ML20082F095

Vol 4 to Idvp, Suppl to Final Rept

ML20082F095
Person / Time
Site:	Fermi
Issue date:	11/15/1983
From:	Ferg D CYGNA ENERGY SERVICES
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TR-83021-1, NUDOCS 8311280428
Download: ML20082F095 (227)

Text

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O INSTRUCTION' SHEET To' incorporate the revised Cover Sheet and Table of Contents into Volume 1 of Cygna's Final Report' for the Independent Design Verifi-

- cation Program on Betroit Edison's Fermi-2 plant (Docket #50-341),

perform the following:

a)_ Remove from Volume 1 the Cover Sheet dated April 29, 1983 and Table of Contents, pages 1, 11, iii, iv and v.

b) Insert into front of Volume 1 the attached revised Cover

. Sheet and Table'of Contents, pages i, ii, iii, iv, y and vi.

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l 831128042E 831114 DR ADOCK 05000

p) y No.: TR-83021-1 Revision 1 FINAL REPORT Independent Design Verification Program of Enrico Fermi - Unit 2 Prepared for The Detroit Edison Company 3331 West Big Beaver Road Troy, Michigan 48084 l

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TABLE OF CONTENTS

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VOLUME 1 Page 1.0 Executive Summary..................................... 1-1 1.1 Introduction..................................... 1-1 1.2 Scope of Work.................................... 1-2 1.3 Project Organization............................. 1-4 1.4 Methodology...................................... 1-5 1.5 Results ........................................ 1-6 1.6 Conclusions...................................... 1-7 2.0 Program Review Scope.................................. 2-1 2.1 Program Objectives............................... 2-1 2.2 System Element Selection......................... 2-2 2.3 Design Control Review............................ 2-3 r~x 2.3.1 Review of Detroit Edison's................ 2-4

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'- Design Control Program 2.3.2 Implementation Evaluation of Detroit...... 2-5 Edison's Design Control Program 2.3.3 Review of Contractor's.................... 2-6 Design Control Programs 2.4 Technical Design Review.......................... 2-7 l 2.4.1 Mechanical Discipline Scope............... 2-7 I 2.4.2 Structural Discipline Scope............... 2-11 2.4.3 Electrical Discipline Scope............... 2-15 2.4.4 Plant Walkdown Review Activity............ 2-17 i

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Page 3.0 Review Approach....................................... 3-1 3.1 Document Collection.............................. 3-2 3.2 Work Instructions / Review Criteria................ 3-3 3.2.1 Design Control Criteria................... 3-3 3.2.2 Design Criteria........................... 3-4 3.3 Review Procedures................................ 3-4 3.1.1 Checklists................................ 3-5 3.3.2 Observation Records....................... 3-6 3.3.3 Potential Finding Report.................. 3-7 3.3.4 Actions Items............................. 3-8 3.4 Design Control and Technical Reviews............. 3-8 3.5 Project Review Team.............................. 3-9

/N 3.6 Senior Review Team............................... 3-10

'v 4.0 Review Results........................................ 4-1 4.1 Introduction..................................... 4-1 4.2 Design Control Review Results.................... 4-2 4.2.1 Detroit Edison Review Results............. 4-2 4.2.2 Contractor Review Results................. 4-3 4.3 Technical Review Results......................... 4-5 4.3.1 Pipe Stress Review Results................ 4-6 4.3.2 Pipe Support Rcview Results............... 4-7 4.3.3 Equipment Qualification Review Results.... 4-9 4.3.4 Structural Review Results................ 4-10 4.3.5 Electrical Review Results................ 4-12 A

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,-s TABLE OF CONTENTS (continued)

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v Page 5.0 Conclusions and Recommendations....................... 5-1 5.1 Potential Finding Reports........................ 5-1 5.2 Significant Conservat1sms........................ 5-7 5.3 Recommendations.................................. 5-8 5.4 Conclusions...................................... 5-10 5.4.1 Design Control Review Conclusions......... 5-10 5.4.2 Technical Review Conclusions.............. 5-12 VOLUMES 2 AND 3

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\_/ 6.0 Appendices Appendix A: Definitions and Nomenclature Appendix B: Documents Reviewed Appendix C: Review Criteria Appendix D: Observation Review Records Appendix E: Potential Finding Reports Appendix F: Checklists Appendix G: Statement of Independence m

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s TABLE OF CONTENTS (continued)

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VOLUME 4 Page, 7.0 Supplemental Information............................. 7.1-1 7.1 Background / Introduction......................... 7.1-1 7.2 Supplemental Discussion......................... 7.2-1 7.3 Expanded Scope.................................. 7.3-1 7.4 Results ....................................... 7.4-1 7.5 Conclusions..................................... 7.5-1 7.6 Revised Potential Finding Reports............... 7.6-1 7.7 Revised Observation Review Records.............. 7.7-1 -

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LIST OF EXHIBITS

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V Exhibit Page No. Exhibit Title No.

.. 3 1.1 Major Shutdown Cooling' Path System............... 1-10 1.2 Responsibility Matrix (RilR Cooling).............. 1-11 1.3 Responsibility flatrix (RilR SW)................... 1-12 1.4 Responsibility flatrix (Cooling Water ............ 1-13 Foundation) 1.5 Responsibility Platrix (Electrical)............... 1-14 1.6 Project Organization............................. 1-15 1.7 Review Process Flow Chart........................ 1-16 1.8 Observation Log..................................

2.1 Major Shutdown Cooling Path System............... 2-20 O

b 2.2 11o r i z o n t a l R e v i ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21 2.3 Vertical Review RIIR Cooling...................... 2-22 2.4 RilR Shutdown Cooling Mode Element................ 2-23 2.5 Responsibility Matrix (Rita Cooling).............. 2-24 2.6 Vertical Review RIIR SW........................... 2-25 ,

2.7 RilR Service Water Element........................ 2-26 2.8 Responsibility I' atrix (RilR SW)................... 2-27 2.9 General Arrangement Drawing, RIIR Complex,........ 2-28 Roof Plan 2.10 RilR Cooling Tower Foundation..................... e.-29

• Exhibit 1.8 is independently numbered p

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k LIST OF EXHIBITS (continued)

O Exhibit Page No. Exhibit Title No.

2.11 Responsibility Matrix (Cooling Water............. 2-30 Foundation) 2.12 Vertical Review Electrical Discipline............ 2-31 2.13 Responsibility Matrix (Electrical)............... 2-32 3.1 Review Process Flow Chart........................ 3-12 3.2 List of Prime Contacts........................... 3-13 3.3 Action Items..................................... 3-14 4.1 Vertical Review RHR Cooling...................... 4-13 4.2 Vertical Review RHR Service Water................ 4-14 4.3 Vertical Review Electrical Discipline............ 4-15 (RHR Cooling Tower Fan Motor)

() 4.4 Vertical Review Structural Discipline............ 4-16 (RHR Cooling Tower Foundation) 7.1 Summary of Review Ef fort by Discipline . . . . . . . . . . 7.2-10 7.2 Summary of Review Ef fort by Design Documents . . . . 7.2-10 7.3 Expanded Review................................. 7.3-2 W d Detroit Edison Company vi f' g" g * "d *Jf'=jFermi 2 Independent Design Verification

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VOLUME 4 Independent Design Verification Program of Enrico Fermi - Unit 2 Prepared for The Detroit Edison Company 3331 West Big Beaver Road Troy, Michigan 48004 g Prepared by

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TABLE OF CONTENTS (q.)

VOLUME 4 l

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7.0 Supplemental Information............................. 7.1-1 7.1- Background / Introduction......................... 7.1-1 7.2 Supplemental Discussion......................... 7.2-1 7.3 Expanded Scope.................................. 7.3-1 7.4 Results ....................................... 7.4-1 7.5 Conclusions..................................... 7.5-1 7.6 Revised Potential Finding Reports............... 7.6-1 7.7 Revised Observation Review Records.............. 7.7-1

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LIST OF EXHIBITS

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s Exhibit #9" NO. Exhibit Title No.

7.1 Summary of Review Ef fort by Discipline . . . . . . . . . . 7.2-10 7.2 Summary of Review Effort by Design Documents. . . . 7.2-10 7.3 Expanded Review ............. ....... 7.3-2 i

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[~^) 7.0 SUPPLEMENTAL INFORMATION

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7.1 Background / Introduction On April 29, 1983, Cygna Energy Services submitted the final report for the Fermi-2 Independent Design Verification Program (IDVP) concurrently to Detroit Edison (DECO) and the Nuclear Regulatory Commission (NRC). Subsequent to this submittal, mem-bers of the NRC and representatives of Detroit Edison and Cygna met in Bethesda, Maryland on June 15, 1983 to discuss in detail the results and conclusions of the IDVP presented in the final report. Following this meeting, the NRC requested Cygna to pro-vide a supplement to the final report which addressed a number of questions raised during the NRC staff review. Primarily, the NRC comments focused on the structural design review of the RHR Complex building and the extent Cygna's review was expanded beyond the originally-defined work scope. The supplement should

) also . clarify and expand on the bases for resolving a number of the reported observations and potential findings. The NRC also agreed .that it would be appropriate for Detroit Edison to provide its views on Cygna's final report. Cygna would respond, as necessary, in the supplement to any DECO comments.

A summary of the meeting on June 15, 1983, and a follow-up con-ference call on June 16, 1983, was provided by NRC letter from Mr. M. D. Lynch, Project Manager, dated July 26, 1983. In mid-July 1983, Cygna received a document entitled " Detroit Edison Comments on Cygna IDVP Final Report on Fermi-2," transmitted by letter from Mr. W. F. Colbert of Detroit Edison to Mr. J. A.

Famiglietti of Cygna Energy Services dated July 18, 1983. Cygna subsequently reviewed both documents and our responses are pro-vided as part of this supplement to the IDVP final report (Section 7.2).

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7.2 Supplemental Discussion G

The purpose of this supplemental volume is basically to expand on the material presented in Volume 1 of the IDVP final report and to amplify the information contained in Attachment A to the Observation' Review Records in Volume 2, Appendix D. It also includes a new section (Section 7.3) which summarizes the speci-fic areas in the review process where the scope-of-work was expanded beyond what was contained in the original program plan.

The NRC review questions and the DECO comments on Volumes 1 and 2 of the IDVP final report required Cygna to conduct further review activities and to perform additional verification audits of selected material referenced by DECO in their document. It is therefore appropriate for Cygna to confirm again, in Section 7.5 of this Supplemental Volume 4, the conclusions of the IDVP per-formed on the Fermi-2 plant.

The overall purpose of the Independent Design Verification f) Program was to e . review an important portion of the present design; e assess the adequacy of the design control process; e assess the adequacy of the overall plant design; e provide added assurance that the plant has been designed safely.

In performing the IDVP for Fermi-2 and reporting the results and conclusions of our effort, Cygna should have stressed two important points. First, the review was undertaken with the understanding that Cygna would examine the actual design and design control activities on Fermi-2 in detail, with defined procedures, and using engineers experienced in design and design

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f) control requirements on nuclear power plants. In this way, the IDVP conclusions woul6 be based on:

e implementation of a program plan with an established work scope and a defined methodology acceptable to the 11RC; e Cygna's ability to perform the actual design work being reviewed.

Second, it was undertaken with the objective to simply state, based on Cygna's understanding and experience with standard engineering practices and knowledge from previous reviews, whether the design and design control process were done adequately and whether the design complies with the licensing requirements and commitments on~ Fermi-2.

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( To this end, Cygna established a methodology for the review which

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documented clearly and concisely how the review was to be con-ducted (work instructions), what the project requirements were (review criteria), what was examined in the course of the review (checklists), and, finally what was found at each stage in the review cycle (observations and potential findings). Consequent-ly, to evaluate Cygna's results of the IDVP, one has to analyze and consider the report and appendices in total.

To summarize, Cygna's confidence in the conclusions of the Fermi-2 IDVP is based on:

• The applicability of the horizontal / vertical review approach.

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e The multi-disciplined review conducted.

v e The fact that the review covered most major contractor interfaces.

e The extent to which the analysis and design process was reviewed from a programmatic standpoint.

e The level of detail of the individual reviews.

• The expansion of scope to resolve items with potential generic impact.

• The results of the design control and technical reviews.

• 'The experience level and continuity of DBCo project /

engineering personnel.

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DECO's commitment to implement the management directives e

issued.

Again, the scope-of-work for the IDVP provided Cygna an oppor-tunity to examine the design process and analytical techniques j used on Fermi-2 by:

o major subcontractors in engineering mechanics; e major civil / structural designer for Category I buildings; em)

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major Class 1 valve supplier; e major flued-head supplier.

Based on this, Cygna was able to accomplish the objectives of the Independent Design Verification Program Plan and provide the NRC and Detroit Edison additional assurances that Fermi-2 has been designed adequately.

The following supplemental information is provided in response to the comments and suggestions of DECO on the IDVP Final Report, and the NRC review questions.

A number of structural observations were resolved as having no safety impact due to the margins between design requirements and the as-built condition. Cygna considers this to be a result of the design process followed at the time and not a result of f) " luck." This is reinforced by the fact that the as-built condi-tion was constructed in accordance with the structural design drawings. Cygna noted this conservatism in Volume 1, Section 5.2 of the Final Report. Further technical discussions are provided on this point in the revised Observation Review Records in Section 7.7.

Cygna believes that the number of observations resulting from our review should not detract from the overall design adequacy or safety margins existing in the system elements reviewed. Work Instructions were issued to the task / discipline reviewers instructing them to record an observation each time they identi-fied an item in apparent nonconformance with the project review criteria. Each observation would then be reviewed by the Project Engineer and others either assigned by the Project Engineer or as O

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part of the Project Review Team. If the observation was deter-(]

U mined to be valid, it underwent further review to assess design impact. If the observation had an impact on the design of Fermi-2, it was reviewed further to determine whether it impacted safety. Consequently, the actual number of observations are unrelated to design adequacy or safety impact. It is a direct result of the level of ietail to which the review was conducted.

Cygna categorizes observations as either invalid or valid.

Guidelines followed in designating an observation as invalid are basically if further review and clarification indicates:

• the item is in conformance with the checklist and project review criteria; or o the checklist or review criteria is inappropriate or not applicable.

Valid observations are all those remaining observations that are (O

not categorized as invalid. All valid observations are then reviewed to determine if any have an impact on plant r.fety. In performing this review, the Project Review Team considers a number of factors, including:

• impact if the observation is for a design error or flaw; e extent if the observation is a result of a programmatic breakdown; e sianificance if the observation represents a code /

standard nonconformance.

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'[m') Generally, if any impact, extent or significance can be assigned to the observation as a result of the review, the observation is identified as a potential finding report. In considering extent, the review determined whether the observation was for an isolated or extensive condition. If it was an unsatisfactory condition ,

found - to be localize 6 and distinct, it was considered isolated.

It was considered extensive if it reflected an unsatisfactory condition found to have generic or programmatic implications.

The ten Potential Finding Reports reflect those items which Cygna felt warranted further consideration and could have possibly

-af fected plant safety.

The Potential Finding Reports and Observation Records have been expanded in Sections 7.6 and 7.7 to provide additional background and technical information considered in Cygna's review. In con-sidering the final report review comments, it is our opinion that the Observation Log is being misinterpreted and misused as a (t..~) summary document. Cygna bases this statement on the perception

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that the NRC and Detroit Edison, in their respective reviews, used the " Rem **ks" column entry as the complete explanation for resolving a particular observation. In all cases, the reviewers should have referred to the particular Observation Review Record or Potential Finding Report for further detailed informction.

The recommendations contained in Section 5.3 were made to Detroit Edison to identify areas where improvements might be made to the final design and de*n verification activities. They represent suggestions only in the purest sense and were never intended to be imposed as requirements on the Fermi-2 project or viewed by anyone as necessary to assure safety. Cygna's review process involved an in-depth assessment of the design. An appropriate extension of the review is the listing of specific recommenda-

-tions with respect to the design process in effect. In some p) -

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cases, the recommendations involved simply documenting the

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V capability and conservatisms which exist in the as-built configuration. In summary, the recommendations were made as suggestions only and should be left solely to Detroit Edison's descretion as to their implementation.

As noted in Section 4.1, management directives were requested by Cygna to provide part of the bases for resolving seven of the Potential Finding Reports. In some cases, these directives served to give more visibility and status to already established or on-going activities. In others, the management directives represented a confirmation or written commitment that certain actions would be performed or various events would occur. In all cases, these directives provided documented evidence of the actions which Cygna felt had to occur or activities which had to continue to completion, to confirm the conclusion of the review.

Management directives should be recognized as an acceptable and f's recommended means to close out a potential finding with a

\U referenceable document that ensures a satisfactory resolution.

In the course of the NRC review, a number of questions were posed to Cygna which will be addressed as follows. First, the NRC requested a breakdown of the manhours expended by Cygna in reviewing the various disciplines. A total of approximately 8,000 manhours were expended by the Cygna review teams. It is estimated that Detroit Edison, Sargent & Lundy and Stone &

Webster expended an equivalent number of manhours in support of this review.

A breakdown of the 8,000 manhour effort oy discipline is provided in Exhibit 7-1. In addition, Exhibit 7-2 provides a summary for the 1,131 documents which Cygna referenced in the course of the revicw effort.

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,m The flRC also expressed a concern that seismic and thermal loads i

,V were not considered in the structural design. Cygna addressed

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that concern by (1) evaluating the significance of t ese loads on the RHR Complex and (2) spot checking to verify that these loads were considered wherever they are significant. Regarding seismic loads, Sargent & Lundy included all significant seismic loads in the structural design of the RHR Complex. Two observations addressed this matter: ST-01-20 and ST-01 -21. In both cases, tornado loads clearly controlled design. Pegarding thermal loads, Sargent & Lundy re-evaluated critical sections of the RHR Complex for thermal loads in response to Observations ST-01-07 and ST-01-08. In each case, the thermal stresses were small and had no impact on design. It should be noted, however, that thermal loads throughout the RHR Complex are small. To address the question of whether or not significant thermal loads were considered in the Fermi 2 structural designs, Cygna spot-checked other structural calculations by Sargent & Lundy. This spot p check verified that significant thermal loads were indeed 1

U coasidered.

The liRC asked Cygna whether the 95 valid observations are significant with respect to the effectiveness of the QA/QC process. The identification of 95 us. lid observations is a direct result of the methodology and thoroughness of the design review and is not a negative reflection on the Fermi-2 design or design process. This possibility was considered specifically in the Senior Review Team review and determined to be unconnected.

Three Potential Finding Reports (PPR-01, PFR-02 and PFR-03) represent the items which Cygna found to be weaknesses in the overall QA/QC process. The concerns identified were basically applicable to a timeframe between 1975 and 1980 and no safety impact was determined. Presently, the QA/QC Organization and activities are functioning effectively from a design review

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Detroit Edison Company 7.2-8 f 4/ id .' T i Fermi 2 Independent Design Verification IIllililllllililllll!!!!Illij Final Report TR-83021-1; Rev. O

standpoint. Cygna's conclusions support this position as stated in Volume 1, Section 5.4.1 of the Final Report.

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EXHIBIT 7-1

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SUMMARY

OF REVIEW EFFORT BY DISCIPLINE Review Discipline Manhours Percentage Design Control 42

- Detroit Edison 1,410

- Sargent and Lundy 1,010

- Stone and Webster 940 Structural

• 1,920 24 Pipe Str-7;* 1,520 19.

Pipe Support

• 800 10 Electrical

• 320 4 Equipment Qualification 80 ,

1 TOTAL 8,000 100%

• Includes the 185 manhours consumed in performing the plant walkdown activity.

EKHIBIT 7-2

SUMMARY

OF REVIEW EFFORT BY DESIGN DOCUMENTS Design Document

• Number Reviewed Specifications 54 Calculation Packages 78 Design Criteria 154 Drawings 338 Project' Correspondence 507 TOTAL 1,131

• An estimated 40 calculations, including computer output and other miscellaneous drawings and correspondence, were re-examined by Cygna following a review of Detroit Edison supplemental comments on the IDVP Final Report.

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-7 . 3 Expanded Scope of Review N.)

It.is important to note that in many cases the review activities were not limited to .the original scope defined in the Program Plan. In. order to draw a substantive conclusion with respect to the overall design of Fermi-2, each observation was fully evaluated in order to address the question of extent. Thus, when it was determined. that an observation dealt with a programmatic issue and it was not possible to assess the impact of that issue on the overall plant design by simply assessing the impact of the specific issue, the review was extended beyond the original scope.

Exhibit 7.3 summarizes the observations which required an expanded review in order to fully assess their potential impact on plant safety. The extent of these expanded reviews was considered adequate when sufficient reviews and spot checks had been performed to reach a sound conclusion. For some observa-

tions, it was anticipated that resolution would extend well beyond the scheduled completion of the IDVP. Cygna reached resolution for these -long-lead items by reviewing and approving a plan of action proposed by the project. Exhibit 7.3 shows that 31 observatios were reviewed to a level of detail and extent beyond the original scope. This represents nearly 33% of the 95 valid observations identified in the IDVP.

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EXHIBIT 7-3 EXPANDED REVIEW Observation No. Description Scope Expansion DC-01-01 DECO contract documents with Stone & Reviewed contracts for additional engi-Webster Engineering Corporation und neering contractors' (Giffels Associates, Sargent & Lundy do not include provisions Nutech, Concourse Engineering, Multiple for QA as required by 10CFR50, Appendix B. Dynamics Corporation, Chicago Bridge &

Iron Company, General Electric Company).

DC-01-03 The DECO Design Control Program does not Reviewed the validation documentation for address requirements for cert.fying i

(vali- all 13 . safety-related computer programs dating) or specifying computer codes used developed and utilized by DECO en Fermi 2.

by the project.

DC-01-08 '%e internal engineering audit system was Reviewed all implementation-type review found to be inadequate to assure total activities relating to Design Control on program implementation / effectiveness. Fermi 2.

DC-01-09 Corrective action to reported audit e Reviewed the entire Corrective Action findings was not always accomplished in a System on Fermi 2.

timely manner nor was senior management e Resulted in issuance of a DECO Manage-appraised of QA program status and ment Directive to resolve this issue.

adequacy.

DC-01-10 The audits of architect engineers were

• Reviewed the combined auditing found to be inadequate to assure total activities of DECO, S&L and S&W.

program implementation / effectiveness.

• Reviewed the DECO audits of all engineering service suppliers on Fermi 2.

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EXPANDED REVIEW Observation Scope Expansion No. Description i

DC-02-03 A review of computer programs developed In the verification review for DYNAS, and utilized by S&L in the EF-2 project version 09.7.090-4.0, it was noted that a disclosed that objective evidence was not later version incorrectly calculated available indicating validation- of absolute displacements. This resulted in computer program DYNAS, version 09.7.090- further investigations to assess the 4.0 impact on design.

A review to determine the adequacy of the e Reviewed an additional sample of DC-02-09 Sargent & Lundy (S&L) EF-2 project control sixteen correspondence, of design interface documents transmitted from DECO disclosed that of thirty-three e Checked eight of the additional EF-2 correspondence addressed to S&L, ten sixteen correspondence to assure that could not be retrieved from the S&L design input contained therein was project files, properly transferred into the final design.

PI-01-03 'Itere is no assurance in the seismic e Reviewed related GE proprietary analyses that a sufficient percentage of . studies.

the mass is included in the analysis.

• Reviewed the Main Steam and RHR/RCIC analyses. This represents 75% of the piping systems analyzed by GE .on Fermi 2.

• Assessed the effect of large masses l

near restraints.

PI-01-06 The stress indices for branch connections Reviewed generic GE studies which evalu-l along straight runs of pipe were not to ated the significance of such branch the GE piping analyses. connections and justified not including them in the piping analyses.

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EKHIBIT 7-3 (continued)

EXPANDED REVIEW Observation No. Description Scope Expansion There is no indication that the AT) , . AT2 , e

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PI-01-07 Performed a detailed review of ANSI-7 and Ta/Tb calculated by ANSI-7 produce the procedure.

• Discussed cause and effect with.GE.

largest Equation 10 and 14' stresses.

] PI-01-08 The effect of thicker sections (such as Reviewed the Main Steam and RHR/RCIC 4 the crctch region of a tee) on axial analyses to confirm the adequacy of GE's

thermal gradients (T,/Tb) has not been normal procedures. This represents 75% of calculated. the piping systems analyzed. by GE on Fermi 2.

l PI-01-09 In the ANSI-7 Computer Output for Joint Reviewed all output locations to ensure 502, the following conditions were found: conservatism of the results.

l a) The " bending + torsion" stress for emergency conditions was given as 2841 psi but was not calculated from the "WT + SSEI" loads which would have resulted in a stress of 2471 psi.

b) The stress for Equation 13 for Load Set -(19-23) is reported as 16750 psi. Using the procedure specified in the ASME Code, Paragraph NB-3653.6(b),

the result is 15608 psi.

PI-01-10 . The shear lug load input to the ANSI 7 Reviewed Main Steam and RHR/RCIC analyses (Joint 527) run is 8855 lbs. The correct to confirm the adequacy of normal GE

.; load is 11041 lbs., which is used in the procedures. This represents 75% of the deadweight (PIPSYS) computer analysis. piping systems analyzed by GE on Fermi 2.

w Detroit Edison Company 7.3-4 l {=g[g-i j ,if] r ermi-2 Independent Design Verification Final Report TR-83021-1; Rev. O g

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EKPANDED REVIEW Observation No. Description Scope Expansion PI-01-12 In the seismic anchor movement (SAM) Evaluated the overall significance of SAM analysis, only the movements at the RPV cn safety-related piping throughout the nozzles and flued head were input. No plant

movements were input at any intermediate restraint locations.

PI-02-02 Mass participation for the seismic modal Assessed the effect of large masses near analyses is 76%, 57%, and 63% in the X, restraints for all safety-related piping.

Y, and' Z directions , respectively. In systems analyzed by S&L.

addition, there is no static calculation to account for this missing mass.

PI-02-03 In the seismic anchor movement (SAM) Evaluated the overall significance of SAM analysis, only movements at the two fully on safety-related piping throughout the restrained penetrations (i.e., three plant.

translational and three rotational directions) were input. No movements were input at the other . restraint points.

PI-03-01 'Ihe AUTOHEAD computer program manual does Performed a conservative assessment of the i not provide a verification of the thermal maximum thermal gradient stress in all transient analysis solution. Only the flued heads on Ebrmi 2.

]

steady state analysis is verified.

3 4

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EXPANDED REVIEW Observation Description Scope Expansion No.

I PI-03-04 Reviewed the emergency stresses in all The stress summary for the emergency condition compares the maximum stress flued heads on Fermi 2 against the correct intensity (which included thermal allowable.

stresses) to 3 S,.

The ASME Code requires that the maximum l primary membrane + primary bending stress intensity (excluding thermal stresses) be evaluated to 1.2 x 1.5 S, = 1.8 S,.

Reviewed all flued heads on Fermi 2, as PI-03-05 The time of maximum thernal transient explained under Observation PI-03-01.

stress is determined by the temperature state corresponding to the maximum thermal gradient between any two adjacent nodes.

l This is usually an area and time of peak stress and as such the combir.ed stresses in other areas of the flued head where the pressure plus pipe-load stresses are high I

will be underestimated.

1 The combination of pressure plus pipeloads Reviewed all flued heads on Fermi 2, as PI-03-06 explained under Observation PI-03-01.

plus seismic plus thermal transient has l not been considered for either:

a. Primary plus secondary stress l

intensity ranges for normal / upset I

l conditions, or

b. Fatigue analysis.

l l

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7.3-6 Detroit Edison Company g g,[ y Fermi 2 Independent Design Verification Final Report TR-83021-1; Rev. O ll111111111lllllll1111llllllll

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EKRIBIT 7-3 (continued)

EXPANDED REVIEW Observation No. Description Scope Expansion EQ-01-03 The calculation to exclude the . stress e Reviewed all Class 1 valves on Fermi 2 reveral cyclic loading evaluation per Code by Wa. Powell Co.

Paragraph NB-3552(a) used an incorrect e Resulted in a DECO Management Direc-pressure of 2425 psi. The correct tive to address this issue during the pressure to use in this calculation is Pd planned third party reviews.

= 1250 psi.

EQ-01-04 The calculation of the yoke arm moment of # Reviewed all Class 1 valves on Fermi 2 inertia assumes a shear transfer between by Wm. Powell Co.

the four legs of the yoke. The more e Resulted in a DECO Management Direc-appropriate approach ~ would be to assume tive to address this issue during the each of the legs acts independently. planned third party reviews.

PS-00-01 S&W pipe support criteria specify maximum Prepared a separate listing of actual vs.

deflection in the restrained direction. analysis pipe support stiffnesses to This could yield support designs with a evaluate the overall impact on the RHR low natural frequency and might affect the cooling piping analysis.

piping analysis, which assumes the sup-ports are rigid and do not amplify the building motion.

PS-00-04 The self-weight excitation of the supports e verified that self-weight excitation is not considered in the S & W support is not significant for the support design. assemblies in the RHR cooling system.

e verified during the 1DVP walkdown. that the support assemblies in the RHR cooling system were representative of th se used throughout the plant (i.e.,

there were no complex support I 1 assemblies).

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t Detroit Diison Company 7.3-7 Fermi 2 Independent Design verification

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EEPABIDED REVIEW observation No. Description Scope Expansion PS-02-06 me center line of the pipe and the center verified that similar gap inconsistencies ,

line of the pipe sleeve 'are offset were identified and evaluated for all j 1 1/8". Wis is inconsistent with the penetraticn sleeves on Fermi 2.

hanger drawing which shows a 2 1/2" high lug and a 1/8" gap between the top of the pipe and the sleeve.

PS-03-01 Anchor straps securing Anchor Structure e Verified that the subject anchor No. 2 exceed the allowable stress (90% of structures provided support for ultimate stress) under faulted loading. " moderate energy" lines and thus need not'be evaluated for faulted loadings.

e Verified that all anchor structures were reviewed on Fermi 2 to assure that, where applicable, faulted allowables were not exceeded.

PS-03-02 For each of the two flued heads in Anchor Reviewed and approved the DECO procedure Structure No. 2, there are loads FX for performing an as-built analysis of all (Axial), i FYZ (Shear), t MX (Torsion), i flued head anchor structures on Fermi 2.

MYZ (Bending Moment). Ralph M Parsons Co.

l calculations consider only two (2) of the j many possible load combinations without written justification for their selection.

l ST-01-02 We ultimate load factor used for soil Assessed the impact on other major plant I loading is 1.4. The ACI 318-71 code s truc tures .

requires an ultimate load factor for soil loading of 1.7.

Detroit. Edison Company 7.3-8 I e g a-4 1

• i Fermi 2 Independent Design Verification

. Nd , , Final Report TR-83021-1; Rev. 0

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EXPANDED REVIEtt Observation No. Description Scope Expansion ST-01-24 The analysis of the embed plates modeled Performed a non-linear analysis to verify with plate, truss and one-way (compression the adequacy of the linear analysis only) boundary finite elements is a techniques.

. nonlinear analysis. The results ' from this nonlinear analysis should not be used for linear extrapolation or . linear load combinations (superposition).

ST-01-30 Following is a summary of the general Reviewed field doctamentation to verify items identified during the structural that adequate corrective action had been walkdown activities in the RHR complex: taken.

a. Generally poor formwork throughout complex.

b. Concrete walls not flat.

, c. Exposed aggregate.

d. voids.

e. Patchwork-grouting.

ST-01-33 Design calculations for shear walls in the

• S&L Performed a 100% evaluation of all RHR complex analyzed as deep beams were calculations on Fermi 2 using SLSAP based on a misinterpretation of Sargent & Element Type 6.

Lundy's SLSAP computer output. Oubput membrane shear stresses (force per unit e Cygna spot checked the evaluation area) for Element Type 6 - Plate and Shell results.

Elements - were misinterpreted as membrane shear forces (force per unit length).

Detroit Edison Company 7.3-9 Q j a-4 C Fermi 2 Independent Design Verification

,f,, Final Report TR-83021-1; Rev. O

l l

O 7.4 Results v

Results of the IDVP program were previously summarized in volume 1 of the Final Report, Sections 1.5 and 4.0. A total of 108 observations were identified in the course of conducting 'the review.

Additional review activities focused on the flRC comments expressed in the June 15, 1983 meeting and a detailed review of the supplemental information provided by Detroit Edison. The 11RC comments were addressed by re-examining the results of the IDVP to reconfirm that the results support the stated conclusions in the Final Report. Areas where the IDVP scope was expanded were also documented (refer to Section 7.3) to provide additional insight into the depth and extent of the design verification effort. Cygna also reviewed subsequent analyses and design information referenced by Detroit Edison to determine whether it

/7 affected the overall results of the original review effort. The

\ 1

primary thrust was to determine if any of the additional DECO material and references could be used to provide more background information to the Observation Review Records, particularly in the structural area.

The supplemental review by Cygna supports the results reported for the orignal review. Of the 108 observations 10 were identi-fied as ' potential findings but all were resolved by both Project Review Team and Senior Review Team reviews as having an insigni-ficant impact on plant safety.

One minor determination was made upon completion of the supple-mental review. Originally, 13 of the 108 observations were determined to be invalid. Cygna's supplemental review identified

that Observation DC-02-04 could have been categorized as an

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Detroit Edison Ccmpany 7.4-1

[i a {fy Fermi 2 Independent Design Verification ll1llll1111111ll111llllll11111 Final Report TR-83021-1; Rev. 0

invalid observation. However, this action would not affect the V overall results of the IDVP and certainly would have no impact on the review conclusions.

l O

O Detroit Edison Company 7.4-2 f,4 M gfj Fermi 2 Independent Design Verification 1111lllllllllllll1111111llllll Final Report TR-83021-1; Rev. 0

7.5 Conclusions (m

)

G' Conclusions of the IDVP program were previously summarized in Volume 1 of the Final Report, Sections 1.6 and 5.4. Cygna's supplemental review supports these conclusions and, in fact, only provided additional information to confirm their validity. To summarize, Cygna has concluded that adequate design control measures are being exercised on Fermi-2 based on a review of important shutdown cooling path elements which indicated that:

e Detroit Edison's design control activities, as defined in their design control program documentation, satisfy the project commitments and standard practice; e The design control activities of Sargent & Lundy and Stone & Webster satisfy the commitments of contract documents and the Fermi-2 SAR; and

,Q V e Based on the resolution of the Potential Finding Reports in the de ign control review, Detroit Edison, Sargent &

Lundy and Stone & Webster have adequately implemented the design control commitments as delineated in their respective design program documentation.

Further, Cygna has concluded the following with respect to the technical design review on the shutdown cooling path elements:

e Based upon the resolution of the Potential Finding Reports in the technical review, selected elements of a plant shutdown cooling path have been adequately designed to perform their intended safety function in accordance with the project commitments, applicable code requirements and industry standards.

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• Proper and acceptable criteria were defined, design procedures were used, design interfaces were identified, design results were documented, design reviews were conducted, and finally, design documents were adequately controlled for the shutdown cooling path scope of work.

3 Design documents have been properly interpreted and implemented by the construction organization.

Again, the scope of work afforded Cygna an opportunity to examine, in detail, the Fermi-2 design process on a safety-related shutdown cooling path located inside both the reactor containment and the RHR Complex building. It covered activities associated with mechanical design (piping, pipe supports, equip-ment qualification) as well as structural and electrical engineering disciplines. It also involved a plant walkdown to verify that the as-built configuration reflected the design

{V] documents. The effort not only followed the flow of information from the preliminary design stage to the as-built condition, but it also assessed the accuracy and completeness of the information at various stages of the design process. This supplemental volume to the final report identifies further the areas in which the review was expanded beyond the original scope of work. It also provides additional information and documentation to support the resolution of all observations and potential finding reports. Based on the results of our design control and technical reviews, and after reviewing the supplmental comments provided by Detroit Edison and the NRC, sufficient assurances still exist for Cygna to conclude that the overall design activi-ties on Fermi-2 are adequate and have been properly performed.

O Detroit Edison Company 7.5-2

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ll"'""llllll!!!Illllll11111 Final Report TR-83021-1; Rev. 0

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SECTION 7.6 POTENTIAL FINDING REPORTS (Revised)

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Potential oth' i Finding mim"""""'"'"""' Report Y,

PFR No. 01 Revision No. 1 observation No. DC-01-08 sheet 1 of 6 I Description A review of DECO QA Engineering Audit Files disclosed that the audit system in place since 1971 was not adequate to effectively evaluate implementation of the design control program. This was substantiated by the following:

1. A review of the fifteen audits performed of project engineering disclosed that approximately thirty five procedures (PPM's) applicable to engineering design activities had not been audited.

2. Objective evidence for at least seven audits was not available indicating that neither checklists nor procedures were used as a basis for auditing.

3. Objective evidence could not be found indicating that an assessment of program effectiveness was accomplished in any of the audits performed.

Requirement

• DECO QAP-19, " Audits"

• DECO PQAP-9600, " Auditing AE's"

• 10CFR50, Appendix B, Criterion XVIII, " Audits" v

Reference Documents l

Project QA audit files for engineering audits.

l l

I Extent l 1solated Extensive y Other (Specify)

This finding applies to the Detroit Edison internal audit system.

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! Detroit Edison Company; 83021 7.6-2 i

Independent Design Verification Program

-= Potential L41C' M Finding Report O """""""""""""""

PFR No. 01 Revision No. 1 Observation No. DC-01-08 sheet 2 of 6 Design impact Design may be impacted if there is inadequate assurance that the design control program was being effectively implemented.

O Potential Safety impact A comprehensive review was performed as directed by the Senior. Review Team to determine whether all elements of the design control program were evaluated during the course of the project. The results of this review are summarized in the attached matrix (see Attachment, Sheets 4, 5 and 6).

1 Originated By Cognizant Group Leader Date JJ */

Approved By Project E'nginger d is hol33

. date '

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-Detroit Edison Company; 3021 Independent Design Verification Program 7*6-3

Potential

[4 M'I Finding Report PFR No. 01 Revision No. 1 Observatern No. DC-01-08 sheet 3 et 6 11 Senior Review Yes No Further Review Required X Valid Observation X Potential Safety Impact X comments The Senior Review Team concurs with the above approach and no potential impact in plant safety exists.

Implementation of Project Directive EF2-62,81G will also ensure that the closure activities will' be properly tracked and performed.

O Approved By CognlN[t Senior Revber

_ nn - ll/to/s3

[ ate til Project Manager Comments Concurs with the conclusions of the Senior Review Team, i Approve Date udd.

l $ By Project %ager n/ule l Detroit Edison Company; 83021 7*6-4 Independent Design Verification Program I

Sheet 4 of 6 Rev. 0

, POTENTIAL FINDING REPORT NO. 01 (3) ATTACHMENT Design Element DECO Audit NRC Inspection Other Design Input. (1)

• Design Instructions X X (1)

• Design Specs (1),(2)

• Design References X System Diagrams (1)

Design Analysis

• Calculations X

• Stress Reports X

• Computer Programs (2)

• Design Document Packages X

• Vendor Document Packages X Drawing Control

• Preparation / Distribution X X (2)

Project Specifications (1)

Procurement Control e Bill of Materials X (2)

• Vendor Document Lists X X (2) k' -

Interface Control

• Correspondence X (2)

• Support Organization X (2)

Design Verification X Document Control X X (2)

Design Changes

• DCR's X X (2)

• DCN's X X (2)

• ASB's X X (2)

• FMR's X X (2)

• Review Board X X

• Vendor DDR's X X

• Site DDR's X X

• DCP's X X (2)

Corrective Action X X Audits X Records (2)

(3

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f e'/d i F i: Detroit Edison Company; 83021 7.6-5 liikillIlllill 11 11 11 Independent Design Verification Program

She::t 5 of 6 Rev. 1

~) Notes:

[O (1) Documents are reviewed and signed by QA to assure inclusion of appropriate quality requirements and implementations of the design control program.

(2) Evidence is available indicating that these aspects of the program were reviewed by means other than the normal audit function. That is, evaluation by the the Quality Assurance Department, Engineerng Assurance, Corporate Auditing, special audits (Diablo Canyon type reviews, special task force investigations, etc.).

In addition to the above activities, the design control program was evaluated in part via the following special reviews:

e Small Bore Designs e Pipe Supports e Large Boro Hanger Designs e- Piping and Tubing e Design Freezes e Restructure of Troy QA Organization e Class 1E Equipment Field Check

(')

'a e Design Control Review of the Core Spray Systems Based on the above activities, assurance exists that all key aspects of the design control program have been evaluated during project duration and no potentiv impact on safety exists. However, for those review activities other than the DT.Co audit system and NRC inspections, a formal system was found lacking for the follow-up of corrective action recommendations. As a result, DECO management issued a directive to QA and EA requiring that a comprehensive review be performed of these review type activities and corrective action recommendations be identified, tracked, and closed. Refer to DECO correspondence EF2-62,816 (attached).

It should also be pointed out that the master audit schedule issued by Detroit Edison in January,1983 provides a formal audit planning program. Continued implementation of this program would assure that coverage of key design control elements is maintained. Furthermore, those less formal reviews referred to in Note (2) of PFR-01 and categorized as "special reviews" were found to be quite thorough and were considered in Cygna's determination on design impact and subsequent resolution of PFR-01. Regarding the thoroughness of formal audits performed, Cygna did verify in cases that a document entitled

" Checklist for Quality Assurance Audit of Design Activities" (28 pages) was used by auditors during the audit process. Detailed review of project files and personnel interviews provided sufficient assurances that auditors were aware of the checklist review criteria, p

p---------

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"'~d Detroit Edison Company; 83021 7.6-6 Illittillllilllililllilllillli Independent Design Verification Program

> Sh:et 6 of 6 Rev. 1

,- 3 In the expanded review, Cygna noted that past Detroit Edison efforts of informing higher management of matters dealing with the QA program allowed (v) management to assess the adequacy and status of the program. For instance, Cygna was aware that during the 1974-1979 time period, monthly meetings were -

held with the Assistant Vice President-Engineering and Construction by the Corporate Director-Quality Assurance and the Fermi Project Director-Quality Assurance to discuss the status of the QA program and to obtain direction.

This monthly meeting is now held with the President of Detroit Edison by the Corporate Manager of Quality Assurance and Project Director of Quality Assurance. This meeting also includes the Group Vice President-0perations, Vice President-Nuclear Operations, and Vice President-Fermi. Pertinent quality assurance matters are discussed and direction would be available from the President for further action.

Cygna also noted that copies of Edison audits and surveillances and NRC inspection reports are received by the Manager-Quality Assurance, Vice President-Fermi, and Manager-Fermi Project. Finally, the Project Hanager's Monthly Report, which is distributed throughout the vice-presidential lesel, and to the Company President, contains summary reports on quality assurar.ce activities and identifies significant quality problems.

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Detroit Edison Company; 83021 7.6-7

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Detroit .

Edison

/; ENRICO FERMI UNIT 2 PROJECT b

April 15, 1983 EF2 - 62,816 To: T. A. Alessi R. A. Vance From: W. J. Fahrner d J. ho Manager-Enrico Fermi 2 Project

Subject:

/ Open Items from Project Engineering Design Control Activities Over the life of the plant, and especially since 1976, many and various review activities of design control have been undertaken by or in behalf of the project. Tracking and closure mechanisms exist for OA audits and NRC inspections. Other management reviews, task forces,

[) investigations, and audits did not necessarily institute

\m) structured tra'cking methods. Consistent with previous directives, it is necessary to close out these items in a timely manner.

Accordingly, I am directing you to develop a program to do the following:

(1) Identify those recommendations and findings from design control review activities not already included on project tracking systems. ,,

l The review activities to be included in this l

encompass both internal and external reviews, audits, task forces, etc. performed by or in behalf of the project.

(2) Provide the current status of each of the items identified in (1) above and those individuals and/or organizations responsible for followup and closure of these items.

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April 15, 1983 f- s EF2 - 62,816

.(] Page 2 (3) Provide periodic status reports with commitment dates for timely close out,of the items identified (4) Provide for appropriate auditable documentation.

(5)' Assure future review activities of this nature l L are appropriately controlled. I Please provide me your plan of action and who will be responsible for overall coordination two weeks from the date of this memo.

OKE:WJF:Iab cc: A. J. Benes W. F. Colbert O. K. Earle W. J. Fahrner W. R. Holland M. G. Sigetich /

H. Tauber R. A. Vance E

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[4M' TJ Finding Report PFR No. 02 Revision No. 0 Observation No. DC-01 09 sheet 1 et 3 i Description DECO management has not consistently reviewed audit results and performed the necessary actions to correct reported deficiencies. Out of eighty-five audit findings issued since October,1976, seventeen have not been resolved, fifteen of which were identified prior to June,1979 A further review of twenty-six surveillance report findin'gs issued during the period of July,1981, through July,1982, disclosed that seventeen (different than those identified above) have not been resolved.

Requirement

• DECO EF-2 QAP-19, " Audits," paragraph 19.0.2 e 10CFR50, Appendix B, Criterion XVIII, " Audits" Reference Documents Project 0A audit files for engineering audits and monitoring reports.

E xterit isolated Extensive X Other (Specify)

This finding applies to DECO's implementation of corrective action for audit

, deficiencies.

Detroit Edison Company; 83021 Independent Design verification Program 7.6-10

M Potential

[416'Id Finding Report Q lll111111lll11lllllll11!!Illll PFR No. 02 Revision No. O Observation No. DC-01-09 sheet 2 of 3 Design impact Design r- De impacted if corrective action is not performed on design control audit findings, i

Potential Safety impact Positive actions hitve been taken and are in progress to resolve all outstanding open audit findings and surveillance items. This is evidenced by a management directive from W. Holland to distribution dated April 12,1983 (attached) plus the inclusion of these items on a corrective action status report which identifies individuals responsible for resolution along with the expected dates of completion. Therefore, no plant safety impact exists and this PFR is considered closed.

Originated By Cognizant Group Leader Date

./ / / // 15 83 Approved By Project Engineer. ,

Date

1. 1 21 4hs/85

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hol I.Luatu Detroit Edison Company; h21 7.6-11 Independent Design Verification. Program

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Potential M M' fi Finding g Report v

PFR No. D2 Revision No. 1 Observatkn No. DC-01-09 sheet 3 of 3

sensor Review Yes No Further Review Required X Valid Observation X Potential Safety impact X Comments The Senior Review Team concurs with the above approach and considers this PFR closed.

Implementation of Project Directive EF2-62,816 will also ensure that the closure ativities will be properly tracked and performed.

In April,1982, Detroit Edison instituted a more formal, systematic system for tracking audit findings and QA remedial / corrective action items. Detroit Edison's Engineering 0A Section presently issues an "Open Item Status Report-Engineering Quality Assurance" periodically to responsible Project Engineering personnel down to, and including, the Group Supervising Engineers. A more recent report dated O

V 2/28/83 reflects that a number of the open items have subsequently been resolved and that progress continues to occur. Cygna also notes that the remaining open items are primarily administrative in nature and do not have a direct impact or bearing on plant safety. With continuing follow-up and management attention, Cygna anticipates the remaining open items will be brought to a satisfactory, timely resolution.

The current monthly meetings with the President of Detroit Edison involving the Corporate Manager of Quality Assurance, Project Director of Quality Assurance, the r Group Vice President - Operations, Vice President - Nuclear Operations and Vice l

President - Fermi would provide an appropriate forum for high-level management to .

I follow the progress in closing out the remaining open items. Pertinent quality assurance matters are discussed and direction would be available from the Company l

President fo fur er action.

-2 - - ////o /E t Approved By Chizan5 Senior Rev(wer - Date' ill Project Manager Comments Concurs with the conclusions of the Senior Review Team.

j P Date Approvbc Bydr lect MangerQ. m nkka' 4 Detroit Edison Company; 83021 7*6-12 Independent Design Verification Program i

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v Date: April 12, 1963 To: F. B. Agocti D. C. Hunt T. A. Alessi. S. H. Noetzel J. C. Ard, Jr. J. W. Nunley R. J. Blok M. Ripley R. J. Buckler D. Spierc W. M. Everett G. M. Trahey l W. J. Fahrner R. A. Vance A.-Godoahian J. G. Walker E. P. Griffing W. P. Wilcon M. W. Hultgren I

From: W. R. Holland

.Sub;fect: Open Itema For the past feu months in our PMO meetingc I have made a point of the importance of the closure of open *itema - both NRC and PQA generated. I have picked on those open more than 180 days. Some progress has been made and some of you have generated accelerated schedules to close these itema out.

T appreciate that moct of thoce items are coftware oriented and do Q)

Q no receive the priority they should. Theu must all be closed out and ue do nos vant the liot to grou - ue vant it to decreaua. Picace establish your priorities ao that these itema receive the attention necessary for prompt closure.

WRH/cu FPBJ-il ,

cc: W. H. Jena D. A. Wella

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Vi 7.6-13

Potential

[4 teh' M Finding Report PFR No. 03 Revision No. O observation No. DC-01-10 Sheet 1 of 4 1 Description See attachment (Sheet 4 of 4).

- Requirement DECO QAP-19, " Audits" DECO PQAP-9600, " Auditing AE's" 10CFR50 Appendix B, Criterion XVIII, " Audits" Reference Documents Project 0A Audit Files for AE Audits Extent leoleted Extenelve X Other (Specify)

This finding applies to all engineering services suppliers O

Detroit Edison Company; 83021 7*6-14 Independent Design Verification Program

n M

A f. M T a Potential Finding I lillllllllllilillillllllillll!

U) Report PFR No. 03 Revision No. 0 Observation No. DC-01-10 sheet 2 of 4 Design impact Design may be impacted if there is inadequate assurance that the design control program was being effectively implemented.

~

Potential Safety impact A. The combined auditing activities by DECO, S&L and S&W provide adequate assurance that the design control programs implemented by both S&L and S&W have been adequately and effectively implemented.

B. A further review of all Engineering Service suppliers utilized on the EF-2 Project disclosed that DECO performed the necessary audits to assure the effective implementations of each respective design control program. These service suppliers included: NUS, Giffels Associates, Nutech, Teledyne, Hopper &

Associates, Bechtel, Multiple Dynamics Corporation anci Parsons.

Therefore, based upon the above, no impact on plant safety exists and this PFR l is considered closed.

l i Originat y Cogn t Gr Leader Date Jw / M &h3 Approved By Project Eqgine,er Date "teol Tu111% +hs/as Detroit Edison Comp M ; 83021 Independent Design Verification Program 7.6-15

Potential A M' 6 Finding mmm""""'""""""

Report PFR No. 03 Revision No. 1 Observation No. DC-01-10 Sheet 3 of 4 11 Senior Review Yes No Further Review Required X Valid Observation X Potential Safety impact X Comments Senior Review Team concurs with the above approach and consideres this PFR closed.

Cygna was also able to canfirm that, in addition to the scheduled audits of Stone &

Webster and Sargent & Lundy for the Fermi-2 project, the Detroit Edison QA organization also acted as an observer of internal audits conducted by the quality assurance departments of the A/E's themselves. In addition to affording an oppor- '

tunity to evaluate the adequacy of their internal audit function, this provided Detroit Edison QA an opportunity to directly assess the degree of compliance of the activity being audited with the A/E's program commitments. Additional involvement by Edison Quality Assurance was achieved by review of A/E (including Stone & Webster

'f and Sargent & Lundy) internal audit reports.

%d I

- ex- ////o/73 Approved BYCognizant Sdor Reviewer D'a t e lli Project Manager Comments Concurs with the conclusions of the Senior Review Team.

I V Approved By Project Manager Date kia 0.k uMea Detroit Edison Company;" 83021 7*6-16 Independent Design Verification Program

__~-_..____ _ __ ._____ _ _ _ _ _ _ . . . _ _ _ _ _ , _ _ _ _ _ _ _ _ _

Sheet 4 of 4 Rev. O POTENTIAL FINDING REPORT N0. 03 ATTACHMENT A review of the DECO audits of architect engineers (AE's) disclosed the following:

1. . Due to the AE audit frequency, it is questionable whether continuous design control program implementation could have been verified. The audits performed and reviewed since December,1974 are as follows:

Sargent & Lundy Stone & Webster December, 1974

- - - - - - - - - - - - - - - Wo r k St op p a g e - - - - - - - - - - - - - -

May, 1977 (start work,1978)

March, 1979 July, 1978 June, 1981 February, 1981 March, 1982 June, 1981

2. For those audits identified above, audit checklists were found to be either missing or, if available, inadequate for assuring that all the

[D kl applicable portions of the AE design control programs were being effectively implemented O

\

Detroit Edison Company; 83021 7.6-17 L7 l .1 L f il Independent Design Verification Program ll111111111111111111llllll1111

Potential

[41 &'TJ Finding Report PFR No. '04 Revision No. 1 Observation No. sheet 1 of 4 EQ-01-03 1 Description The W. Powell Co. Stress Reports for Class 1 valves contain an error in the calculation to exclude the stress reversal cycles due to seismic loads from the l cyclic loading evaluation. The standard calculation pressure, P , was 3 used instead of the design pressure Pd*

Requirement e ASME P&PV Code Sect. III 1971, Winter '71 Addendum Paragraph NB-3652(a) states:

'in satisfying the cyclic loading requirements, the following variations need not be considered:

(a) Cycles with pressure variations less than Pd /3 for carbon and low alloy steels...'

Reference Documents Design Analysis Report for 24" 900# OSY Gate Valve, Figure 19023 W.E., Parts List

1. 64051, Rev. 3, 8/26/82, page 32, Wm. Powell Company.

Extent teoleted Extenelve X other (specify)

This finding applies to Wm. Powell Co. Class 1 valve design reports.

Detroit Edison Company; 83021 Independent Design Verification Program 7.6-18

Potential L41 6'Td Finding O Report PFR No. 04 Revision No. j Observation No. Sheet 2 of EQ-01-03 4 Design impact If the requirements of code paragraph NB-3552(a) are not met, then the stress reversal cycles must be included in the cyclic loading evaluation. This could result in lcrger design stresses for the valve.

Potential Safety impact See Attachment (sheet 4 of 4).

1 I

l i

Date Originated By Cognizant Group Approved By Project Engineer on Leader $ ? nIwles Date fha II//o/6.5 Detroit Edison Company; 83021 7.6-19 Independent Design Verification Program

Potential Ani Finding p'""'""""""""'"""' Report

'd PFR No. 04 Revision No. 1 Observation No. EQ-01-03 Sheet 3 of 4

!! Senior Review Yes No Further Review Required X Valid Observation X Potential Safety impact X ,

Comments Agree with the Project Team conclusion that this potential finding can be closed based on the commitments contained in the attached management directives.

Implementation of Project Directive EF2-62,816 will also ensure that the t.asure act:vities will be properly tracked and performed.

(

l

//ffOf8.9 Approved B'y Cognizant Sklor Reviewer bate til Project Manager Comments Concur with Senior Review Team comments.

i Approv i By Project M ager D e

$- & ll ll Detroit Edison Company; 83021 7.6-20 Independent Design Verification Program

. _ _ _ . .. . ~ _ _ _ _. _ _ _ _ , _ _ . - _ _ . . . - . . _ . _ _ _ . _ . _ _ _ _ _ . . . . _ . _ , , . _ _ _ _ _ _ . . _ _ - - - . _ _ . _ . . _ _ - - . _ _ , _ .

Sh:et 4 of 4 Rav. 1 p P0TENTIAL FINDING REPORT NO. 04 V ATTACHMENT It should be emphasized that ASME Section NB-3552(a) specifies procedures for determining whether or not fatigue effects need to be considered in design.

One of the items this determination is based on is the number of stress reversal cycles occurring at pressure levels greater than 1/3 of the design presssure. It should also be noted that seismic loadings are not normally a significant consideration in valve fatigue evaluations. This is especially true in the case of Fermi-2 where the earthquake loadings are of a relatively small magnitude.

In order to fully evaluate the significance of using the standard calculation pressure, Ps , instead of the design pressure, P d, two items were considered:

• The design pressure, Pd , was used rather than the standard calculation pressure P3.

e Actual valve accelerations from the seismic analysis were used rather than the generic acceleration originally specified by Powell.

This review showed that the recalculated equivalent pressures were less than the Code requirements ofdP /3. Consequently, this potential finding has no

(,)

v impact on the design or safety of Wm. Powell Co. Class 1 valves used for Fermi-2.

For safety related valves other than those provided by Wm. Powell Co., DECO management has issued a project directive (EF2-63,587 dated April 13,1983) which states that the requirements of NB-3552(a) shall be addressed during a third party review process. Third party reviews for safety related equipment are specified in project directive EF2-58,964 dated May 17, 1982. Both of the referenced project directives are attached. Implementation of these directives will ensure that this potential finding has no significant impact on plant safety.

l 1

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Detroit Edison Company; 83021 did 2 Id Independent Design Verification Program 7.6-21 111111llll111llllllllltlllllll l

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~ Detroit

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\/ ENRICO FERMI U:1IT 2 PROJECT ENGINEERING April 13, 1983 EF2-63,587 To: J.W. Nualey Director-Project Design i

From: R.A. Vance h .k .\/ W Asst. Project Mgr., Engineering

Reference:

1. EF2-58,964 dated May 17, 1982

2. Memo, Y.N. Anand to File dated May 12, 1982

Subject:

Project Engineering Open Items It has come to my attention that certain engineering commitments require clarification and emphasis in the area of flued heads and seismic analysis of valves. Accordingly, please insure'the fol-

. N-[~-) lowing items are resolved by fuel load:

1. Flued Heads Perform an as-built analysis on the flued heads and flued head anchor structures. The flued heads shall be analyzed in accordance with the ASME code. The flued head anchor structures shall be re-evaluated for load combinations se-1ected by documented engineering judgement that will result in the most severe condition for the various parts of the structure. Due to the large number of combinations possible

• by considering all of the reversing seismic loads, a complete

- set of load combination analyses is impractical.

In general, the following guidelines shall be followed: s

1. Weight and thermal loads from pipe on both sides of anchor combined algebraically.

2. Seismic and water ha==er loads from pipe on both sides of structure will be combined by SRSS to account for peak loads not occurring simultaneously.

3. Selected co=binations of weight and thermal 1 reversing

(,~, )

loads will be applied to the structure at each flued head.

\- These combinations will be assembled so that various parts

~

of the structure are loaded as severely as possibic.

7.6-22

_ _ _ _ _ . - - , _ - . - _ _ , ~ . . _ - _ _ _ _

s-kao to: ' April 13, 1983 J.W. Nunley

/h Page 2 EF2-63,587

.Y) ,

o

4. The number of load cases considered will depend on the compicxity of the structure as well as the number of heads being anchored.

4 Good engineering judgement will be exercised and docu-mented so that the logic used to arrive at a given set and loading conditions may be reviewed.

5. Faultsd loads need be considered for only one pipe at a time. All other loads will be considered to be at emergency conditions. Each head faulted load will be so considered.

6. The structure will be evaluated for the mos,t severe of the above considering the dif ferent allowable stresses for the different loadings (emergency, faulted, etc.)

7. A more mechanistic approach may be considered as ap-propriate to reduce the conservatism.of the above ap-proach which assumes the worst of several loads occur at the same instant.

i m k_,) Please document the above in stress reports or design cales as appro-priate.

2. Seismic Analysis of Valves The Project is committed to a third party review (references 1 and 2) of all safety related equipment. For all safety rela-ted valves please make sure that the following items are ade-i quately addressed in the third party review process.

l-

. e Use or correct moment of inertia applicable to 4 legged yoke assemblies.

Additionally, make sure that in the design analysis report for t

all class I valves, the following is also properly addressed.

I e Cyclic loading check per section NB-3552 (a) or ASME Code

Section III. .

I have requested, in addition, that the above items be tracked on the Nuclear Operations Action Item List to insure their timely completion.

[

Written by:

h144 W M.G. Sigetich/0.K. Earle

!- /pa cc: T.A. Alessi, Y.N. Anand, R.W. Barr, J.H. Casiglia, W.F. Colbert, C.E. Dewandeler, L. Eix, E. Lusis , J.D. Ryan, W.M. Street , M.S. Williams, Records Center, J.E. Camilleri (EF2 Records Center - 140 NOC (Add to Action Item List) 7.6-23

T Detroit

, --e (3

)

y ENRICO FERMI ATOMIC POhER PLANT - UNIT 2 Architectural / Civil Engineering July 17, 1982 EF2 - 58,964 To: J. W. Nunley, Director Project Design From: LY{Wj gg ' ~

System 4,rajineer . e smic Design q

Subject:

Seismic Qualification Review Progrcm for Seismic Catecory II/I Equipment Enclosed ia a copy of meco dated May 12, 1982 which includes a flow chart depicting the review program basically for Seismic Category I Equipment.

In reference to our discussion of July 14, 1982, I have revised the flow chart to include Seismic Category II/I items.

I am going to discuss with Don Schlagheck incorporating this into Project Procedures.

Should you have any questions, please call me at 7363.

yNA/jlj Enclosures .

cc: M. L. Batch 4, 7gg D. M. Hopper (Hopper & Ascoc.)

E. Lusis W. M. Street D. Schlagheck R. A. Vance A/C Divison File Document Control tp) v

'/.6-24

Deholt .

m  ;. ,. .,

a s 'w i i V)

( - -

. - . . .. .. - . . . . . . . . - - - . ~ - - - -

ENRICO FERMI ATOMIC POWER PLANT - UNIT 2 Architectural / Civil Engineering Date: May 12, 1982 To: File From: Y. N. Anand, System Engineer '"k ,

Aseismic Design

Reference:

1. Ralph M. Parsons Co. letter dated February 16, 1971.

2. EF2 - 9875 dated May 10, 1972

3. EF2 - 10,184 dated May 30, 1982

4. Ralph M. Parsons Co. letter dated September 21, 1972

5. EF2 - 29,658 dated September 19, 1974.

6. EF2 - 38,363 dated September 14, 1977.

7. EF2 - 39,210 dated December 22, 1977.

8. Memo - Cook to Colbert - February 21, 1978.

9. EF2 - 41,755 dated July 25, 1978.

10. EF2 - 41,914 dated August 22, 1978.

11. EF2 - 41,755, Rev. A dated December 11, 1979.

[~ ') 12. EF2 - 38,363, Rev. A dated January 11, 1978.

\_ / 13. EF2 - 41,606 dated June 28, 1978.

14. EF2 - 41,755 dated September 7, 1978.

15. EF2 - 47,206 dated December 4, 1979.

16. Seismic Qualification Review Program: Flow Chart.

Subject:

Seismic Qualification Review Program Our Seismic Qualification Review Program had its beginnings in 1971 l (Reference 1). Seismic qualification was initiated with the help of the Ralph M. Parsons Company. ]

i l In 1974, it was realized that our in-house personnel could be engaged to

successfully carry out the Seismic Qualification Review Program. An in-house task force of reviewers was assembled who carried out the program through 1977.

1 Then in 1977, with substantial increase in work load, seismic qualification l review work was assigned to Stone & Webster.

l l Then in 1981, with work load tapering off, the Seismic Qualification Review Program was brought back in-house again.

l

. /7 l \

' m,f i

7.6-25

G = Memorandum May 12, 1982 File ._

Page 2 t

References 2 through 15 show an evolutionary development of our Seismic Qualification Review Program, consistent with the overall needs of the project.

i Seismic qualification review procedure to be used is depicted in flow chart form: Reference 16.

YNA/jlj Enclosures i

cc: A/C Division File t

o l

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7.6-26 l

l._____.________._._.___.__________..____._--...-

. _ _ . _ _ _ - - - - - - - - - ~ ~ - .. - - -

. rurw0 1.rl. Awp ny a,w I

y.~ . .

FLOW CHART SEISMIC QUALIFICATION REVIEW PROGRAM .

i Seismic Package to  : p Vendor @ -4 i Document Control @

v o

. 2:

Responsible Engineering Group c Supervisor Assigns Technical Contact @ bl

. a

• E

. mr

. 5 .,

Technical Contact Consults System Engineer Aseismic Design @

G .

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Package Acceptable for Review To ,

3s4 E

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[ Syctem Engineer - Aseismic l

Design Assigns Review Responsibility ',

In-House SAL (Sb), (Sa)

Hopper & As cc., (Sc)

Others (Sd) -

. v

• A Prepares Review Package

@ Sends Review Package to @

3F

, @ Sends Review Co:nments to @

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DocumentControl.l Circulates l Finds Reviewe x For Approval Y'" ^ N ekage Acceptab1 v y 7.6-27 l

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. _ .. . - . . . ~ . . __. ... ... _ . , _ .

fREFAngp s 1. A. Ar(Ad9 MAf ::,1962 R v. I 1. M. A/MP Jutf 17,1?!:

FLOW CHART

[( )- SEISMIC QUALIFICATION REVIEW PROGRAM Seismic Package to '

4-Vendor e[ 4 e Document Control @

l '

. A v o as Responsible Engineering Group g Supervisor Assigns Technical Contact Q; u c

5 Technical Contact Consults i

I System Engineer Aseismic Design @ ,

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. 3  :

n v 5 .

s - filSMic CAreccM,Y II[I f0uhttiff -  % '.

Package Acceptable Fow N

Im@ fMTY Efvif14 80T EMEiflAL for Review To 3 r, 4 l I

- l ir System Engineer - Aseismic Design Assigns Review Responsibility In-House (Sa)

SAL (5b)

Hopper I, Assoc (Sc)

O.thers (5d). .-

Prepares Review Package

@ Sends Review Package to @

@ Sends Review Comments to @

1. -

t> ,

,, j Document Control 'N s Circulates Finds Revieweo N  ! I For Approval Yes - No '

b,1f l

. Potential dNJ Finding llm.. im. ma._m__il111m_fl.ll[]

Report P

a Revision wo, 1 PFR No. 05 Observation No. EQ-01-04 sheet 1 of 4 i Desctlption In the seismic evaluation of Wn. Powell Co. Class 1 valves with four-legged yokes, the gross moment of inertia is assumed for the yoke. The legs act independently when subjected to lateral (shear) loads. Thus, the yoke deflection due to these loads is underestimated.

Requirement e ASME B&PV Code Sect. III 1971, Paragraph NB-3524:

"...where valves are provided with operators having extended structures and these structures are essential to maintaining (3 pressure integrity, an analysis....may be performed based on V static forces resulting from equivalent earthquake accelerations acting at the centers of gravity of the extended masses."

Reference Documents

" Design Analysis Report for 24" 900# OSY Gate Valve, Figure 19023 W.E., Parts List

1. 64051," Rev. 3, 8/26/82, Page 34, Wm. Powell Company.

Extent isointed Exten*Ivo X other (epecity)

This finding applies to all Wm. Powell Co. Class 1 valves with four legged yoke assemblies.

Detroit Edison Company; 83021 7.6-29 Independent Design Verification Program l

l __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ __

Potential t4 (% i Finding Report

O PFR No. 05 Revision No. 1 Observation No. EQ-01-04 sheet 2 of 4 Design impact Use of an incorrect moment of inertia will cause the stresses and displacements to be incorrectly predicted. Operability and design acceptability are based on these stresses and displacements.

i Potential Safety impact See Attachment (Sheet 4 of 4).

l l

l l

l Originated By Cognizant Group Leader Date

! M.1;dh ///to/83 Approved By Project Engineer Q Date IibJADM i(bo /B1 Detroit Edison Company; 83021 7.6-30 Independent Design Verification Program

1 Potential e Lni Finding Report PFR No. 05 Revision No. 1 Obeervation No. EQ-01-04 s heet 3 of 4 l

!! Senior Review Yes No Further Review Required X Valid Observation X Potential Safety impact X Comments Agree with the Project Team conclusion that this potential finding can be closed  !

based on the commitments contained in the referenced management directives.

Implementation of Project Directive EF2-62,816 will also ensure that the closure activities will be properly tracked and performed.

J r

App oved By Cognizant S[ lor Reviewer date lil Project Manager Comments Concur with Senior Review Team comments.

Approve y Pro oct Mana r Dat h, s // // 83 Detroit Edison Company;I 83021 l#

7.6-31 l

Independent Design Verification Program t

Sh:et 4 of 4 Rav. O g POTENTIAL FINDING REPORT N0. 05 l l ATTACHMENT

% ./

This PFR applies only to valves with four-legged yoke assemblies. It is related to the Powell calculation of yoke section properties for an applied shear force.

DECO management has actively addressed this issue for all safety-related valves by issuing a project directive (EF2-63,587 dated April 13, 1983) which states that the yoke moment of inertia calculation shall be verified during a third party review process. Third party reviews are specified in project directive EF2-58,964 dated May 17, 1982.

DECO also solicited an evaluation of this issue by Hopper and Associates (HA-9/83-214, dated 8/15/83, copy attached). Based upon detailed finite element analyses, this evaluation shows that the valve operator will transfer both moments and shear forces to the yoke legs. And, it concludes that the yoke deflections can be idealized by assuming that bending moments are transmitted through gross section deformation, and shear forces are transmitted by independent action of the yoke legs.

The third party reviews will, therefore, verify that the yoke section properties are consistent with the applied loads. Based upon this evaluation and the DECO management directives, this PFR is considered to have no potential impact on plant safety.

\j .

l

(

l l

( )

~

Detroit Edison Company; 83021 7.6-32 gy [tj g [j Independent Design Verification Program lllllllll11ll111ll11ll11llllll l

(

HOPPER AND ASSOCIATES ENG'NEEHS 24% AVENDM cEL P.OntE REDONDO BE ACH. CA 90217

['g 213 -31 W 3 *,

, August 15, 1983 HA-9/B3-?14 Contract # 84895A

-Detroit Edison Com:any 3331 W. Big Beaver Road -

Troy, HI 48084

'. Attention: Y.N. Anand, Contract Administrawr

Subject:

Valve Yoke Idealization

References:

1) HA-4/83-164; Hopper and Associates Re? ort; Willian Powell Company 24"-900* OSf Ga te Valves Independent Aseismic Design Review Coments; Dated April 15, 1983.

2) HA-4/83-165; Hopper and Associr.es Rccart; Third Party Aseismic Design ?? view /'laive Formated Review Procedure; Dated .oril 20, 1983.

Gentlemen:

As per your request, we are taking this opcortunity to surnarize 1

(3 our previously established conclusion regarding the a::plicability of

y/ valve yoke leg structural idealizations for design qualification pur-poses.

Valve dynamic response properties and liniting extended operator fragility capability are frequently controlled by the yoka section.

4 This section is corronly co:rorised of a nuncer of inde:endent yoke legs, rigidly connected to an operator and to the valve body / bonnet i at the respective yoke ends, with the valve stem functioning between the yoke legs. -

, It is our position that a typical valve yoke will transmit cend-ing moments through the section by gross ycke section flexaral defor-ration, and shear forces by the independent cui:20 cantilever acticn of each yoke leg acting in combination with o e anntner, i This manual cualification load transmission Healintion ".as been verified by indeoendent finite elenent metbac conuter analysis, which i has shown that nonents acclied to a valve yoke are .rsnvittec throuch the yoke by single cantilever beam section actian, in soite of the iii-ability of the yoke section to transmit "hori catal" shear stresses and

. that shear forces are transmitted through the talve yoke ty independent guided cantilever action of each yoke leg.

The enclosed exnibit sue.arizes various manual analyses idealiza-tion results, and conoares them with a detailed finite elenent analysis.

Deformation ano frecuency comparisons exist on tnis sumary exhibit.

, Similar confirmatory results are cbserved for steepJevels.

If questions arise, please contact the une m;y.J.

p (3

1 v) Very s 1 /y -s , f

,kp /

! b cc: ike Williams vid M. Foacer Documentation Control Professional Engineer 7.6-33

Hopper and Anociate; IIA-9/83-214 9-15-83 C

4 90 - -

a.

80 - f A

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d 70 - 5 / ;- y 48' '

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! (s = W F.E.M. ANALYSIS M =

1 h 1 FREQUENC'n COMPA 9 SON 20 -

I

• I RECOMMENDED !CEALIZATION = 59 CPS

. 1 i F.E.M. AMLYSIS DEFORMATION = 63 CPS 10 -

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! . i e i i i i 100 200 300 .) 400 i, . . . . . .

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DEFLECTION - INCHES x 10 l , C' .

RELATIVE VALVE DEFORMAT10N AND FREQUENCY EXHIBIT 7.6-34 E - _ . - _ _ _ _- ._._ ._..____, . _ _ __ _

. Potential e4 (% i Finding c,m.nn .....""'""'

Report PFR No. 06 Revision No. }

Observation No. PI-03-04 sheet 1 of 3 1 Description Review of the Tube Turns design report for flued head no. X-12 revealed that the stress summary for the emergency condition compares the maximum sununed stress intensity to 3S . This maximum is the sum of the peak, non-linearized primary .

membrane, prima,ry bending and secondary stress intensities. The ASME Code requires a comparison of average primary stress to 1.2 x 1.5S, = 1.8S, and the linearized primary and secondary stress range to 3S,.

Requirement e ASME B&PV Code Secticn III 1971 through Winter 1971 Addendum, paragraph NB-3221 and NB-3224 i-

) e DECO Design Specification 3071-516, Rev. A, Appendix A, Section 2.B.20, " Primary v Containment Penetration Assemblies."

Reference Documents Tube Turns Reports No. 71143-1, Rev. O Tube Turns AUT0 HEAD computer output dated 3/12/74.

Extent isolated Extensiv* other (specify)

X This finding applies to all flued heads analyzed by Tube Turns.

Detroit Edison Company; 83021 7.6-35 Independent Design Verification Program

Potential

[.4 M'T3 Finding

(~') '""""""""'"""""" Report v

PFR No. 06 Revision No. j Observation No. pI-03-04 Sheet 2 of 3 Design impact The maximum primary membrane plus primary bending stress intensity may exceed the ASME Code allowable for emergency conditions.

O(~'N Potential Safety impact DECO has issued the attached project directive (EF2-63,587 dated April 13,1983) instructing that an ASME Code compliance analysis be performed for all flued heads as part of an as-built verification program. If a verified thermal transient solution is not used, Cygna recommends that as part of this analysis, the maximum possible thermal skin stress be considered in the evaluations of all the flued heads in place of the results from the thermal transients. This is a very conservative approach. As part of this analysis, the maximum primary membrane and primary bending stress intensity (excluding thermal stresses) should be evaluated to 1.8 S, for the emergency condition.

Cygna's review of the summaries of all of the flued heads indicates that there is sufficient margin such that there should not be any impact upon design or safety except in the case of flued heads X-13A & B which require additional evaluation for the emergency condition. This evaluation should be conducted as part of the ASME Code compliance analysis.

It should be noted that the table presented in the observation review record compares the peak non-linearized primary plus secondary summed stress intensity to an average primary stress allowable (1.8 Sm ). This is a very conservative comparison.

Originated By Cognizant Group Leader Date Approved By Project Engineer i 41\o U bO!O3 Date

/.[]}.M1Ad IlbolA3 Detroit Edison Company; 83021 7.6-36 Independent Design Verification Program

1 Potential A N ti Finding O "

• P

PFR No. 06 Revision No. 1 Observation No. Pi+03-04 Sheet 3 of 3 l

11 Sonier Review Yes No Further Review Required X Valid Observation X Pctential Safety impact X Comments Senior Review Team concurs with the above approach and considers this PFR closed.

Implementation of Project Directive EF2-62,816 will also ensure that the closure activities will be properly tracked and performed.

O h%d~

Approved By dognizant Sen[or Reviewer n/idn

'Dat e ill Project Manager Comments Concur with the Senior Review Team conclusions.

Y -

lI!!!03 Approved By Project Manager 'D a t e Detroit Edison Company; 83021 7.6-37 Independent Design Verification Program

Potential 3 (% a Finding mn##annnnnc!'"" Report

[U PFR No. Revision No, O

07 Observation No. PS-03-02 sheet 1 . of 3 1 Description Review of the analysis of the flued head anchor structure revealed that for each of the two flued heads in Anchor Structure No. 2, there are loads i FX (Axial), t FYZ (Shear), t MX (Torsion), t MYZ (Bending Moment). Calculations by Ralph M. Parsons Company consider only two (2) of the many possible load combinations without written justification for their selection.

Requirement Detroit Edison Project Design Specificiation 3071-516, Rev. A.

g Reference Documents Stress Analysis, Drywell Penetration, Anchor Structures, October 1974, the Ralph M. Parsons Co.

Extent Isolated Extensive y Other (Speelfy)

This finding applies to all penetration anchor structures analyzed by the

/] Ralph M. Parsons Co.

C' Detroit Edison Companyk 83021 7.6-38 Independent Design Verification Program

L4 L%' M Potential Finding Illilllililllilllllllillllllit (j Report PFR No. 07 Revision No. O Sheet 2 of 3 Design impact Another loading combination may produce larger member stresses and result in a potential failure in the flued head anchor structure.

D Potential Safety impact DECO has issued a Project Directive (EF2-63,587 dated April 13,1983) instructing that an as-built analysis be performed for all flued head anchor structures. As part of this analysis:

" Selected combinations of weight and thermal i reversing loads will be applied to the structure at each flued head. These combinations will be assembled so that various parts of the structure are loaded as severely as possible."

and

" Good engineering judgement will be exercised and documented so that the logic used to arrive at a given set of loading conditions may be reviewed."

Implementation of this directive will assure that the concerns of this finding will be properly addressed in the as-built review. Thus, there is no impact on safety.

Originated By Cognizant Group Leader Date

! ,, QA d ~ 4/m/s3 -

Approved By Project Enginee l(] Date I f. m 4/uhr Detroit Edison Company; 83021 Y 7.6-39 Independent Design Verification Program

Potential til n . i Finding O "*P 't PFR No. 07 Revision No. 0 ,

• l Sheet 3 of 3  !

ll Senior Review Yes No Further Review Required X Valid Observation x Potential Safety impact X Comments Senior Review Team concurs with the above approach and considers this PFR closed.

Implementation of Project Directive EF2-62,816 will also ensure that the closure activities will be properly tracked and performed.

O Approved By Cognizant Sanior Reviewer Date ,

g'f

'f c c j-111 Project Manager '

Comments Concur with the Senior Review Team comments.

O P Date Approved By klect,Manda erk 4e/n Detroit Edison Company; 83821 7.6-40 Independent Design Verification Program i

Potential At% i Finding

""""""""""""""" Report PFR No. 08 Revision No. 1 Observation No. ST-01-02 sheet 1 of 4 1 Description The ultimate load factor used for soil loading is 1.4. The ACI 318-71 code requires an ultimate load factor for soil loading of 1.7.

Requirement e Cygna Design Criteria DC-83021-4, Rev. O, sect 4.3.1 Reference Documents ACI 318-71 Sargent and Lundy Structural Design Criteria DC-SE-01-EF, Rev. 2.

Sargent and Lundy Calculation No. 1.15.10.

Extent isolated Extensive Other (Spect:y)

)(

This finding potentially applies to all buildings designed by Sargent & Lundy on Fermi 2.

Detroit Edison Company; 83021 7.6-41 Independent Design Verification Program

Potential t4F.i t i Finding lilllilllilllllillililillllIll Report Q Revlalon No.

PFR No. 08 1 Observation No. ST-01-02 Sheet 2 of 4 Dealen impact The use of a smaller load factor for soil loading could lead to an unconservative design.

1 1O Potential Safety impact See Attachment (sheet 4 of 4).

I Originated By Cognizant Group Leader . .

Date N[N Il O/d3 Approved By Project Engineer - Date

) T h]AddA4 Ilbo/83 Detroit Edison Company; 83021 Independent Design Verification Program

) 7.6-42 '

Potential AMi Finding Report PFR No. 08 Revision No. 1 Observation No. ST-01-02 Sheet 3 of 4 11 Senior Review Yes No Further Revlow Required X Valid Observation X Potential Safety impact X Comments Concur with the Project Team conclusion that there is no impact on plant safety and that further review is not warranted.

i O

_ _sms - N//o/83 Approved By Cognizant Senior [ viewer Date' Ill Project Manager Comments I Concur with the Senior Review Team conclusions.

l Approv $ By Project Manager Date l . 0- % ll El' 03 i

Detroit Edison Company; 83021 7.6-43 Independent Design Verification Program

Sheet 4 of 4 Rev. 0

, POTENTIAL FINDING REPORT N0. 08 Q ATTACHMENT The following logic was provided by Detroit Edison to explain the use of the 1.4 load factor:

The design criteria for the RHR complex contains three pressure diagrams for the design of subgrade walls; an end-of-construction condition, an after-earthquake condition, and an earthquake condition.

The present governing design basis pressure is 1.4 (2.47 + 1.75) = 5.9 for the after-earthquake condition using a 1.4 load factor for both the soil pressure of 2.47 and the hydrostatic pressure of 1.75 ksf. This pressure is higher than the end of construction condition of 1.7 x 1.85 + 1.4 x 1.75 = 5.6, where 1.85 is soil pressure and 1.75 is hydrostatic pressure. It is also higher than the earthquake condition of 0.75 [1.7 x (2.39 + 0.35) + 1.4 x' 1.75] = 5.33, where 2.39 is the static earth pressure, and 0.35 is the dynamic water pressure increment.

The present design basis pressure includes a conservative seismically consolidated soil pressure of 2.47 which takes into account the residual effects of earthquake. For this condition, a less conservative load factor of 1.4 for soil was considered proper.

g .s The conclusion reached by Detroit Edison is that the design method used is

( adequate. Cygna has reviewed the above and agrees with this conclusion.

Furthermore, Cygna has reviewed the calculations for the following structures and confirmed that a 1.7 load factor was used: ,

e RHR iiat Foundation (Book #4.1) e Reactor / Auxiliary Building Substructure (Book #3.08.00) e Reactor Building Mat Foundation Review for SRV Loads (Book #SF-0002)

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v 7,.

Detroit Edison Company; 83021

(=3[g3_y=j iTil Independent Design Verification Program 7 6-44 1111llll11llll1111ll111lll1111

Potential M%A Finding lHililllilllllillllll((llllli PFR No. 09 Revision No. O Observation No. DC-02-07 sheet 1 ' 3 1 Description Design change documents have not been initiated due to component modification requirements resulting from stress analyses.

For example, in Obsertation PI-02-06, Cygna has noted that the pipe stress analysis specifies the use of lubrite plates for stanchions, but these are not shown in the as-built support drawings. In Observation PI-02-04, Cygna has noted a two-way restraint in the as-built drawing which the pipe stress analysis has changed to a one-way restraint.

Requirement 10CFR50 Appendix B, Criterion III, " Design Control" Sargent & Lundy Engineers EF-2 Project Instructions PI-EF-7, " Scope,

,_s Responsibilities and Authority of S&L Site Liaison Engineers," paragraph 3.2,

( ) requires, in part, that Design Change Notices (DCN's) be generated when requested by

'V Chicago Engineers.

Reference Documents Pipe Stress Report SX-14, "RHR Service Water Return Division II, RHR Complex Subsystem," pages 15 and 16, notes h, i, j, k and 1 l  ;

Extent Extenelve Other (Specify)

Isolated y

.V This finding potentially applies to all piping systems analyzed by Sargent and Lundy engineering.

Detroit Edison Company; 83021 7.6-45 Independent Design Verification Program

Potential m

Af% Td lillllllllllllllllilllililllll Finding CJ s Report PFR No. 09 Revision No. O Sheet 2 of 3 Design impact Design may be impacted if EF-2 plant piping is not reconciled with the stress analyses.

I Potential Safety impact l Further review disclosed that DECO Project Engineering Work Instruction, PDM 1.1, Rev. 1, "As-built Reconciliation of Piping Stress Reports," requires the DECO Mechanical Group to institute measures to assure that the as-built piping is reconciled with pipe stress reports, including those generated by Sargent and Lundy.

l I

l' l

l Originat gniza rou Date

/h/ -l $ W Approved By Project Engineej Date dl2S/A L Detroit Edison CcmpanM 83021 7.6-46 Independent Design Verification Program i

L

Potential A l % -i Finding Report Q

PFR No. 09 Revision No. O Sheet 3 of 3 ll . Senior Review -

Yes No Further Review Required X Valid Observation X Potential Safety impact X Comments The Senior Review Team agrees with the above approach and considers this PFR closed.

O

/

Approved By Cognizant Senior Reviewer p, g__ Date b

f } (L c <-l~~ c Ill Project Manager Comments Concurs with the conclusions of the Senior Review Team.

Approved By Pr ct Manager Date

f. fhg3 '

Detroit Edison Company; 83021 7.6-47 Independent Design Verification Program

Potential A%A Finding ,

111lll111ll1lll1111ll111111111 Report

\

PFR No. Rnision No. g 10 Observation No. sheet 1 of ST-01-33 3 1 Description Design calculations for shear walls analyzed as deep beams in the RHR Complex were based on a misinterpretation of Sargent & Lundy's SLSAP computer output. Output membrane shear stresses (force per unit area) for Element Type 6 - Plate and Shell Elements were misinterpreted as membrane shear forces (force per unit length).

Elements with more than a unit thickness will yield unconservative results. Results will be incorrect by a factor equal to the thickness of the plate element.

Requirement N/A.

Reference Documents Sargent & Lundy Calculation No.1.20.9 Sargent & Lundy Computer Program SLSAP User's Manual,

. Program # 09.7.130-6.6 E xtent isolated Extensive y Other (Specify)

This finding applies to Sargent and Lundy design of elements on Fermi 2.

Detroit Edison Company; 83021 7.6-48 Independent Design Verification Program

EHPappipiiEEE55iig namenspe= Potenteial L4 L%' TJT Finding 1111ll11111111111111111!!!!!!I (mj Report PFR No. 10 Revision No. O Sheet 2 of 3 Design impact Misinterpreting membrane shear stresses as membrane shear forces in the SLSAP computer analysis of shear walls could lead to an unconservative design of the RHR complex structure.

D (V

Potential Safety impact Sargent & Lundy performed a review of Fermi calculations to determine where SLSAP plate element output could have been misinterpreted. A total of 42 calculations using SLSAP were identified (RHR Complex = 5, Reactor / Aux. Bldg. = 37). Of the 42 calculations identified, 5 used the membrane stress output incorrectly. All 5 calculations were for shear walls analyzed as deep beams. Two of the five (RHR Complex = 1, Reactor Bldg. = 1) walls required a refined analysis. This refined analysis indicated that both walls were still adequate. The remaining 3 deep beam calculations in the RHR Complex were revised to indicate that the effect of using the correct shear stresses was minimal.

Of the 42 calculations, 22 interpreted membrane stress output correctly. The remaining 15 calculations did not use membrane stress output.

The Cygna Review Team randomly selected 15 of the 42 calculations to verify Sargent

& Lundy's findings. Since the Review Team's results were consistent with Sargent &

Lundy's, it can be concluded that there is no design or safety impact on Fermi 2.

Therefore, this potential finding can be closed.

I Originated By C gnizant Group Leader Date (g , & b l ). Approved By Project Engineer Date TNTIA kbY8h l Detroit Edison CompanyY 83021 7.6-49 l Independent Design Verification Program

Potential M f. % i Finding Report PFR No. 10 Revision No. O Sheet 3 of 3 ll Senior Review Yes No Further Revlow Required X Valid Observation X Potential Safety impact X Comments Senior Review Team concurs with the above approach and considers this PFR closed.

l Approved By Cognizant Senior Reviewer / j

/' ' "), {! J, Date l jl6f[3 l } .'c y-'

lli Project Manager

/

( Comments I

i Concur with the Senior Review Team Conclusions.

r Date faw Approved By Project Mana 4 des Detroit Edison Company; 83021 7.6-50 Independent Design Verification Program

O SECTION 7.7 OBSERVATION RECORD REVIEWS (Revised)

O r etroit Edison Company 7.7-1 La [d g'friFermi 2 Independent Design Verification lililllilllillllllilillllllllIFinal Report TR-03021-1; Rev. 0

73 08SERVATI0ft SU10ERY b

Observation Reference Number Observation Description Page DC-01-01 A review of contract documents issued to Sargent & 7.7-22 Lundy (Contract No.1C-80002) and Stone & Webster Engineering Corporation (Contract No.1A-84503) failed to impose the requirements of 10 CFR 50 Appendix B.

DC-01-02 The Enrico Fermi 2 Design Control Program utilized 7.7-23 ,

prior to April 28, 1981 did not address the perfor-mance of design verification.

DC-01-03 The Enrico Fermi 2 Design Control Program fails to 7.7-25 address requirements for certifying (validating) or specifying computer codes used on project.

0C-01-04 The current and earlier revisions of the Detroit 7.7-28 Edison Enrico Fermi 2 Project Procedure Manuals are found to be silent with respect to addressing the following requirements:

O a. Design verifying or checking should consist of, as a minimum, reviewing the design, spot checking the calculations or analysis, and assessing the results against the original design bases and functional requirements,

b. Identifying the particular design verification methods utilized,

c. Regardless of the degree of standardization or similarity to previcusly proven designs, the applicability of standardized or previously proven designs with respect to meeting pertinent

! design requirements shall be verified for each l

application.

d. In those cases where the adequacy of design is to be verified by tests, the testing shall be identi fied.

/\

Detroit Edison Company 7.7-2 g {t"jl f j Fermi 2 Independent Design Verification I:::.;;;, ...;;iiililli Final Report TR-83021-1; Rev. 0

, OBSERVATION SUM 4ARY V

Observation Reference Number Observation Description Page 4

DC-01-04 e. Testing shall demonstrate adequacy of perfor- 7.7-28 (continued) mance under the most adverse conditions when performed as a design verification and should consider operating modes and environmental conditions in which the item must perform.

f. If testing indicates that modifications to the item are necessary to obtain acceptable perfor-mance, the item shall be modified and re-tested as necessary to assure satisfactory perfor-mances.

g. Performing design verification prior to fuel load.

DC-01-05 Project Procedures Manual (PPM) procedure 3.2, 7.7-30

" Design Calculations"; 3.13 " Design / Detail Drawings"; 3.27, " Project Specifications";

[] 3.28 " Design Specifications" do not contain require-ss ments for assigning respective documents with a QA Level I, II, III, or commercial grade designation.

DC-01-06 A design specification was revised but not processed 7.7-31 (reviewed / approved) in the same manner as the original design specification in that Design Specification 3071-517, Rev. B, was lacking a P.E.

certification.

! 0C-01-07 Specifications identified on the " Project 7.7-32 Specification Number Recor d" as " Cancelled" were not l

available from the Troy Records Center and therefore l could not be reviewed to determine procedural com-

! pliance.

l l DC-01-08 A review of Project QA Engineering Audit Files 7.7-33 l disclosed that the audit system in place since 1971 l was not adequate te assess the effectiveness of the design control program. This is substantiated by the following:

1 1 ~J Detroit Edison Company 7.7-3

! [eh'(pl ?

11!!b$""$lllllly Fermi ll111ll Final 2 TR-83021-1; Report Independent Rev.Design O Verification

,q

, OBSERVATION SUMARY U

Observation Reference Number Observation Description Page DC-01-08 a. Audit planning was not instituted to assure that 7.7-33 (continued) all aspects of the quality program implemented by Project Engineering was audited. A review of the fifteen audits performed of project engineering disclosed that approximately thirty five procedures (PPM's) applicable to-engineering design activities had not been audited,

b. Objective evidence for at least seven audits was not available indicating that either checklists or procedures were used as a basis for auditing,

c. Objective evidence could not be found indicating that an assessment of program effectiveness was accomplished in any of the audits performed.

DC-01-09 Responsible management is not always reviewing audit 7.7-34 f') results and performing the necessary actions to d correct reported deficiencies. Out of eighty five audit findings issued since October, 1976, seventeen have not been resolved, fifteen of which were identified prior to June,1979 l A further review of twenty six surveillance report findings issued during the period of July,1981, j through July, l'?82, disclosed that seventeen have not been resolved.

l It should also be noted that objective evidence was l not available indicating that the QA Manager was l

reporting quarterly the status and adequacy of the 0A program to the Senior Management Committee.

! DC-01-10 A review of the DECO audits of architect engineers 7.7-35 (AE's) disclosed the following:

a. Due to the AE audit frequency, it is question-able whether continuous design control program implementation could have been verified. The

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Detroit Edison Company 7.7-4

[4(tj { fj Fermi 2 Independent Design Verification ,.

l  ;;,,,$$!!!!!!Illllllll111 Final Report TR-83021-1; Rev. O

4 l

I

,, OBSERVATION

SUMMARY

Observation Reference Number Observation Description Page DC-01-10 audits performed and reviewed since December, 7.7-35 (continued) 1974, are as follows:

Sargent & Lundy Stone & Webster December, 1974

- - - - - - - Work Stoppage - - - - - - - -

May, 1977 (start work, 1978)

March, 1979 July, 1978 June, 1981 February, 1981 March, 1982 June, 1981

b. For those audits identified above, audit check-lists were found to be either missing or, if available, inadequate for assuring that all the applicable portions of the AE design control programs were being effectively implemented.

The Mechanical Design Document Package (DDP) for the 7.7-36 DC-01-11

('

x RHR system has not been updated since October 30,

'1976.

0C-01-12 Evidence could not be found indicating that 7.7-37 personnel who performed audits of project engineering or engineering service suppliers were certified per the requirements of P0AP 9.112,

" Qualification and Certification of P0A Audit Personnel."

DC-02-01 The Seismic Analysis Report (SL-3147, Rev. 1 and 7.7-38 Rev. 2) for the RHR Complex did not reference the following computer programs:

a. DYNAS 09.7.090-9.0 (applicable to Rev. 1 of the report)

b. DYNAS 09.7,090-9.4 (applicable to Rev. 2 of the report)

c. RSG 09.7,050-5.4 (applicable to Rev. 2 of the

-report)

O Detroit Edison Company 7.7-5

, e [4'(p!l fj Fermi 2. Independent Design Verification lilllillikillllililllllillij Final, Report TR-83021-1; Rev. 0

/

OBSERVATION SUM 4ARY t )

v Observation Reference Number Observation Description Page 4

DC-02-02 The specific versions of computer programs used on 7.7-39 the EF-2 project were not specified to project personnel utilizing such programs (i.e., more than one version was available at any one time).

DC-02-03 A review of computer programs developed and utilized

~

7.7-40 by S&L on the EF-2 project disclosed the following:

a. Computer Program INDIA

1. User input instructions were missing.

2. Objective evidence of program validation calculations could not be found,

b. Computer Program SSANA

1. Evidence could not be found indicating that

N version 1.0 was validated.

2. The users manual for version 2.0 was h ' $- missing.

(. c. Computer Program TEMC0 III

1. Objective evidence of program validation

,Y

' ,g calculations could not be found for program versions 3.0 through 3.3.

3

2. The users manual for version 3.2 was missing.

A. ,'

D

d. Objective evidence was not available indicating validation of computer program DYNAS, version N 09.7.090-4.0

. 0C-02-04 The Sargent & Lundy Mechanical and Electrical 7.7-41 departments have not performed system design reviews

't sii to date. Both departments, however, have recently 1 been directed to comence such reviews, pw q M ,..-

N; p

+\A, Detroit Edison Company 7.7-6

[4/ iH ' fgl iFermi 2 Independent Design Verification y, ll111kll1Illllllll1111111ll Final Report TR-83021-1; Rev. 0

,- _ _ . y , , , --. -~y. _,__ ~ r ,,.--- _ -.,-,. -, y_-~___-,-,--.-.,....,r-- - . - - - , _ _ _

OBSERVATION SQMARY (V

Observation Reference Number Observation Description Page DC-02-05 A review of Sargent & Lundy Mechanical Department 7.7-42 pipe support calculations disclosed the following:

a. Several pages of the calculations reviewed were found to be illegible,

b. Several calculation pages were lacking the calculation number, calculation revision number, project number, and identification of safety category.

c. All calculations reviewed were lacking specific identification of calculation sources of data, sources of formulae and references and assumptions,

d. The support load summary sheets (computer summaries) were taken from superseded pipe P;

'n,'

stress analyses. The summaries were dated 11/15/82, whereas the current stress analysis (SX-14) output is dated 12/2/82.

DC-02-06 A review of the Sargent & Lundy Engineers QA audit 7.7-43 files disclosed that certain elements of the EF-2 design control program were not audited on an annual basis as follows:

Procedure Years not Audited G0-3.01 1982 GO-3.10 Prior to 1982 GQ-3.14 1977-1980 ,

PI-EF-1 1977 PI-EF-5 1979 MAS-4 Never MAS-16 Prior to 1982 MAS-20 1979-1982 MAS-EMD-2 1981 SAS-2 1982 SAS-7 Prior to 1982 SAS-28 Prior to 1980

/~'T Detroit Edison Company 7.7-7 f

15le liH ' fy Fermi l15111illitilllilllilllll Final2Report Independent Design TR-83021-1; Rev. 0 Verification

,.3 OBSERVATION SUf94ARY~

V Observation Reference Number. Observation Description Page DC-02-06 Procedure Years not Audited 7.7-43 (continued) GDS-5.1.1 1980, 1981 and prior to 1978 GDS-5.1.4 Prior to 1982 GDS-5.3.1' 1979 and prior to 1977 00-02-07 Design change documents have not been initiated due 7.7-44 to component modification requirements resulting from stress analyses.

00-02-08 A review to determine whether the Sargent & Lundy 7.7-45 (S&L) EF-2 project properly cor. trolled DECO corres-pondence requiring S&L actions disclosed the following conditions upon request of nine corres-pondence letters predetermined to require actions:

a. Three correspondence letters (EF-2 corres-('} pondence) issued to S&L could not be retrieved V and no evidence exists indicating that actions (PAL's) were assigned (EF2-37,199; 33,815; and 38,067).

b. Two correspondence letters issued to S&L were properly retrieved but action items had not been assigned (EF2-34,453 and 35,717).

DC-02-09 A review to determine the Sargent 8 Lundy (S&L) EF-2 7.7-46 project control of design interface documents trans-mitted from DECO disclosed that of thirty-three EF-2 correspondence addressed to S&L, ten could not be retrieved from the S&L project files. These are:

EF2-43,134 EF2-35,713 EF2-51,638 EF2-43,050 EF2-29,522 EF2-32,884 EF2-17,870 EF2-44,093 EF2-34,273 EF2-33,284

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! _ Detroit Edison Company 7.7-8 l ,ce ! M . ry Fermi 2 Independent Design Verification i

j IIllikill5lIlllillll$lillll Final Report TR-83021-1; Rev. 0

l l

,e3 OBSERVATION SUMARY A)  :

Observation .

Reference Number Observation Description Page DC-02-10 Certain pipe support conditions noted in As-Built 7.7-47 Stress Reports were not reported to the As-Built Walkdown Team for verification.

DC-03-01 On drawings originated by others (i.e., R. Parsons 7.7-48 Company, Concourse Engineering Company) and revised by Stone & Webster, the Responsible Engineer's signature was missing from the approval block.

DC-03-02 Stone & Webster does not request receipt acknowl- 7.7-49 edgement for drawings transmitted to DECO.

00-03-03 Seismic report M-109 was found unacceptable by Stone 7.7-50

& Webster (S&W) and returned to DECO for resolution of comments. DECO did not provide resolution of comments through a resubmittal to S&W.

DC-03-04 Dispositioned DCN's returned by DECO to S&W are not 7.7-51 O

\~ /'

attached / filed with the transmittal used to send the original DCN's for disposition.

PI-01-01 The 45' elbows at data points 573 and 579 are 7.7-52 modelled as short radius elbows with a straight piece of pipe between data points 571F and 573N.

The as-built drawing indicates that the elbows are long radius with no straight section of pipe between 571F and 573N.

PI-01-02 The orientation of restraints SB10 and G16 differ 7.7-53 significantly from the as-built drawings.

1. SB10 is modeled with the line of action -10 from the +X axis. Drawing 1801000472 indicates

-43 from the +X axis.

Detroit Edison Company 7.7-9 f 4 f H ? f j Fermi 2 Independent Design Verification IIlllillllilillillillillilill Final Report TR-83021-1; Rev. O

,s OBSERVATION SUf64ARY V

Observation Reference Number Observation Description Page PI-01-02 2. G16 is modeled with the structural attachment 7.7-53 (continued) point 7 1/4" below the pipe attachment point.

Drawing E11-2299-G16 indicates the structural attachment point is 7 1/4" above the pipe attachment point. This results in a change in support angle of 10 .

PI-01-03 There is no assurance in the seismic analyses that a 7.7-55 sufficient percentage of the mass is included in the analysis.

PI-01-04 The input stiffness valves at snubber node points 7.7-56 does not consider the stiffness of the supporting frame. Only the snubber stiffness itself is included in the analysis.

PI-01-05 The weight of the valve bodies are input incorectly 7.7-57 in the Modal Extraction Analysis, v

Valve Valve Body Weight INPUT ACTUAL V8-2090 9550 LBS. 8810 LBS.

(JT.510)

V8-2901 10380 LBS. 8810 LBS.

(JT.522)

V8-3407 10380 LBS. 8810 LBS.

(JT.566)

PI-01-06 The stress indices for a branch connection were not 7.7-58 input at joints 550 and 588 in the computer analysis.

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M Detroit Edison Company 7.7-10

[iid l fj Fermi 2 Independent Design Verification lilllilllllillllllillllllilli Final Report TR-83021-1; Rev. O i

,q OBSERVATION SUPMARY V)

I Observation Reference

. Number Observation Description Page PI-01-07 There is no indication that the AT1 , AT2, and Ta/Tb 7.7-59 calculated by General Electric's ANSI-7 computer program produce the largest stress in Equations 10 and 14 from the ASME Code, Paragraph NB-3653.

PI-01-08 The effect of thicker sections (such as the crotch 7.7-62 region of a tee) on axial thermal gradient (Ta/Tb )

has not been calculated.

PI-01-09 In the ANSI-7 Computer Output for Joint 502, the 7.7-63 following conditions were found:

a) The " bending + torsion" stress for emergency conditions was given as 2841 psi but was not calculated from the "WT + SSEI" loads which would have resulted in a stress of 2471 psi.

b) The stress for Equation 13 for Load Set (19-23)

O V

is reported as 16750 psi. Using the procedure specified in the ASME Code, Paragraph NB-3653.6(b), the result is 15608 psi.

PI-01-10 The shear lug load input to the ANSI 7 (Joint 527) 7.7-64 run is 8855 lbs. The correct load is 11041 lbs.,

which is used in the deadweight (PISYS) computer analysis.

PI-01-11 There is no documentation that faulted loads were 7.7-65 considered.

PI-01-12 In the seismic anchor movement (SAM) analysis, only 7.7-66 the movements at the reactor pressure nozzles and flued head were considered. No movements were input at any intermediate restraint locations.

PI-02-01 The 1 1/2" branch which connects to valve V8-4112 is 7.7-67 modeled at a point 5.92 ft. from the as-built location.

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7.7-11 l f]DetroitEdisonCompany Fermi 2 Independent Design Verification I4'i[illbilllllFinal Report TR-83021-1; Rev. 0 IIlll51llIlllilll l

n OBSERVATION SUpetARY N]

Observation Reference Number Observation Description Page PI-02-02 Mass participation for the seismic modal analyses is 7.7-68 76%, 57%, and 63% in the X, Y, and Z directions, respectively. In addition, there is no static calculation to account for this missing mass.

PI-02-03 In the seismic anchor movement (SAM) analysis, only 7.7-69 movements at the two fully restrained penetrations (i.e., 3 translational and 3 rotational directions) were considered. No movements were input at the other restraint points.

PI-02-04 Restraint No. G01 was input at data point 170 as an 7.7-70 "X" restraint. The support drawing indicates that this restraint acts in both the "X" and "Z" directions.

PI-02-05 The 24" elbow at data points 140, 145, and 147 was 7.7-71 modeled as a long radius elbow. The as-built 9

(V drawing shows this fitting to be a short radius elbow.

PI-02-06 The . local stress calculations for stanchions acting 7.7-72 as vertical supports do not consider any bending loads due to friction between the plate welded to the stanchion and the embed. The latest revisions of the support drawings do not indicate any use of lubrite plates.

PI-03-01 The AUT0 HEAD computer program manual does not 7.7-73 provide a verification of the thermal transient analysis solution. Only the steady state analysis l- is verified.

PI-03-02 a. The axial and shear forces from the inboard 7.7-74 process pipe are not applied.

b. The above forces act in the same direction as the containment pressure load. This was not included per Assumption No. 3 (load combinations) of the report which states that

-(

l ( I Detroit Edison Company 7.7-12

_ Fermi 2 Independent Design Verification

A [tj [ f y Final Report TR-83021-1; Rev. O lllllll1lllllllllll111llllll11 i

OBSERVATION SupMARY v'

Observation Reference Number Observation Description Page PI-03-02 "the containment pressure force was not included 7.7-74 (continued) because it acts opposite the direction of the inboard axial force." For the faulted condition this pressure force is significantly larger than the pipe loads applied (>30 kips).

PI-03-03 The emergency load combinations use a multiplication 7.7-75 factor of 0.91 to scale the outboard bending moment for the normal / upset condition. The design specifi-cation indicates that the appropriate factor should be 28.3/24.3 = 1.16.

PI-03-04 The stress summary for the emergency condition 7.7-76 compares with maximum stress intensity (which included thermal stresses) to 3 Sm .

The ASME Code requires that the maximum primary membrane + primary bending stress intensity (excluding thermal stresses) be evaluated to

(]

v 1.2 x 1.5 Sm = 1.8 Sm.

PI-03-05 The time of maximum thermal transient stress is 7.7-77 determined by the temperature state corresponding to the maximum thermal gradient between any two adjacent nodes. This is usually an area and time of peak stress and as such the combined stresses in other areas of the flued head where the pressure plus pipe-load stresses are high will be under-estimated.

PI-03-06 The combination of pressure plus pipeloads plus 7.7-78 seismic plus thermal transient has not been con-sidered for either:

a. Primary plus secondary stress intensity ranges for normal / upset conditions, or

b. Fatigue analysis.

(#

Detroit Edison Company N Fermi 2 Independent Design Verification 7.7-13 g M l M Final Report TR-83021-1; Rev. 0 I

llllllllll1111111llll11111ll11

/3 t 1 OBSERVATION SUMARY

.' J Observation Reference Number Observation Description Page E0-01-01 The Class 1 gate valve design report (Reference 3.1) 7.7-79 does not consider the shear stress in the thrust ring (which is a pressure retaining component) due to pressure and thrust loads.

EQ-01-02 Page 28A (sheet 5 of 5) of the Class 1 gate valve 7.7-80 design report (Reference 3.1) shows that the axial cyclic stress (SNC) exceeds the 3S m allowable for the 575 F load case. While this load case was run at the client's request (page 22 of the rport) and is not required by the ASME Code, there is no dis-cussion of this in the design report.

EQ-01-03 The calculation to exclude the stress reversal 7.7-81 cycles from the cyclic loading evaluation per Code Paragraph NB-3552(a) used an incorrect pressure of -

2425 psi. The correct pressure to use in this (3 calculation is Pd = 1250 psi.

(

'" ) 7.7-82 EO-01-04 The calculation of the yoke arm moment of inertia assumes a shear transfer between the four legs of the yoke. . The more appropriate approach would be to assume each of the legs acts independently.

PS-00-01 Stone & Webster pipe support criteria specify 7.7-83 maximum deflection 6 = 1/16" in the restrained direction. This is inconsistent with the assumption made in the piping analysis that supports are relatively rigid (having a stiffness equal to the calculated snubber or strut stiffness) and will not amplify the building motion.

PS-00-02 The thermal movements used in the spring hanger 7.7-85 calculations are consistently taken from the same load case. Those used in snubber setting calcu- ,

lation are from either of two thermal cases, some-times carrying the note that the maximum thermal movement was used. Therefore, the maximum movement may not have been used in checking the working range of spring hangers.

C\

= -~- Detroit Edison Company 7.7-14 I

rw i.g 3, w Fermi 2 Independent Design Verification L"a 'iifAl Final Report TR-83021-1; Rev. O llllllll1hlll111111111llll111

--- - - , , - , - , , , - , . - - ~ . - , , , , . , , ,,,.

OBSERVATION St#94ARY 79)

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Observation Reference Number Obseivation Description Page PS-00-03 The Stone & Webster Design Criteria calls for the 7.7-86 snubber rating or 125% of design load for use in

designing supporting steel members. In some cases, this practice was not followed and only the design load was used.

PS-00-04 The self-weight excitation of the snubbers and 7.7-87 support asssemblies was not considered in the Stone

& Webster support desig1 PS-01-01 In the design of the shear lugs and their associated 7.7-88 welds, all four of the lugs are assumed to carry the load. .

PS-01-02 The weld size changes indicated in Stone & Webster 7.7-89 Calculation No. Z-E11-004 pages 19K and 19L, are not reflected in the as-built drawing.

PS-01-03 The annulus pressurization (A/P) loads used in the 7.7-90 (V 's support calculations are not mentioned in the Stone

& Webster specification. The piping, on the other hand, is not analyzed for this load.

PS-01-04 Only the DBE loads are considered in the design 7.7-91 calculations. However, document 3071-528, Rev. A, states that the maximum of either DBE or 1.875 x OBE should be used.

PS-01-05 A 1/8" weld is used between the snubber rear bracket 7.7-92 and the supporting beam. This weld is overstressed by 64% due to the design loading. The design calculations call for a 5/16" weld.

PS-02-01 The "Z" direction gap in support E11-2184-G01 is 7.7-93 less than the movements due to thermal (Ath = 0.327") and seismic (aseismic = 10.086")

movements.

[

, Detroit Edison Company 7.7-15

[ $ M [ T j Fermi 2 Independent Design Verification llll1llllll1111lllllllll1111ll Final Report TR-83021-1; Rev. O

_,s OBSERVATION SUIMARY

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V Observation Reference Number Observation Description Page PS-02-02 The gap in penetrntion MK-184 between the bearing 7.7-94 lugs and the steel sleeve are 1/8" typical. This

-results in a total gap = 1/4" in the restraint direction, which exceeds standard industry practice.

PS-02 The working range for spring E11-2184-G03 (i.e., top 7.7-95 up, bottom out and cold load) was not checked to ensure that the travel due to seismic movement was within the working range of the spring hanger.

PS-02-04 For the referenced hangers, OBE loads are used in 7.7-96 the design load combination instead of DBE loads.

Using the DBE loadings could result in a higher design loading.

PS-02-05 The design calculation considers a lateral bracing 7.7-97 element not shown in the as-built drawing for hanger support E11-2184-607.

A C) PS-02-06 The center line of the pipe and the center line of the pipe, sleeve are offset 1 1/8". This is incon-7.7-98 sistent with the hanger drawing which shows a 2 1/2" high lug and a 1/8" gap between the top of the pipe and the sleeve.

PS-03-01 Anchor straps securing Anchor Structure No. 2 exceed 7.7-99 the allowable stress (90% of ultimate stress) under faulted load conditions.

i

! PS-03-02 For each of the two flued heads in Anchor Structure 7.7-100 l No. 2, there are loads t FX (Axial), t FYZ (Shear),

t MX (Torsion), i MYZ (Bending Moment). Calcula-tions by Ralph M. Parsons Company consider only two (2) of the many possible load combinations without written justification for their selection.

.ST-01-01 The design criteria of the OHR Complex was not 7.7-101 documented for the initial design phase of the structure.

l l O)

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W Detroit Edison Company 7.7-16 r4 iy { M Fermi 2 Independent Design Verification 1llllil11511ll111llll11lllll Final Report TR-83021-1; Rev. 0 l

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g OBSERVATION SUMARY V

Observation Reference Number Observation Description Page ST-01-02 The ultimate load factor used for soil loading is 7.7-102 1.4. The ACI 318-71 code requires an ultimate load factor for soil loading of 1.7.

ST-01-03 The lateral soil loading on the building model does 7.7-103 not match the structural design criteria.

ST-01-04 The RHR Complex was designed for a thermal gradient 7.7-104 due to site ambient temperatures between 70 F and

-18*F. The structural design does not consider higher temperatures in the vicinity of the spray headers which are designed to discharge water as high as 125*F.

ST-01-05 The uppar structural model of frames B and D does 7.7-105 not represent the actual structure in either member size or support condition at the cooling tower location.

O ST-01-06 The basemat ultimate design moment capacity 7.7-106 (Mu=283.6 k-ft) is exceeded at the intersection of the north / south foundation walls Mu=431 k-ft).

ST-01-07 The cooling tower shell is not designed for a 7.7-107 thereal loading condition or gradient across the wall thickness.

ST-01-08 Thermal loading is not evaluated in the analysis of 7.7-108 the slab supporting the cooling tower.

ST-01-09 The thermal stress analysis of the foundation wall 7.7-109 produces moments (Mu=482.89 k-ft) greater than the ultimate design moment (Mu=431 k-ft).

ST-01-10 The loads applied to the cooling tower support slab 7.7-110 are undefined. The weight of the tower applied to the slab is not consistent with the actual weight.

ST-01-11 Ice loading on the interior walls of the pool were 7.7-111 not addressed in the calculations for foundation wall loading.

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L*I M 2 Id Detroit Edison Company 7.7-17 lililllilllilillllilililllilli Fermi 2 Independent Design Verification Final Report TR-83021-1; Rev. O

\

. /7 OBSERVATION SUMARY

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Observation Reference Number Observation Description Page ST-01-12 The foundation wall loads (vertical, shear and 7.7-112 overturning moments) were not applied to the finite element model of the basemat.

ST-01-13 The axial loads on the beams on grids B, C, and D 7.7-113 between grids 1 & 2, 4 & 5, 9 810, and 12 & 13 due to the lateral soil loading on the foundation walls were not considered in the beam design.

ST-01-14 The finite element models of the deep beam 3heer 7.7-114 walls did not evaluate the effects of the seismic shear loads.

ST-01-15 The axial loads in columns due to shear wall over- 7.7-115 turning moments were not included in the original column design loads, ST-01-16 The ultimate moment (Mu=520 k-ft) on the foundation 7.7-117 (n) wall on grid 6 at the east wall exceeds the original

'v' column design moment (Mu=431 k-ft).

ST-01-17 The technique of averaging the spectra from four 7.7-118 different earthquakes is questionable since it involves three geologically different sites, and three independent events.

ST-01-18 No study was made to determine the effectiveness of 7.7-119 pressure grouting of bedrock to minimize ground motion amplification of seismic waves.

ST-01-19 The dynamic lumped mass stick model for the RHR 7.7-120 Complex structure does not take into consideration the presence of the immense body of water inside the building.

ST-01-20 The RHR Complex cooling towers were not analyzed for 7.7-121 forces resulting from a horizontal earthquake.

Detroit Edison Company 7.7-18

[*$ [9 i f d Fermi 2 Independent Design Verification lilllllllllilllllillilllllilli Final Report TR-83021-1; Rev. O

,N OBSERVATION SUMARY

! )

v Observation Reference Number Observation Description Page ST-01-21 The slabs ' supporting the cooling towers and the 7.7-122 walls cupporting these slabs were not checked for shear forces resulting from a horizontal earthquake.

ST-01-22 Reference 3.1 suggests the importance of a 7.7-123 rock / structure interaction analysis. Such analysis was never carried out.

ST-01-23 In some cases, the referenced seismic report 7.7-124 (Reference 3.1) shows accelerations for DBE spectra that are less than those for OBE spectra. For example, for oscillators with T=0.10 sec., DBE North-South at Elevation 637'-0", gives 2.3 g acceleration while OBE North-South at Elevation 637'-0", gives 2.7 g acceleration.

ST-01-24 The anlaysis of the embed plates modeled with plate, 7.7-125 truss and one-way (compression only) boundary finite t

g'l elements is a nonlinear analysis. The results from V this nonlinear analysis are linearly extrapolated and superimposed.

ST-01-25 The maximum plate moment was listed as Mx =.4487 in-k 7.7-126 at element #79. However, the computer output showed the maximum moment asxM =.652 in-k at element #71.

ST-01-26 The allowable load calculation for the stud was 7.7-127 based on the full effective area, since " studs are not fully stressed." Section B.4.2 of the ACI 349-76 Code requires that the calculation be based on the effective areas (overlapping cones).

ST-01-27 The interaction formulas, given in Reference 3.1 for 7.h28 the capacities of embeds (Details 9 and 9A) yield inconsistent stress allowables by combining dif-ferent directional components of stress (e.g. , o x and o platel,) from different locations in the embed p

Detroit Edison Company 7.7-19 L*$ [6-$ i Id Fermi 2 Independent Design Verification ll11llll11llllll111lllllllllll Final Report TR-83021-1; Rev. 0

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Q)

OBSERVATION SUM 4ARY Observation Reference Number Observation Description Page ST-01-28 The section properties for Member #1 in computer 7.7-129 runs 6.1 and 7.1 are not consistent (Ax=63.6 in run 6.1 versus Ax =57.8 in run 7.1).

ST-01-29 The soil investigation indicated the presence of 7.7-130 fractured dolomite bedrock beneath the glacial till. The fractured bedrock was pressure grouted to depths of about 6 to 20' below foundation level to reduce effects of seismic wave amplification.

However, the fractured bedrock extends well below the grouted level. Since grouted bedrock effectively becomes part of foundation, (i.e., the final effect is a deeper foundation) amplification is still possible.

In general, the presence of fractured bedrock below and outside the site should be considered in g analysis.

\) ST-01-30 Following is a summary of the general items identi- 7.7-131 fled during the structural walkdown of the RHR Complex,

a. Generally poor formwork throughout complex.

b. Concrete walls not flat.

c. Exposed aggregate.

d. Voids,

e. Patchwork-grouting.

ST-01-31 The following items were identified during the 7.7-132 walkdown of the cooling tower support cross beams for Fan Assembly "D".

a. Poor formwork.

b. Exposed rebar (approximately 18" exposure, east-west beam, south face, east end).

c. Void with plywood cast in beam (east-west beam, south face, midspan).

( =e= =-

-V 7.7-20

[LaQ= n.Fermi

';if11 7 v=y2 Independent G { OetroitDesign Edison Company Verification 11111111lllllllllll11111ll1lll Final Report TR-83021-1; Rev. 0

p OBSERVATION SUMARY U

Observation Reference Number Observation Description Page ST-01-32 The stairway on the south end of the east exterior 7.7-138 wall appears to be cantilevered from the building.

ST-01-33 Design calculations for the RHR Complex shear walls 7.7-139 analyzed as deep beams were based on a misinter-pretation of Sargent & Lundy's SLSAP computer output. Output membrane shear stresses (force per unit area) for Element Type 6 - Plate and Shell Elements were misinterpreted as membrane shear forces (force per unit length).

Elements with more than a unit thickness will yield unconservative results. Results will be incorrect by a factor equal to the thickness of the plate element.

EE-01-01 The circuit breaker interrupting rating for the 7.7-140

, 480 V switchgear has not been specifled to the

(] manufacturer in the switchgear specifications.

I /

EE-01-02 A check of design drawings reveals a discrepency 7.7-141 between cable tray identification drawings, cable routing schedules, and electrical equipment plan drawings concerning power cable conduit sizes.

EE-01-03 A check of the minimum motor starting voltage 7.7-142 requirements reveals the following discrepancy:

1.1 Reference 3.1 - 85% rated voltage.

l 1. P. Reference 3.2 - 75% rated voltage.

l 1.3 Reference 3.3 - 75% rated voltage.

i-EE-01-04 Cable Tray Hanger 2H18, cross brace not installed. 7.7-144

! Brace is tied and tagged to vertical hanger member.

! Brace cannot be installed, will interfere with ductwork.

l I

f l D Detroit Edison Company 7.7-21 g i g y j Fermi 2 Independent Design Verification lll11kll151llllllllllll111111 Final Report TR-83021-1; Rev. 0 l

Observation M LW Id Record Review p Attachment A k.J Checklist No. DC-01-09 Revision No. 7 Observation No. DC-01-01 Sheet 7 of 7

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments The contract document for work performed by Sargent & Lundy Engineers (S&L) includes an EF-2 correspondence letter from DECO (EF2-30167, dated Dec. 31, 1974). This correspondence forwards the scope of work to be performed by S&L by issue of Bill of Materials (B/M) numbers A2-17E, A2-18E, A2-N-1C and A2-N-1M. Each of the B/Ms required S&L to perform the work in accordance with the requirements of the S&L QA program. The majority of S&L design activities were completed past the 1974 time period.

In addition, the contract document (1A-84503) imposed on Stone & Webster Engineering p

Q Corporation (SWEC) requires that the work be performed in accordance with SWEC methods and tern's of the contract. Further, the work will be performed in accordance with all applicable Federal laws, regulations....."To assure that this was accomplished, DECO audits (EF2-43,314) disclosed that the work performed by S&W was oerformed in accordance with the requirements of its own QA program and that the QA program meets le requirements of 10CFR50, Appendix B.

Furthermore, Sargent & Lundy letter, SLM-436 dated 9/3/76, indicated that the NRC had reviewed and accepted the QA program as described in 3 topical report submitted by Sargent & Lundy in late 1975. This document was incorporated as the Sargent &

. Lundy QA Manual and used to perform engineering work on Fermi 2 in conformance with 10CFR50, Appendix B. The Stone & Webster Standard Nuclear Quality Assurance Program was also reviewed and approved by the NRC under Topical Report Nmnber SWSQAP 1-74, i Revision B. Cygna reviewed several audit reports confirming that both Sargent &

l Lundy and Stone & Webster were implementing the provisions of their respective QA programs.

Based upon the above, appropriate measures were instituted by DECO to assure that contractors performed work in accordance with 10CFR50, Appendix B. This observation is therefore closed.

Approved By Project Manager Date

k. Ilfitf53 Detroit Edison Company; 83021

. Independent Design Verification Program 7.7-22

Observation MM fd Record Review mmmmimimummli i i Attachment A V

Checklist No. DC-01-00 Revision No. O Observation No. Sheet p of DC-01-02 3 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Edition 1 of the DECO Project Procedures Manual (PPM), originally issued in early 1971, does adequately address design verification in the form of design reviews, alternate calculations and performance of testing (see Observation Record Review to Observation DC-01-04).

The establishment of this design verification program is integrated in PPM Part II, Appendix B, Engineering Section B.1.0, entitled " Design Control." This section in particular defines the procedures to be followed for the preparation, review, and approval of all key design documents (both major documents used in the engineering and design of major systems and detail documents required for the assembly, Q("N fabrication and erection of various components of the system). These key documents include:

• Design Instructions

• Design Calculations

• System Diagrams i

• Design Drawings i

• Specifications

• Bill of Materials

• Proposal Evaluations

• Detailed Design Drawings The review process specified includes:

A. The project engineering Group Leader and System Engineer are responsible for assuring that design documents incorporate all applicable design bases and regulatory requirements included in the Design Instructions.

B. A checking engineer (second Group Engineer), other reviewers and Design Review Committee (if convened) are responsible for confirming that each design document complies with design bases regulatory requirements and other system l compatibility.

Approved By olect Man ger Dat k -

M $3 l "

t Detroit Edison Company; 83021 7.7-23 Independent Design Verification Program l

Observation

[4M id Record Review liiiiiiiiiiiiiiiiiiiiiiiiiiiii Attachment A d

Checklist No. Revision No.

DC-01-00 O Sheet *'

Observation No. DC-01-02 3 3 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Based on the above, and supported by the Cygna implementation evaluation of the EF-2 Design Control Program, substantial evidence is available indicating that design verification as per formed is adequate and conforms to the requirements of 10CFR50, Appendix B, Criterion III. Therefore, this observation is considered invalid.

O 1

Approved By Project ManaQer

( '

Bud a 6,s> Date/6 1

Detroit Edison Company; 8302"1 Independent Design Verification Program 7.7-24 l

i 1 -- ._ _ ._._ _ _ . . _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ , _ , _ _ . . . _ _ _ _ . _ _ . _

Observation UtM TA Record Review immimumummmni Attachment A V

Checittist No. Revision No.

DC-01-00 7 Observation No. Sheet of 4

0C-01-03 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments A review was performed to assure that the following DECO computer programs utilized in a safety-related application were reviewed for proper verification and control:

a. Cable Routing

b. BASEPLATE

c. STARDYNE

d. PENLIN

e. Barrier Cable Tray Dead Weight

f. Cable Support Intervals (Calculation 882)

Sizing of Electrical Components to Intermittent Duty Motors

]

b g.

(Calculation 968)

h. Sizing of Electrical Components to Motor Control Center (Calculation 969)

1. Motor Control Center Short Circuit Analysis (Calculation 611)

j. PDROP (Calculation 597)

k. HVACI (Calculation 746)

1. TRNSNT TR (Calculation 104) i

m. Orifice Plate Sizing (Calculation 4675) l' The review disclosed the following:

1. Adequate documentations in the form of program theory, user information and verifications was evident (see items a, b, c, d, j, k,1, m above).

2. User information was not readily available in the form of program input instructions (see items e, f, g,.h above). Further review disclosed that these programs were developed and used solely by one individual and not made available for use on a v:idespread basis. In all cases, user input instructions were deemed unnecessary due to input information being either easily l

retrievable or reconstructable.

l Approved By roject Manager Date (j ,

d.(-/4g //!//63 Detroit Edison Company; 830[1 7.7-25 Independent Design Verification Program

r , , . Observation MM id Record Review g)

L limimimmmmmimi Attachment A Checklist No. Revision No.

DC-01-00 7 Observation No. DC-01-03 Sheet 3

' 4 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

I Closed X Comments

'3. Program verification was not available (see items f and i above). In both cases verification was performed during program development and testing. To provide documentation of such, calculations were developed to substantiate program validity. In one case, Calculation 882, minor discrepancies were discovered between computer calculations and sample problem hand calculations. However, the discrepancies were minor in nature and documented via DECO internal memorandum to F. Bosetti from M. Wisihod dated April 15, 1983.

Based upon the above review, DECO demonstrated adequate controls of computer program O)

( usage and this observation is considered resolved.

In general, Detroit Edison's Design Control Program imposes procedural requirements and contains commitments for certifying and specifying computer codes on the Fermi 2 project. For example:

e Final Safety Analysis Report (FSAR) Section 3.13, Computer Programs for Structural Analysis and Design, provides verification and theory for computer programs utilized by Sargent & Lundy, Stone & Webster, Chicago Bridge and Iron, and others, as referenced in Sections 3.7 and 3.8 of the FSAR.

e Detroit Edison's Project Procedure 3.2, Design Calculations, Section 5.1.C, Preparation, requires the preparer of the calculation to clearly indicate computer codes used and verification of acceptability (i.e.,

sample problem).

• Detroit Edison's Project Procedure 3.3, Design Verification, describes the requirements for verification of design documents. This procedure contains a Design Review Guideline which lists questions to be considered during a review of design documents. Question 19 states: "Have computer codes used been verified for acceptability?"

) Approved By Pr > ject Manager

'v pf f . ~

lyrf, v

Datellll l lf}

Detroit Edison Company; 83021 7.7-26 Independent Design Verification Program

Observation Mbilib imummimmimmim Record Review g Attachment A V

Checklist No. Raision No. p DC-01-00 Observation No. Sheet of DC-01-03 4 4 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments The use of NRC's Standard Review Plan during Cygna's review was to establish guidelines for standard industry practice. It was understood that the Fermi 2 project is not committed to the NRC's Standard Review Plan. As stated in Section 3.2 (page 3-3) of the final report, Cygna committed to review the Fermi 2 project against standard industry practice.

O t

I p Approved By Project Manager Date M Q.% (f ulule3 I I Detroit Edison Company; 83021 7 7-27 Independent Design Verification Program

_ . _ - . _ . . _ . _ _ _ . _ _ _ _ _ . , _ _ . _ _ _ . . _ . _ . . - _ ..- _ ~ ~..___.._ _ -._..-_-_. _ __ _-

Observation MMid Record Review Attachment A vn)

(

Checklist No. DC-01-00 Revision No. 1 Observation No. DC-01-04 Sheet 3 of 4 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments

a. All designs are checked by an individual other than the preparer and reviewed by at least a third individual. The checking function, as spelled out in appropriate procedures, is for assurance that the design is correct and in conformance with all design base documents. This activity is accomplished in Design Instructions, Design calculations, Drawings, System Changes, Design Drawings, Specifications, Bill of Materials and Detail Design Drawings.

Thaefore, observation (a) is determined to be invalid.

Project Procedure 3.3, Design Verification, lists twenty-five review questions for the checker to use as a guideline when reviewing / verifying design documents. The checker uses these questions as an aid to not only ensure that the design is correct and in conformance with all design base documents, but also to' address testing requirements, documentation, practical application aspects of the design (i.e., constructability, maintainability, etc.), and other areas as necessary for proper design verification.

b. All designs undergo a design review (see part 4.a above). If it is determined that testing is required in addition to design reviews, the provisions for testing are identified in the appropriate design instruction and controlled during construction testing, checkout and initial operatioas, preoperational testing and/or start-up testing. Adequate provisions exist in both editions of the Project Procedures Manual (PPM) to indicate that identifying the design verification method is adequately addressed. Therefore, observation 4.b is determined to be invalid, c.. Design verification is performed on all designs; hence this option of performing verification is not utilized by DECO. Therefore, observation 4.c is determined to be invalid,

d. When testing is required, it is spelled out in appropriate design instructions. This requirement is adequately addressed in the PPM. Therefore, this observation is considered invalid.

/'

( ')

Approved ByJ'M 0 %jer roject Manas Date

. n/ues Detroit Edison Company; k3021 7*7-28 Independent Design Verification Program

- . _ _ __ _. _ _ _ _ . _ . _ .- - . _ , _ ___ . _ . _ . . _ _ _ _ ~ .

i Observation M16 TJ Record Review immimimmimimmi Attachment A

\

Checklist No. Rnision No.

DC-01-00 3 sheet of Observation No. DC-01-04 4 4 Yes No Valid Observation X Potential Finding X (PFR No. N/A ) .

Closed X Comments

e. Procediare B.1.5.1.2 adequately addresses testing under the most adverse conditions. Therefore, this observation is considered invalid.

f. Modifications resulting from system or equipment tests are handled via the DECO Design Change Control / Field Modification Control systems and appropriately addressed in the PPM program. Therefore, this observation is considered invalid.

The Startup Manual, Section 4.0, Nonconformances, provides added assurances that conditions adverse to quality or operation (such as equipment failure, u malfunctions, documentation, design deficiencies, incorrect design or installation and defective material) are promptly identified and corrected (via the Design Change Control / Field Modification Control Systems). Further, the manual indicates that if test results are unacceptable, they are returned to the Startup Test Engineer for resolution or retest. Also, the requirements of testing and/or retesting to assure satisfactory performance to an item are imposed on suppliers by Project Specification 3071-125.

g. Although the PPM does not specifically state that design verification be performed prior to fuel load, the design reviews and testing inherent in the DECO design verification program assure that this is accomplished. Therefore, this observation is considered invalid.

O Approved By Project Manager Date Qf y k.4%r lifff63 -

Detrolt-Edison Company; 83021 7.7-29 Independent Design Verification Program

-=

Observation M i'fd Record Review Attachment A Checklist No. gggy,gp Revision No.

Observation No. Sheet of DC-01-05 7 7 Yes No Valid Observation y Potential Finding y (PFR No. N/A )

Closed X Comments With respect to Edition 2, Project Procedure 3.1, Design Instruction, provides a basis for the development of various design documents on the Fermi 2 project including design calculations, design detail drawings and design specifications. In preparing a design instruction, the referenced document requires that the system quality assurance level be stated with rationale identified if items within a safety-related system are not assigned as QA Level I. Cygna, however, does not consider Project Procedure 3.1 as a sufficiently adequate procedure for assigning QA-level designations and consequently held that the four identified project procedures should have contained requirements for assigning documents with QA level.

5 G DECO Project Procedure Manual (PPM) Edition 1, however adequately addresses the assignment of QA level designations to key design documents. As stated in the observation, Edition 2 of the PPM, does not. However, the implementation evaluation of the design control program disclosed that the QA designation requirements specified in Edition 1 of the PPM are still being followed in that all key design documents were reviewed and contain the required QA level designation. Therefore, this observation is considered closed.

i l

l l

i

{ Approved By oject Manager Date 0

1Mf-t l\ \\ 03 Detroit Edison Company; 83021 7.7-30 Independent Design Verification Program

- ._ - . _ - .- _ -. - _ - _ _ _ ~ .- -. _- , .-

= ,== Observation L4Ri 2 Td Record Review Attachment A Checkilst No. DC-01-04 Revision No. 7 Observation No. sheet p of DC-01-M 7 Yes No Valid Observation x Potential Finding X j (PFR No. N/A )

Closed X-Comments l This condition has been determined to be isolated. Even though the revised specification lacked a P.E. certification, a number of reviewers did review the l

specification to ensure it did not contain any design errors. To resolve this, Specification 3071-517 was revised and reissued with the P.E. certification. This obsarvation is closed.

l d )

l l

l l

l l l l

t I

l Approved B Project Manag r Date acm He '

! Detroit Edison Company; 83$21 7 7-31 Independent Design Verification Program l

Observation M1C TJ Record Review iiiniininunilinuinilii Attachment A

'd .

Checklist No. Revision No. O DC-01-04 Observation No. Sheet of DC-01-07 7 7 Yes No Valid Observation y Potential Finding y (PFR No. N/A )

• Closed X _

Comments It was determined during the review that Fermi Specifications 3071-194 and'3071-231 '--

were cancelled prior to being formally issued and therefore not subject to the requirements of Project Procedure 3.27, paragraph 5.c. Therefore, this' observation is determined to be invalid. ,

l

• l A) Approved By roject Managerg 8%00- 34 Date4 NI63 ,

Detroit Edison Company; 83051 Independent Design Verification Program 7.7-32  ;

- ~

c .

-/ ~

j ,

a

/

[Exe r... .-

7 Observation L4f.ejifd . , ~

Record Review ninniimi1inninunm -

g 7 Attachment A

( _

i"' l Checilist No. Revision No. g DCb1'08 -

O b se rv a tion; No. sheet of 7

DC-01-08 7

,[' Yes No Valid Observation x Potential Finding X (PFR No. 01 1 )

closed (see PFR)

Comments This review disclosed that DECO's implementation of it's internal audit system is ipadequate. This is therefore considared a condition which may have impact on final design and is reported as a potential finding.

/

d

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7

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7 I

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l f Approved By Pbject [anagera.f% DateAve3 4

Detroit Edison Company; 83021 7.7-33 Independent Design Verification Program 7 . .-. - - . - - ....-.. . . . - - , - - - . . - . . - . - - - . _ .

Observation Bl*h' /d Record Review g tilitiliaisiittilitialittiini Attachment A V

Checklist No. Rnision No.

00-01-08 g Observation No. Sheet p of 7

JC-_01-09 Yes No Valid Observation X Potential Finding X (PFR No. 02 )

C!osed Partial (Refer to PFR)*

Comments A. Regarding the reporting of the status and adequacy of the QA Program to the president, DECO has exhibited appropriate controls for reporting to upper level management with monthly project reports and the Quarterly QA Report. In addition to these reports, the QA manager reports to the Edison Senior Management Committee. However, the reporting is verbal rather than written.

Based upon the extent of quality reporting, this portion of the observation is resolved. Refer to PFR 01 and 02 for additional details of the reporting of the status and adequacy of the Ferrni 2 QA program.

'

• This Observation Record Review pertains only to the QA Manager quarterly

' \. reporting. PFR 02 addresses the remaining issues.

l l

l Approved By Prole Date

-a 4 Manager uMe Detroit Edison Company; 83021 7 7-34 Independent Design Verification Program

k =

Observation MM' f/1 Record Review Attachment A Checklist No.

DC-01-08 Revision No. g Observation No. sheet *'

DC-01-10 2 2 Yes No Valid Observation X Potential Finding X (PFR No. 03 )

Closed (see PFR)

Comments This review disclosed that DECO's implementation of its external audit system is inadequate. This is therefore considered a condition which may have impact on final safety and is reported as a potential finding.

O d

' Approved By P lect anager7 Date

@ i 63 I '

Detroit Edison Company; 83021 7*7-35 Independent Design Verification Program

+ === Observation

[41*j l fd Record Review nuinunininnuninnn Attachment A V

Checklist Ne- DC-01-02 Revisi n No. g Observation No. sheet of DC-01-11 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Design Document Packages (DDP's) are not used for design, only to assure that all the records which prescribe the design and verify fabrication, erection, and testing to the design are identified, collected and stored by their associated QA Level I component, system and structure. Therefore, based on the fact that DDP's are not used for design, this observation is considered closed.

Approved By Pr ect Manager Date Y' 15$

v Detroit Edison Company; 83021 7.7-36 independent Design Verification Program

== = m Observation

[4M' ffi Record Review 7

imummmmmmimii Attachment A V

Checklist No. Revision No.

DC-01-08 3 Observation No. sheet of p 0C-01-12 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments This observation concerns an administrative procedural noncompliance in that auditor certification records had not been generated to date. A review of the personnel who acted as lead auditors since 1978 disclosed that each has sufficient education / experience plus required training to be certified as lead auditors.

Therefore, this observation is considered closed.

Cygna also noted in the course of the review that individuals who acted as auditors and lead auditors prior to issuance of ANSI Standard N45.2.23 were well qualified.

They were primarily engineers with degrees, many were registered, and all received

, (' formal QA training.

\

l l

I rs Approved By Projec Mana er Date

$1rQ h.;/1Mt IIf\lf63 I

Detroit Edison Company; 83021 7*7-37 Independent Design Verification Program

\

- = -

Observation

[4M' fd npininnininininnin Record Review

,, Attachment A L.] ___

Checklist No. Revision No.

DC-02 06 3 Sheet of

• Observation No. 0C-02-01 7 7 Yes No Valid Observation x Potential Finding X (PFR No. N/A )

Closed X Comments Report SL-3147 is supported by a calculation containing response spectra developed utilizing the subject computer codes. To provide adequate design analyses traceability, the subject report has been revised to provide the appropriate computer program references. This observation is closed.

("

Ns)'

O.

( ) Approved By Projec,t Manager Date

-C Wk Y $3 Detroit Edison Company; 830$1 7.7-38 Independent Design Verification Program

=cs.s= e q Observation M n'id Record Review mimimmmmmmmi Attachment A U Revision No.

Checklist No* DC-02-02 O Sheet p of Observation No. DC-02-02 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Project instructions specifying use of particular computer program revisions are not necessary for the designs performed by Sargent & Lundy. The projects are provided a computer status listing which lists all the prc'; cams verifled and on the system for engineering use. Engineering personnel can only access computer programs listed on this status report. Further, if there is more than one version of a computer program available for use, a program manual provides information such as the detailed method of analysis, design code and input and output formats.

(^') To assure that the proper computer program was applied on a design by design

() basis, the calculation reviewer has the responsibility to assure that the computer program options chosen by the analyst are correct and the computer analysis performed meets the requirements of the project design criteria and SAR commitments.

I Based upon the above, this finding is considered closed.

i i

l l

q -

roject Manager Date l

Approved By 2g*e4*0.

+k/o Detroit Edison Company; 83021 7.7-39 I Independent Design Verification Program

- Observation M &' fd Record Review D Attachment A O

Checklist No. DC-02-02 Revision No. 1 Observation No.DC-02-03 sheet 3 of 3 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Evidence was provided indicating that the program validatior. nd user manual

, documentation for the identified computer programs was retrieved and is available.

A review to verify the adequacy of this documentation disclosed no problems with one exception. During the verification of DYNAS version 09.7,090-4.0 a comparison of program results was made using DYNAS version 09.7,090-9.2. This resulted in a problem being identified in the latter version 09.7,090-9.2 regarding a computation error in absolute displacements. An investigation to determine impact on Fermi 2 design disclosed no design impact (refer to Correspondence SLM-2099, dated April 18, 1983). Therefore, this observation is closed.

m p ,

Approved By Proje t Manager Date

) 'v O Detroit Edison Company; 83021 7.7-40 Independent Design Verification Program

=- --

Observation L4M'Id Record Review limimmimimmimm Attachment A

' \.j Checklist No. DC-02-02 Revision No. 7 Observatten No. 0C-02-04 Sheet p of 2 Yes No Valid Observation X Potential Finding X l (PFR No. N/A )

Closed X Comments System design reviews were performed by Sargent & Lundy. The Sargent & Lundy directive initiating the review was issued prior to any review activities by Cygna. Design Review Reports were generated and Cygna's review disclosed that arpropriate actions are in place to resolve reviewer comments. This observation is closed.

O i

I l

l

Approved Byboject / ManaQer4& Datedhs Detroit EdOon Company; 83021 7.7-41 Independent Design Verification Program

F= =

Observation MW Id mummmmummmu Record Review 7 Attachment A V

Checklist No.

00-02-02 Revisi n No. 7 Sheet of Observation No. 0C-02-05 3 3 Yes No Valid Observation X Potential Finding X

(PFR No. N/A )

Closed X Comments A. The illegible pages found in the support calculation packages are copies of those sent to S&L by Deco's As-Built Walkdown team. However, the information needed to perform the calculation is legible. Therefore, this portion of the observation is determined to be invalid.

B. Revisions were performed to correct the administrative errors discovered in the calculations. This portion of the observation is considered closed.

C. The sources of formulae, references and data are appropriately contained within T the calculation package. This portion of the observation is determined to be (V invalid.

D. The results from each of the analyses were reviewed and found to be identical.

This portion of the observation is closed.

l l

1 I

I O

l

( Approved By Project Manager Date NIf b y / /

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-42 l

, , , __ . . ~ _ _ _ _ _ _ _ .,___________ _ _

=-- -

Observation ~

L41*i2 fa Record Review limmmummmimim Attachment A O Checklist No. Revision No.

DC-02-15 3 Observation No. DC-02-06 sheet of 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Evidence exists to indicate that the Sargent & Lundy internal audit program instituted in the Fermi 2 project was adequate to ensure overall implementation of the design control program. Those specific procedures not audited identified in this observation fall into at least one of the following categories:

Implementation was audited, but not on an annual basis and project compliance can be proven adequate.

The procedure was not applicable to the Fermi 2 project.

O The Cygna review proves either adequate procedure implementation or identifies an observation where, once resolved, design will not be impacted.

Therefore, based on our review, the weaknesses identified in the S&L audit program do not impact design and this observation is considered closed, t

Cygna also notes the following points as further justification:

a) Since Sargent & Lundy's Audit Team reviews the applicability of the General Quality (GQ) items with the Fermi 2 Project Team prior to an audit, if there is inactivity in the area of a GQ concern, then that item would not be audited; b) Various QA audits conducted in recent years may not have been conducted in prior years due to the fact that these audits covered procedures which were in effect only during the more recent time frame.

Approved By Project Manager Date hh II 1/ 83 Detroit Edison Company; 83021 7.7-43 l Independent Design Verification Program i

, = r ,--,---w-------w. --r -. .- .--.---,.----.r m- e.,--n .- .,,-,,s ,..r- - . - , . - , , - , - , - = , . - - - - , . . . - - -

m .G ' Observation L41*i2Id Record Review Attachment A Checklist No. DC-02-03 Revision No. /g sheet o; Observation No. 00-02-07 7 p Yes No Valid Observation y Potential Finding X (PFR No- 09 )

closed (see PFR)

Comments Since the design may be impacted if Fermi 2 piping is not reconciled with the stress analyses, a Potential Finding Report has been written.

l l

Approved By Date

! oject(AManNagW 4l>sl03 Detroit Edison Company; 83021

' Independent Design Verification Program 7.7-44 l

Observation (4M rd Record Review limmimimmmitmm Attachment A Checklist No. DC-02-13 Revision No. 3 Sheet of Observation No. DC-02-08 7 7 Yes No Valid Observation X Potential Finding y (PFR No. N/A )

Closed X Comments A. The three correspondence which could not be immediately retrieved have been located by Sargent & Lundy with the following results:

1. One correspondence (EF2-37,199) is a DECO internal memoranda requiring no S&L action.

2. Two correspondence (EF2-33,815; EF2-38,067) did not require S&L action.

B. The two correspondence where initial evidence did not exist indicating that l aci. ions required in EF2-34,453 and 35,717 were taken and were in fact

(

(~)S appropriately controlled and resolved.

Therefore, based on the above, this observation is determined to be invalid.

1 1

1 Approved B P Dat

' Mroject Manajpr4 m 4/s3 Detroit Edison Company; 83021 7.7-45 l Independ'ent Design Verification Program

l

Observation

[41dtfd '

tililiittiilitiililiitilliliti Record Review  :

Attachment A V one

. Checklist No. DC-02-13 Revision No. p/ g Observation No.DC-02-09 sheet 2 *'

2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments A. S&L did retrieve all the required correspondence. It should be noted that-correspondence number EF2-24,273, EF2-32,884 and EF2-33,284 were DECO internal doc,uments in which S&L was not included in distribution.

B. To evaluate whether a generic problem existed regarding S&L's handling of DECO

' correspondence, an additional sample of sixteen correspondence was requested to be returned:

EF2-34,390 EF2-54,177 (N EF2-38,067 EF2-58,127

(

) EF2-54,763 EF2-58,458 EF2-51,625 EF2-46,019 EF2-53,853 EF2-58,862 EF2-34,813 EF2-82,842 EF2-10,267 EF2-36,340 EF2-47,117 EF2-20,630 S&L did provide timely retrieval for the above documents.

C. A further review was performed to assure that design input, as contained in correspondence, was properly transferred to final design. The correspondence selected containing design input included:

EF2-34,390 EF2-54,763 EF2-38,067 EF2-34,980 EF2-56,963 EF2-34,701 EF2-59,416 EF2-53,488 In each case, the required design input was translated into final des 1gn.

Based on the above, this observation is considered closed, f

( )l Approved By P oject Man ger Date

. 26 3 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-46

==a Observation

[*ht W Id Record Review immmmimiimimmi

, Attachment A Checklist N - Revision No. 0 DC-02-03 Sheet of g Observation No. DC-02-10 p Yes No Valid Observation

_X Potential Finding X (PFR No. N/A )

Closed X Comments S&L has performed a review of all stress reports and generated a memoranda (P. Petersen to J. Neywork, dated April 6,1983) requesting that the field verify that as-built pipe supports be checked to assure that each is reconciled with the stress analyses. If not, direction exists to assure that the proper design change paper is generated.

Further, for those pipe supports for which DECO is responsible, procedure PDM 1.1 "As-Built Reconcilation of Piping Stress Reports - EG-44," has been revised to include requirements to assure that pipe supports are reconciled with stress analyses.

i The above actions close this observation.

l Approved By ject Manager Date

- CM #

6. h 3 l Detroit Edison Company; 83021 0 7.7-47 i Independent Design Verification Program

n -=

Observation M i'fA Record Review m ' "' ""i """ "'""' " "

Attachment A Checklist No. Revision No. n DC 03 03 Sheet 9 of 9 Observation No. DC 03 01 Yes No Valid Observation x Potential Finding y (PFR No. )

N/A Closed X Comments The drawings in question were superseded drawings and were signed by the cognizant lead discipline engineer, the project design coordinator and project engineer.

During the period that these drawings were processed (1979-1980) the Lead Engineering Mechanics Division engineer (also the task leader) assumed the responsibilities of the responsible engineer. He always signed as the task leader and usually put a dash (-) in the responsible engineers block indicating the intentional omission of the signature.

All the drawings mentioned in the observation plus all drawings containing this C condition have been revised and reissued when a responsible engineer was assigned.

These drawings have been completely and properly reviewed, signed and issued.

Therefore, this observation is considered closed.

[ Approved By P ject Manager r Date Y

Detroit Edison Company; 83021 7.7-48 Independent Design Verification Program

=- 2 Observation MMid Record Review n tiltilitIII11tiillitilistillit Attachment A V

Revision No. g Checklist No. DC-03-03 Sheet 7 of 7

- Observation No. 0C-03-02 Yes No Valid Observation X Potential Finding X (PFR No. )

N/A Closed X Comments All drawings reviewed were sepia mylar copies of pipe support location drawings

(-2's). These drawings were reviewed to incorporate open change documents and maintained for periodic updates.

Stone and Webster (S&W) has other means of verifying receipt acknowledgement to verify that drawings issued to DECO were appropriately received. These are the Automatic Records Management System terminal and printout which lists all the drawings received and in use by DECO and the receipt of drawing aperture cards from s

DECO Document Control, s Therefore, adequate assurance exists to indicate that the proper revisions of drawings are received from S&W and used by DECO, and this observation is closed.

aw

" pr Approved By roject Manag -

Dadtr/o Detroit Edison Company; 83021 7.7-49

! Independent Design Verification Program

,.,m w -- - ,-- ,y, -

,.-g-y v -

"4'--M"- T'""-"--7'"r' * e'"-'T"-W*--T'-' F "Tr

Observation Alth' fd Record Review i:11:ill1111111111111lllllii11 Attachment A U,,

Checklist No. Revision No. g DC-03-05 Sheet p of Observation No. DC-03-03 7 Yes No Valid Observation X Potential Finding X (PFR No. -N/A )

Closed X Comments Further review found this to be an isolated case. In this case, DECO assumed the responsibility for closure of Stone & Webster's comments provided in letter SWEF-1181 dated August 24, 1981. Evidence of comment closure is documented in Deco correspondence EF-2-59,840 dated September 2, 1982. Therefore, this observation is considered closed.

S l

l l

l Approved By Pr lect Manager , Date id<w ds/e3 Detroit Edison Company; 83021 7.7-50 Independent Design Verification Program

- =

Observation

[.Mi fa Record Review iimumummumniiin Attachment A O Checklist No. "** " N -

DC-03-07 n Sheet of Observation No. DC-03-04 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further Cygna review determined that the main purpose of filing dispositioned DCN's with the transmittal is to assure that DECO has responded to " Action" transmittals (e.g., transmittals that require action to be taken by DECO)., Further, review of project files revealed that " Action" transmittals are filed in project job books entitled " Communications" and dispositioned DCN's are filed in project job books entitled " Design Change Notices." In addition, all outgoing transmittals are reviewed by the project clerk for " Action" requirements and all action items are logged in the project action item report for tracking. Upon receipt of appropriate documentation from DECO (i.e., dispositioned DCN) the action item is closed on the o action item report and the documentation filed in the appropriate project job book. Therefore, this observation is considered closed.

Approved By Project Mana0er 7 Date M F '

Detroit Edison Company; 83021 7.7-51 Independent Design Verification Program

Observation

[4M fd Record Review imimimimmmmmil

, Attachment A

(

. v)

Checklist No. PI-01 Revision No. 7 Observation No. PI-01-01 Sheet p of p Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further Cygna review indicates the stress levels in this area are low, therefore the change in calculated stresses and displacements due to the installation of long radius elbows instead of short radius elbows will not significantly affect the results of the pipe stress report. Stresses in the pipe due to the short radius

, elbow are higher so the results of the stress analysis would be conservative. Thus there is no impact upon design or safety due to this observation.

Because this situation was isolated to this one section of pipe between data points 571F and 573N and because the results were conservative, the observation was closed.

a l

l 1

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l l

l Approved By oject Manager Date

(( hg // tl @3 l

Detroit Edison Company; 83021, 7.7-52 l Independent Design Verification Program

=== Observation M M t Td Record Review nmmimunninninnn n Attachment A U

Checklist No. PI-01 Revision No. p Observation No. PI-01-02 sheet *'

2 3 Yes No Valid Observation X Potential Finding X (PFR No. )

Closed X Comments

1. The modeled and correct geometry are shown below:

SB10 aX (Model)

,y 10.6 42.9* B9 (Correct)

(Co ect) 47.10 Z

" PIPE

a. Since the pipe M restrained in two directions (i.e., guided), the point cannot move in the X-Z plane. Thus, the error will not affect the pipe stress results, only the loads in the snubbers,

b. Since SB9 is modeled correctly, the effect of the error in SB10 is to take some of the load that would otherwise exist in SB9. That is, the load in SB10 is conservative, the load in SB9 is not. The error is as follows:

Level B (Normal Loads)

SB9 (output) = 41413#

l SB10 (output) = 21179#

SB9 (corrected) = 41413 + 21179 COS (10.6 + 42.9) = 54022#

! . . increase =

3 = 1.3 l

) Approved By Project Managg Date Ma.es Detroit Edison Company; 83021

+/e

, 7.7-53 Independent Design Verification Program

-- =

Observation

[MM'Id Record Review mmmmmm""""""

Attachment A Checklist No. p[_01 Revision No. 2 Observation No. PI-01-02 Sheet 3 of 3 Yes No Valid Observation X Potential Finding X (PFR No. )

Closed X Comments Level C (Emergency Loads)

SB9 (output) = 50623#

SB10 (output) = 23462#

. . SB9 (corrected) = 50623 x 23462 cos (10.6 + 42.9) = 64592#

. . increase = 0 3 = 1.28 Cygna has evaluated t.te significance of this observation for both the support structure and the components. For supoort structure SB9, the 28% increase in load is more than offset by a 33% increase in allowables which is permitted by the AISC manual, but was not utilized by Stone & Webster. For the components, Stone & Webster conservatively compared Level C loads go Level B allowables.

This resulted in the selection of a snubber with a 120 allgwable{seePSA catalog). As a result, increasing the snubber load from 51 to 65 has no impact on the plant hardware.

2. Review of the support and piping system indicates there will be no significant design impact.

Based on a review of 10 other snubbers in this GE analysis, the source of this observation is isolated.

l l

r

( Approved By ,P oject an er g Date

.hg IlfitfS3 l

Detroit Edison Company; 83021 7.7-54

Independent Design Verification Program

Observation 51dlfd ninniniinninnimnin Record Review

, Attachment A Checklist No. Revision No.

PI-01 0 Sheet of g Observation No. PI-01-03 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Cygna has conducted a review of the RHR supply line plus two of the four main steam loops (MS-C & MS-D).

This review concentrated on the main area of concern associated with this observation (i.e., large masses near restraints). The review indicated that in the areas of concern, the loads associated with the ZPA of the response spectra are enveloped by the loads from the computer analysis. This is due, in part to the relatively low ZPA associated with the response spectra for Fermi 2. Thus, this observation is judged not to have any impact upon design or safety.

(*

(

Date Approved By PDject Manager 4 d,w 4 2s/s3 Detroit Edison Company; 83021 7.7-55 Independent Design Verification Program

-- =

Observation MM' TJ Record Review immmimmmmimm Attachment A G

Checklist No.

PI-01 "*"'""~ l sheet ot Observation No PI-01-04 7 7 Yes No Valid Observation X Potential Finding X (PFR No, )

N/A Closed X Comments Further review of the support drawings indicates the supporting frames are not complex and have a relatively rigid geometry. Consequently, reductions in overall stiffness resulting from this observation will not cause any significant increases in loads or stresses in the piping system.

Because of the design margins in the pipe supports and the small effect estimated by the change in support stiffness, this observation will not have an impact upon design or safety.

O Approved By P lect Manager Date i

hNM N Detroit Edison Company; 8302 7*7-56 Independent Design Verification Program I ___ . . .-. - - - - . - . . . - - . - . .---. -- - - --

~

== =e Observation L4M' fd '

Record Review g nmmimmmmmmm Attachment A V

Checklist No. PI-01 "*"'""* 1 Sheet of Observation No. PI-01-05 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Review indicates that General Electric originally used the flooded weight shown on the valve drawings plus the operator weight for both the deadweight and seismic analyses. Subsequently, GE received a letter from the vendor, kn. Powell Co.

(Refrence 3.3), stating that the flooded weight was the sum of the valve body plus operator weights. The deadweight analysis was rerun but GE determined that the weight change would result in a small change in the seismic response, so the seismic analysis was not rerun. Cygna concurs with ths assessment because of the small shift in mode shapes caused by the weight change and because sufficient stress margins exist in the results of the seismic analysis. Consequently, this observation has an insignificant impact on the design and safety of Fermi 2.

This observation has been determined to be an isolated instance.

l i

n

(") Approved By Project Ma ager 0 m/ -

D a te s> ,

g

<</

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-57

sera =m Observation MM f3 Record Review nmmmmmimmtimi Attachment A v

Checklist No. p{.Q} Revision No. 1 Observation No.PI-01-06 Sheet 2 of 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review by Cygna determined that using the small' branch connection stress indices would not significantly affect the analysis results since the branches are usually located on straight pipe runs and would not be the controlling stress points. As proof, GE was asked to rerun Joints 550 and 588 with branch connection indices. As expected, secondary and fatigue results increased, but they were well below the maximum stress points in the system.

For example, at Joint 588.

S10(588) U (588)

() S 10 A4 " U (MAX)

• In addition, the maximum stress values are well below the corresponding ASME Code allowables.

Cygna has reviewed GE's reanalysis and concurs with the results. Based on our experience, these conclusions can be generally extended to other systems. In the few cases where this point governs, stress levels should already be very low. The inclusion of the indices will not impact design and this item does not warrant further investigation.

Approved By Prc ect Manager Date h.l#y M O.)

Detroit Edison Company; 83021 7.7-58 Independent Design Verification Program

psw+r=d Observation M i'fd Record Review Attachment A Checklist No. pI-01 Revision No. O Observation No.PI-01-07 sheet 2 of 4

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further Cygna review has indicated that ANSI 7 calculates the maximum T a/Tb and AT1 for inclusion in the ASME Code analysis. ANSI 7 then chooses the lower of the AT 2*S associated with the times for max T a/Tb and max ATi . General Electric's apparent rationale is that maximizing T /Tb a and ATg will maximize Equation 10 (in the Codes prior to 1980) and thus maximize the Ke factor for the fatigue analysis. While Cygna believes the method may not produce the maximum peak stress in areas with n lower indices (where fatigue is not usually a problem), it will produce conservative s data in areas with higher indices.

Cygna has reviewed the GE method and estimated its effect as follows:

USE 1971 CODE (CODE OF RECORD)

AND ASSUME SAME AT i AT2 , & T,/Tt COMP 0NENT C K AT AT Ta /Tb SM SP 3 3 1 2 ST. PIPE 1.0 1.0 218 19 36 33167 37862 BRANCH 1.8 1.7 218 19 36 38149 69549 TTJ 1.0 1.5 218 19 36 33167 54446 FILLET 1.8 3.0 218 19 36 38149 119143

") Approved By Project Manager M (s k Date fclu Detroit Edison Company; 83021 Independent Design Verification Program 7.7-59

r === Observation M M 'f]

mummmummmimi Record Review 1 Attachment A V

Checklist No. PI-01 Revision No. 1 observation No. PI-01-07 Sheet 3 of 4 Yes No Valid Observation X Potential Finding X (PFR No. N/A >

Closed X Comments En ATI Sn = C EajT 3

3 -T b ! + 2(1-v)

Ea AT2 Sp = K3 S +

n 1-v Ea = 27.1 x 6.38 = 173 psi /0F (Carbon Steel)

Sp (MAX) with AT2 = STEP = _

= 58 ksi Thus, in 2 cases Spmax is underestimated, but Sn with MAX Sp (AT2 ) would be zero.

Since usage factor problems are usually caused by large Ke (based on Sn) being multiplied by Sp, maximizing Sn should be conservative.

For example, if we double all the above (equivalent to a 470 F shack), we find COMP 0NENT Sn Sp Ke Salt - KeSp/2 ST. PIPE 66334 75274 1.764 66392 BRANCH 76298 139098 2.179 151547 TTJ 66334 108892 1.764 96043 FILLET 76298 238286 2.179 259612 Approved By roject Manager Date

(). Os'y  !!/Af63 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-60

/

/

g=1_ _c Observation

[41d 2 T?i Record Review iiiiiilliiiiiiiiiiiiiiiiiiiiii Attachment A Checklist No. PI-01 Revision No. 1 Observation No.pl.01-07 Sheet 4 of 4 Yes No Valid Observation X

' Potential Finding X

)

/ (PFR No. N/A Closed X Comments (1-n ) S n

~

1)

Ke = 1 + n(m-1) (3Sm Using CS, n = .2 m = 3.0

(')

V 3Sm = 48000 psi (assumed)

Again, using Max AT 2 ' Salt max = 58 ksi Thus, the GE method is conservative:

l for those normal high usage areas (branch connections and fillets) 1)

, 2) for high gradient transients which normally are the high usage producers.

The GE method has no design impact and this observation is closed.

l

/^

Approved By Project Manayr Date

(

M G. m V

+/4s>

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-61

Observation

[41dlTd Record Review Attachment A Checklist No.

PI-01 Revision No. O Observation No. PI-01-08 Sheet p of p Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed 'X Comments General Electric has agreed to evaluate the effect of a 507, increase in component thickness in the final Class 1 stress report. Cygna also reviewed input for the Main Steam line analysis which confirmed that GE normally inputs a thicker section to account for the higher gradients in tees and valves. The increase in thickness will not increase T a/Tb appreciably since that Ta/Tb due to material discontinuity has been included and these gradients already approximate the maximum possible values. Since there will be only minor increase in thermal stresses, and since there already exist large margins in the primary plus secondary and fatigue checks, this items has no design impact and is closed, a

3 l

i i

i Approved By Project Manager, Date l

& h. h(/} h2Sf63

/

Detroit Edison Company; 83021 Independent Design Verification Program 7 7-62

I Observation Mi+-H TJ Record Review l Attachment A Checklist No. PI-01 Revision No. 0 Observation No. PI-01-09 Sheet 2 of 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments a) For emergency conditions, GE ANSI 7 uses the bounding value of OBE or DBE. When OBE is bounding, Cygna has noted a slight difference in the emergency and upset stresses. However, for this situtation both the emergency condition stresses and the upset condition stresses should be equal. Since the difference is conservative, this has no design impact. GE has, howevai, committed to investigate the reason for the difference.

b) For Equation 13, ANSI 7 conservatively chooses the maximum pressure, rather than the range of pressures. Since this procedure is conservative, there is no design impact.

V Based on the above information, no further investigation was warranted. This observation has no impact on the design and safety of Fermi 2.

q Approved By Pr ject Manager Dat

~

h. [fA3, -

l63 I

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-63

. _ _ . - _ _ . _ ~ _

Observation l

(41W TA Record Review Hiiimillimmilillillilli Attachment A 1 V l Checklist No.

PI-01 Revision No. g sheet of Observatloa No.PI-01-10 , 7 Yes No Valid Observation v Potential Finding y (PFR No. N/A )

Closed X Comments Further review of the lugs at joints 598 and 558 indicates the incorrect load was used. GE, however, does conservatively assume one lug takes all the load, rather than dividing the load among half the lugs. Cygna has recalculated the local stresses with the correct loads and has concluded there will be no design impact since there is little increase in stress. Cygna has verified that the correct loads are used in all other calculations and has concluded that this was an isolated incident.

O Cygna does recommend that GE tipdate the final report to evaluate the effect of the I

'J new loads on the local stresses.

(

Approved By ProjectnManager $& Q.

Date

+/w/ea V '

/

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-64

s-w Observation M M'id Record Review nunnmnmumimm" Attachment A Checklist No. py;01 Revision No. 3 Sheet of Observation No. PI-01-ll 7 7 Yes No Valid Observation X Potential Finding y (PFR No. N/A )

Closed X Comments Further Cygna review has indicated that the postulated impingement and surge loads on the RHR system should not be considered since the source of the loads is the broken line to which the RHR line is attached. Detroit Edison will revise the design specification (3071-503) to reflect this. Cygna agrees with this evaluation, since the FSAR, Paragraph 3.6.5.1.1, states " Piping within the broken loop shall no longer be considered part of the RCPB (reactor coolant pressure boundcry)."

In evaluating faulted conditions in general, Reference 3.2, Article 4.5 states

"...LOCA does not create temperature or pressure surges in the piping systems of any

! significance and therefore it is not evaluated for this event." This reference also Q states in Article 4.7 that " pipe stress due to Annulus Pressurization is not required to be included in the Code analysis and stress report."

l Based on this information, this observation does not warrant any further j investigation.

l Supplemental review has revealed that a separate report from the ASME Design Report was generated to assess the impact of annulus pressurization on piping and structures. This approach had been agreed to with the NRC because annulus pressurization was not in the original design basis for Fermi 2. Nevertheless, the piping supports are designed to accommodate the additional loads predicted by this analysis. The probable cause of this observation was the failure to update the DECO design specification to reflect the design basis commitments as stated above.

l

\

I l

t Approved By Loject Manager.a a 4e Da &e Detroit Edison Company; 8302$

7*7-65 Independent Design Verification Program

r- 7 . .

2 Observation-MieH fd Record Review imummmmiimimili Attachment A O Checklist No.

PI-01 Revision No. g sheet of Observation No. PI-01-12 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further Cygna review indicates that a revised building seismic analysis (1979) shows the displacements to be = 1/10 of those used in the analysis (Ref. GE DRF A12-6, dated 12/1/82). Since this will cause all displacements to be less than 1/10", any change in application of movements will not significantly affect design loads and stresses. Thus there is no impact upon design or safety.

O Approved By P olect Manager Date ha4 0.!w W 1/a/m

'4 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-66

- - -

• Observation Mi' C1 Record Review Attachment A -

Checklist No. PI-02 Raision No.

O Observation No. PI-02-01 sheet 2

' 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments This branch connection is a sockolet with a stress intensification factor of 1.0 for the run pipe and 2.1 for the branch. Thus, there will be no increase in stress in the run pipe at the as-built location. In addition, branch pipe strasses were determined to be minimal. Therefore, there is no impact upon design or safety as a result of this observation. This was the only error in geometry of significant magnitude observed in the review of the RHR-Service Water piping element.

O o

( Approved By Pr lect Manager " ate

h. 4 f W03 /

Detroit Edison Company; 83021 7.7-67 Independent Design Verification Program

Observation (4M fd Record Review Attachment A Checklist No. PI-02 "**'""* O Observation No. PI-02-02 Sheet of 7 7 Yes No Valid Observation x Potential Finding y (PFR No. N/A )

Closed X Comments Cygna has conducted a survey of 44 Sargent & Lundy stress report for both the RHR Complex and the Reactor Building. This represents over 90% of the total r. umber of systems analyzed by S&L. Of these 44, one was reviewed as part of the original IDV scope (SX-14) and 12 were reviewed in detail. The majority of the other systems were given a cursory review and were determined not to require any further investigation due to similarity tc other systems and/or lack of large masses.

The detailed review concentrated on the main area of concern associated with this observation (i.e., large masses near restraints). The review indicated that for the f] majority of the systems reviewed, the loads associated with the ZPA of the response V spectra are enveloped by the loads from the computer analysis. This is due, in part, to the relatively low ZPA associated with the response spectra for Fermi 2.

The few systems where the loads were not enveloped were judged to be acceptable due to the low magnitude of the differences.

Thus this observation is judged not to have any impact upon design or safety.

Approved By Praiect Manager, Date kt G-M &sie '

Detroit Edison Company; 83031 Independent Design Verification Program 7.7-68

I Observation MW fn Record Review Attachment A Checklist No. .py,gp Revision No.

Observation No. PT 02 03 Sh*

?

' 9 Yes No Valid Observation y Potential Finding y (PFR No. N/A )

Closed X Comments Further review of the seismic analyses in References 3.2 and 3.3, for both the reactor building and the RHR Complex indicates that all structural seismic displacements are less than 1/10". Although the roof has higher displacements, no safety-related piping was attached to the roof. Therefore a revised SAM analysis would not have any significant effect on the piping and supprt designs in the piping systems anayzed by Sargent & Lundy. Thus there is no impact upon design or safety.

O V

4 Approved ByLoject Manager;p a. dn Dkatn Detroit Edison Company; 83021 7.7-69 Independent Design Verification Program

i

= --

Observation Mdlfd Record Review unmnnnmunim"""

Attachment A Checklist No. PI-02 Revision No. O Observation No. PI-02-04 Sheet p of g Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments S&L has transmitted a letter to DECO (SLM No. 2055, 3/4/83) regarding the required support modification. As a result of this action the analysis will reflect the t

actual configuration. Therefore, there is no design impact.

O) l l

kproved By Project Manager Date henk G.k &le Detroit Edison Company; 83021 7.7-70 independent Design Verification Program

, .-.._.m

=- Observation

[4bj273 Record Review immiimmiimimitml Attachment A Checklist No.

PI-02 Revision No. n Observailon No.PI-02-05 Sheet of ,

7 Yes No Valid Observation y Potential Finding y (PFR No. N/A )

Closed X Comments Further review'by Cygna indicates that the as-built drawing wa's in error since the elbow is in fact a long radius elbow (Reference 3.3). Since the input to the pipe stress analysis agrees with the as-built condition, there is no design or safety impact as a result of this observation.

G.

l l

Approved By Project Manager Date kiaGn 4ds, Detroit Edison Company; 8[021 Independent Design Verification Program 7.7-71

Observation

[+hn' fd Record Review Attachment A Checklist No.

PI-02 Revision No. 3 Observation No. PI-02-06 sheet , et ,

Yes No Valid Observation X Potential Finding y (PFR No. N/A )

Closed X Comments Sargent & Lundy has issued the following correspondence calling for the addition of lubrite plates for the three stanchions in question:

1) Letter from R.J. Peterson/S&L to A.M. Alchalabi/ DECO, dated 3/4/83, "RHR Complex Pipe Support Modifications."

2) IOM from R.J. Peterson to J. Neymark/S&L site dated 4/8/83, "RHR Complex Pipe Support Modifications."

A These modifications eliminate the concern which orginated this observation. Thus,

() there is no impact upon design or safety.

Supplemental review has revealed that S&L has issued SLM No. 2101 dated 4/18/83.

This letter documents their review of all stanchions in the RHR Complex.

w Approved By Project a. Manager %

Detroit Edison Company; 83021 y

DateWe a

Independent Design Verification Program 7.7-72

- =

Observation 14kj;' Td -Record Review liimilimilimimmillii Attachment A O Checklist No. Revision No.

PI-03 O Observation No. PI-03-01 Sheet p of g Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments DECO has issued a project directive (EF2-63,587, dated April 13, 1983) instructing that an ASME Code Compliance Analysis be performed for all flued heads as part of an as-built verification program. As part of this analysis, if a verified thermal transient solution is not used, Cygna recommends that the maximum possible thermal skin stress be considered in the evaluations of all the flued heads in place of the results from the thermal transients. This is a very conservative approach and would eliminate the need for verification of the thermal transient analysis.

Due to the large margins observed in Cygna's review of the summaries of all of the flued head analyses, there is not expected to be any impact upon design.

v O Approved By Project Managergg g g Date# /,je Detroit Edison Company; 83021 Independent Design Verification Program 7.7-73

--

Observation Lild fd Record Review un:"""""""'"'"""'

Attachment A '

Checklist No. PI-03 Revision No. g Observation No. PI-03-02 Sheet Uf 2 2 Yes No Valid Observation X Potential Finding X (PF R No. N/A )

Closed X Comments '

a. Since stresses due to axial load and shear are small in the flued head, j inclusion of the inboard components will have negligible impact on the design.

l This reasoning also applies to the remaining flued heads and this observation is, therefore, closed, l b. Cygna has evaluated stresses due to the 56 psi containment pressure force.

These will be small (approximately of 500 psi) in the flued head and anchor structures. Therefore, there is minimal design impact and the observation is closed.

p i \s/ Based on the above information, Cygna determined no further investigation was warranted.

1 Approved By Project Manager Date 6%u 8.fa

~

6de> '

Detroit Edison Company; 8302f Independent Design Verification Program 7.7-74 l

Observation M N 2fA Record Review mmimmimmmmim Attachment A G

Checklist No. PI-03 Revision No. g Observation No. PI-03-03 Sheet p of p Yes No Valid Observation X

-Potential Finding X (PFR No. N/A )

Closed X Comments Further review indicates that the factor = 0.91 is correct. The outboard shear load is applied at a point 7-7/8" from the process pipe to flued head weld. This results in an additional bending moment .which is eliminated by use of the lower scale factor.

(28.3 x 12 x 1000) - (9530 x 7.875) = 0.91 291000

~

Thus, the normal and upset load combinations are conservative in that this reduction in bending was not considered.

Because of the above information, this observation was considered to be invalid.

l.

) Approved By 9 oject Manage Dat b h &Vj-25 63 Detroit Edison Company; 83021 7.7-75 Independent Design Verification Program

==- Observation MitId Record Review mimimimmiimmmi -

Attachment A

\)

Checklist No. PI-03 Revision No. O Observation No. PI-03-04 Sheet g of 7

Yes No Valid Observation X Potential Finding X (PFR No. 06 )

Closed (See PFR)

Comments Review of flued head X-12 indicates that at Element 179, primary membrane plus primary bending stress intensity =

43715 - (13751 - 459) = 30423 psi < 1.8 Sm = 32760 psi where, Reported Maximum Emergency SI = 43715 psi Thermal SI = (13751 - 459) psi Since the margin is very small (0.93), review of the other flued heads by Tube Turns V) was performed to determine other areas of potential problems. This simplistic review indicates four flued heads where Emergency stress exceeds 1.8 S m Flued Head Max SI/3 Sm Max SF/1.8 S, X-7 0.610 1.02 X-8 0.73 1.22 X-13 0.891 1.49 X-16 0.615 1.03 DECO has issued a project directive (EF2-63,587, dated April 13, 1983) instructing that an ASME Code Compliance Analysis be performed for all flued heads as part of an as-built verification program. As part of this analysis, tiie maximum primary membrane and primary bending stress intensities (excluding thermal stresses) should l be evaluated to 1.8 S, for the emergency condition.

l l'

Due to the possible impact upon design, a PFR has been written.

Approved By Project Manager beid Q- bzw -

1lDtenk3 Detroit Edison Company; 83021 7.7-76 Independent Design Verification Program

Observation .

Mdlfd mmunmimunnmun Record Review l Attachment A U

Checklist No. PI-03 Revision No. 0 Observation No. PI-03-05 Sheet p of g l

4 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments DECO has issued a project directive (EF2-63,587, dated April 13,1983) instructing that an ASME Code Compliance Analysis.be performed for all flued heads as part of an as-built verification program. As part of this analysis, if a verified thermal transient solution is not used, Cygna recomends that the maximum possible skin stress be considered in the evaluation of all the flued heads in place of the results from the thermal transient analysis. This value should be added to the maximuri pressure plus pipe-load stress. This is a very conservative approach.

However, further review by Cygna of the summaries of all of the flued heads indicates that there is sufficient margin such that there will not be any impact b upon design.

l l

p Approved By Project Manager Date t

b4 0 &n -

dnle Detroit Edison Company; 83021 Independent Design Verification Program 7.7-77

. . . - - - . - - . - - . - , ,,,_.-....,,-.,_,.n._.-- . - , _ , , , . , , , . a.-, ,a.---- . , , , - - , , - - - ,,,,--,,,-------a, -

Observation j

[41 6'fd Record Review i Illililiiilitiliitiililliliiti Attachment A

)

Checklist No.

PI-03 R*'"N- n Sheet of Observation No. PI-03-06 7 7 Yes No Valid Observation X Potential Finding X

(PFR No. N/A )

Closed X Comments I

9ECO has issued a project directive (EF2-63,587, dated April 13, 1983) instructing that an ASME Code Compliance Analysis be performed for all flued heads as part of an as-built verification program. As part of this analysis, if a verified thermal transient solution is not used, Cygna recommends that the maximum possible skin stress be considered for all flued heads in place of the results from the thermal transient analysis. This value sbeuld be used in the evaluation of a) primary plus secondary stress intensity ranges for normal / upset conditions, and b) fatigue analysis. This is a very conservative approach.

N However, further review by Cygna of the summaries of all of the flued heads (d indicates that there is sufficient margin such that there will not be any impact upon design.

Approved By Project Manager Date na m g

dn/n Detroit Edison Company; 83021 7 7-78 Independent Design Verification Program

- =

Observation E41WIJi Record Review uninnm"""""""""

Attachment A

~

Checklist No.

E0-01 Revision No. O Sheet p of p Observation No. EQ-01-01 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review indicates that failure of the thrust ring in shear is not possible and this load is taken by the body to bonnet bolting.

l Date Approved BLroject Man:geram Detroit Edison Company; 83021 We Independent Design Verification Program 7.7-79

Observation M M'Td Record Review Attachment A Checklist No. Revision No.

E0-01 7 Sheet g of p Observation No. EQ-01-02 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Review indicates that this observation is due to a limitation of the computer program which was used. The program did not take advantage of Code Paragraph NB-3543 which allows calculation of an interpolated primary pressure rating, Pr, i.e.,

Pd - P ) x [pp , pp Pr = Pr1*(P 2 1 0

= 400 + (f5 4 - 10 ) x (600 - 400) 0 575 F

= 495#

The corresponding standard calculation pressure, P s = 1350 psi.

The value of P used in the computer anaysis was 2270 psi. This substantial reduction in P would allow the requirements of Code Paragraph NB-3554(a) to be easily met.

l It should be emphasized that this load case was not required by the ASME Code. It was performed at Detroit Edison's request. The ASME code calculation performed shows that the appropriate axial cylic stress limit was met. l i

l l 0 l

Date Approved By Pro (1. lj ct Manager 54 da/es 0

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-80 1 . _ _ . _ - . - . . _ _ _ - , . _ - _ _ _ _ - _ -

i Observation L41W Ta Record Review ilmmilmmillimilmit Attachment A O

Checklist No. Revision No. g E0-01 Sheet p of Observation No. E0-01-03 7 Yes No Valid Observation X Potential Finding X (PFR No. 04 )

Closed (see PFR)

Comments Use of the correct pressure (Pd = 1250) reveals that .the . requirements of Code Paragraph NB-3552(a) are still satisfied:

= 417 PressureVariations=400<f=123 The value of f used in the Design Report was 808. Because of the magnitude of the deviation (almost 100%) and the low margin (less than 5%), a PFR has been written.

l i

l l

l l oate i

l Approved By PLect Managera a. L u

<!A I i Detroit Edison Company; 83021 Independent Design Verification Program 7.7-81

=- =-

Observation l M id 2 fd Record Review mmilmimmmimimi

! )

Attachment A

%./

Checklist No. EQ-01 Revision No. 0 Sheet p of g Observation No. EQ-01-04 Yes No Valid Observation X Potential Finding X (PFR No. 05 )

Closed (see PFR)

Comments Calculation of the individual moment of inertia yields the following:

'l Ix= 13.553 in", C x= 2.643 Iy = 12.958 in", Cy = 2.25

- + #

.S x = 13553 2.643 = 5.128 12.958 S = = 5.759 y 2.25 3

Assuming the yoke acts as a guided cantilever, the maximum ratio of new to old bending stress is

[252.251/10.3125) 5.128 = 0.60 The ratio of new to old deflection is 3 x 252.251 12 x (2 x 13.553 + 2 x 12.958) " I*19 This results in a frequecy decrease of less than 10%. Therefore, there is no impact upon design. However, due to the possible impact upon other valve reports, a PFR has been written.

[h Approved By Pr lect Manager

}- Date

& 0. hLr$t- if%f83 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-82

. . ~ . . - . - . -.. . _ , . - . .-. -- . . - - .

Observation

[41d 2 fd Record Review e Attachment A Checklist No. General Revision No. 0 Observation No. PS-00-01 Sheet g of 3

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X l Comments l An approximate evluation of this issue revealed that for a cantilevered support I

(limiting case) with a deflection, 6, of 1/16" and an applied load, P, approximately l equal to the tributary mass weight of the piping, the fundamental frequency of the i

pipe / support system is approximately 1 9 1 f=_

2n/ =

2n/386.4 = 12.5 cps 6 1/16 This frequency ir.dicates that the pipe / support system has a flexibility which could lp affect the piping analysis.

\)

Based on the above, Cygna performed a review of the pipe support stif fness used in the piping analysis versus the actual pipe support stiffness calculated in the pipe l support design calculations (see the attached sumary). It is Cygna belief that the difference between these two would not cause any significant impact on the design or safety of the system, and that further investigation is not warranted.

I i

l l

l 1 m f Approved By Project Manager Date 0- i ,

Detroit Edison Company; 83021 7 7-83

! Independent Design Verification Program

Observation A (E Ta Record Review  :

ittiallitiililliliiiiiiiiiiii Attachment A V

Checklist No. General Revision No. O Observation No.PS-00-01 Sheet 3 of 3 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Independent Design Review Pipe Support Stiffness Summary (Lb/In)

Support No. Analysis Actual Comments G01 -- --

Spring hanger G02 -- -- Spring hanger G03 -- --

Spring hanger Gil -- --

Spring hanger 5

G14 3.1 x 10 Rigid Attached to existing steel G15 3.1 x 10 5 Rigid Attached to existing steel G16 7.9 x 10 5 Rigid Attached to existing steel G17 7.9 x 10 5 2.3 x 10 6 G18 7.9 X 10 5 Rigid Attached to embed G19 7.9 x 10 5 1.33 x 10 6 G20 7.9 x 10 5 Rigid G21 7.2 x 10 5 2.29 x 10 6 G22 7.9 x 10 5 8.24 x 10 5 Approved By roject Manager Date 0' fff $ s1if61 Detroit Edison Company; 83b21 Independent Design Verification Program 7*7-84

==

.= .. ..__

Observation L4L i'Td Record Review nummmmmmmimi Attachment A O

Checklist No. General Revision No. g Observation No. PS-00-02 Sheet p of p Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Cygna's review indicates there is no design or safety impact on either the RHR Complex piping and in-containment RHR cooling piping elements since the thermal movements are small for both systems. Accordingly, further investigation is not warranted.

O l

1 l

Approved By roject Manager Date

• N DV i Detroit Edison Company; 83021 7.7-85 Independent Design Verification Program

aa=-- Observation M i*ilfd Record Review Attachment A Checklist No. General Revision No. }

Observation No. PS-00-03 sheet 2

' 2 Yes No Valid Observation X Potential Finding . X (PFR No. N/A )

Closed X Comments The conservatism inherent in the design criteria was not implemented in the design calculation and does not affect the adequacy of the support. Therefore there is no safety impact. l Requiring the snubber rating to be 125% of the design load is conservative. Because a snubber rating equivalent to at least the design load is adequate and acceptable, this observation has no safety impact on the system design.

Because of the above consideration, this observation is considered invalid.

Approved Prc, ject Managpr Date m . -

UlA % $ ll O v i Detroit Edison Company; 83021 7.7-86 Independent Design Verification Program

= Observation M P]lfd ilmimmmmimmmil Record Review .

Attachment A  ;

V Checklist No. General Revlalon No. O Observation No. pS-00-04 sheet 2 ' 2 Yes No _

Valid Observation X Potential Finding X (PFR No. N/A )

Closed X C o n.m e nt s There is no safety impact on RHR cooling system because of the following i considerations:

1. Stresses due to large bore pipe loads are much greater than those due to self-excitation loads from snubber and support assemblies.

2. A110wables are taken from the AISE code without the standard 33% increase for seismic loads.

O Due to the conservatism in the design, no further evaluation will be performed. l O As verified by the Cygna walkdown, the support assemblies for this system are l

representative of the support assemblies throughout the plant. Thus, this observation has no impact upon design or safety. l Date Approved Bybroject mManag$eud B. d>s/m U l I Detroit Edison Company; 83021 7.7-87 Independent Design Verification _ Program

Observation M eh'TA Record Review ilmlitimimimiimiliti g Attachment A U

Checklist No. PS-01-01 Revision No. 1 Observation No. PS-01-01 Sheet 2 of 2 i

Yes No

- Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments The design of shear lugs for ASME Class I piping is verified in piping stress analysis. Since lugs are covered there, no further review is needed of hanger calculations.

The local pipe stresses due to the shear lugs for ASME Class I piping are considered in the piping stress analysis. Lug size and welding requirements are based on Detroit Edison's Standard Drawing No. 3M-2331. Review of this analysis shows that there 'are no stresses which exceed the code allowables (refer to Observation PI-01-10). Therefore, there is no impact on the design and safety of the plant.

Supplemental review revealed that all Class 1 integral welded attachments are evaluated by GE in the Class 1 Piping Stress Reports, and not the Stone & Webster Pipe Support Design Calculations. The probable cause of this observation was the i failure to void the lug evaluation portion of the pipe support calculation.

i l

l l

l Approved By Project Manager Dat 0 (W N ll 63 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-88

Observation M LW TJ Record Review

.nmmummumunnui Attachment A Checklist No. PS-01-01 Revision No. y Observation No. PS-01-02 Sheet p of 7

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review has shown that the weld on page 19K was incorporated in Rev. I of the DCR. The weld increased on page 19L is no longer required due to the decrease in

, as-built reconciled loads.

Further Cygna review found that the weld size increase specified on page 19X was incorporated into the Fermi 2 design by DCR P-3076, Rev. 1. The weld size increased on page 19L is not required because of a subsequent and sufficient decrease in the as-built reconciled loads. Therfore, this observation is considered invalid.

v) 2 l

l I

l 4

0 Approved By Project Manager Date

% Il lf bb Detroit Edison Company; 8[021 Independent Design Verification Program 7.7-89

rwa m=

=== Observation A L %'rd Record Review iiiiiiiiiiiiim!;mimiliti Attachment A O Checklist No. Revision No.

PS-01-05 THRU PS-01-13 3 Sheet of p Observation No. PS-01-03 p Yes No Valid' O b se r v a tion X Potentla! Finding X (PFR No. N/A )

clokea' X Comments The inclusion of A/P loads is not required, as discussed in Observation PI-01-11.

Therefore, the loads are conservative, s

i Date Approved LProloct Man;pgera, s .

ele Detroit Edison Company; 83021 Independent Design Verification Program 7.7-90

s ==

Observation

[4(%'TJ Record Review iiiiiiiiiiiiiiiiiiiiiiiiiiiiii 7 Attachment A O

Checklist No. Revision No.

PS-01-05. PS-01-10. PS-01-13 O Sheet p of p Observation No. PS-01-04 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review revealed that the DBE loading combinations for pipe support design are acceptable and the comparison with 1.875 times OBE is conservative (see Observation ST-01-23). To clarify this issue in their future work and to reduce conservatism, Detroit Edison has agreed to revise Section 7.6 in Specification 3071-52B, to delete the following:

"The design loads shall be taken as the larger of the fol10 wing loads

1. The loading predicted due to the shutdown earthquake (SSE).

k_) 2. 1.875 times the loading predicted due to the operational basis earthquake (0BE) at a minimum."

\

( Approved By P oject Managerg Dat k.dM bSh Detroit Edison Company; 87[M Independent Design Verificat an Program 7.7-91

===sa Observation LiLi'TJ inininunniinninnun Record Review

. Attachment A

(

Checklist No. WD-01 Revision No. 0 Observation No. PS-01-05 Sheet p of 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Per Reference 3.2, the rear bracket will be replaced and proper weld will be provided. The bracket welding was temporary at the time of the walkdown.

This is considered a random and isolated occurrence.

A b

Approved By Project anager Date if). .

$ %5f93 .

Detroit Edison Company; 83021 7.7-92 Independent Design Verification Program

gzz=== Observation M W fn Record Review ninuninininunninni Attachment A I)

N /

Checklist No. PS-02-01 "* ""'

1 Observation Nc. PS-02-01 Sheet 7

of 7 Yes No Valid Observation y Potential Finding X

(PFR No. N/A )

Closed X Comments This support design is being revised as discussed in PI-02-04. The revision will eliminate the design impact of this observation per DECO document PDM 1.1, "As-Built Reconciliation of Piping Stress Report -- EG 44". This revision will result in an update of the support drawing to reflect comments on the S&L stress report. This was determined to be a random and isolated occurrence.

This observation resulted because the support drawing had not yet been updated to reflect the comments in the S&L Stress Report. This can be considered to be

[-~ ; attributed to lack of documentation during the design process.

v t

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Approved By Project Manager Date

(

M 0. %

Detroit Edison Company; 83021 duk3

'/

Independent Design Verification Program 7.7-93

====@ Observation MM'id Record Review imiimimimimmiimi Attachment A

\

Checklist No. PS-02-09 Revision No. }

Observation No. PS-02-02 Sheet g of 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments DCCo has reviewed the remaining sleeves. The only other sleeve this occurs on is in SX-13, which is a mirror image of SX-14, and thus used as a " typical" support detail. Per Sargent & Lundy document SLM No. 2110, dated April 22, 1983, corrective action is being evaluated to address the concern of this observation as it pertains to both SX-13 and SX-14. Since the problem is isolated and will be remedied, this will have no safety impact on the plant.

A memo has been written to the field to shim between the lugs (top and bottom) and the sleeve.

/D 3

( l Approved By Woject Manager Date k)& (). hrsg. IlfIlf63

/

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-94

tr#=ase Observation Mi*h' Id Record Review immimmmmmimili g Attachment A V

Checklist No, p g'-02 -03 Revision No. g Observation No. sheet of PS-02-03 7 7 Yes No Valid Observation y Potential Finding X (PFR No. N/A )

Closed X Comments Since the seismic movements are less than 1/10" at the spring hangers in both the RHR cooling and the RHR service water systems, the adequacy of hangers is not affected, and thus there is no impact upon design. Since these two systems are representative, there should be no impact on the safety of the plant. Cygna recommends, however, that DECO review the remaining spring hangers to verify this.

(v l

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l ys I( Approved By Project Manager Date U #64 W bl63 Detroit Edison Company; 83021 7.7-95 Independent Design Verification Program l

y==p=: Observation

[41 6'id immmilmimmmimi-Record Review Attachment A L,

Checklist No. PS-02-01. PS-02-06 Revision No. 3 Observation No. sheet of PS-02-04 7 7 Yes No Valid Observation y Potential Finding X (PFR No. N/A )

Closed X Comments For the two referenced hangers, the difference between the OBE and DBE loadings is small and there is sufficient margin in the load capacity of both hangers to ensure there will be no impact on the adequacy of the support design. For other hangers reviewed, the OBE loads were larger than the DBE loads so use of the OBE loads was l correct. The design and safety impact on the plant is therefore negligible. I Due to the conservative design procedures for hangers and the relative equality fs between OBE and DBE loads (see Observation ST-01-23), no further investigation is f warranted, r,

f Approved By roject Manager j r Date h- Q Y[ 03 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-96

!=c=m Observation

[fDilfU 111111111:illIlllllll1lll11:11 Record Review Attachment A V

Checklist No. PS-02-07 Revisi n No. g  ;

Observation No. PS-02-05 sheet p of p J Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Sargent & Lundy has issued a letter (Ref. 3.2) indicating that the design calculation has been revised to eliminate any reference to the brace. The design is acceptable without the brace. As this is considered to be an isolated occurence, this observation is judged to have no impact upon design or safety.

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l t .

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l Approved B Project Manager Date AA d.b A/s3 Detroit Edison Company; 83021 Independent Design Verification Program 7 7-97 1

?"=m Observation M it-R/d Record Review iiiiiiiiiiiiiiiiiiiiiiiiiiiiii Attachment A Checklist No. WD-02 Revision No. 3 sbaet of Observation No. PS-02-06 7 2 Yes No Valid Observation X Pe* intial Finding X (f A No. N/A )

I ssed X m

Comments DECO has reviewed the remaining sleeves. The only other sleeve this occurs on is in SX-13, which is a mirror image of SX-14, and thus used as a " typical" support detail. Per Sargent & Lundy document SLM No. 2110, dated April 22, 1983, corrective action is being evaluated to address the concern of this observation as it pertains to both SX-13 and SX-14. Since the problem is isolated and will be remedied, this will have no safety impact on the plant.

See Observation Record PS-02-02.

l g Pro Date Approved By% ject ManagL a- m ulule Detroit Edison Company; 83b21 7.7-98 Independent Design Verification Program

- - w= Observation L4f.?.'id Record Review nunnununinnininni Attachment A V

Checklist No.

PS-03 Revision No. j Observation No. pg p,3-01 sheet 7 of p Yes No Valid Observation x Potential Finding X (PFR No. N/A )

Closed X Comments Since this pentration is moderate energy, a circumferential pipe break need not be postulated, only a split. Thus, the plastic loads are not applicable, as stated in the design report.

Detroit Edison has reviewed the remaining stress reports for similar results. For the three other cases where failures are reported for the faulted condition, the lines were also moderate energy and were, therefore, acceptable. Cygna has reviewed selected reports and agrees with the Detroit Edison finding that there is no design impact.

Based on the information described above, no further investigation for this observation is warranted.

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Approved y Project Manager Date

k. 'Q. 1[.LT[$3 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-99

4

====ess Observation

[4(tilfd inninunnnninuninn Record Review Attachment A L] Checklist No. Revision No, g

PS-03 Observation No. sheet at ,

PS-03-02 7 Yes No Valid Observation x Potential Finding X (PFR No. 07 )

Closed (see PFR)

Comments Cygna is concerned that one load case in particular, with both bending moments in the same direction and both shear forces acting to increase the bending, may produce higher stresses.

Due to the potential design impact associated with this observation, a PFR has been written.

G(m.,

l l

l

, Approved By P Ject Manager Date MW Detroit Edison Company; 83021 7.7-100 Independent Design Verification Program

y =

Observation

[41 6'/d Record Review mmimmmmmumm Attachment A e)

Checklist No. Revision No.

ST-01 3 Sheet of Observation No. ST-01-01 7 7 Yes No Valid Observation y Potential Finding X (PFR No. N/A )

Closed X Comments Cygna's review determined the following:

a. Revision 1 of the " Project Structural Design Criteria" was issued on 12/1/81, seven years after completion of the design calculations;

b. Reference 2, issued 4/1/70, was considered by Sargent & Lundy to be the effective design criteria at that time;

c. Reference 3, issued 4/1/74, was considered by Sargent & Lundy to be the effective design criteria at that time.

Further review indicated that Reference 3.1 was a summary document of all the design codes and standards used in the RHR Complex structural design and that it was Sargent & Lundy's practice to define specific design criteria in each structural design calculation rather than a single design criteria document. This general practice has no impact on the design or safety of the RHR Complex. l

[

l l Approved By Project Manager Aa a4 Detroit Edison Company; 83021 Dahtas Independent Design Verification Program 7.7-101

e=~ Observation

[4M' fd immmmummuman Record Review 7, Attachment A Checklist No. " " " " '

ST-01 1 sheet p of Observation No. ST-01-02 7 Yes No Valid Observation X Potential Finding X (PFR No. 08 )

Closed (see PFR)

Comments The use of the 1.4 soil load factor with the most conservative soil pressure of 2.47 (consolidated after an earthquake) results in:

1.4 (2.47 + 1.75) = 5.9 Using the 1.7 soil load factor with end-of-construction condition gives:

1.7 (1.85) + 1.4 (1.75) = 5.6 fi Using the 1.7 soil load factor with the earthquake soil pressure of 2.39 + 0.35 =

V 2.74 results in:

0.75 [1.7 (2.74) + 1.4 (1.75)] = 5.33 Thus the design is considered adequate. However, since compliance with the ACI Code was not strictly followed, a Potential Finding Report was prepared.

l l

Approved By roject Manager Date

a. k U akin

'I Detroit Edison Company; 83021 7.7-102 Independent Design Verification Program

=r==d Observation MA 2 fii Record Review imiimimimmmmmi q Attachment A LJ Checklist No. ST-01 Revision No. 3 Observation No. Sheet of ST-01-03 7 7 Yes No Valid Observation y Potential Finding X (PFR No. N/A/ )

Closed X Comments Further review has shown that both the reservoir full and the reservoir empty conditions were analyzed. The reservoir full case was used in the computer analysis of the frame and the results factored by 1.709 to obtain the reservoir empty results.

The resolution to Observation ST-01-06 addresses the design of the basemat for these loads and discusses the interrelationship between original design loads, present calculated load and as-built capacity.

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Approved By roject Manage Date M ll Il N3 V '/

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-103

E===2 Observation Li L% TJ Record Review mmimmmmimmmi g Attachment A Checklist No. Revision No, ST-01 y Observation No.ST-01-04 Sheet g of p Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments In response to this observation, Sargent & Lundy provided the following explanation:

The thermal gradient due to the site ambient temperatures (70 F and -18 F) is the critical design case for the RHR Complex. The structural design did not consider the higher temperatures in the vicinity of the spray headers, which are designed for 125 F, due to the location of the spray headers and the nature of the structure.

The critical thermal gradient occurs in the winter when 'the ambient temperature falls below zero, and the temperature in the spray headers is not expected to be higher than 60*F to 70 F. This is consistent with the design thermal gradient.

{'s During the summer, the temperature of water in the spray headers would be 125"F.

However, with the cooling tower fans working, the surface temperature of the concrete walls is not expected to exceed 100 F giving a thermal gradient of 30 F to 40*F.

Cygna considers this response to be adequate justification for the design thermal gradients, i

}

Approved By Pr ect Manager

!'i -

ak Detroit Edison Company; 83021 Date ul 63 Independent Design Verification Program 7.7-104

- =

Observation MitH fd mmimmmumummi Record Review Attachment A V

Checklist No.

ST-01 Revisi n No. )

Observation No. Sheet of ST-01-05 7 7 Yes No Valid Observation y Potential Finding X (PFR No. N/A )

Closed X Comments Further review has shown that the structural model for Frames B and D was not used to design the cooling tower cylinder, floor slabs or external walls below grade.

The overall lateral loading (e.g., seismic or tornado) is effectively resisted by the shear walls. The cooling tower modeling is approximate but it will not affect the design of the frames.

Based on the above information, this observation is closed and has no impact on plant safety.

O A supplemental review showed that the cooling tower model used in the frame analysis b has the following features:

• Rigid boundary conditions at the tower / roof slab connection properly reflect the relative rotations and translations, in that the tower and building shear walls are very stiff.

• Design moments calculated for a supporting column compare favorably with a simple hand calculation.

i e Member properties in the tower model incorporate a missile shield which was later eliminated. Including these properties does not significantly increase j the relative stiffness of the tower. Including the mass of this proposed l

shield in the model is conservative since it tends to increase the axial column l

loads.

e Model developed to determine the moment distribution in the frame.

In conclusion, the frame model is acceptable to perform its intended function.

l (O Approved By roject Manager Dat IUY G**]- 0lll E Detroit' Edison Company; 83021 Independent Design Verification Program 7.7-105 l

Observation MM' Ta Record Review mmmimimmiimimi Attachment A Checklist No. ST-01 Revision No. }

Observation No. ST-01-06 Sheet p of g Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review of Reference 3.3 indicates that the reinforcing steel placed in the basement in accordance with the design drawings provides adequate load bearing capacity to withstand the maximum applied moment. As a result, there is no design or safety impact on the RHR Complex Structure, ,

Since the normal design process has adequately addressed this observation, an expanded review is not warranted.

/7 Further review of Reference 3.1 shows that the original calculation did address

() design moments at the wall /basemat intersection. This was documented on Sheet 12 of 21 which states, "For sections with moments bigger than the allowable 302 K-ft, the extra steel has been provided to increase the mat capacity (#110 6" has been used for these sections)." The design capacity of #11 0 6" is 567 K-ft for a 4' section.

In that calculation package, the maximum wall /basemat moments ranged from 311 to 401 K-ft. These moments are less than 75% of the ultimate design capacity. Revision 1 of Reference 3.1, dated 6/30/83, calculates a maximum wall moment of 431 K-ft. This wall-to-basemat moment is 7% larger than the basemat-to-wall moment originally calculated, but is still less tnan 80% of the ultimate design capacity.

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[

bh t Approve By Project Manager Date l

l}b& 0. fld']. .

UU

! Detroit Edison Company; 83021 7.7-106 i Independent Design Verification Program

m - - -- = Observation

[4 M 'In Record Review mimimmmimimimi Attachment A Checklist No. Revision No.

ST-01 1 Sheet p of Observation No. ST-01-07 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Because of the small reinforcing steel stresses (5-10 ksi) produced by the thermal loadings (thermal design gradient, AT = 70*F), there is insignificant design impact. For future traceability, Reference 3.1 has been revised to state that these small thermal stresses were evaluated and determined to be insignificant.

Due to the small thermal stresses, this observation does not warrant further investigation.

To evaluate the effects of thermal loads, Sargent & Lundy performed a cracked

/7 section analysis using their TEMCO program. Their revised calculation 1.21.5, dated V 6/22/83, shows that the impact of thermal grad 1ents on the cooling tower shell design are small. For a 3' section reinforced by 0.37 sq. in, of tensile steel per foot, an 80 F thermal gradient results in the following tensile reinforcement stresses (fs ) at the critical location:

Dead load + tornado f s

= 3.58 ksi Dead load + tornado + temperature fs = 12.5 ksi

. The combined stress (12.5 ksi) and change in stress (8.7 ksi) are much less than the 54 ksi allowable strength of the reinforcement. In addition, it should be noted that an 80 F thermal gradient is conservative for this tower which is open to the outside environment. Such a thermal gradient would be especially conservative during a tornado, (o

) Date LJ G Approved By P,4oject Manage % aluh>

Detroit Edison Company; 8302[

Independent Design Verification Program 7.7-107

g= = = Observation MM'In Record Review g immmmimimimimi Attachment A O

Checklist No. ST-01 Revision No. }

Observation No. ST-01-08 sheet p of 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Because of the small reinforcing steel stresses (5-10 ksi) produced by the thermal loadings (thermal design gradient, AT = 70 F), there is insignificant design impact. For future traceability, Reference 3.1 has been revised to state that these small thermal stresses were evaluated and determined to be insignificant.

Due to the small thermal stresses, this observation does not warrant further investigation.

(7 To evaluate the effects of thermal loads, Sargent & Lundy performed a cracked d section analysis using their TEMC0 program. Their revised calculation 1.21.5, dated 6/22/83, shows that the impact of thermal gradients on the cooling tower shell design are small. For a 30" section reinforced by 0.79 sq. in. of tensile steel per foot, an 80 F thermal gradient results in the following tensile reinforcement stresses (f3 ) at the critical location:

Dead load +' tornado fs = 33 ksi

Dead load + tornado + temperature fs = 43 ksi l

The combined stress (43 ksi) and change in stress (10 ksi) are well within the 54 ksi allowable strength of the reinforcement.

/O

\ < Approved By Pr ect Manager Dat h LV). Ilj {l 6)

Detroit Edison Company; 83021 7.7-108 Independent Design Verification Program

!=-+====

Observation

[4 %' 2fd Record Review uniumninmuunnnn Attachment A O Checklist No. ST-01 Revision No. 3 Observation No. Sheet of ST-01-09 7 7 Yes No Valid Observation X Potential Finding X

(PFR No. N/A )

Closed X Comments Further review of Reference 3.2 indicates that the reinforcing steel placed in the concrete in accordance with the design drawings provides adequate load bearing capacity of the foundation wall to withstand the maximum applied moment. As a result, there is no design or safety impact on the RHR Complex structure.

Since the normal design process has adequately addressed this observation, an expanded review is not warranted.

A supplemental review of the original design drawing (Reference 3.3) shows that the m specified reinforcement has an ultimate moment capacity of 515 K-ft. This results

) in the following design margins at the critical wall section:

Original design moment 19% margin Original design moment + thermal 7% margin

( Approved By Pro pct Manager Date j e k

. Detroit Edison Company; 8302i 7*7-109 Independent Design Verification Program

_ . - - . . _ . _ _ - . _ _ _ . . _ _ - _ _ _ ._ - _ . - _ _ _ .~ _ __

==

= Observation bi14lfd immmmmmmmm Record Review Attachment A V

Checklist No. ST-01 Revision No. p Observation No. ST-01-10 Sheet p of p i

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments An apparent moment is applied to the slab in the load input. Source or calculations of , joint loads were not found.

The gravity loading of the tower to the slab was applied by an area times density calculation. The area used in the section properties is approximately 26% less than the actual area. This could result in lower tower loads and an unconservative design.

5 Further review confirmed that the area was incorrectly specified in the calculations (References 3.2 and 3.3), however, the correct area was used in the computer run (Reference 3.1).

Based on the above, this error is considered isolated and has no design or safety impact on the RHR complex structure. Subsequent review by Cygna indicated that Sargent & Lundy2 has revised the original calculations to clarify that the correct area (i.e., 66 ft /ft) was used in the computer analysis.

Approved By Project Manager Date

h. WL llII03 Detroit Edison Company; 83821 Independent Design Verification Program 7.7-110

m x Observation

[il i'fd iiiiiiiiiiiiiiiiiiiiiiiiiiiiii Record Review Attachment A Checklist No. ST-01 Revisi n No. g Observation No. ST-01-11 Sheet of p p Yes No Valid Observation X

Potential Finding X

(PFR No. N/A )

Closed X Comments Further review by Cygna indicates there is no inpact on the design or safety of the RHR Complex structure because the FSAR (Refere.nce 3.2) contains a commitment that the wall will be heated to prevent freezing. Consequently, this is considered an invalid observation.

\

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l A pprove d ger Date

' y Project a. Mahn 4bc/e>

Detroit Edison Company; 83021 Independent Design Verification Program 7 7-111

Mrrr Observation L4 Dilfd Record Review immmmmummnmi Attachment A Checklist No. ST-01 Revision No. 3 Observation No. Sheet p of ST-01-12 p Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X

- Comments Per Reference 3.1, the governing load case for the basement is with the reservoir empty with full hydrostatic pressure. The vertical loads due to overturning at the l foundation wall are less than the gravity loads with the reservoir full.

Based on the above information, the design loads are conservative and there is no design or safety impact as a result of this observation.

Further Cygna review confirmed that the foundation wall loads (vertical, shear and overturning moment) were not applied on the finite element model due to the f-) following considerations:

a) Due to the higher stiffness of the rock on which the complex is founded, the vertical load from the wall will not be distributed into the base mat.

b) Horizontal shear from the foundation walls has no effect on the bending moments in the mat.

c) Sargent & Lundy calculation #1.15.10 evaluates the shear walls as individual components acting to resist in-place shear and overturning moments. In the N-S direction, the vertical gravity loads are always greater than the vertical gravity loads (110.13 ksf vs. -7.52 ksf at the corner of the wall).

With respect to itam c), it should be noted that analyzing the walls as components acting individually is extremely conservative when considering overall structural stability. Subsequent calculations performed by Sargent & Lundy confirm that when the RHR Complex Building is considered as a unit, the vertical gravity loads are always greater than those caused by the overturning moment. For the E-W earthquake, the dead load stress is 7.69 ksf; the corresponding seismic stress is 15.09 ksf.

Approved By Pr lect Manager Date

$/V" , //ft/f63 Detroit Edison Company; 83021 <

Independent Design Verification Program 7.7-112

er=me=a Observation (41dt'f]

nmummummmunn Record Review Attachment A O

Checklist No. ST-01 Revision No. 7 Observation No. ST-01-13 sheet 2 ' 2 Yos No Valid Observation X Potential F!nding X (PFR No. N/A )

Closed X Comments Further review of Reference 3.1 indicates that the reinforcing steel placed in the beams in accordance with the design drawing will provide sufficient capacity to withstand the maximum loading, including the axial loads. As a result, there is no design or safety impact on the RHR Complex structure.

The moment capacity of the beam actually increases slightly (from 1501.1 K-ft to 1507.5 K-ft) when axial loads are considered.

Since the normal design process has adequately addressed this observation, an expanded review is not warranted,

(]/

sv Approved By oject Manager Date

~ '

h lof f(filj $)

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-113

E;; m ses Observation MN fd mimmmmmmmmti Record Review Attachment A N.j Checklist No. Revisi n No.  ;

ST-01

^

Sheet p of p Observation No. ST-01-14 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review indicates that the finite element model for the deep beam shear wall was used to analyze for vertical loads only. A separate seismic analysis was used to determine the horizontal shear loads on the wall. These seismic shear loads were checked in combination with the stresses in the wall due to vertical loading. The deep beam shear wall was found to be adequate for the combined horizontal shear and vertical loads. For future traceability, Reference 3.4 has been revised by Sargent

& Lundy to show how the seismic shear loads were considered in the design of the shear wall.

^ Based on the above information, this observation does not warrant further

[b investigation.

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( ) Approved By roject Manageg Date

'd#f. //!kf$3 Detroit Edison Company; 83b21 l 7.7-114 .

Independent Design Verification Program

pre ==si Observation L4L %'TJ Record Review 7, nmummmunmmun Attachment A O

Checklist No. Revision No.

ST-01 3 Observation No. Sheet p of ST-01-15 3 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review indicates that the reinforcement of column SE will provide the l required load bearing capacity including the additional axial loads (Reference 3.1). No additional reinforcement is required in the basemat to accomodate the punchout shear stresses since the basemat is founded on rock and these stresses will be negligible . There is, therefore, no design or safety impact on the RHR Complex structure.

Since the normal design process process accomodates this observation, an expanded review is not warranted.

Review of additional calculations prepared by Sargent & Lundy (Calc. #1.14.7) document the following:

LOAD IN KIPS OR FT-KIPS l Column Line 5&9 F E D C B l

DL x 1.4 933 1234 1337 796 564 EQUIP. x 1.4 108 117 132 230 130 LL x 1.7 543 406 387 353 202 j SEISMIC x 1.9 t 213 t 121 0 t 101 t 212 l TOTAL ULT. LOAD 1797 1878 1856 1480 1108 l

MAX. APPLIED M0 MENT 5391 5641 15472 13502 7672 1

2 0.1(t) (Load) Governs

! o Actual Moment Governs k Approved By Pr act Manager j Date

<D 0# 3 Detroit Edison Company; 83021 7.7-115 Independent Design Verification Program

=;2pgqcs Observation

[4 (*ii f a Record Review immmmilimilmiimi Attachment A O Revision No.

Checklist No. ST-01 }

Observation No.ST-01-15 Sheet 3 of

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments From PCA Ultimate Strength Design of Reinforced Columns:

0P = 2000 K => M = 1959 K-ft Pu = 1500 K => Mu = 2173 K-ft Therefore, it can be seen that the axial compression in tne columns, including the additional axial loads due to shear wall overturning moments, is less than the column capacity as designed.

Furthermore, the reinforcing referred to above was installed in accordance with j Sargent & Lundy drawings issued to the field for construction.

,f- Approved By P oject Managep Date k 0 ?!4'] 5lI/f63 Detroit Edison Company; 83b21 ,

7._i-116 Independent Design Verification Program

R:r= Observation M W fa

,illiniliiiiiiiiiiiiiiiiiiiiii Record Review Attachment A V

Checklist No. ST-01 Revision No. 1 Observation No. ST-01-16 sheet 7 of 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

' Closed X Comments e Further review of Reference 3.2 indicates that the reinforcing steel placed in the concrete in accordance with the design drawings provides adequate load bearing capacity of the foundation wall to withstand the maximum applied moment. As a result, there is no design or safety impact on the RHR Complex structure.

Since the normal design process has adequately addressed this observation, an

, expanded review is not warranted.

(~%

(j Revised calculation 1.15.10 shows the design moment for the foundation wall at grid 6 to be 260 K-ft, not 520 K-ft. This di.fference is the result of dividing the gross moment by the bay spacing (33'-3") rather than an effective width. Using the

-' effective width is appropriate for framing in the computer model, but not for the continuous foundation wall.

In calculating the load on the frame, the tributary width of 33.25' was used. In

, calculating a unit moment to be applied to the wall, the total moment was divided by the effective width of a T-section, which is 16.5'. Therefore, the unit moment

. applied to the base of the wall was extremely conservative. The capacity of the wall is sufficient for the design moments calculated and significantly greater than t

that required. The capacity of the wall is based on the reinforcing steel installed in accordance with the design drawing.

At Cygna's request, Sargent & Lundy tabulated the loading information used for the RHR Complex frame analyses. This table shows that the correct tributary width was used in all cases. Cygna verified this by spot checking two of the seven calculation books referenced.

/3 ij

' Approved By P Date kject Managerstd.k uMe>

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-117

== -

Observation

[41C fn Record Review n Attachment A U Checklist No. Revision No.

ST-01 g Observation No. Sheet of ST=01-17 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments The techniques for obtaining an earthquake spectra for the RHR Complex structure was reviewed and accepted as a reasonable design basis event in the Fermi 2 FSAR (Reference 3.2). This observation is, therefore, considered to be invalid because it has been previously addressed and accepted through the FSAR review process.

O LJ

{

I Approved By Pro ct Manager Date

(.

hf ~LYx).

T Af2.S/B3 Detroit Edison Company; 83021

• 7.7-118 Independent Design Verification Program r

I. l } e

=_g -

Observation M ejlTA Record Review

- immimiimmilmilmi O Attachment A O Checklist No. "*" " " '

ST-01 n Sheet of Observation No. ST-01-18 9 Yes No Valid Observation X Potential Finding X

(PFR No. N/A )

Closed X Comments Further review resulted in the following conclusions:

• Pressure grouting is an ineffective technique for significantly minimizing the seismic amplification at this particular site, due to the small size (<2.0 in.)

and depth (<20 ft.) of the fracturing.

The shear wave velocity of the fractured foundation material is approximately 7600 fps, which is considerably higher than the 3500 fps value specified in Section 3.7 of the NRC Standard Review Plan, to define rock sites.

O Q Cygna considers this foundation material to be seismically sound without pressure groating.

Approved By Project Manager Dat

'l/t M 83 Detroit Edison Company; 8302f Independent Design Verification Program 7.7-119

M Observation Mii fd Record Review immimmimimmimi Attachment A Checklist No. ST-01 Revision No. 0 Observation No. ST-01-19 sheet 2 *'

2 Yes No Valid Obst, sation X Potential Finding X (PFR No. N/A )

Closed X Comments Further Cygna review determined that the effects of the mass of the water in the reservoir (both rigid and sloshing) on the response of the RHR Complex to seismic loading will be minor. The natural frequencies of the structural model change by 3%

or less when the mass of the water is included. Based on these results, there will be no design impact, For future traceability, Reference 3.1 has been revised by Sargent & Lundy to state that reservoir water was considered with respect to the seismic loadings and determined to be insignificant.

Due to the small effect of the water and existing design margins in the RHR Complex structure, this observation does not warrant further investigation.

)

%J l-i l

l l

i Date

- Approved ) By PLoject Manageras%

v V 4ds2 E

Detroit Edison Company; 83021 7.7-120 Independent Design Verification Program

y= -

Observation N W fa Record Review immmmmmiimimii Attachment A i

Checklist No. Revisi n No.

ST-01 3 Observation No. Sheet of ST-01-20 7 7 Yes No Valid Observation x Potential Finding X (PFR No. N/A )

Closed X Comments Further Cygna review determined that the nature frequency for the horizontal excitation of the cooling tower supported on the slab is 27.6 Hz. The acceleration corresponding to this frequency is almost equal to the rigid value. Consequently, shear forces from a horizontcl earthquake are insignificant. Based on this information, there is no design or safety impact on the RHR Complex structure.

A subsequent review by Cygna confirmed that Sargent & Lundy has reviewed References 3.1 and 3.2 to document the minimal effect of the cooling tower frequency for a horizontal excitation in the original design calculations.

O G

k Approved By P ect Manager Date 0% fB3 Detroit Edison Company; 83021

. Independent Design Verification Program 7.7-121

- -- e Observation M M'In Record Review p Attachment A V Revision No, Checklist No. ST-01 y Observation No. ST-01-21 Sheet g of g Yes No Valid Observation X Potential Finding X (PFR Nc. N/A )

Closed X Comments Further Cygna review determined that tornado loading governs the design of the slab

. supporting the cooling tower. The slab design includes gravity loads plus all up

. and down loads on the periphery. of the tower / slab connection. Consequently, there is no impact on the design of the RHR Complex structure as a result of this observation.

- A subsequent followup review by Cygna confirmed that Sargent & Lundy has revised References 3.1 and 3.2 to indicate earthquake loads were considered and detennined to have no affect on the results of the original design calculations. Based on this information, no further investigations were warranted.

Subsequent review by Cygna indicated that the moment applied to the slab to account for tornado wind loading the cooling tower shell was 2134.9 K-ft. The moment at the base of the shell from a horizontal earthquake was calculated to be 1255 K-ft.

Applying a load factor of 1.0 to the tornado wind loads and 0.75 x 1.87 = 1.4 to the seismic loads results in the following:

Mt - 2134.9 > 1.4 x MEQ = 1757 K-ft Thus, the tornado wind loading guverns the design.

Approved By P Ject Manager Dat O. h -

d43 Detroit Edison Company; 83021 7.7-122 Independent Design Verification Program

. - - _ _ - - _ . _ - . _ . ~ . - . - . -. - _ - -

Observation ine];'Ta Record Review

'"""""""'""""""" Attachment A Checklist No. Revision No. g ST-01 Observation No. Sheet p of p ST-01-22 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Because the statement made in the Fermi 2 FSAR, Section 3.7.1.6, directly addresses this issue and indicates that sufficient concern does not exist to perfonn the rock / structure interaction analysis, this observation is considered invalid.

O

1. Approved By P oject Manager Date h k LV4v

~

28 03 i

Detroit Edison Company; 83021 7.7-123

! Independent Design Verification Program

[

i __

_ _ _ _ . . ~ . _ _ _ . _ _ . ..._ __. _ . _ ..._____..._ _____ _.._. _ __

-w -

Observation

[4 Dfilfa Record Review nmimmummimmm Attachment A U

Checklist No. Revision No, ST-01 y Sheet p of Observation No. ST-01-23 g Yes No Valid Observation X Potential Finding X

.. (P FR No. N/A )

Closed X Comments Further Cygna review has shown that the accelerations having a fundamental frequency of 9 Hz (approximately equal to that for the RHR Complex, see Reference 3.1) using the attached Housner ground spectra would be as follows:

OBE (2% damping) = .26 x (*,

) = .14 SSE (5% damping) = .17 Therefore OBE and SSE (DBE) accelerations in the RHR Complex could be expected to be p

V nearly equal.

In the seismic analysis, Detroit Edison used 0.08% horizontal acceleration for OBE with 2% critical damping and 0.15g horizontal acceleration for DBE with 5% critical damping. The ratio of the acceleration values for DBE and OBE is (0.15 - 0.08) 1.875. Theoretically, at resonance the specified amplification factor is 1/(2B) where B is critical damping. Hence, at resonance the ratio of amplification factors for OBE with 2% damping and DBE with 5% damping is (0.05/0.02)

= 2.5. It is then theoretically possible to have DBE spectrum value for 5% damping less than that for OBE value for 2% damping, especially at or near resonance condition.

For the example cited, the acceleration value at T = 0.01 sec. for DBE case is for 5% structural and 1% equipment damping whereas acceleration value for OBE case is for 2% structural and 0.5% equipment damping; hence, the OBE value is higher than the DBE value.

The damping values used in the seismic analysis are in agreement with the tabulated values in the FSAR. Furthermore, the theoretical justification for OBE spectral values greater than DBE values is based on sound engineering.

A l Approved By roject Manager Date 0dse ul0ln i '

Detroit Edison Company; 83k21 7.7-124 Independent Design Verification Program

s-- -

Observation M Dilfd Recor'd Review

,m Attachment A N

Checklist No. ST-01 Revision No. O Observation No. Sheet p of g ST-01-24 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments The embed plate (Detail 9) was analyzed with Cygna's in-house program (EPLATE),

which is similar to Sarge-t & Lundy's "SLSAP". The full maximum load (P, Mx or My) was applied to the model in one nonlinear run. It was found that the stud loads and plate stresses agreed with the extrapolated and superimposed results from SLSAP withir. 5 to 10%. Therefore, there is no significant design or safety impact resulting from the extrapolation of data from the nonlinear analysis on the design of the RHR Complex structure.

O'

%)

Date

" Approved By Project Manager n y

dek a a. 4 dea I i Detroit Edison Company; 8302I 7.7-125 Independent Design Verification Program

Observation L4M' fd Record Review iiiilliiiiiiiiiiiiiiiiiiiiiiii Attachment A O

Checklist N Rnision No.

ST-01 0 Observation No. ST-01-25 sheet 2

' 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments The computer model is thicker at Element #71 (1.0") compared to Element #79 (0.5"). -While the bending moment is larger at Element #71, the resulting bending stress at Element #71 is less than that given for Element #79.

Based on the above information, this is an invalid observation.

O 1

t 4

Approved By P r? ject Manager Date skk

~

k ) 8. L a o i Detroit Edison Company; 83021 7.7-126 Independent Design Verification Program

=

Observation Mid 2 fU Record Review Immummuumunmi Attachment A V

Checklist No.

ST-01 Revision No. 7 Observation No. Sheet p of p ST-01-26 Yes- No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review revealed that the use of the full effective area instead of the effective area based on overlapping cones combined with the interaction formula which considers all loads (P, Mx, My, V) will produce conservative results.

Therefore, this general practice has no impact on the design and safety of the plant.

Sargent & Lundy calculation #1.25.1 determines the maximum tension, shear and bi-axial moments that can be applied to a unit length of a standard embedment place

/' detail. Three separate details are evaluated. These maximum loads are calculated by considering each different load individually and then imposing the following interaction equation:

T V M M x y T

+

V

+

M

+

M

< 1.0 -

a a xa ya where the denominator of each term is the maximum allowable load for each load considered individually.

l In determining Ta , the calculation considered the effect of overlapping cones per

ACI 349-76. However, if the consideration of the studs as fully stressed limited Ta , the calculation then considered the studs as a group and calculated the T based l on a larger shear zone and the correct assumption that the studs were not fuliy l

stressed.

Subsequent calculations by S&L also examined the case for the maximum allowable l

attachment loads applied at the minimum' allowable spacing on the embedment plate.

These calculations confirmed that the interaction equations are valid.

l Approve 3y Project Ma Date A a. 6na er uhin i'

Detroit. Edison Company; U83021 7.7-127 Independent Design Verification Program

= Observation

[.41rHfd Record Review Immmmmmiimmm Attachment A i I V

Checklist No. R *"l88 " N -

ST-01 n Sheet of Observation No. ST-01-27 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments This observation is invalid in that it leads to conservative results.

Cygna's review revealed that the interaction formula based on the capacities of the stud and plate was never meant to give the actual stresses at any one point but to provide a conservative tool for determining the adequacy of the embed plate for given loads. Cygna performed independent calculations which show that the method is indeed conservative.

n a Date Approved 4 Bybroject Q- Mana%g v hk /

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-128

Observation

[4(*i;'fA Record Review nunninnunnununin

, Attachment A t

a' Checklist No. ST-01 Revision No. 7 Observation No. Sheet p of ST-01-28 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A -)

Closed X Comments Based on' Cygna's full review of the RHR Complex, this oversight was determined to be a random and isolated occurrence. The bending moments in the frame members are dependent upon relative flexural stiffnesses. A small (10%) variation in axial stiffness of the wall member will have an insignificant effect on moment distribution. Therefore, there is no impact on plant design or safety.

(3 V

l i,

O \

Approved By Pr ject Manager Date h~ II I O I Detroit Edison Company; 830$1 7*7-129 Independent Design Verification Program l

r

F 9 eq=2 Observation Mej TJ Record Review mmimimmmummii Attachment A U Checklist No. Revision No, ST-01 g Observation No* Sheet of ST-01-29 7 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Further review revealed that in situ measurements indicate a rock shear wave velocity of 7600 ft/sec, whicTis considerably higher than the 3500 ft/sec value specified in NRC Standard Review Plan Section 3.7, to define rock sites. No significant seismic site amplification is expected for rock sites with a shear wave velocity > 3500 ft/sec. Discussions with Detroit Edison personnel who had participated in the pressure grouting decision revealed that the upper regions of the rock foundation were grouted in order to help counter a potential bouyancy problem with the RHR complex during the design flood. It was planned to resist these bouyant forces by embedding rock anchors into the grouted region. Later p design evolutions, especially those related to tornado loads, resulted in a structure with sufficient dead weight to prevent uplift during the design flood.

V Rock anchors therefore are not needed in the current design. Consequently, this observation does not impact the design or safety of the RHR complex structure.

b) Approved By Project Manager Date 014 0. bst u 4k5/83 Detroit Edison Company; 83021 Independent Design Verification Program 7.7-130 f

_. , , - . . - .,y ,. _ _ - - . _ e , ,., ,. ... _ , - , . _ , , - . ,,_o, _ , . - . - --

Observation

@h Leh' fa Record Review g-g lli1111llilll1ll1llli111ll111 Attachment A V

Checklist No. WD-03 Revision No. 7 Observation No. Sheet of ST-01-30 p 7 Yes No Valid Observation X Potential Finding X (PFR No. )

Closed X Comments Further Cygna review indicates that Deviation Disposition Requests (DDR's) have documented the generally poor concrete workmanship (voids, honeycombing, patchwork, etc.) in the RHR complex. The DDRs, issued prior to the Cygna review, indicate corrective action was taken with subsequent verification of the completed disposition. Detroit Edison will also perform regular maintenance inspections of the RHR Complex in compliance with NRC Regulatory Guide 1.127.

Based on this subsequent information this observation has been addressed by the normal design / construction process. The impact on design and safety is therefore OU/

negligible.

f g.

j Approved y Project Manager Date W $

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-131

=-r Observation (diej fa Record Review itmitmmimiimimmi Attachment A J

Checklist N - WD-03 Revision No. 3 Observation No. Sheet of ST-01-31 7 7 Yes No Valid Observation .X Potential Finding X (PFR No. N/A )

Closed X Comments Based on review of the beam structural drawings, there is no design or safety impact since the exposed rebar is not part of the main reinforcement and the void with plywood exposed occurs in the beam's tension zone. As indicated in the attached Deviation Disposition Request No. C-11050, Detroit Edison will remove both the plywood and exposed rebar, will repair the concrete at these locations, and will perform an evaluation of the design impact.

Detroit Edison has completed the evaluation of DDR No. C-11050, as documented in the

[-)' attached letter (EF2-64,261 dated 9/14/83). Cygna considers this closure to be b - complete and adequate.

f Approved By Pr ect Manager Date

'~ -

a. & 6h3 Detroit Edison Company; 8302$

7.7-132 Independent Design Verification Program

I 1

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.io.. ~ m e 1 7.7-133

Detroit

~

• 2000 Second Avenue

.[ ) Detroit. %chigan 48226

\ / (313) 237-8000 v

$\ EF2 - 64,261 b( g- -September 14 , 1983 PIS No. X22-03 CYGNA Energy, Services 101 California St. - 9th Floor San Francisco, CA 94111 Attention: Mr. Ted Wittig

Reference:

Enrico Fermi Atomic Power Plant - Unit 2

1. CYGNA independent design verification project -

Observation No. ST-01-31

Subject:

Exposed Piece of Wood and Rebar in RilR Complex-South Cooling Tower, Beam D

_(

L Gentlemen:

In response to your request to Mr. W. M. Street; enclosed is a copy of EF2 - 63,416 which resolves the concerns of observation in reference 1.

Sincerely, gl -

• M. G. Sigetich, Asst. Dir.

Project Design e=-

Written by: Y. N. AnandA MGS/YNA/jlj Enclosures cc: W. M. Street A/C Divisic. File NOC Approval Control RECElVED i

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7.7-135

- Detroit.

%<c w me==== n m--m -

./u a ; u . : ...4.m. ,

' gg ENRICO FERMI PROJECT - UNIT 2 '

Architectural / Civil' Engineering July 6, 1983 -

EF2 - 63,416 PIS No. X22-03

-Memo To: File From: Y. N. Anand .

Systems-Engineer /

Reference:

1. CYGNA Independent Design Verification Project - Observation No. ST-01-31 2.: DDR C-31050

Subject:

Exposed piece of wood and rebar in RHR Complex South Cooling Tower Beam D

'DDR C-11050 (Ref 2) was issued in response to CYGNA Observation (Ref 1) concern.

j] A piece of 1/4" diameter bar (rebar support) about 24" long and a triangular

'G  : piece of wood, longest side approximately 7" were removed from the surface of the beam-(photocopy enclosed). The indented concrete surface has been patened up.

'It has L)een ' determined that the structural strength of the concrete beam bas not been' impaired. No further work is required.

YA/cb

t. 'cc: .

W .M. Street

.k. C. Anderson M. C. Sigetich WW5AWa$}/lD?'Ufl},0lO UOC Approval Control .

A/C Division File d

l 7.7-136

1C

s. 5: ,

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EXPOSED PIECE OF WOOD AND REBAR RHR COMPLEX SOUTl! COOLING TOWER BEAM D 15" ruler in background for comparative value t

l

[

l l

l 7.7-137 1

Observation biM' fd Record Review nmmmmimmimmil Attachment A

() Checklist No.- WD-03 Revision N

• 0 Observation No. ST-01-32 Sheet g of 7

Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Upon request by Cygna, Sargent & Lundy revised Reference 3.2 to include the cantilevered effect of the entrance stair slab on the RHR Complex structure. The resultant loads from the entrance stairway produced stresses which were within 1.07.

of the allowable stresses.

Based on this information, Cygna has determined that an insignificant impact on

, design and safety of the RHR Complex has resulted from this observation. No further investigations were deemed to be warranted.

l Approved By Pro' ct Manager Date ek V Sa> /

. Detroit Edison Company; 83021 7.7-138 Independent Design Verification Program

l 1

l r.z Observation i M r]lfd Record Review l nunninininninunnn Attachment A V

Checklist No. ST-01 Revision No. g Observation No. Sheet of ST-01-33 7 7 Yes No Valid Observation x Potential Finding X (PFR No. 10' )

closed (see PFR)

Comments A review of all structures analyzed by SLSAP Plate and Shell Elements will be required to close.this observation. Since this misinterpretstion of SLSAP computer output results has a potential safety impact on the plant, a Potential Finding Report has been prepared.

{N) l l

l l

l

[

i.

l O

l q'j Approved By ProMj ct Mcnagerdfor Date+ 4r/s3 v '

! Detroit Edison Company; 83021 Independent Design Verification Program 7.7-139

= --

m Observation

[*hIM id Record Review nunmummmunnmi Attachment A (vl Checklist No. FF-Ol Revision No.

Observation No. Sheet of EE-01-01 7 7 Yes No Valid Observation y Potential Finding y (PFR No. N/A )

Closed y Comments Review of circuit breaker Quality Control records verifies that an ITE Type K-600S circuit breaker was purchased, tested, and installed in the switchgear. This circuit breaker has an interrupting rating of 30,000 amps which satisfies the assumption made in the design calculation (Reference 3.3).

Since the interrupting rating of the breaker does exceed the maximum value of fault current, this observation has no design or safety impact on Fermi 2 and does not warrant further investigation.

CN Supplemental information provided by Detroit Edison and subsequently reviewed and d verified by Cygna indicates a minimum 600-ampere frame size for all circuit breakers in the switchgear. This requirement was noted on Fermi-2 drawings 6SD721-2510-1 and 6S0721-2510-5 and was satisfied by the switchgear manufacturer with the selection of 600-ampere frame ITE Type K-600S circuit breakers. At the time of manufacture of the switchgear, a 600-ampere frame was synonymous with a 30,000 ampere interrupting rating. Since these breakers have a 30,000 ampere symmetrical instantaneous and a 22,000 ampere symmetrical delayed trip interrupting rating, the breakers are adequately sized to clear the maximum fault currents which might occur on any safety-related 480 volt bus. In preparing the original response, Cygna reviewed the calculated values of fault current for each of the safety-related 480 volt switchgear to ensure the design on Fermi-2 was adequate with respect to circuit breaker interrupting current ratings, (n

N_)

i Approved By Pr lect Manager Date u - .

Detroit Edison Company; 83021 Independent Design Verification Program 7.7-140

rM Observation

>= W fd Record Review j- immumimmmimmi Attachment A V

Checklist No. EE-01 Revision No. 1 Observation No. EE-01-02 sheet 2 of 2 Yes No Valid Observation X Potential Finding X (PFR No. N/A >

E Closed Comments The discrepancy consisted of a larger conduit size being installed than the size specified on the cable tray identification drawings. Consequently, this observation has no design or safety impact. This discrepancy in design information was considered as a random and isolated occurence.

Cable tray identification drawings are used by Detroit Edison as a construction aid to identify embedded conduit and cable trays and to inform construction personnel of their intended use. As such, they help bridge design information contained on the cable routing schedules with detailed Plan-Electrical drawings. Plan-Electrical drawings show physical locations for cable trays, raceways, conduit, sills, sleeves, etc., in the Fermi-2 plant. For example, Plan-Electrical drawings would generally

\. specify embedded conduit size but not call out the assigned identification number of each conduit run. For embedded conduit, this information is provided on the Cable Tray Identification drawings which also contain the one-line physical routing information described on the cable routing schedules.

For the conduit in question, the size was correctly noted on the Plan-Electrical drawings, 6E72IN-28 and 6E72IN-32 and was consistent with information on the concrete framing detail structural drawing 6C72IN-2311. Detroit Edison acknowledged that since the Cable Tray Identification drawing did indicate a size for the embedded conduit, the drawing should be revised to be consistent with the Plan-Electrical and detailed structural drawings.

Prior to Cygna's review, Field Engineering Memorandum (FEM) El-3460 (5/6/82) was generated which requested permission to assign identification numbers for the

_ control conduits to the cooling tower fan motors (motor control center). In making this request, it was noted on El-3460 that the Cable Tray Identification drawings, 6E72IN-80 and 6E721N-82, did not indicata the correct size or quantity of embedded conduit. The engineering response to El-3460 was to run the control conduit with the power conduit for the embedded portion and revise the Cable Tray Identification drawings to be consistent with the Plan-Electrical drawings. Since the Plan-i Electrical drawings were always in agreement with the actual structural detail drawing, this discrepancy had no design or safety impact on Fermi-2 as determined by Cygna reviewers, g)

I

Approved By P ject Macager Date

9. fer ////</o Detroit Edison Company; 83021 7.7-141 Independent Design _ Verification Program

- ==== =

Observation (Wil f/1 mumummunnmum Record Review Attachment A O'

Checklist No. EE-01 Revision No. 1 Observation No. EE-01-03 Sheet p of 3 Yes No Valid Observation X Potential Finding X (PFR No. (N/A) )

Closed X Comments The lowest voltage which the motors will see on starting is during the first loading step of the diesel generator sequencing when the RHR pump motor attempts to start.

Review of speed-torque curves for RHR pumps show these motors will start at 70%

rated voltage. Review of test results of the Diesel Generator Voltage profile during a test LOP loading of large E.S.F. loads shows that the generator voltage dips to a minimum of 75% rated voltage during the starting of the RHR pump, recovers to almost 100% within 0.5 seconds, and fully stabilizes in 3 seconds.

S The diesel generator voltage profile test results show that all motors will start on

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u the above worst case low starting voltage; therefore, this observation has no design impact on Fermi-2.

The only potentially significant voltage dip following the one occurring when the RHR pump motor starts would be when the core spray pump motor is sequenced onto the diesel generator. However, a conservative calculation using the LOFSTAB computer program (" Evaluation of Enrico Fermi-2 Reactor Emergency Cooling Motor Start by On-Site Emergency Diesel Generators" by Detroit Edison Systems Engineering Department dated Aguust 25,1972) for this loading sequence predicted a maximum drop of not less than 85% of nominal (4160 volts) voltage. The basis for the stated conservatism is that the same calculation predicts a maximum drop in bus voltage to 70% when the RHR pump motor is initially started (actual test results indicate a maximum drop to 75% as described above). Since the diesel generator voltage profile is not expected to dip below 85% of nominal voltage for any loads other than the RHR pump motor, a minimum motor starting voltage of 85% is sufficient and adequate and a 75% rating is not needed.

I g Approved By oject Manager Dat 7

k.@ff. ///// O Detroit Edison Company; 83021 7.7-142 Independent Design Verification Program

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Checklist No. EE-01 Revision No. }

Observation No. EE-01-03 Sheet 3 of 3 Yes No Valid Observation X Potential Finding X (PFR No. (N/A) )

Closed X Comments In performing the review, Cygna noted that the worst-case voltage condition on the 480 volt bus (72EC) which supplies the fan motor occurs when the diesel generator is supplying the 4160 volt bus (13EC). The degraded offsite voltage condition was considered and reviewed, however, because the secondary side of the sub-station transformer feeding the 480 volt bus (72EC) has a voltage regulator, the voltage drop for degraded offsite voltage conditions is limited to not less than 97% of nominal bus voltage (480 volt). Consequently, the core spray pump and RHR pump motors would be expected to start even under degraded voltage conditions.

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) Approved By Pro ect Manager Date O.ht v

uk/s3 Detroit Edison Company; 83021 7*7-143 Independent Design Verification Program

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Observation

[4 LW in Record Review s ininininnninnilliinn Attachment A v) i Checklist No.

WD-04 Revision No. O Observation No. EE-01-04 Sheet g, of 7 Yes No Valid Observation X Potential Finding X (PFR No. N/A )

Closed X Comments Presence of yellow " Hold" tag on brace member indicates that corrective action is being taken. (Called Jim Mullins, DECO Site Engineer, to confirm.)

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g 0 CTlA]- 03 V I Detroit Edison Company; 83021 7.7-144 Independent Design Verification Program

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