ML20214R829
| ML20214R829 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/28/1987 |
| From: | Charemagne Grimes NRC OFFICE OF SPECIAL PROJECTS |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8706090007 | |
| Download: ML20214R829 (17) | |
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May 28, 1987 1
4 Docket Nos. 50-445 and 50-446 i
Mr. William G. Counsil Executive Vice President Texas Utilities Electric Company i
400 North Olive Street, L.B. 81 l
Dallas, Texas 75201 j
Dear Mr. Counsil:
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SUBJECT:
ALLEGATIONS OF DESIGN AND CONSTRUCTION DEFICIENCIES t
J The staff has received allegations, from a confidential alleaer, as i
enclosed, pertainino to the Comanche Peak Steam Electric Station, Units 1 and 2.
We have presented the questions, after consultina with the alleaer's i
counsel, in an effort to protect the alleaer's confidentiality. You are requested to review the allegations and conduct appropriate inspections and/or evaluations as necessary.
Substantiated alleaations may warrant corrective actions. We request that you inform us, within 30 deys of receipt of this letter, of your initial assessment of these all ations and the actions you intend to take. We intend to inspect rei.ed activities and audit the records of
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your completed actions.
Please contact us should you have any questions reaardina this matter, j
Sincerely, j
(Original signed by)
Christopher 1. Grimes, Director Comanche Peak Project Division Office of Special Projects i
Enclosure:
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y May 28, 1987 Docket Nos. 50-445 and 50-446 Mr. William G. Counsil Executive Vice President Texas Utilities Electric Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201
Dear Mr. Counsil:
SUBJECT:
ALLEGATIONS OF DESIGN AND CONSTRUCTION DEFICIENCIES The staff has received alleaations, from a confidential allecer, as enclosed, pertainina to the Comanche Peak Steam Electric Station, Units 1 dnd 2.
We haVe presented the questions, after consultino with the allecer's counsel, in an effort to protect the alleaer's confidentiality.
You are requested to review the alleaations and conduct appropriate inspections and/or evaluations as necessary.
Substantiated alleaations may warrant corrective actions. We request that you inform us, within 30 days of receipt of this letter, of your initial assessment of these alleaations and the actions you intend to take. We intend to inspect related activities and audit the records of your completed actions.
Please contact us should you have any questions reoardina this matter.
Sincerely,
_L Christopher I. Grimes, Director Comanche Peak Project Division Office of Special Projects
Enclosure:
As stated cc: See next paae
o W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Electric Company Units 1 and 2 f
cc:
Thomas G. Dianan, Jr.
Asst. Director for Inspec. Proarams Ropes & Gray Comanche Peak Project Division 225 Franklin Street U.S. Nuclear Reaulatory Commission Boston, Massachusetts 02110 P. O. Box 1029 Granbury, Texas 76048 Robert A. Wooldridae, Esq.
Reaional Administrator, Reaion IV Worsham, Forsythe, Sampels &
U.S. Nuclear Reaulatory Commission Wooldridae 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlinaton, Texas 76011 Dallas, Texas 75201 Lanny A. Sinkin Mr. Homer C. Schmidt Christic Institute Director of Nuclear Services 1324 North Capitol Street Texas Utilities Electric Company Washinaton, D.C.
20002 Skyway Tower 400 North Olive Street, L.B. 81 Ms. Billie Pirner Garde Dallas, Texas 75201 Government Accountability Project Midwest Office Mr. Robert E. Ballard, Jr.
104 E. Wisconsin Avenue Director of Projects Appleton, WI 54915-8605 Gibbs and Hill, Inc.
11 Pen Plaza hew York, New York 10001 David R. Piaott, Esq.
Orrick, Herrinaton & Sutcliffe i
600 Montaomery Street Mr. R. S. Howard San Francisco, California 94111 i
Westinahouse Electric Corporation P. O. Box 355 Anthony Z. Roisman, Esq.
Pittsburah, Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Renea Hicks, Esq.
Washinaton, D.C. 20005 Assistant Attorney General Environmental Protection Division Robert Jablon P. O. Box 12548, Capitol Station Bonnie S. Blair Austin, Texas 78711 Spieael & McDiarmid i
1350 New York Avenue, NW Mrs. Juanita Ellis, President Washinaton, D.C. 20005-4798 Citizens Association for Sound Eneray 1426 South Polk Dallas, Texas 75224 Ms. Nancy H. Williams CYGNA 101 California Street, Suite 1000 San Francisco, California 94111
Texas Utilities Electric Company Comanche Peak Electric Station Units 1 and 2 cc:
Joseph F. Fulbricht Fulbright & Jaworski 1301 McKinney Street Houston, Texas 77010 Mr. John W. Beck Vice President Texas Utilities Electric Company Skyway Tower 400 N. Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Jack Reddina c/o Qatel Service Corp.
Texas Utilities Electric Company 7910 Woodmont Avenue, Ste. 208 Bethesda, Maryland 20814 William A. Burchette, Esq.
Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washinoton, D.C.
20007 James M. McGauchy GDS Associates, Inc.
2525 Cumberland Parkway Suite 450 Atlanta, Georaia-30339 Administrative Judae Peter Bloch U.S. Nuclear Reaulatory Commission Washinaton, D.C.
20555 Elizabeth B. Johnson Administrative Judae Oak Ridge National Laboratory i
P. O. Box X, Buildina 3500 Oak Ridae, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan Administrative Judae 881 West Outer Drive j
Oak Ridae, Tennessee 37830 4
ENCLOSURE a
LIST OF CONCERNS Item Description of Concern j
i 1
The documentation on the project has been described as l
" hopeless" and it is imperative that the calculations and drawings be totally reviewed, since the standard re-view process cannot reveal all the safety flaws.
2 The NPS design manual should be reviewed to determine whether the provisions for punching shear are acceptable and meet specification requirements.
3 The April and August 1985 versions of STRUDL were not being used correctly by the pipe support engineers.
Ex-1 amples are (1) slenderness ratio defaulted to K=1, un-less specified as some value which most analysts omit-ted, and (2) local effects (web crippling, effect of l
holes in structural tube steel, punching shear calculations, etc.) which cannot be obtained directly f rom STRUDL output were not being evaluated correctly (manual calculations).
l 4
There is a problem with f rame SB3-2 in Unit 2 concerning l
STRUDL, the design was analyzed without the STRUDL being i
checked.
There was a 24 inch discrepancy in a member a
length.
5 No training was given to engineers on PSDI STRUDL con-cerning Code check features, such as slenderness ratio.
This was significant, since there were more than thirty different items that had to be checked.
6 There was a lack of management concern for the require-ment to check and sign the STRUDL computer printout.
There were examples of situations where engineers were required to sign the outputs without having checked it.
7 Embedded plates were failing using the loads from the unchecked STRUDL, and also with the loads from the re-vised STRUDL. This concern is connected to the concern of the large frame SB3-2.
8 Until August 16, 1985, different pipe support groups applied different criteria to Richmond insert design.
The design consisting of Richmond inserts going through structural tubes is not a good design.
It is thought that this design concept has not been tested dynamic-ally.
Note: Acronym list is attached for reference.
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Page 2 Item Description of Concern 9
A designer was told to only use tension & shear for bolt interaction (for Richmond insert and bolt. [ rod] design) while other groups were also considering bolt bending.
When brought to the attention of the group supervisor, he indicated that the bolt design should be performed as directed (No specific design).
10 A DCA exists that allows the designer to use far higher allowables loads for Richmond inserts for emergency con-ditions than for normal condition (No specific DCA).
i 11 There is a concern that the boundary conditions between the Richmond insert and the concrete surface (i.e. fully or partially fixed) have not been satisfactorily estab-lished (No specific design).
12 Richmond insert testing currently being done is too lim-ited, since interactions on the Richmond insert rods may i
be as high as
.8.
Full scale testing on site should be performed or accurate experimental work done at various university laboratories, j
13 Alleger states that his real problem is not Richmond in-sert per se, but rather with their use in non standard connections like tube steel rather than baseplates.
14 A higher allowable load was used for Richmond inserts and the associated rods under emergency loadings during 1983 or 1984.
This approach is not correct and should-be investigated (No specific design).
15 A review of the calculations ~for Richmond inserts indi-cated that on numerous occasions the Richmond insert spacing was not properly considered while applying the allowable loads.
Since the spacing requirements for i
Richmond inserts is defined in the design specification, this indicates that the procedures were not being fol-i lowed (No specific design).
16 The allowable loads for Richmond Inserts and the associ-ated rods are dif ferent due to material and. testing con-siderations. However, the Richmond insert allowable was l
often incorrectly used for the rods (No specific design).
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Page 3 Item 6
Description of Concern 17 There is a question as to the validity of the use of the i
specified allowable loads for the spacing of adjacent Hilti bolts when the spacing is less than 10 bolt diame-ters.
This should be investigated (No specific de-sign).
18 There is a question as to the allowable load that should be used for the design of Hilti bolts when they are lo-l cated near equipment that vibrates.
If a higher factor of safety is to be used, the basis for this allowable load should be explained (No specific design).
19 There is a concern that a minimum size baseplate should l
be used on the CPSES proj ect.
Other proj ects have a 3/4" minimum plate thickness by specification.
There are some large structural frames at Comanche Peak that have baseplates as thin as 3/8", which can cause warpage j
in the baseplate due to welding (No specific design).
20 A question has been raised concerning the design /struc-tural adequacy of a support structure contained in a re-4 modification package of about 100 supports selected by the CPRT.
The sketch is shown as Exhibit No. 1.
i 21 There is a concern that different allowable pipe anchor deflections exists for the various pipe support groups.
One group uses.005" while another group uses.03" or 1/16 of an inch.
The allowable pipe anchor deflection should be governed by the appropriate procedures.
22 There is a concern that the frequency of the sketch shown in Exhibit 1 is inadequate, since the frequency is l
relatively low, only 7 or 8 Hz (in the unrestrained direction).
Also at one time there was a mandatory requirement that each support should have.a frequency of a least 20 Hz.
This was removed from the criteria when i
many supports were not meeting this requirement (refer to Item 20).
23 There is a concern that if supports did not meet the ap-2 propriate design criteria using the NPS design specifi-cation, the supports were sent to another pipe support design group, such as PSE, and would be considered-ac-ceptable using different design criteria.
This condi-i tion indicates that different design criteria was used in the various pipe support design groups (NPS, ITT-G and PSE). (Criteria may be different for Richmond Insert 2
loads).
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Page 4 Item Description of Concern 24 There is a concern that the value of the coef ficient of friction and the method for determining the normal con-dition load is different among the various pipe support design groups.
Again this indicates different groups using different criteria (See concern 23 above).
For example, the values of the friction coef ficient used on the proj ect varies between.3 and.45, where.3 is ap-plied to the normal load and.45 is applied to the upset load.
25 There is a concern that there never was a procedure for the design / analysis of washer plates in the PSE group.
Also NPS Class 1 supports have washer plates that are welded.
Since the design rules for Class 1, 2, 3 are the same, why do only Class 1 supports require welding, and not Class 2 or 3.
26 There is a concern that the stiffness of pipe support hardware (i.e.
clamps, bolts and pins, rear brackets, etc.) is not included in the pipe support stiffness when calculating the overall pipe support stiffness to be provided to Westinghouse for the Class 1 piping analy-sis.
27 When large structures are supported f rom the ceiling, the additional loading due to the y acceleration of the structure itself (i.e.
structural inertia effects) should be considered.
The most important consideration is the additional loadings on the baseplate and anchor bolts, which can be overlooked and which will therefore reduce the manufacturers specified maximum factor of safety.
28 There was at least two dif ferent criteria being used to determine the allowable stress for Plate and Shell type welds.
One pipe support group's design guideline stated that the allowable loads can be increased for emergency and faulted conditions, while another group's guidelines did not permit any increase in allowable stress for higher loading conditions.
These inconsistencies caused discrepancies between the engineer and checker.
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t Page 5 i
Item
! l Description of Concern i
29 For an unspecified pipe support, a weld length.was re-i quired by calculation to be 4 inches and this package was approved and sent to the permanent plant records vault.
Later, additional loads were added and this cal-culation was revised and a request was made to see if a weld of 6 inches could be made.
The field response was that the actual weld was only 3 inches rather than the original design of 4 inches.
The concern, then, is that the as-built documentation is not consistent with the design documentation.
30 The alleger stated that Mike Chamberlain said that he qualified many supports without taking the required minimum edge distance into consideration.
For example, a support baseplate that required a minimum edge dis-4 tance of 1-1/4 inches based on the bolt diameter, actu-ally had an edge distance much smaller than 1-1/4 inches.
The concern is that minimum edge distance on j
baseplates may not have been considered properly.
31 On some Unit 1 pipe support designs the loadings listed on the drawing were different than the loadings used in the design calculations.
This indicates that there was a lack of design control for the pipe support designs.
32 The allowable stress used for supports in the Contain-ment Building (no Unit #) used allowable stress values at 2000F rather than at 2850F as required by the pipe support procedures.
At least 15 examples of this condition were found by the alleger.
33 Exhibit #2 shows a weld symbol for both a two-sided and an all around weld.
The concern is that the joint was welded on two sides and not all around as specified in the pipe support calculation.
This should be investiga-ted from the standpoint of the as-built program.
I 34 In many pipe support calculations the engineers were not deducting the two inch non-structural concrete topping when they computed the embedment depth of the particular Hilti bolts.
This was required by procedure.
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-Item Description of Concern 35 At least three or four pipe support calculation packages were found where the additional forces and moments on baseplates caused by the weight of constant support han-gers were not considered.
This weight can sometimes be as high as 500 to 1000 pounds and can occur when the constant support hanger is welded to a structural frame.
36 When calculating the deflection of a cantilever support, the additional deflection due to the rotation of the baseplate has not been considered.
This calculation is important for all Classes of supports, since stiffness calculations were required for Class 1 supports, and Class 2&3 supports had a deflection criteria.
37 There is a concern that Gibbs & Hill procedure SS-30 is not adequate for determining the allowable loads on em-bedded plates, since it does not agree with finite ele-ment results.
An embedded plate might be approved by procedure SS-30, however, it would not be approved, if analyzed by a finite element model.
38 There is concern that the interaction formula for struc-tural tubing in the ASME Section III and AISC Codes con-sider tension and bending, but do not consider shear stresses.
Shear stress caused by torsion is not consi-dered in the interaction equations.- The AISI commentary by Prof. Sherman should be consulted and a determination made concerning the use of shear stress in the interac-tion equation.
39 There was concern that some engineers were told that they were not responsible for the original Class 5 and 6 supports designed by NPS (and possibly ITT Grinnell).
They were told that they were responsible only for the field changes to these designs.
However, visual inspec-tion of several designs would determine that the designs were unstable.
This situation was confusing and caused great concern.
40 There was a concern that acute weld calculations (skewed welds) were not being performed correctly by NPS.
No specific concerns were given.
Page 7 Item Description of Concern 41 There is a concern that an unstable support can result due to the lack of a resisting force, when a structural tube support design uses only 2 Richmond inserts and is subj ected to a torsional load.
The out-of-plane loads combine with the location of the two Richmond inserts to create a hinged condition making the support unstable.
42 The PSE guidelines for Unit 2 require a minimum size rigid strut for a certain pipe size; however, Unit 1 has no similar requirement.
The PSE guidelines for Unit 1 should be reviewed to explain why no similar requirement exists for Unit 1.
43 Similar to Concern 42 the design requirement for U-bolts are different from Unit 1 to Unit 2 (number of bolts, torque, etc.).
This should be investigated.
44 There is a concern that a supervisor would review fin-ished calculations and make changes to these calcula-tions without initialing them.
These comments, then, would not go through the checking process and could be opposite in conclusion from the original calculational results.
This practice violates the controls in the design process.
45 There is a concern that some of the hardware for Unit 1 support designs was not qualified in the calculation (i.e.
a comparison of applied load to manufacturer's maximum allowable load was not being performed).
46 There is a concern that some washer plates are not being used with the correct thickness (refer to Item #25).
Also, in many instances, washer plates were required for both sides of a particular design, however, the supports may not have always been installed with two washer plates.
47 The alleger thinks that embedded plates for Unit 2 were analyzed by Westinghouse considering all loadings from various pipe support and other groups.
The concern is how were the embedded plates addressed in Unit 1, and has the Westinghouse program been properly verified.
Also, was Westinghouse responsible for all of the embed-ded pla,tes, or just inside containment.
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Page 8 Item Description of Concern t
48 In September ^ 9 85 numerous bugs were found by GT STRUDL i
l personnel in the STRUDL version used by NPS in the Secaucus, New Jersey office.
The effect that these bugs had on supports previously designed by NPS may not have 1
been properly addressed.
One of the supports designed using this version of the STRUDL program was a large 21 pipe gang support in Unit 1.
IT is felt that this support was never designed and reviewed properly (i.e.
all required loading conditions were not considered).
i 49 There is a concern that the two bugs in the version of GT STRUDL used by NPS that were determined to have an impact on designed structures were not corrected, and, I
therefore, any problems resulting from the bugs were not corrected.
I 50 There is a concern that the correct value of slenderness
- ratio, K, when rigid struts are used connected to an-other structural member, such as a wide flange or structural tube (see Exhibit 2).
It is not sure whether the K-value was correctly considered.
I 51 There is a concern that, since the frequency of a long l
braced cantilever may be very low, a lateral accelera-l tion value of greater than 1-G should have been used.
A support in question was in the service intake structure I
and was part of a 100 support package submitted by John l
Finnerman for the ASLB hearings.
The status of this 4
support is not known, since it was taken from the alle-j ger and given to someone else (refer to Item 22).
)
52 There is a concern that a painting stamp was missing on a pipe support drawing and therefore the support may not have been painted as required.
53 Thermal movements were not shown on some Unit 1 draw-
{
ings where they should have been.
On Unit 2, PSE main-tained a computer program called HEDR which contained j
thermal movements and notes for all Unit 2 supports.
Also, the latest support loads used in the structural calculations were not on the drawing (refer to Item 31).
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This reflects on the quality of the design control used for pipe supports.
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Page 9 Item Description of_ Concern 54 There is a. concern that the latest revision of the sup-port drawing may not always be installed in the field.
When new loads were received, engineering was supposed to qualify the hardware.
During the exchange of in-formation with the field, it was determined that some of the information shown on the latest revision of the sup-port drawing had not been implemented in the field.
55 The interaction equations used for the design of bolts l
in Richmond inserts was not performed separate from the design of the inserts (the same as Item # 15).
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56 The Unit 1 pipe support drawings had the location plan i
in the lower right corner deleted f rom the drawing and placed on the accompanying BRHL once the revision 0 sup-a port was installed.
However, Unit 2 drawings had the location plan intact.
Why were these units treated dif-ferently?
i l
57 There is a concern that consistent design criteria be-l tween the different pipe support groups performing de-i sign calculations (PSE, NPS AND ITT-G) was not required I
j by TUGCO.
(Refer to Items 8, 21, 23, 24 and 28c.)
58 There is a concern about design criteria for Hilti bolt a
spacings less than 10 diameters.
A technical letter by i
John Finnerman did exist on this subject; however, the question is whether this letter has an adequate techni-cal basis (refer to Item 17).
Also, John Finnerman i
issued a memo or letter directing the use of a factor of i
safety of 4 rather than 5 for hilti bolts design for the feedwater system (why change requirements),
t 59 There is a concern that some design review calculations 4
were stamped with a phrase similar to " functionally de-sign review".
However, sometimes a certification stamp was incorrectly put on these drawings which was not cor-rect since the certification calculations had not been performed, s
60 There is a concern that structural angles used in the design of Class 5 & 6 supports may not have been analy-(
zed correctly, since they are asymmetrical sections and the calculation of their properties and principal axes is tedious.
This pertains to designs by NPS.
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Page 10 Item Description of Concern 61 There is a concern that pipe support design guidelines were changed by internal memo's issued by a group leader or supervisor and of ten their superiors were not on dis-tribution.
These design guidelines should have been controlled.
Also, different pipe support design groups were performing calculations in a different manner.
62 In August 1985, a gang support was incorrectly shown on a computer listing as supporting 3 pipes, when actually 4 supports were attached to the gang support.
A super-visor resisted making changes, therefore, the concern was management's lack of commitment to doing a thorough job.
63 No clear cut criteria for Class 5/6 supports existed.
The concern is that if these supports are not correctly designed, they might fail and damage safety-related equipment.
64 Supports should be designed to some minimum loads rather than performing analysis on actual loads.
65 There is a concern over welding performed by MPS in both shop and field with particular concern over minimum weld size violations.
The concern is that welds were underspecified on design drawings when compared to Table XVII-2452.1 of Appendix XVII, 1
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I List of Acronyms PSDI Programs for Structural Design Inc.
STRUDL Structural Design Language DCA Design Change Authorization CPSES Comanche Peak Steam Electric Station CPRT Comanche Peak Response Team NPS Nuclear Power Services PSE Pipe Support Engineering ITT-G ITT-Grinnell AISC American Institute of Steel Construction ASME American Society of Mechanical Engineers AISI American Iron and Steel Institute ASLB Atomic Safety and Licensing Board BRHL Brown & Root Hanger Location TUGCO Texas Utilities Generating Company l