IR 05000358/1978018

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IE Inspec Rept 50-358/78-18 on 780809-11,15,16 During Which 6 Items of Noncompliance Were Noted:Installation of Concrete Expansion Bolts for Hangers & Snubbers Not IAW Drawings
ML20148K672
Person / Time
Site: Zimmer
Issue date: 10/03/1978
From: Foster J, Gallagher E, Yin I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148K657 List:
References
50-358-78-18, NUDOCS 7811170264
Download: ML20148K672 (19)


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U.S." NUCLEAR REGULATORY COMMISSION j OFFICE OF INSPECTION AND. ENFORCEMENT l

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REGION III

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Report No.. 50-358/78-18 r Docket No. 50-358 License No.'CPPR-88 ,

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Licensee: Cincinnati Gas and Electri j Company 139 East'4th Street

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i Cincinnati, OH' 45201 Facility Name: Zimmer, Unit 1 Investigation At: Zimmer 1 Site, Moscow, OH Investigation Conducted: August'9-11,.15 and 16, 1978 ,

k CU Y 4/th75 Investigator:

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Inspectors: / 7[ l'/78 1 n.I. T. Yin

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E. J. Ga lagher '.),

f7 i fw M d M rt'A Charles E. Nore11us  ? /29[7fr Reviewed By:

Assistant to the Director

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Duane H. Danielson, Chief .

Engineering Support Section 2 si TY.,, ,T-/f9ctn.,-/*

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Richard L. Spessard, Chief /

Engineering Support Section 1 t

Jnvestigation Summary-

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Investigation on August 9-11, 15 and 16, 1978 (Report No. 50-358/78-18)

y eas Inspected: Special, unannounced inspection of procurement, desig ,

j control, inspection program, and installation procedures for pipe hangers, restraints, and snubbers; review of pertinent recor.ds, inspection of r

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The investigation installed components and interviews with personne involved Results:

84 inspector-hours onsite by three NRC inspectors.Six in the following areas; (Installation of concrete expansion bolts for hangers and snubbers not in accordance with drawings - Section III, Paragraph 2; Inadequate procurement documents for the concrete expan-sion bolts - Section III, Paragraph 3; Inadequate QC inspections for installation of hangers, snubbers and concrete expansion bolts -

Section II, Paragraph 1 and Section III, Paragraph 2; I 1; anchor bolts - Section II, Paragraph 2 and Section III, Paragraph Inadequate control of issuance of procedure changes - Section II, Paragraph 3; Inadequate measures to protect hydraulic snubber components from damage - Section II, Paragraph 4).

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- l-INTRODUCTION The Zimmer Unit l' nuclear power plant,flicensed to the' Cincinnati Gas and Electric Company, is under construction near Moscow, Ohio.. Sargent

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and Lundy is the Architect-Engineering firm for the plant, which is &

being constructed by Kaiser. Engineering, Inc.. The' facility will utilize a Boiling Water Reactor (BWR) designed by General' Electric j Compan ,

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REASON FOR INVESTIGATION ,

On June'27,'1978, representatives of NRC. contacted Individual "A" by telephone, and discussed concerns which he had relative to the design and installation of pipe hangers, restraints, and snubbers at the Zimmer 1. plant. During the conversation Individual "A" alleged various problems related to design and installation of this equipment. An ,

investigation was initiated into.these allegation .

SUMMARY'0F FACTS-On June 27, 1978, an-individual contacted the NRC Division of Nuclear Reactor Regulation in Bethesda, MD, and indicated that Individual."A" had concerns related to design and installation of piping equipment at- ,

the Zimmer site. NRC personnel contacted Individual "A"aan that date, ,

discussed his concerns, and received several allegations of improper

' construction. Information from this discussion was transmitted to NRC Region III (RIII) for action.-

On June 29, 1978, RIII personnel contacted Individual "A", an employee at the 7.immer 1 site, and discussed concerns relative to pipe hanger, restraint, and snubber design and installation. General information *

as to the various concerns was obtained,'and Individual "A" was requested to note specific locations of nonconforming equipmen RIII representatives interviewed Individual "A" on July 11, 197 l Discussion indicated that his concerns related to what he felt was inadequate. design, and improper installation of pipe hangers, restraints, and-snubbers. Design concerns expressed included:

insufficient thickness of base plates'for pipe supports, insuf- ,

ficient bolt diameter, overall hanger. geometry, and lack of ,;

consideration given to design loading conditions. Installation

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problems discussed included improper embedment length of expansive concrete anchors, installation of pipe supports attached to block walls, and lack of lock nuts where require Individual "A" provided the RIII representatives with a number of locations where_ allegedly deficient pipe hangers and snubbers could be located. He indicated that this list was a selection of observed Individual "A" problem locations, not a full list of all location stated that limiting of NRC inspection to these areas would not be necessary, as a general inspection of pipe hangers and snubbers would

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identify similar defect Discussion with personnel of the NRC Office of Standards Development indicated that possible deficiencies related to design to pipe support base plates had been identified as a As generic such, problem affecting the concern relatedall to reactor sites, and was under revie base plate design will not be treated in this repor A Zimmer site inspection performed during August 9-11, 15 and 16, 1978, reviewed the allegation During the inspection, a selection of the locations provided by Individual "A", and several additional locations selected at random were inspecte The inspection revealed thatinstallation, significant deficiencies'did and inspection ofexist piperelative to design control and review, Four items of noncom-hangers, restraints, and snubbers, as allege i pliance with NRC requirements were identified in areas where l deficienc d es were alleged, and two items were identified during inspection of re ate area The licensee was advised of the findings of the investigation ona August 11, 1978, the licensee advised RIII repre-and 16, 1978. On August' 15, 1978, ,

sentatives that a stop work order had been issued for installationthe licensee infor On August 28, 1978, of concrete expansion bolt Rill that a stop work order had been issued for hydraulic snubber A stop work order for installation of mechanical snubbers was issued It was indicated that the stop work orders would remain previously.in effect until evaluations had been completed and corrective measures As part of the corrective action program, had been establishe Sargent and Lundy design engineers have been assigned to the Zimmer site to review and coordinate design of pipe hangers and snubber A design review committee will be formed to review future designs,i and an inspection team will be formed to review completed installat on This program will be reviewed by RIII inspectors during subsequent inspection .

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CONCLUSIONS Adequacy of pipe support base plate design was not reviewed as a part of this investigation, but will be treated as a part of a generic issue.- Six items of noncompliance with NRC requirements were identified, ,

four of which were directly related to allegations made by Individual "A". These items of noncompliance were related to:

concrete anchor bolt installation, pipe hanger and concrete anchor bolt inspection, quality documentation for concrete anchor bolts, pipe hanger. design control, document control and review, and protection of equipment during constructio ,

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s DETAILS Section I Prepared by J. E. Foster Reviewed by C. E. Norelius, Assistant to the Director

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, Personnel Contacted  :

Cincinnati Gas and Electric Company _  !

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B. K. Culver, Project Manager D. C. Kramer, Quality Assurance Engineer J. R, Schott, Station Superintendent W. W. Schwiers, Principal Quality Assurance and Standards Engineer [

i J. F. Weissenberg, Quality Assurance Engineer ,

Kaiser Engineering, Incorporated _

F E. Arnett, Pipefitter W. Garner, Pipefitter R. Marshal, Construction Manager W. Puckett, Lead Mechanical Quality Assurance Inspector K. T. Shinkle, Hanger and Mechanical Inspector R. Turner, Quality Assurance Manager

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Individuals Individual " A"  ? _Sc op This investigation focused on the expressed concerns of Individual

"A", relative to pipe hangers, restraints, and snubbers Zimmer 1 sit An expressed concern relative were principal areas of interes i hin the i to base plate design (thickness) was not considered as w tis being tre scope of this investigation, as it issu NRC Headquarters personnel contacted Individual On June 27, 1978,

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on June 29, 1978, RIII personnel contacted Indiviaual "A" by telephon On July 11, 1978, RIII personnel interviewed Individual "A".

During August 9-11, 15 and 16, 1978, an on-site inspection was I performe . Initial Contact with Individual "A" On June 29, 1978, RIII personnel contacted Individual "A" by tele-phone. Individual "A" indicated that he was employed at the Zimmer site, and was involved with work on pipe hangers, restraints, and ;

snubbers. He stated that he felt that there were major problems related to piping equipment at the site. These problems included both design and installation of hangers, snubbers, and restraint Individual "A" indicated that he questioned much of the criteria apparently utilized in the design of plant piping suspension systems. He discussed concerns related to the size of bolts used on pipe hangers, thickness of pipe support base plates, snubbers '

possibly misaligned with anticipated load axes, pipe supports ;

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acting as anchors, and the adequacy of pipe support anchorages mounted to block wall He also indicated that, in many cases, installation of pipe hangers, snubbers, and restraints was improper. He indicated that crafts-men frequently installed components not in accordance with the '

design drawings. The deviations were recorded in as-built drawings and were sent to Sargent and Lundy for approval. Individual "A" also stated that concrete expansion bolt type anchors were improperly installed, locknuts were missing in some hanger locations, and ;

seismic snubbers were improperly installe . Interview of Individual "A" On July 11, 1978, Individual "A" was interviewed by RIII personne He repeated the comments made previously, and provided details as to locations and drawing numbers for a' number of pipe hangers and snubbers alleged to be deficient. Individual "A" indicated that-this was not a full listing of locations of deficient components, and a general inspection of hangers and snubbers would easily "

identify the problems he mentione Individual "A" provided additional information as to improper

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installation of concrete expansion anchors. He indicated that there were many examples of incorrect embedment depth for the

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anchors,,and locations where the anchor bolts had been cut off !

-to disguise improper embedment depth (the top of the bolt would i be cut off to make it. appear.that the proper length of'the bolt was embedded). Individual "A" stated that he believed that- i

"Phillipe red head" concrete anchor bolts had been substituted f for "Hilti-quick" anchor bolts in,some location [

Discussion with Individual "A" provided additional information as ;

to possible design problems. He indicated that in many places, i pipe restraints designed as rigid supports were actually " anchors" .(

as they would not allow pipe movement in any direction. Con-  ;

cerns related to the thickness of pipe support base plates were ;

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discussed, and Individual "A" was advised that base plate thickness (rigid plate analysis) had been identified as a generic ;

issue applicable to many architect-engineering firms, and was being pursued by the NR ,

i Individual "A" indicated that an additional design problem was ,

indicated by the fact that site specifications prohibited welding of attachments across the flange of a steel beam, and yet this ;

had been done on the snubbers for the main steam lines, q Individual "A" stated that a possible design deficiency existed

where attachments were welded to Bergen-Paterson pipe clamps  ;

rather than utilizing additional clamps. He stated that this may

overstress the pipe clamp i' Inspection .

i Information developed through contacts with Individual "A" was- ,

provided to RIII' inspectors for review during a site inspection of pipe hangers, restraints, snubbers, and related piping com-The details of inspection findings are covered in-

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ponent Sections II and III of this report. An Rill Investigation Specialist accompanied the inspectors during the initial portion i of the inspection. During the inspection, a number of the-locations provided by Individual "A" were inspecte . Concerns not covered by thic report Several concerns indicated by Individual "A" are not treated in this report. These apply to items not yet fabricated, or instal-lation problems such as the lack of locknuts or other easily correctable problems. It was found that the licensee had not performed final inspections of any safety-related hangers, snubbers, and restraint installations, and thus had not had the opportunity to identify and correct minor nonconformance ,

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Section II Prepared by I. T. Yin Reviewed by D. H. Danielson, Chief Engineering Support Section 2 Hanger and Snubber Inspection Program More than 50" of all the safety related hangers and snubbers have been' installed, however, none of these items have received final quality control inspection and signoff. Many of these installed items were inspected for proper welding procedures, materials, weld size, and surface conditions. The inspector observed approximately 30 safety related hangers, snubbers, and restraints and identified the following: Installations that Deviated From Design Drawings !

lWS - 027sR - The snubber weld attachment was bolted to the wall instead of welded to a embeded plate as shown on the drawin lWS - 033SR - Same deviation as 1WS-027S lWS - 138HA - The vertical anchor structure plate was fastened to the concrete by 2 bolts on one side and welded to a embeded plate on the other side instead of being completely welded to the embed plate as shown on the drawin WS - 025HV - Two of the four pipe riser shear lugs were not resting on the pipe clam RT - 014SR - An additional structural member was welded between the web of the I-beam and the snubber weld attachmen RT - 016SR - The snubber was attached to a horizontal beam instead of vertical post as shown on the drawin The attachment differed from that shown on the drawin WR - 215HR - The horizontal pipe line was supported on a column instead of resting on a structural system con-sisting of a horizontal beam, vertical hanger, and a U-bol .

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1WR - ' 200 liR '- The pipe line' was' supported on a column instead-of by a structural' system consisting of a swivel

linkag WR - 214HR - Same deviation as 1WR'- 200H ~

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'1RH ~ OllHR - The rigid strut was welded to the web of

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W 12 x 27 below instead of being welded to an embedment ,

plate above. The filler weld size was measuredThe to be weld 'l 1/4", same as the web thickness of W 12 x 27. measured

.ments of'KEI QACMI M-1 .

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j A Design Document Change (DDC) was written for 1RH-OllH .

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and was. approved by the Architect Engineer and the: license The actual installation differed from that approved by the DD A DDC has been written for 1WS-033, but was not yet approve Two DDC's for 1RT-014SR and 1RT-016SR were in'

preparation, Conflict Between Design'and Construction Requirements P Welds crossing a beam flange were observed at many locations '

including the following snubber and hanger beam. attachments:

1RT - 008SR 1RH - 485HR 1RT - 009SR 1RH - 486HR .l 1RH - 006SR lRH -1487HR-1RH - 004SF 1RH '- 002SR '

The welding was as specified on the design drawings, how- ,

ever welding across a beam flange is in conflict with commo '

industrial practice, and the requirements of KEI QAMCI M-12.-  !

In view of the above identified problems, the licensee's ha'nge and snubber inspection program appears'to be inadequate in that, repeated nonconformances were permitted to continue because none-of the-installation has received finalfinspection as of the date of NRC inspectio This is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion X, and Wm. H. Zimmer, Unit 1, FSAR Paragraph 17.1.10 requirements. (358/78-18-01)

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2' . - Review of D'esign Changes  ;

An Inter-office Memorandum (IOM), entitled " Essential Piping Hanger Installation. Criteria and-Inspection Requirements,"

iasued by the KEI QA Manager, dated. September 22, 1977, was-

- reviewed by the inspector. Among the instructions, it states that " Modifications to hanger designs will be accomplished by; issue of a DDC. Inspection verification of. compliance with .

- DDC's will be recorded on the inspection record copy Lof the-drawing. A ' copy off the .DDC must be available to Quality Assurance prior to performing the construction change. In the event con-struction modification is to be accomplished prior to formal  ;

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," approval of the DDC, Quality Assurance will perform inspections in accordance with the unapproved DDC's requirements.. In thes ;

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cases final acceptance will be withheld-until an approved. cop j of the DDC is received."

This instruction deviated from the Cincinnati Gas and Electric >

Company QA Manual, dated May 6, 1977, Paragraph 3.12.2(c), '

which states that "DDC's are used when it is desired to obtain expedited approval of drawing or specification-changes without waiti ; for a formal revision of the affected document."

As noted in Paragraph 1.a above, hangers and snubbers have been  :

installed contrary to design requirements. In discussion with with KEI QA inspection group, the inspector was-informed of

- the site common practice of " red lining" as-built deviations .;

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after component installation and submitting these " red lined" drawings to the design engineer's office in hopes that the .;

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changes would be acceptabl This is considered an item of noncompliance with 10 CFR 50, I Appendix B, Criterion III, and Wm H. Zimmet, Unit 1, FSAR Paragraph 17.1.3 requirements. (358/78-18-02) Document Control

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The use of IOM to document work instruction'as described in Paragraph 2 above without issuance, review, and approval as-well as other document controls such as updating and distribution is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion VI, v.id Wm H. Zimmer, Unit 1. FSAR Paragraph 17. requirement (358/78-18-03)

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TheLinspector questioned if work instructions for other safety

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related construction had been issued through IOM's? -It.was '

further noted that all instructions documented

~ The licensee in IOM's shoul be placed-in controlled manuals or. procedures.-

agreed to' review this matte . Protection for Hydraulic Snubbers f

Bergen-Paterson (B-P) snubbers numbered 1RT-0175R, 1RT-015SR, j 1RH-006HR, 1RH-001SR'and 1WS-044SR, which represent approxi- 1 '

mately 20% of all the snubbers observed, were i observed er The without

' .the required accumulator indicator protect ve cov requirement for installing these covers was Ciscussed during1-2, 1978, (Rep' .

a previous RIII inspection on May 31 cnd Ju No. 50-358/78-10, Paragraph 5.b).

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Failure to protect safety related component during installation .

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is considered an item of noncompliance with 10 CFR 50,-Appendix h 17.1.13' B,

. Criterion XIII, and Wm. - H. Zimmer, Unit 1, FSAR Paragrap ,

requirements. (358/78-18-04) ,

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- Design Review +

and attached The following hanger, snubber, pipe whip restraint, '

structures were. observed by the inspecto l 1RT - 016SR - The installation deviated f rom design drawings >  :

(Para. 1.a). .The torsional moment at the horizontal-I-beam-

-may be excessiv RT - 014SR - The insta11ation' deviated from design dra (Para. 1.a).

at the same location. The attachment of snubber 1RT-016SR to '

the horizontal beam could impose an additional torsional momen The 1/4" fillet veld on. the W 8 x 17 beam having a web thickness uf 1/4" is not in accordance with'KEI QACMI M12 which requires  ;

the weld at the web to be 1/16" less than the web thicknes WS - 138HA - The installation deviated from design drawings The structural arrangement may not be sufficient (Para. 1.a).

for the loadings shown on the drawing.

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.011HR - The installation deviated from design drawings The loading shown on the drawing may be excessive >

(Para. 1.a).

for the as-built conditio ,

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1 WR - 322HA - The anchor attachment to the pipe may not be sufficient to withstand the loading shown on the drawing.

I 1 RH - 271HV - The two tack welds on the pipe saddle may not 4 be sufficient to withstand system vibration loading j l

l 1 WS - 025HV - The installation deviated from design drawings I (Para. 1.a). Excessive loading could be imposed on the pipe riser lug RHFR - 1003 - A portion of the pipe whip restraint ring section (2'-6" dia. x 8" vide x 2" thick) was removed to provide clearance for the pipe. The DDC S-1276 allowed a 1 3/4" x l'-3" cut with radius corners. The starting edge of the cut was shown-to start 3" from the edge of positioning structur The actual cut started 9 3/4" away from the edge of positioning structure and extended outward at approximately 45 without radius corners. Tne inside j

dimension of the cut was approximately 2 7/8" x l' -10" (near center) and 2' -1" (at the edge of the ring). The outside l

f dimension of the cut was approximately 2" x l' -10" (near center)

i and 2 ' -1" (at the edge of the ring). The cut was tapered at all locations. A nonconformance report had not been writte Beam Cuts - One side of the I-beam flanges on a W24 x 68 radial structural beam at El. 534' was cut out to the edge of the we The cut length was 12" at the top and 24" at the bottom. The flange of a W14 x 314 beam was welded to the web of the W24 x 6 No reinforcement was at the cut. The cut was made to clear the recirculation loop discharge valve actuator. The structural arrangement is shown on S&L Drawing S-39 RH-017SR - A DPE load of 4686 lbs. is shown acting on the 1/4" thick web of a W 8 x 17 beam. The structural adequacy is questione In addition, a 1/4" fillet veld is shown on the drawing, which is in conflict with KEI requirements, (see 1RT-014SR above for explanation),

1RH-443SR and 1RH-4555R - Two horizontal seismic restraints are installed on each side of valve 1E12F073B and valve 1E12F074 The pipe line is 1RH 56BB 1 1/2". The inspector questioned the following: The adeqauacy of the W 8 x 17 beam to resist the torsional moment imposed by this installatio .

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The weight of each valve including the motor operator is j i 220 lbs. + 10% and is about 13" off the centerline of the 1 1/2" pipe. The adequacy of the pipe section to withstand the total offset loading of 440 lbs., taking into consideration local pipe stress and seismic restraint requirement l Beam Stiffeners - A '2mber of beam gusset plates were welded to I-beam sections in the area of the RHR Heat Exchanger Room Wes The plates were welded on three sides without opening at the corners. This is not considered an acceptable industry practice because the triaxial stresses imposed due to welding could result in cracking at the weldmen The licensee agreed to perform a complete review of hanger, restraint and attachment structure designs used on all safety related piping systems. This is considered an unresolved ite (358/78-18-05)

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Section III Prepared by E. J. Gallagher Reviewed by R. L. Spessard, Chief Engineering Support Section 1 Review of Design / Construction Drawings For Installation of Anchorage of Supports Using Conc _ rete Exp_ansion Anchor Bolts The. inspector reviewed selected drawings being used to install-safety-related supports and restraints anchorage to concrete The following are the using concrete expansion anchor bolt results: Drawing Nos. M-126-10H-58 (1WS 172SR), M-126-10H-57 (1WS 171SR), and M-126-7H-15 (IWR 137HR) are Sargent and Lundy detail construction drawings which do not include instructions critical to the anchorage detail to assure anchorage' capacity, i.e., expansion bolt length nor embedment depth. These drawings have received design review and QA review, The following drawings reviewed do not include the embedment depth to which the anchor bolts are to be(1WR M-448-3H-29 installed to assure 205HR),

adequate anchorage capacity:

M-126-7H-19 (1WS 220HR), M-448-3H-64 (1WR 175SR) andIt M-448-3H-61 (1WR 236HR).

attention that none of the detail drawings issued to date include these instructions to assure proper installatio Specifications, procedures or instructions have not been written to date, regarding the use, installation or testing required when using concrete expansion anchor bolts Instruc-for anchorage of safety-related supports or reatraint tions that would be required include minimum embedment depth for each diameter bolt, minimum spacing requirements, minimum edge distance, instructions when in contact with reinforcing steel, relocation instructions and torque requirements to assure the bolts are capable to develop the tensile capacity requ1 re The inspector reviewed design / construction drawings which indicate anchorage of safety-related supports and restraints

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to non-safety related block walls both hollow core block (concrete filled) and high density shielding block walls bonded together with a mortar mix. Specification H-2174, Sectic. 4-1 (masonry work) includes hollow core block and high censity block walls. This specification was identi-fied as (nonessential) non-saf ety related wor Examples of this condition are shown on drawings M-448-6H-41 The safety-related (1WR08HR) and M-488-8H-20 (1WR232SR).

supports are designed to transmit loads to structural member This f ailtr e to assure that applicable design bases, as indicated above in MI'through d, for safety-related supports and restraints are correctly translated into specifications, procedures, drawings or instructions is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion III. (358/78-18-06)

This same condition was previously identified in RIII Inspection and Enforcement Report No. 358/78-09 (1 tem 358/78-09-04). Observation of Anchorage of Supports and Restraints Installed The following table is a list of support and restraints installed that the inspector observed to ascertain the quality of the installation versus the details on the design drawings:

Design Drawing N (Restraint No.) Observations 1WRG875R (1) Three of four expansion bolts are (M-448-6H-24)

saw cut, therefore the length of the bolt is questionabl (2) The plate is not fully bearing on the concrete due to improper embedcent depth. The support at this ti=e is unrestrained and free to move under load condition ,

IMS01045R Main steam line snubber is welded (M-401-9H-63)

across the flange which confifets with requirements of inspection pro-cedure QACMI-M12, Section 5.2.12(a).

1RR175SR At least three holes are drilled next to installed anchor bolt plat Holes (M-448-3H-64)

reduce the effective concrete stress

' cone resisting anchor plate load ,

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1WS220HR (1) Plate Detailisdrawing 3/4 inch off floor indicates slab. directly bearing (M-126-7H-19) on sla (2) Due to condition in (1) improper embed-ment depth is eviden (1) Drawing indicatesinstalleduse of embed plate uses expansion 1WR013SR where restraint (M-448-5H-42) anchor bolt (2) . Washers under nut turns yet nu. has been tightene (3) Two nuts have not been tightened or torque (4) One bolt has a stack of four washers, therefore reducing embedment depth require (5) Bolts have improper embedment depth i.e.,

as per manufactures instructions, 4.5 times diameter of bolt (6) Bolts installed on angle reducing capacity of bol (7) Bolts installed violate manufacturers i.e.,

minimum spacing requirements, 10 times anchor diameter Drawing indicates base plate under LWR 205HR pipe stanchion; no base plate installed (M-448-3H-29) and pipe is completely restrained to walls. Base plate unable to be installed in this situatio (1)

Nuts on bolts not fully engaging threads; 1WS033SR potential cause for thread failure under (M-126-13H-32) load.

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(2) Drawing indicates use of embedded plate and restraint installed uses four expansion bolts of undetermined lengt No design change issued for this restrain .

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lWS025HV Bolts installed violate minimum edge distance requirement of manufacturer, i.e., minimum 5 times anchor diamete Based on the above observations, work has not been accomplished in <

l accordance with the construction details provided by the applicable drawing This failure to accomplish activities affecting quality in accord-ance with instructions or drawings is considered an item of noncom . i pliance with 10 CFR 50, Appendix B, Criterion V. (358/78-18-07) ,

In addition to the observations made on the above specific supports and restraints the following two general observations were made: The inspector determined that the bolts installed to date have had no inspection performed to assure that the correct length bolt has been installed according to design drawing The bolts do not include a length identification marker that is available from the supplier of the bolts to be inspected subsequent to installation nor has any inspection been per-formed during installation to ascertain the use of the correct length bolt Interviews with two pipe fitters responsible for installing the anchors indicated that the expansion bolts have been installed without applying a torque to the specified ranges of values as required by Design Document Control (DDC) N SLS-266 dated April 5, 19 . No inspection had been provided to assure the use of a calibrated torque wrench'for setting the bolts to the prescribed torque range. The torque applied to the bolt directly affects the tensile capacity of the bol Based on the above observations of installed supports and restraints and interviews with the pipe fitters performing the installation of the concrete expansion anchors, Kaiser Engineer, Inc. , (KEI) has not provided an inspection program to assure that anchorage of safety-related components has been installed to the design drawings

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and manufacturers minimum requirement This failure to provide an inspection program to assure adequate installation of safety-related items is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion (358/78-18-08)

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Review of Procurement Documents for Concrete Expansion Anchor Bolts The inspector reviewed the procurement documents used to purchase concrete expansion anchor or bolts used for anchorage of safety-related support The procurement documents do not indicate quality assurance requirements in the space provided for such requirement & Lundy informed the inspector that Sargent The procurement agent ,

Specification H-2174, Section 5-4.6.4 requires the use of TheHilti

" Kwik. Bolts" and does not specify any quality requirement supplier has therefore not submitted a QA Manual The nor has KEl procurement or CG&E performed any QA audits of the supplie documents do not reference quality standards for the material supplier nor a certificate of conformanc This failure to assure that requirements which are necessary to ,

asaure adequate quality are suitably included or referenced in the documents for procurement of material and services is con-sidered an item of noncompliance with 10 CFR 50, Appendix B, Criterion I (358/78-18-09)

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