ML20214R384

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Followup SEP Evaluation of Part of Remaining Open Items for Oyster Creek Nuclear Power Plant
ML20214R384
Person / Time
Site: Oyster Creek
Issue date: 03/31/1987
From: Nitzel M
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML20214R361 List:
References
CON-FIN-A-6808 NUDOCS 8706080106
Download: ML20214R384 (73)


Text

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FOLLOW-UP SEP EVALUATION OF PART OF THE REMAINING OPEN ITEMS FOR THE OYSTER CREEK NUCLEAR POWER PLANT T

4 M. E.'Nitzel 4

March, 1987 E

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EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76IO01570 FIN No. A6808 8706000106 870312 9 PDR ADOCK 0500 p u

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SUMMARY

'The Oyster Creek Nuclear Power Plant, one of the group I plants for the Systematic Evaluation Program (SEP), was initially reviewed by the Nuclear Regulatory Commission (NRC) and their consultants Lawrence Livermore National Laboratory (LLNL) and EG&G Idaho, Inc. The results of this review were published in NUREG/CR-1981 in April of 1981. The plant was evaluated against current standards of acceptability but several open items resulted from the review. Subsequently, the NRC contracted the INEL to perform a follow-up review of additional information supplied by the licensee to address some of the open items. This report describes the additional information submitted to date and the results of the reviews performed thereof.

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ACKNOWLEDGMENTS S. L. Morton performed the majority of the review work on the reanalysis of the control rod drive' return piping, 4160 V and 460 V switchgear cabinets, and reanalysis of the core spray and' liquid poison.

pipirsg systems. Associated sections in the draft version of this report (October, 1984)'were also completed by S. L. Morton.

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CONTENTS

SUMMARY

.............................................................. ii ACKNOWLEDGMENTS...................................................... iii l'

1. INTRODUCTION....................................................
2. DESCRIPTION OF REVIEW........................................... 3 2.1 Control Rod Drive Return Piping System..................... 3 2.2 4160V and 460V Switchgear Cabinets......................... 9 2.3 Liquid Poison Piping System................................ 13 i

. 2.4 Core Spray Piping System................................... 15 1

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- 2. 5 Main Steam And Feedwater Piping Supports In Cont'ainment.... 17

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2.6 Piping System MNCR Review.................................. 18

3. CONCLUSIONS...................................................... 14 3 1
4. RECOMMENDATIONS.................................................. 44
5. REFERENCES....................................................... 49 T

TABLES

1. CRDR PIPING STRESSES............................................. 6
2. CORRECTED CRDR PIPING STRESSES................................... 8
3. DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs............ 31 iv 4

FIGURES

1. Oyster Creek Feedwater Piping - 1980 SEP Data.................... 21
2. Oyster Creek Feedwater Piping - 1985 Walkdown Data............... 22

!' APPENDIX A - Notes From MNCR Review.................................. Al l-i

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FOLLOW-UP SEP EVALUATION OF PART OF THE REMAINING OPEN ITEMS FOR THE OYSTER CREEK NUCLEAR POWER PLANT

1. INTRODUCTION The Systematic Evaluation Program (SEP) was initiated by the United States Nuclear Regulatory Commission (NRC) in 1977 to review the designs of older operating nuclear power plants and to document their safety when compared against more recent acceptance criteria. Under SEP seismic reevaluation, these older plants were categorized into two groups based upon the original seismic design and the availability of seismic design documentation. Group I included those plants that had some original seismic analysis even though these analyses were not consistent with current standards. Group II included those plants whose original design did not include seismic analyses. The Oyster Creek Nuclear Power Plant was placed in Group I for the purposes of the SEP.

The Oyster Creek Nuclear Power Plant was initially reviewed by the NRC and their consultants, Lawrence Livermore National Laboratory (LLNL) and the Idaho National Engineering Laboratory (INEL, EG&G Idaho, Inc.,

contractor). Confirmatory analyses were performed by the INEL on portions of five different piping systems. These systems were the main steam, feedwater, CRD return and water and steam filled portions of the isolation condenser piping. The results of this review were published in an INEL informal report l. LLNL was responsible for assessing the structural I adequacy of major structures and equipment and preparing a report describing the overall adequacy of the plant2. The plant was evaluated against current standards of acceptability (circa 1980) but several open items resulted from the review.

1 Subsequently, the NRC contracted the INEL to perform a follow-up review of additional information supplied by the licensee to address some of the open items. A rough draft of a report describing the results of the review of the additional information was prepared in late 1984 and was under NRC review when questions were raised regarding possible 1

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inaccuracies in some of the information provided by GPU Nuclear (GPUN),

the plant licensee. The information utilized in the INEL confirmatory analyses was assumed to be accurate "as-built" data regarding supports and piping geometry. These data were provided by the licensee. An inspection conducted by NRC Region I in May, 1985, included findings which questioned the accuracy of the original field verification efforts. If the originally supplied information contained inaccuracies, then the reported SEP results could also reflect a misleading picture of the piping safety margins.

GPUN agreed to provide updated field inspection data so that an assessment of the validity of the original SEP piping analyses could be made. The first group of this information was provided subsequent to a June 25, 1985, meeting between GPUN and NRC representatives. As agreed, the licensee provided the available information and noted that inspection efforts for all safety-related piping systems had not been completed at that time. The information provided was in the form of Material Nonconformance Reports (MNCRs). The available information was compared to 4

the original SEP piping input to determine if significant discrepancies existed that would potentially invalidate the results and conclusions reached in the earlier work. Subseouent submittals by the licensee have ,

been reviewed in the same manner. It should be clearly understood that the MNCR information pertains only to the piping systems. No such effort to verify information provided for structures or equipment has been undertaken. It should also be noted that the original SEP piping analyses concentrated on an evaluation of the piping stresses only. Inspection and Enforcement (I&E) Bulletin 79-02 required system walkdowns and verification of the adequacy of certain piping supports using concrete anchor bolts. I&E Bulletin 79-14 required an examination of Seismic Category I piping systems to verify that the analyzed geometry matched the as-built geometry. Thus, the SEP did not address the adequacy of piping

] supports because this topic was to be covered by the responses to the above mentioned bulletins.

On April 24, 1986, a meeting was held between the licensee, NRC, and 1

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consultants for both the licensee and NRC. The purpose of this meeting was to discuss open items delineated-in the draft Technical Evaluation Report (TER) that was prepared in October, 1984. The licensee provided draft responses to many of the open items and certain of the open items were tentatively closed pending review of the formal final response. A meeting summary 3 was prepared by the NRC project manager and docketed.

The following pages of this report contain descriptions of the additional information submitted for INEL review since the publication of Reference 2. Specifically, the open items addressed in this report are:

1. The reanalysis of the Control' Rod Drive Return (CRDR) system piping,

- 2. The structural integrity of the 4160 V switchgear and 460 V unit substation cabinets,

3. The seismic reanalysis of the liquid poison system piping,
4. The seismic reanalysis of the core spray system piping,
5. The seismic reanalysis of the main steam and feedwater piping supports inside containment,
6. The effect that discrepancies described by the MNCR data may have on piping system structural adequacy.

Each of these topics will be addressed separately with a discussion of the additional information, review comments, and current review status.

2. DESCRIPTION OF REVIEW 2.1 CRDR System piping Reanalysis Subsequent to the publication of Reference 1, GPUN informed the NRC 3

that additional field inspection information not incorporated in the original SEP confirmatory analyses was available. This new information

{ consisted of revised pipe support and branch piping information. Also, site specific response spectra were developed for use in the seismic load cases. These response spectra were less severe than the original NRC spectra. On this basis, the spectra from the original confirmatory analyses were scaled down by a factor of 0.165g/0.220g (ratio of zero period accelerations) and utilized in a reanalysis of the CRDR piping. A supplement 4 to the Reference 1 report was written to describe the i

results of this reanalysis effort. After reviewing the results of the INEL analysis, the licensee indicated their belief that some of the

assumptions used by the INEL may have been too conservative.. It was agreed that the licensee would perform an analysis of this system using their own set of assumptions and the results would be reviewed.

The analysis5performed for GPUN by their consultant (MPR Associates, Inc.) was submitted for NRC review in 1983. This document stated that the EG&G reanalysis could have been conservatively high due to: (a) The analysis did not consider axial restraint at U-bolt supports due to friction effects, and (b) the seismic loads were based on scaled-Regulatory Guide 1.60 floor response spectra rather than the more

realistic floor response spectra specifically developed for the Oyster I Creek site. MPR Associates (hereafter, MPR) performed a comparative l analysis to the EG8G reanalysis utilizing only a small section of the EG&G i model. There were three parts to the MPR analysis. For the first part, an analysis was performed utilizing the same information as in the EG&G model. This analysis was performed to determine if MPR's short model produced similar results to EG&G's larger model. The results from each

! model's analysis were determined to be similar by MPR. The second part incorporated an axial restraint to a U-bolt support (Node No. 1105) on MPR's short model near an overstressed area indicated in EG&G's analysis.

A linear reduction factor was then determined from MPR's results and directly applied to these results to estimate the resulting stresses for this support change in the larger EG&G model. These estimated stresses 4

are listed in Table 1. The third part of this analysis utilized the

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Oyster Creek site specific spectra as well as adding the axial restraint to the U-bolt support as discussed in the second part. Stresses for the larger EG&G model were again estimated by applying a factor determined by MPR to the resulting stresses in MPR's part three analysis. The estimated EG&G resulting stresses are contained in Table 1. Table 1 also contains estimated stresses resulting from the Oyster Creek site specific spectra without the axial stiffness from the U-bolt (Node No.1105).

The arguments presented in the licensee's CRDR system piping reanalysis appear to show the adequacy of this piping system to withstand seismic loading. However, concerns were raised regarding the licensee's methods utilized in exercising these arguments. The following paragraphs explain these concerns.

s GPUN has indicated that axshi restraint at U-bolt supports due to friction effects was not considered in tne EG&G model. EG&G has not received documentation from GPUN on the control of U-bolt tightness to the pipe allowing some axial restraint nor has it received results of testing or experimentation conducted by the licensee to determine and/or verify an appropriate frictional coefficient. Documentation of this type should also address the effect of localized stresses imposed on the pipe due to:

(a) tightened U-bolt support and (b) radial thermal expansion against a tightened U-bolt support. Without this documentation, the friction factors are unknown, control of U-bolt tightness to pipes cannot be guaranteed, and imposed localized stresses were not considered. Unless GPUN can guarantee frictional control on U-bolts, the practice of utilizing U-bolts as axial restraints is not recommended.

GPUN has also indicated that EG&G's reanalysis utilized seismic loads based on Regulatory Guide 1.60 floor response spectra specifically developed for the Oyster Creek site. The Oyster Creek site specific spectra would lower the seismic stresses in the CRDR system piping to some degree; however, EG&G was never supplied with this spectra. GPUN's consultant attempted to estimate the EG&G stresses utilizing the site 5

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Table 1 - CRDR PIPING STRESSES MPR Analysis - MPN Analysis -

EG&G Stresses $hortened Piping Shortened Piping Estimated W /0 Axial U-Bolt System W/ Axial System W/ Axial Estimated Stresses Estimated Stresses in EGtG s Support at Node U-Bolt Support - Support and Site In EG&G Model Stresses in EGLG Model W/0 Axial

  1. 1105 and Reg.  % Reduction Specific Spectra- W/ Axial U-Bolt Model W/ Axial Support but with Highest Stress Guide 1.60 Spectra in Stress 1 Reduction Support and Reg. Support and Site Site Specific Locations hate (1) hbte (2) In Stress Guide 1.60 Spectra Specific Spectra Spectra hade fl310-Reducer 46174 4.16 18.49 44251 37638 39272 1" Recirculation Line hode f l380-Tee 52312 12.95 34.36 45536 34340 39449 1" Recirculation Line Node # 1455-Straight 54236 13.68 34.32 46814 35620 41265 ch Run I" Recirculation Line bode f l4 70-Redbcer 43933 6.13 22.70 41239 33959 36177 1" Recirculation Line (Note 3)
1. Allowable stress is 42,000 psi .
2. Reaction load in axial direction at U-bolt support #1105 is 81 lbs.
3. Stresses in 2" CRDR piping are within allowable limits for all analyses.

specific spectra on their shortened model. These stresses, contained in Table 1, appear to have been ratioed in their entirety during the estimation of the EG&G stresses. Despite the axial support and seismic differences applied to the model, the stresses due to pressure and weight should not be affected. Therefore, the weight plus pressure stresses i should have been subtracted from the total stress before the reduction was performed. Table 2 presents MPR's estimated stresses if these reductions were calculated correctly. Since axial restraint on U-bolts is not '

recommended without documentation of the friction factors, the estimated EG&G stresses are contained in the last column. These stresses still remain within the allowable stress of 42 ksi. These estimated stresses j for the EG&G model appear acceptable provided the responses between MPR's shortened model and EG&G's long model are adequately similar. MPR did compare and confirm the similarity of the responses of the large and small i models, but these results were not sent to the NRC prior to the April 24, 1986 meeting. I The concerns described above were discussed at the April 24, 1986 I meeting. The licensee stated their position that since tt)e estimated l maximum stress shown in Table 2 is below the allowable limit, the utilization of U-bolts to provide axial restraint by friction is a moot point for the CRDR piping system model. This item was considered closed for the subject piping system; however, the licensee did not clearly indicate whether structural adequacy calculations for any other piping systems in the plant included axial restraint from U-bolt friction. The licensee acknowledged that an error had been made in including deadweight and pressure stresses in the scaling process used to estimate seismic stresses shown in Reference 5 for the CRDR system. This item was considered closed since the maximum stress shown in Table 2 is below the '

allowable limit. The licensee's draft responses included information l detailing the comparison of the MPR "short" model to the INEL larger model of the subject piping. This information was reviewed by the NRC and INEL personnel and found to be acceptable. This information closed the open item concerning the validity of the shortened piping model. In the course j 4

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'l Table 2 - CORRECTED CRDR PIPING STRESSES MPR Analysis - MPR Analysis -

EG&G Stresses Shortened Piping Shortened Piping Estimated Estimated W/0 Axial U-Bolt System W/ Axial System W/ Axial EG&G Stresses in EG&G Stresses in EG&G Support at Node U-Bolt Support - Support and Site Weight Plus Model W/ Axial Model W/0 Axial

  1. 1105 and Reg. 1 Reduction Specific Spectra- Pressure Support and Site Support but with Highest Stress Guide 1.60 Spectra In Stress 1 Reduction Stresses 5pecific Spectra Site Specific loCdtions Note (1) Note (2) In Stress (Note 4) (Note 5) Spectra hode #1310-Reducer 46174 4.16 18.49 3456 38215 39786 l* Recirculation Line i Node #1380-Tee 52312 12.95 34.36 2517 35202 40064 l 1" Recirculation Line Node #1455-Straight 54236 13.68 34.32 2774 36574 41931 Run l* Recirculation Line Node f l4 70-Reducer 43933 6.13 22.70 2626 34556 36641 ao 1" Recirculation Line I (Note 3)
1. Allowable stress is 42,000 psi.
2. Reaction load in axial direction at U-bolt support #1105 is 81 lbs.
3. Stresses in 2" CRDR piping are within allowable limits for all analyses.
4. Ubtained from EG&G reanalysis.
5. Used only to obtain stresses without axial support (last column).
.e.6 M n- .a.,.) g-- - A 9A 4 ..o ,- a y M of discussion it'was' asked whether the site specific response spectra -

w developed by MPR had been reviewed. The licensee stated that the spectra

'had been reviewed'and accepted by the NRC.

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' The Mate'ri'al Nonconformance' Report (MNCR) review was completed as a

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.q separate effort as described inSection 2.6. Numerous MNCRs for the CROR-

! . piping under consideration were submitted and reviewed. It was concluded that'none of the discrepancies detailed by the MNCRs would significantly affe'cc the results and conclusions previously described for this piping.

system. -

t '\Nt v7 g% Based upon the information described above, the seismic qualification

  • cf'the4 portion of the,CRDR piping system chosen for the confirmatory analysis'was considered acceptable. ,

l 2.2 Analysis Of 4160 V Switchaear And 460 V Unit Substation Cabinets

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'4 The 4160 V switchgear'and 460 V unit substation cabinets.were examine'd for seismic adequach by the' licensee's consultant, MPR. The equivalent static load method was utilized in determining the anchor adequacy and in performing the load path evaluations. . Loadings due to weight, Operating Basis Earthquake (OBE), and Safe Shutdown Earthquake (SSE) were included in these analyses.

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The anchor adequacy analysis wat performed ~by calculating the pullout i and shear loads on the concrete anchor bolts which secure the cabinets to i

the floor and comparing.these s loads to appropriate allowable values.

i Testing performed for a utility owner's group 7~in response to~ Inspection

! and Enfo'ics:nent ( E) Bulletin 79-02 was used by MPR to ' define maximum:

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. s allowable loads. The stated objective of the. analyses was to show that

-the minimum factor of safety for'the combined pullout and shear loading exceeds 4.0. For the vertical direction seismic loading MpR utilized the l Zero Period Acceleration (ZPA) of the NRC developed. seismic response j spectra multiplied by .165g/.22g. This reduction factor was applied to produce approximate acceleration values consistent with the less severe 9

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site specific response spectra. The ZPA value was used since the natural ,

frequencies of the cabinets in the vertical direction were above 33 hertz. Horizontal peak accelerations multiplied by the same .165g/.22g factor were utilized since the natural frequencies of the cabinets in the horizontal direction were estimated to be between five and ten hertz.

.This frequency range encompasses the horizontal response spectra' peak.

The .165g/.229 factor was recommended by the NRC for use in the SEP evaluations. The calculated pullout and shear loads were combined using the square root of the sum of the squares (SRSS) method. For-the SSE plus

. weight loading, the 460 V unit substations' anchorages resulted in factors 4

of safety of 3.45 and 3.58, but the 4160 V switchgear units maintained a factor of safety above 4.0. For the OBE plus weight loadings, the factors of safety on all units remained above 4.0, MPR also performed a load path evaluation on the internals of the 4160 V switEhgear and 460 V unit substation cabinets. The limiting i structural and support members of these cabinets were examined-and results of these calculations were compared to the recommended allowables in the ASME Code.8 The limiting components that were evaluated for the 4160 V. .

switchgear cabinets were:

1. Shear on the 0.125-in, welds connecting the support angles to the breaker frame
2. Bending of the support angles t
3. Shear across tha 0.25 X 0.66-in. tip of the support box grooves
4. Shear on the 0.500-in. diameter support rods.

The limiting components that were evaluated for the 460 V unit substation cabinets were:

1. Shear on the four.0.500-in. breaker pins 10 i
2. Shear on the two 0.125 x 0.375-in. keys
3. Shear on the eight 0.250-in. rivets.

All of the load path calculations performed on the cabinets indicate that the cabinet internal stresses- remained well within the ASME Code' allowable stresses.

MPR chose to perform the simpler equivalent static load method rather than a dynamic analysis for the 4160 V switchgear and 460 V unit substation cabinets anal <ses. While this approach appeared acceptable, certain concerns were raised. These were:

1. The realism of the simple model representation
2. The conservative responses of the model
3. Reasons for no additional factor of conservatism applied to the horizontal and vertical accelerations.

The acceptance criteria utilized for the analyses of the 4160 V and 460 V cabinets were found to be acceptable.

In preparation for the April 24, 1986 meeting an additional review of these analyses was performed. The following concerns were raised at this time:

4. The licensee should justify _ not maintaining a factor of safety (FS) of 4.0 as required by IE Bulletin 79-02 particularly when the accelerations were not multiplied by a factor of.1.5 for conservatism.
5. Figure 3-1 in the licensee's report (Reference 6) shows concrete anchor bolts in close proximity to each other. The licensee should describe in detail what measures were taken to account 11

for reduced bolt capacities due to close spacing.

6. The licensee should address the possibility of cabinets interacting (impacting) during horizontal movement during a seismic event.
7. The licensee should describe what factors of safety would result if friction was not used to reduce shear loads on the concrete anchor bolts.
8. On page 3-7 of the licensee's report (Reference 6) it is stated that the type and embedment of the anchor bolts for the 4160 V cabinets is unknown. If the licensee cannot verify that sleeve type anchors are not used, then use of a factor of safety of 4.0 versus 5.0 as specified by IE Bulletin 79-02 should be justified.
9. The licensee should justify the use of seven percent damping.

IE Bulletin 79-02 is cited in items 4 and 8 above. Although this bulletin is directed specifically at concrete anchor bolts in piping supports, its provisions correspond with those of general industry practice and with SEP guidelines which have been used as review criteria for other SEP plants. Because of this, the use of the bulletin safety factors applied to concrete anchor bolts used to anchor switchgear cabinets is a logical extension and application of criteria.

The concerns described above were discussed at the April 24, 1986 meeting. The licensee's draft responses included additional information which would appear to answer items 1, 2, 3, and 9 above. However, the responses to these items referenced an undocketed report. The licensee agreed to include this reference in their formal final response. The licensee should provide complete copies of all undocketed references in future responses. The licensee pointed out that actual concrete anchor bolt installations were separated farther than appeared in Figure 3-1 of 12 e

Reference 6. Field inspection "as-built" sketches were referenced as evidence. This information was found to be adequate to answer the concern (item 5 above) regarding concrete anchor bolt spacing. During the discussions at this meeting, the licensee stated the belief that these cabinets were fastened together such that interaction (impacting) during a seismic event would not occur. No field inspection data or other information was presented to reinforce this belief.

Based on the information described above, items 1, 2, 3, 5, and 9 listed above in this section are considered closed pending review of the licensee's formal final response. Information that addresses items 4, 6, 7, and 8 should be provided for review.

2.3 Liquid poison System pipino Reanalysis Due to the questions raised during the confirmatory analyses of the CRDR piping system, the licensee committed to analyze portions of two additional small bore piping systems. These were the core spray system (north and south loops) inside containment and the liquid poison system outside containment.

The seismic reanalysis of the liquid poison system piping was also performed by the licensee's consultant, MPR. Their submitted report 9 contains a summary of the computer analysis and the stress results for this piping system. The liquid poison system was evaluated by utilizing three piping computer models. The piping system was analyzed to the ASME Code, 1980 Edition including the Summer 1981 Addenda. OBE was considered a Service Level B event and it was analyzed accordingly. SSE was analyzed as a Service Level C event with the modal responses summed by the square root sum of the squares (SRSS) method for both OBE and SSE loadings.

Weight, pressure, and thermal expansion loads were also considered, but seismic anchor movements (SAMs) were considered negligible. This piping system was analyzed using the finite element computer program PIPESD, Version 6.2. Appropriate mass point spacing, stress intensification factors, and response spectra were utilized. The results of these analyses indicate the maximum stress ratio to be less 13

a fthan one. Therefore, this piping system was considered seismically adequate by MPR.

Even though the analysis was performed according to the ASME Code,-

some of the modeling techniques and analyst's philosophies did not appear totally' acceptable. This piping system was divided into three models.

The piping represented by two of these-models is interconnected in actual installation. However, no overlapping was exhibited between these two models preventing response due to the attached piping from affecting the individual computer models. This additional responsefcould possibly increase the stress ratios for some areas of the model. It was suggested that overlapping of computer models should be performed to the extent of at:least two supports in each direction. This amount.of overlapping can 3

then incorporate most of the response from adjacent piping making the computer model more. realistic.

4 In addition to the computer model overlap problem, MPR's analyses indicated that seismic anchor movements were negligible. Their, assumption was. based on an anchor displacement calculation for the reactor vessel. ,

This calculation indicated that the first natural frequency.of the reactor 4

vessel was at an acceleration higher than the ZPA. The licensee was-requested to justify the use of the ZPA for their reactor vessel anchor displacement calculation. They were also requested to provide an explanation as to what is considered a negligible anchor movement.

The. concerns described above were discussed at the April 24, 1986,- ,

meeting. The licensee's draft responses _provided additional details regarding model boundaries and interaction that satisfied the concern i regarding model overlapping. The licensee stated that.they believed SAMs were not significant. This was explained by stating that the subject.

piping was anchored eitherEto the reactor drywell or to the reactor

j. building structure. All of the subject piping is at approximately the. I

! same elevation and the reactor building and the drywell are-supported from i the same base mat. The licensee was requested to provide additional information regarding relative stiffnesses of.the drywell and reactor

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building structure-in'the area of the piping anchors. The licensee was

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also requested to justify lthe use .of the ZPA for the reactor vessel l

-displacement calculation and clarify what is meant by.a " negligible anchor  ;

movement."

'The MNCR review ~for the liquid poison piping system is described in l Section 2.6. Several items of concern were identified and certain follow-up actions are recommended.

Assessment of the liquid poison piping system acceptability cannot be completed until the licensee provides the requested information'regarding-C the relative stiffnesses of the drywell and reactor. building structure in-the area of the piping anchors and justifies:the use.of.the ZPA for the reactor vessel displacement calculations so the importance of the SAM contribution can be made. The licensee should also establish the value of-significant anchor movements and address the. discrepancies noted in the MNCR review section for this piping.

2.4 Core Spray Piping System Reanalysis-1

l In addition to the liquid poison piping system, the licensee submitted the core spray system piping reanalysis!0 The report indicated that the core spray system analysis was performed in the same manner as the liquid poison piping. Two models were used in this i

analysis. The first model contained the north loop of the core spray

{ system and the second model contained the south loop. These are two separate piping runs; thus, model overlap was not a concern. However,

{ these lines do attach to the reactor vessel and the same anchor.

displacement c.alculation used for the liquid poison system was utilized to justify not analyzing SAM loading for the core spray system. As in the liquid poison line, the licensee should justify using the ZPA for their-

] reactor vessel anchor displacement calculation. They should also provide an explanation as to what is considered a negligible anchor movement.

The MNCR review for the core spray piping system is described in l

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Section 2.6. .Several items of concern were identified and certain-follow-up actions are recommended.

Assessment of the core _ spray piping system acceptability cannot be ,

completed until the licensee provides the requested. information regarding -

justification of the use of the ZPA for the reactor vessel displacement

-calculations so the importance of the SAM contribution can be made. The licensee should also establish the value of significant anchor movements and address the discrepancies noted in the MNCR review section for this piping.

2.5 Main Steam And Feedwater Piping Support Reanalysis Reanalysis of certain piping supports on the main steam and feedwater 5 piping ~ systems was performed by the licensee's consultant, MPR. This analysis was performed in response to questions:regarding possible snubber cverloading that were raised in the Reference 1 report and reiterated in Reference 2. The MPR report ll specifically addresses the following supports:

Main Steam System X-2A-SS-1 l

i MS-R1A J I

MS-R2A MS-R3A .i

! MS-R4A MS-RSA Feedwater System X-48-SS-1 RF-RIA RF R2A RF-R3A RF-R4A RF-R5A l RF-R6A 1

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t All of the supports above'are snubbers.

The method of analysis employed by MPR was to utilize finite element models from.the Reference 1 report. The appropriate models were modified-to explicitly-include support substructure and current as-built ,

i- configuration data. New snubber loads were generated by computer analyses i using the-same NRC safe shutdown earthquake (SSE) response spectra as in the NRC contractors' analysis (Reference'1). MPR scaled the resulting

snubber loads by the. ratio oflthe Oyster Creek Site specific zero period y

. acceleration (ZPA) to the NRC spectra ZPA (i.e., 0.165 g/0.220 g). : The scaled loads were used to complete the evaluation of components (clevises, i' bolts, plates, welds, etc.) for each support.

The only load case applied to the subject feedwater system snubbers I was the SSE. SSE plus relief and safety valve discharge loads were applied to the main steam system snubbers. Service Level 0' stress limits as specified by Section-III, Division I Subsection NF of the ASME Code (1980 edition plus Winter 1982 addenda) were used as acceptance criteria.

i l Review of the MPR report ll shows that appropriate modeling, load I cases and acceptance criteria were used. The stress calculations were reviewed on a sample basis and found to be done in a consistent and

! appropriate manner. However, current support drawings were not included-in the MPR report; thus, it was not possible to independently verify or spot check correct component data. This omission was discussed in~the i

April 24, 1986, meeting. The licensee stated that this'information would be addressed in the MNCRs which they would be submitting, i

Numerous MNCRs for the main steam and feedwater piping systems were submitted for review. These are discussed in Section 2.6. In general, the discrepancies described by the MNCRs would not have:a major effect on '

j the structural adequacy of the subject supports. However, MNCRs involving supports MS-RIA, MS-R3A (main steam system), X-48-SS-1, and RF-R1A

. (feedwater system) were found to have discrepancies warranting follow-up 17 I

i

r l

actions. Further details may be found.in Section 2.6. Also, no MNCRs i p

were submitted for feedwater supports RF-R4A, RF-RSA, and RF-R6A. The

-licensee should clarify if these supports were found to be without i discrepancies or if additional inspection inforr'ation will be submitted.

From the information presented, it appears that the subject main steam and feedwater piping system snubbers are adequate for the expected SSE loads. However, the licensee should address the follow-up items resulting from the MNCR reviews and clarify the status of feedwater supports RF-R4A, RF-RSA, and RF-R6A.

2.6 Pipino System MNCR Review As described in Section 1., confirmatory analyses were previously performed by EG&G Idaho on portions of five different piping systems.

These systems were the main steam, faedwater, CRD return and water and steam filled portions of the isolation condenser piping. Subsequently,

the licensee committed to analyze portions of two additional systems.

, These were the core spray system (north and south loops) inside

! containment and the liquid poison system outside containment. The i information utilized in the EG&G confirmatory analyses was based on the assumption of accurate "as-built" data regarding supports and piping geometry. These data were provided by the licensee. An inspection conducted by USNRC Region I in May, 1985, included findings which

' questioned the accuracy of the original field verification efforts. If the originally supplied information contained inaccuracies, then the

reported SEP results could also reflect a misleading picture of the piping I' safety margins. It should be noted that the original SEP analyses concentrated on an evaluation of the piping stresses only. Inspection and Enforcement (I&E) Bulletin 79-02 required system walkdowns and verification of the adequacy of certain piping supports using concrete anchor bolts. I&E Bulletin 79-14 required an examination of Seismic Category I piping systems to verify that the analyzed geometry matched the as-built geometry. Thus, the SEP program did not address the adequacy of i piping supports because this topic was to be covered by the responses to 1

18

]

the above mentioned bulletins.

The Oyster Creek licensee agreed to provide updated field inspection data so that an assessment of the validity of the original SEP piping analyses could be made. The first group of this information was provided subsequent to a June 25, 1985, meeting between GPUN and NRC representatives. As agreed, the licensee provided the available information noting that efforts for all safety-related systems had not been completed at that time. The information provided was in the form of Material Nonconformance Reports (MNCRs). Specific information requested for the SEP piping systems included marked-up drawings or piping isometrics resulting frcm the latest inspections, copies of the pipe support drawings and written descriptions of all nonconformances found during the latest inspections of these systems. The available information was then compared to the original SEP piping input in an effort to determine if significant discrepancies existed that would potentially invalidate the results and conclusions reached in the earlier work. The results of the review of the first group of information were summarized and informally transmitted to the NRC technical monitor in July of 1985 for information and review. Subsequent submittals by the licensee have been reviewed in the same manner. The following paragraphs contain comments on the discrepancies found and assessments of their impact on the analysis results. As previously explained, the original SEP analyses did not address piping support adequacy. Thus, the primary emphasis of the current comparisons was on the validity of the piping analyses; however, comments are included regarding the piping supports.

l All MNCR information submitted by the licensee for the five piping I models included in the confirmatory analysis originally performed by EG&G have been reviewed. These systems include the main steam, feedwater, steam and water filled isolation condenser piping and control rod drive (CRO) pump discharge piping. Also, MNCRs dealing with the core spray system and the liquid poison system which were reanalyzed by the licensee's consultant (MpR) have been reviewed. Notes describing the nature and extent of the repo*ted discrepancies are attached as 19

Appendix A. This same information is also presented with slightly less detail in Table 3. Note that those items which the reviewer believes should receive follow-up action have their MNCR numbers underlined in Table 3. Specific summaries of the results regarding each system are listed below. Since the numerous MNCRs.for each system are shown both in Appendix A and, Table 3, only general summaries of the review results will be described in the following paragraphs. Due to its length, Table 3 has been located after the summary text.

2.6.1 Feedwater 2.6.1.1 piping.

RF-2-18" and RF-2-10" (south side, inside drywell) 2.6.1.2 Discrepancies.

MNCR 85-112-1 relates how the support configuration differs from that used in the original analysis. MNCR 85-112-8 includes geometric discrepancies. These include the note that only a partial reinspection was performed and length differences were found in certain piping segments. Also, elevation discrepancies were noted by the reviewer that were not noted by GPUN on the MNCR. Figure 1 shows a sketch of the feedwater piping model as used in the 1980 SEP confirmatory analysis.

Figure 2 shows a sketch with this elevation mismatch noted.

2.6.1.3 Assessment.

As noted above, a complete reinspection was not performed. Further information is needed before an accurate assessment of the validity of the  ;

original analysis can be made. The known discrepancies noted above would )

be expected to alter system dynamic response and seismic stress levels. I Steps should be taken to assure the completeness and accuracy of the new 20

I 1

X En CTM, 4,gi  %* >y'.

1 /s p-

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i b

4 k

e 7 4  %

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8 e ~ ,

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  • H , A!S
  • V 1 4*p r. L . = ao. s '

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I Data Sources:

Owg. JCP-19433, Sht. 2, Rev. 1 Dwg. 2109-5, Rev. 5 Personal connunications with GPUN personnel l

Figure 1 - Oyster Creek Feedwater Piping - 1980 SEP Data I

y R, crx.

14 , g t'

, < >y'.

Is

, 6 6*

=

O Note: Mismatch of elevations

',$ when consider diagonal and vertical runs.

y a v #$ o

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/,

V S *#, ys

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k 9 DrAGoMAL SEc.ftEM f k

,/ sL ' ys*H,vr*v T. L . a e s ss'3"

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& EL. 46'-lo gf

  • Data Source:

" Marked-up" drawing JCP-19433, Sht. 2, Rev. 2 4

Figure 2 - Oyster Creek Feedwater Piping - 1985 Walkdown Data

information since discrepancies not noted by GPUN were found by the reviewer. Piping support adequacy should be' evaluated accounting for any discrepancies found during a complete reinspection.

Only two MNCRs dealing with the feedwater system were included in the latest (3-19-86) submittal. This information did not address any of the comments made above regarding the system adequacy. It was not clearly stated whether the two additional MNCRs were the only ones resulting from a complete reinspection of the system or whether completion of the reinspection effort was pending. The licensee snould clarify the status of the inspection effort for this system.

2.6.2 Main Steam t

2.6.2.1 pipina.

MS-1-24" south side, inside drywell.

2.6.2.2 Discrepancies.

MNCR 85-110-2 states that only a partial reinspection was performed.

MNCR 85-110-15 notes several changes in the configuration of support MS-R3A (snubber). One of the changes is that the snubber is anchored so as to produce torsion on a wide flange beam (6WF15.5). The support may not have the stiffness originally assumed. MNCR 85-110-18 notes dimensional discrepancies on crawing JCP-19442, Sheet 2 of 4. Revision 2.

The drawing attached to the MNCR is cut and portions are missing. Also, some dimensions on the drawing are unreadable. A complete review can not be made without a complete and readable copy of the marked-up drawing.

4 MNCR 85-110-24 notes that a snubber from the clean-up demineralizer system is attached to the beam to which the snubber of support MS-RIA is attached. While this will not have a significant impact on the results of the main steam piping analysis, it could have a significant effect on the structural adequacy of the support. It should be verified that all loads j are accounted for in the support analysis or the structural steel analysis l

j 23

if it is handled as a separate item. MNCRs 85-211-1 to 13 (main steam vent line) were also reviewed. MNCRs 85-211-5, 7, ard 9 showed snubbers attached to springs. This could have a significant effect on the analysis l results if support stiffnesses are not modeled accurately.

2.6.2.3 Assessment

The available information for this system is incomplete. The l licensee should clarify whether or not a complete reinspection of tne system has been completed and all MNCR information forwarded for review.

! No assessment regarding the validity of the original SEP analysis can be made until it.is known that all MNCR information has been considered.

Although the main steam vent line is not part of the SEP main steam r.onfirmatory analysis model, the piping analysis of this line should be l reviewed to be certain that the supports mentioned above are properly 1

modeled and results are reasonable.

I 2.6.3 Isolation Condenser (k'ater Filled. "A" Loop) 2.6.3.1 piping.

NE-2-10" and NE-2-8" outside drywell.

I 2.6.3.2 Discrepancies.

Numerous MNCRs on this system (85-095-17, 21, 27, 29, 30, and 32) were found to contain discrepancies that should receive attention.

Further information is contained in Table 3 and Appendix A. The discrepancies noted in the MNCRs above are of a nature that would not usually directly affect the piping analysis due to the way supports are commonly modeled. However, in the worst case, if these supports were unable to reliably perform their intended function, the structural I adequacy of the individual supports and the piping system as a whole could l be adversely affected. MNCR 85-095-24 includes several geometric discrepancies from the original analysis. These are described on page A9 of Appendix A.

l 24

2.6.3.3 Assessment.

The licensee did not provide separate copies of the drawings for all supports located on the system as previously requested. However, all supports included in the original SEP analysis of this line have been accounted for in the MNCR documentation. The geometric discrepancies noted above would affect the calculated dynamic response and seismic stress _ levels. Judgement may indicate that it is not likely that allowable stress levels would be exceeded particularly when one considers that the more recently developed site-specific response spectra is lower than that used in the original SEP analysis. However, the combination of the numerous support and geometric discrepancies have not been included in an accurate "as-built" analysis of the system; thus, the cumulative effects are not known. The discrepancies noted on this system would seem to be of such a nature and combination that a reevaluation would be warranted. The maximum benefit of an updated piping and supports analysis would be to provide an accurate reflection of the current system configuration and updated stress results. This would answer SEP concerns and serve as a qualification baseline for any future system modifications.

2.6.4 Isolation Condenser (Steam Filled, "A" Loop) 2.6.4.1 Piping.

NE-5-10", NE-1-16", NE-1-12" outside drywell.

2.6.4.2 Discrecancies.

Numerous MNCRs on this system (85-095-37, 38, 39, 40, 48, 50, and 54) were found to contain discrepancies that should receive attention.

Further information is contained in Table 3 and Appendix A. The discrepancies noted in the MNCRs above are of a nature that would not usually directly affect the piping analysis due to the way supports are commonly modelad. However, in the worst case, if these supports were )

unable to reliably perform their intended function, the structural 25

adequacy of the individual supports and the piping system as a whole could be adversely affected. MNCR 85-095-55 includes several geometric discrepancies from the original analysis. These are described on page A12 of Appendix A.

2.6.4.3 Assessment.

The licensee did not provide separate copies of the drawings for all supports located on the system as previously requested. However, all supports included in the original SEP analysis of this line have been accounted for in the MNCR documentation. The geometric discreaancies noted above would affect the calculated dynamic response and seismic stress levels. Judgement may indicate that it is not likely that allowable stress levels would be exceeded particularly when one considers that the more recently developed site-specific response spectra is lower than that used in the original SEP analysis. However, .the combination of the numerous support and geometric discrepancies have not been included in an accurate "as-built" analysis of the system; thus, the cumulative effects are not known. The discrepancies noted on this system would seem to be of such a nature and combination that a reevaluation would be warranted. The maximum benefit of an updated piping and supports analysis would be to provide an accurate reflection of the current system configuration and updated stress results. This would answer SEP concerns and serve as a qualification baseline for any future system modifications.

2.6.5 CR0 pump Discharge 2.6.5.1 piping.

l l

NC-2-2" outside drywell from pumps to filters 2.6.5.2 Discrepancies.

Numerous MNCR's were generated to describe the discrepancies found.

General comments regarding these are contained in Appendix A.

26

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

2.6.5.3 Assessment All MNCR's supplied by the licensee for this line were examined. Due to their extensive nature, individual notes were not included in Appendix A. No discrepancies were found that were judged to have a 'significant impact on the piping stress results for seismic load cases.

2.6.6 Core Soray (North Loop) i 2.6.6.1 piping.

NZ-3-8" from penetration X-128 to reactor vessel. '

! 2.6.6.2 Discrepancies.

MNCR 85-113-10 notes several discrepancies in the configuration of support NZ-3-53 including two missing bolts in the snubber attachment.

MNCR 85-113-12 notes discrepancies in support X128-SS-1. This support could not be positively identified in the licensee's analysis. MNCR 85-113-9 notes discrepancies in the system configuration; however, the isometric included in the MNCR was not complete.

i 2.6.6.3 Assessment. i i

A complete assessment of this system could not be performed. The licensee's disposition of the missing bolts in MNCR 85-113-10 stated simply that this was acceptable. References to calculations or other sources used to establish structural adequacy should be noted on the MNCR

! and provided for review. A complete copy of the system isometric clearly identifying all supports and anchor points should be provided.

27

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

2.6.7 Core Spray (South Loop) 2.6.7.1 piping.

NZ-3-8" from penetration X-70 to reactor vessel.

2.6.7.2 Discrepancies.

MNCR 85-113-2 deals with support NE-3-59. This support could not be positively identified in the licensee's analysis. MNCR 85-113-8 indicates that the only significant geometric discrepancy is in the mislocation of a spring hanger; however, the sketch included in the MNCR does not show sufficient detail to permit verification of the licensee's computer modeling.

2.6.7.3 Assessment.

The assessment of this system is not complete. A complete copy of the system isometric clearly identifying all supports and anchor points should be provided. This will enable computer modeling verification to be completed.

2.6.8 Liquid poison System 2.6.8.1 piping.

NP-2-1.5" from pumps to containment penetration. NP-2-1" from accumulator to poison tank. NP-1-2.5" from poison tank to pumps (pump suction).

2.6.8.2 Discreaancies.

Numerous MNCRs (85-098-3, 5, 2, 8, 1, 9, 4, 13, and 15) were noted to .

I have discrepancies which should receive follow-up attention. These are described in more detail in Appendix A and Table 3. Most of these 28 l

discrepancies deal with pipe supports.

2.6.8.3 Assessment.

Assessment of the adequacy of the liquid poison piping analyses provided by the licensee cannot be finalized until the discrepancies noted ,

l in Appendix A and Table 3 for MNCRs 85-098-3, 5, 2, 8, 1, 9, 4, 13, and 15 are addressed. As noted in Table 3 and Appendix A, some of these MNCRs ,

would not directly affect the piping analysis due to the way supports are commonly modeled. However, in the worst case, if these supports were unable to reliably perform their intended function, the structural adequacy of the individual supports and the piping system as a whole could be adversely affected.

l 2.6.9 ADDITIONAL COMMENTS As noted in the paragraphs above, the available information received  !

is considered incomplete. Also, it has been noted that some component attachments wtre not inspected due to being covered by insulation.  ;

Supplement 2 to I&E Bulletin 79-14 requires that insulation be removed.if necessary to inspect and verify piping attachments. Furthermore, numerous  ;

instances of discrepancies that would affect base plates and concrete anchors subject to I&E Sulletin 79-02 were observed. Examples of these i include: '

1. Holes in concrete near anchor bolts. This would potentially l

violate spacing criteria. Examples can be seen in MNCR 85-095-17.23 and 54.

l 2. Lack of sufficient concrete edge distance. This would reduce i i

the anchor bolt allowable load. Examples can be seen in MNCR 85-095-27 and 41.

3. Lack of adequate base plate bearing. This would alter the load transferral from plate to anchor bolts, possibly invalidating 29

i the base plate and/or anchor bolt analysis. MNCR 85-095-29 can be used as an example. l l

Another observation concerns the two isolation condenser system pipe lines. The original SEP analysis input for the water filled "A" loop line )

was taken from drawing JCP-19433, Sheet 4, Rev. 2. The MNCR documentation noted above was based on revision 3 of tha same drawing. Upon comparison it can be seen that there were major dimensional changes (for example, one dimension changed by approximately six feet); however, both revisions were noted as " field verification for NRC I&E Bulletin 79-14." The discrepancies further noted against revision three as reported in the MNCR documentation lead one to question the thoroughness and adequacy of the 1

licensee inspections of this line. Similarly, the criginal SEP analysis 1 l input for the steam filled "A" loop line was taken from drawing JCP-19433, Sheet 2 Rev.2. The MNCR documentation noted above was apparently based l 1

l on revision 3 of the same drawing. Again, both revisions are noted as i " field verification for NRC ISE Bulletin 79-14." As before, the discrepancies noted against revision three as reported in the MNCR's lead l to questions regarding the thoroughness and adequacy of the licensee

! inspections of this line. It appears that several inspections have been I performed by the licensee on both lines with discrepancies noted each j time. This situation should be addressed and the reliability of the information assured.

l All of the discrepancies in Table 3 noted by an underlined MNCR number c.uld impact the validity of the respective I&E bulletin responses and the stress levels of the affected piping and supports.

30 l

l

Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs System MNCR Discrepancy Assessment Feed Water MNCR-85-112-1 Differences in snubber Differences in restraint installations for support directions may affect results.

X-4B-SS-1. In-the original SEP analysis three restraints designated RF-HR1, RF-HR2 and RF-HR3 were shown (dwg. JCP-19443, sht. 2, Rev. 1) at this location.

Support X-4B-SS-1 consists of two snubbers which provide vertical and horizontal (N-S) restraint. The original three supports were arranged to provide restraint in all three global directions.

Location is the same as the SEP analysis.

MNCR 85-112-2 Support RF-R2A. Minor No effect on piping analysis.

snubber / extension discrepancies.

II MNCR 85-112-3 Support RF-R3A. Minor dimensional Ho effect on piping analysis, and weld discrepancies.

MNCR 85-112-4 Support RF-RIA. Snubber reversed No effect on piping model and weld discrepancies. MNCR assuming support is adaquate.

disposition says incomplete weld on bracket stanchion is acceptable, but the load used is not listed.

The support load is not shown on the support drawing.

NNCR 85-112-5 Support RF-R-H9. Minor weld and No effect on piping analysis.

dimensional discrepancies.

MNCR 85-112-6 Support RF-R-H8. Configuration and No effect on piping analysis.

dimensional discrepancies.

MNCR 85-112-7 Support RF-R-H7. Brace members No effect on piping analysis, installed upside down. MNCR disposition notes that a loose nut should be tightened; however, no loose nut is noted on the marked-up support

I Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment

} drawing. '

MNCR 85-212-2 Supported valve is not identified. N.A. - Not Applicable to SEP Appears to be on north loop. model.

HNCR 85-212-1 Supported valve is not identified. Spring would affect weight Appears to be valve in south loop stresses; however weight between drywell and piping anchor. stresses are only Spring hanger (RF-R-H12, B&P dwg. approximately 7 ksi in area of 802) is not included in SEP valve. No significant impact analysis. Spring would not affect on analysis.

seismic analyses.

MNCR 85-112-8 Description states only a partial Complete assessment not walkdown was performed due to possible - see section 1.2 in accessibility. Numerous geometric Summary Assessment Appendix A.

discrepancies - see section 1.2 in Summary Assessment, Appendix A.

Main 3 team NNCR 85-110-1 Support X-28-SS-1. Minor No effect on piping analysis.

I k! dimensional and configuration discrepancies. ,

MNCR 85-110-2 Incorrect penetration marking. Licensee should affirm This MNCR states that the complete inspection of pipe inspection was performed for only a line.

portion of the line.

MNCR 85-110-3 Support MSH-7. Minor configuration No effect on piping analysis.

discrepancies on spring hanger.

NNCR 85-110-6 Support MS-RSA. Minor No effect on piping analysis.

configuration discrepancies on snubber installation.

MNCR 85-110-9 Support X-2A-SS-1 (513). Will not affect piping .

Dimensional discrepancies. analysis.

NNCR 85-110-11 Support X-2A-SS-1 (Snubber S14). Will not affect piping Dimensional discrepancies. analysis.

MNCR 85-110-12 Applies to north loop. N.A.

MNCR 85-110-13 Applies to north loop. N.A.

MNCR 85-110-14 Applies to north loop. N.A.

MNCR 85-110-15 Support MS-R3A. Several changes in Support analysis should be 2

Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment support configuration. Snubber checked. Decreased support anchored so as to produce torsion stiffness may affect seismic on 6WF15.5 beams. . Support may not results.

nave stiffness originally assumed.

MNCR 85-110-16 Support MS-R2A (snubber). No affect on piping analyses.

Dimensional changes on base plate.

HNCR 85-110-17 Applies to north loop. N.A.

MNCR 85-110-19 Support MSH-5. Minor discrepancies No affect on piping analysis.

on support drawing.

MNCR 85-110-20 Support MSH-6. Weld discrepancies No affect on piping analysis.

I on support.

! MNCR 85-110-21 Applies to north loop. N.A.

MNCR 85-110-22 Applies to north loop. N.A.

MNCR 85-110-23 Support MS-R4A. Welding and No effect on piping analysis.

I dimensional discrepancies.

t$ MNCR 85-110-24 Support MS-RIA. Configuration It should be verified that all discrepancies on support. It is loads are accounted for in the i

noted that another snubber (for support analysis.

I clean-up demin. sys.) is also l attached to the beam of this support.

HNCR's 85-211- Main steam vent line. MNCR's Although M.S. vent line is not I to -13 85-211-8, 7, 9 had snubbers included in the SEP piping attached to spring cans. mode, the piping analysis for this line should be reviewed to be certain that the supports mentioned above are properly modeled and results are correct.

MNCR 85-110-2 The nature and extent of geometric See MNCR 85-110-18 discrepancies is not known. As noted in the MNCR, only a portion of the line was reinspected. No marked-up piping isometric was furnished.

t

Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System HNCR Discrepancy Assessment MNCR 85-110-18 Dwg. 19442, Sht. 2, Rev. 2 (H. S. Assessment cannot be made piping, S. loop). Dimensional without complete and readable discrepancies on drawing. Drawing marked up drawing. Licensee attached to MNCR is cut and should affirm that a complete portions are missing. Also, some reinspection of the piping dimensions, etc. are unreadable. system has been accomplished.

Licensee should supply complete and readable drawing including mark-ups of all walkdown discrepancies.

Iso. Condenser MNCR 85-095-15 Support NE-2-S10 (G.P.). No effect on piping analysis.

(Water Filled Configuration discrepancies.

"A" Loop)

MNCR 85-095-16 Support NE-2-S9 (G.P.). Snubber No effect on the piping location discrepancy and minor analysis.

configuration discrepancies. This 3: is an axial snubber.

NNCR 85-095-17 Support NE-2-58 (G.P.). Concrete No effect on piping analysis anchor discrepancies. assuming recommended support repair is performed.

MNCR 85-095-18 Support NE-2-S14 (G.P.). Minor No effect on piping analysis, dimensional discrepancies.

MNCR 85-095-19 Support NE-2-H10 (G.P.). No effect on piping analysis.

Configuration discrepancies on spring hanger.

MNCR 85-095-20 Support NE-2-S12 (G.P.). No effect on piping analysis.

Configuration discrepancies on snubber installation.

t MNCR 85-095-21 Support NE-2-H9 (G.P.). No effect on piping analysis.

Configuration discrepancies. Holes Structural adequacy of the in angle section are not addressed support could be affected.

in MNCR disposition.

MNCR 85-095-22 Support NE-2-S13 (G.P.). No effect on piping analysis.

Dimensional discrepancies.

MNCR 85-095-23 Support NE-2-H4 (G.P.). Weld and No effect on piping analysis.

Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd) i System MNCR Discrepancy Assessment installation discrepancies.

MNCR 85-095-25 Support NE-2-5. Various weld and No effect on piping analysis, dimensional discrepancies on spring hanger.

MNCR 85-095-26 Support NE-2-H6 (G.P.). No effect on piping analysis.

Configuration discrepancy on spring hanger.

HNCR 85-095-27 Support NE-2-S11 (G.P.). Weld and No effect on piping analysis.

structural discrepancies on snubber Structural adequacy of support installation. should be verified.

i MNCR 85-095-28 Support NE-2-H12 (G.P.). Weld and No effect on piping analysis.  ;

dimensional discrepancies on spring  ;

hanger.

MNCR 85-095-29 Support NE-2-H14 (G.P.). Weld No effect will be seen in the discrepancies and additional piping analysis; however, the ,

attachments. additional attachments to the  !

. support steel should be l' ti verified for inclusion in the structural analysis of the s

' support.

MNCR 85-095-30 Support NE-2-S16 and NE-2-S15 No effect on piping analysis.  :

missing welds and incorrect weld These snubbers are located sizes on snubber installations. very near a drywell penetration and it is questionable if there is 2

enough piping movement to actuate the snubbers. -

Verification of this should be provided..

MhCR 85-095- Supports X-58-MR-1 and X-5B-MR-3 No effect on SEP piping (B-P). Snubbers not installed - analysis since they were not apparently replaced by support originally included.

NE-2-S16.

MNCR 85-095-32 Support NE-2-H11 (G.P.). _W eld and No effect on SEP piping 1 dimensional discrepancies on spring analysis. Support structural ~  ;

1 1

l i-1 i

Table 3 - DISCREPANCIES FOUND FROM REVIEW 0F OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment hanger. analysis could be affected.

MNCR 85-095-24 Numerous geometric discrepancies - Geometric discrepancies could see section 3.2 of Summary affect analytical results.

Assessment, Appendix A. See Summary Assessment, Appendix A.

Iso. Condenser MNCR 85-095-36 Support NE-5-3. Weld and No effect on piping analysis. ,

(Steam Filled dimensional discrepancies on spring "A" Loop) hanger installation.

MNCR 85-095-37 Support NE-5-3A. Weld and No effect on piping analysis, configuration discrepancies on Support calcs should be spring hanger. checked for the effect of i

these discrepancies.

! MNCR 85-095-38 Support NE-5-H4 (G.P.). Weld and No effect on piping analysis.

configuration discrepancies on Support calcs should be spring hanger installation. checked. '

MNCR 85-095-39 Support NE-1-H1 (G.P.). No effect on piping analysis.

g; Dimensional and configuration Support calcs (structural discrepancies on spring hanger steel) should be checked.

installation.

MNCR 85-095-40 Support NE-1-S1 (G..P.). No effect on piping analysis. !

Dimensional and structural Close proximity of unused i

discrepancies on snubber anchor hole in concrete could installation. have lowered the factor of.

safety of the existing anchor bolts and violated the requirements of IEB 79-02.

Support calcs should be checked.

MNCR 85-095-43 Support NE-1-H5 (G.P.). No effect on piping analysis.

Dimensional and configuration discrepancies on spring hanger installation.

1 l

1

Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment MNCR 85-095-46 Support NE-1-S4 (G.P.). Weld No effect on piping analysis.

discrepancies on snubber installation.

MNCR 85-095-48 Support NE-1-H4 (G.P.). Anchor No effect on piping analysis, bolt deficiencies on spring hanger Support cales should be installation. checked.

MNCR 85-095-49 Support NE-1-H7. Dimensional and No effect on piping analysis, configuration discrepancies on spring hanger installation.

MNCR 85-095-50 Support NE-1-H3 (G.P.). Base plate No effect on analysis of and dimensional discrepancies on piping but support base plate spring hanger installation. calculations should be checked.

MNCR 85-095-53 Support NE-1-53 (G.P.). No effect on piping analysis.

Dimensional discrepancies on u>

snubber installation.

MNCR 85-095-54 Support NE-1-S5 (G.P.). Weld and No effect on piping analysis.

base plate discrepancies on snubber Proximity of threaded insert installation. hole to concrete anchor is not addressed in MNCR disposition. The effect of this on bolt F.S. should be checked.

MNCR 85-095-58 Support NE-1-H2 (G.P.). No effect on piping analysis.

Dimensional discrepancies on snubber installation.

MNCR 85-095-55 Contains the marked-up drawing Possible effect on piping resulting from the latest analysis results.

walkdown. Several dimensional discrepancies - see section 4.2 in Summary Assessment, Appendix A.

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

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, i Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment CRD Numerous Numerous Numerous MNCRs were generated to describe the discrepancies found. All discrepancies were examined and judged not to impact the SEP piping analysis. .

Core Spray MNCR 85-113-10 Support NZ-3-S3 (G.P.). Support Will not affect piping (N. Loop) configuration, weld, and base plate analysis. References to a discrepancies. Effect of missing calculations or other sources i bolts (noted on support drawing) used to disposition does not appear to have been- discrepancy should be considered in detail. provided.

MNCR 85-113-11 Support NZ-3-S4 (G.P.). No effect on piping analysis.

Installation and weld discrepancies.

w MNCR 85-113-12 Support X128-SS-1 (B.P.). Weld Possible effects on piping

" discrepancies. This support does analysis, not appear to be included in the MPR piping model.

MNCR.85-113-13 Support NZ-3-H3 (G.P.). Weld and Will not affect piping other dimensional. discrepancies. analysis. See also MNCR 85-113-15.

MNCR 85-113-14 Support NZ-3-H4 (G.P.). Weld and Will not affect piping configuration discrepancies. analysis.

MNCR 85-113-15 Support NZ-3-H3'(G.P.). Weld Will not affect piping discrepancies on spring hanger analysis.

attachment members - for further evaluation see MNCR 85-113-13.

MNCR 85-113-9 Geometry / configuration Cannot compare to computer '

discrepancies. Drawing isometric . model. Licensee should ,

l in MNCR is not complete. provide complete drawing.

. . Core Spray MNCR 85-113-1 Support NZ-3-H9 (G.P.). Support No effect on piping analysis.

(S. Loop) weld anomalies.

t it

Table 3 - DISCREPANCIES FOUND FROM REVIEW 0F OYSTER CREEK MNCRs (Cont'd) l System MNCR Discrepancy Assessment 1

! MNCR 85-113-2 Support NE-3-S9 (G.P.). This Possible effects on piping support apparently not included in analysis.

MPR's analysis.

MNCR 85-113-3 Support NZ-3-S8 (G.P.) (B. P. No effect on piping analysis.

  1. 461-R2). Dimensional discrepancies.

NNCR 85-113-4 Support NZ-3-H8 (G.P.). Will not affect piping Configuration changes. analysis.

MNCR 85-113-5 Support NZ-3-H7 (G.P.). Will not affect piping Configuration discrepancies. analysis.

MNCR 85-113-6 Support NZ-3-H10 (G.'Ps ) . Base No effect on piping analysis.

plate dimensional changes.

MNCR 85-113-7 Support NZ-3-S7 (G.P.). No effect on piping analysis.

Dimensional discrepancy. MNCR states that snubber is tagged w

NZ-3-S9.

MNCR 85-113-8 NNCR on piping The sketch contained in this geometry / configuration - states MNCR does not show sufficient that only discrepancy is in detail to permit verification location of spring support NZ-3-H8. of computer modeling. Appears to be possible discrepancies in model geometry.

Liquid Poison MNCR 85-098-22 Support NP-2-H3. No ID/ scale plate No effect on piping analysis.

(Containment - on spring can.

Explosive Vivs.)

MNCR 85-098-23 Support NP-2-H2. No ID/ scale No effect on piping analysis, plate.

MNCR 85-098-3 Support NP-2-R7. Anchor bolt No probable effect on piping discrepancies, weld discrepancies analysis. However, this and U-bolt size discrepancies. support attaches to several pipe lines. Total loading should be verified and the support adequacy confirmed for the total load.

i

Table 3 - DISCREPANCIES FOUND FROM REVIEW 0F OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment MNCR 85-098-5 Support NP-2-R7A. U-bolt size Will not affect piping discrepancies. Drawing shows analysis. However, support excessive bolt and thread should be verified to have projection. adequate torque such that U-bolts are properly set.

MNCR 85-098-6 Support NP-1-RS. Gang support for No effect on piping analysis.

several lines. Added brace, weld discrepancies.

MNCR 85-098-12 Support NP-2-R3. Support base No effect on piping analysis.

plate orientation changed.

MNCR 85-098-20 Dimensional discrepancies on Seismic stress should be containment - explosive valves reduced. No detrimental piping. One segment of piping is effect on piping analysis, shorter.

Liquid Poison MNCR 85-098-11 Support NP-1-R6A. Weld No effect on. piping analysis.

t. (Exp. Vlvs - discrepancies.

Pumps)

MNCR 85-098-10 Support NP-1-R68. Weld and No effect on piping analysis, dimensional discrepancies.

MNCR 85-098-2 Support NP-2-RI. Weld and anchor- Drawing indicates support is bolt discrepancies. to withstand lateral motion (N-S) but base plate is only 2 hole pattern in wrong direction. Support will not resist lateral load very well. Support drawing references drawing for NP-2-R2 which has an added brace. But brace and base plate details for NP-2-R1 are not shown.

Licensee should clarify support details.

MNCR 85-098-8 Support NP-2-RIB. Weld Should check ~ adequate torque discrepancies and excessive anchor for " setting" anchor bolt. No bolt projection, effect on piping analysis.

Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment MNCR 85-098-1 Support NP-2-R2. Weld and Base plate for lateral brace configuration discrepancies. has highly unsymmetrical bolt Lateral brace has been added. pattern. Base plate and anchor bolt calcs should be verified.

MNCR 85-098-9 Support NP-1-R6. Configuration Should verify anchor bolts set discrepancies, excessive anchor properly. No effect on piping bolt projection, analysis.

MNCR 85-098-4 Marked up drawing from field This added mass coupled with walkdown of subject piping shows the support discrepancies some dimensional changes plus noted above for these systems flanges and valves not shown on the will change the piping system IS0's used for the analysis. response to seismic loading.

Stresses will probably not be over the allowable limits;

, however, this cannot be

>- assured without reanalysis.

Liquid Poison MNCR 85-098-17 Support NP-1-H1A. Weld and No effect on piping analysis.

(Pump Suction) configuration discrepancies, excessive anchor bolt projection.

MNCR 85-098-18 Support NP-1-HIB. Weld and slight No effect on piping analysis, configuration discrepancies.

MNCR 85-093-13 Support NP-1-H2. Added welds. Piping loads (SSE) are Base plate orientation shown on relatively small; however, the drawing would not be effective to adequacy of the support should resist moments due to lateral be verified. The licensee's seismic loads. conditional release assessment doesn't appear to adequately consider the base plate orientation.

MNCR 85-098-15 Support NP-1-R10. Weld Another case where support discrepancies and excessive anchor base plate is oriented 900 bolt projection. from proper direction to resist majority of loads. No probable effect on piping

j Table 3 - DISCREPANCIES FOUND FROM REVIEW OF OYSTER CREEK MNCRs (Cont'd)

System MNCR Discrepancy Assessment analysis.

MNCR 85-098-19' Piping system geometry Stresses were low so adequacy discrepancies on pump suction- of piping analysis will line. Slight differences.in probably still be acceptable. -

apparent configuration.

Note: Underlining of MNCR numbers indicates those MNCRs which, in the reviewer's opinion, should receive follow-up action.

R

=

3. CONCLUSIONS The additional information submitted by the Oyster Creek licensee.

since-the completion of the P.eference 1 and 2 reports has been reviewed by 3

INEL personnel. Open items concerning the following topics have been addressed:

1. The reanalysis of the Control Rod Drive Return (CRDR) system piping,
2. The structural integrity of the 4160 V switchgear and 460 V unit substation cabinets, .
3. The seismic reanalysis of the liquid poison system piping,
4. The seismic reanalysis of the core spray system piping,
5. The seismic reanalysis of the main steam and feedwater piping

' supports inside containment, 4

6. The effect that discrepancies described.by the MNCR data may.

have on piping system structural adequacy.

Pending review of the licensee's formal final response, the following conclusions are indicated:

1. The seismic qualification of the CRDR piping system has been found to be acceptable
2. The acceptability of the other topics listed above.cannot be

! finalized until the licensee addresses the open items identified in the previous sections. These open items are summarized in Section 4.

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v , , . . - , , ,y -

w< w

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4. RECOMMENDATIONS 1 As noted in the previous sections, the licensee has agreed to provide certain additional information in the formal version of their draft responses that were discussed in the April 24, 1986 meeting. Pending its .

review, this information should enable the closure of several of the open items previously discussed. The licensee should.also provide the additional information necessary to close the additional concerns that have been identified during the MNCR reviews. Completion of the recommended follow-up actions and provision of the necessary information will enable the satisfactory closure of all identified open items.

It is recommended that the licensee address the open items summarized below. Additional details regarding these items can be found in the body of the report.

4.1 General

1. The licensee should provide their final version of the draft responses discussed at the April 24, 1986, meeting.
2. The licensee should address the need for a verification program similar to that conducted for the piping systems (MNCR review) to ascertain that information utilized for the analysis of structures l

and equipment is accurate "as-built" data.

3. The licensee should verify whether any other piping. systems in the plant utilize axial restraint from U-bolts in their seismic aualification. If so, the licensee should provide documentation describing the testing or calculations used to determine friction coefficients expected in actual plant conditions, the procedures used to control U-bolt tightness, and the effects of imposed localized stresses on the pipe.
4. The licensee should provide complete copies of all references used 44

- _ = ~ .

unless thsy are entered in the NRC docket for this plant and readily retrievable.

4.2 4160 V and 460 V Switchaear Cabinets

1. Reference i from the licensee's draft response discussed at the April 24, 1986, meeting should be provided.
2. The licensee should justify not maintaining a factor of safety (FS) of 4.0 as required by IE Bulletin 79-02 particularly when the accelerations were not multiplied by a factor of 1.5 for conservatism.
3. The licensee should address the possibility of cabinets interacting-(impacting) during horizontal movement during a seismic event.
4. The licensee should describe what factors of safety would result if friction was not used to reduce shear loads on the concrete anchor

, bolts.

5. On page 3-7 of the licensee's report (Reference 6) it is stated that the type and embedment of the anchor bolts for the 4160 V cabinets is unknown. If the licensee cannot verify that sleeve type anchors are not used, then use of a factor of safety of 4.0 versus 5.0 as-

)- specified by IE Bulletin 79-02 should be justified.

4.3 Liouid Pcison Pipina System Reanalysis-1

1. The licensee should provide additional information regarding relative-

) stiffnesses of the drywell and reactor building structure in the area-of the piping anchors.

j 2. Justification should be provided for.the use of the ZPA for the reactor vessel displacement calculation.

45

3. Clarification should be provided as to what is. meant by a " negligible anchor movement."

4.4 Core Spray pining System Reanalysis

1. Justification should be provided for the use of the ZpA for the reactor vessel displacement calculation.
2. Clarification should be provided as to what is meant by a " negligible anchor movement."

4.5 Main Steam And Feedwater Piping Support Reanalysis

1. The licensee should address the follow-up items resulting from the MNCR reviews of the subject supports.
2. Clarification of the status of feedwater supports RF-R4A, RF-RSA, and RF-R6A should be provided.

4.6 piping Systcm MNCR Review

< 1. Appropriate follow-up actions should be taken on all MNCRs shown underlined in Table 3.

2. The licensee should clarify whether complete information has been supplied for the feedwater piping codel.
3. The licensee should confirm v;hether a complete reinspection of the main steam system has been completed.
4. Complete and readable marked-up isometrics should be supplied for the main steam piping model.
5. The changing configurations of the isolation condenser lines should be addressed to explain the numerous licensee inspections and 46

resulting discrepancies.

6. The licensee should assure compliance with all applicable I&E bulletin requirements that may be affected by the discrepancies found.
7. The licensee should describe the quality control measures taken to assure the accuracy of all information provided.
8. The licensee should clearly state which systems are considered to have complete information. For those systems which are not comp!ete, the licensee should state what information is expected to be added and orovide an estimated schedule for the delivery of information.
9. The potential for increased piping support loads caused by geometric discrepancies in the piping system layout or differences obscrsed in ,

the as built location or configuration of the support should be addressed. Support adequacy under any revised loads should be assured and the licensee should demonstrate tnat all applicable requirements of I&E Bulletin 79-02 are satisfied.

It is the opinion of the author that while the discrepancies noted above do not, individually, constitute immediate safety issues, a sufficient number and relationship exist so as to question whether all aspects of the as-built versus as-analyzed correlation have been j satisfied. It would appear to be in the best interest of all parties if complete information could be supplied es soon as possible so that all assessments could be completed and any open questions regarding the items addressed in this report could be resolved. .

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5. REFERENCES
1. M. E. Nitzel, " Summary of the Oyster Creek Unit 1 Piping Calculations Performed for the Systematic Evaluation Program" EG&G Idaho, In:,,

EGG-EA-5211, July 1980.

2. R. C. Murray, T. A. Nelson, S. M. Ma, J. D. Stevenson; " Seismic Review of the Oyster Creek ku lear Power Plant as Part of the Systematic evaluation Program;" Lawrence Livermore National Laboratory Report; NUREG/CR-1981; April 1981.
3. J. N. Donohew, USNRC, " April 24, 1986, Meeting With GPU Nuclear Corporation (GPUN) To Discuss the Graft Technical Evaluation Report (TER) For Integrated Plant Safety Assessment Repor';, Section 4.11, Seismic Design Considerati r.s," Memo to docket 50-219, May 19, 1986.
4. B. F. Saffel, Jr. ltr to J. E. Solecki, Supplement to EGG-EA-5211 Report Concerning Oyster Creek CRD Returr. Line Piping Stress Results (A6426) - Saff-315-82, August 13, 1982.
5. P. B. Fiedler ltr to D. M. Crutchfield; Oyster Creek Nuclear Generating Station--Docket No. 50-219--SEP Topic III-6, Seismic Design Considerations; January 20, 1983.
6. P. B. Fiedler ltr to D. M. Crutchfield; Oyster Creek Nuclear Generating Station (OCNGS), Docket No. 50-219, SEP Topic No. III-6, Seismic Design Considerations; March 13, 1984.
7. Teledyne Summary Report, TR-3501-2, " Generic Response to USNRC I&E Bulletin Number 79-02 Base Plate / Concrete Expansion Anchor Bolts,"

August 30, 1979.

E. American Society of Mechanical Engineers, ASME Boiler and pressure Vessel Code,Section III, Division 1, " Nuclear Power Plant ,

Components," Subsection NF, 1983 Edition.

48

9. MPR Associates, Inc. report for GPU Nuclear, "0yster Creek Nuclear Generating Station Seismic Reanalysis of Liquid Poison System Piping," Report No. MPR-780, December 1983.
10. MPR Associates, Inc. reoort for GPU Nuclear, "0yster Creek Nuclear Generating Station Seismic Reanalysis of Core Spray System Piping,"

Report No. MPR-777, September 1983.

11. MPR Associates, Inc. Report for GPU Nuclear, " Seismic Reanalysis of Main Steam and Feedwater Piping Supports Inside Containment," Report 4 No. MPR-802, Rev. 1, September 1984.

1 1

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49

)

N Appendix A Notes From MNCR Review t

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4 APPENDIX A MNCR Review Notes Revision 1 4

The following notes pertain to the reverification of the Oyster Creek SEP Piping Analyses. This was done to reconcile differences between the actual as-built configurations and the information provided for use when the analyses were originally performed (Spring, 1980). This effort was required because of the findings of a USNRC Region I inspection (No. 85-14) conducted during May, 1985.

311ght organizational changes have been made to the original notes in this revision. Also, additional MNCRs were subsequently provided by the licensee. This additional information applied to the feedwater, main steam, core spray (north and south loops), and liquid poison piping systems.

1.0 FEED WATER SYSTEM 1.1 pioe Support Discrepancies i

1. MNCR-85-112-1 describes differences in snubber installations for support X-48-SS-1. In tne original SEP analysis three restraints l designated RF-HR1, RF-HR2 and RF-HR3 were shown (dwg. JCP-19443, sht. 2, Rev. 1) at this location. Support X-4B-SS-1' consists of two snubbers which provide vertical and horizontal (N-S) -l restraint. The original three supports were arranged to provide restraint in all three global directions. Location is the same as the SEP analysis. Differences in restraint directions may affect results.

Al l

I i

2. 'MNCR 85-112-2: Support RF-R2A. Minor snubber / extension discrepancies - no effect of MNCR data on piping analysis.
3. MNCR 85-112-3: Support RF-R3A. Minor dimensional and weld l

discrepancies - no effect on piping analysis.  ;

NOTE : It has been observed that'some pipe attachments have been noted as inaccessible and, thus, were not inspected. 1 IEB 79-14 requires insulation to be removed to inspect all such attachments.

4. MNCR 85-112-4: Support RF-R1A. Snubber reversed.and weld discrepancies. MNCR disposition says incomplete weld on bracket stanchion is acceptable, but the load used is not listed. The support load is not shown on the support drawing. No effect on piping model assuming support is adequate.
5. MNCR 85-112-5: Support RF-R-H9. Minor weld and dimensional-discrepancies. No effect on piping analysis.
6. MNCR 85-112-6: Support RF-R-H8. Configuration and dimensional i discrepancies. No effect on piping analysis.
7. MNCR 95-112-7: Support RF-R-H7. Brace members installed upside-l down. No effect on piping analysis. MNCR disposition notes that:

a loose nut should be tightened; however, no loose. nut is noted on the marked-up support drawing.

l -l

8. MNCR 85-212-2: Supported valve is not identified. Appears to be _

l on north loop (see loc. plan & dwg. (GE) 2109-5) which does.not apply to SEP model.

9. MNCR 85-212-1: Supported valve is not identified. Appears to be l

valve in south loop between drywell and piping anchor.

Spring hanger (RF-R-H12, B&P dwg. 802) is not included in SEP L

A2 l

i l

analysis. Spring would not affect seismic analyses. Spring would affect weight stresses; however weight stresses are only approximately 7 ksi in area of valve. No significant impact on analysis.

NOTE: Only two (2) MNCR's dealing with the feedwater system were

, included in the 3-19-86 submittal. This information did not address any of the comments made regarding the feedwater system in the 2/86 revision of the Summary Assessment.

1.2 Geometric Discrepancies (MNCR 85-112-8)

1. The MNCR 85-112-8 description states that only a partial walkdown was performed due to accessibility. IEB 79-14 required complete inspection except as justified on a case by case basis described in IEC 79-14 Supplement 2. Any discrepancies in the uninspected piping could affect the analysis.
2. Support RF-RIA was found to be mislocated by approximately three feet. Since this is an axial snubber, no significant effect should be seen in the piping analysis.
3. Support RF-R-H9 (spring hanger) as built location is approximately 18 in. away from the location used in the SEP piping model. Since this is a weight support, no effect will be seen in the seismic results. Some change would be expected in the weight and thermal results; however, it is expected that these changes would be minor and have no significant effect on ASME Code acceptability.

1 4 The location of support RF-R-H7 (spring hanger) shown on drawing I JCP-19443 (sheet 2) is about 7 ft different from the location used in the origiral SEP analysis. Since this is a spring hanger on a vertical pipe run the analysis results should not be l A3

I k affected.

The length of the East leg (10 in, pipe) of the feedwater piping 5.

is different than that used in the original SEP analysis.

! Original information indicated that the total length of the 4

diagonal run (45 degrees H, 45 degrees V) was 20.5 ft while the latest information lists this length as 15.25.ft. This discrepancy could affect the calculated dynamic response and, j' thus, the seismic stress levels.

6. Another discrepancy contained in the marked-up copy of Drawing JCP-19443, Sheet 2, concerns both legs of the 10-in.

I piping. The Drawing shows both reactor vessel nozzles.at an elevation of 74 ft 11 in, and both diagonal runs (45 degrees H, 45 degrees V) with total lengths of 15 ft 0 in, and 15 ft 3 in.

The vertical runs of the 10-in. lines are noted to be 16 ft-0 in, and 13 ft 0 in. Thus it appears that the latest walkdown_information is still inaccurate. This apparent '

discrepancy in lengths and/or elevations should be resolved so an assessment of the impact on the analysis can be made.

I 2.0 MAIN STEAM SYSTEM i

I 1

2.1 Pipe Support Discrepancies i l

i j 1. MNCR 85-110-1: Support X-28-SS-1. Minor dimensional and l configuration discrepancies. No effect on piping analysis, i

2. MNCR 85-110-2: Incorrect penetration marking.

NOTE: This MNCR states that the inspection was performad for only a portion of the line. .

NOTE: No marked-up ISO was sent for this-line.

.. A4

m. ___.____
3. MNCR 85-110-3: Support MSH-7. Minor configuration discrepancies on spring hanger. No effect on piping analysis.
4. MNCR 85-110-6: Support MS-R5A. Minor configuration discrepancies on snubber installation. No effect on piping analysis.
5. MNCR 85-110-9: Support X-2A-SS-1 (S13) dimensional discrepancies - will not affect piping analysis.

1 NOTE: MNCR 85-110-2 reviewed in 7/86 stated that penetration marking was wrong. Penetration for main steam south loop is X-2A with Azimuth 1710 .

6. MNCR 85-110-11: Support X-2A-SS-1 (Snubber S14) dimensional i discrepancies - will not affect piping analysis MNCR 85-110-12: Applies to north loop.

7.

8. MNCR 85-110-13: Applies to north loop.
9. MNCR 85-110-14: Applied to north loop.
10. MNCR 85-110-15: Support MS-R3A. Several changes in support configuration. Snubber anchored so as to produce torsion on 6WF15.5 beams. Support may not have stiffness originally assumed. Support analysis should be checked. Decreased support stiffness may affect seismic results.
11. MNCR 85-110-16: Support MS-R2A (snubber). Dimensional changes l

an base plate. No affect on piping analyses.

12. MNCR 85-110-17: Applies to north loop, i
A5 i
13. MNCR 85-110-19: Support MSH-5. Discrepancies on support drawing. No affect on piping analysis.
14. MNCR 85-110-20: Support MSH-6. Weld discrepancies on support.

Will not affect piping analysis.

15. MNCR 85-110-21: Applies to north loop.
16. MNCR 85-110-22: Applies to north loop.
17. MNCR 85-110-23: Support MS-R4A. Welding and dimensional discrepancies. No effect on piping analysis.
18. MNCR 85-110-24: Support MS-RIA. Configuration discrepancies on support. It is note.d that another snubber (for clean-up domin.

sys.) is also attached to the beam of this support. It should be verified that all loads are accounted for in the support analysis.

NOTE: Also reviewed MNCR's 85-211-1 to -13 on main steam vent line. MNCR's 85-211-8, 7, 9 had snubbers attached to spring cans. Altbough this part of the M.S. vent line is not included in the SEP piping mode, the piping analysis for this line should be reviewed to be certain that the supports mentioned above are properly modeled and results are correct.

2.1 Geometric Discrepancies

1. The nature and extent of geometric discrepancies is not known.  ;

As noted in MNCR E~-110-2 only a portion of the line was l reinspected. No marked-up piping isometric was furnished. .)

2. MNCR 85-110-18: Dwg. 19442, Sht. 2, Rev. 2 (S. M.S. loop geo.

discrepancies). Dimensional discrepancies on drawing. Drawing A6 1

1

l attached to MNCR'is cut and portions are missing. Also, some dimensions, etc. are unreadaole. Assessment cannot be made j

without complete and readable marked up drawing.

!~

i 3.0 ISO. CONDENSER SYSTEM (WATER FILLED "A" LOOP) 4 3.1 Pipe Support Discrepancies COMMENT : GPUN should clarify whether-the Bergen-Patterson or General Physics support designations are being used on the.MNCRs.

1. MNCR 85-095-15: Support NE-2-S10.(G.P.). Configuration

} discrepancies - no effect on piping analysis.

i l 2. MNCR 85-095-16: Support NE-2-S9 (G.P.). Snubber location i discrepancy and minor configuration discrepancies. This is an -

1 l'

axial snubber. No effect will be evident on the piping analysis. -

J

3. MNCR 85-095-17: Support NE-2-S8 (G.P.). Concrete anchor discrepancies - no effect on piping analysis assuming recommended support repair is performed..

j 4. MNCR 85-095-18: Support NE-2-S14.(G.P.). Minor. dimensional j discrepancies - no effect on piping analysis.

1

5. MNCR 85-095-19: Support NE-2-H10 (G.P.). Configuration discrepancies on spring hanger - no effect on piping analysis.

i :i

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6. MNCR 85-095-20: Support NE-2-S12.(G.P.). Configuration i discrepancies on snubber installation - no effect on piping analysis.
7. MNCR 85-095-21: Support NE-2-H9 (G.P.). Configuration I

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A7 I

s-discrepancies - no effect on' piping analysis. Holes in angle section are not addressed in MNCR. disposition - structural adequacy of the support could be affected.-

8. MNCR 85-095-22: Support NE-2-S13 (G.P.). Dimensional discrepancies - no effect on piping analysis.
9. MNCR 85-095-23: Support NE-2-H4 (G.P.). Weld and installation-discrepancies - no effect on piping analysis.
10. MNCR 85-095-25: Support NE-2-5. Various weld and dimensional I discrepancies on spring hanger - no effect on piping analysis.

2

11. MNCR 85-095-26
Support NE-2-H6 (G.P.). Configuration discrepancy on spring hanger - no effect on piping analysis.

!' 12. MNCR 85-095-27: Support NE-2-S11 (G.P.). Weld and structural.

I discrepancies on snubber installation - no effect on piping analysis. Structural adequacy of support should be verified.

13. MNCR 85-095-28: Support NE-2-H12 (G.P.). Weld and dimensional discrepancies on spring hanger - no effect on piping analysis.

Weld discrepancies

14. MNCR 85-095-29: Support NE-2-H14 (G.P.).

j and additional attachments. No effect will be seen in the piping analysis; however, the additional attachments to the i support steel should be verified for inclusion in the structural

analysis of the support.
15. MNCR 85-095-30: Support NE-2-516 and NE-2-S15 missing welds and incorrect weld sizes on snubber installations - no effect on 1

piping analysis. These snubbers are located very near a drywell

' penetration and it is questionable if there is enough piping movement to actuate the snubbers. Verification of this should I

be provided.

A8 l

y. m-.,,94 , , , m-_n---p.- _- + - - - - , - - . _w.---.__, . - - _ - _ - _ y .__q p-- 9 _%-.--

9 -e- p p

1 I

16. MNCR 85-095-31: Supports X-5B-MR-1 and X-58-MR-3 (B-P).

Snubbers not installed - apparently replaced by support NE-2-S16. No effect on SEP piping analysis since they were not originally included.

17. MNCR 85-095-32: Support NE-2-H11 (G.P.). Weld and dimensional discrepancies on spring hanger - no effect on SEP piping analysis. Support structural analysis could be affected.

3.2 Piping Geometry Discrepancies Described in MNCR 85-095-24

1. Support NE-2-H7 is listed as missing. Original SEP information indicated that this was a rigid support in the axial direction of the pipe. This discrepancy would affect the results of the SEP analysis.
2. The piping configuration of the North branch of line NE-2-8" is different from that used in the SEP analysis. The subject piping is now shown with an additional vertically sloping segment. This discrepancy could also be expected to influence the analytical results.
3. The vertical pipe run upstream from support NE-2-H4 is now shown to be 7 ft 8 in, whereas the initial SEP analysis information indicated 13 ft 2 in.
4. Numerous other dimensional changes are shown. These discrepancies range from several inches to over one foot.

NOTE : The original SEP analysis input was taken from Orawing JCP-19433, Sheet 4, Revision 2. This revision was A9 I

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, noted as " Field Verification for NRC ISE Sulletin 79-14." i The MNCR listed above (85-095-24) is based on Revision 3 of' the same drawing which is roted as a field verification as above. Upon comparison it can be seen that there were i several major dimensional changes. MNCR 85-095-24 notes.

!- additional discrepancies. Thus, this line has been

- inspected numerous times with numerous discrepancies noted. This situation should be addressed and the reliability of the information assured. .

4.0 150. CONDENSER SYSTEM (STEAM FILLED "A" LOOP) 1, 4.1 pipe Support Discrepancies i

5 MNCR 65-095-36: Support NE-5-3.

1. Weld and dimensional discrepancies on spring hanger installation - no effect on piping analysis. ,

I 2. MNCR 85-095-37: Support NE-5-3A. Weld and configuration discrepancies on spring hanger - no effect on piping analysis.. "

Support cales should be checked for the effect of these
discrepancies.

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3. MNCR 85-095-38: Support NE-5-H4 (G.P.). Weld and configuration i discrepancies on spring hanger installation - no effect on I

piping analysis. Support cales should be checked I

i i- 4. MNCR 85-095-39: Support NE-1-H1 (G.P.). Dimensional and configuration discrepancies on spring hanger installation - no effect on piping analysis. Support'calcs should be checked - i structural steel.

5. MNCR 85-095-40: Support NE-1-Si (G.P.). Dimensional and I structural discrepancies on snubber installation - no effect on j .

oiping analysis. Close proximity of unused anchor hole in A10 4

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concrete could have lowered the factor of safety of the existing I anchor bolts and violated the requirements of IEB 79-02.

j Support cales should be checked.

6. MNCR 85-095-43: Support NE-1-HS (G.P.). Dimensional and configuration discrepancies on spring hanger installation - no effect on piping analysis. -
7. MNCR 85-095-46: Support NE-1-S4 (G.P.). Weld discrepancies on snubber installation - no effect on piping analysis.
8. MNCR 85-095-48: Support NE-1-H4 (G.P.). Anchor bolt deficiencies on spring hanger installation - no effect on piping analysis. Support cales should be checked.
9. NNCR 85-095-49: Support NE-1-H7. Dimensional and configuration discrepancies on spring hanger installation - no effect on piping analysis, j
10. MNCR 85-095-50: Support NE-1-H3 (G.P.). Base plate and dimensional discrepancies on spring hinger installation - no effect on analysis of piping but support base plate calculations should be checked.
11. MNCR 85-095-53: Support NE-1-S3 (G.P.). Dimensional l

discrepancies on snubber installation - no effect on piping analysis.

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12. MNCR 85-095-54: Support NE-1-SS (G.P.). Weld and base plate '

discrepancies - snubber installation - no effect on piping l' analysis. Proximity of threaded insert hole to concrete anchor is not addressed in MNCR disposition. The effect of this on i bolt F.S. should be checked.

13. MNCR 85-095-58: Support NE-1-H2 (G.P.). Dimensional 4

All i

i discrepancies on snubber installation - no effect on piping analysis.

4.2 Geometric Discrepancies i

1. MNCR 85-095-55 contains the marked-up drawing resulting from the latest walkdown. Several dimensional discrepancies were noted.

Most of these were considered minor; however, the three most significant are listed below:

a. In the original analysis the North bound horizontal leg had a total length of 35 ft 9 in, while the latest information shows this total to be 32 ft 10 in.'
b. The marked-up drawing (JCP-19433, Sheet 2, Revision 3)-

shows an " extra support" about which no information is given.

c. The vertical riser total rise is now shown to be approximately 24 ft 6 in. This total rise was 21 ft 0 in. ,

in the original analysis.

5.0 Control Rod Drive The CRD pump discharge piping shown on drawing SK-F-M-0020, Rev. O was included in the SEP analyses. Numerous MNCRs were generated to describe the discrepancies found. All discrepancies were examined and judged not to impact the SEP piping analysis.

6.0 CORE SPRAY SYSTEM (North loop) 6.1 pipe Support Discrepancies A12

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1. MNCR 85-113-10: ' Support NZ-3-S3 (G.P.). Support configuration, weld, and bass plate discrepancies. Will not affect piping analysis. However, effect'of bolts (noted on drawing) does not appear to have been considered in detail. References to calculations or other sources used to disposition discrepancy should be provided..
3. MNCR 85-113-11: Support NZ-3-S4 (G.P.). Installation and weld discrepancies. No effect on piping analysis.
4. MNCR 85-113-12: Support X12B-SS-1 (B.P.). Weld discrepancies.

NOTE: This support does not appear to be included in the MPR piping model.

5. MNCR 85-113-13: Support NZ-3-H3 (G.P.). Weld and other ,

dimensional discrepancies - will not affect piping analysis.

d See also MNCR 85-113-15.

6. MNCR 85-113-14: Support NZ-3-H4 (G.P.). Weld and configuration' discrepancies - will not affect piping analysis.
7. MNCR 85-113-15: Support NZ-3-H3 (G.P.). Weld discrepancies on spring hanger attachment members further evaluation (see MNCR 85-113-13). Will not affect piping analysis (spring hanger). , , ]

I 6.2 Geometric Discrepancies

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1. MNCR 85-113-9: Geometry /confiCuration discrepancies.- Orawing 150 in MNCR is not complete. Cannot verify to computer model.

7.0 CORE SPRAY SYS. MNCR REVIEW (South loop) 7.1 pioe Suoport Discrepancies A13 .

1. Mh3 85-113-1: Support NZ-3-H9 (G.P.). Support weld anomalies. No effect on piping analysis.
2. MNCR 85-113-2: Support GP NE-3-59 (B.P.) (S. Loop).

NOTE: This support apparently-not included in MPR's analysis.

3. -MNCR 85-113-3: Support NZ-3-S8 (G.P.) (Bergen-Pat, h461-R2).

Dimensional discrepancies - no effect on piping analysis.

4. MNCR 85-113-4: Support NZ-3-H8 (G.P.). Configuration changes -

will not affect piping analysis.

5. MNCR 85-113-5: Support NZ-3-H7 (G.P.). Configuration discrepancies - will not affect piping analysis.
6. MNCR 85-113-6: Support NZ-3-H10 (G.P.). Base plate dimensional changes - no effect on piping analysis.
7. MNCR 85-113-7: Support NZ-3-S7 (G.P.). Dimensional discrepancy

- no effect on piping analysis.

NOTE: MNCR states that snubber is taggea NZ-3-S9.

7.2 Geometric Discrepancies

1. MNCR 85-113-8: MNCR on piping geometry / configuration - states 4 that only discrepancy is in location of spring support NZ-3-H8.

NOTE: That the sketch contained in this MNCR does not show sufficient detail to. permit verification of computer modeling. Appears to be possible discrepancies in model geometry.

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8.0 LIQUID POISON PIPING OUTSIDE CTMT.

NOTE: All support numbers shown below are Bergen-Patterson' designations.

8.1 Containment - Explosive Valves (pump Discharge Line).

8.1.1 Pipe Support Discrepancies

1. MNCR 85-098-22: Support NP-2-H3. No ID/ scale plate on spring can. No effect on piping analysis.
2. MNCR 85-098-23: Support NP-2-H2. No ID/ scale plate. No effect on piping analysis
3. MNCR 85-098-3: Support NP-2-R7. Anchor bolt discrepancies, weld discrepancies and U-bolt size discrepancies. No probable effect on piping analysis. However, this s'upport attaches to several pipe lines. Total loading should be verified and the support adequacy confirmed for the total load.
4. MNCR 85-098-5: Support NP-2-R7A. U-bolt size discrepancies. ~

Will not affect piping analysis. However, support'should be verified to have adequate torque such that U-bolts are properly set. Drawing shows excessive bolt and thread projection.

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5. MNCR 85-098-6: Support NP-1-RS. Gang support for several lines. Added brace, weld discrepancies. No effect on piping analysis.
6. ' MNCR 85-098-12: Support NP-2-Rt. dureaft base plate crientation changed. No effect on piping analysis.

8.1.2 Geometric D'screoancies I

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1. MNCR 85-098-20: Dimensional discrepancies on containment -

explosive valves piping. One segment of piping is shorter.

Seismic stress should be reduced.

8.2 Explosive Valves - pumps (Pump Discharge Line) 8.2.1 pioe Supoort Discrepancies

1. MNCR 85-098-11: Support NP-1-R6A. Weld discrepancies. No effect on piping analysis.
2. MNCR 85-098-10: Support NP-1-R68. Weld and dimensional discrepancies. No effect on piping analysis.
3. MNCR 85-098-2: Support NP-2-R1. Weld and anchor bolt discrepancies. Drawing indicates support is to withstand lateral motion (N-S) but base plate is only 2 hole pattern in wrong direction. Support will not resist lateral load very well. Support drawing references drawing for NP-2-R2 which has an added brace. But brace and base plate details for NP-2-R1 are not shown.

NOTE: Walkdown forms were presented for support NP-2-RIA.

Results conformed to the drawing - no MNCR resulted.

4. MNCR 85-098-8: Support NP-2-R18. Weld discrepancies and excessive anchor bolt projection. Should check adequate torque for " setting" anchor bolt. No effect on piping analysis.
5. MNCR 85-098-1: Support NP-2-R2. Weld and configuration discrepancies. Lateral brace has been added. Base plate for lateral brace has highly unsymmetrical bolt pattern. Base plate -

and anchor bolt calcs should be verified.

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6. MNCR 85-098-9: Support Np-1-R6. Configuration discrepancies, excessive anchor bolt projection. Should verify anchor bolts

-set properly. No effect on piping analysis.

8.2.2 Geometric Discrepancies

1. MNCR 85-098-4: Marked up drawing-from field walkdown of subject' piping shows some dimensional. changes plus flanges and valves T

not shown-on the ISO's used for the analysis. This added mass coupled with the support discrepancies noted above for these systems will change th'e piping system response to seismic.

loading. Stresses will probably not be over the allowable limits; however, this,cannot be assured without reanalysis.

8.3 pump Suction Line 8.3.1 pipe Support Discrepancies i

1. MNCR 85-098-17: Support NP-1-H1A. Weld and configuration discrepancies, excessive anchor bolt projection. No effect on-l piping analysis.

i 2. MNCR 85-098-18: Support NP-1-H18. Weld and slight i configuration discrepancies. No effect on piping analysis.

3. MNCR 85-093-13: Support NP-1-H2. Added welds. Base plate orientation shown on drawing would not be effective to resist moments due to lateral seismic loads. Piping loads (SSE) are relatively small; however,'the adequacy of the support'should be verified. The licensee's conditional release assessment doesn't appear to adequately consider the base plate orientation.

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4. MNCR 35-098-15: Support NP-1-R10. Wela discrepancies and i

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excessive anchor bolt projection. Another case where support-base plate is oriented 900 from proper direction to resist.

majority of loads. No probable effect on piping analysis.

8.3.2 Geometric Discrepancies

1. MNCR 85-098-19: Piping system geometry discrepancies on pump suction line. Slight differences in apparent' configuration.

Stresses were low so adequacy of piping analysis will probably still be acceptable.

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