ML20215H937
| ML20215H937 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, 05000000 |
| Issue date: | 12/08/1983 |
| From: | Hoch J PACIFIC GAS & ELECTRIC CO. |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20213D283 | List: |
| References | |
| FOIA-84-21 NUDOCS 8705070156 | |
| Download: ML20215H937 (33) | |
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PACIFIC GAS AND E LE C T RIC C O M PANY bbW3 [ 24S MARNET STREET = SAN FRANCISCO. CALIFOR NIA 94106 * (415) 7814211
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- December 8, 1983 Mr. T. W. Bishop NRC Region V Division Director
SUBJECT:
Response to NRC Request for Information Regarding Engineering Walkdowns and the Accuracy of the Information Generated.
Dear Mr. Bishop:
The following is our response to your questions of December 6, 1983, concerning engineering walkdown information and the accuracy of this information as,it was used as input in the verification effort of the Diablo Canyon Nuclear Power Plant, (DCNPP), Unit 1. It should be recognized that the DCNPP-1 design verification program consisted of simultaneous efforts by the PG&E Internal Technical Program (ITP) and the Independent Design Verification Program (IDVP).
The following are responses to your specific questions.
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- 1. What er.gineering walkdowns were performed?
The Engineering walkdowns performed were described in the report entitled "Supplemant on As-Builts" submitted to the NRC on June 24, l'98 in E
accordance with the three-step licensing process. (Attachment})
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Engineering walkdowns were performed by the ITP and the IDVP in virtually all areas of DCNNP-1 and the as-built information from these walkdowns was l used in the design reverification work. The scope of the ITP review is presented in the Phase I Final Report and that of the IDVP in the IDVP Final Report. Table 1 presents a sumary tabulation of the areas of ITP review with page references from the Phase I Final Report. Similarly, Table 2 presents a sumary tabulation of the areas of the IDVP review with page references from the IDVP Final Report. A review of these two tables shows the scope of the combined ITP and IDVP review efforts in the area of engineering walkdowns.
- 2. Why were only these areas selected?
The areas for which engineering walkdowns were conducted are considered to l include all major areas of interest in the verification program including virtually all of the seismic aspects of the plant. Walkdowns were not conducted where they were deemed unnecessary to complete verification of a design.
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- 3. .What written criteria were used for the walkdown? If none, why not?
If verbal criteria were used, what were the criteria and how was the criteria clearly controlled 7_
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gheengineeringwalkdownsperformedcanbecharacterizedintwo[
hategories. The first category involved walkdowns performed by groups outside of the home office engineering organizations using specific written procedures developed by the ITP. These included the following 1
walkdown areas:
I i o Large bcre piping and pipe supports o Small bore piping and pipe supports o Electrical raceway supports HVAC duct supports o
o Equipment The second category involved walkdowns performed by design engineers from the home office who were knowledgeable in the design data needed to develop accurate input for verification calculations. These include walkdowns conducted to support structural design verification. No written procedures were considered necessary for these walkdowns given the expertise of the walkdown team mem6ers.
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- 4. What basis or rationale do you have for believing the results of the walkdown to be accurate? Was any QC performed or other check for accuracy?
The accuracy of the results of the walkdowns is assured by the-following -
4easons: I T
Where walkdown procedures were provided they constituted a systematic basis for assuring an accurate check of the as-built condition. These walkdowns were originated and checked prior to sending them to Project Engineering. Periodic reviews of such as-builts by the requesting discipline group provided an additional check to assure proper content and accuracy.
The IDVP did extensive field verification of as-built conditions as part of their seismic verification program. For example, during its initial review of the auxiliary building, the IDVP performed field inspection of the building. During its verification of the DCP corrective action, the IDVP performed a field inspection of concrete portions of the auxiliary building which included field verification of the as-built condition of 1
the shear walls and slabs. This was performed to ensure consistency with
- the design drawings and analysis. During its sample of large bore pipfng
- (15 analyses), the IDVP field-verified each sample problem. Information that was field-verified included
- pipe size, location concentrated weights (valves, flanges, etc.), insulation, vent / drain lines, valves .
I{a.g.,operatororientation),suppoets.(location, type, orientation)and
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connected equipment. Additionally, the IDVP reviewed 21 analysis in
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verification of the DCP corrective action. Model geometries for 12 of the analyses were walked-down by the IDVP to ensure conformance between design drawings and the as-built condition.
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jnboththeinitialandadditionalIDVPsampleofHVACcomponen$s ,
location, dimensions,andconfigurationwereverified. Upon completion of the.ITP work the IDVP selected a sample of eight HVAC components for 4
verification between as-installed t.nd as-analyzed conditions.
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The IDVP also did extensive field' verification as part of its non-seismic 4
program actions. As an example, for this initial sample of systems, the IDVP expended about 38 man-days of field verification: 20 on the auxiliary feedwater system, 15 on the control room ventilation and pressurization system, and three on the 4160V electrical system.
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- 5. Where and how were the results recorded?
The design calculations and/or design analysis packages incorporate the j as-built walkdown information. Ultimately, these design packages reflect the record of the design work or the reverification of the design. Where specific walkdown activities were guided by procedure, the records of the walkdown are also available in project files.
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- 6. Did the results show the design drawings to be accurate?
In areas reviewed by the ITP and the areas of the'ITP work sampled by the IDVPtheas-builtswerefoundtoadequatelyagreewiththeacth1 plant bonditions.
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s In sununary, we hope we have addressed the aliove questions to your satisfaction. Please advise at your earliest convenience if you have coannents 1
or questions concerning these responses, or require additonal information.
- . Very truly yours.
PbjectManager Response Required: No JBH/R0 man /jic At.tachments: 'r. Letter, J. O. Schuyler to D. G. Eisenhut, June 24, 1983, transmitting " Supplement on As-Builts."
- 2. Table 1 - Summary Tabulation of Areas of ITP Review of DCNPP-1 As-Built Conditions
- 3. Table 2 - Summary Tabulation of Areas of IDVP Review of DCNPP-1 As-Built Conditions 1
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.:: GAO AND ELECTRf CO A e...
ATTACHMENT 1
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. T June 24, 1983 l 5 l 6 i W. Darrell G. Ef.senh:::, Di:setor . l Df. vision of .T 4 ==ing Office of Eclear Rasctor Regn1=H=
U. S. Nuclear Ragulatory F7 4esion 13=eht,gton, D. C. 20555 Ra: Docket No. 50-275, CL-DIR-76 Diablo Canyon Unic & . 1 In accoh with the three-step licensing process for Diable Canyon Unit 1 app:cved by the F-4esian on N-M 8,1982, enclosed is PGarxE's u.yuuc entitled ' Supplement on As-Builts".
Since:ely, -
J. O. Schuyler opu/Jos/m Ecclosure cc (w/ene.): Dr. v. E. Cooper .
W. J. B. Martin Serrice List becv/ enc: Diablo Distribution t
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f p 41,01) . s occ 4717 (l' RECED'I .D JUN 2 7 'S83 wrncmrime .,._
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2.0 COhTICURATION CONTROL F10 CESS .27 Configuration control ~as used in this. report. is that process,*by which':
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k R i (a) Construction is advised of approved design changes to the plant configurations (b) The implementation of such changes is controlled by the organization in charge of the plant at the time the design change is issued (c) The results of implementation are reviewed to assure that the implementation complies with appropriate design criteria *
(d) Dedign documents reflecit . tc the extent necessary, the exact
. plant configuration point in time -
The following sections describe the responsibilities of General
- i Construction and Engineering in this process.
l 2.1 construction PG'andE has recognized the need for "as-built" drawings and control of ,
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de)ign changes since, the beginning of construction activit{,e, s at Diablo
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Canyon. PCandt Standard Practices, which were in effect prior?.to the start .
of Diablo Canyon, specified the method for changing drevings' and provided the distribution for the "as-built" drawings. At Diablo Canyon. additional X 47:.q C 061.d{Og .
DCC .
SUFF1-DIS AS-2 Rev 0-06/24/83 .
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24327 1.0 INTRCDUCTION The three-step licensing approach requires submittal'of an as-htilt
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menit report by the Proj ect. This attachment provides a de(cription of !
deksnandconstructionconfigurationcontralprocessandas-builtwalkdown activities . by the Proj ect showing that plant ~ and system modifications i l
conform with design requirements. This process assures that the as-built conditions conform with the design of safety-related systems, structures, and components required for fuel-loading (Step 1), low-power testing (Step 2), and full-power operation (Step. 3) . Furthernere, the as-built valkdown activities pr$ vide confidence that current as-built conditions are adequately and appropriately used in the verification of safety-related design.
Provided belsv is a description of the Project's configuration controls -
which incorporate the appropriate elements of cons'truction and engineering procedures, and appropriate quality assurance practices. Also provided is
. a description of as-built walkdown activities performed by the ' individual engineering groups for civil structural co=ponents, instrumentation and control components, piping and piping supports, mechanical, EVAC and Class 1E electrical equipment.
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g TABLE OT' CONTENTS-2432'[
1.0 INTRODUCTION
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2.9 CONTIGURATION CON nOL PROCESS 4 .
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2.1 CONSTRUCTION 2.2 ENGINEIRING ,
3.0 DCP WALKDOWNS ,
3.1 CIVIL / STRUCTURAL VALKDOWN 3.2 FIPE AND SUPPORT,5 WAIJ:DOWN 3.3 INSTRUNINTATION AND CobTROLS WALKDOW 3.4 MECHANICAL EQUIPMENT WALXDOWN 3.5 HVAC AND ELECTRICAL WALKDOWN 4.0 IDVP VALIDOWNS , t S
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DCC 4717 Rev 0 11 AFFNDI-DIS' .
06/24/83
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(b) Auxiliarv Building / Fuel Bandling Building
> i Basad on the results of the data obtained fr p walkdowns k S
. performed by both the DCP and the IDTP. the revised seismic 6
analysis was , performed. A walkdown was also made in selected areas of the auxiliary building to verify the weight and location of minor equipse.st and utilities for their effect on floor i- flexibility'. ,
- A walkdown vill assure that the major temporary construction openings.in ' concrete are closed.
i The seismic analysis and design of the fuel handling building and' crane have been reviewed to assure that the models used in the DE, DDE, and Rosgri analyses adequately represen't the as-built
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conditions. This preliminary review included field investigation of as-built conditions, review of applicable criteria, and sin-plified analysis of selected portions of the structure.
The modification to the fuel handling buiiding has been performed in accordance with the ohnp drawings prepared from the design drawings. A detailed walkdown will provide the basis for
] revision to the design __dravings and additional verification analysis of the as-built condition. 7 DCC 4717 SUFF1-D15 h5-8 ,
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2?327 3.O DCP WU E:DOWN5 As part of the verification procedure, existing drawings and ther avail-abIe information are . reviewed, including design drawings and kocumentation ishted to modifications, to assemble a set of documents reflecting current conditions. In order to increase confidence that as-built conditions are identified, documents thus developed are compared in the' field with the physical ' configuration by conducting a walkdown. Based on these data, verification and analyses are performed. An evaluation is performed to assess the effects of any required modifications on the current design.
3.1 Civil / Structural Walkdown (a) Containment The design drawings were reconciled with'the as-built information obtained from the pour lif t drawings for both the containment and the interior concrete structures. Walkdowns were made to assure
- that analysis models representing both primary and secondary members of the structural. steel framing system of the annulus and
. the platforms accurately represent the existing conditions.
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DCC 4717 !
SUFF1-DIS AS-7 Rev 0 m, . 1
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24327 issued design documents must reflect the operating plant configuration; a proposed d4 sign. change cannot be reflected in a formal revision to an "as-built" drawing. Second, implementation of a design chainge "
must be
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controlledbyPlantOperationsandtheimplementedchangemustpeaccepted
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by flant Operations prior to returning that affected part of cle plant to an operating status. This complete proces: is carefully controlled by documented procedures in Engineering and Plant Operations to assure that:
i (a) Current documents' reflect the as-built conditions prior to any design change.
,. l (b) The implementation of the design change is controlled by Plant Operations to assure proper continued and restored operation.
(c) The' exact implementation'of the change is reviewed by Engineering to assure compliance with appropriate design criteria.
(d) Design documents which depict the plant configuration. are .
controlled to assure that implementation of design changes ~ is promptly reflected in such documents, and such inf orma ti'o'n is
- readily accessible to Plant Operations personnel.
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DCC 4717
'ggrP1. Dis AS-4 Rev 0 06/24/83
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to be located. The piping installation contractor prepares erection l 1
isometrics from the area drawings. The construction design change and r
"as-built" drawing control programs are applied to these , contractor-areption isometries. As required by Engineering Department ekteria, any Y 4
- varlan'ces requiring design change approval and "as- built" dtavings are s
- processed in accordance with Construction Quality Assurance and Quality Control Procedures and "as-built" drawings are forwarded to, the Engineering Department for review and incorporation of the appropriate drawings.
2.2 Engineering During initial plant construction. Engineering documents reflected the actual results of the constr,uction ef fort through the "as-built" process.
Selected documents were identified as subject to this process. The actual results of the construction ef fort, i.e., selected dimensions, data, or
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other information, were noted by General Construction or the contractor on a copy of the drawing or in notes attached to the copy. Engineering reviewed the noted results for technical correctness, and, if acceptable, .
formally revised the affected drawing to reflect the as-built ' condition.
If the results were not acceptable, General Construction was advised and
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the ites was changed as directed by Engineering. In this way the physical a
i plant configuration was documented at any point in time. If, during the cogstruction process, a design change was made, the affected design documents were revised and issued to 4 eneral Construction. ,
2 Following issue of the plant operating license, such unilateral revis,1on of design documents.to illustrata design changes is not permitted. First, the As-5 y0 SUFF1-dis 06/24/83 J
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2?327 ne adequacy of implementation of these procedures has been verified by continuing audits of the entire design drawing control process by the General . Construction Quality Control Department, by the y Corporate
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QuaiLity Assurance Department, and by NRC laspections. nese4 audits have codistently verified that programs existed, that they are adequate, and their implementation "s i effective. Construction- forces, including supervisors, field engineers and inspectors of contracto'rs , and PGandI, have always recognized the need for construction work to comply with general design details. The specific placement and routing is left to the discretion of field construction forces. At Diablo Canyon, these " field run" commodities are subsequently walked down to assure compliance with changing criteria.
In other cases, the Engineering Department furnishes criteria and installation ' tolerances within which variances do not require design change
, approval or drawing "as-builts." Any changes in installation work outside c' of these Engineering Department specified censtruction tolerances would require design change approval and "as-built" drawings. Variances .fron -
design drawings requiring "as-built" sketches and drawings are furnished to.
the Engineering Department by General Construction. ne Engineering Department has final authority on which sketches and "as-built" changes require incorporation on record drawings and require design review.
e As- an illustrative , example of the process, piping is >installed in accordance with the piping . and mechanical area drawings -f;. Dese area drsvings prescribe to General Construction how and where piping and' piping system components such as valves, flanges, branch lines, and fittings are OCC 4717 SUFp1-DIS AS-4
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24327 direction is given in various other instructions and procedures to. assure transmittal of design changes and "as-built" drawings to the Engineering Department for incorporation on " record drawings." *
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- Foy the purpose of clarity. PGandE uses the term "as-built" vben referenc-t in[the information generated by General Construction in the form of a marked-up drawing, sketch, or revised design data that portrays the condition as installed in the plant. his "as-built" information is
! forwarded to the Engineering Department for incorporation on the record drawings. A record drawing is a design drawing that has been assignad a record number and has been issued by the Engineering Department.
Since 1968 memoranda and procedures have been developed to address the
. handling of "as-built" drawings at Diablo Canyon. These procedures clearly i specify in great detail the General Construction responsibility f or the t
control of design changes and submittal of "as-built" information to the -
Engineering Department for incorporation on record drawings.
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These procedures clearly indicate a recognition of the need' to control i des'ign changes and "as-built" information and have been in place and fully I
implemented throughout the construction of Diablo Canyon. These procedures are the implementing instructions "to meet the requirements of the Diablo
, Canyon Quality Assurance Manual and are updated and revised in accordance
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with Construction. Engineering.-Quality Assurance, and regulatory 1 g l
! requirements. These procedures assure that design changes (re controlled 1 and the "as-built" plant condition documented. ,
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DCC 4717
. SUFF1-DIS AS-3 Rev 0 06/24/s3
24327 (c) Intake As-built information . including pour lif t and shop dfjvings were 4
I compared with the design drawings'and any minor diffdrences were
. m k resolved and factored into the ' verification analysis. A valkdow l vas performed to verify the dimensions of' selected structural elements.
(d) Turbine !suilding De various design and construction o c,cument s , e.g., design drawings, . shop drawings, pour lif t drawings, and manufacturers' drawings, were rev'ievid. ne field walkdown assisted in this review. A comparison was also made of Bosgri modifications with the existing shop and des'ign drawings, and a walkdown was made of ,
significant concrete and structural steel members.
(e), EVAC Supports .
l ne design verification is performed on a generic basis. Duct l ,
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supports 'are grouped into similar (generic) types, based on a 1
, field walkdown of Design Class 1 ductvori. De groups are defined such that evaluation of one critical support in each 1 group can be taken as a conservative representationifer the rest 1 e of the supports 'in that group. y DCC 4717 SUF?1-DIS , ,
AS-9 Rev 0
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Du'etwork that does not satisfy applicable criteria based on generic qualification is evaluated for its actual (specific) e.
i condition. Specificconditionsofeachsupportarehtainedfron k 4 -
- . . a field walkdown. Evaluation of a specific support. follows the i ?
same procedure used for generic qualifications, but considers the {
I' actual duct size, span, weight, pressure, and building location.
l (f) Raceway and Conduit Supports A detailed walkdown is performed for type and location of the l
Category I ' rsc evay and conduit supports.
The supports are l
generally qualified on the basis of generic types. Any type of support that cannot be qualified- for its generic case is investigated in the plant to determine the worst as-built conditions. The parameters considered include location of the support in the plant, dimensions of the support, bracing configuration, sizes and locations of raceways in the support.
span lengths, and raceway identification numbers so that actual weights of raceways are determined. Using this information, static analyses are performed again for each support of that type in the same manner as for the generic case, except that in this case as-built parameters are used. The loads used in this static
! analysis result from , uniform acceleration obtained by the 1 i appropriate response spectra of a period zesociated with the as-built conditions. .
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24327 All safety-related areas in Unit I were inspected. Class -1I condu'it runs were documented. Rose runs judged to be s.
susceptible to longitudinal loads are identifik and their i 4
_. . as-built condition documented. -
3.2 Pising and Pipe Supnerts Walkdowns -
(a) Piping ,
ne Design Review Isometries (DRI) reflect the basis by which
. large bore piping was reviewed. Design changes are issued to the site for piping modifications and pipe support modifications such.
as additions, deletioni, relocations, and changes in support 1
direction, and the changes zioted on the DRI. When the field modification is complete, the design change document is returned to Engineering indicating insta11stion according to design or it is accompanied by a marked-up drawing indicating the as-built can' figuration. In either case, the as-built change ~ is incorporated in the DRI, the associated piping analyses rev.ieved and.any design differences reconciled. If necessary, additional design changes will be issued to assure compliance with criteria.
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ne process for small .bara piping is similar to that for large l bore. ne ' major difference is that small bore field run piping
- is controlled by th's contractor's drawings. RevisiWas are issued l -
i against these drawings and the resulting as-builts are reviewed as described previously.
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. (b) Five Supoorts ,
'ne process for large bore pipe supports is simikar,to that for
'e piping. When the design change document and mark -up drawing
'[' for the pipe support are received'. the support 'as-built is
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reviewed against the design change t.o assure pipe support and pipe stress criteria are still met and the acceptance documented.
In a f ew cases, another design change is issued if the as-built support is reject'ed.
De process for s=all bore pipe supports is similar to that for large bore. ne major difference is that small bore supports are controlled by the contractor's drawings. Revisions are issued against these drawings and the resulting as-builts are reviewed as destribed previously.
3.3 Instrumentation and Controls Walkdosn (a) Instruments All Design class 1 instruments were reviewed. by Engineering to determine their mounting characteristics:
2 (1)' Wall mounted - .
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- DCC Rev 0 4717 .
SUFF1-DIS As-12 06/24/83
-- - --. = = ; = _. _ _ ..-_.__ _ _ _ _
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4 (3) Mounted on annulus steel ,
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If any instruments are mounted on the piping or astiulus +
steel, i 4
_ . they are reviewed separately for required s,eismic gpalification
= 5 levels. ,
In general, instruments that are installed in various locations throughout the plant are qualified using " worst ca s e" required response spectra (RRS) envelopes and standard installation details. Where location or mounting details are considered critical to the device qualification, these have been verified by field walkdowns.
6 (b) Instrument Enclosures A valkdown by Engineering was cond' u cted to verify the loca: ion and arrangement of Class 1 instrument panels. Information obt'ained from this walkdown was used to develop representative models for the panels. The panels are qualified based on. these
- models and analysis using envelopes of RAS for all panel
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l 3, (c) Instrument Tubing Supports a ,
a f
. Design and installation of instivment tubing supporYs is based on standard details provided by Engineering. These details are used -
by General Construction as needed to layout a. particular tubing DCC 4717 SWP1-DIS .
AS-13 , Rev 0
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- f 24327 run. Details for use in special applications may be prepared based on criteria in the standard detail drawings. Verification l o-of g the instrument tubing supports is based enjinformation k S
_. . obtained by a walkdown performed by General Constry.ction. The
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- walkdown wa's done using a procedure approved by Engineering and General Construction. The procedure required that construction 6
personnel review all tubing supports in the containment annulus to determine the worst case configuration for analysis. The
, criteria for determining the . worst . case were the length of the cantilever sections and the total load on the support. Sketches ,
resulting fion the walkdown were transmitted to Engineering f or use in the calculation. -
l i 3.4 Mechanical Ecuipment Walkdown The ceisnie. qualification effort for' Design Class I mechanical I
l equipment includes a field walkdown as described below:
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Before performing an analysis or reviewing qualification test reports, .
equipment in the field is observed. Analyses are performed based on then current nozzle loads, spectra, and drawings. Each analysis is reviewed in order to determine which items are critical and should be 3, verified as-built, e.g., weld lengths, hold down bolt sizes, and
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embedment plate thickness. The critical dimensions are t3en confirmed
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I in the field., Calculations are revised, if appropriate.t.
DCC 4717 EUPP1-DIS As-14 Rev 0 q- y e g'w--P e m --+-v-wy wwgg & -,--,yrvv w,w,vw-e-ww-v
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- .. - 24327 3.5 RVAC and Class lE Electrical Ecuitment Walkdown In f.he process of reviewing seisr.ic analysis for EVAC _and Class 1E
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g electrical equipment and updating them to meet currentschicinputs,
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s' a field walkdown is undertaken. The field walkdown includes the measurement and id'entification of elements of the equipment critical to the seismic qualification. Where field installation conditions vary among simila'r items, individual . components are inspected and measured. The data obtained from the field walkdown is compared with the information used in the seis=ic analyses. If any differences are identified, an evaluation is made to deter =ine whether they af f ect analyses results.
4.0 IDVP WAIXDOWNS The IDVP has responsibility for field verification of certain aspects of the DCP verk as stated in the IDVP Phase I and II Progra= Plans. and -
subsequent Interim Technical Reports (ITRs). ITRs 8, 34, and 35 deal with the IDVP verification of DCP activities. IDVP field verification includes the following three areas: ,
(a) Overall modeling and methodology vill be evaluated on basis of
, consistency, with as-built- conditions (sampling basisj .
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(b) Selected details and dimensions.will be field verified. .
occ 4717 sUPP1-DIS AS-15 Rev 0 2.-._-..__._,,__
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(c) Required modifications vill be field verified (either on a sample
, basis or for specific modifications resulting from IDVP open items). 3
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.' ' ATTACHMENT 2 Page 1 of 1 TABLE 1
SUMMARY
TABULATION OF AREAS .
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0F ITP REVIEW OF DCNPP-1 AS-BUILT CONDITIONS i 4 i PHASE I FINAL REPORT TSUBJECT AREA PAGE NUMBER
- 1. CONTAINMENT 2.1.1-18
- 2. AUXILIARY BUILDING 2.1.1-29 2.1.1-42
- 3. FUEL HANDLING BUILDING 2.1.3-9
- 4. TURBINE BUILDING 2.1.4-21 2.1.4-24
- 5. INTAKE STRUCTURE 2.1.5-10 .
2.1.5-15
- 6. OUTDOOR STORAGE TANXS 2.1.6-4
- 7. LARGE BORE PIPING 2.2.1-6
- 8. SMALL. BORE PIPING 2.2.2-2
- 9. LARGE BORE PIPE SUPPORTS 2.2.3-4
- 10. SMALL BORE PIPE SUPPORTS 2.2.4-2
- 11. MECHANICAL EQUIPMENT 2.3.1-5
- 12. ELECTRICAL RACEWAY SUPPORTS -
2.4-1 2.4-7
- 13. HVAC DUCTS AND SUPPORTS 2.5-1
- 14. INSTRUMENT TUBING AND 2.6-2 l
TUBING SUPPORTS l
e 5" 4
-s t
l
- _ : _. _ -~~ z 7 ::. . .: : ~__ - __: :~ - :
~
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+
, ATTACHMENT 3 Page 1 of 2 TABLE 2 SUMARY TABULATION OF AREAS ,
OF IDVP REVIEW OF DCNPP-1 AS-BUILT CONDITIONS g r
i 4 7 PHASE I FINAL REPORT iSUBJECTAREA PAGE NUMBER
- 1. SPECTRA DEVELOPMENT 4.3.2-1
- 2. AUXILIARY BUILDING 4.4.2-2
- 3. FUEL HANDLING BUILDING 4.4.3-1
- 4. CONTAINMENT 4.4.5-2 4.4.5-8
- 5. INTAKE STRUCTURE 4.4.6-2 1
- 6. TURBINE BUILDING 4.4.8-5 l
- 7. LARGE BORE PIPING 4.5.2-2 4.5.2.3-3 4.5.2.3-11
- 8. SMALL BORE PIPING 4.5.3-2 4.5.3-3 4.5.3.2-2 4.5.3.2-4 4.5.3.2-10
- 9. TANKS 4.6.2-1
- 10. VALVES - 4.6.3-1 4.6.3-2 4.6.4-2
- 12. HEAT EXCHANGERS 4.6.5-1 .
- 13. HVAC COMPONENTS 4.6.6-1
- 14. HVAC SUPPORTS 4.6.6-6 jl5 . ELECTRICAL EQUIPMENT 4.6.7-1
$16. ELECTRICAL RACEWAY SUPPORTS - -- 4.6.8-2 i 4.6.8-6 +
4.6.8-7 f-9 -*G +**8M'* M-4hh
- WN* * ** " ' " " N -*
ATTACHMENT 3
.- Page 2 of 2 TABLE 2
SUMMARY
TABULATION OF AREAS OF IDVP REVIEW OF DCNPP-1 AS-BUILT CONDITIONS . {
(Continued) 3 i 4
- ~
i PHASE I FINAL REPORT TSUBJECT AREA PAGE NUMBER
- 17. INSTRUMENT TUBING 4.6.8-9
- 18. INSTRUMENT TUBING 4.6.8-9
- 19. AUXILIARY FEEDWATER SYSTEM 4.7.2-7 4.7.2-8 4.7.2-10 4.7.2-11
~
- 20. HELB REVIEW OF AFWS 4.7.2-14 4.7.2-16
- 21. MELB REVIEW OF AFWS 4.7.2-17
- 22. CONTROL ROOM VENTILATION AND 4.7.3-1 PRESSURIZATION.(CRVP) SYSTEM 4.7.3-5 4.7.3-6
. 4.7.3-7
- 23. HELB REVIEW FOR CRVP 4.7.3-5
- 24. 4160 V SAFETY-RELATED 4.7.4-2 ELECTRICAL SYSTEM
- 25. RADIOLOGICAL ANALYSIS 4.7.5-3
- 26. PRESSURE AND TEMPERATURE ANALYSES 4.7.6-1 4.7.6-5
- 27. JET IMPINGEMENT EFFECTS 4.8.5-1 4.8.5-2 l 28. CIRCUIT SEPARATION AND SINGLE 4.8.6-1 ,
FAILURE REVIEW 7 29. EQUIPMENT QUALIFIED BY TESTING 4.9.1-4 1 .
i
'30. RUPTURE RESTRAINTS 4.9.3-1 7 l 4.9.3-2 .7 1 4.9.3-3 f l
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-ity RED HEAD anchoring products with confi- 4 )
- e..We offer an anchor style and size for practic- AVallability IS M6V67 2 probient *
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.y seary 'as:aning applic~ation. Our quality ancnors RED HEAD ancnors can be wnere you want thern 1 i e btcked by the skilled engineering. quality control when you nced thern thanks to our nationwide network I id reliability represented by the narne RED HEAD. of authorized distributors.
Q 1 iN M M K > %5-i?" W b J S L J S k M d k 2 2 E N D 5 % M s .. ling Anchor provides
- ~
'tese casscst) es 88"*'-
- 8, e, ,3,* . i steel drill for every W8 # 1[8 g3*
p .,_.,,e, hole, eliminating the need for expensive and easily damaged carbide drills. Its unique de-
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we. size crete oesin etse 4,08a *s.
- sagn assures.conssstent holding caCacity Dlus T. ,,,,, , . . .
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1:stt stott ne. It's the mest dependa:le heavy duty anchor y: . s.ss %~ 1"I - *.~ %.- % 70 e sacret and clean in the industry. Installatien nith the 747
- e e.risce ne:ivs ltoto Stop Hammer creates ene of the fastest- eM
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systems"in the werfd.
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3,.p'v' ,3., '8ased on Independent Testing Laboratory _,,
33k",8 3 I'C$$,,
s , , , #, tests conducted n stone a ;regate concrete. ;[ L es.
eo, n .a 3 e
. e, For manufacturers recommenced safe work- 0.;? , ,,,,,,,
ing loads use 25% el above load values, ' j c.:. l s.it unie in'ls,,a- oisa- Pui8eet 8* * *'
traxa arence - Meets or exceeds U.S. Government G.S.A. A: , ne. l sia, seern creu i eter sert sacast.a asie Scecification No. FF 5 325. Gr:up Ill. Type 1. -2 nn o rnia n:ia. . r.i. . . -
.. .=,,- sv.- .- Jero 132s
- * (Dated ollCl571 , . J' a r is %.- % t' . nu- :oso roso For installation in structural light weight y" ~. inU,, I..*,[ $ $
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concrete use 70% of the above load values. M.
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r!Di TECHNICAL INFORMATION
/{DL bolt. Expansion is acecmplished by
- 1. Anchor Design ith a setting tool. Both the plug and ex Expansion of this anchor is independent of the fastening driving a prefitted plug to the end of the anchor after expansion wd to give'a pansion sections of the anchor are designe side of the hole.
before expansion-II h hk ;
lY.'[ h$h _
irtually cylindrical stress distribution, r unit over The distinguishing feature of this hors.
anchorThis design is the vreduces the pressure pe a large area, compared to conventional fh base' anc material failure. This fe of area of base material and prevents premature Special with low slip characteristics. llll[l2 3 expansion provides Conventional da maximumfriction against J undercut SKpansion Can wall of hole
,N o, stress concrete
- -i beyond its elastic lim!t fi
- 2. Maximum Working Load % of the average ultimatedvalue hould for a s The maximum working load should not exceedbe used depe 1 anchor size. The actual factor of safety to EE=. be selected by the designer on this basis.
- for 100% effective HDI anchor perform
- 3. Anchor Spacing The minimum anchor spacing and edge distancesManufactu ance according to EAMI (Expansion Anchor Minimum Anchor Spacing = 10 hole diameters
= 5 hole diameters Minimum Edge Distance j i ht line interaction diagram of pure s
- 4. Combined Loading Combined loads should be calc'ulated upon a stra g .
(S) and pure tension (T).
S app!!ed_ + T applied SI T allowable S allowable Use able overall Thre ad Anchor Length
- 5. Anchor Dimensions Hole Length Bolt size 7/16" Anchor Size 1" S/8"
- ; Description 3/8" 1-9/16" 11/16*
1/4" 1/2" HDI 1/4" 2" 7/8" 3/8' 5/8" HDI 3/8" 1/2"
~
2-17/32" 1-3/ 8" HDI 1/2" 27/32" 3-3/16" 5/8" 1" l
plus thread length. ,
Minimum embedment = anchor lengthMaximum ii
- e a
,01 -DROP IN ' ANUMuno . ,. ., ~ n -
NDJ .
ORDERING INFORMATION -
GENERAL INFORMATION h;fg h'**'*g f,#/
Maximum holding power through more uniform stress Key Descrip- Bolt 508 distribution in the surrounding concrete achieved by Cat.No. No, tion size Bit Dia. t.ength exc,Vve smooth, hole hugging design. w" % L" 100
-5490000 sa7 HDI %
Faster setting than comparable size self.dritting anchors. %" 50 HDI % * %" %
, 5490016 669 No installation problems-even in the hardest concrete. HDI % * %" % 8b" 50 _
5490024 690 25
%~ 2h %"
Pre assembled one-piece design eliminates lost plugs, 5490032 691 HDI %
- l assures expansion even in soft or lightweight concrete. %" l_
1* 1%" l 25
- 5490040 ,692 j HDI %
- l Corrosion resistant zinc plating meets or exceeds all applicable standards.
Bottom of hole not required to set anchor since it is designed with an internal plug which is set* from thethreaded ,
listed and ~~,'g}end approved of the anch and allows for either flush or countersunk installation. 767G ,m,,,,
Pipe Hangers" HDI INSTALL.ATION INSTRUCTIONS ' - 7, 3_ *
- 1. Set drill depth gauge to length of anchor, add- .
- s. xtygi g' ing the drill bit tip length plus %". _
% NC
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- i. e.nr ... 4.
- 2. Drill
- and clean hole; insert anchor. Anchor Setting Tools f . .
l 3..' Fit setting tool into chuck and full,y expand - - _ _ -
anchor, or use hammer and setting tool. -
- ~^ 'A c
l gey for Anchor No. Description Cat. No.
HDI %
f 661 MSD 6 _
, 5454504
/ HSD 10 HDI % __
5454520 663 HSD 12 HDI %
5454528 664
\% 665 HSD 16 hcl %
~5454536 HDI % j HSD 20 j
,5454540 ;666 i
- To obtain maximurn published hold ng velues, use only
_.d. -
7_. . -
Htt.Tl carbide bits. -
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'GEAER'AL INFORMATION M KWIK-BOLT FEATURES
" _- , ,, e., r. e .wnw e The heavier the load, the harder it holds .
1w. ... . Hitti KWIK-BOLT is manufactured from high
. X # _
tensile steel that's about twice as strong as a' J T g'
t-Grade Two bolt normally used in construction.
y ,( S'"
This provides greater holding power. Fewer Hitti KWIK-BOLT *S superior holding power is due' or smaller fasteners can be used. which means to (1) highest grade carbon steel construction, less drilling time and less chance of hitting (2) solid installation to the full diameter of the a reinforcing bar.
hole, and (3) 360* gripping action of the patented spring steel wedges. Bolt size is hole size.
You can use a smaller bit, reducing drill strain, EASY 3-STEP INSTALLATION worker fatigue and bit costs. Hitti KWIK-BOLT is ideal for through drilling applications, such as
- anchoring machines, conveyors, railings, etc. It mhh3
- ? eliminates double handling and templates, further lowering your "In place" f astening costs.
[-.! ,
7 ' A Hilli KWIK BOLT is a complete unit (nut, (er-r
~
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- N.7'.,, .
washer, stud or bolt).The correct size nut and
,...{ . s.* i ;
washer means quick, simple, dependable
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- j
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installatir.,a. There's no inconvenience or tims
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.] T.'e.,i .[
l'ost-handiing separate picces. There's less inventory, less loss.
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, .* [ .. Independent spring steel wedges.
Two wedges provide twice as much dependabili}
i.',.3[*)?, (*j {.;.. h.";, ",'.*'
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- as a one piece unit.They are pre-tensioned whea
. put into the hole. Fastening is quicker, since th
- 2. Insert 3. Anchor anchor is set as you tighten the material inte
- 1. Drill place. Independent floating action gives fu anchorage. Hilti KWIK-BOLTS give better holdi
- 1. Simply drill a hole
- the same diameter as the values than comparable anchors - an extra Hitti KWIK BOLT, with or without the fixture safety factor.
i in place. Don't worry about drilling too '
Bottom of hole is not necessary to set the an deep-KWIK-BOLT works in a " bottomless" . A Hilti KWIK BOLT sets itself when an objact is l
hole. f astened.4he amount of thread exposed is ,
l flexible, depending upon the thickness of the l 2. Drive the Hilti KWIK-BOLT far enough into the hole so that at least six threads are below fixture. Shimmiryg is not necessary.
the top surface of the fixture.
f,"ch Hi ti WIK-BOLT component is zine pla9
- 3. Merely tighten the nut. Resistance will according to Federal Specification 00-Z-3256 increase rapidly after the third or fourth turn, clear chromate plated for extra protection That's all there is to it. against corros, ion. Hitti KWIK-BOLTS arc sui:
aMe for M Moor ad odoor appkah
- 4. The wedges are progressively forced against and meet or exceed all known specifications the side of the hole thus exertin9 a compres-and standards.
sive reaction on the concrete rather than---a pure friction grip (See Fig.1).
At=.-
L ..._
- w=-
I, l fo obtain masamum putWished holding waives, use only NILTI cartnde tWes. - _ _ _ _ _
- *w**-.mgi , ,,
-.--- .--~.. -
.. J &C /04 /J.pg zE .
Task:
FILE Co Allegation or Concern Nos. 25, 58, 142, 154, 176 ATS No: RV-83-A-33,- RV-83-A-57, RV-84-A-0015, RV-84 A-0017, W%
'f, p k RV-84-A-0007 BN No: N/A M S *8 Y 'SY k Tel4%
Characterization 4f Alleged deficiencies in the installation of concrete expansion anchor bolts by site contractor H..P. Foley.
Implied Significance to Plant Design, Construction, or Operation Improper installation of anchor bolts could result in reduced load capacity of the anchor bolts with attendant loss of design function during normal operation or design basis events, including seismic events.
Assessment of Safety Significance This issue was discussed in SSER21 (NUREG 0675), pages 2-44 through 2-54 allegation No. 25. The staff's subsequent reviews of the issues in SSER-21
/
and other related allegations are documented below.
l l The concerns raised by these allegations involve the installation and inspection of concrete expansion anchors by the H. P. Foley Company. A general and non specific concern witE anchor bolts was supplied initially to i
the staff from an anonymous alleger. Subsequent interviews of onsite contractor personnel resulted in additional concerns with added detail in some
- (oS
- 1
. .,....,..n ~.. ~ n..- 4._. ~- + - - . ~ ~ - - - - - - ~ ~ ~ = - ~~ -~ ~
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cases. The substance of the initial allegation and concerns obtained from interviews have been characterized by the staff as follows:
. 1. -Phillips Red Head Stud Anchors have been forbidden for use in nuclear power plants.
I
- 2. Phillips Red Head Anchors are not good because at other nuclear power plants they have been removed or not used.
- 3. Many anchors have been installed improperly.
- 4. Anchors have not been torqued.
- 5. Phillips Red Head nuts are only tightened " finger tight".
- 6. Wa'shers are not used on concrete anchors.
- 7. Quality Control does not inspect or inadequately inspects anchor bolt
. holes prior to installation.
- 8. Quality Control inspection of 10% of anchors on instrument supports is inadequate.
The staff approach to resolution of these issues was to: (1) review installation procedures, audita, nonconformance reports, discrepancy reports, and licensee correspondence relating to concrete anchor bolts; (2) have an independent NRC contract team (Lawrence Livermore National Laboratory) inspect
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e.e a sample of 124 ele::trical raceway supports modified in 1982 (involving hundreds of anchors bolts); and (3) request the licensee to perform torque tests and ultrasonic examination on a sample.of 40 installed anchor bolts to
. verify the adequacy of installation
~
The results of the staff investigation, as applied to the general concerns listed above are:
(1)&(2) The concern that Phillips Red Head Stud Anchors are forbidden to use in nuclear power plants or are not good is not supported by any NRC criteria or industry standards. These anchor bolts are acceptable.
(3) The concern that many anchors have been installed improperly was not confirmed by field torque tests.
(4) The concern that anchors have not been torqued was confirmed, however, there is no NRC criteria which require anchor bolts installed in electrical, heating, ventilation and air conditioning, and instrument
, tubing applications to be torqued to any specified value. The staff also reviewed the licensee's electrical raceway qualification tests to determine if bolt torque was a significant parameter and concluded that l anchor bolt torque would not impact the use of the qualification test results.
(5) The concern that Phillips Red HesdTuts are only tightened " finger tight" was not confirmed. The " finger tight" check is a Quality Control
- l inspection point. The anchor bolt installation procedures require nuts l
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- _ . - . . ' . _ '
- _ " _ _ _
,m Action Required The inspector still has to complete review of the PG&E material concerning the
. items questioned by the inspector. Further followup action by the staff will be performed as part of the routine inspection program. .
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g k N T 3-69 FALSE FLOOR IN CA3LE SPREADING ROOMS IS NOT CLASS 1 During a walkdown of cable tray and conduit supports on January 14, 1984, the NRC inspector identified two Class I Electrical Raceway Supports attached to the Non-Class I steel supporting the diamond plate in the cable spreading rcom, elevation 127 ft. These supports were CSR-127-3-634 and CSR-127-3-573. The inspector also noticed several deficiencies in the installation of the concrete anchor bolts securing the structural steel to the concrete.
The deficiencies in the anchorage of the structural steel had been identified by a Foley inspector on October 7, 1983. The concern was based on the fact that this structural steel was being used to support Class'1E electrical panels in the cable spreading room. PG&E initiated a minor variation report (MVR No. C-1338) on December 1, 1983 to
,4s. bee =sLA-address the deficient anchor bolts. This was evaluated by GPEC"gand a y disposition requiring corrective action was issued to construction on January 11, 1984.
In addition, as a result of the NRC inspection MVR E-2773 was written pr me rasosrwG e**T1+G MRC 3 by PG&E on January 17, 1984 andsenttoengineeringforresolution.fis MYK (A>et uf }MN 10 misf91wsArtse dCsfa.$ on 44gjandy 19, Mst,r jysp 15 g 3df/Mr, Revosw'nD Tb MMIG k'/MCMit TMa* IMM If n consrMaestrod 36&ressah:;Y
(/KfR3%566)) oL Peenm& AG9a/ AIM 6- /$barAner.d; ef f AttleGCdd. MVdA/1~RsNA1*,
1P FSAR Section 3.2.1 addresses the classifications of structures. ,
Page 3.2-2 states " Plant features which correspond to Category I as identified in AEC Safety Guide 29 are designated as Design Class I."
In addition, the FSAR states that the Diablo Canyon Quality Assurance Program applies to Design Class I items. Design Class I items include
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those items whose failure could reduce the functioning of other Design Class I items (Item 17 page 3.2-5).
Contrary to the FSAR commitments, PG&E has not designed and constructed the structural steel supporting the diamond plate to Design Class I requirements.
tat- asu<.s a,,s.
- Sne el4 9n sit pav ferr>L 6sk lf DLS/&d Crfdedn'IA)f k empt,,a nc,g egge & M PCSL . Design Besos r4 by f ps/C P _1 m m p ! & -_ w u w = %Od-n Doc asamunL s,<
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) gg1 NRC Walkdown of Anchor Bolt Installations vb g
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%'~ &0 The NRC walkdown on Janauary 14, 1984, identified the following durn ef 4
deficiencies in addition to the Class I supports welded to Non-Class I structural steel.
- 1. CSR 127-3-77 One bolt installed at approximately 19 One bolt with projection of 2 7/16 inch with two nuts on the stud.
One bolt that did not have a full thread projection.
nomgrws-
- 2. Three BJH-17 junction boxes with one, boley missing on the cable
- arenantf.y spreading room floor.
- 3. CSR-127-5-11 Bracket pulled away from'vall.
- 4. Two loose nuts.
GEfGW140-4-1071-Support CSR 127-3-77 had been recently "as-built" and transmitted to PG&E engineering on September 10, 1982. The "as-built" identified the projection but did not identify the bolt angle.
SupportsGEfGW-140-4-1071 and CSR-127-5-11 have been documented by PG&E x
~
MUR E-2771 and MVR E-2772 for corrective action. ,
Foley QC inspected these junction boxes on January 19, 1984, by removing the covers. The missing anchor bolts were inside the covers, y v
73
_ _ _ _ , , ~ _ _ ,
,- . . . ~ - . . ..
' ~
I M /. ,N Wand s[wb N were installed in accordance with the detail requirements.
Wf /7til h! 25 -$ Foley QC will document the results of this reinspection.
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Problem Statement Allegation #(s): 1] -_
ATS No.(s): ND3d5}
_ .}
BS(s):
This document lists (or directly references) each allegation or concern brought to the attention of NRC personnel. The purpose of this statement .
l sheet is to assure that all points raised by the alleger are covered. j If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview).
Problem Statements (use extra sheets as n.ecessary) ._
i Allegation # Verbatum Statement or Reference -
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.k P Date This Statenent was Completed 9 d b M -
Technical Reviewer Signature *
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- ALLEGATION DATA FORM u.s. nuctEra secutATcay cc era ssion
, ,l "1f3 , _ _ _ _ ; inrreionsonr x ..oe e ~
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RECEIVING OFFICE Docket Number (if applicable)
- 1. Fi$ility(Iss) Involved: (Neman ,,
its more u.an 3. or it > '., L-A , M:w ':s
. 2 .
genonc. wnte GENERIC) ,
, j
. k 1- L i, t . .. . - .s < -
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l i 2. Functional Ares (s) Involved: i
' (Check appropnata boate.1) operations onsite health and safety i construction offsite heal'th and safety
- ' ~
safeguards omsrgency ;:reparedness
. other (specity) l l
( 3.
Description:
l!a lL lr !i-l/-l-l j l- l7l' l' l -l 4 l l' ' ll-l -l t l l dl d tl' l- l l"l lftl f l t-l l; lkl ,l 'il 1'lc l-. l f l t4l; lt l- lr- l/ l l/tl r li l #l lc ItclaI li:lcIml 131ol.-1..-IrIri Ir-1.l @ l< lei I Ic la 1 IclelW olvl !5l c1F l-Ic lNT131 l l l l l l'l l Ill
- 4. Source of Allegation: -
scheck appropnate boni contractor employee security guard licensee employee news media
, NRC employee private citizen l _ organization (specityl I other (specity b bl NI ~
Mb S E-MM OD YY
- 5. Date Allegation Received: >- -
u 6 3 3
i t I- ( %
- 6. Name of Individual (F;rs: two initials and tast namel b I l
Receiving Allegation:
I
! 7. Office: ei .-
rs s i
ACTION OFFICE l ~
\ ' ,' '
- 8. Action Office
Contact:
tr.rse wo initi.i. .no i..: n.m.: ll I~ I ~ (.
- 9. FTS Telephone Number: y g 3_}773
- 10. Status:
(Check onei Open. if followup actions are pending or iri progress
_ Closed, if followup actions are completed MM DD YY
- 11. Date Closed: 11.1 Document Nos.
l
- 12. Remark.: l l l l ; ; ; l l . ;. l l l ; ; i l ; ; ;-l ; ; l l
,iu m. so ch.,.ci.,ei l IIIIIIIIIIIIIIII IIIIIIIII 12.1 Man-h rs Date ofnee Year Number
- 13. AllegationNum R 1/
A 3 -A- O 0 3 3
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, Tank: Allegation or Concern No. 27 ATS No: RV-83-A-33 BN No: 83-02/14 Characterization:
Inadequate welding procedure and quality of welders and materials used in Superstrut construction for cable trays, conduits and instrument supports.
Action Required No further action required on this allegation - refer to SSER 21.
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FILE C o *N l Task: Allegation or Concern No. 28 99 ATS No.: RV 83A41 BN No.: 83-161 (10/18/83)
- 4. F e-
- Characterization k -
it k
lus structure reverification.
Action Required Information to be supplied by NRR.
4*
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g Task: Allegation No. 29 a g V .
ATS No.: RV 83A41 BN No.: 83-161 (10/18/83) e-
"t Characterization +
4 %
P5peRestraintDesignInadequate.
Action Required No further action required on this allegation - refer to SSER 21
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ww e !. m==du m e 4p e* +ewo-*vm-p q--eW e N- m _ *^--w-**-h+* * * * + - - - " **""**"N'**-
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- e Task: ,
Allegation or Concern No. 30 "=%% .
ATS No.: RV83A41 BN No.: 83-161 (10/18/83) e-
. Characterization 4 4
i 4 S5fety-relatedequipmenthasinadequate/untraceabledocumentation.
Action Required No further action required on this allegation - refer to*SSER 21 e
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ne m - e e m e m +e -e"'- D' * -
- 9" 9*"
- m eang e sy ++ ime ae me e -A+-e w w.ea em gr emv eme'aww--s _
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l Task: Allegation or Concern No. 31 L W ATS No.: RV 83A41 BN No.83-161 (10/18/83)-
e
- Characterization 4
4 i I Qh procedures for structural analysis.
Action Required Information to be supplied by NRR.
4 a
- k 3
,e.e' w 4 me N esmerm-* WeM N-W-a -e N ****% * -' + " * ' " * * * * *~# *
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Task: Allegation or Concern No. 32- I W
ATS No.: RV 83A41 BN No.: 83-161 (10/18/83)-
+
. Characterization 2,
i 4 55emicanalysisorcontainment.
r Action Required Information to be supplied by NRR.
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<-w % s. w w e** -hw .=e- *- =- , - - - = = * =*---=-*-m++ + = - e w -e- -
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Task: Allegation No. 33 Fil E CD ATS No.: RV 83A41 BN No.: 83-161 (10/18/83) e TF
' Characterization +
i I TheturbinebuildingisdesignedasaClass2structurebutcontainsClass1 piping and equipment.
Action Required Re further action required on this allegation - refer to SSER 21 "I . .
- a t
a J
C Task: Allegacian or Concern No. 34 pl' a E b n
V, oy/
ATS No.: RV 83A41- EN No.: 83-161 (10/18/83) 9
' Characterization +
k k I complete as-built drawings.
Action Required Information to be supplied by NRR.
ew a
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. _ , . . - , , _ . _ _ . , _ _ - . . . , _ . _ , _ _ . . _._ . _ , [__=...,,_,m. . . . . - . . . . _ . , , _ _ _ _ , . _ _ . , _ _ , _ _ _ . _ . . _ _ _
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DIABLO CANYON PO'.?ER PLANT PLANT DESIGN C0'"4ENT_
s No. 559 1.3]ECT: P.CS 0.or, a ressurization Protection Eystem ht Low Terf,catures +
I P ORITY: 800A - LONG TERM - REQUIRED FOR HEATUP FOR LOW POWER TESTING 1*
F.EFERE*;CES: 1. W Report " Pressure Mitigating Systems Transient Analysis Report,"
cated July 1977.
- 2. W Letter PGE4049 "RCS Overpressurization at Low Temperatures,"
dated July 9, 1979. File No. 428.4 from W. C. Gangloff to D. V. Kelly.
C0! PENT .
It is our understanding that administrative controls placed on plant operation This is
- to prevent RCS overpressurization transients are no longer necessary. '
due to the implementation of the RCS Overpressurization Protection System -
which uses the pressurizer power operated relief valves as the protective
- equipment. We believe that the basis for the relaxation on administrative .
controls can be concluded from the Westinghouse. report " Pressure Hitigating Systems Transient Analysis Results" dated July 1977. In this report all i credible RCS overpressure events (based on records of Abnormal Occurrence These included:
Reports) during RCS water solid conditions were analyzed.
- 1. Mass input pressure transients
- a. Inadvertant start of an SI pump
- b. Loss of letdown flow with a 120 gpm charging rate
- 2. Heat input pressure transients
- a. RCS tempterature asynynetry - steam generator reactor coolant hotter than - -
remainder of coolant.
- b. RCS temperature asynsnetry - reactor coolant in loop seal piping (between steam generator and reactor coolant pump) colder than remainder of coolant.
- c. Inadvertant energization of pressurizer heaters. -
- d. Loss of decay heat removal.
- The conc 1'usion of the report was that the most severe over pressure transient In our case, a single pressurizer
'was the inadvertant start of an SI pump.
. power operated relief can limit this pressure transient to 490 psia; well within This was confi'rdiiWin W 1etter PGE 4049 dated July 9,1979
' allowable limits. p titled "RCS Overpressurization at Low Temiferature." '
f.
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89 S
- "~
Plt".t b: sign Comment tio. 559
. .' ' PaSe 2 .
RECC""ENDATION
. y Since the RCS Overpressurization Protective System is now suff{cient, we feel ye do not need the following administrative controls previous 1A used for over-pressure protection:- -
. Letdown valves 8149A, B, and C remain open d'Uring RCS water solid condi-tions.
- 3. SI pumps have their breakers racked out in modes 5 and 6. .
. 4. Loop 4 RHR suction valves 8701 and 8702 are open and racked out in modes 5 and 6. -
- 5. Restrictions are placed on restarting re> actor coolant pumps when they have been shut down for more than 5 minutes.
.. 1
. 6. RER flod changes are required to be made carefully. -
s . 1
. We would like W to, concur on these items since they are listed in our pla'nt licitations and setpoint document, page 40.
~
- p. c Y .
R. C. THORNBERRY DBMiklush(69-2451):slj 12/16/80 .
. xc kHFujimote l PPKristensen -
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- Mr_ D P *Thnenho,,y _tmairn nrco Ext. ---
, RM ' RD Etzlez/DA Rockwell ta oi;On GC Instrumentation Exi. 2732 UBJECT Timely revisions tn Plant PrnM ner NPAP E-4 __
File No. __
Attarhoa nione, r4nd a enny nr momn wh 4,.h i m,.nte +n ur JM ,gier1gn nuer_e4ght mnnthe ann in which Y nnfnted nrit an o r,.n ,. 4n plan, y, n ,,31 vn1,,mo +3A aann,,nr4 3tgr _
Rpennhen" annrnvimately civ wanke i n t o ,. 7 ,.,coiy,a a roennneo +1 + hie momn vrne (MF- Rob Fisher $ who assured me that he had changed Volume 16 to reYlect actual conditions ir 1 .y As of today's date. however. this chance has still n' ot been incorocrated by revisino ,
Volume 16. nor has an "On-the-Soot Procedure Change" been written and distributed as rpnui red by adminie tra tivo nrnendura NPAp F-d _ ' in offset; the nna ra tin n infnrmatinn availahla tn the ennten1 renm Onorn+nce hac hegn 4 n,-n rre ct per ei nh* mon +he _ Sinee vou stand comitted to the safe noeration nf Diab 1n ranynn. T'm sure that nne nf your nrimary ennearne 4e that the Onora'tnre i n charna nf the reactne hava nunilahla tn t h o r-- __
the most un tn dato and technically cnrepet infnematinn which we can ornvida. Tn the 4"*e"ert of auclecr :cfety, then, ! . culd 'ike to requcct thct ycu invc:tigct; .cht the r there is som 4aadequacy 4a "" EJ "ich clicef: thi: cituction to devcicp, or tether-the nrnendura eimnly waen't fnllnund in + hie caen Sincerely, M //-[%
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I l} /(/ V PLY .
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SLY BYi P G and E EXT. NO.
l isTRUCTIONS - mEnsOvg vtLLow COPY ANO SENO WHITE ANO PeMst COPtES WITH CAmeOM ONTACT. WMcTE COPY WILL SE RETURNED wtTH W Y. REMOVE SET FROM PAD SEFORE USING.
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w:,vnucTsOws - me eva veus,w em . .sw. ==,vs aa. aa n comes wiva ca. .,..,, ..., ,, ,,u. . actu== . wire.
t~.#b'#. CEteOVE SET FROM PAO SEFORE UStNS.
O e N'e. #' p-e ee se maWW---e.=. M 8,b ' em wei-. we.m-.w.mme - . , , , . , ,,
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Port 50, App. 8 -
Title 10-Energy (
t commensurate ortsinal design and with be those approved appued by thetoorga- the - mentTequiremenWahatt brsys!!hble st the !
- nization that performed the original design nuclear powerpHunt or fuel reprocessing !
i plant site prior tapriaranaf1onser tese of such
' unless the sponalble appUcant organtwarian desfgnates another re , material and equipt. This documentaryl; evidence shad be retained at the nuclear i I W. nocUnsm? Documr coNTa% powerplant or fue repransamina plant site '
. and shall be suffielent to' Identify the specif. .
Measures shau be estabHahed to assure Ic requirements. such as codes, standards, or t that applicable regulatory requirements, g
, demisa bases arid $her reunirements which ppecifications, met by the purchased materi-are necessary to assure adequate quality are al and equipment. The effect;~ 4 the a suitably included or referenced in the docu. control.of quauty by contractors and sub- ,
ments for procurement of material, equip. contractors shall be a==*amed by the appu. .
cant or designee aidaterv ' --- -- t with l ment the and services.
appucant or by its whether contractors purchased or sub.by the importa= co:npleakty, and quantity of )
the product or servious. j t contractorm. To the-estant -. *y pser j curament documents.ahan require contrac. vus. pDrrrricAT1oM AND Corraot or * .
tors or subcontractors to provide a quality.
saggance w - uATen1ALa. FARTS AND CoMroNDrrs I i
tagen_ip , _g. consistent S j pendix with- .athe.per Measures shtU be established for the
- v. nrsTaccTroms, reocapenas. AND DeAWINes identification and control of materials. I j parta, and components.* MM paltta9y ,]
Activities affecting quality shall be pre- fahrtcstee assoudnians. These ======Jhan ,
scribed by documaused instructions. proce- thure tJest-Identification-of-the .umenJs ,
dures, or drawinsa, of a type appropriate to maintained by,haubaardser, parMemenber, l
- the et mata-a and shan be amom- eit i pHahed in accordance with these instmc- @her on the items or on records traceablel toberI i l
130A8 D the item as required throughout fabrica- j i
proce'dures. or'm. w drtWmss.
drawines shau include Instmetlom, appro* tion, erection. Installauon. and use of the .
priata quantitative or en=HtaHve acceptance Iterr These identificauon and control meas- l criteria for determining that importan* ac .hw def@e' -'Nures shall be designed to prevent the u ti{ Lies have. been satisfactorily scessa. ,n.p ,
~AW k
,,,,,,,,,,,,,,,,,,,, xx. corraar.or sraew.noceseas I j Megge gl3g3 bg Wahlinhart gg eggg,g) Memprocesses.
shad be MMed to assure "
i theh of h auch as knagrac- that speefal 'aa'"dt -
- {
- tiana, prosedures, and drawines, meinding "" *---~. and riandana,ustive-tastin , i l abenses theroes, wheen preserste na asert, are Entrolled and -="" " r"g. *
' ties affestAng quanta. These ameneusasphil fled personnel.using 9saHMaa pyggedaggs ja-e- -- _m g h gjjg ennHemhta ggglg, gt3M
! = :- " --- er aaa= and.asswooed.for spedfleations, ertterna, and other special re
, 1 i . av - Dersammel and are dis. getrementh , {
ews.--s a maa -
l l m .re ,
ae tha - ,;, erg i Changes 4e r+-- x.1 sr er - -
- La shall.be reviewW i and approved.4y..the same art ="i==88a"a A posesasadorathspection of.assevet>c"aff i that performed the cristaal-revnew and ap. feWershou be estabitsbetand er- s '
l pmal unless the applicant da=ignataa.an* senated by ar Jas.she erganisasiananersamma- : l l
cther rumocasible organisatica. ing the activity to verify conforma- with the documented instructions, procedures. l l
l Tu, omrract or roncasasse maTwar, and drawines for accompf fshire the activity. I i
==oir-rr.a =vm ._
s
_ Seek inspectio,n,.a.han be perfornned.by Jads. l
. tho,a -ene.nhe Measures shan be estahllshed to assure estavity--beits..laspected. Examir ations.
that purchassuLanatatini, egsh. ^ and measurements, or tasts of material or prod-assWens, through whether partinesed directly or Uets processed shall be performed for each
. .cont.ractors u ._ and sabeen*2 actors, work operstloo where necessary to assure m
f sta,
- These ameasures shad include provtsions, as quauty. If laspectaan of procommed material or preshaeta is insponsible or disadynata- 8 ties.' objectivea ev danas of quality furnishedappropriate. geous. Indirect contrtl by monitettagwee fanaoures proc->==adastande by the contractor or subcontreeter. Inspoo- amming methods, equipment, and personnel .
- tesa at the contracter or subcontractor shanesa be amenMertar provided. BatirinapsuetoninnerDfWt-shan he provided whan men.
l soures, denvery. & - and avame== alan of- products upon trot to iandavaa8* without-both. If c2anda.
_. - tory inspection head points, which require im = . . -
} eena.4. the meure- witne.das or :nspectaps by the appHennss -
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, , c .. EscIMIZRING DEPARDIENT DESIGN CHANGE
' Suzzr 1 e 3 -
, . DIASt.0 CANYOH 1 & 2
. ~ ;e C, ~
I (Pz.ANr)
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1 R. A. Young, 'd. Vahlstrom, T..". From: R.D. EtIler, D. A. Rockwell , R.P. '
- _ h,In:
Crawford, F.J. Cucco Gilbreath, John H. Coocer N.
Description of change: To orevent damace to the #No nieme due to inadver+ent einence
_of suction valves 8701 and '170? at nernen d nn'C 72-R1 (cas i'DDR 8 PIci-R1-nPDinc7)
_,and to elininate olant maintenance on a system which it notused.theateabandnntha
, fame
- RHR tamnere ture/nroeenre nentectinn evete- enneietinn nf Dcsdn1A/2. Dc-AncA /D.
~
Tb4EAA/'t PM An4A. and anviliary relave PF An1AY P' f an7 tty PF A04AY/TE 44A. and g
PC 405BX/TC-454 This systen is no lancer OPERABLE since Technical Soecificatien
" i 46 .neaa on
- 3. A.9.3 r=n Moces auires Ina4.5.hawer n ce removed fenn the rotor coerators for valves 3701 and ,
, 8702 whenever these valves are onen. Tarbnical Enecieicatinn A.5 7 rannine tha+ +be l erwer he remnved fenm thee, nnovatnre when tSo valvoe are cinend 'T n rea14*v- nnwo*
g
. vill nnly he ann 14ed when 4+ 4e daef-ed +n nnnn av n1nco +%oen valvoc Estimated Field Construction Coet:
Effect on Project Schedules @ Hone Other (Pwp1 = 4 n)
Construction Statuss @,NotStarted CPartiall'yComplete Completed I Documents affected by changer F4to ear +4nne 4C 7 and 7 C 7 a77CQ7 in7n17 ek 1989,79Q l In7n1 A ch AR*.Af' in*>n7 ch 78 - and zeenr432nd atoman+me, afsnemme 4n+=e-nnnar*4nn
( ' ;/. dianr me. and diacree of ennnectione.
I.ist of a ch===*=: Sumwv Desinn Chance Safety Review + attachments I.V 2-G d E-#f J. % 2LfB7 *i' ?~ 776 2 /~ G7//
hh # Y i
[$ecdwe//) Requested by John H. Cooper, Field Engineen/Mk s / % %'s 7 Requested change is:
a O Approved at the site by per telecen with on O AFproved 4 O moted, document change not required
, G Rejected (explain) o a norm Ois i= not authorized to Proceed prior to design document revisions in accordance with this Design Qiange Notice.
Safety Related Work: Ore. Ono Additi==al documents attached res no e.
Reviewed by: Ayyaww=/. by:
y scipline Engineer Data Group I,eadar/ Supervisor Date
, h Euclear Project Engd.neer Review Requized. Signature _
e %
RECZIVED REVISIONS'd REVISIONS RECEIVED RECEIVED CDMPI.ETED' APPROVED ENGINEERING DESIGN DRAITING A/E-CONSUI. TANT
( - .
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BY BY BY 3Y BY Data Data Date Data Data f .- .. .. g
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i vapzrIC CAS AND ELEC:RIC kh.'DGD-GF.,=2515-Rev. 1
.g ,3332C3
- CIANGE 17
- 3;:sqI:sttX::2s3 DEPAJtttI:rt SEEE2 3. CF
' . sAs :se. -anh
- Al A/
Ot'ablo Canyon, Uni =(s) ,W Si ' @\ ' l f* T=m RD Etsler, DA RockweII. RF Gilbreatha as . Yoiana. V.Vahlstros. T.N. John H. Cooper _
CraWord, F.J. Cueen q
- sc=.pcias of change .
This M eion sc:: not . wca-h the oridn=1 DCO. but merelv ,
' l provides sapplementary inforestion concerning similar dOproblems810MGuire-1, at othe4-27-81) nuclear plan J
' Attachek are copies of IN=0 Ideensee Event Report usabers 7 7803: Trojan, 3-20-78:
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Mr. T. W. Bishop, Resident ,,...-
LosOs{s, CA 93402 Reactor Rdgion V projects and Engineering Programs 4 150 Maria Lane ,
j Wdtnut Creek, CA 94596 Dear Mr. Bishop tions concerning the RHRThank you for your letter responding to my 8-28-82 allega-Canyon. (Residual Heat Removal) system'at Diablo this investigation,Your and officeI seems appreciate to have spent that fact.quite a bit of time on I however, that much of the information which I gave to Mr.I am concerned, powers during the interview in August of 1982 was apparently not passed on to the Site Representative at Diablo Canyon.
who " paraphrased" my allegations for Inspection Report No.The inspector 275/82-42 50-I would seems to have " missed the point" on several of them. !
like to take this opportunity to restate my position
- on to Mr. Powers. at Diablo Canyon as I previously described them the problems ,
I have attached a copy of " Allegations Regarding the Diablo Canyon 5 of Inspection Report ResidualNo Heat Removal System" beginning on page these allegations paragrap.h by paragraphs and will comment on 58-275/82-42, i
i (a)
! circuit drawings for valves 8781 and a782 as your inspect l h
j report stated. In fact, I provided Mr. Powers with excerpts from i logic diagram explaining 458848, how and electrical this circuit functioned. schematics 437592 and 458846 I pointed out that it was
{ SSPS(Solid State Protection System)not clearly shown on any of them th suction valves to fail closed. I output relays would cause the
, RHR for said_that the power mour ce the iS595_ relays in this circuit shouls co shown on electrical i h
Schemat e- 43759L ,.
electrical schematics _ Theatomission Diablo Canyon of *:hisled informatiE6am to personnel the error 4
causing the inadvertent closure of valve 87e1 and the isolation I i of the pie 57 RHR datedpumps 5-29-81). suction with a pump running (see NpPR DC1-81-OP-' :
1 (b) I did not, at any time during the interview with Mr.
Powers, mention the gh_ygie53 routing of the RHR control cir-
- cuitry. I stated that neither the Senior Control Operator or the i
tiprough the 5805 and that removiMf'the power from the SISC- l relays would cause valves A791 and 8782 to fail closed.)$PS output
.This fact i
{
was paragraph. demonstrated on .
September 29th as mentioned in the9eevious f/ l l
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l (c) . This belows section contains several- errors.which I'have 31sted {
y 1)The SSPS does est, amplify, or in any way[ change the 1 1
i signalcabinets.
relay from the Westighouse "hagan" racks to thge auxiliary I t
- I explained this clearly to Mr. Powers. eM gave him a hand-drawn schematic depicting the complete i
- system function for your office to review. The person within PG&E who told you that "the solid state protection system completes the lo output signal (amps. ). . . gic function and generates a larger electricity. " had-best review his basic 2)That this is a standard Westinghouse design is true, which explains why the Westinghouss reactors are prone to RHR3)suction valves going closed inadvertantly.
I That the PG8E management is " unaware of any problems 3 :
A with this arrangement" is curious. On 1-16-82, I submitted k Design Change Request No. DCO-GE-2518-Rev.1 to PG4E Engi-n1rering. This DCR requested that the RHR system at Diablo l
Canyon be modified to prevent reoccurrance of the incident hq of 9-29-81. Attached to it were copies of 16 Licensee Event p l f capability at other power plants in the Country. ThisReports DCR descri i
I was approved by D.A.Rockwell and R.D.Et21er, both of whom k were present during the NRC investigation into these allega- J i tions.
Powers.
Copies of these LER's were also provided to 'Mr.
(4) The major point which I made to i4r. Powers was that Np the SSPS relays in this system perform D9 fMDEli9D MDA129:
ever, reduce the reliability'of the RHR system, cause a potential forof regardless damage the fact to the RHR pumps, and should be removed, Design". that this is a " Standard Westinghouse t
i (d) I pointed out to Mr.
' been made to "get rid of this problem", Powers and that several gave his attempts a copyhad of
)
E* design change request No. DCO-GE-2518-Rev.1 which I described in paragraph (3) above.
}
Comment No. I also gave him a copy of plant Design i
( your Site Representative confused a " drawingchange 559 which concerned valv request" for J a " design change request".
f (e) I showed Mr. Powers that one portiers of the Diablo Canyon FSAR claimed that valves 8781 and 8702 would close auto-mati.cally on an overpressure /overtemperature condition, while another portion claimed that the power would be removed from these valves during operation. Obviously, a valve can'.4 auto-I matica11y close when the power is removed from its motbr operator) As to the NRC finding that this contradictiet, in the FSAM presents no " noncompliance with regulatory requirements",
may I call your attention to le CFR 58.71, paragraph (e), which annually) that the FSAR be up' dated periodically (no less than requires and shall " reflect all changes up to a maxieum of 6 l
months prior to the date of filing. "
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(f) pG&E maintains that the spurious closure of a motor-operated valve is essentially impossible. As previougriy mentioned, copies of the following Licensee Event Res(orts, all instances of spurious RHR suction valve closures, warte given both tokMr.
I Powers and to pG8E Engineering LER 369-81072r_McGuire-1; 338-79145, North Anna-1; 34G-79036, Farley-1; 344-78010, Tro,1an; 345-80077, Farley-1; 316-80060, Davis-Besse-1;344-76000, Tro,1an; 346-80038-1, Davis Besse-1;316-80013, Davis Besse-1; 339-80001, North pnna-2;346-77000,7 avis Besse-1; 302-80015-1, Crystal River-3; 369-81129, McGuire-1; 317-74000, Calvert Cliffs-1g 346-80000, Farley-1; 3.10-79038, Calvert Cliffs. Why pG4E continues to ignore this evidence is beyond me. -
/ (g) Yes, an RHR pump motor trip is annunciated in the I control room. Unfortunately, the pump motor only trips after the pu:np has been damaged by overheating due to lack of flow; Yes, '
the during monitoraccidentlightconditions, boxes show RHR' suction valve position, but only not during normal operation. When valve 8701 went closed spuriously on 9-29-81, the Control Room Operator would have remained unaware of the fact until RHR pump failure had not a consciencious painter who was working near the pump called the control room due to the loud banging noises the pump was making.I stand on my original allegation: During normal operation there is no control room annunciation that an RHR suction valve is in the closed position, and there should be one to prevent damage to the RHR pumps.
(h) (a) As I explained to Mr. powers, Nuclear plant. problem 3
[ReportNo. DC1-81-Op-A1057 was initiated on 9-29-81, but signed
)j' off as complete wit 9.t1 anx plant management review. When I became aware of this, I contacted Juanito Diamonon, the head of the DC department at the time. NppR DC1-81-Op-p1057 was resurrected from the " closed" files and signed off by Jim Sexton, but classified as '"non-reportable" and without any follow-up $ h l
L (cause of the incident. action such as an RHR pump inspection or investigation into the
- was RemovaA Capa I alleged that both the loss of Residual sty and the failure to report it were repor- l table; The Ievents", former under 10 CFR 50.72 "Notificat ton of significant k
'4 ' which states that: " personnel error or procedural inade-quacy which, during normal operations, anticipated operations, occurences, or accident conditions, prevents or could prevent, by itself, the fulfillment of the safety funcion of those struc-tures, systems, and components important to safety that are
( dowm needied .. *to.. must. (ii)be remove reported residual to the heat NRC. following reactor shut- .
u
- (1)
I am aware that the Diablo Canyon FSAR claims that the RHR not safety suction pump relatedfrove the RCS(Reactor Coolant System) Hot Legs is ,
but my question is tdly! This system is )
certainly necessary, to mitigate the consequences of an accident of the small break LOCA type, so why is it not safety related? In the newer Westinghouse and Combustion Engineering desi 2 ns this '
systear is considered safety related and is totally redundant, y not at Diablo Canyon? so 3
- - - - -- -~ ~~ ~
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That the NRC Site Representative considers it "not of safety solved, significance" that a problem report has beervopen, unre- %%
and unreviewed for 3 years is puzzling to ry.
(1) PGAE elaims no awareness of the incorrect klarm listing 1 in Volume 16 of the Plant Manual. That is really funny, %,
tonsidering that I sent memorandums on this subject to both Mr.
.i. M.
Giscion, the power Plant Engineer, and the second to _Mr. (
' R. C.' Th,ornberry, the Plant Manager! I gave Mr. Powers copies of }
these two memorandums during the interview.
Although your office has gone through the motions .
of an investigation into these problems, it seems to me that the questions which were asked of PGAE were trivial or incorrect representations of those concerns which I conveyed to Mr. Powers.
In addition, it appears that AGSE's answers to even those were accepted without question or follow-up. Furthermore, in the instances where I provided Mr. Powers with documents proving my allegations, the documents were not made available to your Site Representative or were ignored.
I can only hope this and the 14 month delay in answering my concerns can be explained merely as a lack of communication between the Office of Inspection and Enforcement, your office, and the Site Representative at Diablo Canyon.
t Yours Truly,
[-
John H. Cooper k
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