ML20212H051

Rev 2 to Pipe Stress Calculations:Widespread Deficiencies within Pipe Stress Calculations

ML20212H051
Person / Time
Site:	Sequoyah
Issue date:	01/13/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
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ML20212G828	List: ML20212G824 ML20212G859 ML20212G962 ML20212G991 ML20212H051 ML20212H072 ML20212H095 ML20212H103 ML20212H128 ML20212H145
References
218.4-(B), 218.4-(B)-R02, 218.4-(B)-R2, NUDOCS 8701210268
Download: ML20212H051 (22)

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• ' TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 REPORT TYPE: SEQUOYAH ELEMENT TITLE: PIPE STRESS CALCULATIONS Widespread Deficiencies within Pipe Stress Calculations PAGE 10F 21 REASON FOR REVISION:

1. To incorporate additional information provided by TVA (see App. A) and corrections to citations.

2. To incorporate coments by the SRP, TAS, and TVA; to include TVA's ,

corrective action plan infonnation (see Section 10), to comply with current fonnat requirements, to note the schedule for completion of

" Phase II," and general editorial changes.

PREPARATION PREPARED BY:

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2

' PAGE 2 0F 21

1. CHARACTERIZATION OF ISSUE (S):

Concerns: Issue:

SCN-PF-001 -01 a. Alternate analysis is not as detailed "During the exit interview, the as it should be. Although an NCR CI stated that there is an was created to resolve all discrep-Alternate Criteria NCR for the ancies associated with this analysis inadequacy of alternate piping. method, some discrepancies could Any concerns relating to any remain unresolved beyond startup, alternate piping are put under the NCR. The concern is that this is a ' catch-all' and individual items could go unresolved beyond startup."

SON-86-002-01 "During the exit interview the CI stated that alternate piping analysis does not get as specific as it should. Instances where this piping is not qualified gets put into a ' catch-all' NCR.

This item was addressed and corrected at Watts Bar."

2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by TVA Date As noted below Documentation Identifiers:

a. TVA, NCR, SQNSWP8215, Rev. 0 (09/21/82) I

b. TVA, Findings of the Alternate Analysis Review Team for Sequoyah Nuclear Plant, J. B. Thomison, et al. (09/30/82)

c. TVA, NCR, SQNSWP8222, Rev.0 (12/21/82)

d. TVA, SCR, SONCEB8613, Rev. 0 (02/14/86) e

e. TVA, SCR, SCLCEB8614, Rev. 0 (02/18/66) 1104d - 12/31/86

-TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 21

3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.

None

4. INTERVIEW FILES REVIEWED:

a. Review sheet, concern no. 5QN-86-002-01 (01/29/86)

b. Generic Applicability Determination, SQN-86-002-01, ECTG M.1, Att. F, P. 2 of 2, R1 (06/06/86)

c. Employee Concern Preliminary Evaluation, SQN-86-002-01, Standard Practice, Att. B.2, P. 9, R5 (03/19/86)

d. Review for Generic Evaluation, SQN-86-002-01, Standard Practice, Att. B.3, P.10-11, R5 (03/19/86)

e. Watts Bar Nuclear Plant, Employee Concerns Task Group, Review of ECTG Files - Documentation, Concern SON-86-001-001, H. Van Straalen (10/14/86)

f. Watts Bar Nuclear Plant, Employee Concerns Task Group, Ceview of ECTG Files - Documentation, Concern SQN-86-002-001, H. Van Straalen (10/14/86)

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

t

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL ON THIS AREA?

See Appendix A.

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELD 4ENT.

See Appendix A.

i 1104d - 12/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 21 8.4 (8 )

SPECIAL PROGRAM REVISION NUMBER: 2

. PAGE 4 0F 21 s

P. EVALUATION PROCESS:

a. Reviewed the Sequoyah Nuclear Plant Alternate Analysis Review Program for suitability as stand-alone qualification of Alternate Analysis piping.

b. Reviewed expurgated file for any additional information.

9. DISCUSSION, FINDINGS AND CONCLUSIONS:

Chronology:

i 09/21/32: NCR SQNSWP8215 identifies generic technical and documentational deficiencies in the Alternate Analysis 2 criteria used for design of piping.

, 09/30/82: A report is issued by the " Alternate Analysis Review Team" identifying " discrepancies" in the Alternate Analysis criteria'and its implementation at Sequoyah and providing recommendations for corrective action.

12/21/82: NCR SQNSWP8222 identifies failure of EN DES ". . . to develop a procedurally controlled system to ensure that all [ Alternate Analysis piping] has been

• supported to the appropriately specified criteria."

02/14/86: SCR SQNCEB8613 identifies that ". . . Alternate Analysis criteria was misapplied for the Containment Supply Pump 1 A-A miniflow line . . . ."

02/18/85: SCR SQNCEB8614 identified potential discrepancies due to branch line interface movements and extended operators.

circa 05/86: Alternate Analysis Review Program is implemented.

i 06/06/86: Employee Concerns SQN-86-001-01 and SQN-86-002-01 received by TVA.

i Discussion:

Nuclear power plant piping systems that are important to safety are designed to code requirements for loadings such as gravity, thermal expansion, internal pressure, and earthqur'e. For the Sequoyah plant, TVA has generally performed such designs by two types of analysis: Rigorous Analysis and Alternate Analysis.

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218.4 (B)

TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM REVISION NUMBER: 2 E PAGE 5 0F 21 Rigorous Analysis is a computer simulation (by finite-element analysis) of piping behavior for postulated loads and an evaluation of the results of that simulation by a comparison to detailed l engineering data on the strength of the piping material. Alternate Analysis is a simplified handbook method for locating and sizing pipe supports. Both Rigorous and Alternate Analysis are performed for safety-related piping. Nonsafety-related piping (e.g.,

" deadweight-supported") is designed by other means.

The employee concerns, as interpreted, are that the Alternate

• Analysis of piping performed for Sequoyah ". . . does not get as specific as it should," and that, while this concern may be recognized by TVA, individual items are relegated to a " catch-all" nonconformance report (NCR) and, " individual items could go unresolved beyond startup." ,

Section 2, herein, cites reports in which TVA has identified deficiencies in the Alternate Analysis piping designs and design documentation. Implementation of Alternate Analysis for the Sequoyah plant was reviewed in 1982 (Sec. 2.b). This "was not intended to be an exhaustive study," (Sec. 2.b, Introduction) however, a number of " Discrepancies, General Safety Implications and Recommendations" were presented (Sec. 2.b, IV). These are paraphrased as follows:

1. The Alternate Analysis criteria reports may not have censidered seismic response spectra for all buildings for which they may have been used.

2. Alternate Analysis piping may not have been supported to take the loads that may be imposed by adjoining deadweight i

supported piping which is not seismically restrained.

3. Flanges have not been evaluated for bolt stress.

l

, 4. Equipment nozzle loads have not always been evaluated.

5. Valves and other concentrated weights may not have always been supported in accordance with the design criteria.

6. Axial supports may not have always been located according to the design criteria.

7. Documentation of design data CEB 74-2 ( App. A, 5.u) has not been verified.

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• TVA EMPLOYEE CONCERNS REPORT hdriBER: 218.4 (B) x SPECIAL PROGRAM s REVISION NUMBER: 2 .

PAGE 6 0F 21

8. Stress intensification factors may not have been considered in alternate criteria CEB 80-5 ( App. A, 5.t).

9. Revision 2 Addenda to' CEB 60-5 ( App. A, 5.t) is not in MEDS (MEDS is an acronym for a TVA document control system).

10. Support loads in CEB 80-5 ( App. A, 5.t) are significantly .

higher than in CEB 76-5 ( App. A, 5.am). .

4

11. Thermal expansion and anchor movement may sometimes have been f ignored.

12. No documentation was found to support CEB 75-9 (SQN- and WBN-Design Data for Support of Category I Stainless Steel and ~

Copper Tubing as cited in App. A, 5.p, II, A,1, c)

13. Documentation of analyses in many cases has not been \

completed in enough detail to document the scope and basic assumptions used. ,

14. The general technical errors identified during the dBN review '

and documented in NCR WBNSWP8231 were also generally evident on SQN analyses that used CEB 76-5.

15. Some analyses have not been reviewed and kept currtint for "

~

support and piping revisions that occurred subsequent to the '

original design. ,

i A nonconformance report (NCR SQNSWP8215, see App. A, 5.o) wan prepared on September 21, 1982 as a result of these findings. A ,

point-by-point response was attached to a memorandum f om John A.

Raulston to T. C. Campbell, November 26,1982 ( App. A, E.o).

Subsequently, a two-phase program was instituted by TVA to resolve l l concerns arising from some pf the observed deficiencies ( App. A, 5.w) as per NCR SQNSWP8215. 8 l In Phase I of the program, ". . . potential deficiencies which may l cause inoperability of those systems required to mitigate FSAR Chapter 15 events and safely shut down the plant will be evaluated and resolved prior to restart" (from App. A, 5.w, 3.3). Phase I '

l 1 TV/ tas subnitted detailed infonnation describing this program to the NRC

for review (see e.g., App. A, 5.ax). In addition, the NRC condacted a '

technical audit on aspects of the program on a visit to the Sequoyah site 10/Of/E6 - 10/10/86. The evaluation team is not informed of any formal URC conclusions.

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m 4

218.4 (B) r TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM REVISION NUMBER: 2

~

PAGE 7 0F 21 will address three primary areas of concern: 1) whether there is adequate flexibility of branch piping to accept attachment-point-imposed motions, 2) whether pipe stress and pipe support loads were computed with due consideration of the center-of-gravity locations of motor-operated valves, and 3) whether the interfaces between deadweight-supported piping and Alternate Analysis piping greater than 2 inches in diameter were properly evaluated. Licensing basis design criteria will be relaxed for Phase I as described in App. A, 5.x, 5.z, and 7.e.

In Phase II of the program ". . . evaluations that were made prior i to restart will be extended to other alternate [ly] analyzed Category I ANS safety class piping . . ." (from App. A, 5.w, 3.4).

Phase II originally addressed four primary areas of concern: 1) whether there is adequate flexibility for thermal expansion generally, 2) whether the interfaces between deadweight-supported piping and Alternate Analysis piping less than 2-1/2 inches in s .

diameter were properly evaluated, 3) whether long straight lengths

- of piping and integral concentrated weights were adequately supported, and 4) whether " worst-case" examples of supports are adequately designed. Phase II evaluations will comply with the licensing basis design criteria ( App. A, 5.w, 4.2). Recently, TVA has said:

" Phase II of the SQN Alternate Analysis ( AA) Review Program has been expanded to include the requirement that all Category I ANS Safety Class piping be reviewed, and that documentation be developed to demonstrate that all design requirements are met. Thi3 includes identifying and resolving piping and support deficiencies (if any) that are unrelated to the Phase I/ Phase II items. The AA Review Program Procedure (SQN-AA-001) is being revised to reflect this program change" ( App. A, 5.ba and App. A, 7.q).

o Phase II is scheduled to be completed during the second refueling outage following restart for Unit #1 and during the third refueling outage following restart for Unit #2. ( App. A, 5.w, p.19).

Based upon discussions with TVA personnel and review of the documents listed in section 2 herein, the evaluation team believes the employees' concerns were valid when stated. Because TVA has  !

instituted the above program to upgrade the documentation for Alternate Analysis piping, the evaluation team has reviewed that

' program to detemine if it will adequately resolve the concerns. l The remainder of this report therefore addresses the adequacy of the above program to assure qualification of all Alternate Analysis piping.

110ed - 12/31/86

j TVA EMPLOYEE CONCERNS REPORT NLMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 21 The Alternate Analysis Peview Program ( App. A, 5.c) addresses item nos. 2, 5, 6, and 11 above as discussed below.

ITEM NO. 2: CONSIDERATION OF ALTERNATE / DEADWEIGHT INTERACTION Item no. 2 is partially addressed (piping over 2 inches in diameter only) in Appendix A, 5.c as a prerestart item. SQN's commitment is:

"The interface between alternately analyzed piping and position retention for pipe sizes greater than 2" will be reviewed for adequate lapped regions and deficiencies will be evaluated and resolved" (from App.

A, 5.c , p.10,- para. 6) .

The specific procedure for performing the review is defined in Appendix A, 5.d, 3.6 as follows: ,

"1. Determine if the configuration of the [ Alternate

- Analysis] and [ Deadweight] piping and supports is such that the [ Alternate Analysis] piping through the class change is essentially isolated from seismic loads that would result from seismic movement of the [ Deadweight] supported piping. If so the justification for this conclusion will be documented and no further action will be taken.

"2. If the interface is not such that [ Alternate Analysis] piping is isolated from the [ Deadweight]

piping the piping at the interface will be evaluated and resupported if necessary. This evaluation will be made on a case-by-case basis."

This appears to be a reasonable approach. Its actual validity, however, rests heavily on the experience of the individual reviewer to correctly judge when Alternate Analysis piping is " essentially

' isolated" from the Deadweight supported piping and when it is not.

The evaluation team has reviewed a sample of four calculations

( App. A, 5.ar through 5.au). Problem N2-26-A-301 A is an example of an individual reviewer qualifying an interface by judgment. The approach was to estimate the natural frequency of piping in the interface and then to estimate seismic stress. The estimated stress in one instance was 888 psi (see App. A, 5.ar, p. 31). The conclusion was that the Deadweight supported piping had no significant effect on the Alternate Analysis piping. The evaluation team concurs with this particular judgment though it

(

notes that the estimated 888 psi stress was not compared to any specific acceptance criteria.

Il04d - 12/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 21 The balance of the item no. 2 issue of Section 2.b is addressed in the Alternate Analysis Review Program as a postrestart item. The rationale for the postponement is:

"Similar deficiencies of this type in 2" and smaller piping are less significant because the smaller mass of that piping reduces the possibility of piping and support failures. Also, valves and equipment at the interfaces between alternately analyzed piping and position retention-supported piping are relatively stronger for smaller piping. Therefore, deficiencies in this category for 2" and under piping do not represent a short term safety concern and resolution of those deficiencies will be accomplished during the Phase II portion of the alternate analysis review program" (from App. A, 5.c, 3.3(3)).

In the opinion of the evaluation team, the postponement to Phase II is reasonable.

ITEM NO. 5: SUPPORT OF YALVES AND CONCENTRATED WEIGHTS.

Item no. 5, described above, is addressed in the Alternate Analysis Review Program partly as a prerestart item ( App. A, 5.c, 3.3(2))

and partly as a postrestart item. SQH's commitments are:

PRERESTART COMMITMENT

". . . Motor operated and pneumatic valves in alternately analyzed piping will be reviewed and deficiencies will be evaluated and resolved. The influence of supports adjacent to the val [v]e will be evaluated simultaneously with the torsional effect" (from App. A, 5.c, 5.3 (2)).

And, POSTRESTART COMMITMENT

". . . An engineering review will be performed during Phase II, [i.e., postrestart) to identify situations where requirements for support of . . .

concentrated weights may have been overlooked.

Deficiencies in this category will be evaluated and resolved" (from App. A, 5.c, 3.4 (3)).

Il04d - 12/31/86

i s

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 21 Detailed instructions are provided in Appendix A, 5.e,Section IV.E for computation of piping moments (a " moment" is a bending or twisting force) due to the effect of a mass integrally attached to the piping but offset from the piping centerline. The instructions have been revie'wed and are judged to be adequate.

The instructions given for evaluation of concentrated weights-( App. A. 5.e, IV.C) have been reviewed and are judged to be adequate.

ITEM N0. 6: LOCATION OF AXIAL SUPPORTS Item no. 6 of Section 2.b, described above, is addressed in the Alternate Analysis Review Program as a postrestart item. SQN's commitment is:

". . . An engineering review will be performed during Phase II [i.e., postrestart] to identify situations where requirements for support of axial runs . . . may have been overlooked" (from App. A, 5.c, p.13, para. 3).

Detailed instructions are provided in Appendix A, 5.ae,Section IV, D for evaluation of piping for axial support. The instructions have been reviewed and are considered adequate.

ITEM NO.11: THERMAL EXPANSION AND ANCHOR MOVEMENTS Item no.11 of Section 2.b, described above, is addressed in the Alternate Analysis Review Program as a postrestart item.2 SQN's commitment is:

. . . Piping with operating temperatures greater than 120 degrees Fahrenheit will be reviewed and potential deficiencies will be evaluated and

, resolved" (from App. A, 5.c, p.12, para. 2).

l 2 TVA has stated that the program is being revised to require prerestart evaluations of piping operating at temperatures greater than or equal to 200'F (App. A, 5.ao). TVA submitted a description of changes to interim i

(Phase I) acceptance criteria to the NRC on November 10,1986 ( App. A, 5.ba). The stated temperature cut-off was "2000F" rather than the intended 200 F: an apparent typographical error tit is stated as 200 F in the source document: App. A, 5.ap). l l

1104d - 12/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER:- 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 110F 21 The evaluation team believes that this commitment is adequate.

The rationale as to why the remaining items, not specifically addressed in App. A, 5.c, are no longer of concern is described in TVA's reply to RFI SQN-695. The TVA reply is discussed below.

ITEM NO.1: UNCONSERVATIVE SEISMIC RESPONSE SPECTRA TVA states ( App. A, 5.ap) that, based upon experience with the Watts Bar Alternate Analysis review program, it was determined that

". . . seismic stress is not a problem for this piping except for large concentrated weights, long axial runs and the interface with deadweight . . . supported piping. Each of these potential problem areas are being addressed in the [Sequoyah31A Review Program using response spectra for the applicable structure. . . ."

The evaluation team believes TVA's observations are correct.

ITEM 3: FLANGE BOLT STRESS EVALUATIONS TVA states ( App. A, 5.ap) that " Flange bolt stress evaluation is rot required for SQN." The evaluation team concurs with this view. The applicable code is USAS B31.1.0-1967 (see App. A, 6.a, Table 3.9.2-2). Flange qualification is covered in Sections 104.5 and 108.1. Bolt selection is limited by Section 108.5.1 which obviates the need for flange bolt stress evaluations.

ITEM 4: EQUIPMENT N0ZZLE LOADS TVA states ( App. A, 5.ap) that equipment nozzle loads are being evaluated within the Alternate Analysis Review Program (App. A, 5.ac) ". . . where an equipment nozzle is affected by one of the deficiencies being evaluated in the [ Alternate Analysis] Review Program." This approach will assure qualification of equipment nozzles for systems evaluated for any of the seven deficiencies addressed by Alternate Analysis Review Program. However, it does not assure that nozzles in other systems will be qualified. The evaluation team believes the approach is reasonable provided that, if generic nozzle load problems are identified within the above evaluations, the Alternate Analysis Review Program will be expanded to include nozzle qualification for all Alternate Analysis piping.

A review of several Alternate Analysis Review Program calculations reveals that equipment nozzle evaluations are being performed (see App. A, 5.ar through 5.au).

1104t - 12/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2

' PAGE 12 0F 21 ITEM 7: DOCUMENTATION OF CEB 74-2 TVA has stated that CEB 74-2 is not currently used for design (see App. A, E.ap) . Therefore, the evaluation team considers any verification of CEB 74-2 data to be unnecessary since all Alternate Analysis piping, including that designed to CEB 74-2 criteria, is being reevaluated within the Alternate Analysis Review Program.

ITEM 8: CEB 80-5 STRESS INTENSIFICATION FACTORS TVA has stated (see App. A, 5.o and 5.ap) that stress intensification factors were considered in CEB 80-5 ( App. A, 5.t).

The document itself states that for seismic plus gravity load cases:

" Stress intensification factors of short radius elbows and socket welded elbows were calculated and included in the stress evaluation in accordance with the requirements of the B31.1 Code" ( App. A, 5.t, p.15).

Appendix B of CEB 80-5 includes separate tables of support spacings to accommodate thermal expansion for piping containing butt-welded joints, socket-welded joints and elbows. Therefore it is apparent that stress intensification factors have been considered for both primary and secondary loads.

ITEM 9: CEB 80-5, REY. 2 NOT IN MEDS This is a documentational deficiency. TVA intends to correct this deficiency after Unit 2 restart (see App. A. 5.ap). The evaluation team believes this is a reasonable approach.

ITEM 10: CEB 80-5 DESIGN LOADS ARE HIGHER THAN CEB 76-5 DESIGN LOADS TVA has stated that the CEB 80-5 design loads are higher than those of CEB 76-5 due to the differences in the way in which such loads l were derived. The evaluation team sees no reason to believe that either criteria is unconservative. Therefore, this item is resol ved.

ITEM 12: CEB 75-9 MAY BE UNVERIFIED CEB 75-9 provides design criteria for stainless steel and copper tubing. The Alternate Analysis Review Team noted that CEB 75-S is

! generally thought to be very conservative (See 2.b, p.13, item 12). TVA has stated that this concern will be addressed after Unit 2 restart ( App. A, 5.ap). The evaluation team believes this is a reasonable approach.

l 1104d - 12/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 13 0F 21 ITEM 13: INCOMPLETE DOCUMENTATION TVA has found that generic documentational deficiencies did exist in the application of Alternate Analysis criteria at Sequoyah (Sec. 2.a). The Alternate Analysis Review Program (App. A, 5.ac) is intended to address this problem, however, the program, as reviewed, does not require that documentation demonstrating compliance with all aspects of the design criteria will be on file for each piping problem (see e.g., App. A, 5.w, 3.3 and 4.2 and App. A, 5.an, 5.3). However, TVA has stated that the program is being revised to require such documentation (see App. A, 5.ba).

ITEM 14: WATTS BAR REVIEW TVA states ( App. A, 5.ap, conclusion b, item 14) that the reviews discussed in its comments on Item No.1, as provided in its response to RFI SQN-707, resolve any significant deficiencies related to Item 14. In its comnients on Item No.1 (see App. A, 5.ap), TVA stated that:

" Based upon our experience ir. the WBN AA Review Program, s

1[t] was determined that seismic stress is not a problem for this piping except for large concentrated weights, long axial runs and the interface with deadweight . . .

supported piping."

TVA then went on to say that each of the above three exceptions is being addressed in the present Sequoyah Alternate Analysis Review Program. The experience and conclusions of the evaluation team are similar to those of TVA. Therefore, it is concluded that the Alternate Analysis program adequately addresses this issue.

ITEM 15: ANALYSIS NOT CURRENT Cne of the primary purposes of the present Alternate Analysis Review Program is to address this issue. Therefore, this issue should be considered resolved upon satisfactory completion of the present program.

i This ends the discussion of how the Alternate Analysis Review Program addresses the findings of the Alternate Analysis Review Team described above.

1104d - 1?/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISTON NUMBER: 2 PAGE 14 0F 21 One other issue is addressed by the program: adequacy of support designs. The Alternate Analysis Review Program addresses the adequacy of support designs with the following commitment:

. . . [The] review will be accomplished by selecting

' worst-case' support designs . . . Supports will be l evaluated as necessary to develop confidence that the supports meet design requirements [from App. A, 5.c, P. 13, Para. 6]. "

The evaluation team is not aware of any specific instructions for selecting the " worst-case" supports for review or for performing the reviews themselves. However, there are instructicns for reviewing the adequacy of pipe supports to withstand seismic and thermal motions imposed at analysis interfaces ( App. A, 5.aa), for reviewing the effects of unsupported motor-operated valves ( App. A, 5.d, 3.5), and for evaluation of pipe support designs generally

( App. A, 5.ab) .

The evaluation team considers the Alternate Analysis Review Program to be incomplete in that pipe support spacing for seismic and i

gravity loading is not specifically addressed. However, TVA has stated (see App. A, 5.ba and 7.q) that the program is being revised to include verification of support spacing generally during Phase II. Deficiencies will be addressed and corrected as l necessary. This change resolves the evaluation team's concerns related to this item.

The interim acceptance criteria ( App. A, 5.x and 5.aq) have been reviewed as amended by the revision (draf t) provided in App. A, 5.ap (see al so App. A, 5.ba) . The interim acceptance criteria for pipe stress are essentially that piping operating at 200*F and below will not be evaluated for thermal expansion until Phase II (postrestart). The evaluation team considers this to be a reasonable approach. TVA has submitted a description of this interim acceptance criteria to the NRC ( App. A, 5.ba).

Findings:

a. At the time the employees' concerns were stated, documentation assuring the qualification of some Alternate Analysis piping was incomplete.

b. TVA has instituted the Alternate Analysis Review Program to upgrade the design and associated documentation of Alternate Analysis piping to meet all design criteria requirements.

This program is intended to address, prior to restart (i.e.,

during Phase I), potential deficiencies which could cause FSAR chapter 15 type events or prevent the safe shutdown of the plant.

Il04d - 1?/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 i PAGE 15 0F 21

c. The Alternate Analysis Review Program is being revised to l require documentation to'show that all Alternate Analysis ,

piping is qualified to all design requirements by the second l refueling outage following restart for Unit #1 and by the l third refueling outage following restart for Unit #2 (i.e.,

by completion of Phase II). ,

d. Thermal expansion evaluation for piping 200*F and less is l postponed to Phase II.

e. The program is being revised to include a general evaluation l of the conformance of Alternate Analysis piping to the design criteria for gravity and seismic loading.

f. Qualification of integral (i.e., welded) attachments to I Alternate Analysis piping is included as part of the Alternate Analysis Review Program ( App. A, 5.ap).

Conclusions:

( The employees' concerns were valid at tt'e time they were expressed. TVA has subsequently instituted a program to address deficiencies in the design and design documentation of Alternate Analysis piping. The Alternate Analysis Review Program is adequate to resolve the employees' concerns provided that:

a. the comitment ( App. A, 7.q) is carried out to upgrade the program to require that documentation be developed in Phase II to demonstrate that all design requirements are met for all alternately analyzed piping.,

b. the comitment ( App. A, 7.q) is carried out to verify that all Alternate Analysis piping support spacings conform with all design criteria requirements by completion of Phase II. I

10. CORRECTIVE ACTION:

TVA has submitted a corrective action plan ( App. A, 5.bb) which includes commitments to: (a) Revise SCN-AA-001 ". . . to require that documentation be developed in Phase II to demonstrate that all design requirements are met for all alternately analyzed piping . . ." and (b) revise SQN-AA-001 ". . . to require verification in Fhase 11 that support spacings for alternately analyzed piping are such that design requirements are satisfied."

This corrective action is satisfactory to the evaluation team.

1104d - 1?/31/86

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

7 TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 21 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. Piping Analysis Prob. No. N2-03-A-338A (not approved)

b. Piping Analysis Prob. No. N2-72-A-301 A (not approved)

c. Alternate Analysis Review Program, Alternate Analysis Manual, SON-AA-001 (06/25/86)

d. Alternate Analysis Review Program, Evaluation of Piping for Phase I Issues, SQN-AA-006 (06/25/86, not approved)

e. Alternate Analysis Review Program, General Guildelines [ sic]

for Case-by-Case Evaluation of Piping for Deadweight and Seismic Load Cases, Rev. 0 (06/18/86)

f. Alternately Analyzed Piping Review Program, Phase I, Pipe Stress and Support Design - Load Combinations, Allowable

/ Stress and Allowable Loads (06/20/86, not approved) k g. Alternate Piping Analyses and Support Criteria for Category I Piping Systems, Design Criteria No. SGN-DC-Y-13.7 (04/01/73, Rev. 2,10/04/84)

h. Sequoyah Restart Schedule Change Form (05/23/86): Correct Misapplication of Alternate Analysis Criteria for Containment Spray Miniflow Lines (remove from schedule)

1. TVA memo from D. W. Wilson to J. A. Raulston, Chief Nuclear Engineer (05/14/66): SCR-SQNCEB8613 (SCR attached)

j. Engineering Report, Rev. 1 (05/09/86): SCR SQNCEB8613 R0

k. TVA memo from K. L. Mogg to Dave Wilson (04/29/86): SCR CEB8613 and 8614

1. TVA memo from K. L. Mogg to T. C. Cruise (04/17/86): SCR SQNCEB8613 and 8614

m. Engineering Report, Rev.1 (not approved): SQhSWP8215 R0

n. Nonconformance Report, SQNSWP8222 (12/21/62) k 1104d - 12/31/86

c TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 L PAGE 17 0F 21 APPENDIX A (cont'd)

o. TVA memo from John A. Raulston to T. G. Campbell (11/26/82, attached: SQHSWP8215 and failure evaluation)

p. TVA memo from J. B. Thomison to R. O. Barnett et al.

(10/05/82, attached: Findings of the Alternate Analysis Review Team for Sequoyah. . . )

q. Potential Impact Item Data Sheet, Item No. SQN-223, Rev. O

r. TVA memo from W. B. West to Dave Wilson et al. (05/23/86, attached: Engineering Report, Rev.1, not approved, prepared 05/22/86)

s. Design Criteria No. SON-DC-V-13.3, Rev. 3 (08/13/84),

Detailed Analysis of Category I Piping Systems ,

t. Alternate Criteria for Piping Analysis and Support, EDS Report No. 0600105-01, Rev.1 (06/85 TVA procedure 80-5)

u. Sequoyah Nuclear Plant, Earthquake and Dead Load Design Data for Small Diameter Carbon Steel and Aluminum Piping, CEB 74-2 (05-18-74)

v. Alternate Analysis Review Program, Instruction Index (no date)

w. Alternate Analysis Review Program - Program Description -

SQN-AA-001 (07/01/86)

x. Alternate Analysis Review Program, Pipe Stress and Support Design Screening and Evaluation, Load Combinations, Allowable Stress and Allowable Loads, SQh-AA-003 (07/09/86)

y. Title 10, U.S. Code of Ferieral Regulations, Chapter 50

z. Sequoyah Nuclear Plant, [TVA reply to] NRC Technical Information Request on Interim Acceptance Criteria, Civil Engineering Programs (transmitted 8/12/86) aa. Alternate Analysis Review Program, Evaluation of Piping for Anchor Movement Load Cases, SQN-AA-005, Rev. 0 (6/30/86) ab. Alternate Analysis Review Program, Instructions for Pipe Support Design, SON-AA-009, Rev.1 (8/9/86) 1104d - 12/31/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2  !

( PAGE 18 0F 21 APPENDIX A (cont'd) ac. Alternate Analysis Review Program, Program Description, SQN-AA-001, Rev. 0 (7/7/86)-

ad. Alternate Analysis Manual, Documentation of Alternate Analysis Packages, SQN-AA-002, Rev. 0 (6/28/86) ae. Alternate Analysis Review Program, General Cuidelines for Case-by-Case Evaluation of Piping for Deadweight and Seismic Load Cases, SQN-AA-004 (6/18/86) af. Alternate Analysis Review Program, Evaluation of Piping for Anchor Movement Load Cases, SQN-AA-005 (6/3/86)-

ag. Alternate Analysis Review Program, Evaluation of Piping for Phase I Issues, SQN-AA-006, Rev. 0 (7/4/86) ah. Alternate Analysis Review Program, Procedure for Scoping, SQN-AA-007, Rev. 0 (7/4/86) aj. Alternate Analysis Information Bulletin No. SQN-AABU-010, Rev. 0 (7/12/86): Evaluation of Spacing Violations and Embedded Plates ak. Alternate Analysis Information Bulletin No. SQh-AABU-015, Rev. 0 (7/12/86): Rigid Response al. Alternate Analysis Infonr.ation Bulletin No. SON-AABU-14, Rev.

0 (7/12/86): Seismic and Thermal Anchor Movement am. Alternate Criteria for Piping Analysis and Support, CEB-76-5, Rev. 3 (6/13/83) an. Sequoyah Nuclear Performance Plan, Volume II (07/14/86) ao. TVA letter from D. M. Wilson to S. S. Chitnis, Bechtel (10/18/86) with attachment 1: Sequoyah Nuclear Plant, Engineering Related Employee Concerns, Special Program.

ap. TVA reply to RFI SQN-695, (11/05/86) aq. TVA licensing transmittal to NRC on interim acceptance criteria, TVA Transmittal 103, Item #14, (08/12/86) 1104d - 12/31/86

^

- TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 i PAGE 19 0F 21 APPENDIX A (cont'd) a r. TVA Calculation No. N2-26-A-301 A, R0, (09/14/86) as. TVA Calculation No. N2-61-A-301 A, R0, (09/1S/86) at. TVA Calculation No. N2-70-26A through N2-70-41 A, R7 (not dated or approved) au. TVA Calculation No. N2-87-A-301 A, R0, (09/14/86) av. TVA NCR WBNSWP8231, (06/16/82) aw. TVA, Watts Bar Nuclear Plant, Program for Alternate Analysis Fix - Coordinating, Documenting, and Verifying, OE-SEP 82-18, R3, (No date) ax. TVA reply to RFI SQN-713 ay. USA Standard Code for Pressure Piping, USAS B31.1.0-1967, ASME az. [TVA] Response to Request for Information No. SQN-738 (11/25/86) ha. TVA comments provided as a follow-up to telecon of 11/26/86 and acknowledged by RFI SQN-745 bb. TCAB-034, Corrective Action Plan (CAP) for Element 212.4 (B),

(12/18/86)

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

a. TVA, Sequoyah Nuclear Plant, Final Safety Analysis Report Il04d - 12/31/F6

t TVA EMPLOYEE CONCERNS REPORT NIMBER: 218,4 (B)

SPECIAL PROGRAM REVISION NUMBER: 2' PAGE 20 0F 21 APPENDIX A (cont'd)

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSI0h5 RELATED TO ELEMENT.

a. Bechtel RFI #559 (09/18/86)

h. Bechtel RFI #560 (09/15/86)

c. Meeting, J. Blanco and R. Lilkinson, Bechtel, D. Wilson, TVA (08/23/86)

d. Bechtel RFI #575 (09/19/86)

e. Telecon, R. Wilkinson, Bechtel, to D. Wilson, TVA, (Bechtel IOM 331,10/21/86)

f. Bechtel RFI #640 (10/16/86) 9 Bechtel RFI #648 (10/21/86)

h. Bechtel RFI #655 (10/23/86)

1. Bechtel RFI #658 (10/24/86)

~

J. Telecon from N. Liakonis et al., TVA, to M. Khalafallah et al., Bechtel (10/31/86)

k. Bechtel RFI #674 (11/04/86)

1. Bechtel RFI #693 (11/05/60)

m. Bechtel RFI #695 (11/06/86)

n. Bechtel RFI #707 (11/11/86)

o. Bechtel RFI #713 (11/13/86)

p. Bechtel RFI #738 (11/24/86)

q. Telecon, from C. Seidle et al., TVA, to S. Chitnis, l R. Wilkinson, Bechtel (11/26/86)

r. Bcchtel RFI #745 (12/01/86)

s. Telecon, from R. Wilkinson, Bechtel, to B. L. Stocrker,1%,

(12/24/86) 110td - 12/31/86

i TVA EMPLOYEE CONCERNS REPORT NtMBER: 218.4 (B)

SPECIAL PROGRM REVISION NUMBER: .2

)

PAGE 210F 21 CATD LIST The following CATD identify and provide corrective actions for the findings included in this report:

218 04 SON 01 (12/17/86) i i

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88 REFERENCE - ECPS120J-ECPS121C RUN TIHE - 12:57:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR P0HER RUN DATE - 12/02/86 ONP - ISSS - R1:M EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

LIST OF EIFLOYEE CONCERTI INFORMATION CATEGCRY: EN DES PROCESS & OUTPUT SUBCATEGORY: 21804 PIPIN3 CALCULATIONS S GENERIC KEYWORD A H APPL QTC/NSRS P KEYHORD B SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C CONCERN KEYHORD D CAT D LOC FLQB REPORT R DESCRIPTION

) NUMBER CAT SS DURING THE EXIT INTERVIEH, THE CI ST

, SON-86-001-001 EN 21804 N SQN YYNY K-FORM ATED THAT THERE IS AN ALTERNATE CRIT

,] ERIA NCR FOR THE INADEQUACY OF ALTER

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' I NATE PIPING. ANY CONCERNS RELATING TO ANY ALTERNATE PIPING ARE PUT UNDE R THE NCR. THE CONCERN IS THAT THIS g

IS A " CATCH-ALL" AND INDIVIDUAL ITE MS COULD GO UNRESOLVED BEYOND STARTU P.SIMILAR TO SQN-86-002-001 SQN-86-002-001 EN 21804 N SQN YYYY SS DURING THE EXIT INTERVIEW THE CI STA I K-FORM TED THAT ALTERNATE PIPING ANALYSIS D DES NOT GET AS SPECIFIC AS IT SHOULD

. INSTANCES HHERE THIS PIPING IS NO T QUALIFIED GETS PUT INTO A " CATCH-A LL" NCR. THIS ITEM HAS ADDRESSED AN 8

ll D CORRECTED AT HATTS BAR. SI I MILAR TO SQN-86-001-001 1

2 CONCERNS FOR CATEGORY EN SUBCATEGORY 21804 lI

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