK 127A H29-141 MSK 114U H10-214 MSK 127A H29-23 MSK ll6C Hil-1 MSK 127A H29-349 MSK 117F H14-55 '

MSK 1270 H29-21 -

MSK 114F BZ-14C MSK 127B H29-348 MSK ll4F H10-40A MSX 127C H29-27' MSK 117A H14-49 MSK 127C H29-351 MSK 114J H10-215 MSK 1270 H29-25 MSK 101 A H12-52 MSK 1270 H29-350 g O g 38 830906 WEISS83-461 PDR

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H TARGET TECimutuu a u v.

June 30, 1983 h Page 2 L Mr. Leon Guaquil New York Power Authority e  !

It was The Engineer-of-Record f.or the above supports is Stone & Webster. p important for us to establish the quality of theIncluded sample review in the above which you un

and the reasonableness of the conclusions you reached. Our list we from normal operating loads _ an'd have safety implications for the plant. q

~ pre-established position was that if you gave all of the above supports aL bill of health then additional technical dialogue on this subject would probab $

not produce any significant results.

t Our meeting on 6/27/83 at Stone & Webster's offices to discuss my concerns I am sure included senior management from the Authority and Stone However, I would like to offer my comments and observations on some of the  !

discussion which took place:

Rem fl . Stone & Webster indicated that for the supports .

and are satisfied.

Authority's Comment:

The validity of this statement is the responsibility to assess and to act on the b8 sis of their conclusions.

Stone & Websler reviewed the sample list of 20 supports provided Item #2.

by TARGET and found all of them to be acceptable _.

Given the fact that some of the supports show evidence Coment: of physical damage from normal operating loads, the On the other statement appears to us to be incredible.

hand, we are aware that TARGET is only a small consulting company and we do not claim to have the depth of technical .

expertise to challenge an industry leader such as Stone &

Webster.

l TARGET should have considered the normal operating loads at the tim f item #3.

that they did the calculations.

We were told by the Authority and Stone & Webster in 1979 Coment: specifically not to do that because we found supports which were failing the allowable stress limits for the l l normal operating condition. Because at the time of this J l

activity our contract was on a time and material basis, l there was no reason for us to do less than required.

No safety implications are implied because even for the case of zero Item #4. earthquake loading the most that the code allowable limits would be exceeded would be 33 percent.

TARGET TECHNOLOGY LTD.

s June 30,1983

'Mr. Leon Guaquil '

Page 3 (

N:w York Power Authority Coment: An appealing generalization on the surface--however, it does not account for the fact that some of the supports appear to be already overloaded.

Item #5. The supports were initially designed by Bergen-Patterson for normal operating loads and since the show cause order was directed to earthquake effects, the supports must be OK for normal loads.

Coment: An illogical conclusion that is not supported by fact when the following is considered:

(a) Because the majority of the Bergen-patterson calculations are not available--what was actually done during plant construction is an unknown.

(b) The support loads changed dramatically for many supports because the as-built condition of the plant did not match the piping configurations which were initially analyzed.

(c) Supports were added or deleted to' systems.

Item #5. TARGET has not evaluated the 348 support designs for which they are the Engineer-of-Record for normal operating loads.

Comment: Outside of appealing to your sense of professionalism, concern for public safety, and the potential for a huge economic loss, there is not much more than we can do. However, if the Authority elects not to review the 348 support designs for l

normal operating loads, they also must assume 100 percent of the responsibility and the legal consequences.

In our brief discussion on this subject after the conclusion of the formal portion of the meeting you requested background material and a cost estimate for doing the work.

The estimated cost for doing Our proposal is presented as Attachment "A".

l the work is $74,500. If you decide to request us to perfonn the assignment, we will accomplish the task with our usual professional pride and integrity.

The background material which may be useful to your decision making process is enclosed as follows:

Reference 3: Pipe Support Design Criteria - Dated 5/23/79.

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Comment: The initial criteria proposed by TARGET. Because some of the

' support designs did not pass the normal operating loads, we were instructed by the Authority and Stone & Webster to change the criteria.

. TARGET TECHNOLOGY LTD.

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Mr. Leon Guaquil . June 30,1983 New York Power Authority Page 4 Reference 4: Notes of Telephone Conversation - 5/25/79.

Comment: TARGET was trying to establish what design criteria to be used. Also note G. Arena's (S&W) coment that except for components welded directly to the pipe, all other components were considered in the original design to be within the jurisdictional boundaries of the AISC Code.

Reference 5: TARGET's Checking and Modification Design Criteria for Pipe Supports - dated 5/26/79.

Comment: This criteria was reviewed and approved by the Authority.

Note that any consideration of normal. operating loads was deleted per the direction of Reference 4. '

Reference 6: SAR Excerpt. , page Q.4.1-1 Comment: Note comitment to design supports to ANSI B31.1.0-1967.

This comitment is inconsistent with G. Arena'.s coment in Reference 4. The importance of G. Arena's comment was that he was the only available S&W spokesman who had actually worked on the original plant design.

Reference 7: PASNY report to the NRC transmitted via letter JPN-79-48 (Page 4-5)

Coment: Note the statement that "All calculated stresses are checked against allowables specified in ANSI B31.1." This statement is consistent with the original SAR comitments (see Reference

6) but inconsistent with what was actually done.

I

!. In closing, let me 'say that I understand your problem as a technical manager I

in sifting through the conflicting statements. On the one hand, you have a small consulting company telling you that the situation as it currently exists requires corrective action, while on the other hand a major .A/E firm who built the olant initially is telling you not to worry about it--everything is alright.

In my situation the problem is slightly different. As a specialist in the piping area, I am . convinced that unless you do something in the very near future, the plant will have a major Loss-of-Coolant Accident within the next three years.

Waiting for an accident to happen to be proven technically correct seems like an absurd way of accumulating professional credits.

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. . TARGET TECHNOLOGY LTD.

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'Mr. Leon Guaquil

• Jt.ne 30,1983 New York Power Authority .

Page 5 Leon, I have had my final say on this subject. The ball is back in your court. You do what you think is best for you, your employer, the nuclear industry and the general public.

Yours very truly, TARGET TECHNOLOGY LTD.

b ohn Dainora President JD:eh Enclosures cc: Mr. R. Burns (NYPA) -

Mr. J. Leonard (NYPA)

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