ML20212A477

Rev 4 to Element Final Rept C011306-SQN, Testing of Anchors

ML20212A477
Person / Time
Site:	Sequoyah
Issue date:	12/09/1986
From:	Chesney J, Howards J, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212A474	List: ML20212A469 ML20212A477 ML20212A491 ML20212A502
References
C011306-SQN, C011306-SQN-R04, C11306-SQN, C11306-SQN-R4, NUDOCS 8612240168
Download: ML20212A477 (14)

Text

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAM

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i ~ REPORT TYPEi Sequoyah Nuclear Plant Element REVISION NUMBER: 4 (Final Report)

TITLE: Testing of Anchors PAGE 1 0F 13 REASON FOR REVISION:

To incorporate TAS and SRP conunents. Revision 1 To update specific concerns addressed. Revision 2 To incorporate line management response Revision 3 and finalize report.

To incorporate additional SRP comunents Revision 4 m n PREPARATION PREPARED B - f f

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DATE REVIEWS PEER:

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SIGNATURE DATE SIGNATURE

• DATE APPROVED BY:

it /) l$'l0'$h N/A ECSP MANAGFR DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 2 OF 13 I. INTRODUCTION The concerns in this element, IN-85-285-002, IN-85-347-007, IN-86-115-001, IN-86-190-003, and XX-85-023-001, address the testing of anchors. The issue of anchor testing has also been addressed by the QA/QC category, SQN Element Report Number 80203-SQN (Inspection Performance).

II.

SUMMARY

OF PERCEIVED PROBLEMS A. Shell-Self-Drilling (SSD) type anchors were improperly tested or ,

the pull test was bypassed.

D. SSD type anchors are tested by sampling methods instead of on an individual basis.

C. SSD type anchors are being overtorqued.

D. There is no torquing requirement for instrument panel bolts.

III. EVALUATION METHODOLOGY A. Reviewed the Sequoyah Nuclear Plant (SQN) Generic Concerns Task Force (GCTF) Report on Incorrect Installation and Inspection of Anchors for overall content, adequacy, and findings with respect to the subject concerns.

B. Reviewed the Watts Bar Nuclear Plant (WBN) Employee Concerns Task Group (ECTG) Element Report on Testing of Anchors (C011306) for content and generic applicability to SQN.

C, Reviewed Nuclear Safety Review Staff (NSRS) Investigation Report I-85-439-WBN to determine the methodology used in addressing the sampling program issue, the findings and the adequacy of the report with respect to the answering of the subject concern.

D. Reviewed the WBN-Project Manager's Organization (PMO) response to concern IN-85-347-007 for content, findings, and applicability to .

SQN.

E. Reviewed the Division of Nuclear Engineering's (DNE) response to NSRS Investigation Report I-85-657-WBN with respect to anchor lot designations / definitions and justification for sampling methodology.

6 TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 3 0F 13 III. EVALUATION METHODOLOGY (continued)

F. Reviewed SQN Modifications and Additions Instruction (M&AI) 10 (Testing of Expansion Anchors Set in Hardened Concrete), M&AI 11 (Fabrication, Installation and Documentation of Seismic Supports and Supports Attached to Seismic Category I Structures), M&AI 9 (Inspection of Bolted Connections), and General Construction Specification G-32 to determine requirements for anchor testing and identify any criteria for designation of anchor lots. Also, reviewed other applicable procedures and documentation as required to obtain information relevant to the subject concerns.

G. Interviewed knowledgeable personnel in responsible units to obtain additional input applicable to the subject of this element.

IV.

SUMMARY

OF FINDINGS A. The SQN-GCTF Report addressed the subject of this element as well as the parameters of the anchor installation process. With respect to anchor testing, the report referenced sampling programs done to satisfy NRC IE Bulletin 79-02 as well as SSD reinspection and replacement exercises initiated as a result of employee concern XX-85-023-001. Although not specifically referenced in the GCTF report, Nonconformance Report (NCR) 72D and Nuclear Regulatory Commission (NRC) inspection item 328/78-01-14, along with Employee Concern XX-85-023-001, were the basis for the initiation of a Special Maintenance Instruction (SMI-2-317-24R2) to review anchor bolt / baseplate installations for the SQN unit 2 shield building wall.

The report concluded that existing historical information from pull test data, 79-02 inspections, and the SMI-2-317-24R2 anchor survey

, produced results that supported the adequacy of SQN's anchor installation / inspection program. The status of the open issues i

addressed by the SQN report will be addressed in section G.I. of l this report.

B. The WBN-ECTG Element Report for Testing of Anchors did not identify any specific issues generic to SQN. Specific instances of conditions adverse to quality (CAQ) at WBN were documented and corrected according to site NCRs. The report identified no CAQ with respect to the use of sampling programs for proof loading of SSDs.

- TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAM

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SUMMARY

OF FINDINGS (continued)

C. A detailed review of the NSRS Investigation Report I-85-439-WBN was made to evaluate the issue of using sampling techniques to test SSDs. It was discovered that all aspects of the NSRS report were applicable to SQN, except where specific WBN procedures were referenced. The conclusion of the report indicated that

" determination of adequacy of the anchors based on sampling is an acceptable technique endorsed by industry standards TVA procedures and the NRC in IE Bulletin 79-02." This conclusion was based on a detailed review of American National Standards Institute (ANSI) and American Society of Testing and Materials (ASTM) Standarcs. TVA Design Standards, and TVA General Construction Specifications.

D. The WBN-PHO response to the concern on instrument panel bolts (IN-85-347-007) was reviewed and determined to be generic to SQN with respect to tightening requirements for bolts in SSDs even though the response was directed to the concern as expressed at WBN.

The same criterion governing the tightening of SSD bolts at WBN (General Construction Specification G-32, section 3.2.5) is applicable to SQN. The report concluded that the subject bolts were installed in accordance with applicable G-32 criteria which did not require torquing of the bolts. Therefore, no procedural violation was identified. This evaluation agrees with that determination.

E. A detailed review of the DNE response to recommendation 03 of NSRS Investigation Report I-85-657-WBN was made to evaluate the applicability of defined anchor installation lots at SQN. IVA General Construction Specification G-32 provides the procedural criteria for all TVA nuclear plants for the number of anchors i selected and the testing frequency required to prove acceptable l anchor installations. However, G-32 was not intended to provide

, evidence of anchor acceptability based on individual lot test

results. The results of proof load tests are evaluated monthly by DNE, where they are categorized by anchor type and size, not by lot. The defect rate is then determined for each group of anchors, and the results provide the means for evaluating whether the proof

( load failure rate is acceptable. A failure rate of greater than 5 percent for any group of anchors requires additional action (s) and a failure rate close to 5 percent requires further evaluation to determine if trends exist. This methodology recognized the high rate of proof test failures in the SQN unit 2 annulus area and eventually led to identifying the understrength surface concrete problem addressed by NCR-72D. It should also be noted that the statistical sampling plan employed was a recommended method in NRC IE Bulletin 79-02.

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- . TVA EMPLOYEE CONCERNS REPORT. NUMBER: C011306-SQN SPRCIAL PROGRAM

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PAGE 5 0F 13 IV. SUNNARY OF FINDINGS (continued)

F. A review was made of TVA General Construction Specification G-32, RIO, N&AI 9. R7, and N&AI 10. R10 with the following results:

1. The criterion which addresses the designation of anchor lots in N&AI 10 is taken directly from G-32 and provides adequate definition and description of anchor installation lots. This review also determined that no specific criterion existed to require proof testing (pull testing) of SSDs before baseplate installation (although G-32 implied this method) nor was there specific criterion for shimming baseplates when "through the -

plate" testing was performed. See section G.4 of this report for additione.1 information on this subject.

2. The criterion which addresses the tightening requirements for bolts in SSDs at initial installation is section 3.2.5 of G-32. Section 4.6.2 details tightening requirements for bolts in SSDs during inspection for thread engagement. For initial installation, tightening the bolt 1/8 to 1/4 turn after the bolt head contacts the attachment is required. For bolt inspection to verify tightness, the installation is acceptable if the bolt cannot be turned with the fingers. SQN R&AI 9 also contains specific bolt inspection criteria similar to G-32 in that section 6.2.3 requires verification that, as a minimum, the bolt is handtight. Torquing of bolts le SSDs is not a requirement in G-32 nor M&AI 9.

3. Torquing requirements are detailed only if wedge bolt anchors are installed. Both G-32 and SQN N&AI 10 are specific with respect to the torquing method to be used for wedge bolts.

Specific torque values are given for each bolt size as well as how to apply the specific torque correctly. Both G-32 and

, N&AI 10 require all wedge bolt anchors to be torqued, regardless of the feature for which anchorage is being provided.

G. The responsible engineer in SQN/Nodifications Unit was interviewed to obtain information on mechanisms employed to address NSRS recommendation Q-85-023-001-01.

The results of this interview are as follows:

1. NCR-72D was originally issued by DNE to document continual failure of anchor pull tests in the SQN unit 2 annulus area.

The corrective action for this NCR was to replace all 1/2-inch diameter and larger self-drilling (SSD) anchors in the affected area with equivalent size wedge bolts. Excluded from this replacement were 1/4-inch and 3/8-inch diameter SSDs installed

. TVA EMPLOYEE CONCERNS REPORT NUMBER: C013306-SQN SPECIAL PROGRAM REVISION NUMBER: 4

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IV.

SUMMARY

OF FINDINGS (continued) i in specific conduit cupports. The QTC investigation of concern XX-85-023-001 revealed these corrective actions had not been fully implemented. In response to NSRS recommendation Q-15-023-001-01, initiated as a result of the aforementioned QTC investigation, SQN agreed that the corrective action of NCR-72D had not been fully implemented as detailed in a letter from H. L. Abercrombie to R. K. Siberling dated April 24, 1986.

2. Further discussion revealed that the SQN Modifications Unit had initiated SMI-2-317-24 on January 15, 1986 to conduct a field survey of anchor bolt / baseplate installations in the unit 2 shield building wall. This SMI included a sampling program for all anchorages on the vertical interior and etterior wall at all elevations using the following selection process:

a. System 67 (ERCW) in the annulus only

b. Systems 30 and 65 (HVAC ductwork) in the annulus only

c. System 26 (fire suppression) in the annulus only

d. Electrical systems conduit 2-1/2-inch diameter and greater (including some junction boxes and cable trays on the interior / exterior wall)

e. Unistrut attached to wall surfaces that supports pipe or tubing on the interior / exterior wall

f. Cantilever type supports for tubing and conduit 2-inch diameter and smaller

, g. The thirty supports previously identified in the QTC investigation report on the subject concern (XX-85-023-001).

The results of this exercise are as indicated in the letter from C. R. Brimer to H. L. Abercrombie of 11-20-86 concerning the SQN-GCTF recommendations, and reflect an overall acceptance rate of greater than 95 percent. The final number of supports inspected was 1281 (1193 was referenced in the aforementioned letter). The total number found unacceptable was 43, all of which have been or will be reworked as required by specific Maintenance Requests (MRs). Initially, 1/4-inch and 3/8-inch diameter SSDs had been excluded from the inspection under certain conditions (MEMO SWP 781013 005). However, since that

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PAGE 7 0F 13 IV.

SUMMARY

OF FINDINGS (continued) l l

time, conduit loads have been increased so the referenced memo is no longer applicable except in some isolated instances such I as aluminum conduit and small junction box installations. l Workplan 11963 was written to address this issue and to act lR4 as a mechanism for correcting problems found during i performance of the SMI. l Subsequently, SQN Nodifications initiated a test program to l qualify the existing anchorages to. greater loads. Therefore, I per Appendix L of G-32 (SRN-G-32-15) and section 8.8 of l -

SMI-2-317-24 R3, pull tests were performed on 1/4-inch and lR4 3/8-inch diameter SSDs originally exempted from replacement I in the corrective action of NCR-72D. The following is an I excerpt from section L.4.1 Acceptance Criteria of Appendix L: l L.4. EVALUATION OF EXISTING COMPLETED ATTACHMENTS L.4.1 Acceptance Criteria All existing attachments to the unit 2 shield wall which do l not conform to section L.2 shall be evaluated. The I acceptability of existing completed attachments shall be IR4 determined in accordance with sections L.4.2 and L.4.3 or l L.4.4. l I

Evaluation is not required for 3/8-inch "long" wedge I i bolts and 1/2-inch " regular" length wedge bolts that I have attachment thicknesses of 3/8 and 3/4-inches, I respectively. (Wedge anchors with these reduced IR4 maximum attachment thicknesses will have pretightening i embedment that equals or exceeds the minimum wedge l

, - bolt embedmont of 4-1/4-inch for full wedge bolt l capacity. l l

The results of the inspection and testing on an l i

attachment may be applied to adjacent attachments l within a 20-foot by 20-foot area centered on the 1 inspected attachment. (The measurement shall be based l on the clear distance between the attachments). If an l attachment does not meet all specified requirements, l all attachments in the defined area shall be inspected lR4 and tested. (The basis for this requirement is that l the deficiency relates to the quality of the surface l

concrete and not the installation of the anchor. l Also, a 50-percent reduction in allowable design load l l has been implemented by TVA Civil Design Standard l DS-C1.7.1. The 20- by 20-foot area will provide adequate l data to allow identification of any elevations or i

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6 TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAM REVISION NUMBER: 4

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PAGE 8 0F 13 IV.

SUMMARY

OF FINDINGS (continued) areas where the concrete surface condition is l significantly affecting anchor performance.) l The required inspections are related to the condition of the I concrete. Should problems with other attachment I installation parameters be identified, they should be IR4 handled as separate conditions adverse to quality. l If an attachment is inaccessible, the support may be accepted by DNE based on evaluation of the results of lR4 inspection and tests on adjacent attachments. l The results of the pull tests performed were further proof of the l adequacy of the anchor installations in the unit 2 shield building I wall. A total of 1130 anchors were pull tested, the majority of I these pull tests being performed with the base plates removed. IR4 Thirty-six anchors (3.2 percent) failed pull test and 4 of these I failures were directly attributed to the understrength surface l concrete.

In addition, the inspection revealed no SSD anchors to be installed in any of the mechanical systems in the inspected areas - all had been replaced as required by the SQN Final Report for NCR-72D.

3. The responsible engineer in SQN Project Services Section (Site Services) who was also involved in the unit 2 annulus inspection was interviewed. He provided the following information:

a. The strategy behind choosing the System 67, 30, 65 and 26 supports for inspection was that these supports encompassed

, a very large percentage of the installations in the annulus area.

b. M&AI 10 RIO (Testing of Expansion Anchors Set in Hardened Concrete), section 3.3 states, "no 1/2 inch diameter or Jarger SSD type anchors are to be installed in the SQN unit 2 shield building wall." M&AI 11 R12 and G-32 l (SRN-G-32-15) Appendix L, section L.2, also preclude the (R4 use of SSD type anchors as well as detailing specific wedge l bolt anchors for installation in the affected area. These statements provide procedural means of assuring future anchor installations will not violate the criteria of the NCR-72D Final Report.

4. The implications of concern IN-85-285-002 were discussed with the responsible DNE-Civil Engineering Branch (CEB) Central Staff engineer with respect to SQN. He stated that the

. TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN

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IV.

SUMMARY

OF FINDINGS (continued) inspection criteria of 79-02 were sufficient to prevent the anchor shell from contacting the baseplate during "through the plate" proof testing. He also stated that when anchor reinspection required proof testing as a result of a NCR, the reinspection process would require plate shimming if "through the plato" proof loading was performed. However, neither G-32 nor M&AI 10 specifically state that proof testing is to be done i before baseplate installation, nor is there criterion included l which requires shimming of the baseplate when through the plate proof testing is performed. G-32 only implies that the proof test will be done before base plate installation. It was stated, however, that proof testing before base plate installation was standard practice at all plants and shimming of the plate for "through the plate" testing was also a standard, recognized practice. At this point, the positive results of SQN's 79-02 inspection program were discussed as well as the 79-02 inspection procedures for both units which required verification that the anchor shell was not contacting the base plate. The final comments were that a revision to G-32 could be made to include specific statements addressing proof test before base plate installation and shimming when through the plate testing was performed but he did not feel as though a revision was a necessity.

l S. G-32 and M&AI 10 were further discussed with the SQN I

Modifications responsible engineer. He agreed with the comments made in the preceding section by the DNE-CEB engineer that pull testing before base plate installation was a standard, recognized practice even though not a specific

! requirement. He also stated that during reinspections the base

! plate was removed in many cases instead of using shims which

, would allow "through the plate" proof testing.

6. Also discussed concern IN-85-347-007 with the responsible i DNE-CEB Central Staff engineer. He stated that there never

! has been, nor is there now a requirement to torque bolts

, installed in SSD type anchors. Bolt tightness in SSDs is i' achieved and verified by methodology other than torquing as detailed in section IV.F.2 and 3 of this report. He also lR4

• verified that G-32 was very specific with respect to the requirement that all wedge bolt anchors installed were to be

torqued to a specified torque value regardless of what feature j they were providing anchorage for.

H. Conclusions

, 1. This evaluation is in agreement with, and verified the SQN-GCTF i report on the subject of this element. It was concluded that lR4 l

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- TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAN REVISION NUMBER: 4 PAGE 10 OF 13 IV. EUNNARY OF FINDINGS (continued)

SQN's 79-02 reinspection program, the reinspection program initiated according to SMI-2-317-24, and the reinspections performed as a result of the QTC investigation of concern XX-85-023-001 served as mechanisms that prove the overall lR4 adequacy of SQN's concrete anchor installations. The recommendations in the SQN-GCTF report on Incorrect Installation and Inspection of Anchors address 2 other issues:

a. Base plate flexibility - this issue is addressed fully in the WBN-ECTG report for SQN on Design of Plates -

(C011301-SQN).

b. Overtorquing - before outlining the details that relate to this issue, it should be pointed out that overtorquing is not the proper terminology to be used. The concerned individual used the word overtorquing in describing the concern on expansion anchors. However, since expansion shell anchor bolts are " tightened" with a wrench of some type, and not " torqued", the appropriate terminology is "overtightened." The terminology overtorquing and overtightening is not interchangeable in this application.

This issue was initially raised at WBN by employee concern IN-86-115-001. NSRS Investigation Report I-85-659-WBN substantiated the concern and recommended a program to verify anchor integrity based on bolt tightening practices. The WBN-ECTG Element Report on Installation of Anchors further verified the NSRS report and indicated that PIR-WBNCEB8644 had been initiated to evaluate the deficiency.

, Interviews with responsible personnel in SQN Site Services.

Modifications, Compliance Site DNE and CEB Central Staff revealed no evidence to indicate the anchor overtightening issue had ever been addressed by SQN. It is conceivable that sufficient data exists from G-32, 79-02 and other reinspection programs to adequately address this issue.

However SQN should initiate an exercise to evaluate possible anchor overtightening using methodology that will sufficiently answer this potential generic problem.

2. This evaluation did not attempt to verify whether pull tests were bypassed as stated in concern XX-85-023-001.

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. . TVA EMPLOYEE CONCERNS REPORT NUMBER: C011306-SQN SPECIAL PROGRAM

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IV.

SUMMARY

OF FINDINGS (continued)

SMI-2-317-24 R2 and Workplan 11693 adequately addressed all anchorages installed in the unit 2 annulus area where understrength surface concrete was identified and documented by NCR-72D. In addition, specific procedural mechanisms have been implemented to control future installations in this area. The SQN Modifications Unit is performing the aforementioned evaluations.

3. This evaluation is in agreement with and verified the WBN-ECTG Element Report findings as well as the NSRS investigation -

report I-85-439-WBN findings with respect to the use of sampling programs being acceptable. Agreement with the DNE response to NSRS Investigation Report I-85-657-WBN-03 was also determined according to this evaluation. The sampling program issue has been adequately addressed in all cases and no deficient areas were identified. G-32 is adequate with respect to lot definition and testing frequency of concrete anchors.

4. This evaluation determined that torquing of instrument panel bolts is not a requirement when SSD type anchors are installed.

Tightening of SSD bolts is accomplished using a method other than torquing as detailed in section IV.F.2 and 3 of this report. It was also determined that if wedge bolt anchors are installed, fully adequate procedural mechanism exists in the applicable upper-tier criteria (G-32) and at the site level (SQN-M&AI 10) to require torquing of wedge bolts regardless of the features for which they are providing anchorage. Therefore, the concern has not identified a condition adverse to quality nor a procedural deficiency.

5. This evaluation addressed specifically the issue of anchor

, shells contacting base plates during pull tests (concern IN-85-285-002) and determined:

a. No specific criterion in G-32 or M&AI 10 address this issue but 79-02 reinspection programs were governed by mechanisms to verify no contact existed both before and upon completion of the proof test. Since that time sufficient sample, review and reinspection programs have been performed to reveal generic deficiencies with respect to this issue. None have been identified. Therefore, this evaluation does not recommend additional reinspections for this condition.

b. This evaluation did identify that DNE-CEB should review existing G-32 criteria to determine if specific requirements should be implemented which would:

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PAGE 12 OF 13 IV. SUNNARY OF FINDINGS (continued)

(11 require pull tests to be performed before base plate installation (2) require shimming of the base plete when reinspections cause through the plate proof tests to be performed.

c. SQN Nodifications unit should review N&AI 10 to determine if specific requirements should be implemented to address recommendations 1 and 2 above.

V. ROOT CAUSE This evaluation did not identify a specific condition adverse to l quality. The root cause for the potential deficiency described in 1R4 3 section IV.H.5.b is incomplete procedures or a failure to incorporate l all technical requirements. l VI. CORRECTIVE ACTIONS I The line management response as detailed in CATD Number C011306-SQN-01 was that the issue of pull testing through baseplates did not represent a C&Q. The issue will be addressed further in a revision to NAI-10. In l addition, the issue of anchor overtightening was considered not to I be a problem. A revision.to G-32 which will clarify tightening lR4 l requirements for SSDs will be incorporated into NAI-10. l j: Note: The WBN-ECTG agrees that the overtightening issue is not a 4 restart item requiring immediate attention by SQN. However,

, further evaluation has revealed a programmatic problem exists

, at all sites on this issue. This has been discussed with l DNE-CEB Central Staff personnel who have agreed to review and evaluate potential deficiencies on this subject. The WBN-ECTG will address this issue at the subcategory report level which will encompass the concerns at all sites.

VII. GENERIC APPLICABILITY The WBN-ECTG Element Report (C011306) on the subject of this element did not identify generic applicability. However, this evaluation concludes that generic implications exist for all TVA nuclear plants on the following issues:

4. adequacy of inspections and criteria with respect to anchor shells contacting base plates during proof tests B. potential overtightening of SSD type anchors

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PAGE 13 0F 13 g VIII. ATTACHMENTS Attachment A - Listing of Concerne Indicating Safety Relationship '

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IN 285-002 CD 11300 H HBH YYYY ' I-8 5-6 57-HDil SS TVA INSPECTED AtID PULL TESTED REDHEA T50176 K-FORM -

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IN 115-001 CD 11300 H HBil YYYY 1-85-659-HBH SS SELF DRILLING EXPAllSI0li SHELL ANCHOR T50169 REPORT $ ARE BEING OVERTORQUED. THIS IS DO HE TD CORRECT CXCESSIVE GAP BETHEEN BASEPLATE AND llALL. CRAFT PER$0llHEL ARE NOT TRAIllED TO THE REQUIREMENTS OF SPEC. 0-32 PARAGRAPH.3.2. CONST RUCTION DEPT CONCERN-CI HAS NO FURTH '

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11300 H HBil YYYY SS AN EMPLOYTE TOLD THE CI THAT THE SAF IN 190-003 Co REPORT ETY REL ATED CONCRETE AliCHORS (REHEAD

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SS SEQUOYAH. L'il1T 8 2. PULL TESTS HERE XX 023-001 'C0 11300 S SQti il N Y Y -

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