ML20214H976
| ML20214H976 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/07/1986 |
| From: | Howard J, Portwood G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214H850 | List:
|
| References | |
| C011301-SQN, C011301-SQN-R05, C11301-SQN, C11301-SQN-R5, NUDOCS 8612010107 | |
| Download: ML20214H976 (16) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER:
5 TITLE: Dealgn of Plates PAGE 1 0F 15 REASON FOR REVISION:
To incorporate coments Revision 1 To incorporate TAS and SRP coments Revision 2 To incorporate TAS, SRP, and NRC coments Revision 3 To update listing of concerns Revision 4 To incorporate SRP coments Revision 5 m
JUtEPARATION PREPARED B.
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DATE REVIEWS PEER:
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SIGNATURE DATE D
CONCURRENCES' ll* Y"N CEG-H:
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SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
ECSP MANAGER DATE MANAGER OF NUCLEAR F0WER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
1274T 8612010107 861117 PDR ADOCK 05000327 P
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAM REVISION NUMBER:
5 PAGE 2 0F 15 I.
Introduction The concerns in this element, IN-85-031-001, IN-85-109-X04, OE-QMS-8, lR4 IN-85-033-001, and In-85-103-001 address the design of plates.
l II.
Summary of Perceived Problems The perceived problems address the following items:
A.
Errors, omissions, and incorrect assumptions were not corrected in design calculations.
B.
EnDes Procedure 4.03, Appendix 4, which addresses visual acceptance of load additions to embedded plates (embeds), is not adequate.
C.
TVA is not in compliance with Nuclear Regulatory Commission (NRC)
IE Bulletin 79-02 in that base plate flexibility is not a design consideration.
D.
Concrete anchor bolt load allowables for wedge bolt anchors are (R4 greater for Unit 1 than for Unit 2.
1 III. Evaluation Methodology A.
Reviewed the Sequoyah Nuclear Plant (SQN) Generic Concerns Task Force (GCTF) Report on " Inspection and Design Criteria Inadequate on Embedded Plates" for content, adequacy, and findings.
B.
Reviewed the Watts Bar Nuclear Plant (WBN) Employee Concerns Task Group (ECTG) Element Report on the Design of Plates (C011301) to determine generic applicability to SQN as well as content.
C.
Reviewed existing Nonconformance Reports (NCRs) Significant Condition Reports (SCRs), NRC IE Bulletin 79-02, Nuclear Safety Review Staff (NSRS) reports, Nuclear Engineering Procedures, Civil Design Standards, and other documentation and correspondence as required to determine applicability to the subject of this element.
D.
Interviewed knowledgeable personnel, as listed, to evaluate their i
input on applicable areas of the subject of this element. Civil l
Design Analysis (CDA) engineer, SQN - Division of Nuclear (R3 Engineering (DNE); two Civil Design engineers, SQN-DNE; SQN 1
Compliance / Licensing engineer; SQN Electrical Modifications engineer; i DNE-SQN Engineering Project engineer; DNE-Civil Engineering Branch (CEB) Central Staff engineer; SQN Construction M & A Hanger Group lR4 Engineer.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER: 5 PAGE 3 0F 15 IV.
Summary of Findings r
A.
A detailed review of the SQN-GCTF report on Inspection and Design Criteria Inadequate on Embedded Plates revealed the following:
1.
The findings with respect to concern IN-85-033-001 were that l
EnDes Procedure 4.03, appendix 4, applied to WBN only. This I
evaluation agrees with that finding. The SQN-GCIF report also I
stated, "There are no issued instructions for visual approval of l FCRs due to minor loads." This, however, is not a true I
statement. Construction Specification N2C-937 (Locating l
Attachments on Embedded Plates) section 2.5.2, provides l
mechanism for visual examination of. embedded plates by site OE (R4 personnel. This allows for approval of Field Change Request l
(FCRs) without a sketch if the visual examination determines l
that detailed evaluation of the plate (calculation and analysis)
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is not required. Discussions with responsible engineers in the l
SQN site DNE Civil Design Analysis Section revealed that the 1
visual approval mechanism allowed by N2C-937 was not used at SQN. l Therefore, additional evaluation by the WBN-ECTG was performed I
i and revealed significant details on this subject.
l A process is used by the Civil Structural Design Group which l
allows for " preliminary approval" of minor loads attached to I
embeds. This preliminary approval consists of engineering i
evaluation of the specific embed attachment by the responsible i
engineer. FCRs, Engineering Change Notice (ECNs), new l
attachments, alternate analysis review and revised loadings per l
rigorous analysis are sufficient reason to initiate this l
evaluation. A detailed sketch of the individual feature or I
attachment only is attached to a log sheet used for attachments l
to embeds. This sketch along with the information included lR4 on the log sheet provides sufficient detailed information l
for the responsible engineer to evaluate the installation.
l For cases where minor loads are approved without detailed I
calculations being performed, a note is made on the log sheec l
that only a minor load is involved. Subsequently, the assembled 1 information is entered into the group's computer data base l
which will establish a baseline of information for future i
reference. Eventually, detailed calculations can be performed l
on the embed that will include the minor loads which receive l
only preliminary approval under the current program.
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However, it should be noted that this program has been in place
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for approximately 6 months only. Therefore, only the detailed l
calculations for each identified embed attachment submitted l
since the program's origination date and future calculations for I
specific embed attachments will be retrievable from the data l
base. All other existing embeds, including attachment l
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TVA ENPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER:
5 PAGE 4 0F 15 configurations and loads will not be included in the computer l
data base unless they are submitted to or identified by the l
group for evaluation. It is reasonable to assume that the final l
contents of the data base will include only a portion of the l
total number of embeds, their attachments and loads if the l
program continues in its present form. In addition.
lR4 r
discussions with the responsible civil engineer in the group l
revealed.that there were no commitments in place at present to l
perform detailed calculations / analysis on embeds which would l
include the loa' dings from minor load attachments currently l
receiving preliminary approval.
l The process used by the Civil Support Design Group includes the IR4 following:
l a.
A detailed sketch attached to the FCR which includes l
features within a 2-foot radius of the subject embedded lR4 plate attachment.
I b.
When applicable, a note is made on the FCR indicating l
minor loads are attached to the embed. While the minor l
load is shown on the detailed sketch, this load l
l addition to the embed is not always included in the lR4 detailed calculations performed to qualify the embed.
l I
Instead, engineering evaluation by the responsible design l
engineer determines whether the minor load is significant I
to the point that it will be included in the detailed l
calcular.lons.
l Both groups stated that there was no written criteria which l
clearly defined or provided guidelines for identifying minor l
loads. Further discussion led to the conclusion that some l
general guidelines for identifying a minor load could further lR4 enhance the engineering judgment and expertise which is l
currently used to make this determination. This evaluation l
agrees with that conclusion.
l 2.
The SQN-GCTF report specifically addressed concern IN-85-033-001, but the Jeformation offered in Section III, 1 and 2, is indirectly applicable to concern IN-85-031-001 which addressed errors, omissions, and incorrect assumptions in l
design calculations for structural steel access platforms. The SQN-GCTF report referenced Nonconformance Report - Generic Civil Engineering Branch (NCR-GENCEB) 8208 R3 which applies to multiple attachmente to embedded plates; not to the description given above on concern IN-85-031-001.
However, NCR-GENCEB-8208 is indirectly applicable in that it, la conjunction with l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER:
5 PAGE 5 0F 15 NCR-GENCEB-8205 which addressed safety factors for welded stud anchors for embedded plates (embeds), initiated a sampling program of 60 embeds which included independent reviews of existing calculations and visual checks of Field Change Request (FCR) sketches. The sampling process also acted as a mechanism to reveal errors, omissions, etc., and revealed that all sampled supports exceeded the Design Standard (DS) in effect at that time.(DS-C6.1). The sample results reflected a confidence level of 95 percent that less than 5 percent of all erubeds did not meet design requirements. The SQN-GCTF report also mentioned Project Construction Specification N2C-937 as being written to control field installations of multiple embed attachments at SQN when, in fact N2C-937 was written as the
" Action Required to Prevent Recurrence" (ARPR) to NCR-GENCEB-8208, R3.
The NSRS Investigation Report I-85-265-WBN recommend d that a procedure be issued to describe the actual embedded plate approval process: N3C-928 was written for WBN and N2C-937 for SQN. The report concluded that the sampling program done according to NCR-GENCEB-8208, R3, verified the adequacy of embedded plates at SQN.
B.
A detailed review of the WBN ECTG Element Report for Design of Plates (C011301) revealed the following with respect to generic applicability to SQN:
1.
The generic applicability identified in the WBN report was addressed at SQN in SCR-SQNCEB-8607, R0, which applied to the distance between existing embeds and concrete edges. This problem was identified as another part of the multiple attachment to embedded plate scenario originally addressed at WBN in SCR-WBNCEB-8623 and at SQN in SCR-SQNCEB-8622. The t
sampling program initiated according to SCR-WBNCEB-8623 identified no plant hardware deficiencies but raised several
' side issues" which were documented as conditions adverse to L
quality (CAQ). Those determined to be generic to SQN will be addressed later in Section IV.D.1 of this report.
SCR-SQNCEB-8607 is still open and will be addressed in Section IV.C.2 of this report.
C.
1.
A review of NCR-GENCEB-8208 R3 and the reply memorandum documenting the completion of the NCR (B41 850711008) was l
performed. It was discovered that NCR-GENCEB-8205 was also addressed in the sixty plate sample that was done. The results of this sample revealed a 95 percent confidence level that less than 5 percent of the embedded plates sampled would not meet design requirements. All welded studs analyzed had factors-of-safety which exceeded the design standard requirement.
A 1
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C0ll301-SQN SPECIAL PROGRAM REVISION NUMBER:
5 PAGE 6 0F 15 2.
A review of SCR-SQNCEB-8607 which addressed the distance between existing embeds and concrete edges is still open. A summary of the actions being taken with respect to this SCR is as follows:
a.
A 100 percent review of all Type 2 embeds (DSC.l.8.1) is being done by the SQN Civil Design Analysis section.
b.
A " worst case" sample of embeds installed adjacent to concrete edges is also being performed at present. These actions are scheduled for completion before restart of SQN.
After restert, an upgrade of all Type 2 embeds to a higher factor-of-safety will be considered.
3.
Reviewed SCR-SQNCEB-8622 which addressed cable tray supports where all loading _ conditions may not have been considered.
This SCR applies to those embeds with cable tray supports attached and is still open and under review by Civil Design Analysis (CDA), SQN. Approximately 35 embeds are being reviewed on a " worst case" type basis; a load / configuration review was done to identify these embeds. The methodology being applied by the CDA at SQN is to sample different configurations from all Category I buildings to identify and correct all cable tray support problems.
4.
a.
Reviewed NCR-SQNCEB-8404 which was written to document the failure to consider baseplate flexibility when determining anchor bolt loads. This SCR was initiated as a result of the Potential Generic Condition Evaluation performed by SQN in response to NCR-WBPCEB-8402 written at_WBN which originally identified the same problem. These NCRs were initiated because both WBN and SQN designers had i
misinterpreted previous design instructions for baseplate analysis which resulted in the DS-C1.7.1 Design Standard requirements not being fully implemented.
(A review of I
NSRS investigation report I-85-lll-WBN revealed that TVA had not considered baseplate flexibility in baseplate designs as required by NRC IE Bulletin 79-02.
This evaluation agrees with that determination). TVA's response to the NRC's request for additional information on IE 79-02 (A27 800102006) included information on baseplate flexibility (Area 2.c.) and basically " wrote-off" the baseplate. flex question. Design Standard DS-C6.1 was in I
effect.at that time and contained no criteria for l
consideration of baseplate flex. Therefore, sample programs were initiated to evaluate base plates using flexible plate analysis. Because of the similarity between WBN and SQN, as well as the fact that the nonconforming conditions were the same for both plants, a smaller sample g
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IVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER:
5 PAGE 7 0F 15 was justified at SQN (60 supports) since a 300 plate sample was performed at WBN. The support sampling programs required recalculation of anchor bolt loads which would include baseplate flexibility. This exercise is still being performed and evaluated at SQN and NCR-SQNCEB-8404 remains open.
b.
The concern expressed on wedge bolt load allowables I
(IN-85-109-X04) can also be answered by referencing the l
sampling programs initiated per SCR-SQNCEB-8404 for SQN and l
NCR-WBPCEB-8402 for WBN. Since 79-02 increased the factor l
of safety for concrete anchors, this caused a reduction in I
the corresponding allowable bolt loads. These changes l
occurred during a time frame which resulted in the allowable l loads for wedge bolts in WBN Unit 2 being lower than those I
allowed in Unit 1.
The same methodology was employed to l
establish wedge bolt load allowables both in Units 1 and 2 lR4 at SQN and WBN Unit 1.
This fact was verified during l
conversation with DNE-CEB Central Staff personnel.
In l
addition, conversation with previous SQN Construction M&A l
Hanger Group personnel revealed that wedge bolts were used l
at SQN during this timeframe only as a replacement for SSDs l
which had failed the pull test required after installation.
l Therefore, replacing a SSD with the same or larger size l
wedge bolt, as detailed in G-32, would serve to increase the l
overall factor of safety for the feature. These facts are l
presented as evidence that the concern on wedge bolt l
allowable loads is not applicable to SQN.
l S.
A review of SCR-WBNCEB-8650 was performed to determine the parameters of the nonconforming condition identified at WBN on structural steel attachments to buildings and platforms. A search was made for the completed Potential Generic Condition Evaluation form which SQN was required to respond to as required by the SCR at WBN. It was discovered that SQN was still performing the evaluation to determine if the structural steel attachmects en buildings and platforms were also nonconforming at SC-This finding is discussed in greater detail in Section I).D.1, this report.
6.
A review of PIR-WBNCEB-8602 (initially referenced in the WBN-ECTG Element Report on Design of Plates C011301) revealed the PIR to be closed. The Potential Generic Condition Evaluation performed at SQN as a result of the PIR at WBN (Memorandum B25 860124 300) showed the identified condition (s) as being generic and NCR-SQNCEB-8502 had been initiated to document deficiencies in the following areas:
ii.
2-xa:
TVA ENPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER: 5 PAGE 8 0F 15 a.
Inaccurate configuration in approval of FCRs b.
misinterpretation of installation requirements for 1-hole straps (47A05456-2) c.
rigid and rod type supports were mixed on nondivisional conduit d.
supports installed using drawings not approved to qualified criteria The following actions were implemented on the items above:
Initial review of the condition adverse to quality (CAQ) on a.
inaccurate configurations being used in the approval of FCRs has revealed this item as not being significant to the point of preventing conduit from performing its intended design function. The program that will evaluate a sample of the affected supports, as addressed in the subject NCR Engineering Report, to determine their adequacy had not been initiated as of 8-6-86.
b.
Initial review has revealed the worst case failure to be slippage of the conduit through the clamps which would not cause conduit failure in most cases. Some overstress of the conduit could also occur but neither scenario would be likely to impair the overall functionability of the cable.
A sample program as recommended in the Engineering Report of NCR-SQNCEB-8502 R2 will'be performed on the affected supports as well as a test program to verify the design adequacy of the subject clamps. As of 8-6-86, the subject sample program had not been initiated.
The evaluation performed on the mixing of rigid and rod c.
type supports on nondivisional conduit determined that localized support failures would not result in generic failure of conduit support mechanisms. In addition the 47A056-110 typical drawing provides mechanism for the j
mixing of rigid and rod type supports under certain conditions. One specific condition involves the use of flex type conduit between the rigid and rod type support.
Knowledgeable SQN-DNE personnel who were interviewed were not aware of any instance where the flex type conduit had not been used under the subject conditions. Therefore, it I
was concluded that mixing rigid and nonrigid (rod type) supports for nondivisional conduit would not prevent the conduit from remaining in place both during and after a j
safe shutdown earthquake (SSE).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER: 5 PAGE 9 0F 15 d.
Initial review, including detailed calculations, show all of the supports that attached to the steel. containment vessel (SCV) meet category 1(L) criteria and all of the supports except one (support typical drawing 47A056-143) could be shown to meet the more stringent requirements of the SQN Pipe Support Design Manual without any structural modifications. The stresses in the SCV and stiffeners meet the requirements of the ASME Code (III) under the effects of a conduit design basis accident (DBA) and safe shutdown earthquake (SSE) loadings. The small sampling program to be performed on affected conduit supports, to include evaluation of the as-built configurations, had not been initiated as of 8-6-86.
This evaluation has performed a detailed review of the subject NCR and attached Engineering Reports. All indications are that sufficient evaluations to include sampling programs will be performed to fully evaluate and j
determine the functionability of the subject conduit supports.
It was revealed that several areas of the aforementioned engineering reports lack definitive statements with respect to the adequacy of the conduit supports. However, when consideration is given to the fact that the engineering reports reflect only initial results based largely on engineering judgments and experience, the lack of definitive statements does not seem significant.Section IV.E.5, this report, details further actions required on this subject.
l 7.
A review was conducted of Nuclear Engineering Procedure (NEP) 3.1 (Calculations), 3.2 (Design Input), 3.3 (Internal Interface Control), 5.2 (Review), and 6.1 (Change Control) to determine if adequate criteria existed to control the design processes used for calculations / analysis and the other exercises i
l
_ associated with these processes. Also reviewed Modifications and Additions Instruction (N&AI) 11, R12, Section 7.5, and Design Standard (Civil) DS-C1.7.1.
To summarize the results of these reviews, adequate controls and mechanisms are currently in place to control the design / analysis processes required at r
SQN, and to include sufficiently detailed check / review f
procedures for calculation packages.
l 8.
A review was performed of the SQN initial response to NRC IE l
Bulletin 79-02 and 79-02 R3 (A27 790705 010) and the SQN final responses to the same bulletin (A27 810403 011) and (NEB 810324 276). The NRC accepted SQN's final 79-02 evaluation program after SQN answered additional information i
requests made by the NRC subsequent to the initial response.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAM REVISION NUMBER:
5 PAGE 10 0F 15 D.
1.
The responsible engineer, SQN Civil Design Analysis Group, was interviewed and provided applicable information as detailed below:
- SCR-SQNCEB-8622 was applicable to cable tray supports only. He stated that the sampling program addressed in Section IV.C.3, this report, had initially reflected positive results.
- SCR-SQNCEB-8607 was also an open issue that was being reviewed by his group and addressed Type 2 embeds as described in Section IV.C.2., this report. The SQN Potential Generic Condition Evaluation being performed as a result of SCR-WBNCEB-8650 was "to determine cumulative effects of attachments and configurations." The initial review indicated that the latest analysis criteria may not have been used in some cases at SQN and all structural steel attachments may not have been considered. The review includes calculation packages and some "as-constructed" field walkdowns. A Significant Condition Report or Problem Identification Report for SQN may be required when the generic eveluation is finished.
With respect to the " side issues" raised at WBN as a result of SCR-WBNCEB-8623, the following comments were made:
a.
At WBN some embedded plate FCRs reference the wrong unique plate identification number. Reply: SQN embeds were not assigned unique identification numbers like those at WBN so this problems was not generic to SQN. SQN identified embeds by location only.
b.
At WBN attachments were identified which were not shown on the latest embedded plate FCRs.
Reply: FCRs at SQN were evaluated one-by-one, each on a case-by-case basis so this problem also is not generic to SQN. Section d. below also applies to this issue, c.
Errors found in the calculations at WBN would be addressed at SQN in the review required according to SCR-SQNCEB-8622.
d.
At WBN some embedded plate FCRs were accepted using a stendard review form. Reply: This applies to WBN only because SQN has never had and does not have now a standard review for FCRs. As stated in Section b. above, each is considered on a case-by-case basis. Therefore, this problem is not generic to SQN.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: Coll 301-SQN SPECIAL PROGRAN REVISION NUMBER:
5 PAGE 11 0F 15 With respect to errors, omissions, and incorrect assumptions e.
in the calculation / analysis process, he referenced the generic review being done according to SCR-WBNCEB-8650 which would address directly the subject concern at SQN. Preliminary l
results of the generic review revealed potential problem l
areas with respect to all attachments to structural features l
not being considered. However, no instance of actual errors l
or omissions in the calculation / analysis process had been I
identified. He also indicated that human error was a reality IR2 that had to be considered in calculations / analysis but was l
confident that the new NEP described in Section IV.C.7, this l
report, provided sufficient checks and balances for this l
problem. His final comment was that he was not aware of any l
situation where identified errors had been left uncorrected.
l i
2.
The responsible SC-4 SQN Civil Support Design Group, was
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interviewed and indicated that she was not aware of any identified errors not being corrected. Her response to the adequscy of the new NEP as described in Section C.7, this report, was that it provided adequate guidelines and controls for calculations and analysis in the design group.
- 3.
Several conversations with responsible engineers in the Division of Nuclear Engineering (DNE), Civil Engineering Branch 1
(CEB) Central Staff revealed the following:
a.
The sample programs at SQN according, to NCR-GENCEB-8208 l
included independent reviews of existing calculations on embed attachments that would have revealed errors, omissions or incorrect assumptions as addressed in WBN concern IN-85-031-001.
These independent reviews are I
considered to be important and are normally handled within i
the applicable group on a scheduled basis, b.
As of July 15, 1986, 13 supports had been evaluated at SQN as a result of SCR-SQNCEB-8622 and none had failed. The initial sample included thirty cable tray supports that represented a "worat case" sample.
l The 100 percent review being performed at SQN according to c.
SCR-SQNCEB-8607 was scheduled for completion before restart
- after restset, upgrading of Type 2 embeds (DSC 1.8.1) to a higher factor of safety will be considered.
With respect to section D.l.c. and e.,
this report, which address errors in calculations; this specific side issue applied to cable tray supports calculations only and would be adequately addressed according to SCR-SQNCEB-8622.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN
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SPECIAL PROGRAM REVISION NUMBER:
5 PAGE 12 0F 15 d.
As detailed in Section IV.C.3.b. of this report, the l
concern on wedge bolt allowable loads was not applicable to l
SQN because the same methodology was used to calculate these lR4 loads for both Units 1 and 2.
The calculation process and I
the allowable loads were not different for each unit as was I
the case at WBN.
l E.
==
Conclusion:==
In view of the findings in Sections A, B, C and D, the following conclusions are offered:
1.
Sampling programs have been performed or are being performed at SQN as a result of several SCRs, NCRs and Potential Generic Condition Evaluation reports. The sampling program that is complete (according to NCR-GENCEB-8205 and -8208) revealed 95 pcecent confidence that less than 5 percent of the embeds did not meet the required criteria. This sample would also have revealed errors, omissions, etc. that were present in the existing initial calculation packages. The sampling programs in progress according to SCR-SQNCEB-8607 (Section C.2., this report). NCR-SQNCEB-8404 (Section C.4.,
this report)
SCR-SQNCEB-8622 (Section C.3.,
this report) and the Potential Generic Condition Evaluation at SQN according to SCR-WBNCEB-8650 provide sufficient mechanism to address fully the concerns in this element.
2.
Concern IN-85-031-001 will be addressed directly at'SQN by the Potential Generic Condition Evaluation (PGCE) for SCR-WBNCEB-8650.l The plant feature addressed by this SCR is structural steel I
attachments, the same feature identified in the employee concern. l This PGCE will also serve to identify errors, omissions, and lR2 incorrect assumptions in the design calculations for these l
features. In addition, the existence of errors, omissions or I
incorrect assumptions in design calculations, if any, will be l
revealed during the sampling and requalification' programs at SQN. l Section 1 above gives summary information with respect to the l
sampling programs in place, the NCR or SCR which initiated the l
sample as well as specific sections of this evaluation report
[
which contain detailed information on the subject of each NCR l
and SCR.
l Interviews with responsible personnel within the SQN site DNE I
organizations did not reveal evidence of identified errors, lR2 omissions, etc., which would not have been corrected.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: Coll 301-SQN SPECIAL PROGRAN REVISION NUMBER: 5 PAGE 13 OF 15 3.
Concern IN-85-033-001 was not answered adequately by the SQN-GCTF lR5 report. This evaluation determined that the concern expressed on l En Des Procedure 4.03 was not generic to SQN. However, that I
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portion of the concern which specifically addressed minor loads attached to embeds is indirectly applicable to SQN. It was lR4 determined that the programs for evaluation of minor loads l
l attached to embeds are adequate with the following comments:
l DNE-CEB should consider a review to determine whether general lRS a.
guidelines for identifying minor loads would serve to improve I the existing program (s).
An example would be CEB-EP 21.46 l
which was issued at WBN to provide additional guidelines for l attachments to embeds not addressed in N3C-928. Furthermore, I the mechanism for visual approval of loads attached to embeds lR4 as allowed by N2C-937 is not used by the site Civil DNE l
organization. Therefore, consideration should be given to l
deleting section 2.5.2 of N2C-937 unless it can be l
established that future installations will be evaluated using l a visual approval process.
I b.
In addition, DNE-CEB should consider a review to determine whether:
IRS
- The existing program (s) should be expanded so that the l
detailed sketch reflects all features attached to the l
embedded plate. This comprehensive sketch would only l
be required the first time a FCR, ECN, new attachment, l
etc., caused the subject embed to undergo detailed l
calculations. This exercise would serve to establish I
a baseline program which would preclude the potential lR4 for overloading an embed because all attachments had l
not been identified and considered during the calculation l
process. Future FCR, ECN, etc. sketches would only be l
required to reflect the individual feature or attachment i
since the data base would contain detailed calculation I
data on all other attachments to the subject embed.
l
- Any minor loads receiving preliminary approval under l
the current program should eventually be included in the i
detailed calculation process.
lR4 4.
Concern IN-85-103-001 and OE-QMS-8 will be answered directly by the evaluation of NCR-SQNCEB-8404 at SQN. This NCR addresses the issue of baseplate flexibility which was a requirement according to NRC IE Bulletin 79-02.
5.
The issues raised by NCR-SQNCEB-8502 R2 did not directly address a specific concern but did serve to identify problem areas within the subject of this element; Design of Plates.
The review of this NCR has revealed sufficient mechanism is in
_We
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAM REVISION NUMBER:
5 PAGE 14 0F 15 place, i.e., detailed engineering evaluations, to include sampling programs, to insure complete resolution of specific problem areas.
However, section 5 of the subject NCR (NCR-SQNCEB-8502) which l
addresses the cause of the CAQ: details programmatic inadequacies lR2 as the principle cause of the identified deficiencies.
l Additionally SCR-SQNCEB-8607, NCR-SQNCEB-8404 and l
NCR-GENCEB-8205 were also initiated as a result of programmatic l
inadequacies within the DNE organization. The most obvious l
inadequacies being the lack of consistency in the interpretation lR2 and application of design criteria at the site and engineering l
project level.
l Therefore, DNE should consider implementing programs and/or lR5 exercises that will ensure all design personnel are adequately l
trained to applicable design criteria. This training should be l
comprehensive and includo upper-tier and site-specific design l
criteria as well as those site procedures, drawing notes, etc.,
lR2 which contain tolerances that, when applied during the l
installation process by the site, could effect the original l
analysis / qualification basis.
l 6.
The " side issues" raised as a result of SCR-WBNCEB-8623 were l
determined not to be generic to SQN (Section IV.D.1.a-e, gives l
detailed information on this subject) except for the issue of lR2 calculation / documentation errors. This specific issue is l
currently being addressed at SQN by several sampling and/or l
requalification programs as detailed in Sections IV.E.1 and 2 of l l
this evaluation report.
I 7.
The concern In-85-031-001 was verified as being true at.WBN.
It was generically applicable to SQN, and is being adequately addressed at SQN.
The concern IN-85-033-001-was verified as being true at WBN but was not directly applicable to SQN.
The concerns IN-85-103-001 and OE-QMS-8 were verified to be true lR4 at WBN. They were generically applicable to SQN, and are being l
adequately addressed at SQN.
l The concern IN-85-109-Z04 was verified to be true at WBN but was lR4 not applicable to SQN.
l l
l V.
Root Cause 1.
For NCR-SQNCEB-8404 - misinterpretation of instructions by designers for baseplate flexibility analysis and therefore, a failure to follow procedure (DS-C1.7.1).
1
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011301-SQN SPECIAL PROGRAN REVISION NUMBER:
5 PAGE 15 0F 15 V.
Root Cause (continued) 2.
For SCR-SQNCEB-8607 - failure to consider concrete edges on embedded plate capacities during the design evaluation of the plate and lack of adequate procedure.
3.
For SCR-SQNCEB-8622 - all loading conditions for cable tray supports were not considered in the original design and lack of adequate procedure.
For NCR-SQNCEB-8502 - inadequate design criteria and implementation 4.
of requirements, lack of documentation, and lack of adequate training in the applicable design criteria.
VI.
Corrective Actions To be provided by the applicable line organization (s).
lR2 VII. Generic Applicalility The issues raised by the concerns in this element potentially apply to all TVA nuclear plants. This determination was also made by the WBN-ECTG Element Report on the subject of these issues, Design of Plates.
VIII. Attachments Attachment A Listing of Concerns Indicating Safety Relationship and Generic. Applicability
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'IN 031-001 Co 11500 N HBH YYYY IN-85-031-001 S5"'~i ~R5EiNNING PREVIOUSLY APPROVED T50054 K-FORM.
IGN CALCULATIONS FOR STRUCTURAL STEE L ACCESS PLATFORMS LOCATED IN THE RE ACTOR BUILDINGS UNITS 1&2.
CI HAS A T TIMES FOUND ERRORS, OMISSIDHS OR I NCORRECT ASSUMPTIONS WHICH COULD HAV E AN AFFECT DN QUALITY / SAFETY. WHEN CI MADE REQUEST TO SUPERVISOR (NAME KNOHN) TO CORRECT ERRORS, CI HAS To LD THAT THERE HAS NO TIME OR MAN-HOU RS AVAILABLE TO MAKE CORRECTIONS. C I STATED THAT SOME CALCULATION HENT UNCORRECTED. THIS OCCURRED DURING A LL OF 1984. CI COULD NOT PROVID IN 033-001 CD 15300 N HBN NNYY I-85-265-HBN HS,EN DES PROCEDURE EP 4.03 APP. 4 IS I' T50064-REPORT
~ NADEQUATE. EP 4.03 APP.4 ALLOHS ACC EPTANCE OF MINOR LOADS TO EMBEDDED P LATES BY PERFORMING VISUAL INSPECTIO NS OF ATTACHMENTS To EMBEDDED PLATES p/%
SINCE PROCEDURE EP 4.03 APP.4 DOE S NOT DEFINE HHAT A MINOR LOAD IS, T HERE IS NO LIMIT TO HHAT CAN BE ACCE PTED BY VISUAL INSPECTION. EXAMPLE:
FCR EP-3784 ILLUSTRATES PROBLEM HIT H PROGRAM OF VISUAL INSPECTION. NO FOLLOH-UP REQUIRED.
1H 103-001 CD 1l300 N HBN YYYY I-85-111-HBN SS TVA IS NOT IN COMPLIANCE HITN NRC BU T50004 3
K-FORM
~
LLETIN 79-02 (SUPPORT OF RIGID PLATE ASSUMPTIONS IN ANALYSIS) IN THAT BA SE PLATE FLEX IS NOT A DESIGN CONSID ERATION. NO ADDITIONAL CONTACT REQU IRED.
IN 109-XO4 CO.
11300 N HBN YYYY HS-CONCRETE ANCHOR BOLT (HEDGE BOLTS) I
. T50057 REPORT N UNIT 1 a 2.
THE ALLOHABLE BOLT LO ADS FOR UNIT 1 ARE GREATER THAN UNIT 2.
THE DESIGN PHILOSOPHY TO DETERM INE THE ACTUAL ALL0HABLES ON ANCHOR BOLTS HAS CHANGED. FOR UNIT 1, THE DESIGN GROUP DID NOT CONSIDER FLEXIB LE PLATE THEORY, INSTEAD THEY CONSID ERED THE BASE PLATE AS RIGID. CI QU j
ESTIDHS THESE TH0 DIFFERENT ALLOHABL ES.
OE-QMS-8 CO 11300 S HPS YYYY SS TH0 AREAS REGARDING DESIGN METHODS F EN 22200 REPORT OR PIPE SUPPORTS ARE NOT RECEIVING P h.
R0PER CONSIDERATION: 1) EFFECT OF B ASEPLATE FLEXIBILITY ON ANCHOR LOADS
. 2) DETAILING METHODS FOR HELDS.
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