ML20215H933

Provides Info Re Insp Status of 1982 Mods to Idvp & Data Re Raceway Bolts,Per D Kirsh 831130 Request

ML20215H933
Person / Time
Site:	Diablo Canyon, 05000000
Issue date:	12/05/1983
From:	Wade R EG&G, INC.
To:	Kirsh D NRC
Shared Package
ML20213D283	List: ML20213D281 ML20213D547 ML20215H890 ML20215H903 ML20215H922 ML20215H933 ML20215H937 ML20215H969 ML20215H984 ML20215H991 ML20215H997
References
CON-FIN-B-8552, FOIA-84-21 NUDOCS 8705070155
Download: ML20215H933 (11)

Text

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_(

h EGcG ENERGYMEASUREMENTS GROUP San Ramon Operations 28o1 OLD CROW CANYON ROAD. SAN RAMON.CA

• TEL(4151837-5381

• MAIL: BOX 2o4. SAN RAMON. CA 94583 In reply please refer to: WOW: 84-06 5 December 1983 e

. Mr. Dennis Kirsh U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Subject:

INSPECTION ST TUS REPORT

Reference:

Memo; D. Kirsh to W. Wade dated 30 November 1983 provides the information requested in the reference memo.

This report tabulates the information by category with the exception of concrete expansion - anchor bolt data which is not available.

Anchor bolts were inspected against the appropriate Foley or Pullman specifica-tions (QCP9, QCPE9, and ESD 223) when they were used for the installation.

Aside from population data, the information was derived from records main-tained for the inspections conducted under FIN B-8552.

The inspections were conducted between July and November 1983 and some are incomplete.

As a consequen.ce, a description of the discrepancy. and an assessment of the significance is provided only for completed inspections. illustrates the information stored 'in the data file for this The computer was asked to list all completed inspection items project.

having a discrepancy for which a quality assurance (QA) report and/or a has been initiated.

Incomplete inspection items for which QA citation repor.ts have been initiated were also added since these reports provide the. descriptive information needed to assess significance.

If further explanation or additional information is required please contact me at my office in San Ramon.

W. O. WADE MECHANICAL ENGINEERING DEPARTMENT WOW: cog Distribution:

LLNL EG&G /SRO TaTumi ngs R. Pong M. Eli A. Debeling R. Bogdanowicz C. Morton l

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1 PART START COM*LETE STATUS MA4 LOC i

ITEM NUMBER DATE DATE CRIT CONTACTS AFF STATUS DATE INSF HR$

401 KD6 1 RACEWAY SUPPORT 14/CSR-127-!a80 7/13/83 10/19/83 GCP 3 OCP 5A QCP 9 GCP E9 W TEROLA E CAMPBELL F0 M0itRISDN PS PHYSICAL 9/23/83 MWE 8.0 WR-E2625 9/23/83 ACCEPTED 10/19/83 ME

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8. 0 AUI RD6 1 RACENAY SUPPORT 9/K-140-4-140 8/05/83 10/15/83 GCP 3 OCP 5A, DCP 9 GCP E9 MONTER0LA E CAMPRELL FD MORRISON PS PHYSICE 9/15/53 MWE 5.0 WR-E2653 9/15/53 ACC-M/O-GA 10/15/83 NE 7.0 AUI BLD6 1 RACEWAY SUPPORT 9/K-140-4-136 8/05/83 10/15/83 GCP 3 BCP 5A QCP 9 GCP E9 MONTER0LA E CAMPBELL FD MORRISON P6 PHYSIC E 9/15/83 WE 5.0 WR-E2653 9/15/83 ACC-W/0-GA 10/15/53 ME 8.0 CONTAINMENT

• 1 RACEWAY SUPPORT 246-140-8-E3008 10/15/83 OCP 3 GCP 5A GCP 9 GCP E9 MORRISON P6 CAMPBELL F0 PHYSICAL 10/20/83 NE 5.0 WR-E-2698 10/20/83 CCHTAINMENT 1RACEWAYSUPPORT10/F-144-5-965 10/15/83 GCP 3 GCP 5A OCP 9 BCP E9 MORRIS 0N P6 CAMPBELL F0 PHYSIC R 10/20/83 MWE 5.0 WR-E-2699 10/20/53 PENETRAT KD6 1 RACEWAY SUPPORT 146E6Mll51313 10/18/83 10/31/83 BCP 3 BCP 5A GCP 9 QCP E9 MORRIS 0N P6 CAMPBELL F0 PHYSICE 10/20/B3 ME

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OCP 9 GCP E9 MORRISON P6 MELLO F0 RECORDS 10/26/83 RM8 1.0 PHYSICAL 10/26/83 MR-E-2711 10/26/83 ACC-M/O-GA 11/0!/83 RM8 1.0 TC.flNE EDS - 1 RACEWAY SUPPORT 50/A-107-7-88 10/27/83 !!/02/83 GCP 3 OCP 5A DCP 9 GCP E9 MORRISON PS MELLO F0 RECORDS 10/27/63 RM8 1.0 PHYSICAL 10/27/83 MVR-E-2713 10/27/83 ACC-M/O-GA 11/02/83 RM8 1.0 TUR8INE BLD6 1 KACEMAY SUPPORT 50/A-119-2-15 10/27/83 11/02/83 GCP 3 GCP 5A OCP 9 BCP E9 MORRISDN P6 MELLO TO RECORDS 10/27/83 RM8

'!.0 PHYSICAL 10/27/83 MR-E-2714 10/27/83 ACC-M/O-GA 11/02/83 RMB 1.0

' AUI K D6 i RACEWAY SUPPORT CSR-127-4-56 11/08/63 11/17/03 GCP E9 CARP 8 ELL FO MORRISON P6 MVR-E-2729 11/17/83 RP.

3.0 CONTAllstENT 1 RACEWAY SUPPORT H-85-1-42

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CONTAINMENT 1PIPEHAASER 12-196SL 7/07/83 10/12/83 ES3 223 TIKLE P6 6AUDIUSO P6 RECORDS 9/02/83 MNE 8.0 MYR-M-4542 9/02/83 MWE 6.0 329 /see,next N )

ACCEPTED 10/12/83 s

- 7 N/A 1 PIPE HAN6ER 44-9V 7/11/83 7/11/83 ESS 223 HOWELL BE T!*LE P6 CITATION 7/11/83 A69 1.0 RP 1.0 f N/A 1 PIPE HAN6ER 22-396SL 7/13/83 7/13/83 ESD 223 TINKLE P6 HOWELL 3E DR-5194 7/13/83 A6D 2.0 RP 1.0 5 A'l! KD6 1 P!PE HANGER 555-172R 7/19/83 9/02/83 ESD 223 TINKLE P6 6!ACOLON! BE 6AUDIUSO P6 PHYSICAL 8/20/83 WELD 8/20/83 MWE 5.0 i

i MR-M4511 8/20/83 MWE 1.0 d

ACCEPTED T/02/83-7 CONTAllelENT 1P!PEHAN6ER 57N-38R 7/20/83 9/02/83 ESC 223 6AUDIUSS P6 11WLE P6 HOWELL BE WELD 8/20/83flWE 5.0 RECORDS 8/20/03 MVR-M4511 B/20/83 ACCEPTED 9/02/83 MWE 1.0 6 CONTAlleIENT 1 PIPE HAN6ET 57N-28V 7/20/83 9/02/83 ESD 223 TINKLE P6 61ACOLOW1 BE 6AUDIUSS P6 WELD 8/20/83 MWE 5.0 NVR-M4511 8/20/83

!~10:38 (see vwxt pap)

ACCEPTED 9/02/83 MNE

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1 PIPE HANGER 73-39R 8/09/63-4/15/83 ESL 223 TIKLE PG 8ADICO P6 DOLE P6 ItVR M-4533 9/15/83 R65 1.0 CHM, 1.0 0

1 PIPE HAN6ER 92-103R 8/17/83 9/15/83 ESD 223 T!*LE P6 i

6ADICO PS DOLE P6 DR 5144 9/15/83 EWR 1.0 CHM 3.0

,1 N/A I PIPE NAN 8ER 22-5478L 8/24/83 8/24/83 ESS 223 TI KLE P6 LORTIE SE WR 4542 8/24/83 A60 1.0

0 1 WAC SUPPORT SKC-W570 8/ll/83 9/20/83 9CP 40 SER6STEST FO O'CONNOR PS 1R8827-71 9/20/83 RSS 1.0 CNM 3.0

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1 HVAC SUPPORT SIC-HV!67 8/11/63 GCP 40 NOVACK CARLSON FO BEF.551ELT Ft IR8827-73 9/20/33 R65 1.0 CHM

2. 0 CONTAINMENT I ANNULUS 6181-Cl-13-610 7/14/83 QCP 3 QCP 5A QCP C7 QCP 9 KOHLER E

KITCHEN PE BER6 FB PHYSICAL 9/15/83 CA 9/15/83 l

NCR5422272 9/15/83 ME 5.0 N/A 1 SWITCH GEAR 6422-T1-13-871 8/25/83 8/31/83 GCP 3 PALARMO PS NCR 8/31/83 A60 1.0 5422-255 8/31/93 N/A 1 SWITCH 6 EAR 6422-T!-13-874 8/25/83 8/31/83 GCP 3 PALARM0 PE NCR 8/31/83 A6D 1.0 5422-246 8/31/93 FUEL-HANDLING

.1 FUEL HANDLING 6160-F1-13-026-016 9/22/83 10/20/83 QCP 3 GCP 5A -

CCP C7 KOHLER E

TINGLEY FB CANNING FE MUNRO E WELD 10/14/83 M E 3.0 NCR-8833 10/14/83 ACC-W/O-GA 10/20/83 M E 2.0 FUEL Hi.NDLING 1 FUEL HANDLINS 6180-F1-13-026-116 9/22/83 10/20/83 CCP 3 SCP 5A QCP C7 KOHLER E

TINSLEY FB CANNING F9 MUNRO E WELD 10/14/83 ME 3.0 NCR-8833 ACC-W/D-GA 10/20/83 ME 2.0 TURE!NE BLD6 1 TURBlNE PLE6 6424-TI-13-794

!!/01/83 CCP 3 GCP 5A QCP C7 GCP 9 KOHLER E

HARRISON E BERS F3 MARTINSON FB KIRSCH NR WELD 11/01/83 M E 16.0 WCR 11/03/83 RMB 5422-332 11/03/83 NCR 11/03/83 5422-333 11/03/83 NCR 11/03/83 5422-341 11/03/83 NCR 11/10/83 ME 10.0 5422-351

!!/10/83 CliAT1DN

!!/10/83 ME 10.0 5 AU1 BLt6' 1 P!FE FANGER 855-66R 7/07/83 9/15/83 ESD 223 TINrLE P6 Snt1H BE 6AU;1U53 P6 PHTSICAL 9/02/83 r=

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9/07/83

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- (v UNITc0 STATES J?..* *

.i NUCLEAR REGULATORY COMMISSION g/k C/P

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Reason v lg

,,,,,/g 1990 N. CALIF 0HNIA 000LEVAllD

• .we Sulf f 202, WALNUT CHEEK PLA2A WALNUT CRCEN, CAltrOMNIA 94504 June 1. 1979

-Docket Nos.'50-275 50-323 Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Attention: Mr. Philip A. Crane, Jr.

Assistant General Counsel Gentlemen:

Subject:

NRC Inspection at Diablo Canyon Units 1 and 2 T. W. Hutson of this office on April 30 - May 3,1979 of authorized by NRC Construction Permit Nos. CPPR-39 and CPPR-69, and t the discussion of our findings held by Mr. Kirsch with members of your staff at the conclusion of the inspection.

Areas examined during this inspection are described in the enclosed i

inspection report.

Within these areas, the inspection consisted of selective examinations of procedures and representative records, in-tarviews with personnel, and observations by the inspectors.

activities were not conducted in full compliance with NR as ' set forth in the Notice of Violation, enclosed herewith as Appendix A These items of noncompliance have been categorized into a level as de-scribed in our correspondence to all-NRC licensees dated December 31, 1974.

of the NRC's " Rules of Practice," Part 2. Yitle 10, Code Regulations. 'Section 2.201 requires you to submit to this office within thirty (30) days of your receipt of this notice, a written statorent or explanation in reply incMHng (1) corrective stops which have been taken by you and the results achieved; I

which will be taken to avoid further violations; a(nd (3) the date when

2) corrective steps full compliance will be achieved.

1 i

specific items of noncompliance, please include a dis

\\,

e actions you have or plan to take to

• separate ahd/or preclude the asso i

\\

on 18lo1 5uTQ gp Ai J

t

.;ific Gas and Electric Company June 1, 1979

.of non-safety related cables with redundant safety-related cables in order that "no single failure results in loss of the protection' function,"

in accordance with 10 CFR 50, Appendix A Criterion 21.

In accordance with Section 2.790 o'f the NRC's " Rules of Practice,"'

Part 2. Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application

~

to this office, within 30 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary.

The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.

If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions concerning this inspection, we will be glad to discuss them with you.

Sincerely, W'

G. S. Spencer, Chief Reactor Construction and Engineering Support Branch

Enclosures:

A. ' Notice of Violation 8.*

IE Inspection Report Nos. 50-275/79-12 50-323/79-07 cc w/o enclosure B:

W. A. Raymond, PG&E k'

J. D. Worthington, PG&E R.D.Ramsay,PG&E(AvilaBeach) f cc w/ enclosures R. D. Etzler, PG&E (Avila Beach)

J. 8. Hoch, PG&E O

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J' APPENDIX A l

Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Docket Nos. 50-275 and 50-323 Construction Permit Nos. CPPR-39 and CPPR-69 Notice of Violation I

i l

Based on the results of an NRC inspection conducted during the period of April 30 - May 3,1979, it appears that certain of your activities were not conducted in full compliance with conditions of Construction Permits-I Nos. CPPR-39 and CPPR-69 as indicated below.

A.

10 CFR 50, Appendix B, Criterion V, as" implemented by Section 17.1.5 of the FSAR and the PG&E Quality Assurance Manual Section V, states in part that, " Activities affecting quality shall be pre-scribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Paragraph 10 of Drawing 049237 Revision 4 (Piping and Mechanical.

Hanger and Snubber Supplementary Installation Instructions) specifies a maximum attachment weight of 25 pounds when a tubing support is attached to a large bore hanger.

Contrary to the above, a tu'bing support (2-FT-640) that weighed 28 pounds was attached to Unit 2 large bore support 49-12V.

This is an infraction applicable to Unit 2.

B.

10 CFR 50, Appendix B, Criterion V, as implemented by Section 17.1.5 of the FSAR and the PG&E Quality Assurance Manual Section V, states in part that " Activities affecting quality shall be...

accomplished in accordance with... instructions, procedures or drawings."

Foley procedure QCP-9 (Quality Control Pro'cedure for Installation of Raceways, Junction and Terminal Boxes for Wire Pull) Paragraph 4.2.5 (implementing PG&E Drawing 050029, conduit note 60) states that "Where non-class 1 conduit shares supports with more than one class 1 raceway, vital or protection channel, an intermediate class 1 support shall be provided."

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.cific Gas and Electric Company docket Nos. 50-275 and 50-323 APPEtt0!X A (Co,n ' t. )

Foley procedure QCP-9 further requires in Paragraph 4 l.8 050030, note 3) that where raceways (im-plementing PG3E Drawing than those identified as class 1. " cross a class 1 raceway,. other class 1 su a

section." pport shall be constructed on each side of the inter-Contrary to the above requirements, the following conditions were identified on May 1,1979 in the K-100 area of Unit 1:

1.

Non-vital conduits KHT-52 and 53 were both attached to support I

K-115-6-47 (a vital bus F support) and an unnumbered vital bus H support of detail number 397 without having an intermediate class I support provided.

2.

Non-vital conduits K-9424, K-9430 and X-9652 were installed above and crossing vital conduit without having a class 1 support provided on each side of the intersection.

I This is an infraction applicable to Unit 1.

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE of INSFECTIoN AND ENFoRCEMEhT 50-275/79-12 g,e go,50-323/79-07 50-275, 50-323

4cket No.

I.tcense No. CPPR-39, CpPR-69 safesvards croup Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 scility Name:

Diablo Canyon Units 1 and 2

.npaseton at:

Diablo Canyon Site, San Luis Obispo County, California asp:ction conducted:

April 30 - May 3, 1979

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D. F. KVsch, Reactor Inspector Date sisned u \\.1 M 9 T. W. Hutson, Reactor Inspector o cate staned

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cate Signed tprsved By:

k R. T. Dodds Chief. Engineering Section, Reactor Datfn sisned Construction and Engineering Support Branch

"'Y Inspection during period of April 30 - May 3,1979 (Report Nos.

50-275/79-12 and 50-323/79-07)

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of construction activities including:

licensee action on previous inspection findings; licensee action on IE Bulletins and Circulars; physical protection of safety-related equipment; allegations of improper raceway support installation; Unit 2 volume control tank 1

l overpressure corrective actions; NDE' examiner, QC inspector, and welder performance qualifications; welding materia 1 control; and steam generator preservice examination results.

The inspection involved 46 inspector-hours by two NRC inspectors.

Results: Of the eight areas inspected, no items of noncompliance or deviations were identified in six areas, one item of noncompliance was identified in each of the areas of pipe supports (infraction - tubing support installed on another support exceeded the maximum specified weight limit - Paragraph 4.a) and electrical raceway supports (infraction -

failure to install conduit as required by procedures and drawings -

Paragraph 7.b.(4)) and one unresolved item was identified in the ar g ( g g electrical raceway supports (Paragraph 7.b.(3))

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~ DETAILS 1.

Persons Contacted a.

Pacific Gas and Electric Company (PG&E)

M. R. Tressler, Assistant Superintendent - General Construction

' R. D. Etzler, Project Superintendent i

• M. N.-Norem, Startup Engineer

• 0. A. Rockwell, Resident Electrical Engineer i

• V.' L. K111 pack, Resident Mechanical Engineer

• R. K. Rhodes, Instrumentation Supervisor

• M. E. Leppke, QA Supervisor i

• S. J. Foat QC Engineer J. R. Bratton, QC Engineer W. Manegold, Hanger Engineer C. Braff, Pipe Support Supervisor F. J. Cucco, Instrumentation Engineer i

0.- G. Crass Tubing Installation and Valve Maintenance Coordinator F. M. Russell, Acting Resident Civil Engineer V. Smart, Electrical Field Engin.eer R. Whited Electrical Field Engineer G. Hegli, QA Engineer R. Johnson, Civil Field Engineer

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b, Pullman-Kelloco (Xelloco)

O. Geske, QA/QC Manager R. A. Richardson, Receiving Inspector K. W. Melin, Rod Room QA Inspector t

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• Denotes those attending the exit interview.

l 2.

General

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j The licensee anticipates readiness for operating license issuance and fuel load for Unit 1 on or about' July 6,1979.

l 3.

Punch List k.

i The licensee's punch list of incomplete work contained 235 items at a

the time of inspection and efforts were underway to complete the

. work.

The licensee stated that, to assure readiness for licensing and j

fuel load, an instruction would be written detailing (a) individuals responsible for document reviews to assure completion of and/or j

identification of incomplete work, (b) documents required to be -

reviewed and (c) appropriate interface requirements necessary for ll General Construction. Operations Division, and Engineering.

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~2-Licensee Action on Previously Identified Followuo Items-a.

J0peO Unresolved Item - Unistrut Welded to Sucoort 49-12V 4323/P9-05-03) i During the inspection conducted on March 26-29,1979, the inspector noted that a section of unistrut associated with instrument tubing support 2-FT-640 was welded to the bottom of hanger 49-12V in Unit 2.

Paragraph 10 of Drawing 049237, j

Revision 4 (Piping and Mechanical Pipe Hanger and Snubber i

Supplementary Installation Instructions) gives three criteria for determining the. acceptability of attaching a tubing support to a large bore hanger..Those :cr.iteria specify a maximum 25 pound attachment weight.

Subsequent to installation i-and inspector identified concerns, calculations by PG&E showed that the weight of support 2-FT-640, attached to 49-12V, was 28 pounds. The tubing suppo.rt installation contractor, N. P. Foley, installs supports in accordance with Drawing 049238, Change 5, Instrument Tubing Supports.

This drawing did not contain the three acceptance: criteria in Paragraph 10 of Drawing 049237.

Drawing 049237'had not been issued to H. P. Foley. This appears contrary to'the requirements of 10 CFR 50 AppendfTB, Criterion V, 'which states in part that,

" Activities-affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished'in accordance t

with these instructions, procedures, 'or drawings."

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This is an apparent item of noncompliance.

b.

(0 pen) Isolation of Mutually Redundant Circuits (275/79-07-02)

L In order to determine if non-safety related wiring crossed protection set or vitality boundaries, the inspector examined j

the licensee's circuit schedule and a number of mechanical panels housing class 1 instruments in the Unit I containment

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and made the following observaticns.

l (1)

Comon non-vital heater circuits cross the following circuits with less than 5-ipch air separation.

i I

(a) Steam Generator 1-3 level circuits in protection set 1 (PNL46) and protection set 3 (PNL54): Heater circuit No. PJ7116 l

(b) Steam Generator 1-4 steam flow circuits in protection i

I set 1 (PNL47) and protection set 2 (PNLSI): Heater I

circuit No. PJ7107 i

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(c) Steam Generator 1-4 level circuits in protection set i

2 (PNL51) and protection set 4 (PNL59): Heater circuit No. PJ7107.

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(d) ~ P'ressurizer level' circuits in protection set 1 (PNL22), protection set 3 (PNL20) and protection set 2(PNL89): lleater circuit llo. PJ7104 '

.(e) Reactor Coolant System loop 1-2 flow circuits in protection set' 1 (PNL22),-protection set 3 (PNL20) and protection set 2 (PNL89): Heater circuit No.-

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. PJ7104 (f) Steam Generator 1-2 level circuits in-protection. set 1 (PNL45) and protection set 3 (PNL53): Heater

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circuit No. PN7114 i

(2)

In addition, wires at the heater and in panel 57 had been-removed from the heater element and were hanging free.

The wire ends had been taped with electrician tape and were visible inside the tape.

This item is open pending evaluation of additional information to be submitted by the ifcensee.

5.

Licensee Action on 8u11etins and CircularsBulletin 78-04 NAMCO Stem Mounted Limit Switches The inspector examined the Unit 1 installa. tion of five environ-mentally qualified NANCO Snaplock switches, EA 180 series, model No, EA-180-11302 on valves 8149A, 81498, 8149C, LCV 459 and LCY 460.

At present 14 of 18 switches in Unit I had been replaced with the exception of installation of the LOCA seal connections to the limit switches. The LOCA seals had been ordered from the Conax Company, Drawing No. 25K1915, Revision A, Part No. 02 and certified as meeting the applicable environmental qualifications.

The inspector has no further questions on this item.

6.

Physical Protection of Safety-Related Eauipment

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During a tour of the Auxiliary Seawater System (ASW) pump and gate operator area, located in the intake structure, it was observed that'a large screen wash water line was suspended above the Unit 1 and 2 ASW suction gate operating motofs. The line did not appear to be supported by seismically qualifted supports.

In addition, the redundant gate operators for each unit had no physical barriers installed.

The licensee noted that this-problem had been previously identified in Plant Design Comment No. 16.

The followup of this item has been remanded to the cognizance of the Resident Inspector, who was following the licensee's resolution of plant design co.nments.

In addition, this question was addressed to the Project Engineer wito stated that this observation would be examined and that licensee actions deemed necessary or already taken to assure adequate physical protection of safety-related equipment would be identified.

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A11ecations of leproper Raceway Support Installation 7,

Allegations as u'nderstood by the t!RC l

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A11egattuns of improper Unit 1 raceway support installations were received by the Resident Inspector who, in turn, referred them to the regional office for resolution., Specifically, the l

!l allegations were:

(1) Support No. K-115-4-100 had no side brace support to the wall; FE/Rl-2-249 had holes in unistrut welds; and FE/RJ-1-260 welds were not to detail.

(2) Support Hos. C-104-3-7 and 3-8 had 'a unistru't beam on

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j piece S-6 which was not to detail.

i (3) Support Nos. K-100-7-115 and 116 had concrete anchor bolts installed which were not separated from adjacent concrete anchor bolts by the required. distance.

(4) Conduit Nos. K-9424, 9430 and 9652 in K-100 area, run i

above vital conduit and did,not have class 1 supports installed.

I b.

NRC Construction Branch Findinos (1) The allegation was substantiated, however, support Nos.

i K-115-4-100, FE/FW-2-249 and FE/FW-1-260 had been pre-i viously identified by the licensee as discrepant and i

entered onto work package G-93:E-84 for repair by the PG&E cleanup crew.

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(2) The allegation was substantiated; however, examination

)

indicated that support Nos. C-104-3-7 and 3-8 were con-structed'in a manner which exceeded design detail require-i ments. The design details called for a P-3300 unistrut beam attached to piece 56. A P-1000 beam was attached to i

the 56 members for both supports. The P-1000 beam is a

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heavier, more substantial member than P-3300.

The allegation was substantiated. The inspector examined l

the concrete anchor bolt installations for supports r,-

100-7-115, 116 and about 100 other supports located in I

various areas of Unit 1.

In addition to the supports r

j identified by the alleger, it appeared that supports Nos.

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K-100-7-100, K-100'-7-755 and K-100-7-118 (in K-85 area of Unit 1) had anchor bolts which did not meet the specified anchor bolt spacing requirements of Foley procedure QCP-4 i

9.

All of the identified supports had been inspected and

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accepted by Foley in the conduct of the raceway support inspection / inventory program and none of the Support i

Inspection Work Sheets, for the above supports, identified j

anchor bolt spacings as a discrepancy.

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' 'Foley proceduce QCP-9 Paragraph 4b.l', requires

• that

" center-to-center anchor spacing shall not be less than 12 noninal. diameters of the largest anchor. bolt unless directed by PG&E design documents." The supports noted above utilized 1/2 inch diameter concrete anchor bolts which were spaced between 2-1/2 and 3 inches from adjacent anchor bolts.

The licensee's Resident Electrical Engineer believed that

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Foley had been provided with additional PG&E direction, based upon an inspection of all anchor bolt installations by Engineering Department in 1975 and the results of a PGat study performed to establish anchor bolt installation acceptance criteria. This~is an unresolved item pending examination of the additional PG&E directions supplied to the' contractor.

(275/79-12-01)

(4) The allegation was substantiated. An examination of numerous raceway and support inctallations on May 1,1979 in the K-100 area of Unit 1 identified the following discrepancies:

(a) Non-vital conduits K-9424. K-9430 and K-9652 were installed above and crossing vital conduits without having a class 1 support provided on each side of the intersection.

(b)

Non-vital conduits KHT-52 and 53 were both suspended from support K-115-6-47 (a vital bus F support) and an unnumbered vital bus H support of detail number 397, without having ah intermediate class 1 support provided.

Foley procedure QCP-9 (Quality Control Procedure for Installation of Raceways, Junctions and Terminal Boxes for Wire Pull), Paragraph 4.2.5 (implementing PG&E Drawing 050029, conduit note 60) states that "Where non-class I conduit shares supports with>more than one class 1 raceway, vital or protection channel, an intermediate class 1 support shall be provided."

Foley procedure QCP-9. Paragraph 4.1.8 (implementing PG&E 3rawing 050030, note 3 h tates that where raceways, other than those identified as class 1. " cross a class 1 raceway, a class I support shall be constructed on each side of the intersection."

This is an apparent item of noncompliance.

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' Unit 2 Volve Control Tank

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The hydrostatic test records, visual examination and liq'uid penetrant test records for the Unit 2 Volume Control Tank were reviewed by the inspector for compliance 'with the requirements of ASME Section XI, through Summer 1975 Addendum.

The visual and liquid penetrant examinations disclosed surface defects such as slag left on welds during fabrication, excessive weld reinforcement and a misalignment 1

of the shell to head which exceeded allowable code limits.

Non-conformance report DC2-79-QC-P0054 was written to document the

+

deficiencies noted and all data taken had been turned over to L

Westinghouse engineering for evaluation and disposition.

The resolution of this item will be followed through the normal review of HCR's'.

4' No items of noncempliance or deviations were identified.

9.

Nondestructive Examiner and OC Inspector Qualification I

The. inspector reviewed one Level II NDE examiner's qualifications and five Level II QC inspectors' qualifications for conformance to the requirements of SNT-TC1A, Kellogg Procedures ESD-235 (Non-destructive Examination Personnel Qualification and Certification Procedure) and ESD-237 (Quality Assurance Inspector Training Program).

.No' items of noncompliance or deviations were identified.

i

10. Weldina Material Coritrol I

The filler material withdrawal and issue operations and material storage in the Kellogg rod room were examined for compliance with i

Procedure ESD 202 (Weld Material Distribution and Control). The holding ovens were properly marked with the contents and the temperature gauges had been calibrated. All portable rod warmers had been checked for operation and temperature at'the required frequency. The rod room was clean and neat with all cans of moisture sensitive weld rod undamaged and hermetically sealed.

The rod withdrawal slips for May 2,1979 were randomly reviewed and appeared to be properly completed. The receiving inspection reports and certified material test reports foY the following heats of weld rod being issued were reviewed.

I J

Heat Number Rod Type and Size 07L150 E7018 -

3/16" l

412E-0271 E7018 -

5/32" 422E-1681 E7018 -

1/8" j'

29963 E308 1/8" 48116 ER308 -

3/32" i

j 482584 ER308 -

1/8" No items of noncompliance or deviations were noted.

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Wel de r f e,r,t;cy_rine_e Qua l i fi c a t i o n L

Ten weld /rs performing welding on May.2, 1979 were checked for

. proper qualifications using the welders qualification matrix issued for the period Hay 1 through May 31, 1979.

These ten welders l

appeared qualified by use of the matrix.

To verify the accuracy of the matrix. the inspector compared two welders performance qualifi-cation records'with the matrix.

The review showed that the limit of thickness.. stated for a specific welding procedure had been rounded up to. the nearest quarter inch over the 2T (T-thickness 'of test plate) limit required by Section IX of the ASME code.

For example, a 2T limit of 0.636 inches had been rounded up to 0.750 inches in numerous cases. The inspector also found that a procedure qualification record for a welder, symbol BR, was missing from his qualification folder.

This item is open and will be examined j

during a future inspection.

(275/79-12-03) i

12. Steam Generator Preservice Examination f

In the course of liquid penetrant preservice examinations, the licensee reported that indications of crazing were identified on l

the outer diameter of Unit 1 Steam Generators 1 and 2 cold leg ring dams. The indications appeared in the clad area at the edge of the 3

weld material and not in the weld material. Steam Generator 1 had an indication about 3/8 inches long and Steam Generator 2' had a number of large indications. The licensee was still in the process i

l of investigation to determine the exact nature and depth of the indications on Steam Generator 2.

Westinghouse Electric Corporation, the N$55 suppl *ier, had initiated a Field Discrepancy Report and submitted this to their Tampa office for resolution. Westinghouse personnel noted that all previous studies determined that the indications had never gone into base metal. This item will be examined further during a future in-spection.

(275/79-12-04) 13.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. One unresolved item was identified during this inspection and is discussed in Paragraph 7.b.(3).

]

14.

Exit Interview i

The inspectors met with lice 6s F representatives (denoted in Para-i graph 1) on May 3, 1979 and summarized the inspection purpose, scope and findings. The licensee was informed of those matters i

considered as items of noncompliance and unresolved.

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NC 'E AR REGULATORY COMMISSturr I

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REGION V

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SulTE 202.YJALNUT CREE K PLAZA V/ALNUT CnEEK.CALIFOHNIA 94596 g

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JUL'.6 979 Docket Nos. 50-275 50-323 Pacific Gas and Electric Company 77 Beale Struet San Francisco, California 94106 Attention: fir. Philip A. Crane Assistant General Counsel Gentlemen:

Subject:

HRC Inspection at Diablo Canyon Units 1 and 2 This refers to the inspection conducted 'by Messrs. D. F. Kirsch and T. W. Hutson of this office on June 4-7 and 20, 1979 of activities

. authorized by NRC Construction Permit Nos. CPPR-39 and CPPR-69, and

' to the discussions of our findings held with Mr. R. O, Etzler and Mr. J. R. Stevenson and other members of your staff at the conclusion of each inspection period.

Areas examined during this inspection are described in the enclosed inspection report. Within these. areas, the inspection consisted of sel.ective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

No items of noncompliance with NRC requirements were identified within the scope of this inspection.

In accordance with Section 2.790 of the NRC's " Rules of Practice,"

Part 2. Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public If this report contains any information that you believe Document Room.

to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information* be withheld from public disclosure.

The application must include a full stafdent of the reasons why it is e

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6 E79 Pacific Gas and Electric Company 2-e claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.

If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions concerning this inspection, we will be glad to discuss them with you.

Sincerely.

G. S. Spencer, Chief Reactor Construction and Engineering Support Branch

Enclosure:

. IE Inspection Report Nos. 50-275/79-13 and 50-323/79-08 cc w/o enclosure:

l W. A. Raymond, PG&E J. D. Worthington, PG&E 4

R.D'.Ramsay,PG&E(AvilaBeach)

I cc w/ enclosure pR.. D. Etzler, PG&E (Diablo Canyon)

J. B. Hoch, Project Engineer, PG&E t

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q U. S. NUCLEAR REGUIATORY C00241SSION 0.FFICE OF INSPECTION AND ENFORCEMEhT RECION V 50-275/79-13 wrc No.

50-323/79-08 50-275 CPPR-39

~.tct No.

50-323 License No.-

CPPR-69 Safeguards Group Pacific Gas and Electric Company a: stas __

77 Beale Street San Francisco. CA 94106 111ty Name: Diablo Canvon Units 1 and 2 Diablo Canven Site, San Luis Obisco Countv. California and Corocrate Office 7:ction at:

neceton conducted:

June 4-20,1979 y:ctors: --

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'Ddte Signed D. F. Kirsch,' Reactor Inspector

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U 1 s y Da ta ' signed T. W. Hutson, Reactor Inspector Data Signed 7

lrsv:

By:

N ' $18"*d R. T. Dodds, Chief, Reactor Engineering Support Section mary:

Inspection during period of June 4-7 and 20,1979 (Report Nos.

50-275/79-13 and 50-323/79-08)

Areas Inspected: Routine, unannounced inspection by regional based Inspectors of construction activities including:

licensee action on previous inspection findings; licensee action on IE Bulletins and Circulars; licensee action on 50.55 (e) items; safety related component support' modifications; pipe supports and restraints; and nonconformanco reporting system. The inspection involved 45 inspector hours by two flRC inspectors.

Results: Of the six areas inspe' ted', no items of noncompliance or c

deviations were identified.

RV Form 719(7)

DETAILS 1.

Persons Contacted 1

Pacific Gas and Electric Comoiny (PG3E) l

• R. D. Etzler, Project Superintendent

• M. R. Tressler, Assistant Station Construction Superintendent

• 0. A. Rockwell, Resident Electrical Engineer

• F. M. Russell, Resident Civil Engineer

• V. L. Killpack, Resident Mechanical Engineer

• M. E. Leppke, QA Supervisor

• J. Arnold, Coordinating QC Engineer

• J. A. Holley, Mechanical Engineer B. Marver, Project Administrative Assistant i

• • J. R. Stevenson, Project Administrative Engineer i

R. A. Kelmenson, Assistant Licensing Engineer M. V. Williamson, Licensing Engineer I

R. A. Young, Electrical Engineer R. E. Bacher, Senior Mechanical Engineer W. A. Raymond, QA Director O. L. Polley, Assistant to Project Engineer l

J. R. Bratton, QC Engineer I. Sokoloff, Civil Engineer R. D. Kerr, Welding Engineer M. Leisk L

M. 5. 0( g. Inspection Engineer rzenski, QA Engineer F. J. Dodd Level III NDE Examiner S.' J. Foat. QG Engineer

• Pullman Power Products (Kellogo) t

, D. Geske, QA Manager L. F. Myrick, Welding Supervisor V. E. Pilkington, QC Inspector i

T. Meyers, Welding Engineer

• Attended Exit Interview of June 7,1979

• • Attended Exit Interview of June 20,1979 de J.,

t.

General

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The licensees punch list of incomplete Unit I work items was examined.

It was apparent that tie Itcensee had applied a significant effort to assure that the punch list adequately reflects work items which are in progress or incomplete.

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2-The inspectors examined the status of comprehensive design reviews, design review QA audits, engineering equipment releases and as-built completion at the corporate office on June 20, 1979.

The licensee was continuing to apply efforts to assure the completion of these items priur to fuel load.

..IE Bulletin 79-02 was discussed with responsible engineering personnel.

The licensee was in the process of preparing the necessary evaluations and response.

3.

Licensee Action on Previously Identified Enforcement Items a.

(0 pen) Infrac-ion: Failure to translate raceway support design bases into instructions, procedures and drawings.

LZ75/79-05-Cl, 79-06-02 and 323/79-04-01, 79-04-02)

On May 22, 1979, the ifcensee submitted a report, under the provisions of 10 CFR 50.55 (e). The inspector evaluated the report and conducted selective examinations to verify imple. mentation of the indicated corrective actions.

Numerous class 1 raceway support installations in all areas of the plant were examined.

It appeared that the installing contractor had installed saddle bolts on the applicable raceways even though the design details did not specifically require saddle bolt insta11acien.

Furthermore, in the course of the inspections, the inspector did not observe

• any other raceway supports with the saddle bolts missing.

In a response to the item of noncompliance, dated June 4,1979, t

the licensee detailed additional corrective actions to achieve full compitance., The licensee's home office and field engineering departments examined all raceway support details to establish a list of details for which saddle bolting requirements had been omited. New support details-were issued by Engineering showing that the minimum bolting requirement was one bolt in each saddle to cross-member connection.l The inspector examined the procedure for the Unit i raceway saddle bolt inspection program and observed that it appeared adequate in scope and content. The licensee,'s field engineering organization conducted an inspection of all but 43 supports that utilize saddle brackets / bolts (ie: ~3800 supports total).

The 43 supports not inspectedTad been covered with fireproofing pyrocrete.

Licensee review of installation documentation for these 43 supports, inspection of the Unit 2 corresponding supports and the results of the 100% support inspection supplied reasonable

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3-confidence that the 43 inaccessible supports would conform to detail requirements. The licensee's 100% inspection program did not identify any additi'onal supports.with missing saddle bolts. In addition, to verify the adequacy of the field engineering 100% inspection, the QC department inspected a sample of 20% F800 supports) for compliance to detail requirements and noted no additional discrepancies.

Performance of the raceway support inspection inventory program on Unit 2 had been scheduled for a later date.

The revised drawings are to be used as the inspection criteria.

The portion of the noncompliance, identified as 50-275/79-06-01 and 323/79-04-01 in inspection roport number 50-275/79-06,is considered closed.

With regard to the portion of the noncompliance dealing with'

-the failure to translate requirements necessary for support of non-class 1 raceways which cross above class 1 equipment into

'1nstructions, procedures and drawings, the licensee was in the process of evaluating design drawings and conducting a plant walkdown to identify any such discrepancies. The licensee engineering department will then establ.ish criteria and evaluate each discrepancy on a case-by-case basis to

. determine corrective actions necessary. The portion of the noncompliance, identified in IE inspection report number 50-275/79-06 as 275/79-06-02 and 323/79-04-02, is open and will be examined during a future inspection.

b.

(0 pen) Infraction:

Improper support of non-vital raceways which cross vital raceways (275/79-12-02)

The licensee ~ performed a review of layout and installation drawings and determined those support details which would -

i have the maximum probability of compromising support requirements at raceway crossover points.. A weighted average random sample of these supports was inspected by Foley with the result that only two supports, of 500 total, were found a

selected 500 supports of different details (g and QC have unacceptable.

In addition, Field Engineerin from 605 total i

details) at random for an inspection scheduled to be performed at a later date.

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The balance of these supports have been. scheduled for selected inspections.

The results are to be evaluated by the licensee to determin'a necessary corrective actions.

This ites will be examined during a future inspection.

4.lticensee Action on Previously Identified Followup Items a.

[ Closed) Unresolved Item: Raceway suoport anchor bolt spacing

(

ess than 12 nominal bolt diameters (275/79-12-01) i Representatives of the licensee's engir:eering department performed a 100', walk:!cwn of all areas of Units 1 and 2 to identify 4'

discrepant anchor bolt spacings and locations and evaluate each for accep ability. Unacceptable installations were identified and corrected. The K-85 and 100 areas of Unit 1 (where suppcrts K-100-7-100,115,116,118, and 165 are lodated) were inspected by the licensee's engineering department in July,1975, subsequent to the contractors installation and inspection of the supports, and judged as satisfactory. The inspector also examined the contractor's

, quality inspection documentation for the above supports.

No items of noncompliance or deviations were identified.

i i

b. '(Closed) Followup Item: Rounding off of ifmit of thickness on the welders qualification matrix (50-275/79-12-03)

Discussion with cognizant licensee and contractor personnel i

indicated that actual wal.1 thicknesses were being used on i

the matrix and rounded off to the nearest one-quarter inch instead of the nominal wall thickness which was recorded on the individual welder performance qualification records.

Since the last inspection, Kellogg changed the qualification matrix to use the thicknesses stated on the perforniance qualification records, thus making the two records correlate.

The inspector also examined the qualification records of ten welders, selected welder audit sheets and the welders 90 day status sheets for 1979 to verify matrix accuracy.

PG&E has written Minor Variation Report M-3904 to assure verification i

that no welding was performed outside the allowable limit of thickness for the specificJ.rocesses.

This item will be -

examined further during the Yuture reviews of the licensee's nonconformance reporting system.

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Licensee Action on 10 CFR 50.55(e) Items

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Cracks in rupture restraint weldments (Reference IE Inspection Report 50-275/79-07, paragraph 11)

The licensee submitted a preliminary 50.55(e) report on May 3,1975 describing the program for investigation and the results of the investigation to date. Actions were in progress to define the problem, establish problem scope and boundaries and effect l

corrective actions.

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The licensee had established a task force to accomplish the necessary corrective actions. The task force was staffed by Engineering Department, Department of Engineering Research, and Field Engineering. The task force included a design engineer, a welding engineer, the corporate Level III NDE Examiner and other personnel as necessary.

AE index of all full penetration welds on the pipeway had been established.

Each weld was positively 'indentified and a matrix has been established for tracking the status of the weld from l

nondestructive examination through final acceptance. The I

licensee was performing magnetic particle (surface) and ultrasonic (volumetric) examinations of suspect welds. The extent of

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the examinations appear to meet or exceed the AWS D1.0-69 specified HDE requirements.

The licensee had examined the heavy welds on rupture restraints

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inside the Unit 1 containment and determined that the welds

' were satisfactory.

The magnetic particle examinations were performed satisfactorily following minor preparation of the examination surfaces by grinding.

The following procedures and records were examined for compliance with AWS Dl.1-79 and procedural requirements.

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(a) Procedure for Manual Ultrasonic Examination of Welds and Plate in Pipe Rupture Restraints i

(b) Pullman-Kellogg Welding Procedure Code 7/8 and supporting Procedure qualificatiorrrecords (c) Welding Technique Specification AWS-1-1 established te clarify the techniques to be utilized for application of Welding Procedure Code 7/8 to AWS Dl.1-79 welding operations On ee 9

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I (d) Procedure No. 8833 XR-1 Rev 4 Diablo Canyon Rupture Restraint General Repair Procedure' (e) Procedure flo. 8833 XR-2: Proce' dure for Thermal Cutting (f) Procedure No. 8833 XR-3:

Diablo Canyon Rupture. Restraint l

Sampling Plan l

1 (g) Welder performance qualification documentation for five Kellogg welders (h) Field Process Sheets for a number of base metal and field weld repairs (i) Procedure for " Manual Ultrasonic Examination of Welds and Plate in Rupture Restraints - Diablo Canyon Unit 1" In addition, the inspector examined three rupture restraints in various stages of repair for compliance with AWS-DI.1-79 and procedural requirements, io items of riencompliance or deviations were identified.

The licensee appeared to have an adequate program to identify discrepant welds and effect the necessary repairs. This item will be examined during a future inspection. (275/79-13-01) 6.

1.icensee Action on IE Bulletins and Circulars Bulletin _ 79-09: The licensee reported by letter of May 15, 1979 that the subject GE type AK-2 circuit breakers were not used or planned for use at Diablo Canyon. This bulletin is closed.

7.

Component Cooling Water Heat'Exchar.ger Support Modifications The inspector examined the following documents specifying the component cooling water heat, exchanger support modifications.

p (a)'DrawingNos. 463683, 438200, 438299, 43832h 438297, 438306, 2264-T-V-3-398.

(b) Design Change Orders DCO-G-C-650 and DC-1-G-C-865.

It appeared that the licensee's engineering department had determined that concrete anchor bolt lengths of 3'10" were adequate for the support modifications and that-thrthickness of the turbine building basemat conformed to design specifications.

No items of noncompliance or deviations were identified.

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Rupture Restraint Crushable Bumper Gap Settings PG&E has developed an envelope of pipe movement for each rupture restraint by reanalysis of rupture restraint gap settings.

The theoretical hot position has been included on each drawing.

A gap of one-half inch from the edge of the envelope to the cru' hable bumper has been specified for all rupture restraints.

s The setting of the specified gaps had been completed except for eleven rupture restraints, which were undergoing additional reanalysis, and two others, which were on hold pending receipt of material.

No items of noncompliance or deviations were identified.

9.

Pipe Supports and Restraints Nine Unit 2 pipe supports and restraints were selected by the inspector to verify ins.tallation conformance to Kellogg ESD-223, Installation and Inspection of Class I Pipe Supports. The supports inspected are listed below:

Support No.

Drawing No.

Sheet Rev.

548-20 548-20 1

0

.947-7R 051368 11 1

949-203R 051370 203 1

512-42R 049323 53 1

1 75-llSL 051399 15 1

49-ll4R 051352 70 1

6-129R 051351 146

.1 165L 051396 27 1

72-15SL 051396 26 1

Support 512-42R appeared to have one concrete anchor bolt that was cocked at an angle and the bolt head did not appear to be fully bearing on the baseplaterThe inspector also identified that one U-Bolt nut had stripped threads and did not appear to have sufficient thread engagement. Hanger 6-129R did not appear to have the T-shoe gaps specified on the drawing for the top and bottom T-shoes.

The drawing specified a zero gap on the bottom and 1/8" at the top. The gap at the top was zero and the bottom was approximstoly 1/4". A modification to a support down tho line

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appears to have caused the pipe to move and upset the specified gaps. The contractor stated that the cocked anchor bolt, stripped nut and gap deficiencies would be investigated and evaluated.

The inspector examined the cuality records associated with the above listed. supports to evaluate conformance with documentation requirements of ESD 223.

The records included Field Support process Sheets, PSA Snubber Checklists, Minor Variation Reports for applicable supports and as-built drawings.

The records reviewed appeared to accurately document the status and quality of the inspected work.

The inspector will continue to examine the licensee's corrective action on discrepant pipe supports and restraints.. No items of noncompliance were identified.

10.

Monconforcance and Minor Variation Reports The licensee's nonconformance reporting system was examined for compliance with.QA program requirements.

The inspector reviewed selected NCR's and MVR's in the civil, mechanical and electrical areas initiated during the period between April 1,1979 and June 4,1979. The resol.ution and closecut

. of the selected NCP.'s and f1VR's appeared to conform to the requirements of the QA program.

No items of noncompliance or deviations were identified.

11.

Exit Interview

, The inspectors met with lic'ensee representatives (denoted in Paragraph 1) on June 7,1979 and June 20, 1979, at the site and corporate office, respectively, and summarized the inspection gurpose, scope and findings.

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PACIFIC GAS AND EI.,E CTRIC C C M PANY.

77 BEALE STREET, SAM FRANCISCO. CALIFORMI A 94104 TELEPMONE (415) 7014211 pg g January 27, 1984 h

PGandE Letter No: DCL-84-031 Mr. John 8. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 Response to Allegations'25, 58 and 96 - SSER 21

Dear Mr. Martin:

Enclosed is the PGand response to allegations 25, 58, and 96 described in SSER 21 pertaining to expansion anchors.- PGandE's response to the concern regarding the H. P. Fotoy rocedure governing the installation of anchor bolts wili be submitted next weet.

In addition PGandE is currently developing responses to the other allegations and concerns which require resolution prior to criticality.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely,

/

J. B. Hoch for J. O. Schuyler Enclosure

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D. G. Eisenhut H. E. Schierling Service List i

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l PGandE Letter No. DCL-84-031 ENCLOSilRE USE OF CONCRETE EXPANSION ANCHORS AT DIABLO CANYON 1.

Description of Concern Several interrelated concerns about anchor bolts were identified including emedmont, spacing, angularity, and torque requirements. In the following pages we provide information addressing:those concerns.

2.

Resolution of Concern Concrete expansion anchors have been frequently used to attach safety-related components to the ennerate structures at Diablo Canyon Power Plant (DCPP or Diablo Canyon). The major use involved supports for piping, electrical raceways, and HVAC ductwork. Expansion anchors were used in other miscellaneous safety-related and nonsafety-relsted applications. For many years before Diablo Canyon was built, expansion anchors were used in the nuclear industry as well as in non-nuclear construction and have proven to be a satisfactory means of anchoring components to concrete structures. The performance of expansion anchors has been studied analytica1Ty and tested extensively for more than 30 years. lAsile the installation procedurer are basically simple repeatable operations, these numerous studies have identified design margins and

. installation techniques that assure adequate performance.

The use of expansion anchors at DCPP began in the early 1970s, uhen the major concrete structures were erected. At that time the primary source of design data and installation techniques was provided in brochures published by the individual anchor manufacturers. In order to confirm the validity of the manufacturers' data PGang ormed its own tests on a variety of anchor types. Theseincluded static and dynamic tests.

In addition, PGand engineers discussed installation procedures with the various anchor manufacturers' representatives. The manufacturers' data were used as the basis for design and installation of expansion anchors at Diablo Canyon.

In 1974 PGand consolidated the design and installation data from various anchor manufacturers into a single company engineering standard--drawing 054162. This standard was subsequently incorporated into the construction procedures used by the contractors working at the Diablo Canyon jobsite.

These formal construction procedures did not change the manufacturers' requirements, but rather supplemented them and emphasized their importance.

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In the following. years, a series of anchor installation inspections were perforund to verify that the anchors were properly installed. Extensive walkdowns were performed on the piping, raceway,' and HVAC supports. ' The i

relatively few deviations that were found (2 to 3 percent of all installations) demonstrate that the installation procedures were understood and were properly executed. In order to determine the acceptability of anchors deviating from the established installation i

requirements, analytical evaluations and testing programs were performed, i

l is a chronology describing the continuous reviewing and monitoring of the use of expansion anchors at Diablo Canyon. The chronology shows that when problems were encountered in one contractor's installation, the existance of similar problems in the other contractors' l

work was investigated. Resolutions of specific concerns are addressed in l

Attachments 2 through 6.

The dynamic testing program for the DCPP expansion anchors is described in Attachment 7.

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.i In 1979 the IstC recommanded minimus' design margins for piping support i

anchors in I&E Bulletin 79-02. The Diablo Canyon piping support anchors were then requalified in conformance with this bulletin.

In 1982 and 1983 the Diablo Canyon verification program reviewed the usage of expansion anchors. Factors of safety achieved in the installations using drawing 054162 (e.g., raceway, HVAC, and instrumentation supports) were quantified. These safety factors were summarized in a report attached to the verification program E0I 1016 (Attachment 3. Ref. 1).

Previously approved deviation reports were also reviewed. The verification program did not address each individual anchor with a deviation. Rather, the verification program established the acceptability of expansion anchors as follows:

t (1) For anchors installed in accordance with drawing 054162, a factor of safety of at least 3 between demand and capacity was confirmed (see Attachment 2).

(2) For anchors not conforming with drawing 054162, the previous resolutions were reviewed. Based on these previous resolutions, it was established that the deviations would not cause an unsafe condition.

(3) Expansion anchors with known installation deviations were sampled. The anchor capacities were analytically reduced and, in every case, the evaluation found a factor of safety greater than 3.

(4) The support systems using expansion anchors are highly such that the existence of a few anchors with factors redundant,less than 3 would not reduce design margins of safety unacceptably or in inriy way compromise the integrity of the supported systees.

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i In conclusion, expansion anchor usage.at Diablo Canyon has always been carefully implemented and reviewed.-r As shown in the attachments 'a high degree of confidence in the. adequacy of the. anchor installation has1been established. In the verification program the factors of safety were quantified. For properly installed anchors, factors of safety of at least 3 were verified in every case reviewed and most anchors were shown to have factors of safety markedly above 3.

nihile the potential exists that 2 to 3 percent of the expansion anchors may have lower factors of safety due to installation deviations, the overall martlin and redundancy in the design of expansion anchors at DCPP is reasonab'e, conservative, and acceptable.

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, - Expansion Anchor Chronology Governing Inspection (I);

Procedure Date or Test (T)

Description' Manufacturers' Mar 1972 T'

PGandE performed static tests to

_ Instructions validate data in manufacturers' catalogs. Approximately 54 tests of Wej-it Kwik-Bolt, Parabolt, Phillips anchors were performed.

Manufacturers' May 1972 T

PGandE performed 18 dynamic (sine)

Instructions tests at UC Berkeley to define the performance of expansion anchors when subjected to dynamic loads.

16 static tests were performed as well.

PGandE Standard Drawing 054162 Drawing Nov 1974 054162 was issued.

(Foley ocedures were issued in 1975.

Drawing Feb 1975 I

Foley was instructed to sample' 054162 expansion anchor spacing. Some spacing violations were found which.ed to a complete walkdower in July 1975. Some edge distance violations were found which led to testing in September 1975.

Drawing July 1975 I

'A 3-month-long 1005 walkdown of 054162 all recavay installations was made. Construction tagged and logged all spacing vio'ations.

Engineering established a review criteria and inspected all violations. Modifications were made when nicessary.

PGand Calculation Binder 52, Drawing Oct 1975 054162 sheets 150 through 156, contains calculations addressing spacing violations arising from the July 1975 walkdown.

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Governing Inspection (I)

Procedure Date er Test (T)

, ' Description Drawing Oct 1975 T

PGandE tested perforisance of 054162 anchors close to chaefered edges of concrete.

12 tests in shear and pullout were done for 1/2" dia. and 5/8' dia. Hilti anchors.

Drawing Feb 1976 I

Discrepancy report DR E-1235 054162 documented edge distance violations discovered in the July 1975 walkdswn and resolved by the October 1975 tests.

Drawing Dec 1976 I

Piping expansion anchors were 054162 inspected per Inspection Procedure for Installed Flush Shell Concrete Anchors. The following items were inspected:

obvious flaws, cut off anchors, over embedmont, angular alignment, and depth that 4

expansion plugs were driven.

Drawing Dec 1976 T

Procedure for Establishing 054162 Acceptance Criteria for Concrete Anchor Installations was implemented. Testing was

. performed for various setting depths for expansion plugs (approximately 80 tests), cut off ancnors (approximately 30 tests),

angular misalignment (7 tests),

and over-embedmont (10 tests).

Drawing Feb 1977 I

Discrepancy report 282 054162 h - nted the generic review of expansion anchors used in piping

supports, i

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Governing Inspection (I)

Procedure Date or Test (T)

Description i

Discrepancy report 283 Drawing Mar 1977 I. T 054162 extended the anchor review into.

HVAC area. A generic review was made on sampling basis (77 I

anchors). Anchors were inspected for: obvious flaws, cut off ends, overembedmont, angular alignment, and depth that expansion plugs 1

were driven. 3 anchors had plugs not "fuily driven." 11 anchors

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were tested and all exceeded i

allowable load values. No other deviatior.s were found.

Drawing Mar 1977 I

Use of 2-3/4" long Hilti 054162 Kwik-Bolts identified as a potential problem. Usage had stopped in January 1975.

Drawing Apr 1977 I, T Discrepancy report 288 was 054162 issued documenting raceway support anchor embedmont inspections. For 3/8" dia.

i anchors, 448 were checked by measuring bolt projections and 64

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were UT inspected. For 1/Z* dia.

enchors, 508 were measured.

Testing program WA-1 was

' performed in which 110 anchors were tested at embedmonts less than required by drawing 054162.

Drawing May 1977 I, T Discrepancy report 3373 was 054162 issued. Spacing between good and l

abandoned toles/ anchors did not I

always meet drawing 054162 requirements. 65 tests were perforised to evaluate problem.

1/2" dia., 5/8" dia., and 3/4" dia. Hilti wedges and 5/8" dia.,

3/4" dia., and 7/8" dia. Phillips wedges were tested, i

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Governing Inspection (I)

Procedure Date or Test (T)

Description Drawing Sep 1978 I

NCR DC1-80-RE-002 documented a 054162 (through generic (grid) raceway support 1980) review. Foley procedure GI-I was followed and checked 1005 of raceway installations, including inspecting anchors for: spacing, edge distance, angular alignment, nut engagement, eebedment depth, and cut off bolts.

Drawing Oct 1980 I. T A procedure was issued for 054162 developing ultimate pullout capacity criteria for imperfectly installed shell-type concrete anchors. In 1976 piping anchor problemswereresolved(DR282)l but to meet IES 79-02 additiona tests were performed. Expansion plug depths were varied and the i

, anchors were pulled to define their ultimate strength.

Approximately 150 tests were done for 1/2* dia., 5/8" dia., and 3/4" dia. HDI ant. hors and 1/Z' dia., 5/8" dia., 3/4" dia. and 7/J' dia. Phillips self-drilling anchors.

Drawing Nov 1980 I, T A report was issued concerning 054162 inspections, tests, analyses, and rework of saismic Category I pipe supports and concrete expansion anchors in conformance with IEB 79-02. The acceptability of piping anchors was confirmed.

Testing was performed to better define shear-tension interaction (refer to Teledyne re TR 4121-1, July 1980) port Drewing Oct 1981 T

PGandE performed a series of to confirm their behavior. pports iv> situ tests on raceway su 054162 The static tests showed linear

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Governing Inspection (I)

Procedure Date-or Test (T)

Description Drawing Jun 1982 I

The grid program inspection data 054162 was reviewed in the verification program. All anchor bolt 4

deviations were reviewed (3746 problems were identified in the grid walkdown). The verification progree reviewed the acceptability of these anchors.

E0I 1016 report was prepared to Drawing Jun 1982 054162 address factors of safety inherent in the drawing 054162 allowable loads.

Drawing Dec 1982 I

55 anchors with threads cut off 054162 had been identified in the June 1982 grid walkdown review. These anchors were re-inspected and dispositioned in compliance with verification program criteria.

Drawing Jan 1983 I

44 anchors with insufficient 054162 embedmont identified in the grid walkdown were UT examined. Based on the UT results, the design calculations were revised and the

,embedmont probles was resolved.

Drawing Sep 1983 I

NCR-DC1-83-ItM-N004 required 054162 testing tightness of 2400 HVAC bolts. Only 8 were found loose and were all able to be reset l

without replacement.

l Drawing Dec 1983 I. T Per 15tC's request, 40 raceway 054162 anchors were torque-tested to determine adequacy of i

installation. All were found to be tightly instal. led. These 40 were taen UT inspected and 1 had l

l 1ess embedmont than required by drawing 054162 (2-3/4" long Hilti anchor).

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. ~- Factors of-Safety Table A of drawing 054162 gives allowable loads for expansion anchors. These values have been used in design of expansion anchors at Diablo Canyon. In response to verification program EDI 1016 (Ref. 1), the factors of safety achieved by using the Table A allowable loads were quantified. This demonstrated that factors of safety ranging from nearly 4 to 9.1 were achieved between maximum allowable working level loads (DE seismic loads) and the anchor capacities published in the manufacturers' brochures. In accordance with drawing 054162, the allowables in Table A were doubled for severe environmental level loads (Hosgri and DDE seismic loads), thus reducing by half the safety factors stated above.

A review of the electrical raceway support calculations was recently performed. This review shows that for 1005 of the raceway supports, with properly installed anchors, a factor of safety of at least 3 has been maintained between demand and capacity for Hosgri and DDE level loads. A s

le of 45 raceway support calculations found the following distribution in thyfactorsofsafety:

Factor of Safety 1 of supports 13 100 14, 98 15 89 1 10 82 A similar sampling was made of 50 HVAC duct support calculations with the following results:

Factor of Safety.

5 of supports 23 100 14 m

25 62 1 10 3

g The factors of safety listed in the tables above are conservative for the following reasons:

(a) ManycalculationsenveloW1oadstoexpeditetheanalysis.

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(b) Expansion anchor capacities are based on concrete strengths achieved in the 28-day and 60-day cylinder break tests. Concrete typically strengthens 35 to 505 between the test cylinder strength and the 2-year strength. This would result in a 20 to 255 increase in capacity for most anchors.

(c) Most anchors are subjected to both shear and pullout loads. The 5/3 interaction equation specified on drawing 054162 was used to combine shear and pullout loads. This equation results in a conservative design when compared to test results.

Instrumentation supports were also designed usino drawing 054162. The instrumentation supports have higher design margins than the raceway and HVAC supports because the instrumentation supports are almost always very lightly loaded.

Traditional factors of safety for expansion anchors range from 3 recommended by Appendix B of the ACI 349 code, to 4 or 5. recomannded by NRC I&E Bulletin 79-02. Factors of safety for expansion anchors have been set at these hi levels primarily to account for variability in workmanship (installation)gh and to account for reduced capacity in case a concrete crack subsequently passes through the anchor's location (tension zones of reinforced concrete elements). Reference 2 addresses expansion anchor performance in cracked concrete. This report concludes that a factor of safety of 3 (to account for variations in installation) is adequate even for anchors in cracked concrete.

As shown in the preceding tables, the overall margins in the Diablo Canyon expansion anchor designs are large. Factors of safety of at least 3 (and usually much more) have been maintained in the support designs. Only in cases where anchors were not properly inptalled is there a potential for the factor of safety to be less than 3.

Installation deviations, addressed in the following attachments, have been reviewed and it has been found that the factors of safety have not been reduced to unacceptable levels.

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. - Embedmont f

In order to achieve the pullout strengths which were used to compute the factors of safety listed in Attachment 2 minimum embedmonts of the expansion anchors into the concrete structures must be achieved. The manufacturers' i

brochures and drawing 054162 specify the required minimum ediedmonts.

In 1977, a discrepancy report (DR 288) documented a potential embedment deficiency in electrical raceway support anchors. Between 1972 and 1975 approximately 14.000 1/2*-diameter. 2-3/4"-long, wedge-type expansion anchors were bought by the electrical contractor (raceway supports are estimated to contain a total of approximately 125.000 expansion anchors). To install these 1/2"-diameter anchors at the required 2-1/4" embedmont, only 1/2" of the anchor stud would project out from the concrete surface; thus, any of these that were used would likely have been installed at les.: than required l

embedmont.

j Under the assumption that some of these "short" anchors were used in safety-related raceway supports, a testing program was undertaken in 1977.

Test anchors were installed at 1-1/2' of embedeent and were successfully proof-loaded to Hosgri design level loads. A field sampling program was then undertaken in which over 500 1/2"-diameter expansion anchor embedments were measured. This sampling program found all anchors have.at least the 1-1/2" embedmont used in tu testing program. The combination of field sampling and proof testing provided assurance that the use of 2-3/4*-long anchors was acceptable (factor of safety of at least 1).

Between 1978 and 1980, a systematic (grid) program inspected the conformance of all raceway supports to the design drawing requirements. In this inspection, anchor embedmont was determined by subtracting the projecting h.

It was assumed that expansion anchors were at least 3-3/4*-long. length of the anchor from the overall k

not have identified 2-3/4"-long anchors that were set at less than required

.embedmont, it verified that the vast majority of the raceway anchors had the expected embedeent.

In the 1982 verification program, the data compiled in the 1978 grid inspections were reviewed. Only 44 out of approximately 125.000 anchors were found to have less than required embedmont. The embedmont of each of these

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i anchors was checked by UT examination and the allowable loads on these anchors were appropriately reduced in the verification p(rogree calculations. factor of safety g Every I

one of the 44 cases was found to be acceptable

3) when the reduced allowables were compared to the actual demand.

In December 1983. 40 raceway support anchors were selected for torque-testing.

Results showed that all 40 anchorth :properly set. The embedmont on the 40 eschors was then measured. One of the 40 was found to have less than the minimum embedmont required by drawing 054162 and was a 2-3/4*-long anchor.

selected, this sample would Assuming that the 40 anchors were randomly (as determined by a statistical indicate, to about a 755 confidence level consultant), that 2-1/2 percent of the raceway support anctors were the i

2-3/4"-long anchors.

.u-i 0070d

An evaluation of the significance of short embedmont for the raceway support anchors was made recently. Forty-five raceway support calculations.were selected for review. Under the assumption that all anchors had been set at 1-1/4" embedmont*,-the capacities of all anchors were analytically reduced.

The factors of safety for the anchors were then calculated and exhibited the following distribution:

Factor of Safety Percentage of Supports 11 100 13 M

24 25 76

} 10 51 The results above overwhelmingly demonstrate the safety margins in the raceway 4

support designs. Since only about 2-1/2 percent of all anchors are likely to have reduced embedmont, and since only 18 percent of all anchors would have a i

factor of safety less than 3 even if embedded at 1-1/4", the combined probability that any particular anchor would actually have a factor of safety less than 3 is very low. Even with short as6edmonts, the factors of safety for the raceway support anchors would be between 1 and 3 and would not create an unsafe condition.

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• The grid program inspections verXied 2-1/4" embehent for anchors assumed to be 3-3/4"-long. So if some anchors were actually 2-3/4"-long, their actual i

embedmonts would be at least 1-1/4".

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< - Spacing Drauing 054162 and manufacturers brochures specify minimum spacing requirements for installation of adjacent anchors. Spacing between anchors is igortant for the anchors uhose capacities are controlled by pullout of concrete cones around the anchor. M en anchors are placed close together, their pallout cones overlap and reduce their pullout capacities.

In 1975, anchor inspections revealed numerous spacing deviations. Resolution of the deviations was achieved by inspecting all supports using expansion anchors. Anchors with spacing deviations were entered.in a construction log l

and red-tagged for engineering disposition. In July 1975, a 3-month-long walkdown was performed by PGandE engineering. Each spacing deviation was resolved in one of the following ways:

(a) One of the two adjacent anchors was very lightly loaded; i.e.,

anchors securing grounding cables, lighting conduits, etc. More than 50 percent of all violations were of this type.

(b) Both of the adjacent anchors would not experience simultaneous loading. For example, one anchor might be installed in a brace assigned to resist north-south seismic loads, while the other anchor 4

l was installed in an east-west seismic brace.

4 (c) Both of the adjacent anchors were loaded in sheer only. Shear capacities are governed by the shear capacities of the individual anchor's steel shank, not by anchor spacing.

' (d) The design loads were less than the reduced allowable loads.

Engineering reviewed the design calculations of some deviations and analytically reduced the anchor strengths in accordance with drawing 054162.

(e) Pnysical changes to the supports were made. Modifications were made to eliminate the spacing deviations in cases that were not resolved by the means described above.

In 1982 and 1983, extensive walkdowns and design calculation reviews of the supports were made for the verification progree. Were spacing deviations occurred between anchors installed within one support, anchor capacities were reduced in accordance with drawing 054162. For spacing deviations occurring between anchors installed in different supports, the deviations were resolved as follows:

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(a) A sampling of design calculations qualifying supports containing anchors with support-to. support spacing dev<ations was mode. In all cases the actual demand, when compared to reduced capacity, resulted in factors of safety greater than 3.

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(b) The spacing deviation acceptance criteria used in the 1975 walkdown (items (a) through (e) above) were reviewed. With the exception of the deviations sent to englineering for review, the 1975 criteria:

remain valid. Thus, the '975 walkdown satisfactorily resolved the majority of the spacing deviations.

~

(c) Analytical techniques (Ref. 3) for reducing anchor pullout strength, based on overlapping cones, show anchor capacity to be relatively insensitive to reductions in spacing. For example, at half the required spacing. 80 percent of the capacity remains.

(d) A series of spacing tests (Ref. 4) was performed by Doberne and Eigenson in 1962. Phillips Red-Head Self-Drilling expansion anchors were set at varying spacings and pulled to capacity. Evaluation of the test data showed 100 percent capacity available at 10 diameters (10d) spacing (drawing 054162 requires 12d) and 80 percent capacity available at 5d spacing. These data agree with the analytical method referenced above and corroborate the relative insensitivity of anchor capacity to reduced spacing.

The 19'75 spacing review resolved spacing deviations on a case-by-case basis.

In 1982, the verification program resolved spacing deviations on a sampling basis. Every case sampled was found to have an adequate factor of safety (greater than 3). letile some spacing deviations may exist in which there are factors of safety less than 3. these would be very few and would not result in unsafe conditions.

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. - Angular Alignment Drouino 054162 and the contractor's procedures require expansion anchors to be insta1Ted not more than 50 out-of-plumb. This angular tolerance was based 4

on the engineering judgment that a 50 misalignment would have no effect on the anchor's stronfith. At one time some of the ennsfacturers' brochures

)

included a 50 misa'ignment tolerance, also based upon engineering judgement.

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PGancE Engineering subsequently approved anchors installed up to 150 out-of-plumb, although the installation procedures retained the So tolerance. Thus, the only time that the 150 tolerance was used was when an anchor had inadvertently been installed at an angle greater than So, The Engineering acceptance of 150 angularity was based on two sets of l

tests. The first were proof load tests performed in conjunction with discrepancy report 288 (Ref. 5). Wedge-type test anchors were installed 200 out-of-plumb and proof loaded in pullout to the Hosgri design load levels (twice Table A values). The second testing program was performed for piping anchors in conjunction with DR 282 (Ref. 6). These shell-type test anchors were installed 150 out-of-plumb and were proof loaded to more than 150 percent of the Hosgri design level loads (three-times Table A values).

All anchors in both test programs held the proof loads.

Bechtel is currently performing'umb. ultimate si ecG h (failure) tests on expansion anchors installed 10o out-of-p Preliminary results from tests on 3/4" diameter Hilti Kwik-Bolts (wedge-type anchors) indicate that there is no reduction in ultimate strength due to 100 misalignment, thus establishing that the factors of safety are retained in cases when the anchors are misa11gned.

Although none of.the tests referenced above were performed explicitly on Phillips Stud anchors, the anchorate mechanism on the stud-type anchors is identical to that used on the shel'-type anchors. As mentioned above, the shell-type anchors installed 150 out-of-plumb were successfully proof tested to loads 50 p. -et above the Hosgri level allowables.

In sumiary, expansion anchors installed between 50 and 150 out-of-pitmib are very rare occurrences. All of the test data cited above indicate that the anchors perform satisfactorily when installed within the 150 tolerance.

Therefore, approval of the use of anchors at angles up to 150 is reasonable and acceptable.

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- Miscellaneous irrequiarities The inspection and walkdown reports referenced in Attachment 1 note a few-irregularities in anchor installation that are not addressed in Attachments 3 through 5.

Examples of these irregularities include tapping stud anchors sideways to improve alignment and torquing anchors to achieve full nut

y f --- 1;. These are extremely rare occurrences and no test data are avai able to quantify the effects, if any, that these irregularities have on anchor capacities.

l As noted on page 2 of this submittal, it is expected that 2 to 3 percent of all anchors experienced some deviations (or irregularities) in installation.

i These deviations could reduce an anchor's factor of safety below 3 if that j

specific anchor were required to carry the maximum load allowed by drawing U34162. However, it is believed that the irregularities of the type mentioned above would have only minimal adverse impact on the anchor capacities and a factor of safety of at least 3 exists between demand and capacity.

Due to the infrequency of occurrence and the large factor of safety built into the design, installation irregularities would have no significant effect on the overall safety of the attached components.

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, - Simulation of Expansion Anchors in Dynamic Testing Program-t In 1983, dynamic testing of the Diablo Canyon raceway supports was performed at ANCO Engineers, Inc., at the testing facility. In this dynamic testing program, it was not feasible to use expansion anchors due to limitations in mounting concrete slabs on the shake-table. Therefore A307 machine bolts were used in lieu of expansion anchors. The A307 bolts were torqued to produce a preload of about 1050 pounds. The torque necessary to produce this load was small, typically 10 to 12 ft-1bs. This preload value was used use it provided a reasonable representation of the expansion anchors in field conditions. Further justifications for the use of a 1050-pound preload are:

(a) It is a common practice to torque expansion anchors to produce a preload about equal to the working design load (1025 pounds for l

I/2*-diameter bolts in 4000 psi concrete). For example. Hilti recosumends 3 or 4 turns after finger-tight condition, which produces the desired preload.

(b) The use of a wrench for installing expansion bolts is necessary and experience has shown that 12 ft-lbs torque is very easily attained when the nut is turned, even with a 6-inch wrench. This was further verified in the three field-sampling programs, described below.

During an onsite audit. NRC inspectors examined 140 raceway supports. All but 12 anchors were found to be at least snug-tight.

Estimating 4 anchors per support, only 2 percent did not have a preload. In another NRC inspection 40 anchors were randomly selected and all 40 were found to be snug-tight. A third program executed in response to an NCR (Ref. 7) sampled the tightness of E400 HVAC duct support bolts. All except 8 bolts were found to be tightly installed.

In the dynamic testing, at intermediate level shaking (average Hosgri design

. Toad level), almost all of the A307 bolts retained their preload. In the supports where there was some loosening of the A307 bolts, no adverse changes occured in the support's response.

Numerous field inspections have shown that with the exception of an occasional loose bolt, the concrete expansion anchors in place at Diablo Canyon are installed snug-tight. This condition was reflected in the ANCO testing by using preloaded A307 bolts. As observed in the testing, bolt preload did not prec.ude bolt loosening and the supports performed satisfactorily. Therefore modeling of the expansion anchors in the dynamic testing with preloaded A307,

bolts was reasonable and appropriate.

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. - References (1) " Resolution of RLCA EDI 1016,* Diablo Canyon Project Electrical Raceway Support Calculation EDI 1016 Rev. O. June 1982.

(2) " Expansion Anchor Performance in Cracked Concrete " R. W. Cannon, Tennessee Valley Authority, 1981.

(3)

• structural Engineering Aspects of Headed Concrete Anchors and Deformed Bar Anchors in the Concrete Construction Industry," KSM Welding Systems Division Omark Industries, 1971.

(4) " Pullout Capacities of Phillips Red Head Concrete Anchors as Affected by Spacing " Doberne and Elgenson, File 626, September 1962.

(5) " Test Procedure WA-1 Concrete Wedge Anchors " Rev. 1. PGandE, March 1977.

(6) " Procedure for Establishing Acceptance Criteria for Concrete Anchor Installations " Rev. 2. PGandE, December 1976.

(7) Nonconformance Report DC1-83-AM-M004, September 1983.

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PACIFIC GAS AND E LE C T RIC C C MPANY n state stater, saw rnancisco. cauronnia estos trLerwonc <4:n ist.4ri pgg February 7, 1984 PGandE Letter No:

DCL-84-047 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Docket No. 50-323 Diablo Canyon Units 1 and 2 Welding in the Cable Spreading Room

Dear Mr. Martin:

As a result of the recent NRC investigations into the allegations listed in SSER 21, the Staff has raised questions regarding the installation of class I equipment on class II material in the cable spreading room. The enclosure to this letter provides the PGandE response to these questions.

Kindly acknowledge receipt of this material on'the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, J. O. Schuyler by J. D. Shiffer Enclosure cc:

T. W. Bishop D. G. Eisenhut G. W. Knighton H. E. Schierling 634 thte xsw'adet

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PGandE Letter No. DCL-84-47 ENCLOSURE USE OF NON-CLASS I MATERIAL TO StFPORT t

SAFETY-RELAlt.U EQUIrm.NT IN THE CABLE 5PREADING R0GtS

Background

The' NRC has requested' additional information based on their review of the use I

of non-Class I steel to support safety-related equipment in the cable spreading rooms. The information requested is:

l 1.

Show qualification for the materials and installation.

f 2.

Explain why resolution of the problem has not been accomplished in a more timely manner.

3.

Why wasn't the problem discovered by the IDVP or the ITP7 4.

Address generic implications, including late identification of the l

issue as a nonconformance.

Resolution The following discussion provides a response to each question.

1.

Show qualification for the materials and installation.

i The non-Class I steel beams used in this installation have been tested to i

determine chemical and physical properties. The steel was found to have ASTM l

A-36 properties as required by tie design drawings. The beam installations and equipment attachments to the beams have been as-built. Calculations have l

been performed which show qualification of the as-built installation. Refer to Attachment 1 for details.

3 i

2.

Explain why resolution of the problem has not been accomplished in a more j

timely manner.

l On October 6, 1983, H.P. Foley Company identified to PGandE a concern regarding the adequacy of anchor bolt installations which fix the steel beams in place. This initial concern was broadened to include the issue of l

non-Class I material in Class I installations. Resolution has required preparation of additional as-built drawings, material removal for testing and 4

l analysis, and design reanalysis. Although resolution has taken approximately j

four months, when considering the complexity of the issue, we find the i

duration to closure to be reasonable.

3.

Why wasn't the problem discovered by the Independent Design Verification i

Program (Iovr; or tne Internal Tecnnical Program (ITP)7 l

The IDVP was based on a sampling approach. This installation was not included in their sample. However, their revietrdid identify a generic concern for i

adequacy of equipment supports. As a result of this generic concern, the i

equipmene attached to the cable spreading room platforms was reviewed by the ITP. 'The welds from the equipment to the steel beams were found to require i

modification for structural reinforcement. In addition, the design of the cable spreading room platforms was reviewed by the ITP. The design of the i

i i l 0205d i

platform consisted of steel beams installed in a grid pattern fixed to the floor by closely spaced anchor bolts. A senior engineer reviewed this design and judged that margin exists in the design such that as-builting and detailed reanalysis was not warranted. The steel was specified as ASTM A-36 -but no certification was required. Since A-36 is a standard commercial grade steel and no welding problems were apparent,.the material was judged adequate. The review described above was completed prior to identification of the NRC igueqt,iens.

The M ore, this installation was reviewed, weld modifications specified, and the remainder judged adequate by the Diablo Canyon Project. Subsequently, the more detailed January 30, 1984 structural analysis and material testing has confirmed the judgments made in the earlier review. Refer to Question 1 for details.

4.

Address generic implications, including late identification of the issue as a nonconformance.

The unique nature of the steel-frame raised-floor configuration led to the acceptance of the design and material without the detai,ed type of as-builting and analysis that was performed for the other structures. This type of configuration exists only in the cable spreading rooms. All other platforms which support Class I equipraent have been thoroughly analyzed. Therefore, this installation is not a generic issue. The Nonconformance Report (NCR) associated with this issue will be completed by February 17, 1984.

~

The Project has initiated a separate NCR to assess the adequacy of the steps taken in addressing timely identification of this issue as a nonconformance.

This NCR will establish cause, investigate generic implications, determine corrective action to prevent recurrence, and review reportability.

1 i

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k ATTACHMENT 1 MTEROFFICE MEMORANDUM PACIFIC GAS AND B.ECTRIC COMPANY BECHTEL POWER CORPORATION D. Rockwell/M. Leppke g

January 30, 1984 g

J. K. McCall 52.19 Civil Eagineering - Unit 1 Supports for Class I Electrical Panels in the Cable 1

45/23/335 8-1414 Spreading Room.- El.'127 Unit 1

Reference:

Minor Variation Report - MVR No. C-1338 Non-Conformance Report - NCR No. DC1-84-SC-N001 Engineering has evaluated the above referenced reports and following is our engineering disposition:

A.

10WT21 Supporting Beans

1. Structural Evaluation: Based on as-built information from the field and new panel loads furnished by Westinghouse, supporting beams are l

found to be structurally adequate when subjected to Boogri/DDE l

earthqtake.

2. Material: Our calculations are based on the material conforming to ASTM A-36 which requires a minimum yield strength of 36ksi.

It has been confirmed that the material does meet the requirements of ASTM A-36 by the mechanical and chemical tests performed on coupons taken from the supporting beams. The test report will be available upon request.

Based upon the above information. existing supporting besas are considered acceptable and, therefore, use as is. The portion of the beams where the coupons were taken shall be ground smooth to remove any irregularities and sharp notches. The cut out portion need not be welded back.

1 3.

Concrete Expansion Anchors Based on sa-built information from the field and new panel loads furnished by Westinghouse, all expansion anchors are found to be structurally adequate when subjest W to the Woogri/DDE aarthquake. The capacity of espansion anchors are based on the report "Use of Concrete Espansion Anchors at Diabic Canyon" contained in PGandE Letter No.

DCL-44-031 which accounts for embedmont and angularity. All existing expansion anchors are acceptable and therefore,use as is.

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l D. 30ckve11/M. Leppke

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January 30, 1984 For year reference', the calculation number for the above is EFA-9. Bev. 2 and filed sa 52.19.

'Y W If there are r.ny questions, please call Ali Vanek at Ext. 8-5953.

M.e G.d-LJ. K. McCALL Afasek: sip Response Required: Bo.

cr.: IFriend G36oore WIIWhite LIRosetta FRussell PMorsy BOShah 35arkar Avanek,

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77 SEALE STREET. SAN FRANCISCO, CAL'FORNIA 94106 * (415)781 4211

• TWX 910 372 6587

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February 16, 1984 PGandE Letter No: DCL-84-059 Mr. John B. Martin, Regional Administrator U.S. Nuclear Regulatory Comission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 SECY-84 Items 25, 58, 96, 142, 154, and 176 Concrete Expansion Anchors

Dear Mr. Martin:

Infornration on the use of concrete expansion anchors at Diablo Canyon was sumarized in PGandE letter DCL-84-031 dated January 27, 1984. In a subsequent letter DCL-84-048 dated February 7, 1984, PGandE stated that a successful sampling program for as-built conditions of the expansion anchors would e'nhance confidence in conclusions' discussed in the January 27, 1984 letter. The anchor bolt sampling program described in the February 7 1etter and evaluation of the data have been completed. This submittal provides the results of the sampling program.

In the February 7 1etter, PGandE committed to review the electrical

~

contractor's inspection records to identify cases of anchor bolt straightening and torquing to improve nut engagement. The results of this a view are also included in this submittal.

Completion of the anchor bolt sampling program and contractor records review i

confirms PGandE's earlier conclusion regarding the adequacy of concrete anchor bolts.

l Kindly acknowledge receipt of this material on *5e enclosed copy of this letter and return it in the enclosed addresrM etvelope.

_ _ iiMar ;,SY u er i

Enclosures ng Y Service List

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i PGandE Letter No.-DCL-84-059 ENCLOSURE Concrete Expansion Anchors in Electrical Raceway Supports Infor1sation on the use of concrete expansion anchors at the Diablo Canyon Power Plant (Diablo Canyon) was suussarized in PGandE letter DCL-84-031 dated January 27, 1984. This summary contained the results of a review of inspection records, onsite tests, design calculations, and other published data which supported the conclusion that expansion anchor usage at Diablo Canyon is fully acceptable. Subsequently, the NRC Staff and PGandE agreed that sampling the as-built conditions of the expansion anchors would enhance the confidence in the ccnclusions reached in the January 27 1etter. This submittal provides the results of the sampling program.

In another submittal (PGandE letter DCL-84-048 dated February 7, 1984), PGandE provided the NRC Staff with a copy of the instructions that were used to perform the expansion anchor sampling.

In that February 7 letter, PGandE additionally consitted to review the electrical contractor's inspection records to identify cases of anchor bolt straightening and torquing to improve nut engagement. The results of this review are also included in this

~

submittal.

The objective of the sampling program was to confirm the adequacy of expansion anchor installation in electrical raceway supports.on a statistical basis.

For the purpose of this program, adequate installation of an individual support is achieved when the expansion anchors included in the support calculations have a safety factor of at least 3 relative to their capacity.

The overall adequacy of the expansion anchors in the raceway supports is statistically confirmed when a random sampling program achieves a 95%

confidence level that 95% of the supports meet the above definition of adequacy.

The expansion anchor sampling prograe just completed at Diablo Canyon included 98 randomly selected electrical raceway supports. For each of the'se supports, safety factors have been confirmed to be greater than 3 even after reducing individual anchor capacities for concerns such as embedmont, spacing, and ecge distance. Thus, confidence in the adequacy of the raceway supports using expansion anchors exceeds the 95 percent level.

One of the concerns involved the enbedmont of the 2-3/4" long Hilti Kwik-Bolt expansion anchors. The shorter overall-length of these anchors raised a question as to whether the embedmont was sufficient to maintain adequate safety factors. In the primary sample (the 98 randomly selected supports), 10 supports contained the 2-3/4" long anchors. Idhen a 2-3/4" long anchor was encountered, the sampling instructions required adjacent supports along the.

conduit run to be added to the sample. This resulted in investigation of 22 additional supports. Six of these 22 adjacent supports also contained 2-3/4" 0199d 1

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long anchors. Subsequent evaluation of the anchors in all 16 affected.

supports confirmed that factors of safety in excess of 3 existed in every case. These results corroborate the January 27 conclusions regarding the adequacy of supports containing these shorter anchors.

The following attachments provide detafis on the selection of supports to be i

sampled (Attachment A); a summary of the data that was compiled (Attachment B); a discussion on the statistical evaluation of the data (Attachment C); a discussion on how factors of safety were calculated (Attachment D); and a discussion on the significance of the installation deviations found in the l

sampling program, as well as those recorded in the electrical contractor's I

inspection records (Attachment E).

l In summary, the expansion anchor sampling program has confirmed on a statistical basis, that expansion anchor installation at Diablo Canyon is reasonable, conservative, and acceptable.

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4 Attachment A - Selection of Sampled Supports The Diablo Canyon electrical raceways contain approximately 23,000 supports.

The expansion anchor sample set was selected from these supports by numbering each support sequentially and generating a set of random numbers. The supports corresponding to these random numbers comprised the sample set. A total of approximately 100 supports was intended to be sampled.

This sample size is consistent with the statistical evaluation that was desired. See Attachment C for further,information on the statistical evaluation.

As detailed below, some raceway supports could not be used as samples, so it was necessary to review more than 100 supports to obtain the required sample size.

A total of 401 randomly selected raceway supports were investigated before the desired sample size was achieved.

Exclusion of a randomly selected support from the sample set occured for one of the following reasons:

1.

Some supports did not contain expansion anchors. These consisted of supports welded to steel members or attached to embedded Unistrut channels with structural bolts. Of the 401 supports investigated, 112 were of this type.

2.

Other supports were found to be inaccessible.

Inaccessible supports were those that would have required extensive scaffolding to reach, those located in areas of rooms where other work was in progress, and those located behind other plant components such that the measurement equipment could not be readily used. Ther's were 124 supports of this type.

3.

In some highly congested areas, identification of a speciffe support proved difficult. Supports that could not be fully identified within a reasonable time (generally 1/2 hour) were excluded from the sample set.

Twenty-nine supports could not be readily identiffed.

In addition, a single page of the list of random support numbers was inadvertently lost in transmittal to the site. Sampling of the other supports on the list cor.tinued and an' adequate sample size (98) was reached before this was discovered and the page retransmitted. As a result, 37 supports listed on that page were omitted from the sample.

As preyfously noted, 22 supports were added in the sample set to provide additional data for evaluating 2-3/4" long Hilti Kwik-Bolts. These 22 additional samples consisted of supports located directly adjacent to the randomly selected supports that were found to contain the 2-3/4" Tong anchors.

Thus, for the sample program, complete data was cospfled on 120 electrical raceway supports. Attachment 8 contains a summiary of the data recorded for each support sampled.

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Attachment B - Sihmary of Data The following tables contain the data compiled in the expansion anchor sampling program.

Table B-1 provides an overall summary of sampling program findings.

Table B-2 provides a suimmary of findings by specific concern.

Table B-3 contains the data on each support investigated. Except when otherwise noted with the concern, the numbers in this table represent the quantity of anchors identified by the column heading Factors of safety are listed for supports containing one or more anchors with concerns. For all other supports, specific factors of safety have not been calculated, but are always greater than 3 based on previous generic calculations.

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Attachment B Table B Summary 'of Sample Findings Randon Samples Adjacent Samples Pre-1975 Post-1975 Total Pre-1975 Post-1975 Total No. of supports 25 39 64 12 1

13 containing anchors with no concerns No. of supports 22 12 34 8

1 9

containing one or more anchors with specific concerns Total 47 51 98 20 2

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Table B Summary Lf sting of Concerns (l)

Randon Samples Adjacent Samples Pre-1975 Post 1975 Total Pre-1975 Post 1975 Total 2-3/4" long Hilti Kwik-Bolts 9

1(2) 10 6

0 6

Embedmont less than minimum 12 2

14 6

1 7

per Dwg. 054162 Angle between 50 - 150 5

6 11 1

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Angle greater 0

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1 than 150 Spacing less than 12 5

17 1

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1 10 diameters Edge distance 2

0 2

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0 less than 5 diameters Nut engagement 1

0 1

1 0

1 less than flush Nuts not tight 4

0 4

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0 NOTES:

(1) The numbers in the table represent the quantity of supports containing one or more anchors with the concerns listed.

l (2) This support was probably installed before 1975 (cable was pulled on 10/75) m 2

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i Notes:

(1 The date installed is actually the date cable was pulled through the conduit attached to the subject support.

1 (2

Th

@epre-1975sequencenumberincludesallsupportswhichhadcablepulledbyJuly,1975.

i (3

indicates that the affected anchor (s) are in a fitting. Spacing concerns were accounted for in the i

design calculations.

l i.

(4) @e identifies an adjacent support sample (i.e. not one of the primary 98 randomly selected supports).

}

(5) indicates that the factor of safety was obtained from a generic calculation. The actual factor of i

j l

safety for specific support is likely to be much higher.

j

- 818 -

l-1

Attachment C - Statistical Discussion The objective of the sampling program was to select a statistically valid sample from which an appropriate confidence level on the adequacy of raceway support expansion anchor installation could be ' established.

In applying this approach, adequacy of a support is achieved when the expansion anchors included in the support calculations have a safety factor of at least 3 relative to their capacity.

(See Attachment D for a discussion on factors of safety.)

It was determined that the sample program would be adequate if it could be demonstrated at a 95% confidence leve' that 95% of the supports sampled meet the test of adequacy defined above. Based on the statistics described below, this confidence level is demonstrated when no unacceptable conditions are found in 58 randomly selected samples (or no more than one unacceptable condition in 92 samples; no more than two unacceptable conditions in 123 samples, etc.). The sample size for Diablo Canyon consisted of 98 supports which were selected as described in Attachment A.

The statfstfcal theory involved assumes that the probabflity function P (m) n of encountering (m) defects in a sample of (n) items selected at random from a total of (N) items is hypergeometric. This function can be approximated for (n) less than 0.10 N by the following binomial distribution:.

j I

P,(s)={p"(1-p)"*

(n 1st ratio of unacceptable supports to the total number p

=

supports = 0.05 i

The conffdence level (c) is obtained from the following relationship:

i a

1 c=1-[P,(s)

=

i e

l 0199d C1

~~ ~EE Z2C $$

.T.

i Application of this statistical criterfon to the Diablo Canyon expansion anchor sampling program resulted in a confidence level that exceeds 955. Of the 98 supports in the suspie, no condition existed which was found to reduce the safety factor below 3.

j There was some concern that supports constructed prior to January 1975 were of questionable quality due to the use of 2-3/4" long Hilti Kwik-Bolts. Idhen the pre-1975 fnsta11ations are separated from the 98 random saspies, 47 pre-1975 supports were found to have been saspied.

In addition, 22 adjacent supports, also of pre-1975 vintage, were sampled, making a total of 69 pre-1975 samples. As each of these saspies has been shown to have a factor of safety of at least 3, the conclusions stated above are valid for installations both i

pre-and post-1975.

1 1

t i

I i

l j

3

\\

I l

0199d C2 i

._.---.-.,.--._-..-_.A._-..-.-.__-.-

=L

. - Factors of Safety j

The acceptance criteria for supports that were evaluated as a result of this sampling program has been defined in terms'of factors of safety. The factor i

of safety is the ratio of the expansfon anchor's average capacity to the maximum load the anchors are expected to experience. The magnitude of an acceptable factor of safety was discussed in the January 27, 1984 letter. A l

value of 3 was determined to constitute an acceptable number and was used to measure the adequacy of the individual supports evaluated in this sampling program.

Design loads on the raceway expansion anchors were developed in the Dfablo Canyon Project (DCP) calculations. A criterion deffning the methodology for i

analyzing the raceway supports was previously estab11shed by the DCP and was used in all cases reported herefn. No special analysis techniques, 4

i refinements to the existing procedures, or removal of conservatisms inherent 4

in the methodology were required to demonstrate a factor of safety of l

at least 3.

Anchor capacities were determined as described in the January 27, 1984 i

letter. Briefly summarized, the capacities were determined by averaging i

published test data on all of the types of expansion anchors in use at Diablo 1

Canyon. Development of anchor capacities and factors of safety are contained j

fn calculations prepared by the DCP.

l In cases where installation concerns were raised, the anchor capacities were analytically reduced before calculating the factors of safety. The following is a list.of the analytical reduction methods used for each type of concern:

Concern Reduction' Method j

Short Embedmont Reduction in pullout capacitfes were made in proportion to pullout shear l

cone areas:

l p"r,,",ffactual 2

l

/requir%

where:

Pu' = reduced pullout capacity l

Pu = pullout capacity for full ombedmont j

f dactual=actualembedmontlength l

l

~ 3 required = embedmont length

]

required by Dwg. 054162 j

i I

0199d D1 1

i t

Spacing less than 10 Reduction in pullout capacities were diameters or edge made using the equation given on Dwg.

distance less than 5 054162, except that full capacity was

~

L diameters assumed to be developed at 10d spacings and 5d edge distances 1

us u %)W) j where

Pu' = reduced pullout capacity Pu = pullout capacity at full spacing and edge distances j

N

= no. of diameters of actual anchor spacing E

= no. of diameters of actual edge distance The above equation is very I

conservative when compared to test data.

Angular Alignment For anchors installed within 150 of plumb, no reduction in anchor capacity was made. See Attachment E i

j for further information on angularity.

Nut Engagement Since so few cases of these types of and Loose Nuts concerns were found, they were addressed on a case by case basis.

j See Attachment E for further j

information.

f Notwithstanding the conservative analysis techniques and the conservative sothods used to reduce capacities for installation concerns, most su have factors of safety well in excess of the acceptance limit of 3. pports l

j i

l l

l l

0199d D2 f

==: : =:

2

O Attachment E - Significance of Installation Concerns This attachment addresses the sampling program ffndings for each type of concern. As described in Attachment D, anchor capacities were reduced to account for most of these concerns. The supports were then evaluated using reduced anchor capacities and were found to have factors of safety exceeding 3 in every case. This result, by itself, indicates that the concerns have not reduced safety margins to unacceptable levels. However, further conclusions can be made regarding the specific concerns.

2-3/4" 1.ong Anchors In the' period prior to January 1975, a total of approximately 14,000 of the shorter (2-3/4" in length) Hfiti Kwik-Bolts were bought by the electrical contractor. The total number of expansion anchors used in the Class I raceway supports was approximately 125,000. Some of the shorter anchors were used in Class 1 raceway supports. The concern with these anchors is that due to their short overall length, their embedmont may not have been sufficient to maintain an adequate safety factor. These short anchors were found in 10 of the 98 randomly selected supports. Twenty-two adjacent supports were also sampled in which 6 supports were also found to contain the short anchors.

Every support, in both the random sample and in the adjacent support sample, that contained a short anchor was evaluated using the actual embedment to reduce the anchors's capacity. A factor of safety greater than 3 was conffreed in every case. As reported in the PGand January 27, 1984 letter, the margin in the design of the raceway supports is large. The effect of relatively few short anchors on the overall safety was determined to be negligable. This conclusion has been confirmed by the random samp11ng program.

Embedmont Fourteen of the 98 supports sampled contained anchors that did not have the embedmont speciffed on Drawing 054162. Ten of these supports were those containing the short Hiltf Kwik-Bolts. In most of the cases, the embedment was'within.3/16" of the required embedment so the resulting reduction in pullout capacity was relatively small. Nevertheless, in all cases factors of safety greater than 3 were conffreed.

Spacing Of the 98 supports sampled,17 had anchors spaced closer than 10 diameters (10d) from anchors in other supports. Most of these spacings were in the 7d to 9d range. Even after using the conservative reduction equation stated in Attachment D, all such cases were confirmed to have a factor of safety in excess of 3.

I 0199d E1

~

....e-.

se,.

r -mee wo wO

• + ^ * " " ' * " * *

~

. - = -

Also, 72 of the 98 supports were found to contain anchors spaced closer than s

10d from another anchor in the same support. The inter-support anchor spacings are frequently less than 10d because manufactured fittings with 4

prodrilled holes are comonly used in the raceway support designs.

These conditions had already been accounted for in the design calculations by neglecting one anchor or derating the capacity and they do not constitute deviations from design requirements.

Edge Distance i

Two supports contained anchors spaced less than 5 diameters from concrete edges or embedded items. Both of these cases were evaluated and were found to -

be acceptable (factor of safety much greater than 3).

Angular Alignment Eleven of the 98 sampled supports contained anchors installed between 50 and i

150 out-of-plumb. In PGandE's January 27 letter, a discussion on the effects of anchors installed up to 150 out-of-plumb was presented.

All available test data indicates that anchors installed within this tolerance perform satisfactorily.

As a follow-up to the testing of misaligned anchors referenced in the January 27 1etter, the testing of 1/2" diameter and 3/4" l

diameter Hilti Kwik-Bolts is now complete. The test report is currently being written. These tests demonstrated that there is no reduction in ultimate capacity for anchors installed within a nominal 100 tolerance (the tested angles ranged from 90 to 12o).

j In the sampling of the " adjacent" supports, one support was found to contain 2 anchors instal ed at angles just over 150 (approximately 16o or 170).

This support has a factor of safety exceeding 10 and was, therefore, judged to be acceptable.

Miscellaneous Irregularities As expected, a few supports were found to contain anchors with miscellaneous irregularities. All of these anchors were found acceptable for the reasons described below, Loose nuts were found on four anchors.

In one case, the loose nut o

occurred in an anchor installed in a base connection containing two anchors. 'The design required only one anchor in the connection. As one anchor in the connection was installed with no deviations, the loose nut on the other anchor is of no concern.

In a similar case, one of two anchors in the connection did not have a nut. As the design only required one anchor, this condition is also acceptable. The other two i

cases were also evaluated and judged to be satisfactory even with one anchor nut slightly loose.

I i

i

~

1 0199d E2

=====ev e-mue=>.-

me<,speg>-eg..--

--=-e--e.

er

-6, a

I

'o factor of safetOne anchor was found to be one' thread shy of full be acceptakte. y on this anchor exceeded 10 and was, therefore, j.

nut engagement The udged to One anchor nut was observed to be damaged o

two-anchor connection whose design required only oThe acchor was In a related, but separate investigation, the electric l ne anchor.

inspection records were reviewed to identif straightened to improve alignment, and (2) y cases in which anchors were (

a contractor's QC torqued to improve nut engagement.

cases were found (in ther approximatelyIn situations invo anchors inspected in the recent random sampling gnment, only 11 125,000 anchors addressed in the showed signs of straightening.

Of the nearly 400

, only one anchor realigned by hammering, the infrequency of occurrance elimiEven if concern.

nates this as a been torqued to improve nut engagement.The results of th installation of approximately ses in which anchors had occurred in less than 1/2 of 1 per, cent of the anchorsThe in 125 000 expansion an hc ors. Thus torquaing significant effect on the overall safety margin in Thisclearlyhasno systems.

anchors deflect between 1/2* and 1" before their ultim support reached.

show that the

.Thus, torquing the bolts to enga s rengths are would deflect the bolt approximately 1/8")ge one or two more threads, (which would not be cause for any concern.

As indicated earlier, raceway support systems are desig factors of safety.

is evident that the factors of safety built into thFrom the results of th are large enough to tolerate an occasional irregularity ie raceway sup

, it installation.

\\

n expansion anchor

-o o

0199d 6

E3

_--- - -- 3 ;3

~

• trq,g9 3-Qy 4 Q '2.C8S)Ib COJYY

@f. l 7 k lTi gl7IP) i PACIFIC GAS AND E LE C T RIC C C M PANY n state svaert. saa ramacisco cauronnia seios re w =ont <4:s> ret.4r::

gg February 7, 1984 PGandE Letter No: ICL-84-048 Mr. John 8. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 SSER 21 - Allegations 25, 58, and 96 Concrete Expansion Anchors

Dear Mr. Martin:

As a result of the NRC exit interview on January 19, 1984 at Diablo Canyon, and the NRC review of PGandE letter DCL-84-031, dated January 27, 1984, only two issues remain to be resolved regarding the allegations listed in SSER 21 on.concreta expansion anchors. These issues are (1) review of H. P. Foley

. Company Procedure QCP-9 that governs installation of expansion anchors and (2)

PGandE expansion anchor sampling program.

With respect to the first issue, the review of QCP-9 is complete and the results are presented in Enclosure 1.

For the second issue, the NRC Staff and

. PGandE had agreed that a successfully executed fi. eld sampling program would add significantly to the confidence that the expansion anchors used in the electrical raceway supports are adequately installed. Enclosure 2 contains a co'py of the instructions that were prepared for this sampling program. The sa=pling program has been initiated and is expected to be complete en February 8, 1984. Evaluation of the data will then be performed. A report to the NRC, containing the results of the sampling and of the data evaluation, is scheduled to be submitted by February 13, 1984.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the er. closed addressed envelope.

Sincerely, J. O. Schuyler l

by J. D. Shiffer Enclosures cc:

T. W. Bishoa N. E. Schierling 0%0%

9 "

_ -. E.. J Y

-nimiL.

PGandE Letter No: DCL-84-048 l

ENCLOSURE 1 1

FOLEY QA PROCEDURES All of the electrical raceway construction at Diablo Canyon has been performed by one contractor, the H. P. Foley Company. Foley's construction procedures i

address many components of raceway installation. One of these components is i

expansion anchors. The portions of Foley's procedures that govern i

i installation of expansion anchors have never been revised in a way that i

significantly altered the installation process. The attached table tracks the pertinent installation requirements through the revisions of Foley's i

procedures, from their first issuance in 1973 to those in use today. It i

i should be noted that most of the procedure revisions pertain to aspects of raceway construction that do not affect expansion anchor insta1Tation.

However, the revisions affecting expansion anchors show increasing attention to QC verification of the expansion anchor installations, which paratief s the nuclear industry's increased awareness in the benefits of anchor inspections.

In a recent NRC site inspection, the QC expansion anchor inspection records were reviewed. These records indicated cases in which the anchors were (1) s+.raightened to improve alignment and (2) torcued to faprove nut engagement.

As stated in PGand's letter DCL-84-031, datec January 27, 1984, the frequency of these occurrences is so low that there,would be no significant effect on the overall safety of the raceway. support system..To further quantify the rate of occurrence, the QC inspection records are being reviewed to identify all rec.orded cases of bolt straightening after installation and torquing to taprove nut engagement. The results of this review will be analyzed to verify that the frequency of occurrence supports the position that no further action is required. The results will be reported to the NRC by February 13, 1984.

Should we determine additional action is necessary, it will be included in the report.

In suenary, Foley Company did not make any significant changes in the expansion anchor installation requirements. This procedural consistency helps maintain consistency in installation. QC inspection was increased over the years, yet no significant changes in the installation proceduces were found necessary. Thus, the procedures governing raceway expansion anchor installation at Diablo Canyon have proven to be consistent and adequate.

0131d

=

~-.

d i

ATTAC N NT A TO ENCLOSURE 1 1

il-Date Precedure Number and Title Description J i.

12/28/73 IDR-1, Quality control Procedure This procedure required inspection of conduit and for inspection and Documentation cable trays after installation, but did not lji of Raceways specific 11y address supports or expansion anchors.

i 7/16/74 QCP-9 Rev. 1, Quality Control This procedure contained the same requirements as d

Procedure for Inspection and IDR-1, except that an inspection block for supports Documentation of Raceways was added to the inspection form.

(was procedure IDR-1) 1 l0 2/24/75 QCP-9, Rev. 2 Quality Control Installation acceptance requirements for expansion j

Procedure for Raceways, Junction anchors were added to the procedure. The following and Teminal Boxes acceptance requirements for expansion anchors were

!{

specified:

4 Acceptable anchor types: McCulloch Kwik Bolts,

!]

Phillips Red Head Wedges, Hilti Kwik Bolts

- Center-to-center spacing:

12 diameters lj

- Edge distance: 6 diameters

- Minimum embedmonts: Anchor Stre Nin. Esbedment ji U4"-dia.

Z" 3/8"-dia.

2-1/2" 1/2"-dia.

2-1/2" i3 5/8"-dia.

2-7/8" 3/4"-dia.

3-1/2"

!E

.l In addition, an inspection block for expansion l ',

anchors was added to inspection forms.

5/6/75 QCP-9, Rev. 3 Quality Control Changes did not affect expansion anchors.

i Procedure for Raceways Junction jj and Terminal Boxes d 't l

5/30/75 QCP-9 Rev. 3. Procedure Changes did not affect expansion anchors.

j, Change Notice 1 (PCN 1)

-1~

0131d i

i

i

~

e ATTACl#ENT A TO ENCLOSURE 1 Data Precedure Humber and Title Description n

7/21/75 QCP-9. Rev. 3. PCN 2 Changes did not affect expansion anchors.

7/15/75 QCP-9. Rev. 3. PCN 3 Changes did not affect expansion anchors.

[

7/10/75 QCP-9. Rev. 3. PCN 4 Changes did not affect expansion anchors.

i 1

7/17/75 QCP-9a Rev. 3. PCN 5 Changes did not affect expansion anchors.

9/29/75 QCP-9. Rev. 4. Quality control Thefollowin!1ationrequirements: additions were made to the e M.

Procedure for Installation of anchor insta i

Raceways. Junction and Terminal Boxes

- Edge distance measurements were clarified requiring consideration of concrete corners and embedded items.

n

- Spacing between good and abandoned anchers/ holes

}

was specified as 1" clear.

1/23/76 l

QCP-9. Rev. 4. PCN 7 Changes did not affect expansion anchors.

(PCNs to (CP-9. Rev. 4 start with no. T)

~

5/6/76 QCP-9. Rev. 4. PCN 8 Changes did not affect expansion anchors.

Phillips Stud' anchors were added to the list of 6/29/76 QCP-9. Rev. 4. PCN 9 acceptable anchor types.

8/9/76 QCP-9. Rev. % PCN 10 Edge distance measurements were clarified requiring j~

chaefers to be considered as concrete edges.

!'Ii 11/9/76 QCP-9. Rev. 4. PCN 11 Changes did not affect expansion anchors.

l!

i 12/15/76 QCP-9. Rev. 4. PLN 12 Changes did not affect expansion anchors.

j 12/30/76 QCP-9. Rev. 4. PCN 13 Changes did not affect expansion anchors.

)1

- l!

0131d e

4

4 1

ATTAcitENT A TO ENCLOSURE 1 i

Date Procedure number a'nd. Title Description 3/4/77 QCP-9. Rev. 4. PCN 14

~ The followinti additions were made to the expansion anchor instalation acceptance requirements:

i..

- The use of Phillips Stud anchors was 11mited to i

sizes up to 3/4" diameter.

- The 12d spacing requirement was clartffed to mean 12 times the diameter of the larger of the two sdjacent anchors.

i

- Empty holes within 4.5 diameters of a good anchor were required to be filled with grout, i

In addition, quality control inspections were i

required to be performed on a pertodic basis.

4 11/23/77 QCP-9. Rev. 4. PCN 15 Changes did not affect expansion anchors.

2/15/78 QCP-9 Rev. 4. PCN 16 Changes did not affect expansion anchors.

4/7/78 QCP-9. Rev. 4. PCN 17 In this PCN. the following changes were inadvertently made regard < ng spacing and edge distance requirements. (These changes were mada "

due to a misinterpretation of the engineering requirements on drawing 054162 and were promptly corrected - see PCN 19. This is of no concern because almost no raceway was constructed during j

the period that reduced spacing was allowed):

- Acceptable spacing revised from 12d to 6d.

- Acceptable edge distance revised from 6d to 3d.

Jl Also in this PCN. the acceptable clear distance 4

between good and abandoned holes was reduced from l.-

1" to 1/2".

i a

I i{

ij

~ {'

0131d I

I ATTACiOEhT A TO ENCLOSURE 1 f

Date Procedure Number and Title Description l

6/8/78 QCP-9. Rev. 4. PCN 18 In this PCN, an anchor inspection form was added which provided verification blocks for the following items:

- Anchor type

- Ant. hor size

- Anchor hole diameter and depth

- Length of bolt exposed after setting

- Length of bolt ex msed after torquis.g l!

- Anchor not more tian 50 misaliguient (with

}-

respect to perpendicular) a 8/11/78 QCP-9 Rev. 4 PCN-19 Spacing requirements were changed back to the 1

correct values in this PCN:

j

, Acceptable spacing returned to 12d.

i l

- Acceptable edge distance returned to 6d.

1,

Also in this PCN, anchor spacing was clarified to include anchors installed in Unistrut members.

1 l

10/2/78 QCP-9 Rev. 4. PCN 20 Changes did not affect expansion anchors.

10/18/78 QCP-9, Rev. 4. PCN 21 Changes did not affect expansion anchors.

1/4/79 QCP-9.'Rev. 4. PCN 72 Changes did not affect expansion anchors.

j j 5/30/80 QCP-9, Rev. 4. PCN 23 Changes did not affect expansion anchors.

i l

11/25/80 QCP-9 Rev. 4. PCN 24 Changes did not affect expansion anchors.

I 1

a e

i 0131d

L ATTACHE NT A TO ENCLOSURE 1 5

l Date Procedure Number and T1tle Deseript1on 6/24/81 QCPE-9. Rev. 0. Qual 1ty j j Control Procedure for In thfr revis1on the fallowfng addit 1ons and clariffcations were made:

Installation of Electrical Raceways. Junction and

- Acceptable anchor types were revised to Terminal Somes "Phillip: Red Head Stud anchor or (was QCP-9) approved equal."

(was QCP-9)

- 105 QC Inspection of anchors was i

required.

3 l

For new installations, the followfag requirements j

were added:

II

- At least 1 bolt thread must be exposed l

- A 12" minimum distance from pipe supports above its nut.

i aust be maintained.

i l l

8/10/81l QCPE-9. Rev. O. PCN 1 Changes did not affect expansion anchors.

1 11/9/81 QCPE-9. Rev. O. PCN 2 Changes did not affect expansion anchors.

5/6/82 QCPE-9. Rev. O. PCN 3 Changes did not affect expansion anchors.

5/6/82 QCPE-9. Rev. O. PCN 4 Changes did not affact expans1on anchors.

5/6/82 QCPE-9. Rev. O. PCN 5 Changes did not affect expansion anchors.

a ii l

6/15/82 QCPE-9. Rev. O. PCN 6 Changes did not affect expansion anchors.

6/17/82 QCPE-9. Rev. O. PCN 7 Changes did not affect expansion anchors.

7/16/82 QCPE-9. Rev. O. PCN 8 Changes did not affect expansion eachers.

O 4 >

G 0131d 3

l ATTAC K NT A TO ENCLOSURE 1 s

Date Procedure Number and Title Description h

7/15'82 QCPE-9. Rev. O. PCN 9 Changes did not affect expansion anchors.

/

8/18/82 QCPE-9. Rev. O. PCN 10 Changes did not affect expansion anchors.

4/15/83 QCPE-9. Rev. O. PCN 11 Changes did not affect expansion anchors.

i 4/15/83 QCPE-9. Rev. O. PCN 12 Changes did not affect expansion anchors.

5/2J/83 QCPE-9. Rev. 0. PCN 13 Changes did not affect expansion anchors.

i QCPE-9. Rev. O. PCN 14 This PCN was not issued.

6/28/83 QCPE-9. Rev. O. PCN 15 Changes did not affect expansion anchors.

l' 8/8/83 QCPE-9. Rev. O. PCN 16 Changes did not affect expansion anchors.

I 8/5/83 l

QCPE-9. Rev. O. PCil 17 Changes did not affect expansion anchors.

'I;!

9/23/83 QCPE-9. Rev. O. PCN 18 Changes did not affect expansion anchors.

i!

I; 9/23/83 QCPE-9. Rev. O. PCN 19 Changes,did not affect expansion anchors.

l!

9/12/83 QCPE-9. Rev. O. PCN 20

. Changes did'not affect expansion anchors.

L 9/19/83 QCPE-9. Rev. O, PCN 21 Cha' ages did not affect expansion anchors.

i 11/7/83 QCPE-9. Rev. 1. Quality Control

• Expansion anchor requirements were deferred to i-Procedure for Raceways. Junction QCP-9. Rev. 5 (QCPE-9 no longer addresses expansion

.l and Terminal Saxes anchors),

p..

!l e

II j

l 0131d 8

t

I t

u l

ATTACHENT A TO EELOSURE 1 Date Procedure W and Title Descriptton

~ ;

11/7/83 QCP-9 Rev. 5. Quality Control QCP-9. Rev. 4, addressed all aspects of raceway l

Procedure for Installation and installation. QCP-9, Rev. 5. only addressed

'i Inspection of Stud and Shell expansion anchors (for use in raceways or any other j

Concrete Expansion Anchors work done by Foley).

(QCP-9 Rev. 5 was l

l 1ssued 4/13/82 for general (CP-9, Rev. 5 requires detailed inspections and use) cocumentation for new work.

r i

l l

l h

?

i I

s t

.L, 1

i i

i;,

7 l

0131d

e PGandE Letter No. DCL-84-048 ENCLOSURE 2 -

INSTRUCTIONS FOR SAMPLING CONCRETE EXPANSION ANCHORS AMM ALLED IN ELECTRICAL RACEWAY 5UPPORT5 1.0 General These instructions shall be followed to obtain data from a random sagling of the concrete axpansion anchors used in the Diablo Canyon Unit i electrical raceway supports. Questions or modifications regarding these instructions shall be discussed with Project Engineering or their on-site representative.

2.0 Sagle Size The data defined in Section 3.0 shall be recorded for 100 raceway supports. Attachment A prJvides a list of 200 randomly selected raceway supports from which the samples shall be taken. Starting with the first support on the list and proceeding sequentially down the list each-support shall be located. If the support cannot be found, does not contain any concrete expansion anchors, or if the support is f

inaccessible, it shall be so noted on a sampling. form (Attachment B) and 1tng shall be continued with the next support on the list. When data o9n00 supports have been recorded, the sag ling shall be terminated. If more support numers are req' ired. Project Engineering shall be contacted.

u 3.0 Recording Data The form provided in Attachment B shall be used for recording data',

outlined below, that shall be compiled for each support.

A) The sample number and the. support number (from Attachment A) shall be recorded.

B) The date that the support was instillod shall be recorded. If the support was subsequently modif fed, the data of the original installation shall be used. If the actual date is not readily available it should be specified if installation occurred before or after January 1975.

C) The quantity of expansion anchors used in the supports shall be recorded. When more than one anchor has been used, a simple sketch of the support shall be made.. Each anchor's location within the support shall be noted on the sketch and shall be given a sequential number.

.l.

0131d eg-

,,_ ~ -%-,-,,,,.-e--_,,,__---,-,-.-i-.

-,rer--w--yte m v

i-w-4

.e r--s-k-seya.-

2

-m

--.-3

-.=v-+i

-.e

-y.-

e g----

,g-s n

--1-.

i For each expansion anchor in the support, the following data shall be recorded. The individual anchor data shall correspond to the anchor numbering sequence established on the support sketch prepared in Section 3.C. above.

D) The anchor diameter (1/2" diameter. 5/8" diameter, etc.) shall be recorded.

E) The anchor type (wedge type. Phillips Stud type or shell type) shall be recorded.

F) The anchor embedment (for stud or wedge type anchors only) shall be determined by using the following method:

F.1)

The overall anchor length, determined by UT measurement, shall be recorded.

F.2)

The exposed length of anchor that projects out beyond the concrete surface shall be recorded.

F.3)

The embedmont, determined by subtracting the projecting length (F.2) from the overall length (F.1), shall be recorded.

G)

The angular alignment of the anchor (the anchor of the axis of the anchor with respect to perpendicular) shall be recorded..

H)

The distance (spacing) to the closest

• a'djacent expansion anchor, whether in the sampled support or in any other adjacent support, shall be recorded. If the distance is greater than 10 bolt diameters, sisply state:

10d.

l l

I)

The (edge) distance to the nearest concrete edge (chaefer),

i embedded plate or other embedded item shall be recorded. If the distance is greater than 5 bolt diameters, simply state:

5d

' J)

The engagement of nuts (for stud or wedge type anchors only) shall be recorded, noting the number of exposed threads on the anchors.

K)

It shall be determined if the anchor has been tightly installed.

Tight is defined as being unable to turn the nut (or bolt in a shell anchor) by hand.

4.0 Sampling of Adjacent Supports If one or more anchors in a sampled support has an overall length of 2-3/4" or less (as determined by UT examination per section 3.F.1) and adjacent support along the conduit run, selected from either side of the 1e support, shall be added te the sample set. This adjacent support s9ha 1 be inspected in accordance with Section 3.0, above, and shall be l

1

~

l 0131d

=9 ene w w 9

,.-.,,.-,,.-,,..._-..,m.

,p.

.....,w.m,

,, _,,, __,.,,.,-a-e-

a - *-

,-e+-w-i.-w-wwwe.-wwwwww=--

clearly identified, on its data form, as an addition to the original sasuple.

If the adjacent support also contains a 2-3/4" long anchor, a second adjacent support shall be added to the sample set as described above.

5.0 As-Built Sketches As-built sketches of the sampled supports shall be prepared when installation deviations, as defined below, are found. The as-built sketches shall be prepared in accordance with " Minimum As-Built Requirenents" which was attached to December 13, 1983 setting minutes (Chron No. 040424)

As-built sketches shall be prepared when any of the following deviations are found:

(a) the embedment, determined per Section 3.F.3, is less than that specified on drawing 054162 (e.g., less than 2-1/4" for 1/2" diameter anchors)

(b) the angularity, determined per Section 3.G. is greater than 50 (c) the spacing, determined per Section 3.H is less than 10d. In addition to the sampled support, any other support (s) involved in the spacing deviation shall also be as-built.

(d) the' edge distance, determined per Section 3.I, is less thazn 5d.

l 6.0 Quality Assurance All data compiled for this sampling shall be recorded on the forms provided in Attachment B and shall be signed by the originator and a checker.

The UT machine shall be calibrated prior to use.

l 7.0 Data Transmittal All data sheets and as-builts compiled in this sampling program shall be expeditiously transmitted to Project Engineering, Attention: J. K. McCall.

e m

O 0131d

• • • NN

,m-mw---

~-.ww_

. mi no +-

--e.-

ATTACHENT A TO. ENCLOSURE 2 Sample Support Support Conduit '

No.

No.

Type No.

1.

CSR-127-4-13 5-296 K7887 2.

K-73-2-12 5-19A E8591 3.

C-140-9-23 5-149 K2704 4.

A-140-3-39 5-48 K2652 5.

K-140-3-31 5-596 K9796 6.

8-104-5-35 5-415 KA730 7.

K-115-3-34 5-20 KT571 8.

GE/GW-140-4-857 5-102 K7353 9.

GE/GW-140-4-370 5-288 K6592 10.

H-115-5-27 5-288 K8393 11.

GE/GW-115-2-104 5-115 K6097 12.

GE/GW-115-3-202 5-7 K6310 13.

TG8-140-2-3 5-197 KA109 14.

GE/GW-140-6-61 5-20 K6132 15.

GE/GW-140-4-740 5-415 K5769 16.

K-115-4-157 5-19A K9108 17.

G-140-7-243 5-48 K1993 18.

GE/GW-140-7-137 5-19A KT573 19.

G-140-8-541 5-19A KX208 20.

• GE/GW-140-4-1020 5-87 KT152

21. -

K-85-5-32 5-194

• K6679 22'.

K-115-4-104 5-289 KH323 23.

C-104-10-12 5-149 K2724 24.

A-119-5-13 5-415 K2635 4

25.

C-104-2-15 5415 K4012 26.

J-115-5-8 5-20 K8066 27.

GE/GW-115-2-48 5-18 K6099 28.

D-104-2-31 5-243 K2415

' 29.

K-140-1-155 5-19A KT879 30.

H-128-3-237 5-19B K7788 31.

GE/GW-100-1-108 5-198 K6114 i

32.

H-73-5-4 5-87 KK617ny 33.

K-100-1-191 5-252 K9242 34.

L-140-4-33 5-20 K8212 35.

G-140-4-45 5-102 K9507ny 36.

CSR-127-3-461 5-88 K9759 37.

E-140-5-13 5-20 K7002 38.

A-107-6-32 5-454 BTA201

. 39.

FE/FW-140-1-17 5-19A K5776 40.

GE/GW-115-2-77 5-18 K6397 41.

A-107-12 5-172 K2449 42.

GE/GW-140-6-206 5-172 K6769 43.

H-128-1-95 5-104 ERAna 44.

K-154-1-350 5-243 KV160

. 0131d

f ATTAC) DENT A TO ENCLOSURE 2-I Sample Support Support Conduit No.

No.

Type No.

45.

E/GW-15-3-124 S-18 K6392 46.

E/GW-15-2-282 5-415 K8770 47.

CSR-127-6-431 S-198 K7911 48.

J-115-5-3 5-20 K8066 49.

CSR-127-5-297 S-19A KT366 50.

F-140-1-58 S-41 XX895 51.

G-117-2-(68) 5-197 VKX394 52.

CSR-127-3-391 5-19A KT358 53.

GE/GW-140-4-817 S-19A KT148 54.

E/GW-115-4-58 5-415 KT598 55.

GE/GW-115-4-48 5-85 KT286 56.

E/GW-140-4-797 5-243 K5779 57.

CSR-127-5-76 5-102 KT069 58.

CSR-127-4-310 5-19A K7137 59.

K-100-1-54 S-183 K9336 K5275 60.

D-140-5-54 5-171

' K5252 61.

D-140-5-33 5 415 62.

K-185-1-24 5-19AK K6843 63.

K-154-1-324 5-87 KV106 64.

GE/GW-115-4-361 5-202 K8496

65. -

H-128-11-43 5-20 K8873 66.

K-11'5-4-133 5-19A K9107 67.

A-107-4-39 5-372 K2339 68.

A-140-4-1 5-415 K2859 69.

G-117-1-638 5-202 KX616 70.

GE/GW-115-3-127 5-288 KT319 71.

CSR-127-4-11 5-87 K2449

- 72.

K-115-2-23 5-19A K3853ny 73.

L-140-7-106 5-202 _

KT967ny 74.

A-107-11-19 S-58 K2641 75.

GE/GW-115-2-141 5-387 K7307 76.

K-115-3-148 5-314 KH323 77.

K-140-9-135 5-23 KH569 78.

K-115-1-15 5-20 KT589 79.

G-117-1-106 S-19A KX525 80.

L-140-2-12 5-20 K8256 81.

K-140-1-156 5-289 KT510 82.

A-107-4-27 5-20 K2480 83.

E/GW-140-6-117 5-288 K6429 5-88 K811 St.

CSR-127-5-175' 5-243 K8235 86.

J-115-1-56 i

86.

L-140-4-71 5-20 K3281 87.

CSR-127-5-196 5-121 KT003 88.

H-86-1-42 5-288 KT959

-t-8131d v-v-

yw w.y w-w

-,v---

,y---

wy.m re-,,y e.----,e-.--------.,,,--.,,m.---

--aw-v-,,

-.,,. + - - - -, -. - - - - -,,, -, - - -. - - - - - - - -. -

ATTACHENT A 70* ENCLOSURE 2 Sample Support Support Conduit No.

No.

Type No.

89.

CSR-127-3-387 S-140 K8615 90.

GE/GW-140-4-372 S-288 K6532 91.

K-140-9-119 S-23 KH545 92.

D-104-5-12 5-195 K4879 93.

A-107-3-3 5-7 K2408 94.

GE/ % 140-6-134 5-20 KT573 95.

A-107-4-37 S-392 K2339 96.

A-119-8-1 5-20 K2453 97.

H-128-11-8 S-242 K8725ny 98.

GE/GW-100-2-12 5-87 K6764 l

99.

G-140-6-885 5-102 XX991 l

100.

J-140-4-141 5-87 KK713 l

101.

L-165-2-53 5-20 K8471. K8469ny 102.

H-115-2-53 5-80A K6014, FNED, FNAD, FMEC, FNAC 103.

H-115-3-134 S-183

K7107ny,

K7108ny,

- I

K7109ny, K7110nv 104.

GE/GW-140-4-886 5-87 K8764 105.

CSR-127-6-96 S-19-8 K6510nv 106'.

CSR-127-5-241 5-438 TRAny, KRO15ny 107.

F-140-5-20 5-20 KX498 108.

K-154-1-3006 5-87 K6515 109.

D-104-5-84 5-20 KX4846 110.

H-115-1-48 S-85 KT781

~111.

D-104-5-95 5-20 K5049 112.

GE/ @ 140-6-113 S-19-A K6429 113.

J-115-1-63 5-20 K8237 114.

J-115-2-21 5-143 X8098 115.

A-85-5-12 5-115 K2631 116.

F-165-6-(10)

S-19-A FX460 117.

K-100-6-76 5-19-8 K9786 118.

G-140-7-257 S-20 K1503 K1504, KX875ny 119.

CSR-127-4-453 S-87 K145H 120.

K-140-3-68 S-288 K6094 121.

CSR-127-7-125 5-91 K7246 122.

G-117-2-31 5-415 K1541ny, XX462 123.

FE/FW-117-2-15 124.

K-140-4-187 ~

S-415 K5907 5-264 E9913. K9799, K9982 e

e 0131d

ATTACHMENT A TO ENCLOSURE 2 Sample Support Support Conduit No.

No.

Type No.

125.

GE/GW-140-1-69 S-104

TARny, KS643ny, K6120 K6121. KT062 126.

H-115-5-83 S-19A K7130nv 127.

X-140-9-166 S-172 KH550 128.

FE/FW-140-1-55 S-415 K5839 129.

CSR-127-5-399 S-19-A KK303 130.

CSR-127-5-137 S-288 KT765 131.

CSR-127-6-168 S-69 KT777 132.

8-104-10-24 5-415 K3214ny 133.

CSR-127-5-221 5-286 K7221 134.

G-140-4-(11) 5-214 KX211 135.

G-140-1-92 S-19-A XX678ny, KX498 136.

CSR-127-5-400 S-97 KK300 137.

K-140-3-31 S-596 K9796 138.

FE/FW-140-1-4 S-19-A K5774 139.

H-128-2-145 5-202 K5969 140 J-115-10-71 5-370 KK807ny 141.

K-115-4-161 5-19-A K3853 142.

CSR-127-6-50 5-19-8 K6503 143.

Hi128-3-8 S-114

KK528ny, K7006ny, K7016, K7010 144.

G-140-7-510A S-102 KX050nv 145.

F-117-6-17 S-618 EJCA 146.

FE/FW-117-1-281 S-231 KT610 147.

K-100-2-21 5-20 KH340. KH546 148.

K-140-9-46 5-87 KH532

'149.

F-165-3-711 5-415 K1428 150.

GE/GW-115-3-210 S-172 K5091 151.

K-154-1-126 S-19A KV068 152.

F-140-2-162 5-214 K1729 153.

GE/GW-140-6-114 S-19-A K6429 154.

J-115-9-13 5-387 K8931 155.

H-128-5-51 5-202 K7660ny, K7493,

K6585ny, 16633ny 156.

A-140-6-22 5-19-A K2855ny 157.

GE/GW-100-1-60$

S-87 K8909ny 158.

GE-GW-140-5-163 5-243 K8530 159.

F-165-4-764 -_

S-20 EX864, KX865 160.

CSR-127-6-25 5-19-8 KT830nv e

0131d

_ 2 u :== __._ =_- -

= _ _ _._ _ _ 1 __ _. _.

[

o j

1. t.

)

l._

ATTAC)OENT A TO ENCLOSURE 2 Sample Support Support Conduit No.

No.

Type No.

161.

K-185-1-22 5-19-A K6843 162.

GE/GW-140-4-370 5288 K6592 163.

K-85-4-95 5-19-A K6024 164.

GE/CW-140-4-884 S-19-8 K6227ny, K7250 165.

P-115-4-45 5-576.

K6748 166.

CSR-127-7-415 S-19-A K7168 167.

GE/GW-140-4-159 5-20 KT625, K6494 K6235ny 168.

H-115-4-3 5-20 KT630 169.

GE/GW-115-1-168 5-20 K6543 170.

C-104-3-2 5-216 K3904 171.

8-104-16-10 5-149 K2415 172.

C-104-10-12 5-149 K2724 173.

K-115-4-4 5-410 KK524 174.

G17.5-4-48 S-172 K1093 175.

E/GW-140-1-304 S-183 TARFny, K6001, K4312 176.

GE/GW-100-1-276 5-243 K7191 177.

CSR-127-5-58

$=243 KT538ny l

178.

.H-128-3-180 5-289 KK305 179.

GE/GW-l'O + t29 5-20

K5562ny, l

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KT124 180.

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F-140-2-(33) 5-214 K1729 182.

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GE/GW-140-4-1171 5-102 K7266 185.

G-140-6-(11) 5-20 KX572 184.

K-140-1-142 5-20 KT940 186.

CSR-127-3-230 S-288 K8657ny 187.

2K-100-2-68 5-7 K9440 188.

CSR-127-3-545 5-19-A K7159 189.

K-154-1-346 5-87 KV170 190.

CSR-127-7-347 5-83 K7952 191.

CSR-127-3-451 5-19-8 K7866 192.

GE/GW-140-4-1132 5-202 K2894 193.

GE/GW-100-1-546 5-202 K3474ny 194.

E-GW-100-1-565 5-19-A K4143nv 195.

J-115-1-63 5-20 K8237 196.

FE/FW-117-1-380 5-415 K5834 197.

K-85-4-161 5-87 K8897 198.

GE/GW-140-4-822 -

5-19-A K8770 199.

A-119-5-25 5-288 K2773 200.

GE/GW-140-7-193 5-102 KT169. K5763

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3 ATTACl#ENT 8 TO ENCLOSURE 2

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Expansion Anchor Sampling Data Form

$4FPORT DATA A) Sample No.

Support No.

If data has not been compiled, specify why not:

B) Date Support Installed:

C) Quantity of Anchors in Support:

Sketch Numbering the Individual Anchors Attached?

Yes No ANCHOR DATA Anchor #1 Anchor #2 Anchor #3 Anchor #4 D)

?.nchor Diameter E)

Aachor Type F.1) Overall Length F.2) Exposed Length 7.3) Esbedded Length G)

Angularity H) - Spacing I)

Edge Distance i

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Nut Engagement (specify no. of exposed threads) l K)-

Tightness (specify tight er loose) i

$1GNATWtES Originator (s)

Checker (s)

Date(s)

Data (s)

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• !['-r, UNITED STATES o,,

g NUCLEAR REGULATORY COMMCSION g

c e REGION V 0,

,a7 146o MARIA LANE. SUITE 210

,o WALNUT CREEK. CALIFORNIA 94596 DEC 121983 e.?

MEMORANDUM FOR:

G. Knighton, Chief, Reactor Licensing Branch r,.

It No. 3, NRR 4

H. Scherling, Diablo Canyon Project Manager, NRR 4

P. T. Kuo, Structural and Geotechnical Engineering Branch, NRR THRU:

D. F. Kirsch, Chief, Reactor Projects Section No. 3 FROM:

P. J. Morrill, Reactor Inspector, RV

SUBJECT:

DIABLO CANYON - ALLEGATIONS CONCERNING ERRORS IN DESIGN / DOCUMENTATION OF SAFETY RELATED SYSTEMS, STRUCTURES, AND COMPONENTS The purpose of this memo is to forward my feeder report from the follow-up of items number two and seven of the subject allegations (enclosed). Should you have questions or comments please contact me at FTS 463-3740.

Il d

i P. J. Morrill Reactor Inspector

Enclosure:

As stated cc:

(w/ enclosure)

T. Bishop, RV D. Kirsch, RV #

P. Morrill, RV M. Mendonca, RV l

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ENCLOSURE DIABLO CANYON - FOIL 0W-UP OF ITEMS TWO AND SEVEN REGARDING AILEGATIONS CONCERNING ERRORS IN DESIGN / DOCUMENTATION OF SAFETY RELATED SYSTEMS, STRUCTURES, AND COMP 0NEETS 4

ExaminationsconductedOctober25andNovember3,1983atPacifpGasand Electric Company offices in San Francisco, California

{A) ALLEGATION NUMBER TWO:

GENERAL: Allegation number two states, " Safety related equipment has inadequate / untraceable documentation". In general, safety related equipment requires documentation to (1) demonstrate that the equipment is qualified to meet its' intended purpose and (2) provide information for maintenance and operation. Consequently, the inspector decided to examine the licensee's systems used to document the qualifications of safety related equipment, examine the resolution of licensee identified documentation problem areas; question licensee personnel as to documentation problems which they were aware of,' and examine a sample of licensee records which document equipment acceptance or qualifications to verify the adequacy of this documentation.

i EXAMINATION: The inspector examined the licensee's project nonconformances identified in 1982 and 1983, the procedures the licensee uses to assure adequate qualifications of equipment are completed, and the engineering project files related to documentation and qualification records for safety related mechanical equipment. The isspector also discussed this issue with licensee engineers and management personnel in conjunction with the examination of documents. The inspector asked the li.censee personnel contacted if they were aware of any circumstances which might cause such an allegation to be made.

The following personnel were contacted.

E. Kahler, Diablo Canyon Project, Engineering QC Supervisor M. Williamson,. Senior Licensing Engineer F. Zerebinski, Assistant QC Engineer, Unit 1 M. Guasan, QA Engineer J. McCracken, Senior Engineer, Engineering Mechanical Systems R. Laverty, Deputy Engineering Group Supervisor, EMS T. McIlraith, Mechanical Engineer, Engineering Department The documents reviewed included the following.

Diablo Canyon Project Engineer's Instruction No. 5, " Design Interfaces",

Rev. 3, effective October 10, 1983.

Weblo Canyon Project Engineer's Instruction No.11, " Design Review Due to Response Spectra Revision", Rev. 2,1ffective March 11, 1983.

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2 Diablo Canyon Project Non-Conformance Report Log 1982 and 1983 Non-Conformance Reports: DC0 82-EN-06, initiated April 28, 1982, " Class I equipment-for ASWS qualified to Rosari ground accelerations.rather than floor response spectra": DC0 82-EN-14, initiated May 12, 1982, ' " Hand _ Mas of Westinghouse NSSS Supplier Drawing Revisions": DCI 82-EN-20, 1

.{uly 26, 1982, "HVAC seismic supports generic support type do(itiated y not satisfy Epsgri Criteria".

Engineering Department Procedure 7.2, Rev.1, dated April 12, 1979,

" Engineering Release".

j Engineering Release Documents: ER 1654 " Reactor Coolant Subcooling Margin Monitor" (Combustion Engineering): ER 1653 " Reactor Head Vent Solenoid 1

Valves" (Westinghouse): ER 1642 "LCV 106, 197, 198, 109 - Motor Operators" (Lintorque).

4 PG&E letter to Westinghouse, McCracken to Hobel, dated March 29, 1983, tabulation of all safety related Westinghouse equipment.

Westinghouse letter to PG&E, Robel to Rocca, dated September 16, 1983, status 3

report of Westinghouse equipment qualification.

Calculation, SQE 8.1 (D21.1-2, Rev. I and D21.1-3, Rev. 1), dated August 16, 1983, Qualification of. Diesel Generator System ANALYSIS:

(Based on awa=4n= tion of the records and interviews of the personnel listed above) the engineering organization (Project) is responsible for obtaining and maintaining appropriate qualification and descriptive documentation of purchased equipment. Each discipline (Mechanical, Civil, Electric, etc.) Group Supervisor is responsible for obtaining appropriate descriptive documentation for each purchase order and for tabulating and maintaining a list of safety related equipment and qualification requirements for their discipline.

Descriptive documentaiton takes the form of drawings, technical manuals, and data reports. These items are obtained, coordinated, reviewed and approved by engineering prior to distribution to other potential users.

Qualification documentation of safety related equipment is either obtai~ned from the vendor or produced by the Project. Vendor supplied qualification docusentaiton is reviewed by responsible engineers who document their' reviews on " Engineering Release" forms. Qualifications conducted by the Project are doucmented by controled calcuilations or reports. Licensee personnel stated that the Diablo Canyon Project was different from other Bechtel projects in i

that the large civil / structural scope of the project necessitated that many gpslification analyses had to be assigned to support staff groups within Bechtel or PG&E rather than the civil / structural group. They waist on to suggest that since the civil discipliffe was not completing many4f the qualifications which they normally would, this might be preceivald as a failure to do the qualifications by some people in the civil engineering group. When revisions to qualification requirements (such as seismic spectra) occur, the change is issued as a revision to a Design Criteria Memorandum (DCM) and distributed to the discipline groups. The engineers within each group are l

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responsible for reviewing these changes and verifying that equipment either meets the revised requirements or is requalified. With the exception of the NSSS supplier, safety related equipment lists are controlled documents and are in the form of calculations or indexes. In the case of the NSSS supplieru.

(Westinghouse) the tabulation is in the form of a licensee lettfr addressed to Westinghouse. Revisions to DCMs are sent to Westinghouse by th responsible opgineer who receives a monthly status report from Westinghouse (ps to the status of qualification for each revision of each DCM for each piece of safety plated equipment. Project procedures provide guidance as to which group is responsible for which qualifications.

The inspector observed that the documentation associated with the qualification of the reactor vessel head vent solenoid, the reactor coolant subcooling meter, four auxiliary feedwater level control valves, and the seismic analysis of the diesel generators appeared satisfactory. The inspector also observed that documentation and qualification problems identified by the licensee had generally been identified in the licensee's or j

Independent Verification Program reports to the 1tRC. One #CR appeared to support the allegation in that licensee' personnel had identified documentation problems related to Westinghouse vendor prints. Licensee personnel stated that when plant maintenance personnel attempted to repair a valve they found the vendor drawing for the valve was incorrect (a check valve was 3/4" taller than indicated on the drawing). A subsequent examination revealed that following each shipment of a valve or valves from Westinghouse a vendor print would be issued for that shipment. Subsequent valves (in some cases) were fabricated to a different revision of that drawing and shipped with that drawing revision following them. Engineering personnel, thinking the earlier revisions were no longer applicable, disposed of the older drawings. PG&E personnel went on to demonstrate to the inspector that the missing revisions had been rec'ently purchased from Westinghouse and that this information was now available to plant personnel.

CONCLUSIONS: The inspector found that the allegation had merit, in that drawings of some Westinghouse valves had been inadvertently thrown away. The licensee subsequently identified this problem and obtained the missing documents.

Current documentation of qualifications and analyses appeared satisfactory.

(B) ALLEGATION NUMBER SEVEN:

GENERAL: Allegation number seven states, "There are no complete sets of l

"As-Built" drawings for the containment and other areas. Even the ones existing have discrepancies with erection drawings and DC's issued". The inspector's understanding of the basic requirements related to this allegation are that drawings depicting the final "as-built" condition of the plant l

(1) should exisc, (2) have been examined by the responsible engineers to l

3Isrify the plant as constructed is consistent with their design and analyses, and (3) are available to personnel,of_the plant staff consistent,with their deed for this type of drawing for maintaining and operating the vlant.

+

l The inspector concentrated on the containment annulus structural ~ steel

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l connnections, to determine (1) if "as-built" drawings exist, (2) wheather or

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not the responsible engineers are receiving these drawings in a timely manner, (3) if the engineers are reviewing these drawings for consistency with their

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4 design work, (4) if the subject drawings are available to the plant staff and other potential users in a timely manner, and~(5) when will the relevant i

design drawings be finalized "as-built".

EXAMINATION: The inspector examined the licensee's procedures $ lated to the control of DCNs and the "as-builting" of drawings as well as re5evant DCNs, shop drawings, field change transmittals, and working drawings.4 The inspector also discussed this issue and the associated work in progress with licensee W loyees to determine the status of "as-built" drawings and the nature of descrepancies in existing drawings.

4 The persons contacted are listed below.

G. Moore, Diablo Canyon Unit 1, Project Engineer J. McCall, Diablo Canyon Project, Civil Group Supervisor W. White, Special Assistant to the Civil Group Supervisor E. Eahler, Diablo Canyon Project, Engineering QC Supervisor N. Tuholski, Deputy Civil Group Supervisor J. Osborne, Drafting Group Supervisor R. Delrosario, Supervising Designer M. Williamson, Senior Licensing Engineer P.' Kousharian, Senior Engineer

]

K. Mandagi, Supervising Engineer The documents examined included those listed below.

Engineering Procedure 3.6, dated June 25,' 1982, " Design Changes".

Engineering, Procedure 3.50N, dated August 15, 1983, " Operating Nuclear Plant Design Changes".

Engineering Procedure 3.7, dated September 1, 1983, "As-Built Documents".

Diablo Canyon Project Procedure CE-DC-5, dated November 1, 1982, " Procedure for Issue of Civil Structural Design Modifications".

PG&E Drawing 447245, Rev. 7, dated April 12, 1982, "Annulua Hanger Frames at Elevation 101 and 106, Containment Structure Area F & G".

PG&E Drawing 47281, Rev. 9, dated July 8, 1981, " Annulus Platform Framing Elevation 87".

PG&E Drawing 438282, Rev. 10, dated July 1, 1981, " Annulus Platform Framing Elevation 140".

Pp4E Drawing 447254, Rev. 4, dated April 21, 1980, " Concrete Outline and Beinforcing Platform at Elevation 140".

PG&E Drawings 468984, Rev. 01B, dated March 7,1983,468985,Ref.01B, dated March 7, 1983, 468986, Rev. 01A, dated December 1, 1982, " Civil ?lans, Details and Sections, Column Additions & Column Braces, Annulus Frames 6 Containment Structure".

_.., _,. _ _ _[

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PG&E Drawing 468987, Rev. 01A, dated February 28, 1983, " Annulus Steel'-

Radial Frame Additions, Colume 1".

PG&E Drawing 468988, Rev. 01A, dated February 28, 1983, " Annulus Steel -

Radial Frame Additions, Column 2".

TP RG&E Drawing 468989,Rev.01B,datedJuly3,1983,"AnnulusStep-Tangential Neam Modifications".

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$signChangeNoticeDC1-EC-3601,Rev.O,GenericDCNforannulusstructural steel and plantform modifications, including the DCN drawing index, Drawing Transmittal Forms, and DCN Drawings.

PG&E Drawings 468990 & 468991, Rev. 01A, dated February 28, 1983, " Annulus Steel Radial Frame Additions, Design I,ayout and Sections".

Plant Modification Follower, D1-3601-CRO, dated November 3,1982.

Design Criteria Memorandum, C-27, Rev. O, " Containment Annulus Structure".

Design Criteria Memorandum, C-49, Rev. O, " Class I Architectural Platforms, Unit No. 1 Containment Structure".

Field Change Transmittals & Associated Foley Drawings, FCT 4473A through G corresponding to Foley drawings 6181-CI-13-40,41,44,46,47,43 & 42.

ANALYSIS:

(based upon the examinations described above) At the time of this examination the licensee's Design Change Notice (DCN) for the containment annulus steel connections was incomplete. The DCN (DC1-EC-3601, Rev. 0) is a

" generic" DON which consists of many individual design changes. One or more changes is depicted on sketches prepared by engineering (the Project) and transmitted to Construction by Drawing Transmittal Forms. Each transmittal is uniquely numbered and includes an updated DCN Drawing Index. The On-Site-Engineering Group (OSEG) can also issue design changes for this DCN in the same manner, with the condition that field initiated changes are within a predetermined scope and are coordinated with the Project.

Construction i

reviews the changes from both the Project and the OSEG and turns them over to their contractor (H. P. Foley in this case) for construction. The change is engineered and completed by Foley with one or more " shop drawings". These drawings are "as-built" by Foley and checked by construction to document what was constructed for that particular change. The " shop drawing (s)"'is then reviewed by construction and transmitted to the Project for review and approval by a Field Change Transmittal (FCT). At the completion of all Drawing Transmittals (which comprise the DCN), the licensee's " record drawings" are updated based on the FCTs which forwarded the " shop drawings" and the DCN is closed. The Nuclear Power Operations staff and Plant prations staff have reviewed this " generic" DCN prior to work commencing and are required to review the complete DCN after it is finished. The Foley " shop drawings" are reviewed and approved by-Construction and Project; personnel.

In the event a " shop drawing" is unsatisfactory the responsible engineers or construction personnel contact Foley personnel to correct the ddficiency. The DCN, DCN sketches and drawing index, FCTs, and " shop drawings" 'a're placed in the licensee's Records Management System (RMS) as these documents are,

processed through the system described above.

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The inspector verified that the licensee personnel maintain a DCN Transmittal Log with copies of the DCN design sketches. The inspector also verified that the Foley " shop drawings" were also controled, were being reviewed and approved by the responsible engineers, and were being placed in the licensee's RMS. As of November 3, 1983 approximately 380 Foley " shop draw 4pss" had been received and over 90% had been approved by the Project. DuringW nterviews the inspectorverifiedthatresponsibleengineershadbeentothefyldtoexamine the work and that they were satisfied with the quality of construction. The fnspector observed that the " drawings of record" had not been "a's-built" to Peflect the subject DCN. Licensee personnel stated that (based on current procedures) these drawings would be reissuea "as-built" within thirty days of completion of the DCN.

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CONCLUSIONS: The inspector found that for the DCN covering the modifications to the annulus steel the allegation is correct, but the "as-built" information was available through the Foley " shop drawings". The transmittal of these drawings was controlled and they werie being reviewed and approved by both Construction and Engineering. These " shop drawings" were available to potential users through the licensee's RMS system and were scheduled to be incorporated into final "as-built" drawings within 30 days of completion of the associated DCN.

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3-5 PACIFIC OAS AND E LE C T RIC C O M PANY BOWS l

77 BEALE STREET. SAN FRANCl$CO, CAUFORNIA 94106. (415)781 4 51. TWX 910 372 6587

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February 17, 1984 PGandE Letter No.:

DCL-84-063 Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D.C.

20555 Re: Docket No. 50-275, OL-DPR-76 l

Diablo Canyon Unit 1 SSER 21'- Allegations 31 and 32

Dear Mr. Knighton:

This letter provides the NRC Staff with information to resolve allegations 31 and 32 of Supplement 21 to the Safety Evaluation Report (SSER 21). This is in response to the specific information requested in SSER 21 on pages 2-71 and l

2-74 for items 31 and 32, respective.

Regarding allegation 31, PGandE has assured that verification documentation is available for all the technical options of computer programs, including pre-and post-processors, that are being used by the Diablo Canyon Project, Unit 1 l

Civil Structural Group. The computer programs used by consultants are verified and documented in accordance with their respective QA procedures l

which have been audited and approved by the appropriate PGandE or Bechtei QA l

organization. All programs developed for the Unit 1 civil structural design have been verified in the time frame from December 14, 1982 to the present.

Rreviously developed programs have been verified prior to December 1982. The verification is consistent with PGendE's Quality Assurance Program.

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-a Regarding allegation 32, PGandE has performed calculations in accordance with applicable licensing criteria to confirm that all penetrations to the containment shell are structurally adequate. These calculations are documented in PGandE files.

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Mr. G. W. Knit $ ton i

February 17,'984

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PGandE Letter No.: DCL-84-063 page Two j

- Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely,-

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J. O. Schuyler cc:

T. W. Bishop J. B. Martin H. E. Schierling Service List Y

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.itt e ALLEGATION DATA FORM u.s. wuct Aa caous.Arony commession 7 i.. l I

RECEIVING OFFICE

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I fW me Docket Number lif applicable)

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2. Functlenel Aree(s) involved:

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onsite health and safety construction offsite health and safety safeguards

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Description:

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Office of. Inspection and Enforcement, Region V October 9,1983.

Tuclear Regulatory Commission 1/.50 Maria Lane Walnut Creek, Ca.

Gentlemen

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REI Safety related concerns on Diablo Canyon Nuclear Power Plant, Unit 1.

ThIfollowingerrorsindesign/documentationonthesubjectplanthavebeen ide~ntified:

1. Pipe rupture restraints are designed inadequately.

2. Safety related equipment has inadequate / untraceable documentation.

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3. Structural programs are being used without proper QA procedures.

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4. Dynamic analysis of the containment building, its roof and interaction with soil and adjoining structures is inadequate.

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5. Inserts and attachments to containment valls are inadequate as well as connections to the liner plate.

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6. The turbine building is designed as a Class 2 structure but contains class 1 piping and equipment.

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7. There are no complete sets of " As - Built " drawings for the containment and other areas. Even the ones e:tsting have discrepancies with erection drawings and DCH's issued.

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8. The Annulus Structure reverification is erroneous due to the following:

(1)

The computer model used is incorrect. Members are missing, have wrong properties input and have boundary conditions different from existing conditions.

(ii) Loads from large bore piping are wrong and unrealistic in the way they are input in the model. Also, Fan Cooler loads azu not censidered.

(iii) Loading conditions used are incomplete without LOCA, rupture loads and I

l proper thermal loads between polar crane vall and the Annulus structure.

(iv) All members are not selected for design re-verification in Phase II design.

Hand computations and the pr'ogram CE 2'17 ar'e' usseif to ide'ntify " critical members ". Both of these methods are unconservative in their treatment of torsion - which governa in.a_few members. As a result of using this procedure, some overstressed members may not be checked foR adequacy.

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SHEET 2 0F 2 CHEETS RE : Safety related concerns on DIABID CA!;YO!! I;UCLEUt POWER PLAhT, Ul:IT 1 (v)

Frequency modifications have be.sn done on the structure. Additional bracings, stub columns and other members have been added without any backup calculations for the members or their connections.

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(v0 DeficienciesintheCE217programprecludecheckingofcoposite 1

members and built - up members. To date these have not been, checked f

and may have some over-stressed members which have not been identified.

The above are a few of the concerns that we, the employees of BECHTEL POWER CORPORATIOli and PG E-E have. We are not able to address these and other related issues since ve have to meet very stringent schedules and management is not interested in resolving the potential problems. We feel that if we are unable to resolve tha subject issues, the safety of the general public vould be at stake in the ovent of a nuclear accident.

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1480 MARIA LANE.SulTE 210 VWALMUT CREEK CALIPORNIA 94888 g *.. *,e OCT 121983 MEMORANDUM FOR:

D.'G.Eisenhut, Director,Divisionof;Licensia),NRR

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FROM:

T. W. Bishop, Director, Division of Resident, teactor Projects and Engineering-Programs i

SUBJECT:

Allegations of Errors in Design / Documentation of Safety Related Structures, Systems and Components, Diablo Canyon Unit 1, Docket Number 50-275, Transfer of Lead Responsibility On October 12, 1983, Region V received the attached letter alleging the inadequacy of design / documentation of safety related structures, systems and components at Diablo Canyon Unit 1.

Although the letter is unsigned, the authors present themselves to be employees of Bechtel and PG&E.

Accordingly, Region V requests that NRR take lead responsibility for resolving the alleged discrepancies documented in the attached letter and document the resolution in a letter to the region.

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Region V will assist NRR as necessary in this effort. The Region V contact on this issue is D. F. Kirsch (FTS 463-3723).

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p. W. Bishop, D ectord Division of Resident, Reactor Projects and Engineering Programs

Attachment:

As stated cc w/ attachment:

G. Knighton, NRR H. Schierling, NRR B. Buckley, NRR D. Kirsch, RV P. Morrill, RV

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l0ffice of Inspection'and Enforcement, ReCion V October 9,1983.

Nuclear Regulatory Commission 1450 Maria Lane:

Valnut Creek, Ca..

Gentlemen:

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reg Safety related concerns on Diablo Canyon Nuclear Power Plant,4 Unit 1.

1 Th4 following errors in design / documentation on the subject plant have been identified:

1. Pipe rupture astraints are designed inadequately.

. h. h Cafety nlated equipment has inadequate / untraceable documentation.

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3. Structural programs are being used without proper QA procedures.

4. Dynamic analysis of the containment building, its roof and interaction with soil and adjoining structures is inadequate.

5. Inserts and attachments to containment valls are inadequate as well as connections to the liner plate.

6. The turbine building is designed as a Class 2 structure but contains class 1 piping and equipment.

h @ There.are no complete sets of 8 As - Built " drawings for the containment and

.other areas. Even the ones existing have discrepancies with erection drawings anil DCN's issued.

8. The Annulus Structure reverification is erroneous due to the following:

(1)

The computer model used is incorrect. Members are missing, have wrong properties input and have boundary conditions different.from existing conditions.

(ii) Loads from large bore piping are wrong and unrealistic in the way they are input in the model. Also, Fan Cooler loads are not considered.

(iii) Loading conditions used are incomplete without LOCA, rupture loads and proper thermal loads between polar crane vall and the Annulus structure.

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(iv) All members are not selected for design re-verification in Phase II design.

Hand computations and the program CE 2'17 a6 usie'd' to ide'ntify a critical i

0 members ". Both of these methods are unconservative in their treatment

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of torsion - which governs in a few members. As a result of using this procedure, some overstressed mes5iirs may not be checked fozsadequacy.

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SIU T? 2 0F 2 OHEETS RE : Safety related concerns on DIADID CAfiYOI: ITUCLEAR POWER PLA:.T, UI IT 1 (v)

' Frequency modifications have been done on the structure. Additional bracing =,

stub columns and other members have been added without any backup calculations for the members or their connections.

(vi)

Deficiencies in the CE 217 program preclude checking of coq osite-5 members and built - up members. To date these have not beent checked 7

and may have some over-stressed members which have not been' identified.

T The above are a few of the concerns that we, the employees of BE0HTEL POW.R CORPORATIO!! and PG & E have. We are not able to address these and other related issues since we have to meet very stringent schedules and management is not interested in resolving the potential problems. We feel that if we are unable to resolve the subject issues, the safety of the general public vould be at stake in the event of a nuclear accident.

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CONFIDEMPIAL f

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.2 Office of Inspection and Enforcement, Region V NUCLEAR REGULATORY COHHISSI0tl

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TASK INTERFACE AGREEMENT DATE:

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PR08 TEM: Diablo Canyon 1 - Structural Allegations j

LEAD OSFICE: / 3 I&E

/ $ NRR

/ 3 REGION

_/3 JOIT NOTIFIGTION:

REFERENCES:

Meno to DEisenhut from TBishop dated 10/12/83 subject: Allegations of Errors in Safety-Related Structures Systems, and Components at Diablo Canyon 1.

ACTION PLAN:

R-V/NRR:1. Conduct preliminary evaluation of alleged errors in design / documentation at Diablo Canyon Unit 1 (as described in unsigned letter submitted to R-V)

Detennine if hilegations have impact on Commission considerations to lift the Diablo Canyon suspended license. Division of evaluation responsibility is as shown on marked up copy of alleger's letter.

(SGEBlead;MEBassist) 2.If preliminary evaluation (Item 1) substantiates the need. complete evaluation j

of the allegations and provide evaluation memo to PM (SGEBlead;MESassist)

O Site Visit Scheduled for 10/25-26/83 Complete Item 1 by 10/28/83,

Complete Item 2 by 12/15/83 NOTES:

1. Contacts with licensee or AE nant he coordinated with R-V.

2. Alleger's letter provided directly to revie.wers.

3.

Reviewers should be sensitive to any evidence of management nsalfeasance. Such issues would be followed up by OI.

l'RR: Designate Lead Project Manager to assign TACS and coordinate correspondence, meetings, and reports (ORB #

/ LBf 3 H. Schierling)

Prepare response to R-V for DL signature.

OFFICE COORDINATORS:

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TA*G. Holahan

_(X27415)

R. Vollmer (y 27207)

APPROVED:

T. Novak (X 27425)

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V. Stallo, ROGR J. Heltames, AE00 9

Regional Ades.

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0. Eisenhut. NRR G. Knighton. LB#3 R. Vollmer. NRR J. P. Knight, AD:CSE R. Idessndn. DL R. Bosnak. MEB

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ATTACHMENT

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Office of Inspection.and Enforeceent, Racion V October 9,1923.

!!uelear Regulatory Comai=sion 1453 V. aria Lane Valinst Creek, Ca.

e.1 Centlemen:

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E ?5afety related concerns on Diablo Canyon Nuclear Power Plant,' Unit 1.

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Ine following errors in design / documentation on sne subject plant have tecs

- :=y. identified:

hlRt-1. Pipe rupture astraints are desir;ned inadequately.

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2. Oafety related equipment has inadequate / untraceable documentation.

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- 3. Structural programs a.re being used without proper QA procedurws.

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4. Dynamic analysis of the containment building, its roof and interaction with soil and adjoininC structures is inadequate.

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5. Inserts and attach =ents to corf.ainment valls are inadequate as well as connections to the liner plate.

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6. The turbine building is designed as a Class 2 structure but contains class 1 piping and equipment.

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7. There are no. complete sets of " As - Built '" drawings for the contai: ment and other areas. Even the ones existing have discrepancies"vith erection drawings and DCK's issued.

VER 2. The Annulus Structure reverification is erroneous due to the following:

(1)

The co..puter model used is incorrect. Members are missing, have wrong properties input and have boundary conditions different fron existing l

conditions.

(ii) Loads from large bore piping are wrong and unrealistic in the way they are input in the model. Also, Fan Cooler l'eads are not considered.

(iii) I.cading conditions used are incomplete without LOCA, rupture loads and proper thermal loads between polar crane vall and the Annulus structure.

(iv).. All members are not selected for dssign re-verification in Phase II desi;;n.

Hand computations and the pr'ogram CE Z17 ar's use'd to ide'ntify a critical

.- members ". Both of these methods are unconservative in their treat =ent

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of torsion -- which governs in'a few members. As a result (f using this procedure, some overstressed members may not be checked rop, adequacy.

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.v UNITED STATES NUCLEAR REGULATORY COMMISSION cs

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FILE COPY' - DO NOT REMOVE Dockst No.: 50-275/323 OCI 18 O 4

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bRANDUMFOR:

Chainean ~ Palladino i

Coussissioner Gilinsky Consnissioner Roberts Consnissioner Asselstine Coassissioner Bernthal FROM:

Darrell G. Eisenhut. Director Division of Licensing

SUBJECT:

DIABLO CANYON - ALLEGATIONS CONCERNING ERRORS IN DESIGN / DOCUMENTATION OF SAFETY RELATED SYSTEMS, STRUCTURES, AND COMPONENTS (Board Notification 83-161)

In accordance with the procedures for Board Notification the following infor-mation is being pmvided directly to the Conunission. The Scards and Parties are being infonned by copy of this memorandum.

On October 12. the NRC staff (Region V) received anonymous allegations concerr.-

ing certain safety-related systems, structures and components of Diablo Canyon 1 (Enclosum).

j Specifically, these allegations related to the adequacy of (1) the annulus structure reverification effort (2) pipe restraint design. (3) equipment documentation, (4) QA proceoures for structural programs (5) dynamic analysis of the containment building, and other matters.

The allegations were submitted.as " confidential" and, to date, the identity of the allegers is unknown. The NRC staff plans to evaluate these allegations, We will infom you of the results of these efforts when available.

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[ Division of Licensing Darrell G. Eisenhut, Director l.

Enclosure:

Mesi to DGEisenhut fm TBishop dtd:10/12/83 i

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