ML20235B766
| ML20235B766 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/06/1987 |
| From: | Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 10400, 10400-V01-R02, 10400-V1-R2, NUDOCS 8902140425 | |
| Download: ML20235B766 (149) | |
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EMPLOYEE CONCERNS SPECIAL PROGRAM VOLUME 1 CONSTRUCTION CATEGORY SUBCATEGORY REPORT 10400 EMBEDS UPDATED TVA NUCLEAR POWER
m TVA RMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL l'ROGRAN REPORT TTPE: SUBCATEGORY - Construction REVISION NUMBER: 2 Final Report TITLE: Embeds PAGE 1 0F 121 REASON FOR REVISION:
Revised to incorporate SRP, conunents TAS review commenta, Revision 1 incorporate line management responses, and finalize report.
To incorporate SEP and NRC conusents, line management response (s),
additional evaluation findings and refinalize report.
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i Preface, G1tssary, and List cf Acronyms for ECTG Subcategory Reports HISTORY OF REVISION
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REV NUMBER PAGES REVISED REASON FOR CURRENT REVISION 3
i To clarify that one or more attachments will help the reader find where a particular concern is evaluated l
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TVA EMPLOYER CONCERNS REPORT NUMBER: 10400 SPECIAL PROGEAR FRONT MATTER REY: 3 PAGE 1 0F vili Preface
'i This subcategory report is one of a series of reports prepared for the Employee Concerns Speciti Program (ECSP) of the Tennessee Valley Authority (TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (0NP) employee concerns filed before February 1, 1986. Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns. Each of the concerns was a l
formal, written description of a circumstance or circumstances that an l
employee thought was unsafe, unjust, inefficient, or inappropriate. The mission of the Employee Concerns Special Program was to thoroughly I
investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP. employees, the NEC, and the general public. The results of these investigations are communicated by four levels of ECSP reports: element, subcategory, category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's j
reactor unit 2.
An element consists of one or more closely related issues. An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns. For efficient handling, what appeared to be similar concerns were grouped into l
elements early in the program, but issue definitions emerged from the l
evaluation process itself. Consequently, some elements did include only l
one issue, but often the ECTG evaluation found more than one issue per l
l element.
Subcategory reports summarize the evaluation of a number of elements.
However, the subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report: a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
Additionally, at the end of each subcategory report will be a Subcategory Sunuaary Table that includes the concern numbers; identifies other subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic appilcability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE 11 0F vill The subcategories are themselves summarized in a series of eight category reports. Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction material control operations quality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual. The Manual spells out the program's objectives, scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and closecut of the issues raised by employee concerns.
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1 TVA RMPLOYEE CONCERNS RRPORT NUMBER: 10400 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGR 111 0F vill ECSP GLOSSARY OF REPORT TERMS
- classification of evaluated issues the evaluation of an issue leads to one of the following determinations 1
Class At Issue cannot be verified as fsetual l
Class B: Issue is factually accurate, but what is described is not a problem (i.e., not a condition requiring corrective action)
Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D: Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
1 collective significance an analysis which determines the importance and J
consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see " employee concern")
l corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence, criterion (plural: criteria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see also " requirement").
element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues, employee concern a formal, written description of a circumstance or circumstances that an employen thinks unsafe, unjust, inefficient or inappropriate; usually documetted on a K-form or a form equivalent to the K-form, i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE iv 0F viii evaluator (s) the individual (s) assigned the responsibility to asisess a specific grouping of employee concerns, findinr.s includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation process, raised in one or more concerns.
K-form (see " employee concern")
requirement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based, root cause the underlying reason for a problem.
- Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-related, unreviewed safety-significant question).
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM FRONT MATTER REY: 2 i
i PAGE v 0F vili Acronyms AI Administrative Instruction AISC American Institute of Steel Construction i
ALARA As Low As Reasonably Achievable ANS American Nuclear Society 1
ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials l
AWS American Welding Society BFN Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual CMTR Certified Material Test Report C0C Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON)
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE vi 0F vill DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division of Nuclear Training DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ECN Engineering Change Notice ECP Employee Concerns Program l
ECP-SR Employee Concerns Program-Site Representative 1
ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Med) cal Response Team EN DES Engineering Design ERT Employee Response Team or Emergency Response Team FCR Fleid Change Request FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training i
HCI Hazard Control Instruction j
HVAC Heating Ventilating. Air Conditioning l
l II Installation Instruction 1
INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice i
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v TVA EMPLOYEE CONCERNS REPORT NUNBER: 10400 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vil 0F vill L/R Labor Relations Staff MLAI Modifications and Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board MT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch NSRS Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC) i NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health Administration (or Act)
ONP office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction
a.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE vill 0F viii QCP Quality Control Procedure QTC Quality Technology Company RIP Reduction in Force RT Radiographic Testing SQN Sequoyah Nuclear Plant SI Surveillance Instruction SGP Standard Operating Procedure l
SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff i
T&L Trades and Labor TVA Tennessee Valley Authority I
TVTLC Tennessee Valley Trades and Labor Councli UT Ultrasonic Testing i
VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant i
I WR Work Request or Work Rules WP Workplans 3
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 121 Outline of Contents Page Number SUBCATEGORY EXECUTIVE SUKMARY 1.0 Characterization of Issues 5
1.1 Introduction 1.2 Description of Issues 1.2.1 - 1.2.3 Generic 1.2.4 - 1.2.6 Watts Bar Nuclear Plant 1.2.7 Bellefonte Nuclear Plant 2.0 Summary 8
2.1 Summary of Issues 2.1.1.1 - 2.1.1.2 Generic 2.1.1.3 Watts Bar Nuclear Plant 2.1.1.4 Bellefonte Nuclear Plant 2.2 Summary of the Evaluation Process 2.3 Summary of Findings 2.3.1 - 2.3.3 Generic 2.3.4 - 2.3.6 Watts Bar Nuclear Plant 2.3.7 Bellefonte Nuclear Plant 2.4 Summary of Collective Significance l
2.5 Summary of Causes 2.6 Summary of Corrective Actions
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM t
REVISION NUMBER: 2 I
PAGE 3 0F 121 Page Number 3.0 EVALUATION PROCESS 18 1
3.1 General Methods of Evaluation 3.1.1 - 3.1.3 Generic l
3.1.4 - 3.1.6 Watts Bar Nuclear Plant 3.1.7 Bellefonte Nuclear Plant 3.2 Requirements or Criteria Established for Individual Issues 3.2.1 - 3.2.3 Generic 3.2.4 - 3.2.6 Watts Bar Nuclear Plant 3.2.7 Bellefonte Nuclear Plant i
4.0 FINDINGS 35 4.1 Embedded plate design u th respect to:
8 Errors, omissions, or incorrect assumptions in design calculations identified during 1984 but not corrected, noncompliance with NRC IE Bulletin 79-02 with respect to baseplate flexibility and undocumented loads on supports.
4.2 Bolt load allowables greater for unit I than unit 2.
4.3 Visual approval for minor loads on embedded plates.
4.4 Minimum spacing criteria change.
4.5 Engineering disposition for exemptions of minimum spacing requirements.
4.6
" Hollow" sounding embedded plates.
4.7 Verification of anchor load espability when surface mounted plates are deleted.
t 5.0 COLLECTIVE SIGNIFICANCE 94 5.1 Collective Significance of Each Issue
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 121 l
5.1.1 Generic 5.2 Collective Significance of the Subcategory 5.2.1 Generic 6.0 CAUSES 97 6.1 - 6.3 Generic i
6.4 - 6.6 Watts Bar Nuclear Plant 6.7 Bellefonte Nuclear Plant 7.0 CORRECTIVE ACTIONS 102 i
7.1 Corrective Actions 8.0 ATTACHMENTS 121 8.1 Attachment A. " Subcategory Summary Table and List of Concerns" 8.2 Attachment B. " List of Evaluators" 8.3 Attachment C. " List of Concerns by Issue"
1 EXECUTIVE
SUMMARY
EMBEDS Report Number:
10400 Summary of Issues l
This report addresses 18 concerns relative to the design and Installation of I
embedded plates. The concerns are divided into seven issues which addressed errors, omissions or incorrect assumptions discovered in previously approved design calculations during 1984 that were not corrected, noncompliance with i
the Nuclear Regulatory Commission Office cf Investigation and Enforcement Bulletin 79-02, undocumented loads on embodded plates, changes in tne design philosophy that allowed greater bolt loads for unit 1 than unit 2, procedural inadequacies for visually approving minor loads to embeds, minimum spacing criteria changes, engineering approval for minimum spacing violations. " hollow" sounding embedded plates, and lack of verification for the load bearing capacity for welded studs. Seven concerns were generic to TVA plants under design or construction, one concern was pertinent to Watts Bar (WBli) and Sequoyah Nuclear Plants (SQN), one concern was site-specific to Bellefonte Nuclear Plant (BLN), and nine concerns were site-specific to VBN. All concerns were considered safety-related.
Major Findings I
l The Employee Concerns Task Group (ECTG) evaluation found that of the seven l
issues evaluated the four issues involving bolt load allowables, minimum j
spacing criteria change, engineering approval for exceptions to minimum I
spacing and " hollow" sounding embedded plates were factually accurate as I
addressed by the concern but did not represent a problem or compromise the I
safe operation of the plant. The generic issue concerning non-compliance with NRC Bulletin 79-02 was identified as factual. TVA had identifi d and t
initiated corrective action to resolve these items before the ECTG evaluation of the issues began with the exception of the specific deficiency on the I
qualification and use of Rawl self-drilling anchors. A CAQR has been initiated iR2 for this item.
Errors in calculations were found to be factual for WBN l
only and corrective actions were initiated as a result of the evaluation. In IR2 addition, the NRC is requiring SQN to regenerate approximately 5600 calculations l for pipe supports on rigorously analyzed piping systems prior to unit 2 restart.
Undocumented loads on embedded plates was factual for all plants based on the findings. CAQs have been initiated to correct further problems. The issues involving visual approval of minor loads to embeds was not verified as factual for SQN but resulted in corrective actions being initiated for WBN.
l The change in bolt load allowables was proven ~to be fictual for VBN only; however what was described does not represent a problem.
Collective Significance of Findings Collectively, this evaluation focuses on TVA's delay in implementing procedurally the requirements of Bulletin 79-02.
The investigation concludes that four years elapsed before manar. ament implemented procedural changes relative to the 79-02 bulletin and six yests elapsed before TVA met 3250T Page 1 of 2
with the NRC to establish a direct plan of action for WBN that would resolve any outstanding NRC questions concerning their response. CAQs and sampling programs initiated and performed by TVA to verify adequate factors-of-safety have substantiated a 95 percent confidence level that less than 5 percent of the original designs of embedded plates may have factors-of-safety lower than those mandated by the NRC. Results of the sampling programs do not indicate that the design utilized by TVA rendered the plant to be unsafe fo,r operation.
Causes of the Major Findingq It can be surmised that poor technical communications existed between TVA and the NRC. TVA's management was negligent in incorporating the 79-02 requirements into procedures after issuance and they failed to establish a direct plan of action with the NRC which would have allowed prompt closure of this bulletin.
Corrective Actions of the Major Findings The ECTG evaluation found that corrective actions had been initiated before this evaluation to address procedurally the embedded plate designs for pipe supports. Actions already taken included sampling programs for all sites which provided a 95 percent confidence level that less than five percent of the pipe supports may not meet the intent of Bulletin 79-02.
Also, procedures were revised to incorporate the 79-02 requirements and designers were retrained, drawing notes and procedures were revised with respect to the effects of field tolerances and WBN reviewed instrument, process pipe, and civil features attached to embedded items to ensure proper documentation existed. For SQN, the qualification and use of the Rawl self-drilling anchors has resulted in a CAQR being initiated.
l The issues involving minimum spacing criteria changes, exemptions IR2 to minimum spacing requirements and " hollow" sounding I
embedded plates did not require corrective actions with respect to conditions I
adverse to quality. However, during this evaluation, a CAQ was initiated to I
address baseplate flexibility for cable tray supports and errors in l
calculations for WBN. For SQN, regeneration of the 5600 (approximate) l calculation packages prior to unit 2 restart will earve to verify that
( R2,
baseplate flexibility has been considered in calculations for surface I
mounted baseplates using concrete anchors. For BLN, CAQs were l
initiated to address unrestrained embedded nuts during i
concrete placement and the effects of missing nuts on type 49 plates.
I Note: See Executivo Summary Table # 1 for Issue Evaluation l
l Page 2 of 2
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6 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE S OF 121 1.0 CHARACTERI2ATION OF ISSUES
- 1. '. Introduction This subcategory report addresses 18 concerns relative to the design of embedded plates. The concerns are divided into seven issues as l
described in section 1.2 and are considered safety-related. Seven concerns were generic to TVA nuclear plants under design or construction; one concern was pertinent to both Watts Bar (WBN) and Sequoyah Nuclear Plants (SQN), one concern was site-specific to Bellefonte Nuclear Plant (BLN), and nine concerns were site-specific to WBN.
l l
Two concerns identified additional technical issues that are being addressed in the subcategory reports noted below:
I a.
Concern OE-QMS-8:
Design methods for detailing welds for pipe supports is addressed in subcategory report EN22200 - Pipe Support Weld Design, b.
Concern IN-85-110-001:
Design calculations for pipe supports from Bergen-Paterson and Engineering Data Systems (EDS) which were intentionally destroyed by the Tennessee Valley Authority (TVA) has been addressed in Subcategory Reports EN20500 - Control of Design Calculations and EN22100 - Pipe Support Design.
i l
One concern HI-85-071-002 addressed nontechnical aspects for the design of plates and is addressed in subcategory IH-00000-Intimidation j
l and Harrassment.
The concerns addressed in this subcategory report with the exception of SCR WBNCEB8623 R1 did not identify deficiencies that had not been previously addressed by TVA. This report will chronologically detail the conditions adverse to quality (CAQ) identified by TVA after the issuance of NRC-IE Bulletin 79-02 as related to this subcategory.
1.2 Description of Issues Generic Issues:
1.2.1 Embedded plate design with respect to:
l a.
Concern IN-85-031-001 addressed errors, omissions or incorrect assumptions discovered in previously approved design calculations during 1984 that were not corrected.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 121 b.
Concerns IN-85-103-001 and OE-QMS-8 addressed noncompliance with the Nuclear Regulatory Commission Office of Investigation and Enforcement (OIE) Bulletin 02, " Pipe Support Base Plate Design Using Concrete Expansion Anchor Bolts" in that TVA did not consider baseplate flexibility.
c.
Concerns HI-85-077-N18. IN-85-110-001, and WBM-86-009-001 dealt with undocumented loads on embedded plates or attachments to embedded plates without the benefit of l
design review.
l 1.2.2 Bolt Load Allowables:
Concern IN-85-109-X04 questioned the deolgn philosophy that allowed greater bolt loads (wedge bolts) for unit 1 than unit 2.
This concern also addressed baseplate flexibility which is covered in section 1.2.1.
SON and WBN Issues:
1.2.3 Visual Approval for Minor Loads:
l Concern IN-85-033-001 addressed problems with Engineering Procedure (EP)-4.03, Appendix 4.
This allows visual acceptance of minor loads to embedded plates. However, a minor load is not defined; therefore, there is no limit to what can be i
i accepted.
Embedded plate Fleid Change Request (FCR) 3784 is an example.
WBN 1.2.4 Minimum Spacing Criteria Change:
i Concern IN-85-595-002 stated procedural requirements became l
more stringent in 1982. Minimum spacing criteria changed from 18 inches to 24 inches and 8 nominal bolt diameters to 10 nominal bolt diameters.
Previous installations did not require re-evaluation or rework.
l 1.2.5 Engineering Approval for Minimum Spacing:
1 Concern IN-85-672-005 dealt with the engineering disposition and approval of attachments to embedded plates that do not meet the minimum allowable spacing as shown in N3C-928.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 7 OF 121 I
1.2.6
" Hollow" Sounding Embedded Plates:
Seven concerns addressed the " hollow" sounding embedded plates as follows:
a.
IN-86-305-001 addressed the fan bases on the second story of the Additional Diesel Generator Building.
b.
IN-85-693-006 identified the Reactor Building unit 1 cavity wall elevation 728, azimuth 222 degrees, missile ledge attachment piste.
l c.
IN-85-693-007 addressed the Reactor Building unit 2, elevation 730, azimuth 135 degrees, (by the strip heater) inside the crane wall.
d.
IN-85-678-001 addressed the Reactor Building unit 2 embedded plates that hold the polar crane in place.
e.
IN-85-439-002 stated the existence of these plates throughout units 1 and 2 and specifically identified:
l 1.
Auxiliary Building, elevation 713, near A and I lines unit 1 (near double doors) 10 feet high on the wall.
l 2.
Auxiliary Building, elevation 711. 15-20 feet through the double doors, 12-14 feet high on the well.
3.
Auxiliary Building, elevation 726, at A-13 and U line.
f.
Hollow plates with no given locations:
1 Concern IN-85-410-003 expressed that some embedded plates at WBN are hollow without giving a specific location.
Concern HI-85-071-002 expressed that personnel were told not to report hollow embedded plates encountered in the course of their work, No specific location was given.
E.15 1.2.7 Verification of Load Capacity:
Concern KI-85-097-001 stated that several pipe support hangers attached to embedded plates (inside containment, east-west
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 l
l PAGE 8 0F 121 walls, Reactor Building unit 1) have only 1 or 2 ' welded studs to hold'the plate to the concrete. They are cast-in-place i
anchors but there is no documentation for these anchors verifying their ability to support the loads to which they are subjected. These plates were originally designed for high pressure injection restraints.
2.0
SUMMARY
2.1 Summary of Issues 2.1.1 The 18 concerns relative to the design of embedded plates were divided into seven issues. These issues are summarized below:
2.1.1.1 Generic (WBN, SQN, BLN Browns Ferry (BFN))
Errors, omissions or incorrect assumptions a.
discovered in design calculations during 1984 that were identified but not corrected (1 concern) b.
Noncompliance with NRC IE Bulletin 79-02 with l
respect to baseplate flexibility (2 concerns) c.
Undocumented loads on embedded plates I
or supports (3 concerns).
d.
Wedge bolt allowables are greater for unit 1 than unit 2 (1 concern) 2.1.1.2 Generic (WBN, SQN):
Visual approval for minor loads on embedded plates a.
(1 concern) 2.1.1.3 Site-Specific (WBN):
Minimum spacing criteria changed from 18 inches to a.
24 inches and 8 nominal bolt diameters to 10 nominal bolt diameters in 1982 (1 concern) b.
Esemptions to the minimum spacing requirements (1 concern)
Hollow sounding embedded plates when tspped c.
(7 concerns) 3
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v TVA EMPLOYEE CONCERES REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 121 2.1.1.4 Site-Specific (BLN):
a.
Embedded plates with welded studs and cr.st-in-place anchors supporting loads for which no documentation exists to verify their ability to support the loads (1 concern) 2.2 Summary of Evaluation Process The methodology utilized to evaluate the concerns in this subcategory consisted of the following:
a.
Reviewed the construction specifications relative to embedded plates. The construction specifications were compared to the site implementing procedures for compliance in areas relative to the issues.
I b.
Reviewed the WBN ECTG files for additional information.
c.
Performed informal walkdowns as required to verify the as-built condition of pertinent features.
I d.
Researched CAQ reports and related correspondence.
l e.
Reviewed NRC IE Bulletin 79-02 with respect to the requirements l
concerning pipe support baseplate designs using concrete expansion anchor bolts.
I 2.3 Summary of Findings
]
The seven issues contained in this subcategory report addressed items that had been previously identified by TVA. The exception to this is the issue concerning baseplate flexibility with respect to cable tray supports and the qualification /use of Rawl anchors at SQN.
lR2 Corrective actions are in place relative to the concerns in this subcategory. One issue (hollow plates) resulted in a corrective action which would inform the employees of the engineering significance of the hollow sounds associated with the embedded plate.
The following is a summary of the findings and conclusions for each of the seven issues:
2.3.1 Errors, omissions or incorrect assumptions discovered in design calculations during 1984 that were identified but not corrected, noncompliance with NRC IE Bulletin 79-02 with respect to baseplate flexibility, and undocumented loads on embedded plates and supports.
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 121 i
2.3.1.1 Generic - WBN This issue was determined to be factual. TVA correspondence with the NRC and existing CAQ reports support this finding. With the exception of the issues addressed on SCR WBNCEB8623R1, TVA had identified to the NRC the problems addressed in the concerns before the investigation of the issues.
Corrective actions are in place.
SON. BLN. BFN With the exception of errors, omissions, or incorrect assumptions discovered in design calculations during 1984 which were uncorrected, the issue was determined to be factual. CAQ reports have been initiated that will specify the corrective actions for the concerns.
2.3.2 Wedge Bolt Allowables for Unit 1 Are Greater Than Unit 2 2.3.2.1 Generic - WBN This concern was determined to be fe,ctual. The service load allowables did not change, however, for those designs based on normalized loads, the allowables for unit 2 were reduced to maintain a factor-of-safety of four.
SON BLN. BFN The concern was not factual for these projects. No changes were made in the methodology used to calculate l
wedge bolt allowables.
i 2.3.3 Visual Approval for Minor Loads on Embedded Plates l
2.3.3.1 Generic - WBN j
This concern was determined to be factual based on DNE approval for FCRs that did not fall within the acceptance guidelines for minor loads. Procedures will be revised to list standard acceptance criteria for minor loads. The sampling program performed by DNE did not identify any areas where plates were overstressed that were visually approved.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM l
REVISION NUMBER: 2 PAGE 11 0F 121 S9H EP-4.03 Appendix 4 is site-specific to WBN. The visual approval program is not utilized by DNE SQN.
2.3.4 Minimum spacing criteria change from 18 inches to 24 inches and 8 nominal bolt diameters to 10 nominal bolt diameters in 1982.
2.3.4.1 Site-Specific - WBN This concern was determined to be factual. Minimum spacing requirements were changed without q
re-evaluation or rework being performed. However.
changes were not made because of inadequate procedures but were revised to allow the field to use smaller minimum spacings for plates for which the welded stud spacing is less than 12-inches. The 18-inch minimum l
requirement is still utilized by SQN, BLN and BFN.
2.3.5 Exemptions to the Minimum Spacing Requirements 2.3.5.1 Site-Specific - WBN The concern is factual in that DNE can approve violations to the minimum spacing criteria. However, l
procedures are in place to avoid overloading of the l
embedded plate.
2.3.6 Hollow Sounding Embedded Plates l
2.3.6.1 Site-Specific - WBN The concern is factual in that portions of an embedded plate may sound hollow when tapped. However, the bollow sound (produced by small gaps under the embedded plate) does not have a significant effect on the structural performance of the embedded plates.
2.3.7 Verification of Load Capacity 2.3.8.1 Site-Specific - BLN The concern is factual and corrective actions have been taken by BLN that will verify the stud anchor and/or plate integrity.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 12 0F 121 2.4 Summary of Collective Significance The following comments are specifically directed towards the design considerations of TVA's concrete anchor program, and; therefore, TVA's handling of issues related to NRC OIE Bulletin 79-02.
Management effectiveness was exempliary in the development of programs which proved to be economical and time efficient. Anchor spacing tolarances were relaxed where possible and engineering expertise war utilized to visually approve minor loads on embeds.
Management also displayed consistency in their willingness to l
initiate sample programs for fleid installations to prove the adequacy of design and construction methods for NRC OIE Bulletin 79-02.
l Management was ineffective in their willingness and ability to communicate with the NRC on 79-02 issues. The initial TVA response to the NRC on this subject was based on design methods and criteria which they were confident met or exceeded the intent of the bulletin. However, correspondence between TVA and the NRC was limited and additional information requests by the NRC should have indicated to management that the NRC was not totally satisfied with the TVA response. Instead of establishing a definitive policy of communication with the NRC on bulletin issues, management's philosophy was to further justify TVA's existing methodology instead of incorporating 79-02 requirements. Failure to establish definitive communication with the NRC and an attitude of " justify" instead of " incorporate and comply" has resulted in the bulletin l
remaining open for BFN, WBN, and BLN eight years after initial j
issuance.
1 i
Management was also deficient in the area of employee training and failed to ensure that adequate procedures were in place to effectively control the required work, or stress the need for high i
quality and accurate work by employees. A large number of CAQ's i
have been identified in this area where effective management could have, as a minimum, curtailed these occurrences. Management was j
l also ineffective in communicating with employees on specific 1
technical issues as evidenced by the large number of employee i
concerns expressed on similar subjects, l
lj NOTE: The findings with respect to TVA management's performance on NRC OIE Bulletin 79-02 are less than adequate. Therefore, a generic evaluation at the Category and Final Report level of 3,
TVA's method for handling NRC Bulletins on other issues is warranted.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PRCGRAM REVISION NUMBER: 2 PAGE 13 0F 121 Employee effectiveness was impacted by inadequate procedural I
requirements and a lack of adequate training. However a lower i
quality of work than required was identified, as both errors and l
inaccurate information were found to have occurred more often than l
l was acceptable.
From another perspective employee effectiveness could be regarded as positive when consideration is given to the lack of effective management, inadequate procedures and training.
Technical adequacy has shown a marked improvement during the l
mid-1980's. Program changes and enhancements have increased the l
overall adequacy of design criteria, construction specifications and site procedures. The resolution of generic technical issues identified during the late 1970s and very early 1980s has revealed TVA was effective in identifying and implementing corrective action for significant program inadequacies. However, the number of changes and enhancements implemented is indicative of the overall lack of technical adequacy during that time period.
2.5 Summary of Causes The cause of the problems identified in this subcategory can be attributed to a time delay in implementing the 79-02 requirements into design procedures, failure to adequately address all aspects of loading which could affect plate capacity, poor technical communications between TVA and the NRC, and failure of employees to demonstrate the quality in their work that is necessary to ensure all procedural and drawing requirements are implemented.
2.6 Summary of Corrective Action l
2.6.1 Corrective Actions Already Taken l
Sampling programs were initiated that provided a high confidence level that expansion anchor designs met the
)'
intent of 79-02 and results were submitted to the NRC.
The 1982 memorandum instructing designers to consider only rigid plate analysis was revised to refer designers to the requirements of DS-C1.7.1 i
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 14 0F 121 DS-C1.7.1 was revised to clarify limitations and applicability of rigid plate analysis.
DS-C1.7.1 was revised to provide a method for accounting for the effects of construction tolerances on calculated anchor bolt loads and baseplate stresses.
The 47A050 notes for WBN and SQN were revised to assure that field changes to baseplates did not result in unacceptable increases in liaseplate stresses or anchor bolt loads.
G-43 was revised to change the allowable tolerances for fabrication dimensions for baseplates.
Revised WBN EP-FCRs which referenced the wrong plate number or incorrect drawing revision level.
CEB issued an explanation as to why some embedded plates sound hollow when tapped and information will be presented to DNC employees in their Employee Involvement Program.
An addendum to QCI-3.09 R2 was issued to require a work release for any rework or additions to any conduit support which was already inspected and documented.
Designers were trained in methods for considering baseplate tolerances in design and evaluation of supports.
Performed sampling programs on EP-FCRs, to ensure compliance with 10CFR50 Appendix B and verify visual approval program.
MAI-13 R3 was revised to have existing supports evaluated when new conduits are added.
DNC completed a 100 percent review of Instrumentation SVSs and EP-FCRs issued for unit 2.
Two supports were identified that required new SYSs. These have been issued and submitted to DNE for approval. QCP-3.11-1 R8 was revised to clarify inspection requirements to prevent recurrence.
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TVA EMPLOYEE CONCEENS REPORT NUMBER: 10400 SPECIAL PROGRAM
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2 EEVISION NUMBER:
PAGE 15 0F 121 Modifications has reviewed all instrument, process pipe, and civil features attached to entedded items to ensure propfir documentation existL.
Procedure rovisions to QCP-1.14, and QCP-3.11-1 have been incorporated to require documentation for attachments to an embed.
DNC has revised QCI-1.13 to require an FCR when attachments are made to building and miscellaneous steel (except embedded plates).
Modifications has reviewed engineered supports installed or modified by the Modifications Branch or Nuclear Services Branch since system transfer from DNC that did not have an FCR showing the exact installed location of the attachment to building steel. One support was identified and FCR 86-28 was initiated to show the exact installed location. DNE issued ECN 6420 to add appropriate notes to the 47A050 general notes which will require FCRs to be written when an engineered support is installed on building or platform structural steel in order to documsnt the actual as-built locations of the supports.
SQN has evaluated calculation packages for the thirty worst case supports which could have affected qualification of embeds. A field survey was also performed to obtain "as-constructed" information and supports will be evaluated for design capacity. This is required for interim operation.
2.6.2 Corrective Actions to be Taken MAI-2 is being issued by ONP to address the evaluation of existing supports for load requirements when fire l
barrier insulation is added.
DNE will review past installations for situations when a new attachment was added to an existing documented conduit support.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 121 DNC is currently reviewing documentation for d11 hangers, instrument supports, and miscellaneous steel attachments to embedded plates to ensure proper documentation exists.
A field review of attachments to building and miscellaneous steel, cable tray supports and baseplates will be performed at WBN. DNC will provide DNE with marked structural drawings showing attachment locations to potentially overstressed structures and identification of pipe support members. DNE will be notified of additional attachments and will evaluate loading.
Changes will be made if necessary.
DNE initiated a verification program for WBN embedded plates used for anchorages of cable tray supports.
Review WBN cable tray supports on surface mounted baseplates which use expansion anchors to determine if baseplate flexibility and construction tolerances were adequately considered in the design.
Review documentation for identified WBN embedded plates which do not have a required FCR.
Review WBN embedded plate drawings for spacing deficiencies between adjacent embedded plates and for embedded plates installed adjacent to concrete edges.
e Revise WBN N3C-928 to incorporate spacing requirements 1
between adjacent plates and concreto edges to require a 6
new or revised FCR on the embedded plate if attachments to the support were previously approved by an FCR, and to require a location description for all EP-FCRs.
Revise CEB-21.46 to list some standard acceptance criteria with respect to the visual approval program used for EP-FCRs.
SQN will conduct a random sampling program for typical supports to determine their adequacy.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGEAM REVISION NUMBER: 2 PAGE 17 0F 121 1
SQN will review all Type II embeds and do a sampling of 40 " worst case" embeds to determine the effect of adjacent concrete edges on the embedded plate capacity. These items are to be performed before SQN restart.
1 SQN to regenerate 5600 (approximate) calculation packages l
for seismic pipe supports on rigorously analyzed systems l
prior to unit 2 restart.
Calculation packages for affected lR2 pipe supports on alternately analyzed /small bore piping l
systems will be regenerated after unit 2 restart.
l SQN will establish guidelines for minor load attachments and establish procedural controls for the evaluation method of attachments to embedded plates.
CAQR-SQF870101 documents the deficiency on the l
l qualification and use of Rawl self-drilling anchors.
lR2 j
Corrective action (s) for this CAQ is being developed.
I l
DNE will issue BLN N4C-935 to control attachments to
{
i embedded plates and revise conduit support drawings to delete free area requirements after N4C-935 is issued.
DNE will conduct a sampling program to evaluate the effects of the free area requirements for BLN.
DNE will review BLN conduit and instrumentation support f
calculations to determine actual loadings.
BLN-CEU will assign unique identifiers to type 49 plates to ensure all shims and nuts are installed and inspected.
DNE will review BLN's embedded plate drawings and calculation packages for plates located adjacent to concrete edges and the effects on the embeddet. plate's i
capacity.
DNE will evaluate the BLN type 49 plates for possible overload conditions, f
4 DNE to evaluate past installations for BLN where no requirements existed for restraining nuts on embedded bolts during concrete pours.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 18 0F 121 1
DNE will verify that the factor-of-safety has not been compromised for BLN when the effects of base plate flexibility on the welded stud capacity is considered.
DNE will establish a method for restraining bolts for future installations.
DNE will verify that for BEN the required minimum spacing is maintained when the effects of multiple attachments to embeds are considered.
A waltdown will be performed to verify the qualification of BFN baseplates and concrete anchors as required in BFN-50-712.
BFN DNE will determine any corrective action required
=
to assure that construction tolerances will not affect anchor bolt loads and baseplate stresses.
BFN DNE will determine any corrective action necessary to account for the effects of adjacent concrete edges on the embedded plate's capacity.
3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation The following addresses the summary of the specific evaluation methodology utilized in the evaluation of the seven issues in the embedded plate subcategory.
Generic Evaluation Process 3.1.1 This section discusses the evaluation procedure utilized for the issue described in section 1.2.1.
This issue addressed errors, omissions or incorrect assumptions in design calculations during 1984, which were identified but left uncorrected, noncompliance with NRC IE Bulletin 79-02 with respect to baseplate flexibility, and undocumented loads on supports.
This element was evaluated utilizing the following methodology:
c TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 19 0F 121 l
a.
Reviewed Nuclear Engineering Procedures, General Construction Specifications Site Construction Specifications and site procedures to address:
1.
Adequacy of calculation procedures with respect to technical reviews of calculations.
2.
Procedural requirements for baseplate flexibility.
3.
Controls to prevent inadvertent overloading of embedded plates.
L b.
Compiled and reviewed Problem Identification Reports (PIRs) Nonconformance Condition Reports (NCRs),
Significant Condition Reports (SCRs) Corrective Action Reports (CARS), Engineering Reports (ERs) Field Change Requests (FCRs) NRC-IE Bulletin 79-02, NRC correspondence, NSRS reports, QTC reports, and related memorandums.
c.
Reviewed DNE responses to employee concerns.
I d.
Interviews with knowledgeable personnel in responsible j
organizations as-required concerning procedures and i
i possible causes of perceived problems associated with embedmonts, i
e.
Reviewed,QTC expurgated files and WBN ECTG files for 1
additional information.
f.
Reviewed SQN Generic Concerns Task Group (ECTG) report for content, adequacy and findings.
g.
Reviewed WBN ECTG Element report on embedmonts and generic l
appilcability to SQN, BLN and BFN.
j Generic Evaluation Process:
3.1.2 This section discusses the evaluation methodology used for the issue stated in 1.2.2.
This issue addresses concrete anchor j
bolt (wedge bolts) allowables are greater in unit 1 than unit 2.
l l-l l
l
v TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 l
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 20 0F 121 l
1 The WBN ECTG files were reviewed for additional information l
a.
regarding this issue.
1 b.
Reviewed NRC-IE Bulletin 79-02 and TVA responses to the NRC concerning this issue, Reviewed Civil Design Standards and General Construction l
c.
Specifications relative to this issue.
d.
Compiled and reviewed condition adverse to quality reports.
3.1.3 This section discusses the evaluation methodology used for the issue stated in section 1.2.3.
This issue addresses visual approval of minor loads on embedded plates.
WE:
a.
The EBN ECTG files were reviewed for additional information l
regarding this issue.
1 b.
Design and site procedures were reviewed relative to the programs in place for visual approval.
c.
Evaluated the following NSRS report for details of their investigation relative to this issue:
I-85-265-WBN d.
Reviewed 10 CFR 50. Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion III".
e.
Reviewed DNE responses to employee concerns, f.
Complied and reviewed SCRs. ERs. and related correspondence.
g.
Interviewed knowledgeable personnel with respect to the visual approval program.
S S
a.
Design and site procedures were reviewed relative to the programs in place for visual approval and preliminary approval.
v 1
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM j
REVISION NUMBER: 2 PAGE 21 0F 121 b.
Reviewed the SQN Generic Concerns Task Group (ECTG) Report for content, adequacy and findings.
c.
Reviewed the SQN Element Report for content, adequacy, and findings.
d.
Interviewed knowledgeable personnel with respect to the visus 1 approval program and preliminary approval program.
WBN Evaluation Process:
3.1.4 This section discusses the evaluation methodology used for the issue stated in section 1.2.4.
This issue addresses the j
minimum spacing criteria change.
a.
The WBN ECTG files were reviewed for additional information regarding this issue.
b.
Design and site procedures, General Construction l
Specifications and Site Construction Specifications were i
compiled and reviewed, c.
Reviewed NCRs and DNE correspondence relative to the
{
concern.
f 3.1.5 This section discusses the evaluation methodology used for the issue stated in 1.2.5.
This issue addresses engineering l
disposition of exemptions from minimum spacing requirements.
a.
The WBN ECTG files were reviewed for additional information regarding this issue.
b.
Reviewed General Construction Specifications, Site Construction Specification Design and site procedures relative to minimum spacings.
j J
c.
Reviewed DNE memorandums related to sampling programs for l
1 3.1.6 This section discusses the evaluation methodology used for the
(
issue stated in section 1.2.6.
This issue addresses hollow sounding embedded plates.
j a.
The WBN ECTG files were reviewed for additional information i
regarding this issue.
l l
1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 22 0F 121 b.
Reviewed the following NSRS reports for adequacy in determining the validity and potential resolution of the concerns:
1.
NSRS I-85-666-WBN 2.
NSRS I-85-665-WBN 3.
NSRS I-85-692-WBN c.
Reviewed nonconforming condition reports related to
- concerns, d.
Reviewed the DNF response to hollow counding embedded plates.
e.
Interviewed a DNE Lead Civil Engineer for the following:
1 1.
Potential causes for the hollow sound.
2.
Effect on the structural integrity of the plate.
BLN Evaluation Process:
3.1.7 This section discusses the evaluation methodology used for the issue stated in sectian 1.2.7.
This issue addresses the lack of documentation to verify anchor load capacity when surface l
mounted plates are deleted.
i s.
The WBN ECTG files were reviewed for additional information regarding this issue.
b.
Reviewed site drawings and procedural requirements for original design of the plates in question.
c.
Reviewed FCR-0-4866 which changed the original design, d.
Performed a field walkdown of the type of plates questioned for installed configuration.
e.
Interviewed CEU-BLN supervisor, DNE CEB lead engineer, and DNE-BLN unit supervisor concerning plate installation, plate integrity and probability of a nut backing off the anchor stud.
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 i
PAGE 23 0F 121 3.2 Requirements or Criteria Established for Individual Issue Historical Background k
3.2.1 Embedded Plate Design as noted in paragraph 1.2.1:
l a.
NRC IE Bulletin 79-02, " Pipe Support Baseplate Designs Using Concrete Expansion Anchor Bolts." dated March 8, 1979 Revision 0 (MEB 790313 383) b.
NRC IE Bulletin 79-02, " Pipe Support Baseplate in Designs Using Concrete Expansion Anchor Bolts " dated June 21,
)
1919 Revision 1 (MEB 790625 393)
]
c.
NRC IE Bulletin 79-02 " Pipe Support Baseplate in Designs Using Concrete Expansion Anchor Bc,1ts." dated August 20, 1979, Revision 1, Supplement 1 (NEB 790824 122) d.
NRC IE Bulletin 79-02, " Pipe Support Baseplate in Designs Using Concrete Expansion Anchor Bolts," dated November 8, 1979, Revision 2 (NEB 791116 100) e.
Memorandums 1
1.
To H. S. Fox from R. H. Dunham, dated May 25, 1979 (CEB 790525 042) 2.
To D. R. Patterson from R. G. Domer, dated July 3, 1979 (CEB 790703 029) 3.
To W. F. Willis from E. A. Belvin, dated August 17, 1979 (DES 79082 022) 4 To H. G. Parris from C. E. Murphy, dated September 6, 1979 (A02 790910 015) 5.
To G. G. Stack from R. M. Pierce, dated October 18, 1979 (CEB 791018 003) 6.
To D. R. Patterson from R. G. Domer, dated November 28, 1979 (CEB 791128 022) 7.
To J. P. O'Reilly from L. M. Mills, dated December 6, 1979 (A27 791207 001) l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 24 OF 121 To L. M. Mills from G. F. D111 worth, dat'ed 8.
December 21 1979 (NEB 791221 256) 9.
To L. M. Mills from D. R. Patterson, dated December 6, 1979 (NEB 791206 129)
To J. P. O'Reilly from L. M. Mills, dated 10.
January 2, 1980 (A27 800102 006) 11.
To L. M. Mills from G. F. D111 worth, dated February 1, 1980 (NEB 800201 250)
To M. N. Sprouse from R. O. Barnett, dated May 14, 12.
1980 (CEB 800514 005)
To J. P. O'Relliy from L. M. Mills, dated April 3, 13.
1981 (A27 810403 011) 14.
To Those listed fro.
. N. Sprouse, dated April 30, 1981 (CEB d20430 021) 15.
To R. W. Cantrell from R. O. Barnett, dated June 16, 1981 (CEB"810616 007) 16.
To J. P. O'Reilly from L. M. Mills, dated June 20, 1984 (A27 840620 001) 17.
To L. M. Mills from J. A. Raulston, dated October 10, 1984 (NEB 841010 256) 18.
To J. P. O'Reilly from L. M. Mills, dated October 24, 1984 (L44 841024 302) 19.
To H. G. Parris from D. M. Verre111, dated February 25, 1985 (A02 850226 001) 20.
To J. N. Grace from J. W. Huffham, dated May 17, 1985 To W. T. Cottle from J. C. Standifer, dated 21.
February 14, 1986 t
l v
4
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM l
REVISION NUMBER: 2 PAGE 25 0F 121 f.
Civil Design Standard DS-C6.1, R0, R1, " Concrete Anchorages" l
1 g.
Civil Design Standard, DS-1.7.1, R0-R3, " General Anchorage to Concrete" h.
Nuclear Engineering Procedure NEP-9.1, R0, " Corrective Action" i.
" Attribute Sampling - Tables and Explanations" by Herman Burstein, 1971 1
- j. Conditions Adverse to Quality (CAQs) 1.
NCR WBNCEB8203 2.
NCR GENCED8208 3.
NCR GENCEB8205 4.
NCR GENQAB8203 l
k.
Construction Specifications I
l 1.
WBN N3C-928, "Locatir.g attachments on Embedded Plates,"
R0-R2 i
I 2.
SQN N2C-937, " Locating Attachments on Embedded Plates,"
l RO
- WBN, s.
Memorandums 1.
To J. C. Standifer from R. O. Barnett, dated May 22, 1982 (CEB 820521 003)
I 2.
To Gust:ter Wadewitz from J. C. Standifer, dated January 14, 1983 (SWP 830114 020) 3.
To H. G. Parris from NRC Region II, dated February 29, 1984 l
4.
To H. G. Parris from NRC Region II, dated May 3, 1984 5.
To J. P. O'Reilly from TVA, dated October 30, 1984 (L44 841030 002) l i
1
~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 I
SPECIAL PROGRAM f
REVISION NUMBER: 2 PAGE 26 OF 121 6.
To J. P. O'Reilly from TVA, dated April'4, 1984 (A72 840402 025) 7.
To L. M. Mills from J. A. Raulston, dated October 11, 1984 (NEB 841011 261) 8.
To Guenter Wadewitz from R. W. Dibelor dated.
August 9, 1985 (CO3 850809 001) 9.
To W. T. Cottle from J. C. Standifer, dated February 14, 1986 b.
General Construction Specification G-32, R8-R11. " Bolt Anchorages Set in Hardened Concrete" c.
General Construction Specification G-43, R7, R9, " Support and Installation of Piping Systems in Category I Structures" d.
Construction Specification N3C-928, R0-R2, " Locating Attachments on Embedded Plates" e.
Procedures 1.
W8N-QCP-1.14 R12-R18. " Inspection and Testing of Bolt Anchors Set in Hardened Concrete and Control of Attachments to Embedded Plates" 2.
WBN-QCI-1.13. R8-R14 " Preparation and Documentation of Fleid Change Requests" 3.
Engineering Procedure EP 4.03, R8-R11. " Field Change Requests Initicted by Construction" 4.
CEB 21.46. RO " Field Change Requests Initiated by the Office of Construction as a Result of WBN Construction. Specification N3C-928" 5.
Civil Design Standard DS-C5.1, R0-R1, " Concrete Anchorages" 6.
Civil Desirca Standard DS-C1.7.1, R0, " General Anchorage to Concrete" t
TV2 EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 27 OF 121 7.
WBN-QCP-3.09, R0-R3, " Inspection of Supports for i
Electrical Conduit and Junction Box" 8.
Engineering Procedure EP-4.03, R8-R11 " Field Change Requests Initiated by Construction:
9.
CEB 21.46, R0, " Field Change Request Initiated by the Office of Construction as an Result of WBN Construction Specification W3C-928" 10.
Civil Design Standard DS-C6.1, R0-R1, " Concrete Anchorages" 11.
Civil Design Standard DS-C1.7.1, R0, " General i
Anchorage to Concrete" f.
Significant Condition Reports (SCRs) 1.
SCR WBNCEB8623 2.
SCR WBNCEB 8650 3.
SCR 6498-S 4.
SCR 6597-S g.
Nonconforming Condition Reports (NCRs) 1.
NCR WBMWBP8402 2.
NCR WBNCEB8419 3.
NCR 3659 l
4.
NCR 6498 5.
NCR 6564 6.
NCR 6735 7.
NCE W-403-P 8.
NCE W-435-P 1
l
/
1 REPORT NUMBER: 10400 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 28 0F 121 1
h.
Problem Identification Reports 1.
PIR WBNCEB8543 2.
PIR WBNCEB8601 I
3.
PIR WBNCEB8602 1
4.
PIR WBNCEB8635
)
1.
Field Change Requests 1.
EP 37s4 2.
H-10917
)
3.
EP-9458 4.
EP-9574 1
]
5.
EP-9549 6.
EP-9550 7.
EP-7316 i
8.
FCR 86-28
- j. EIP-CEO-238 S._QN Memorandum to J. C. Standifer from R. O. Barnett, dated a.
May 21, 1982 (CEB 820521 003) b.
Civil Design Standard DS-C6.1, RO, R1, " Concrete Anchorages" Civil Design Standard DS-C1.7.1, R0-R3, " General c.
Anchorage to Concrete"
\\
d.
Civil Design Standard DS-C1.8.1, R0, " Standard f
Calculation for Evaluating Type II Embedded Plates" Construction Specification N2C-937, RO, " Locating e.
Attachments on Embedded Plates" l
a
I TVA RMPLOYER CONCERNS REPORT NUMBER: 10400 i
I SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 29 0F 121 f.
General Construction Specification G-32. R8-R11. " Bolt Anchorages Set in Hardened Concrete" g.
Problem Identification Reports 1.
PIR-SQNCEB-8658 h.
Nonconforming Condition Reports 1.
NCR SQNCEB8404, R1 j
2.
NCR SQNCEB8502, R2 1.
Significant Condition Reports 1.
2.
SCR SQNEEB8620, R1 3.
SCR SQNCEB8622. R1
- j. Condition Adverse to Quality Reports 1.
CAQR-SQF870101, RO lR2 EL!!
a.
General Construction Specification G-32 R8-R11. " Bolt Anchorages Set in Hardened Concrete" b.
Civil Design Standard, DS-C1.7.1, R0, " General Anchorage to Concrete" c.
Memorandum to R. M. Hodges from J. R. Lyons, dated June 19, 1885 (B49 850619 002) d.
Memorandum to J. F. Weinhold from R. O. Barnett, dated June 3, 1986 (B41 860603 004) e.
Memorandum to R. O. Barnett from C. W. Hetmater, dated November 19, 1985 (B21 851119 008) f.
Memorandum to R. O. Barnett from J. P. Wooten, dated January 14, 1986 (B21 860114 003)
.___________-___._-.___.______-.____.__._.m.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 30 0F 121 Memorandum to R. O. Barnett from J. P. Wooten,' dated g.
May 16, 1986 (B21 860516 002) h.
Nonconforming Condition Report NCR BLNCEB8421 1.
Problem Identification Reports (PIRs) l 1.
PIR BLNCEB8518 2.
PIR BLNCEB8610 3.
PIR BLNCEB8612 4.
PIR BLNCEB8616 g.
Significant Condition Report SCR BLNCEB8518
- BfN, s.
General Construction Specification G-32 R8-R11. " Bolt Anchors Set in Hardened Concrete" I
f b.
Significant Condition Reports (SCRs) 1.
SCR BFNCEB8520 2.
SCR BFNCEB8614 l
3.
SCR BFNCEB8617 c.
Memorandum to G. R. Hall from N. R. Beasley, dated February 19, 1986 (B22 860219 001)
)
d.
J. D. Cowart's 45D to S. A. Thibadoux, dated l
January 16, 1986 e.
Engineering Procedure 3.03 Revision 0, " Design l
Calculations" f.
Unresolved Item Numbers 50-259/85-21, 50-260/85-21, 50-296/82-21 g.
Corrective Action Report (CAR)85-059 l
)
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 20400
{
J SPECIAL PROGRAM f
REVISION NUMBER: 2 PAGE 31 0F 121 h.
Memorandums 1.
To R. O. Barnett from J. M. Marshall, dated January 23, 1986 (B22 860123 013) 2.
To R. O. Barnett from J. M. Marshall, dated January 23, 1986 (B22 860123 012) 1 3.
To. R. O. Barnett from J. M. Marshall, dated March 13, 1986 (B22 860313 007) 4.
To R. O. Barnett from J. M. Marshall, dated April 10, 1986 5.
To R. O. Barnett from T. M. Brothers, dated May 28, 1986 (B22 860528 009) 1.
BFNP-PI 85-02, Revision 3. " Seismic Qualification of Existing Electrical Conduit and Conduit Supports" j
3.2.2 Bolt Load Allowables as noted in paragraph 1.2.2:
a.
NRC IE Bulletin 79-02, " Pipe Support Baseplate Designs Using Concrete Expansion Anchor Bolts " dated November 8, 1979, R2 li b.
Memorandum to J. N. Grace from J. W. Huffman, dated i
j May 17, 1985 (L44 850517 803) l l
c.
General Construction Specification G-32. ES-R11. " Bolt J
Anchors Set in Hardened Concrete" d.
Civil Design Standard DS-C6.1, R0, R1, " Concrete Anchorages" i
l e.
Civil Desigt. Standard DS-C1.7.1, R0, " General Anchorage to Concrete" I
f.
Nonconformance Condition Report NCR WBNCEB8402 3.2.3 Visual Approval for Minor Loads as stated in paragraph 1.2.3:
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 32 0F 121 WBN Nuclear Safety Review Staff (NSRS) Investigation Report a.
I-85-265-WBN b.
10 CFR 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
Criterion III" c.
Memorandum to W. T. Cottle from J. C. Standifer, dated February 14, 1986 d.
Construction Specification N3C-928, R0-R2, " Locating Attachments on Embedded Plates" Engineering Procedure EP-4.03, Appendix 4. R8-R11. "Fleid e.
i Change Requests Initiated by Construction" f.
CEB 21.46 RO, " Field Change Requests Initiated by the Office of Construction as a Result of WBN Construction Specification N3C-928" g.
Fleid Change Request (FCR) H-10917 h.
Significant Condition Report SCR WBNCEB8623R1 SM SQN Generic Concerns Task Group Report on Employee a.
Concern IN-85-033-001 1
b.
Engineering Procedure EP-4.03, R11. " Field Change i
Requests Initiated by Construction" Construction Specification N2C-937. RO, " Locating c.
Attachments on Embedded Plates" d.
Modifications and Additions Instruction MLAI-11, Revision 12. " Fabrication, Installation, and Documentation of Seismic Supports and Supports Attached to Seismic Category I Structures"
{
t' O
1 I
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION N5dBER: 2 PAGE 33 0F 121 e.
Log Sheets for Attachments to Embedded Plate 1.
Plate Number 48N1219MK16WPL1 2.
Plate Number 48NB74MKSPL1 1
3.
Plate Number 48N1221MK21WPL3 l
4.
Plate Number 48N1219MK7WPL5
{
3.2.4 Minimum Spacing Criteria Change as stated in paragraph 1.2.4:
a.
General Construction Specification G-32, RS-R11. " Bolt Anchorages Set in Hardened Concrete" b.
Civil Design Standard DS-C1.7.1, RO, " General Anchorages to Concrete" j
c.
Nonconforming Condition Report NCR WBNCEB8203 R0, R1 l
d.
Construction Specification N3C-928. R0-R2, " Locating Attachments on Embedded Plates" e.
Field Change Requests, FCR-H-9521 f.
Informal memorandum to J. Cromer from M. A. Cones, dated
)
September 22, 1986 g.
Informal memorandum to M. U. Rudolphi from R. O. Hernandez l
l h.
Specification Revision Notices (SRN) l 1.
S RN-G-3 2 -1 2.
SRN-G-32-3 3.
S RN-G-32-4 l
l
- i. WBN QCP-1.14. R9, 12, 18. " Inspection and Testing of Bolt Anchors Set in Hardened Concrete and Control of Attachments to Embedded Plates" l
l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 34 0F 121 3.2.5 Engineering Approval for Minimum Spacing as stated in paragraph 1.2.5:
Construction Specification N3C-928. R0-R2, " Locating a.
Attachments on Embedded Plates" b.
WBN-QCI-1.13. R14 " Preparation and Documentation of Field Change Requests" CEB-21.46 R0, " Field Change Requests Initiated by the c.
Office of Construction as a Result of WBN Construction Specification N3C-928" d.
General Construction Specification G-32, R8-R11. " Bolt Anchors Set in Hardened Concrete" e.
Memorandum to W. T. Cottle from J. C. Standifer, dated February 14, 1986 f.
Significant Condition Report SCR WBNCEB8623. R1 3.2.6
" Hollow" Sounding Embedded Plates as stated in paragraph 1.2.6:
a.
Nuclear Safety Review Staff (NSRS) Investigation Reports 1.
I-85-692-WBN
(
f 2.
I-85-665-WBN 3.
1-85-666-WBN b.
Memorandum to W. R. Brown from K. C. Gandhi, dated i
September 24, 1986 (B26 860924 045) l c.
Nonconformance Condition Report NCR 6470 d.
General Construction Spectrication G-2, RS, " Plain and Reinforced Concrete" e.
General Construction Specification G-32. R-11. " Bolt Anchors Set in Hardened Concrete" f.
WBN-QCP-2.02, R10. " Concrete Placement and Documentation" l
l
TVA RMPLOYEE CONCERNS RRPORT NUMBER: 10400 SPECIAL PROGRAN RRVISION NUMBER: 2 PAGR 35 0F 121 3.2.7 Verification of Load Capacity as stated in paragraph 1.2.8:
a.
Construction Specification G-32, R-11. " Bolt Anchors Set in Hardened Concrete" b.
TVA Design Drawings i
1.
4RWO425-X2-10 l
~
2.
4RWO507-X2-C2 3.
4RWO516-X2-02 c.
Field Change Request 1-4866 4.0 FINDINGS Historical Outline l
March 8, 1979 The NRC issued IE Bulletin 79-02, " Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts." A written response was required from all holders of a construction permit or operating license.
June 19, 1979 TVA submitted their response to Bulletin 79-02 for BFN.
June 21, 1979 The NRC lasued IE Bulletin 79-02 R1.
The purpose of the revision was to identify acceptable ways of satisfying the original Bulletin requirements and provide additional information and clarification as requested by utilities.
July 5, 1979 TVA issued to the NRC a generic response for their design program and individual responses for SQN, WBN, BLN HNP, PBN, and YCN.
August 3, 1979 TVA met with IE Region II to discuss their proposal for BFN concerning pre 1973 anchor installations.
4 NRC had informed TVA that the response to 79-02 for 1
installations prior to 1973 did not meet IE Bulletin 79-02 requirements. This did not require a reactor shutdown; however, an inspection and evaluation program for pre 1973 anchors was to be performed.
m l
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 36 0F 121 1
August 8-10, 1979 The NRC conducted a scheduled inspection at BFN in
)
the area of concrete expansion anchor installation l
(79-02) and identified no items of noncompliance or i
deviations. The NRC agreed that the operation of BFN could continue simultaneously with the visual inspection and evaluation program of the concrete anchors installed before 1973.
August 20, 1979 The NRC issued IE Bulletin 79-02 Supplement 1 to RI.
This supplement established criteria for the evaluation of interim acceptability of plant operation. This was for plants that did not conform to the design factors-of-safety for piping supports due to as-built problems, base plate flexibility, or anchor bolt deficiencies.
September 21, 1979 Region II contacted TVA and requested TVA to t
{
4 re-examine their response to 79-02 for SQN and investigate additional areas concerning a factor-of-safety of five for expansion anchors. The i
NRC also requested confirmation that baseplate flexibility was considered in the design analysis and that a program be initiated to visually inspect embeds with respect to G-32 requirements.
October 18, 1979 Sampling programs of safety-related piping systems concrete expansion anchors were conducted at SQN and revealed areas where the thread engagement of some anchors did not meet the requirements of G-32.
Tests had previously been conducted by Singleton Materials i
Engineering Lab to establish for BFN acceptable I
anchor load capacities. The inspected anchors at SQN fell within the established limits for BFN. The NRC inspectors stated that the BFN criteria were also l
acceptable for SQN. Therefore anchors installed I
before October 29, 1979 were adequate. Installations after October 29, 1979 were required to meet the G-32 i
criteria.
November 8, 1979 The NRC issued IE Bulletin 79-02 R2.
This revision was intended to further clarify the intent of the Bulletin and establish the NRC positions on the minimum factor-of-safety, anchor bolt proofload, and espected date of completion for certain Bulletin requirements.
l l
1
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NURBER: 2 l
PAGE 37 0F 121 1
December 6, 1979 TVA provided to the NRC the results of the investigations for Bulletin 79-02 Revision 2.
TVA included in their response, the inspection and testing schedule for anchor pull tests for BFN. For J
the remaining TVA nuclear plants. TVA stated that the
(
previous response submitted July 5, 1979 remained valid.
January 2, 1980 TVA responded to additional information requested i
verbally from the NRC concerning anchor bolt safety I
factors and thread engagement for SQN.
February 1, 1980 TVA responded to additional information requested by the NRC concerning SQN.
I l
May 14, 1980 Memorandum from R. O. Barnett to M. N. Sprouse j
concerning Bulletins 79-02 and 79-14.
This addressed the need for programs to be revised or developed by TVA that would ensure requirements established by the t
NRC were met concerning the Bulletins. Programs were to be developed to verify TVAs position prior to NRC inspections and verifications. It was stated in the memorandum that to date, the NRC had not formally responded to TVA's submittals on the subject bulletins.
April 3, 1981 TV'A submitted to the NRC the complete SQN response 1
for Bulletin 79-02.
April 30, 1981 TVA issued a notice of advanced changes to Design Standard DS-C6.1 (" Concrete Anchorages') concerning revised factors-of-safety for expansion anchor design as required per IE Bulletin 79-02.
1 l
September 24, 1981 WBN identified that attachments to building or i
miscellaneous steel (except embedded plates) were being performed without the benefit of an FCR.
CAQ: NCR 3659 March 4, 1982 DNE discovered that multip.e supports had been attached to embedded plates without the benefit of a design review.
CAQ: WBNCEB8203-WBN f
l l
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 38 0F 121 May 21, 1982 Policy memorandum issued instructing des'igners to complete the analysis of WBN with the rigid plate method. The design instructions were also utilized for SQN.
January 17-20 1984 The NRC conducted an evaluation of TVAs design organization's implementation of the requirements for concrete expansion anchor bolts in their anchorage designs.
j Unresolved Items and Violations Initiated:
a.
390, 391/84-05-01: Minimum factors-of-safety in DS-C1.7.1 do not meet requirements of IE Bulletin 79-02.
b.
390, 391/84-05-02: Base plate designs have not accounted for plate flexibility when determining the maximum anchor design loads and factor-of-safety required by Bulletin 79-02.
c.
390, 391/84-05-03: Failure to follow procedure in area of base plate designs.
d.
190, 391/84-05-04: Portions of design calculations were not performed per procedure, e.
390, 391/84-05-05: Static friction loading i
during DBA was not considered in pipe support t
designs.
October 24, 1984 TVA provided the NRC with supplemental information concerning concrete expansion anchor bolts for WBN Unit 1.
CAQs 1984 Baseplate flexibility not considered in original design.
CAQs: WBNWBP8402 (closed)
SQNCEB8404 i
k
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10000 SPECIAL PROGRAM RIVISION NUMBER: 2 PAGE 39 0F 121 l
l Cural bm effects of field tolerances not considered i
in c:<gJral design.
CAQs: WBNCEB8419 SQNCEBB404 I
BLNCEB8421 l
BFNCEB8614 l
January 1985 TVA met with the NRC Region II to discuss WBN unit 1.
One major topic of discussion involved Bulletin 79-02.
l February 15, 1985 The NRC documented the January technical meeting with TVA and stated TVA's connaitment to perform a 100 l
percent review of design calculations for engineered pipe supports to assure expansion anchor i
factor-of-safety requirements are met before the first refueling outage of WBN unit 1.
May 17, 1985 TVA responded to the February 15, 1985 tea.hnical meeting notes and stated a procedure will be prepared to establish the program to be used to evaluate safety-related systems and associated supports. This program will render further evidence that TVA is currently in compliance with NRC IE Bulletin 79-02.
CAQs 1905 Cable tray support baseplate flexibility not considered in original design.
CAQs: PIRWBNCEB8523 (superceded by SCR WBNCEB8623)
Conduit supports that exceed design allowable stresses CAQ:
SQNCEB8502 Qualification of some baseplates and concrete anchors in typical support details cannot be verified and some supports have undersized welds.
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 i
PAGE 40 0F 121 CAQs: BFNCEB8520 BFNMEB8400 February 14. 1986 TVA documented the results of the findings evaluated during sampling programs for visually approved and office approved FCRs initiated in response to employee concerns IN-85-31-001 and IN-85-33-001.
CAQs 1986:
Baseplate flexibility not considered for cable tray supports.
CAQs: WBNCEB8623 SQNCEB8622 BLNCEB8616 Effects of insulations on conduit and variances of typical supports.
CAQs: WBNCEB8601 WBNCEB8602 NCR 6735 NCR W-403-P BLNCEB8610 Attachments to embedded features without proper documentation.
CAQs: NCR 6498, 6498-S SCR 6567-S NCR W-435-P 1
NCR 6564 Attachments to building or miscellaneous steel without an FCR.
L CAQs: WBNCEB8650 CAR 86-059 Embedded plates installed with a plate edge adjacent to a concrete edge or free edge violations.
J CAQs: WBNCEB8623 (EIP-CEO-238)
SQNCEBB607 BLNCEB8518 I
BLNCEB8612 l
BFNCEB8617 1
1
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 41 0F 121 March-June, 1987 NRC identified a deficiency in the qualification l
and use of Rawl self-drilling snehors at SQN l
during formal review / audit of ECTG-SQN Element l
Reports C011301 - Design of Plates. C011305 -
lR2 Anchors Cut Off and C011306 - Testing of Anchors.
l The NRC also identified inadequacies in the sample i
program performed to satisify NCR-SQNCEB-8404 l
(baseplate flexibility).
CAQs 1987:
Qualification and use of Rawl self-drilling anchors IR2 at SQN.
CAQ: CAQR-SQF870101 lR2 Attachments to building or miscellaneous steel not considered in the calculation of loads.
CAQ: PIR-SQNCEB-8658 Corrective action for these CAQs are addressed in Section 7.1.1.
Historical Background In March 1979, the NRC issued IE Bulletin 79-02.
The bulletin focused on four areas where problems associated with pipe support base plate designs and anchor bolts had been identified throughout the nuclear industry.
The bulletin specifically identified design deficiencies for pipe support base plates that use concrete expansion anchor bolts in seismic category I systems as defined by Regulatory Guide 1.29. " Seismic Design Classification". Revision 1. dated August 1973 or as defined in the applicable FSAR. Holders of construction permits and operating licenses for nuclear power plants were required to provide a written response to the NRC for the following:
1.
Verification that pipe support base plate flexibility was accounted for in the calculation of anchor bolt loads.
2.
Verification that the concrete expansion anchor bolts have the following minimum factor-of-safety between the bolt design load and the bolt ultimate capacity determined from static load tests which simulate the actual conditions of installation:
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2
)
PAGE 42 0F 121 1.
Four - for wedge and sleeve type anchor bolts I
2.
Five - for shell type anchor bolts j
I 3.
Description of the design requirements if applicable for anchor bolts to withstand cyclic loads.
4.
Verification from existing QC documentation that design requirements have been met for each anchor bolt in the following areas:
1 a.
Cyclic loads have been considered b.
Specified design size and type is correctly installed l
If sufficient documentation does not exist, then initiate a testing j
program that will assure that minimum design requirements have been met with respect to subitems a. and b. above.
Items 1. and 2. addressed by this bulletin are applicable to the concerns stated in section 1.2.1 and will be addressed in this report. Items 3.
l and 4. are addressed in Subcategory Report C011300 - Anchorages.
In June and July of 1979, TVA provided their evaluation results to the NEC pertaining to IE Bulletin 79-02.
The responses relative to flexible' plates and expansion anchor factor-of-safety were as follows:
All anchor plates designed by TVA were assumed rigid in calculating anchor loads for WBN, SQN, BLN, and BFN. A comparison of the effects of rigid plate assumptions stated that rigid plate assumptions will underestimate anchor loads under service-(normal operating) load l
conditions. However, it will not affect system capacity if the i
factor of-safety utilized in the design of the anchors is equal to or greatei than that used in the design of the pipe position retention i
attachment by a sufficient margin to compensate for any displacement limitations of the anchors. At most, the effect of this underestimation would be an increase in system deflections by 20 to 25 percent under service load conditions. Plate flexibility was considered by ITT I
l Grinnell in their design of anchors for pipe supports for BLN.
The allowable loads for expansion bolt anchors utilized by TVA were l
obtained from a table based on manufacturers' data for WBN, SQN, and BLN. The allowable loadings according to the tables required a factor-of-safety of 4 for service load conditions. TVA's Civil Design Standard DS-C6.1, " Concrete Anchorages " issued in September 1975 required factors-of-safety of 4 for wedge bolts and 4.5 for shell type anchors based on minimum qualification test requirements. For WBN and 4
I SQN, only self-drilling type expansion anchors were used before 1976.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 4
i SPECIAL PROGRAM REVISION NUMBEtt 2 i
PAGE 43 0F 121 Major piping systems for WBN were designed by Bergen-Paterson (BP) and Engineering Data Systems (EDS) Nuclear. For the design of anchorages, EDS used a minimum factor-of-safety of 6 before the issuance of DS-C6.1.
Afterwards, EDS used DS-C6.1 to design anchorages. Bergen-Paterson used the factors-of-safety of 4 for wedge bolts and 4.5 for shell-type anchors as required in DS-C6.1.
The piping systems designed by TVA utilized a i
minimum factor-of-safety of 4 for service loads. All other safety system l
anchorages designed by TVA engineers used the factor-of-safety specified i
in DS-C6.1.
Major piping systems for SQN were designed by Bergen-Paterson, Basic Engineers, and EDS Nuclear. For the design of anchorages, Basic Engineers used a minimum factor-of-safety of 5 and EDS used a minimum of 6 before the issuance of DS-C6.1.
After issuance of DS-C6.1, EDS Nuclear and Bergen-Paterson used the requirements of DS-C6.1.
The piping systems I
and other safety system anchorages designed by TVA utilized the same l
factor-of-safety as those stated above for WBN.
l Major piping systems at BLN were designed by ITT Grinnell. ITT Grinnell I
used manufacturer's allowable loads based on a factor-of-safety of 4 for service load conditions.
i l
For BFN, all major piping systems were designed by Bergen-Paterson.
l l
Their designs required a minimum factor-of-safety of 8 for self-drilling anchors and 4 for wedge bolts. A few small piping systems were designed by TVA and required a minimum factor-of-safety of 4.
l The major portion of cable tray supports were designed by TVA electrical engineers. Sampilng of computations indicates a variation in applied factors-of-safety from 6.75 to 9.7.
A small number of cable tray supports were designed by TVA civil engineers and for those designs a i
minimum factor-of-safety of 4 was applied for maximum load combinations.
I Electrical support systems, instrumentation lines, battery racks, etc.,
were designed by TVA civil engineers with a minimum factor-of-safety of 4 for maximum load conditions.
The above factors-of-safety for BFN are very conservative considering that current practice allows increased stress allowables or decreased factors-of-safety for maximum earthquake loading and for other unusual, improbable, or infrequent loading combinations.
Terms that will be used throughout this report are defined as follows:
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 44 0F 121
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a.
Field Change Request (FCR): document used by DNC and DNP to request 1
DNE approval for changes to approved documents to facilitate construction, correct minor drawing discrepancies, or provide additional design information, b.
Support Variance Sheet (SVS): used to make alterations to en existing typical drawing and only applies to the specified support at the specified location.
c.
Typical Support - a field located support configuration which is shown on DNE issued drawings of the 47A051, 52, 53, 54, 56, and 58
)
series.
d.
Engineered Support - a unique designed configuration for a specific location, issued and controlled by DNE by way of an analysis package consisting of a piping segment analysis drawing (if it is a rigorously analyzed segment) and the unique support configuration drawing detailing location, orientation, and configuration.
e.
Condition Adverse to Quality (CAQ): Errors, omissions, test failures, incorrect or inadequate documentation, deviations from prescribed inspection or test procedures, or failure to meet engineering design or procedural requirements, f.
Nonconforming Condition Report (NCR): documents a CAQ as utilized by DNC and DNP.
g.
Problem Identification Report (PIR): documents a non-significant CAQ as utilized by DNE.
j h.
Significant Condition Report (SCR): documents a significant CAQ which meets any of the following:
1.
If left uncorrected, the CAQ could challenge the integrity of the reactor coolant pressure boundary, degrade the capability to shutdown the reactor and maintain it in a safe shutdown configuration, or degrade the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposure comparable to those in 10 CFR 200, or 2.
The CAQ requires extensive repair, rework, or 3.
The CAO has substantial generic impilcations to other structures.
systems, or components in the identified plant or has substantial generic implications at other TVA nuclear plants, or
TVA EMPLOYLE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 45 0F 121 4.
The CAQ is a falsification of records, or j
5.
The CAQ is a deliberate failure to follow procedures, or 6.
The CAQ has recurred repeatedly such as to reasonably indicate an adverse trend or programmatic failure of a substantial nature, or
~
7.
The CAQ is a failure to comply with the Atomic Energy Act of 1954, as amended or any applicable rule, regulation, order, or license of the NRC relating to a substantial hazard.
The majority of the sampling programs initiated by TVA in response to the CAQs are based on the following:
In an unlimited population, zero defects in a sample of 60 provides a 95 percent confidence level that less than 5 percent of the l
population is defective.
Reference:
" Attribute Sampling" by Herman Burstein, TVA library 519.52 B97s.
Generic CAQs (for all sites) previously identified and corrected by TVA will be addressed in this section to avoid repetition.
l l
These CAQs include:
a.
Multiple supports have been attached to an embedded plate without a design review of the embedded plate capacity. This could have resulted in the plate anchors being overloaded and could effect any system utilizing the plates. The deficiency is documented for WBN on NCR WBNCEBB203 and NCR GENCEB8208 for SQN, BLN, and BFN.
The deficiency was caused by inadequate requirements issued by DNE to control the minimum distance between attachments to embedded plates or the minimum distance between attachments and embedded plate edges.
Sampling programs were conducted for WBN, SQN, and BLN to determine if support failure could occur because of multiple loads and evaluate the inplace factor-of-safety against concrete failure for welded stud anchors.
The samples indicated that an adequate level of safety exists against concrete failure, therefore, embedded plates were approved use-as-is for SQN and BLN. One embedded plate stud at WBN stressed to.96 Fy which exceeds TVA's maximum design allowable of.9 Fy.
Stiffners were added to the plate to reduce the stud stress below.9 Fy.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 46 0F 121 Construction Specifications WBN N3C-928 (February 10, 1983) and SQN N2C-937 (November 20, 1984), both titled " Locating Attachments on Embedded Plates," were issued by DNE. These specifications detail i
the requirements'for locating attachments to embedded plates. The specification requires design approval of all future attachments on embedded plates that do no meet the specified minimum spacing requirements.
With respect to BFN, a field review of approximately 800 significantly loaded embedded plates with multiple attachments revealed that no problem exists at BFN. Unlike WBN, random strip plates were not installed at BFN during early stages of construction with the intention of utilizing the plates for future unidentified supports. With cerpect to embedded plate design, this was completed at BFN before the issuance of DS-C1.7.1.
Therefore, it was determined that NCR GENCE88208 did not apply to BFN.
In order to assure designers applied the correct factor-of-safety during future design DS-C1.7.1 was revised for clarification pertaining to correct usage of factors-of-safety.
b.
DS-C1.7.1 states that ductility of anchorages should be assured by limiting the failure mechanism to steel where possible. When ductility is not possible and the failure mechanism is concrete, the factor-of-safety for service loads should be at least four. Stud anchors that would be ductile in single loading will fail concrete as a group at some of the spacings used on the strip plates.
Computations for strip plates using closely spaced Nelson studs at WBN indicate that in some cases design loads were compared to the ultimate concrete strength when checking attachments. This could indicate that some safety-related supports have a factor-of-safety as low as one when a minimum of four is required.
This deficiency is documented on NCR GENCEB8205 for WBN, SQN, BLN and BFN and was caused by failure of designers to apply the factor-of-safety as required by DS-C1.7.1 c.
Minimum spacing criteria as provided by G-32 R-5 could have been inadequate in that espansion anchors can be installed at various plaats which do not meet minimum spacing requirements when the combined action of multiple attachments are considered. This deficiency is documented on NCR GENQAB8203. Field sampling programs were performed g
for WEN SQN, and BLN where expansion anchors were installed at less than the G-32 minimum spacing requirements. No deficiencies were noted la the random sample for the sites. Zero failures results in a l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 47 0F 121 95-percent confidence level that no more than 5-percent of the total population would be defective. Therefore, the possible spacing violation covered by this NCR had no significant effect on the expansion anchor factor-of-safety.
BFN has not evaluated the occurrences where expansion anchors for adjacent attachments are spaced closer than the G-32 requirements.
4.1 The findings as indicated below address the first issue noted in paragraph 1.2.1.
This issue is relative to errors, omissions or incorrect assumptions in calculations tt'at were identified during 1984 but not corrected, noncompliance with NRC IE Bulletin 79-02 with respect to baseplate flexibility, and undocumented 7.oads on embeds or attachments to embeds without a design review.
4.1.1 Generic Discussion - WBN i
In May 1982. DNE-CEB established a policy for all future support base plate analysis at WBN. The decision was made to i
complete the analysis of support base plates using the rigid plate method. This decision was primarily based on a sampling program conducted at SQN which revealed adequate conservatism existed in TVA designs using rigid plate 1
analysis to compensate for the effects of base plate flexibility. The NRC reviewed the sampling results and I
concurred with TVA's findings.
i In January 1984, the NRC conducted an inspection in the areas of pipe support base plate designs using concrete expansion i
anchor bolts as addressed by TVA's Office of Engineering i
Design (IE Bulletin 79-02).
The inspection findings are summarized below:
a.
Unresolved Item 390,391/84-05-01, Factors-of-Safety for Concrete Expansion Anchor Bolts (IE Bulletin 79-02) Civil Design Standard DS-C1.7.1, paragraph Sa.
This involves
)
the factor-of-safety for self-drilling expansion shell anchors (SSD) and wedge bolts (WB). The factor-of-safety in DS-C1.7.1 (formerly DS-C6.1) for SSD and WB anchors under normal loading conditions are 4.5 and 4.0, respectively. In accordance with IE Bulletin 79-02 the requirements for the minimum factors-of-safety for SSD
)
and WB anchors should have been 5 and 4 respectively.
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 j
SPECIAL PROGRAM l
REVISION NUMBER: 2 i
PAGE 48 0F 121 b.
Unresolved Item 390,391/84-05-02, Pipe Support Base Plate Design Consideration (IE Bulletin 79-02), DS-C1.7.1 paragraph 5.b.
This requires that the effect of base
)
plate flexibility be considered in obtaining the anchor's maximum design load. As stated in the historical, WBN's base plate designs have not accounted for plate flexibility when determining the maxi. mum anchor design loads and factors-of-safety as required by the bulletin.
I c.
Violation 390,391/84-05-03, Failure to Follow Procedure DS-C1.7.1 paragraph 5.c.
This noted that TVA DS-C1.7.1 had not been implemented by the pipe support group in the f
area of base plate designs. The failure of implementing q
this criteria was a violation of 10 CFR 50, Appendix B, Criterion V.
d.
Violation 390,391/84-05-04, Failure to Follow Procedures for Pipe Support and Base Plate Design Calculations, I
DS-C1.7.1 paragraph 5.b.
The inspector reviewed portions of design calculations and computer applientions in the area of pipe support analysis and base plate designs.
The calculations were evaluated for thoroughness, clarity, consistency and accuracy. Conformance to analysis criteria, appilcable code NRC requirements and licensee commitments i
were also reviewed. Discrepancies were noted in calculations for four supports which indicated that portions of these design calculations were not performed in accordance with Engineering Procedure EP 3.03, " Design Calculations", Civil Design Standards, and sound engineering applications. These were violations of 10 CFR 50, Appendix B, Celterion V.
The violations and unresolved items have been closed by the NRC for unit 1.
Violations for unit 2 are still pending actions by TVA.
1 Later in 1984, two supports had base plates and anchor bolts designed using the rigid plate theory. 110 wever, the configuration of the anchor bolt locations in relation to the attachment did not meet the criteria necessary for design and classification as a rigid plate. This resulted in unequal distribution in the tenslie pullout load which could cause the anchor bolts in the insnediate proximity of the attachment to i
(
take a greater portion of the induced load.
l
s<-
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I TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 49 0F 121 According to approximate hand calculations, the anchor bolts would not be within the specified limits. NCR WBNWBP8402 was initiated to document the two supports and addressed the potential for other similar conditions to exist.
It was determined that designers were not implementing
)
DS-C1.7.1, section 5.1 which states that the limitations for the use of rigid plate analysis mothods must be applied unless documented justification is submitted for the limitations.
WBN designers were interpreting the May 1982 memorandum as justification to apply rigid plate analysis to all embedded plate designs. This memorandum did not delineate any limitations and did not provide the necessary justification as required according to the procedure. This misinterpretation resulted in baseplates being designed using rigid plate assumptions when the plates did not meet the rigid requirements specified by NRC IE Bulletin 79-02.
In order to evaluate the effect of baseplate flexibility and construction tolerances, a samp: ling program for pipe supports was conducted. The results confirmed a 95 percent confidence l
1evel that less than 5 percent of the pipe supports did not meet
{
the design criteria. Supports identified in the sample that did not meet the criteria were modified. Remaining supports required no further evaluatior, or rework.
DNE revised the 1982 memorandum to refer designers to the requirements of DS-C1.7.1, clarified limitations and applicability of rigid plate analysis in DS-C1.7.1 and trained l
designers to this requirement.
DNE drawing series 47A050 includes several tolerances for the l
location of concrete anchorages, movement of attachments and modifications of baseplates for supports.
The tolerances given in the 47A050 notes were based on rigid plate assumptions. The effect of fleid tolerances on loads and stresses would be smaller for rigid plates than flexible plates. No documentation exists to show that the effect of construction tolerances on loads and stresses was considered in the development of the 47A050 notes.
NCR WBNCEB8419 was initiated to document that the cumulative effects of these tolerances may have resulted in significant increases in baseplate stresses and anchor bolt loads.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 I
SPECIAL PROGRAM I
REVISION NUMBER: 2 PAGE 50 0F 121 A sampling program evaluating 496 pipe supports produced a 95 percent confidence level that less than 2.1 percent of the supports had a factor-of-safety of less than the 5 required l
according to 79-02.
These results were included as part of a l
total evaluation for NRC IE Bulletin 79-02.
l i
DNE performed the following actions to prevent recurrence:
Revised the 47A050 notes to limit allowable field applied a.
tolerances, b.
Revised G-43 to change the tolerances for the fabrication dimensions of plates.
l c.
Revised DS-C1.7.1 to specify the method for calculating amplification factors for anchor bolt loads and base plate stresses to account for fleid installation I
tolerances.
i d.
Trained designers in methods for considering baseplate l
tolerances in design and evaluation of supports.
A review of TVA's final response to NRC IE Bulletin 79-02 l
has shown that TVA did not take into account base plate flexibility in the design of baseplates before the issuance of DS-C1.7.1 (formerly DS-C6.1 issued September 1975).
I
{
In January, 1985, a meeting was held in the Region II offices l
between TVA and the NRC at TVA's request to discuss design i
issues involving WBN unit 1.
The two major topics of discussion involved IE Bulletin 79-02 factor-of-safety 1
requirements and missing EDS Nuclear calculations (addressed in Subcategory Reports EN20500 - Control of Design i
Calculations and EN22100 - Pipe Support Design). TVA presented to the NRC their verification of a sample of the calculations affected by the design issues in question.
l The NRC agreed that the design verifications provided reasonable assurance that there are no safety concerns which would preclude the issuance of an operating license for l
l unit 1.
However, in order to provide complete assurance that j
r.: problems exist TVA and Region II agreed that a complete review of all affected support calculations would be performed. Reasonable completion dates for these reviews as stipulated by the NRC was the first refueling outage for unit 4
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 51 0F 121 1 and by initial fuel load for unit 2.
This is documented in a letter dated February 15, 1985 from D. M. Verre111 to TVA.
l TVA's response to the NRC dated May 17, 1985 committed TVA to a 100-percent review of the design calculations for l
engineered pipe supports for WBN unit 1 to assure that the expansion anchor f actor-of-safety requirements c f IE Bulletin 79-02 are met. The review will be performed on engineered pipe supports for unit 1 that were designed prior to the implementation of IE Bulletin 79-02 requirements in TVA Civil Design Standard DS-C1.7.1.
The methods used for the review of the supports will be the same as those used for evaluation of the sample of the 496 supports reported in revision 2 of the final report on IE Bulletin 79-02 for WBN unit 1.
TVA committed to develop a special procedure for the review and complete the review for unit 1 before the first refueling outage.
For unit 2, these issues are being addressed in the ongoing design process. Therefore, compliance with the IE Bulletin 79-02 will de achieved by unit 2 fuel load.
Since the May 17 memorandum, fuel load for WBN unit I has slipped. As a result, TVA has committed to review the.
safety-related piping systems and cassociated engineered supports for WBN unit I before loading fuel.
WBN Engineering Project Procedure WBEP-SEP 86-02 is being prepared to establish the program to be used to evaluate these systems and associated supports. This program will render further evidence that WBN is currently in compliance with NRC IE Bulletin 79-02.
The above analysis for baseplate flexibility and tolerances-excluded the cable tray support anchor bolt loads.
In 1985 CEB initiated PIR WBNCEB8543 which stated that baseplate flexibility for the calculation of anchor bolt loads was not considered for cable tray supports and possible miscellaneous steel supports. This may have resulted in some supports having a reduced margin of safety. An independent review of 60 embedded plates with cable tray supports was performed by DNE and the following were identified:
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REPORT NUMBER: 10400 f
TVA EMPLOYEE CONCERNS J
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 52 0F 121 Cable tray supports may overstress portions of the embedded a.
plate when baseplate flexibility and installed location of the support on the embedded plate are considered, Cable tray support calculations used the wrong allowable b.
anchor stresses in some cases.
l 1
i Cable tray supports did not take into account all design l
c.
i considerations in some cases.
l PIR WBNCEB8543 has been superceded by SCR WBNCEB8623 R1.
This SCR and the aforementioned CAQ's document the failure l
of TVA designer's to consider baseplate flexibility.
The QTC investigation of the concern dealing with errors, omissions, or incorrect assumptions found in design calculations during 1984 that were not corrected resulted in additional issues.
These are as follows:
Transfer of work between sections (original employee a.
concern) b.
Calculation errors in load determination for EP-FCR's requiring detailed evaluation.
Effectiveness of the visual inspection program and the c.
effects of cumulative loads (visual inspection addressed
'(
in section 4.2.3).
f In order to determine the validity of the above issues. DNE initiated a sampling program consisting of 60 EP-FCRs where analysis packages were available. The EP-FCRs were randomly selected from the population of embedded plates which had been approved the last time a FCR had been initiated on the embedded plate.
The predetermined acceptance criteria for the sample was based on identifying zero defects from the sample of 60 and on identifying no significant program deficiencies.
For each embedded plate in the sample, the following were performed:
l
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s TVA EMPLOYEE CONCERMS REPORT NUMBER: 10400 SPECIAL PROGRAM RETISION NUMBER: 2 PAGE $3 0F 121 q
a.
Field verification comparing the most recent EP-FCR and the as-constructed configuration of embedded plate attachments, q
b.
Existing calculations for reactions were independently
)
reviewed. The calculations for each embedded plate was revised to document the independent review. Any l
discrepancies found during the review were included in l
the revised calculations.
l c.
Existing calculations of the embedded plates were reviewed by a group independent from the group which I
l handled the original evaluation of the embedded plate FCRs.
l The review of the documentation and detailed evaluation of l
the embedded plates identified the following discrepancies:
a.
Incorrect plate numbers or incorrect drawing revision levels were referenced on five EP-FCRs. The errors were not identified by DNE during the initial evaluations for l
the five embedded plate FCRs therefore, detailed calculations were performed on the wrong plates.
l b.
The review of the field sketch for an embedded plate identified four other plates which had additional I
attachments that were not shown on the sketch and should have been shown based on the requir6ments of N3C-928.
c.
The review of the load determination calculations performed by DNE onsite identified 7 calculations which contained errors or omissions in the load determinations. None of the errors resulted in load increases that were significant with respect to the capacity of the embedded plate.
d.
Embedded plate FCRs were visually approved by field inspections by a designer using engineering judgment based on the assumption of the acceptability of an existing attachment with a major load (generally a cable tray support).
l
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l TVA EMPLOYEE CONCERNS kEPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 54 0F 121 l
e.
Tbv allowable stress on 5 of the embedded plat'es in the sample exceeded the allowable using the cable tray reactions given in the existing cable tray support calculation packages. Using more refined seismic analysis resulted in a reduction in stress to within allowable values.
f.
For some calculations for evaluation of the embedded plate FCRs, the effects of baseplate flexibility were not considered.
g.
A standard "by inspection" evaluation form was used for evaluation of 10 of the embedded plates. Information contained on the form was generally acceptable, however, some unconservative assumptions were identified.
h.
Approximately 30 of the calculation packages for I
evaluation of the embedded plates documented acceptance by engineering judgment. The basis for the engineering judgment was not explicitly docuruented as required by procedure.
These deficiencies are documented on SCR WBNCEB8623R1 and l
document errors, ommissions and incorrect assumptions in previously approved calculations. liowever, it could not l
be determined that these particular errors had been previously
{
identified but left uncorrected, j
DNE will also investigate two other potential deficiencies in the design of plates under SCR WBNCEB8623. They are as i
follows s.
Embedded plates identified by an EP-FCR in accordance with DC-928 may not have considered the effects of loads on adjacent embedded plates (identified by DNC, Employee j
Involvement Program EIP-CE0-238).
b.
The effects of an adjacent concrete edge on the embedded plate capscity may not have been considered in the des 8gn of the plate (PIR WBNCEB8635).
I
7 v
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM RRVISION NUMBER: 2 PAGE 55 0F 121 In January 1986 PIR WBNCEB8601 and PIR WBNCEB8602 were initiated.
PIR WBNCEB8601 addressed the potential for insulation to be installed on a conduit after the typical conduit support had been finalized. If the conduit support had been varied from the original design and qualified based on the uninsulated condition, the added weight of the insulation could result in support overstress. Also, embedded features could possibly be affected by the additional loading.
When a typical support is varied, the support has frequently been qualified based on the load from the actual number of conduits or piping attached to the typical. DNC or ONP may have added conduit or piping to the existing varied typical without approval from DNE.
Therefore, the qualification of the varied typical based on the actual number of conduit or piping may be unconservative. This problem would also affect the qualification of embedded plates. This is documented on PIR WBNCEB8602.
DNC has initiated NCRs 6735'and W-403-P in response to PIR WBNCEB8601 and PIR WBNCEB8602.
In December, 1985, NCR 6498 was initiated to identify unit 2 process pipe supports attached to embedded features which had been installed and documented without initiating an attachment "G" as required by procedure WBN-QCP 1.14, which is the document which tracks attachments to embedded features and notifies DNE of the existence of the feature. Because of this, supports may have been statused as complete according to WBN QCI-1.40-3, " Universal System Program" without a DNE evaluation of the attachment to the embedded feature being performed. Inis situation was caused by the fact that WBN QCI-1.40.3 designed test number 1 to be for expansion anchors in hardened concrete without including a test or inspection for the control of the attachment to the embedded plate as required by WBN-QCP 1.14
____..___.__m.
a e
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 56 0F 121 A generic applicability review conducted by DNC has identified that this condition also affects structural and miscellaneous steel features attached to embedded plates as well as instrumentation sense line supports.
These additional deficiencies have been documented on NCRs 6567 and 6564 for unit 2 and NCR W-435-P for unit 1.
Before 1981, several notes in the drawing series 47A050 and 47A058 permitted DNC to make attachments to i
miscellaneous building steel (except embedded plates),
cable tray supports, and baseplates for supports of all types. These notes specified the additional loading allowance that was acceptable without the benefit of an FCR or support variance.
However, the loading criteria either did not consider the effects of cumulative loads, was not well enough defined for construction application, or was misinterpreted by construction and resulted in overstressing of supports in some cases.
DNC lhitiated NCR 3659 (September 24, 1981) to document this deficiency and is providing DNE with field installed i
configuration details of structural steel drawings showing attachment locations to potentially overstressed structures.
DNE will evaluate the attachments to the structures and make the necessary changes to design drawings.
l In April 1986 CEB initiated SCR WBNCEB8650. This identified a potential problem with the Office of Nuclear Power attaching engineered supports to cable tray f
supports, building and miscellaneous steel (excluding embedded plates) without an FCR. This is the same problem identified on DNC NCR 3659.
i The WBN ONP site procedures do not require the generation of an FCR when attaching to building or miscellaneous steel (except embedded plates) because of DNE's failure
{
to incorporate the FCR requirement into a governing General Construction Specification such as G-43 or on I
design drawings.
l a
k e
9
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 57 0F 121 A review of engineered supports installed by WBN ONP was performed by Modifications to identify supports which were attached to building and structural steel without an FCR showing the exact installed location and configuration.
One support was identified as having been attached to building steel by WBN ONP without an FCR as of June 17, 1986.
The subject support was modified by way of Engineering Change Notice (ECN) 5678 and FCR 86-28 was generated to show the exact location and configuration of the l
attachment to building steel.
Based on conversations with Civil Design Engineers with the DNE section, the conservatism utilized by TVA designers was confirmed in the various sampling programs conducted in respect to baseplate flexibility and loading
~
on supports. Problems with the qualification of cable tray supports was identified and is in the process of being resolved. Safety related piping systems and associated engineered supports for unit I will be re-evaPlated before fuel load.
Interviews conducted with DNC engineers concerning the inspection documentation reviews performed ensured that l
any feature attached to an embedded plate has been or l
will be documented and inspected. Any feature attached I
to an embedded plate that is discovered to not have a 1
documented inspection or an approved embedded plate PCR will be inspected, documented, and evaluated by DNE.
Conclusion The sampling programs initiated by TVA identified errors, l
ommissions, and incorrect assumptions in previously approved design calculations. Undocumented loads and noncompliance with NRC IE Bulletin 79-02 are factual based on l
the findings, i
Discussion - SQN l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 58 0F 121 Pipe supports for WBN and SQN were designed using the same design criteria and procedures. For the majority of the design period, work for both plants was being performed concurrently by the same designers. The 1982 memorandum (CEB820521003) which discussed baseplate design stated that rigid plate analysis should be used for the completion of WBN. The design instructions were also used for SQN.
The memorandum was generally interpreted by SQN designers to allow use of rigid plate analysis without evaluation of plate rigidity. This interpretation resulted in many baseplates l
being designed using rigid plate assumptions which would not be classified as rigid using the 79-02 criteria.
Upon identification of baseplate flexibility not being addressed for WBN (NCR WBMWBP8402), DNE-SQN initiated l
NCR SQNCEB8404.
This NCR stated that DS-C1.7.1 requires that the effects of l
baseplate flexibility and anchor deformations be considered in determining the loads on anchor bolts if the baseplate does not meet the parameters given in the standard for a i
rigid plate design. Failure to follow these guidelines could cause the anchor bolts to exceed the allowable loads specified in the standard. The applicable requirements in the standard have not been followed in the design of pipe supports since the standard was issued in May 1983.
The designers were interpreting the 1982 memorandum as justification to the limitations on the use of rigid plate analysis. This memorandum did not delinate any limitations l
and therefore did not provide the justification required by 2
DS-C1.7.1 to use rigid plate analysis.
Configuration tolerances for pipe supports are given in the DNE drawing series 47A050 for both WBN and SQN. NCR WBNCEB8419 noted that the cumulative effects of these tolerances may result in altnificant incre6ses in baseplate stresses and anchor bolt loads. SQN also addressed this deficiency on NCR SQNCEB8404.
In order to determine the effect of baseplate flexibility and installation tolerances, SQN initiated a random sampling of 60 pipe supports and calculated the expansion anchor factor-of-safety for each support. The calculated factors-of-safety were based on baseplate dimensions and drawing configuration. The calculations for the supports in the sample included consideration of baseplate flexibility.
v l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 59 0F 121 l
DS-C1.7.1 states that self-drilling expansion anchors shall require a factor-of-safety of 5 and wedge bolts require 4 A
review of the OE calculation sunsaary for the NCR SQNCEB 8404 l
sample program revealed 59 out of the 60 sampled supports had l
factors of safety greater than the DS-C1.7.1 requirement of l
five for SSDs. One support which used SSD type anchors had a factor of safety of 3.5.
However, the support with the reduced factor of safety met the requirements for rigid plate analysis and therefore, had a factor of safety greater than I
that required for the original design.
j In addition, the results of the NCR WBNCEB8419 sampilns performed at WBN with respect to construction tolerances are applicable to the expansion-anchored pipe supports for SQN.
I This conclusion is based on:
Pipe supports for both plants were designed using the a.
same methods and procedures. For most of the design period, work for both plants was being performed by the same designers. Therefore, the sample performed at WBN (R2 was reflective of the support designs at SQN.
I b.
l The 47A050 drawings for SQN contained fewer and more l
conservative tolerances than the WBN 47A050 drawings.
I Because of this fact, the probability of error in the IR2 application and/or interpretation of the SQN drawings was I
considerably reduced.
l No failure evaluation of installation tolerances or baseplate flexibility was required because:
More conservatism was built into the design of supports a.
Note: The sampling program performed at WBN did not identify a problem caused by the use of fleid installation tolerances, b.
Sampilng of 60 SQN supports for baseplate flexibility and comparison of field installation tolerance work for SQN and WBN provided a 95 percent confidence level that less than 5 percent of the embedded plates do not meet design requirements.
)
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 1
PAGE 60 0F 121 However, during an NRC audit in March, 1987, inadequacies were I discovered in the sampling program performed as a result of l
NCR-SQNCEB-8404. The NRC indicated that the subject sampling i
program did not adequately address the baseplate flexibility 1R2 issue at SQN. Further discussions between NRC and ECTG 1ed I
to the following conclusions on this subject:
l i
The NRC is requiring SQN to regenerate calculation I
packages (approximately 5600) for seismic pipe supports I
on rigorously analyzed systems prior to unit 2 restart.
l This action has been designated a SQN restart item.
IR2 l
Calculation packages for affected pipe supports on l
alternately analyzed /small bore piping systems will be I
regenerated after restart of unit 2.
l 1
The regeneration of the subject calculation packages will l
effectively evaluate the issue of baseplate flexibility at l
SQN. This fact was verified by ECTG in conversations with l
DNE personnel at SQN and CEB in Knoxville. Civil Design IR2 Standard DSC-1.7.1 requires that baseplate flexibility be I
considered during the analysis process unless the baseplate 1
meets criteria for rigid plate analysis (also specified in i
DSC-1.7.1).
It was also stated that qualification of l
expansion shell anchors would be to a safety factor of-l five as required by NRC OIE Bulletin 79-02.
Interim I
qualification to a reduced factor-of-safety would not be i
performed.
l CEB initiated SCE SQNCEB8502 to address programmatic deficiencies concerning the design and installation of seismically qualified conduit supports as shown on the 47A056 drawing series of typical supports. A potential exists for electrical conduits and their supports to exceed design i
allowable stresses. However, because of the ductility of the materials and conservative methods of enveloping loads, physical member lengths, and placement of loads, the possibility of actual conduit failures are extremely remote.
One item identified in SCR SQNCEB8502 that directly relates to this subcategory is:
L-____-_-_____-______________
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 61 0F 121 Inaccurate configuration utilized in the approval of field change requests. The implementation of the variance program as applied to conduit supports does not provide assurance that the support configuration evaluated and documented by design is consistent with the as-constructed configuration.
Variances as submitted by constructing organizations, identify only the current change. Previous variances or configuration changes to a specific support are not normally identified. Failure to consider previous variances to a specific support results in evaluation and documentation of an inaccurate configuration.
Embedded plates have been installed with the plate edge adjacent to a concrete edge. The effect of the concrete edge on the embedded plate capacity may not have been considered in the design evaluation of the plate. This is documented on SCR SQNCEB8607.
This deficiency is known to have occurred for the embedded l
plates for four feedwater deadweight supports in the Reactor l
Building. Cracking of the concrete because of the proximity of the anchors to the concrete edge was observed and repairs were made.
l During the evaluation of the above conditions, the following I
were identified:
I a.
The original design of some cable tray supports may not have used the correct response spectra or considered effects of loads from other attachments, weight of' j
insulation, torsional loads, or 75 pound / foot loading on the top tray, b.
When baseplate flexibility, installed location of supports on the embedded plate and the effect of closely spaced anchors are considered, the embedded plate may not be qualified.
l c.
The effect of overloaded trays (SCR SQNEEB8650) when combined with all identified design and "as-constructed" deficiencies may overstress the cable tray support or the baseplate to which it is attached. Particularly, AWS punching shear allowables at tube to tube connections may be exceeded, e
O m
m.,
t I
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 62 0F 121 d.
As-constructed cable tray spans are longer than specified i
by design drawings.
e.
Some surface mounted baseplates were modified by field changes and the "as-constructed" baseplates were not qualified by design calculations.
SCR SQNCEB8622R1 was initiated to document these deficiencies.
A review was performed by SQN to determine if attachment of engineered supports to cable tray supporto, building steel and miscellaneous steel (except embedded plates) are 3
documented on FCR's that show the actual locations and configuration of the supports.
This review was conducted as a result of the initiation of SCR WBNCEB8650 which identified the above deficiency at WBN.
Initial results indicated that the same deficiency existed at SQN and PIR-SQNCEB-8658 was subsequently initiated.
Interviews with the responsible engineers in the SQN Civil l
Design Analysis Group and DNE revealed the following:
l a.
The review performed in accordance with SCR WBNCEB8650 i
would address errors, omissions, and incorrect assumptions in the calculation / analysis.
Preliminary results of the review had revealed potential problem areas with respect to all attachments to structural features not being considered and PIR-SQNCEB-8658 was o
initiated. However, no instance of actual errors, or omissions in the calculation / analysis process had been F
identified.
It was stated that human error was a reality a
that had to be considered in calculations / analysis but
[
felt that the Nuclear Engineering Procedure 3.1 j
" Calculations" provides sufficient checks and balances to
.i overcome this problem.
1
~
b.
Two responsible SQN engineers were not aware of any 3
situations where identified errors had been left
{
uncorrected.
i c.
Errors in calculations will be adequately andressed in
\\
the review required by SCR SQNCEB8622. Previous sampling l
[
programs have not identified problems in this area.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVIS20N NUMBER: 2 1
PAGE 63 0F 121 An additional deficiency relevant to the issue (s) of I
section 1.2.1 is the qualification and use of Rawl l
self-drilling anchors at SQN. The ECTG evaluation of this IR2 subject has revealed the following:
l l
The NRC accepted SQN's final 79-02 evaluation program I
with ap> roved deviations after SQN had answered additional I
information requests on 79-02 issues. 'The NRC's IR2 acceptance is documented in the SQN Safety Evaluation l
Report Supplement 2, section 3.9.2, dated August, 1980.
l I
However, a discrepancy has been identified in the TVA l
response to six additional questions posed by the NRC l
l concerning specific issues related to 79-02.
TVA l
memorandum NEB 800201 250 dated February 1, 1980, j
' documents the six questions and the TVA response to each question. Question three states, "For each type and size 1
of expansion anchor used at SQN, provide a comparable table l of the maximum allowable design loads and the manufacturers' l average ultimate strength valves considering the actual I
concrete strength, embedment depth, plus depth and applied I
preload (as applicable)." The TVA response to this request I
included the table as well as the manufacturers' information IR2 on which the table was based. The response also stated, i
"Of the four manufacturers, Rawl is the only one who quotes I
capacities which are consistently less than G-32 l
requirements.
In our opinion, the lower Rawl test values I
are directly related to specimen size and testing l
procedures. To the best of our knowledge, no Rawl l
self-drilling anchors were used at SQN. Rawl has not l
bid on supplying any TVA project with self-drilling I
anchors and therefore, we have not tested any of I
their anchors." It has been determined however, that l
Rawl anchors were, in fact, used at SQN.
l 1
Therefore, DNE-CEB has initiated CAQR-SQF870101, I
revision 0, to document the use of Rawl self-drilling i
i anchors at SQN. The CAQR description of condition states, i
"Rawl self-drilling anchors have been used at SQN. The l
manufacturers' data indicates capacities less than the IR2 Phillips anchors used as the standard.
In addition. TVA's i
response to NRC OIE Bulletin 79-02 states, "to the best i
of our knowledge no Rawl anchors were used at SQN."
l This discrepancy was identified by an NRC inspector I
during an audit of the Employee Concerns Task Group l
report on anchorage."
(CATD C011301-SQN-09) l
-v TVA EMPLOYEE CONCERNS REPORT NUMBER:- 10400 SPECIAL PROGRAM i
REVISION NUMBER: 2
{
PAGE 64 0F 121 Conclusion i
Errors, omissions, or incorrect assumptions in design calculations that were identified and not corrected during 1984 has not been proven to be factual.
Noncompliance with NRC IE Bulletin 79-02 and undocumented I
j loads are factual based on the findings.
1 Discussion - BLN TVA's drawing 3GA0059-00-12 Revision 4, Note III.1, provides TVA's Division of Nuclear Construction with several tolerances for fabrication and modification of baseplates and installation of anchor bolts (excluding TVA typical supports which are modified by field variance). These tolerances were primarily given to allow DNC to resolve problems with interferences of expansion anchors with reinforcing steel.
The cumulative effects of the use of these tolerances may o
A have resulted in significant increases in baseplate stresses and anchor bolt loads. The potential increases because of cumulative effects were not considered in the design of the various supports. This deficiency is documented on NCR BLNCEB8421.
Failure to consider the potential cumulative effects of modifying supports within the approved tolerance envelopes could result in an "as-built" support configuration that does not meet desigt requirements.
I For supports already installed, a statistical sampling of j
existing field installations was made to determine actual i
field use of baseplate tolerances and existing
)
factors-of-safety.
Ninety-eight expansion anchored pipe supports were randomly l
selected and inspected. Supports which utilized installation I
tolerances were reanalyzed. Factors-of-safety for all 98 supports were consistent with design requirements I
(self-drilling expansion anchor factor-of-esfety greater l
than 5; wedge bolt factor-of-safety greater than a).
This sample provides a 95-percent confidence level that less than 3 percent of the supports have factors-of-safety less than design requirements. Based on the sample results, j
modification of existing supports was not required.
l l
m TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 65 0F 121 A study was made to assess the detrimental effects of failing to consider baseplate configuration tolerances in the oriLinal design process. The purpose of the study was to determine the following:
a.
Which combination of tolerances will give the worst case condition.
b.
Amplification factors which should be applied in the original design process if tolerances are not considered.
Based on the results of this study, the following actions were performed:
a.
Support designers were trained in the appropriate methods for consideration of baseplate tolerances.
b.
DS-C1.7.1 was revised to specify methods for amplification of expansion anchor loads and baseplate stresses.
In June 1985. TVA's Technical and Administrative Staff (TAS -
responsible for maintaining the DNE CAQ data base) identified an apparent adverse trend with regard to conduit supports not complying with the free area of attachment requirements shown on the design drawings.
This trend was identified during a review of CAQ Reports on
" Conduit Supports." Nine NCRs had been written involving violations of the free area of attachment requirement on the design drawing for BLN during 1984 to 1985.
The detailed review of the NCRs indicated that all nine NCRs were dispositioned to "use-as-is".
Further investigation revealed that more examples of this type problem exist and will be documented as CAQs in the future.
A concern was expressed that the project and site engineers are aware of the recurring problem with the free area of attachment requirement but have not taken any actions to identify and correct the root cause to prevent these recurring problems.
At this time, the problem does not appear to exist at any other l
TVA plants and therefore was deemed site specific to BLN.
i
TVA EMPLOYEE CONCEEX3 REPORT NUMBER: 10400 SPECIAL PROGEAM REVISION NUMBER: 2 PAGE 66 0F 121 Note:
In August 1985, the free edge violation was investigated for WBN and determined that the problem was not limited to free edge violations but also free area violations of drawing specifications at both WBN and BLN. WBN addressed this on SCR WBNCEB8623.
TAS recommended that the BLN Engineering Project investigate the handling of the free area requirement at other sites and/or the possibility of an over-restrictive free area requirement. Corrective action was to be initiated as necessary.
In response to TAS comments, CEB initiated PIR BLNCEB8518 to address the free area attachment requirements. This PIR was upgraded to a significant condition report SCR BLNCEB8518.
CEB initiated PIR VBNCEB8601 to address the effect of the additionel loading when insulation is applied to condult.
The PIR was reviewed by a BLN Electrical Staff Engineer who stated the following:
a.
No conduits supported by TVA are insulated. Therefore, the referenced PIR is not applicable to BLN.
b.
After Appendix R evaluations are completed some conduits may require insulation. However, these changes will be coordinated with the project civil group and any changes required will be worked under the ECN existing for Appendix R work.
CEB initiated PIR WBNCEB8602 to address typical support qualification.
PIR BLNCEB8610 was generated to identify the probles, at BLN.
This states that DNC has added conduit or other features (permitted by drawings) to civil structural supports after an altered configuration typical support has been checked and approved for current actual loadings.
Verification is required to determine that when the altered a
support was checked, the maximum loading condition permitted by the typical drawings was used and not the actual loading condition at the time to assure the worst case condition was considered.
4
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PACE 67 0F 121 Reviews of conduit and instrumentation support calculations and pertinent revision documentation are being performed to determine if deficient calculations for supports were approved by using current loading that was less than the maximum allowable design loading. Corrective actions will be taken as required ac:ording to the results of the reviews.
The result of the generic evaluation for SCR SQNCEB8607 resulted in PIR BLNCEB8612 being generated. This PIR states that some embedded plates are installed with the plate edge adjacent to a concrete edge. The edge may not have been considered in the capacity evaluation of the plate in some instances. A cursory review indicates that plate design accounted for edge capacity reductions; however, an in-depth verification will be performed to verify structural adequacy where required.
l The generic review for SCR WBNCEB8623 resulted in PIR BLNCEB8616 being initiated. This addressed the design of baseplates for cable tray supports, duct supports, miscellaneous steel access platforms, etc., before May 31, 1983 which were performed using approved computer program BAP222 and design standards Chen in effect. Because of the effect of plate flexibility on the welded stud capacity, these designs may not have the factors-of-safety against pullout required by DS-C1.7.1 (implemented on May 31, 1983).
The previous sampling programs utilized for GEN NCRCEB8208 and the additional information compiled as a result of PIR BLNCEB8518 will be used to qualify the existing design in response to PIR BLNCEB8616.
BLN Engineering Project reviewed SCR WBNCEB8650 which addressed attachments to engineered supports, cable tray supports, building steel, and miscellaneous steel (except embedded plates) without the benefit of an approved FCR and determined that this condition did not exist at BLN.
This was based on the fact that ONP has not made any installations referenced in this SCR. Modifications or deviations from detail drawings are made by controlled procedures FCRs, or interface reviews; therefore, this condition does not exist at BLN.
M
v-TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 68 0F 121 Conclusion Errors, omissions, or incorrect assumptions in design calculations that were identified and not corrected during 1984 hos not been proven to be factual.
Noncompliance with NRC IE Bulletin 79-02 and undocumented loads are factual based on the findings.
Discussion - BFN In 1982, it was discovered that the minimum spacing criteria as provided by G-32 R5 could have been inadequate in that expansion anchors can be installed at various plants which do not meet minimum spacing requirements when combined action of multiple attachments are considered. This deficiency is documented on NCR GENQAB8203. BFN has not evaluated the occurrences where expansion anchors for adjacent attachments are spaced closer than the G-32 requirements.
During a criteria review, the qualification of some
(
baseplates and concrete anchors in the typical support details of design criteria BFN-50-712 could not be verified I
and no weld details were specified. This is documented on l
SCR BFNCEB8520. Also addressed is the deficiency noted on NCR BFNMEB8406 concerning some supports for field routed l
schedule 160 piping which could be undersized based on their selection using the table in BFN-50-712 designated for l
schedule 40 and 80 piping.
This could possibly result in the baseplates, welds, and/or anchorage for supports given in criteria BFN-50-712 to be overstressed for the design loads given in the support tables.
This problem is not considered to be generic because of the fact that BFN is the only TVA nuclear plant where support typicals are given in the small bore piping criteria.
In order to evaluate the extent of this program deficiency, the following recommendations were given in the Engineering Report:
s
\\
l' t
l
________ _ ~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PRuGRAM REVISION NUMBER: 2 PAGE 69 0F 121 1.
Perform a walkdown review of a representative sample of existing 2-inch and smaller seismic cleas 1 field-routed pipe support installations. Identify any instances of configurations which cannot be defended on the basis of i
actual earthquate experience data.
2.
As required from the walkdown revarv, perform an engineering evaluation of the suppoJt installations and if required, take corrective action.
3.
Prepare DNE output documents as needed for new field-routed pipe support installations.
DNE prepared the scope of wort document, engineering costs, and timeframe necessary to perform a waltdown inspection and engineering evaluation of a representative sample of existing 2-inch and smaller class 1 field routed piping supports. The scope of wort document was BFPSWD 86-10. " Evaluation of Baseplates and Anchorages of Piping Systems Instslied to BFN-50-712."
In 1985, the NRC initiated Unresolved Item (URI) Numbers i
50-259/85-21, 50-260/85-21, and 50-296/85-21. These URIs identified deficiencies with DNE employees implementing TVA EP, 3.03 " Design Calculations." The deficiencies identified did not result in unacceptable support designs. The calculations were rechecked and revised *in accordance with EP-3.03 and training sessions were held to review the requirements for pipe supports.
The NRC also questioned TVA's technical basis that allowed the applied direct shear for the expansion anchor base plates to be distributed in inverse proportion to the tensile loading in the anchors.
TVA performed a random sample to prove that the use of a shear distribution method (which allowed the distribution of shear in inverse proportion to the tensile load in the archor) had not resulted in a significant number of supports with an inadequate factor-of-safety. The results indicate with a 95 percent confidence level that less than 5 percent of the anchors have an interaction ratio greater than 1.0.
l i
4
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 70 0F 121 PIR WBNCE28601 was initiated to identify a potential problem concerning the application of insulation to conduit after the typical conduit supports had been finalized.
BFN Project Engineering examined their activities in this area and found that the condition does not exist at BFN.
This is based on the following:
1.
All insulation installed after May 1984, in Class I structures is controlled by MAI 27.
This requires installing supports according to typical drawings 45A800 which specifically prohibits the use of any kind of wrap or by using specific drawings which would consider the additional loading.
2.
Conduits installed before May 1984, are being addressed by Class 1E conduit qualification program (BFNP PI 85-02).
Note: BFN PI 85-02 was issued to detail DNE's methods for inspection and seismic qualification of existing electrical conduit and conduit supports installed in Class I structures at BFN before May 1984 A final report will be prepared by CEB to document the seismic qualification of all electrical conduit and conduit supports. The report will be prepared after all inspections have been performed, discrepancies resolved, and necessary drawings have been issued.
PIB WBNCEB8602 was initiated to address typical support qualification. BFN Project Engineering examined their activities in this area and found that the condition does not i
exist at BFN. This is based on BFN Plant Procedure MAI 27 which controls the installation of conduit in Class I Structures. This procedure prohibits any attachment to conduit supports that is not specifically allowed by design drawings. Class 1E conduit installed before May 1984, is being walked down and qualified by a Class IE conduit qualification program.
(BFNP PI 85-02).
l f
i 9
l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAN REVISION NUMBER:
2 PAGE 71 0F 121 Construction tolerances for attachment location, anchor location, and baseplate configuration for pipe supports are noted for BFN on drawing Note 22 on 478435-1 and Note'35 on 478435-2. During a design review, it was noted that amplification of calculated anchor bolt loads and baseplate l
stresses will occur if the tolerances are used. This was not accounted for during the initial design.- This deficiency is documented on SCR BFNCEB8614. The remarks section~of this NCR references hCR SQNCEB8404, NCR BLNCEB8421, and l
NCR WBNCEB8419. Each of these NCRs document deficiencies with respect to TVAs failure to consider baseplate-flexibility during the initial design process. The baseplate flexibility issue is addressed by SCR BFNCEB8614.in that the description block specifically states that amplification of anchor bolt loads and baseplate stresses (both of which are considerations when accounting for baseplate flexibility) was not accounted for during initial design.
NOTE: The issue of baseplate flexibility was also addressed by the Engineering Category Browns Ferry Element Report 220.3(c), R2, on Support Design General. The report specifically addresses the Civil Design Standard DS-C1 7.1 requirement'for. consider.ation of baseplate flexibility and states that this requirement," is referenced in the BFN Design Criteria." It also states that. " rigid plate analysis instead of flexible plate l
analysis may be used to calculate the bolt tensile load provided the conditions specified in section 5.1 (DS-C1.7.1) are met."
The Engineering Category evaluation included a review of 21 sample supports and their calculation packages. Ten of these supports utilized baseplates and anchor bolts and five supports met the DS-C1.7.1 requirement for the flexible plate method of analysis. The report further states that, "the calculation for support RHR R159, unit 3, did not consider baseplate flexibility as required by DS-C1.7.1."
In the findings section of the Engineering Category Element report, it is stated that "... the supports were found to be adequate for the specified load.
Although the pipe supports were found to be adequate, their associated calculations were found to be incomplete and/or contained minor discrepancies
(.
. baseplate flexibility is not considered in the evaluation of anchor bolts). The calculation for support RHR R159, unit 3..
did not provide analyses for the critical baseplates."
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 72 0F 121 Therefore, based on the findings of the Engineer 15g Category Element report, a CATD was issued for BFN to specifically require flexible plate analysis on support KHR R159, unit 3, (CATD 10400-BFN-06). Since this Construction Subcategory report also addresses the baseplate flexibility issue from a broader perspective that includes NRC OIE Bulletin 79-02 criteria, the aforementioned CATD is included in this report instead of the Engineering Category Element report.
SCR SQNCEB8607 identified a deficiency addressing embedded plates installed with a plate edge adjacent to a concente edge.
A random ileid waltdown was conducted at BFN to determine generic applicability and several deficient areas were identified. A specific location noted is the Diesel Generator Building.
At the time of the initial design and installation of the embedded plates, considering the effects of a concrete edge on the embedded plate capacity was not a requirement. This is documented on SCR BFNCEBB617.
l The deficiencies in embedded plate design for cable tray supports and control of fleid change requests as identified by SCR WBNCEB8623 and SCR SQNCEB8622 were reviewed by BFN Engineering Project.
The conditions outlined in SCR WBNCEB8623 potentially exist at BFN. BFN has been and is presently undergoing evaluation of the following:
[
1.
Piping systems their supports and anchorages under the 79-02 and 79-14 programs.
2.
Conduit and their supports under the conduit qualification program.
3.
Cable trays and their supports will be reviewed under the long term cable tray systen qualification program.
4.
Heating and ventilation ducts (HVAC) and their supports will be reviewed under the HVAC qualification program.
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TVA EMPLO7EE CONCERNS REPotT NUMBER: 10400 SPECIAL PROGEAN REFISION NUMBER: '2 PAGE 73 0F 121 The above programs will address any deficient conditions. A program of constructability walkdowns is now la effect at BFN and all new modifications will be walked down and fully coordinated before the start of the design activity.
In response to SCE SQNCEB8622 (cable trays do not meet design requirements) BFN stated the conditions do exist and are being covered for unit 2 by an Interim Qualification by United Engineers and for the other units by the long term requalification of the cable trays.
In response to SCR WBNCEB8650 (miscellaneous steel and attachments) CAR 85-059 had already been initiated to address this deficiency.
For any future pipe supports the pipe support designer will be required to design the miscellaneous steel support framing in addition to the pipe support or to transmit the loads to the miscellaneous steel support framing designers for analysis.
The existing pipe supports, cable tray supports, and conduit supports will be verified or qualified by ongoing programs.
Conclusion Errors, deviations, and incorrect assumptions in design calculations that were identified and not corrected during 1984 has not been determined to be factual.
Noncompliance with NEC IE Bulletin 79-02 and undocumented loads are factual based on the findings.
4.2 The findings as indicated below address the second issue (noted in paragraph 1.2.2).
This issue states that the design philosophy for concrete anchor bolt (wedge bolts) allowable loads for unit 1 are greater than unit 2.
4.2.1 Generic Discussion - WBN i
NRC IE Bulletin 79-02 specifies that the. factor-of-safety for all loading conditions shall be 5 for espansion shell anchors and 4 for wedge bolt anchors unless justification for a lower
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 74 0F 121 factor-of-safety is provided. Before 1981. TVA ailowable tensile design loads for uervice conditions were based on a factor-of-safety of 4.5 for self-drilling anchors (Redheads) and 4.0 for wedge bolt anchors. Initially, the factor-of-safety for shell anchors was applied to the average tensile capacities obtained from manufacturer's tests.
In 1977, onsite qualification tests were performed and results l
l were added to G-32 (Appendix C).
The factors-of-safety for J
l both shell and wedge anchors were based on the minimum j
qualification load.
In 1981, the allowable tensile loads for self-drilling anchors were reduced to maintain a factor-of-safety of 5 with respect to the minimum ultimate tenslie capacities derived from onsite qualification tests. The service load allowables did not change, however, for those designs that were based on normalized loads. The allowables were reduced to maintain a factor-of-safety of four.
==
Conclusion:==
The allowables for unit 1 are greater than unit 2; therefore, this concern is factual.
l Discussion - SQN l
l The increase in the factor-of-safety required by IE Bulletin l
79-02 resulted in a corresponding reduction in the allowable bolt loads. This change occurred during a timeframe which resulted in the allowable loads for wedge bolts in VBN unit 2 t
being lower than those allowed in unit 1.
However, these changes did not effect the methodology utilized in determining the wedge bolt allowables for SQN units 1 and 2 and VBN unit 1.
==
Conclusion:==
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The same criteria was used to calculate the wedge bolt l
allowables for SQN units 1 and 2.
Therefore, this concern is not factual.
Discussion - BLN Before the issuance of DS-C1.7.1 (issued May 31, 1983) allowable loads for expansion anchor bolts were obtained from l
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 75 0F 121 manufacturer's literature. The allowable loadings were based on a factor-of-safety of four for service load conditions.
For extreme loading conditions load allowables were increased
{
by 60 percent. The factors-of-safety of 4 for wedge bolts and 4.5 for shell-type anchors were based on minimum qualification test requirements.
Mejor piping systems were designed by ITT Grinnell and utilized a factor-of-ssfety of 4 for service load conditions based on manufacturer's allowable loads.
Conclusio_n:
There were no changes in the methodology used to calculate the wedge bolt allowables for BLN, therefore, the concern is not factual.
Discussion - BFN All major piping systems were designed by Bergen-Paterson and required a minimum factor-of-safety of 4 for wedge bolts.
In addition. TVA designed systems were also designed with a minimum factor-of-safety of 4 for maximum load conditions.
==
Conclusion:==
The minimum factor-of-safety for loading conditions for wedge bolts has always been 4.
Therefore, this concern is not factual.
4.3 The findings as indicated below address the third issue (noted in paragraph 1.2.3).
This issue questions visual approval for minor loads on embedded plates.
4.3.1 Generic Discussion - WBN The NSRS investigation of this issue consisted of procedural reviews, review of FCRs Interviews with DNE engineers and fleid observations relating to the visual approval of embedded plate FCRs. The following summarizes their findings:
NSRS substantiated the concern based upon a review of DNE EP-4.03 Appendix 4 and associated FCRs.-
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 76 0F 121 l
l Construction Specification N3C-928, " Locating Attachments on i
Embedded Plates," addresses the minimum spacing requirements and the visual program implemented by FCR H-10917 on January 6, 1984. The procedure states in section 2.4.3:
"An FCR may be approved by EN DES representatives onsite without a sketch if they determine by visual examination that a detailed evaluation of the plate is not required,"
NSRS stated that no clarification or qualification is provided in the specification. Visual inspection of certain attachments is allowed by EN DES EP-4.03 Appendix 4 if the support attachment exhibits minor load characteristics similar to the following:
a.
Small attachment members such as unistrut members or standard structural shapes of strength similar to unistrut.
b.
Attachments which support single runs of conduit of diameters less than or equal to 3 inches; or multiple runs of conduit exhibiting similar load characteristics.
c.
Attachments which support single pipes of diameter less than or equal to 2 inches.
Design calculations (WBP 840515 212) have been performed to provide technical justification for acceptance of the minor loads listed above in an individual application. However, the calculations do not take into account loads applied by previous attachments.
If the attachment cannot be visually approved, further evaluation is required.
I The following FCRs were approved visually with minor loads added.
a.
FCR EP-3733 b.
FCR EP-3752 c.
FCR EP-3759 d.
FCR EP-3784 e.
FCR EP-5171
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 77 0F 121 These FCRs were discussed with DNE personnel and were determined to have been approved when they did not meet the intent of the visual program. The attachments were welded to embedded plates which in most cases supported other attachments.
The visual approval program was observed in the field for eight FCRs. The following FCR's had supports as defined by EP-4.03 Appendix 4 (currently CEB-21.46) however, four of the FCRs were for embedded plates with multiple attachments.
(
a.
FCR EP-9911 b.
FCR EP-9912 c.
FCR EP-9913 d.
FCR EP-9917 (multiple attachments) e.
FCR EP-9918 f.
FCR EP-9919 (multiple attachments) l g.
FCR EP-9920 (multiple attachments) h.
FCR EP-9921 (multiple attachments)
Discussions between NSRS and DNE personnel indicated that the approval of embedded plate FCRs was an engineering evaluation rather than an actual visual inspection. They stated that l
the approval process was based upon actual loading, allowabia l
loading and previous engineering evaluations. However, in I
l most cases there was no documentation to support this justification.
l NSRS recommended the following:
1.
Evaluate the adequacy of the visual inspection program by performing calculations on a random sample of embedded plate FCRs which include:
a.
EP FCRs visually approved more than once to address multiple attachments, b.
Systems critical to safe shutdown.
t
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 78 0F 121 2.
If the sample provides evidence that the v'isual program is effective then perform the following:
a.
Develop a procedure to describe the actual EP-FCR approval process b.
Require DNE approval before actual installation of an attachment which deviates from the required minimum spacing I
Provide justification that the visual approval program c.
complies with 10 CFR 50 Appendix B, Criteria III 3.
If the sample provides evidence that the visual program is not effective then:
Revise N3C-928 to remove paragraph 2.4.3 which refers a.
to visual inspection b.
Perform design calculations on previously visually approved EP-FCRs and require calculations of all future EP-FCRs on October 18, 1985 DNE met with representatives from QTC l
and NSRS and discussed the following issues:
l a.
Transfer of work between sections b.
Calculation errors in the load determination for EP-FCRs requiring detailed evaluation l
Effectiveness of the visual inspection program and c.
effects of cumulative loads (NSRS concern)
Items a. and b. are covered in section 4.1.1.
In order to address the effectiveness of the visual approval program. DNE agreed to evaluate 60 visually approved EP-FCRs.
Documentation deficiencies found in the evaluation which did not meet the acceptability criteria would be evaluated as conditions adverse to quality.
The sample was randomly selected from the population of embedded plates which had b6en approved at least 3 times and had never been office approved. The subpopulation meeting j
these criteria consisted of 219 embedded plates.
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TVA EMPLOYEE CONCRRNS REPOET NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 79 0F 121 1
The analysis of the sample showed all 60 embedded plates were qualified. The stresses in the plates, anchors, and concrete are within the allowable limits. Therefore, it can be stated with a 95 percent confidence level that no more than 5 percent of the embedded plates which have been visually approved have stresses which exceed allowable loads. This was in accordance with the original acceptance criteria.
The following items were observed during the sampling program:
a.
Approximately 20 percent of 270 FCRs written by DNC in the sample reference incorrect plate numbers. The approved FCRs indicate that most of the errors were identified by DNE during the visual examination and corrected. The document reviews identified four FCRs which were approved but referenced the wrong plate number, b.
The allowable stress for the anchorage for one embedded plate exceeded the allowable stress using the cable tray calculations.
Reanalysis of the cable tray using more l
refined seismic analysis resulted in a reduction in stress to well within the allowables.
c.
Reactions calculated by DNE are for the typical configuration currently attached to the embedded plate.
There is a potential where the fleid (DNC) could have added pipes.or conduits to the support and not reported the modification to DNE (see section 4.1.1).
With respect to the evaluation procedure and compliance with 10 CFR 50 the following was provided:
a.
The visual approval provisions for evaluation of embedded plate FCRs was included in WBN Project General Construction Specification N3C-928 because experience j
with the evaluation of the FCRs on embedded plates showed that less than 5 percent of the FCRs were being rejected. This occurred primarily because most of the attachments causing the violation of the spacing were typical lightly loaded supports.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 80 0F 121 b.
Since the rejection rate was so small and the' preparation of a sketch for each of the FCEs was very labor intensive, the specification was revised. The revision allowed DNE engineers / designers to visually examine the embedded plate to determine if a sketch and detailed evaluation was required.
c.
This method of evaluation was considered to be acceptable since the engineers performing the visual examination are expeelenced in the analysis of the embedded plates and since a review of the approval is performed by an equally qualified individual. This evaluation and review is in compliance with the requirements of 10 CFR 50.
f d.
The visual approval process is commensurate with the i
original design. The majority of the embedded plates were designed and installed for intended later use by supports that were unidentified at that time. Many embedded plate details were dupilcated from SQN drawings.
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- 1. While specific loadings were not available for most embedded plates, engineers provided plates which would be expected to provide adeguate capacity for any future unidentified supports. The selection of the specific embedded plate size and thickness and the welded stud size, length, and spacing was based mainly on historical usage and engineering judgment.
However, some calculations are available for SQN which determine embedded plate dimensions and details needed I
to envelop loads provided by mechanical support
)
designers, i
- 2. Embedded plates of the size and configuration used at WBN can accommodate supports with a variety of load magnitudes and locations. Therefore, visual approval 1
of minor load additions is within the scope of the l
criginal design.
A review of the work done to date indicates approximately 70 percent of the embedded plate FCRs are visually approved. Of the remaining 30 percent that are submitted for detailed evaluation only 3 percent have been rejected. This indicates that the DNE personnel in the fleid are conservative in their visual evaluation methods.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 81 0F 121 Conclusion
'The sampling program for visually approved embedded plate 1
FCRs indicates that the procedures used have been effective l
and comply with 10 CFR 50 Appendit B.
I The visual approval process is commensurate with the original 1
design of the embedded plates and the experience and sampling j
have shown that the program has been effective. However, some enhancements to the visual approval program will be made:
I a.
The engineering and construction procedures will be l
revised to emphasize the necessity of assuring the l
correct plate number is on the FCR.
b.
The engineering procedure will be revised to list some standard acceptance criteria. Listing of some examples I
will be made, however, the visual examination will allow other items to be accepted if justification is given on the FCR form.
i The evaluation performed by the NSRS provided examples where attachments to embedded plates had been visually approved but did not meet the guidelines in CEB-21.46 and visual approval was performed for an embedded plate that was already supporting other attachments. A specific definition for a minor load is not given in CEB-21.46.
Examples to be used as guidelines are shown. EP-FCRs that did not meet this requirement were determined to have been visually approved, therefore, the concern is considered to be factual.
Discussion - SQN EP-4.03 Appendix 4 is site specific to WBN. In reviewing the SQN-GCTF Report, it was stated that no issued instructions exist for visual approval of FCRs, However, N2C-937
" Locating Attachments on Embedded Plates," Section 2.5.2 states:
"An FCR may be approved by CE representatives onsite without a sketch if they determine by visual examination that a detailed evaluation of the plate is not required."
This provides a mechanism for a visual program. The contradiction in the SQN-GCTF and the procedure resulted in additional evaluation.
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SPECIAL PROGRAM REVISION NUMBER: 2 d
PAGE 82 OF 121 1
Responsi' ole engineers were; interviewed in the DME.Clyll i
Design Analysis Section and it was' determined that the visual approval mechanism allowed by N2C-937 was not utilized at SQN. Further dise.ussions concerning minor loads reiealed the following:
)
J 1.
A process is used by the Civil Structural Design Group j
which allows for " preliminary approval" of minor loads attached to embods. This preliminary approval conrists of engineering evaluation of the specific embed
)
attachment by the responsible design engineer. FCRs.
l ECNs, new attachments, alternate analysis and revised i
loadinga resulting from rigorous analysis are sufficient reason to initiate this' evaluation. A detailed sketch of the individual' feature or attachment is attached to a log sheet used for attachments to embeds. This sketch along with the information included on the log sheet provides sufficient. detailed information for the responsibic engineer to evaluate the installation. For cases where minor loads aro approved without detailed calculations being performed, the responsible engineer makes a note on the log sheet that only a minor lond is involved.
Subsequently, the assembled information is entered into I
the group's computer data base which will establish a baseline of information for future reference.
/
Eventually, detailed calculations can be performed on the embed that'will include the minor loads which receive only preliminary approval under the current program.
It should be noted that this program has been in place approximate"2y one year (established in early 1986).
The'/efore, only the detailed calculations for each 1
identiflad embed ut.tachment submitted since the program's origination date and futurw calculations for specific embed attachasnts will be retriev:ble from the data base. All other existing embeds including configurations and loads will not be included in the computcr data base i
unless they are submitted to or identiflad by the group for evaluation. It is reasonable to ensume that the l'inal contents of tha data base will include only a j
portion of the total number of embeds, their attachments and loads if the program continues.In its present form.
In addition, dircuasions with the responsible civil engineer in the group revealed that there were nu
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM RRVISION NUMBER: 2 PAGE B3 0F 121 commitments in place at present to perform detailed i
calculations / analysis on embeds which would include the loadings from minor load attachments currently receiving preliminary approval.
The process used by the Civil Support Design Group includes the following:
q A detailed sketch attached to the FCR Which includes
)
s.
features within a 2-foot radius of the subject embedded plate attachment.
b.
1her. applicable, a note is made on the TCR by the re:4ponsible. engineer indicating minor loads are attached to the embed. While the minor load is shown on the detailed sketch this load addition to the embed is not always included in the detailed calculations performed to gunlify the embed.
Instead, engineering evaluation by the responsible design engineer determines whether the minor load is significant to the point that it will be included in the detailed calculations, goth groups stated that thnee was no written criteria which clearly defined or provided guidelines for identifyltig minor loads.
Further discussion led to the conclusion that some general guidelines for identifying a minor load could further enhance the engineering judgment and expe'rtise which is currently used to make this determination. This evaluation agrees with that conclusion.
Corelusion:
Concern IN-85-003-001 was not answered adequately by the SQN-GC7F report. However, this evaluatiren determined that the concern was not generic to SQN. In addition, the program-for evaluation of minor losde attached to embeds.are adequate with the following comments:
a.
DNd-CEB should conuider a review to determina whether insplementing general guidelines for identifying ainer loads attached to embeds would serve to improve the exist.ing program (s).
At VBN DNE-CEB ipoued CEB-EP 21.46 to provide further guidelines for attachments to embeds which were not addressed in N3C-928. Furthermore, the mechanism for visual approval of loads attached to embeds 1
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1 REPORT NUMBER: 10400 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 2 PAGE B4 0F 121 as allowed by N2C-937 is not used by the site Civil DNE Therefore, consideration should be given organization.
to deleting section 2.5.2 of N2C-937 unless it can be f
established that future installations will be evaluated using the visual approval process.
In addition. DNE-CEB should consider a review to b.
determine whether:
The existing program (s) should be expanded so that the detailed sketch reflects all features attached to the This comprehensive sketch would only be embedded plate.
required the first time a FCR, ECN. new attachment, etc.,
caused the subject embed to undergo detailed This exercise would serve to establish a calculations.
baseline program which would preclude the potential for overloading an embed because all attachments had not been identified and considered during the calculation Future FCR, ECN, etc. sketches would only be process.
required to reflect the individual feature or attachment I
since the data base would contain detailed calculation data on all other attachments to the subject embed.
Any minor loads receivi'ng preliminary approval under the current program should eventually be included in the detailed calculation process.
The findings as indicated below address the fourth issue (noted in This issue questions the minimum spacing criteria 4.4 paragraph 1.2.4).
inches and 8 nominal bolt diameters to change from 18 inches to 24 10 nominal bolt diameters in 1982.
4.4.1 Site-Specific
.D.is_cussion - WBN In March 1982, CEB' initiated NCR WBNCEB8203 which addressed loading on embedded plates without a design review of the embedded plate capacity..(See section 4.0.)
A random sampling Program of 69 embedded plates did not idsntify any support failures.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM j
REVISION NUMBER: 2 PAGE 85 0F 121 The undocumented loads on the embedded plates resulted from a lack of complete requirements in either a construction specification or design drawings to control the minimum distance between the attachments to embedded plates or the I
minimum distance between attachments to embedded plate edges. To prevent recurrence, DNE initiated N3C-928 (February 10, 1983) which addressed the minimum distance l
requirements.
All future attachments that violated the minimum spacing requirements would require approval from DNE.
I N3C-928 required a 24-inch minimum clear separation in at least one direction parallel to a plate edge. For specific plates, the minimum clear distance could be reduced to two times the spacing of the embedded (welded) stud rows which are perpendicular to the direction of measurement.
G-32, R7, in effect during the same timeframe, allowed the minimum spacings between expansion anchors and embedded l
plates or strip inserte and the minimum spacing between i
grouted anchors and embedded plates or strip inserts to be reduced to a minimum of 2 inches for embedded plates or 1 inch for strip inserts, provided at least 18 inches is maintained between the anchor and any attachment welded to the embedded plate or between the ancher and any bolt
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Note:
G-32 provided a radial close distance. The change to l
the parallel measurement allowed the field to use smaller minimum spacings for plates where the welded stud spacing is less than 12 inches.
The contradiction in requirements between N3C-928 and G-32 l
was resolved in G-32, R8.
This revision included section 3.6 i
for location of anchors specifically for WBN. The 18-inch minimum spacing requirement was revised to 24 inches to agree with N3C-928. The minimum spacing of 18-inches remained unchanged for the other nuclear plant sites.
The above changes provided:
j a.
Separate minimum spacing requirements for WBN in order to match N3C-928.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 Y
PAGE 86 0F 121 i
b.
Revision to the minimum spacing requirement for expansion anchors to a free edge and embedded plate edge, c.
Allowance for DNC to attach to an embed if two rows of embedded (welded) studs separate an existing attachment l
and the new attachment.
i d.
Additional conservatism as compared to the original spacing criteria.
G-32 RS (issued July 21, 1977) section 3.5.2 required the l
minimum side cover (edge) distance between an expansion or grouted anchor and a concrete edge to be 6 nominal bolt diameters. The requirement has never been 8 bolt diameters as stated in the concern.
1 Civil Design Standard DS-C1.7.1 addressed edge distance and
{
the effect that an adjacent free edge may have regarding the capability of an anchor to transfer tension and shear loads i
to the underlying foundation.
i The 6 nominal bolt diameter was for expansion anchors in
)
tension to prevent spalling or cracking of the concrete 1
during installation. This is addressed in Section 8.1.2 of
)
DS-C1.7.1 which states that the primary lateral forces developed in concrete by expansion anchers occur during installation.
Therefore, the tensile loading is not of primary importance in determining the edge distance for expansion anchors but to prevent spalling or cracking of the concrete during installation.
G32, R6 (issued February 17, 1981) went to a 10 nominal bolt diameter separation for expansion anchors I
and/or free edge which enabled DNE to maintain a conservative l
position and eliminated DNC's need to determine whether the load on the anchor was tension and/or shear toward the free edge. The responsibility for determining that load requirements are met is covered by DNE in DS-C1.7.1, section 8.0.
No rework or reevaluation was necessary because of the fact that the changes were not made for technical reasons, inadequate requirements, or load bearing capacity for embeds.
1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 87 0F 121 Conclusion Minimum spacing and edge distance requirements did change and no review was performed of the existing installations; therefore, the concern is factual. However, as stated above, the changes were not made for technical reasons and the 18-inch minimum spacing requirement remains in effect at all other TVA nuclear plants.
4.5 The findings as indicated below address the fifth issue (noted in paragraph 1.2.5).
This issue concerned engineering disposition for exemptions of minimum spacing requirements.
4.5.1 Site-Specific Discussion - WBN WBN Project Specification N3C-928. R2, " Locating Attachments on Embedded Plates" provides requirements for the location of attachments with respect to minimum edge distance, minimum spacing between attachments, and minimum spacing between expansion anchors and attachments that do not require DNE review.
If conformance to the requirement for edge distance or for s' pacing between attachments on the embedded plate is impractical, an embedded plate field change request (EP-FCR) is initiated by DNC.
The EP-FCR is submitted to DNE for approval of the location and loading on each attachment. This assures that anchors spaced less than the normally applied minimum have been evaluated for the effect of the reduced spacing on anchor capacity. An FCR may be approved visually by DNE representatives onsite if they determine that a detailed evaluation of the plate is not required.
The result of the sampling programs as addressed in Section 4.1.1 and 4.3.1 confirms that the design established for embedded plates has been proven to be conservative enough to accommodate unforeseen deviations from the prescribed parameters without compromising the load bearing capacity of the embed.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 88 0F 121 The sampilng programs provide a 95 percent confidence lovel that less than 5 percent of the population is defective.
==
Conclusion:==
The concern le factual in that minimum spacing requirements can be reduced according to the FCR process. However, the exemptions to minimum spacing requirements are procedurally l
controlled to avoid overloading of the embedded plate.
l 4.6 The findings as indicated below address the sixth issue (noted in paragraph 1.2.6).
This issue addresses the hollow sound that occurs when embedded plates are tapped.
4.6.1 Site-Specific Discussion - WBN l
1 Areas of some embedded plates at WBN have a " dead" or
" hollow" sound when struck or tapped with a metal object.
This sound indicates that a portion of the plate is not in solid contact with the underlying concrete.
The NSRS investigated concerns addressing the " hollow" plate sound. The concerns were substantiated in that some areas on embeds do sound hollow when tapped. However NSRS found no l
evidence of large voids existing behind the embedded plates l
and although substantiated, this situation does not have an l
adverse effect on nuclear safety.
DNE met with the Employee Concern Senior Review Panel on June 26, 1986. The panel requested DNE provide input to the engineering significance of the hollow sounds for some i
embedded plates and their effect on the capacity of the l
plates. The following excerpt was taken from the DNE-CEB l
response:
The " dead" or " hollow" sound indic6tes that the concrete is not bonded to the plate and may not be in solid contact with the underlying concrete. The loss of bond or the lack of solid contact could be caused by:
a.
Concrete placing Vold l
A concrete placing void behind the embedded plate would I
result in lack of solid contact. The void could be caused by congestion from the reinforcing bars and the l
anchors or by inadequate consolidation of the concrete.
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TVA EMPLOYEE C0!4CBtw3 REPORT N'JMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 89 OF 121 l
The occurrence of plecing volds behind plates on vertical l
surfaces is consi.lered unlikely. The congestion behind l
the plate la not significantly worse than for most portions of a trall or column end. is better than many i
locations such a, ti.e ervus around penetrations. Placing volds or "honeyco..b" are sometimes encountered at horizontal construction joints, but large random surface volds which are visible on the surface when the forms ar,e removed are uncommon. Placing voids at the horizontal jolrA are generally less than 2 inches in height and extend for several feet. Therefore, if those volds occurred behind entadded plates they would have been
)
l visible beyond the plate and would have been repaired or l
l would have been very limited in width.,
I b.
Warpage of Embeddyd tlates 5
When a feature is wetdec to an embedded plate, the temperature diffei :
't.s netween localized areas of the plate are very L ir
- e 1crge temperature gradient occurs across the t nler:.ess of the plate. The in-plane temperature difference and temperature gradient will result in some lota.ized yielding of the plate and will result in a 1 css of !.cnd between the plate and the concrete.
The larger th
.t-end the larger the size of the weld; the hither the temperature, the temperature gradient, and the area cf the plate that will be affected. The weldint procedure and sequence of welding also affects the temperature of the plate. A common occurrence durint welding to embedded plates is minor spalling of the concrete at the plate perimeter because of the in-plane expansion of the plate.
After completiom of welding, the subsequent cooling of the plate to ambient temperature, results in residual stresses which will reniain in portions of the plate. The plate is restrained from free contraction by the anchors. These residual stresses could result in additional loss of bond and frequently result in some minor warpage of the plate. Generally, the plate deformations are not visually apparent.
The warping of the p2.Les because of welding is the probable cause for most occurrences of " hollow" sounding embedded plates. However, the gap between the concrete and the plate would be very small unless the plates were visually warped.
1 1
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM REVISION NUMBER: 2 1
PAGE 90 0F 121 i
l Visible warpage of embedded plates has occasionally l
occurred as evidenced by WBNNCR6470, however, no generic j
problems with warpage of embedded plates have occurred at any TVA plant. Excessive gaps because of welding of attachments is not likely to be a problem at WBN.
{
c.
Concrete Shrinkage l
The hardening of concrete is an exothermic reaction (hydration of the portland cement) which results in l
significantly increased temperature in the concrete mass for some period of time after placing. The volume change I
during the cooling to ambient temperature is significant for large concrete members like those in a power plant.
j Some drying shrinkage also occurs. These volume changes j
could result in a loss of bond and could potentially result in a small' gap between the plate and concrete.
The shrinkage of'the concrete would result in both tensile and shear stresses at the interface between the embedded plate and the concrete. These stresses would oe expected to be relatively small but would combine with any stresses because of the temperature cycles that the embedded plate and the concrete surface would have been exposed to during the various stages of construction.
The temperature of the underlying concrete would significantly lag the temperature of the plate during periods of fluctuating temperature.
The loss of bond between the embedded plate and the underlying concrete and the possibility of a small gap would be expected to result in a noticeable difference in the sound that would result from striking the plate.
However, the gap would not be expected to have a width that would affect the design of the embedded plate.
All baseplates, including embedded plates, are designed by assuming that a perfectly elastic plate is in perfect contact with a perfectly elastic underlying material. These assumptions are never totally achieved for actual installations but engineering experience has shown that these assumptions have resulted in safe and serviceable designs.
Should a small gap exist under a portion of an embedded plate, the primary effect on the design would be a potential increase in the deflection of the attached structure and a potential increase in the loads on the anchors.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 j
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 91 0F 121 1
Deflection could increase if the attachment was placing l
compression stresses between the plates and concrete and the gap was large enough in area to a' tow the plate to deform into the gap. Small gaps resulting from plate warpage or temperature change would have minimal effect on the j
deflection of the structure, especially if the structure was braced or had multiple attachment points.
If a gap with a relatively large area existed under a plate, the anchor loads at working load levels could increase for 4
attachments placing bending moment on the plate. The increase would occur because the moment arm between the anchors and the resultant compressive force would be reduced. For example, it is conceivable that the moment arm 1
for an embedded plate could be reduced from 8 to 6 inches under working load conditions. This would result in a increase of about 30 percent in the anchor loads.
1 The underestimation of the anchor loads at the working load level is not significant for this condition. As the load increases the plete movement would close the gap and the moment arm would return to the predicted value. Since the factor-of-safety for welded studs for working loads is at l
1 east 3 and usually 4 the deviation at the working loads level is not significant. The required factor-of-safety for ultimate loading is maintained.
The unimportance of small gaps or voids under the plate is further emphasized by the fact that most embedded plates would support their design loads with a relatively large gap i
under the entire plate.
Unlike other types of anchors (such l
as anchor boli.s), welded stud anchors will carry a compressive load. Therefore, if a large gap occurred, both the tenslie and compression loads would be transferred to the anchors. The anchor loads would probably be somewhat less I
because of an increase in the moment arm and the plate
{
bending stresses will probably be somewhat higher because of j
the greater distance between the attachment and the resultant
{
compressive force. If any portion of the plate was in contact with the concrete the stresses and loads would approach the calculated values.
==
Conclusion:==
The " hollow" sounds exhibited by some embedded plates when struck with a metal object are not necessarily indicative of the presence of large volds under the plate. Small gaps are expected to occur under the plates and these small gaps could result in the " hollow" sounds that have been observed.
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1
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 l
SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 92 0F 121 Small gaps under embedded plates do not have a significant J
effect on the structural performance of the embedded plates, i
Unidentified volds large enough to effect the design are very unlikely since these volds would probably have extended beyond the plate and would have been identified and repaired.
The concerns are factual in that some plates do sound hollow when tapped. However, no condition adverse to quality exists.
l l
4.7 The findings as indicated below aduress the seventh issue (as noted in paragraph 1.2.7).
This concern addresses plates with I or 2 welded studs and cast-in-place anchors supporting loads for which no documentation exists to verify their ability to support the loads.
4.7.1 Site-Specific Discussion - BLN The configurations for the subject plates are shown on drawings 4RWO425-X2-10, 4RWO507-X2-02, and 4RWO516-X2-02.
The original design of this feature was to have a surface mounted plate installed spanning the existing embedded plate supported by cast-in-place anchors (type 49 plate).
FCR-0-4866 was initiated on 3/5/86 to allow the surface-mounted plate to be deleted providing the outer nuts on the cast-in-place anchors were torqued to snug tight. By torquing these nuts the loading is placed on the cast-in-place anchors snd not on the welded studs.
\\
I l
A visual inspection of four pipe supports attached to the l
type 49 plates revealed that the outer nuts on the cast-in-place anchors were not torquod and in most cases were not installed. Three of the four type 49 plates had pipe supports installed according to the DNE drawings.
Note:
BLN NCR 5007 was initiated by the site to document the deficiency of improperly installed and/or missing anchor bolt nuts.
In reviewing drawings and procedural requirements, it was noted that no requirements exist for restraining nuts of embedded bolts from movement or loosening during concrete pours.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 93 0F 121 Note:
BLN NCR 5016 was initiated by the site to document procedural and drawing deficiencies in addressing locking / restraining methods for the embedded nuts.
The DNC BLN Civil Engineering Unit Supervisor was interviewed and the following was stated:
a.
The pipe support drawings do not reflect the type 49 plate configuration as being part of the support drawing; therefore, Hanger Quality Control (HQC) was not required to inspect the nuts during the hanger inspection, b.
The embedded feature configuration and material requirements are noted on the civil drawings. No provision is provided for a locking / restraining method for the embedded nuts.
A discussion with a BLN DNE unit supervisor revealed the l
following:
l l
a.
The plate integrity where a single nelson (welded) stud is suspected of accepting the entire load of the installation should be questioned.
b.
He was not sure what the design basis was for the original analysis of the plate nor could he verify what specific purpose the nelson stud served (alignment versus loading).
Both issues will be addressed in the NCR response.
In regards to restraining the nuts on the embedded bolts during concrete pours a DNE-CEB engineer stated that any problems would have been identified in the proof load failure rates. He estimated that during a concrete pour, if a nut moved it would probably be 1/4 of a turn. He estimated that it would take approximately 8 turns for the nut to back off the stud.
==
Conclusion:==
The concern relative to this issue is factual. The disposition of the nonconformances initiated as a result of this concern will verify stud anchor and/or plate integrity.
y m
REPORT NUMBER: 10400 TVA EMPLOYEE CONCERNS l
SPECIAL PROGRAT REVISION NUMBER: 2 PAGE 94 0F 121 5.0 COLLECTIVE SIGNIFICANCE 5.1 Collective Sir.nificance of Issues i
l The following is a summary of collective significance findings for the seven issues comprising this subcategory.
Management effectiveness was exemplary in the development of 5.1.1 programs which proved to be economical and time efficient.
Anchor spacing tolerances were relaxed where possible and engineering expertise was utilized to' visually approve minor loads on embeds. Management also displayed consistency in their willingness to initiate sample programs for field l
installations to prove the adequacy of design and construction methods for NRC OIE Bulletin 79-02.
However, management was ineffective in their willingness and ability to communicate with the NRC on 79-02 issues. The initial TVA response to the NRC on this subject was based on i
design methods and criteria which they were confident met or exceeded the intent of the bulletin. Furthermore, correspondence between TVA and the NRC was limited and additional information requests by the NRC should have indicated to management that the NRC was not totally satisfied with the TVA response. Instead of establishing a definitive policy of communication with the NRC on bulletin issues, management's philosophy was to further justify TVA's existing methodology instead of incorporating 79-02 requirements. Failure to establish definitive communication wi'b the NRC and un attitude of " justify" instead of si. corporate and comply" has resulted in the bulletin
In addition, the regeneration of I
calculation packages and the documented deficiency of Rawl IR:
anchors has caused additional work at SQN on 79-02 related l
l issues.
Management was also deficient in the area of employee training and failed to ensure that adequate procedures were in place to effectively control the required wort, or stressA the need for high quality and accurate work by employees.
large number of CAQ's have been identified in this area where effective management could have, as a minimum, curtailed these occurrences. Management was also ineffective in communicating with employees on specific technical issues as evidenced by the large number of employee concerns expressed on similar subjects.
v TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 95 0F 121 Employee effectiveness was impacted by inadequate procedural requirements and a lack of adequate training. However, a lower quality of work than required was identified, as both errors and inaccurate information were found to have occurred more often.than was acceptable.
From another perspective employee effectiveness could be regarded as positive when consideration is given to the lack of effective management, inadequate procedures, and training.
Technical adequacy has shown a marked improvement during the mid-1980's. Program changes and enhancements have increased the overall adequacy of design criteria and site procedures.
The resolution of generic technical issues identified during the late 1970s and very early 1980s has revealed TVA was
{
effective in identifying and implementing corrective action j
for significant program inadequacies. However, the number of i
changes and program enhancements implemented is indicative of the lack of technical adequacy during that time period.
5.2 Collective Significance of the Subcategory 5.2.1 Generic a.
Management Effectiveness Collectively. TVA responded to NRC Bulletin 79-02 within the 120-day timeframe as required. The generic and individual site responses specified the design criteria utilized by TVA designers which were felt by TVA to meet and/or exceed the intent of Bulletin 79-02.
Additional information requests from the NRC resulted in acceptance and closure of the Bulletin for SQN unit I which was under operation and SQN unit 2 which was still under construction.
The WBN unit I response (originally submitted in July 1979) has not been accepted nor rejected to date by the NRC. As a result, TVA requested a meeting with the NRC in January 1985, to present the 79-02 factor-of-safety concern and the lack of EDS calculations (addressed in subcategory reports EN 20500 - Control of Design Calculations and EN 22100 - Pipe Support Designs).
The NRC agreed in this meeting that TVA's design
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 I
SPECIAL PROGRAM j
REVISION NUMBER: 2 i
PAGE 96 0F 121 l
verification work provided reasonable assurance that there were no safety concerns which would preclude issuance of an operating license for WBN. The NRC also asserted that a 100% review of all affected design support calculations would provide complete assurance that the requirements of 79-02 were met. TVA subsequently agreed to the review which was to be completed prior to the first refueling I
i l
outage. This meant that WBN could have loaded fuel and j
operated prior to the review being completed.
l The audit of TVA's design procedures by the NRC five years after the issuance of 79-02 and TVA's negligence in I
establishing technical convounications with the NRC that were necessary in order to resolve TVA's position do not appear to have been performed in a timely manner. However, TVA's assumption that their response to 79-02 was adequate and their failure to incorporate Bulletin requirements into their procedures in 1979 can not be justified. Had i
TVA incorporated procedurally the bulletin requirements l
after issuance, questions concerning compilance and j
closure of this Bulletin for WBN and BFN may have been eliminated.
With respect to loading, the design of embedded plates did not address all the potential factors that could affect the integrity of the embedded plates. This has resulted in various CAQs being initiated to evaluate the potential for overloading embedded plates.
The visual approval EP-FCR program and preapproval program (enhancements suggested) utilized by WBN and SQN respectively, provide an economical and sound engineering method for approving the addition of minor loads.
1 Management utilized past trends of low rejection rates 1
for embedded plate FCRs to establish a program that would minimize construction delays with no impact on quality or i
performance capabilities.
~
b.
Employee Effectiveness Empicyees have not demonstrated the quality in their work that is necessary to ensure all procedural and drawing requirements l
I are implemented.
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TVA EMPLOYEE CONCEENS REPORT NUMBER: 10400 i
SPECIAL PROGRAM l
REVISION NUMBER: 2 PAGE 97 0F 121 l
l c.
Technical Adequacy l
The significance of the generic issues (with the exception of cable tray support baseplate flexibility) is that TVA had already identiflad and taken actions to ensure their programs complied with the NRC requirements. These actions were identified in accordance with the CAQ program.
l l
Technically, the original design of embedded plates (even though l
the original design did not meet the requirements of NRC IE l
Bulletin 79-02) are adequate with a 95-percent level of l
confidence. Sampling programs have not identified conditions that
(
would hinder the safe operation of TVA plants.
l 6.0 CAUSES The following are perceived causes for the seven issues in this subcategory.
6.1 Errors, omissions, or incorrect assumptions in calculations identified during 1984 but left uncorrected.
6.1.1 WBN l
Cause:
The deficiencies identified in analysis calculations as well j
as the identification of incorrect plate numbers referenced on the FCRs were attributed to employee oversights.
l l
Responsibility:
DNE and DNC to addrese employee effectiveness.
Generic: - (WBN, SQN. BLN, BFN)
Noncompliance with NRC IE Bulletin 79-02 and undocumented loads on embedded plates.
Cause:
1 The deficiencies documented on CAQs originated from DNE's failure to implement NRC's mandated requirements with respect to baseplate flexibility and minimum factors-of-safety in a timely manner.
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\\
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 98 0F 121 1
Responsibility:
DNE has initiated the appropriate clarifications to DS-C1.7.1 and conducted training sessions for designers.
)
Cause:
Inadequate procedural requirements with respect to multiple attachments added without a design review of embedded plate capacity.
Responsibility:
DNE provided construction specification WBN N3C-928, SQN N2C-937, and is in the process of issuing ~BLN N4C-935.
l l
l Cause:
l 1
Inadequate procedurallrequirements with respect to the effect l
of construction tolerances on baseplate loads and stresses.
Responsibility:
DNE has revised appropriate drawing notes applicable to construction tolerances, revised G-43, and DS-C1.7.1 and retrained designers in the application of construction baseplate tolerances for the design and evaluation of supports.
Cause:
Inadequate procedural requirements with respect to the qualification of varied typical supports.
Responsibility:
DNC procedures do not contain a requirement to notify DNE by a support variance sheet (SVS) of any additional attachments made to supports after DNE had approved a previous SVS for the support.
TY& EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 99 0F 120 DNE did not provide an adequate variance, program as related I
to conduit supports.
1 I
Cause:
I l
Inadequate procedural requirements with respect to I
attachments to building and miscellaneous steel (except l
embedded plates) without a FCR or SVS.
I l
Responsibility:
1 1
DNE did not implement criteria requiring an FCR which would I
document the exact location of engineered supports attached IR1 to cable tray suppo.rts, building steel or miscellaneous steel i
on the applicable drawing.
l I
Cause:
l I
Inadequate design with respect to effects of loads on I
adjacent embedded plates and effects of a concrete edge on I
the embedded plate capacity.
1 I
Responsibility:
l l
DNE to review embedded plate drawings and calculations and l
qualify embedded plates.
I 6.2 Anchor bolt (wedge bolt) allowable loads for unit 1 are greater than unit 2.
(See paragraph 1.2.2 for detailed description.)
6.2.1 Ge,neric WN Cause:
Normalized loads could result in a factor-of-safety less than 4.
Responsibility:
DNE reduced the allowables for unit 2 to ensure a minimum factor-of-safety of 4.
SON, BLN. BFN 6.2.1.1 No cause was assigned regarding the specific issue since investigations did not prove the concern generic to these sites.
l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400
[
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 100 0F 121 6.3 Visual approval for minor loads on embedded plates (see paragraph 1.2.3 for detailed description).
6.3.1 Generic MaH j
l Cause:
l Procedures do not emphasize the necersity for assuring the correct embedded plate number is contained on the FCR and associated sketch. Also, employees failed to demonstrate the quality in their work that is necessary to ensure
]
analysis is performed on the appropriate plate.
Responsibility:
J DNE and DNC to provide mechanism to employees that will emphasize accuracy on FCRs.
I Cause:
l 1
i Procedure does not provide a standard acceptance criteria or examples for visual approval program.
Responsibility:
DNE to revise CEB-21.46 to incorporate the above.
j l
E9E Investigations proved that EP-4.03 Appendix A was site-specific to WBN. Therefore, no cause was assigned.
6.4 Minimum spacIns criteria change (see paragraph 1.2.4 for detailed description).
6.4.1 Site-Specific-WBN No cause was assigned regarding the specific lesue since the changes were not made because of technical inadequacies.
6.5 Engineering disposition for exemptions of minimum spacing requirements (see paragraph 1.2.5 for detailed description)
In regards to the specific issue, procedures are in place to allow minimum space reduction. Because of the concern being evaluated as factual, a cause has been assigned.
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 101 0F 121 l
6.5.1 Site-Specific - WBN Cause:
Spacing requirements are given to DNC which provide a high confidence level for what can be installed without a design i
review of the embedded plate capacity. These are only guidelines and do not necessarily mean anything installed closer than specified would cause overloading.
Responsibility:
DNE controls spacing exemptions to avoid overloading of the embedded plate.
6.6 Hollow Sounding embedded plates (see paragraph 1.2.6 for detailed description) 6.6.1 Sito-Specific - WBN cause:
The dead or hollow sound indicates that the steel plate is not bonded to the concrete and may not be in full, solid contact with the underlying concrete. The loss of bond or the lack of solid contact could be caused by:
concrete placing void warpage of the embedded plate concrete shrinkage Responsibility):
Small gaps under embedded plates do not have a significant effect on the structural performance of the embedded plates; therefore, a responsibility was not assigned.
6.7 No docume'ntation to verify anchor load bearing capability when surface mounted plates are deleted (see paragraph 1.2.7 for detailed description).
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____-___.-.----_.-_____O
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400
)
SPECIAL PROGRAM REVISION NUMBER: 2
)
i PAGE 102 0F 121 6.7.1 Site-Specific-BLN Cause:
Hanger drawings do not reflect the type 49 plate configuration as part of the support drawing therefore, no inspection is required or performed for the outer nuts on the cast-in-place
- anchors, t
Responsibility:
DNC to assign unique numbers to the type 49 plates which will ensure that inspection of the shims and nuts are performed.
i Cause:
Design drawings and specifications do not address requirements for restraining nuts of embedded bolts from movement or loosening during concrete pours.
Responsibility:
DNE to evaluate and correct as required.
Cause:
Employees failed to install nuts as required by the l
1 drawing.
Responsibility:
Management to ensure employees are aware of job requirements.
l 7.0 CORRECTIVE ACTIONS 7.1 Corrective Actions 7.1.1 Errors, omissions, or incorrect assumptions in design calculations identified during 1984 but left uncorrected, and noncompliance with NRC-IE Bulletin 79-02 with respect to baseplate flexibility.
(addressed in Section 4.1) l l
I I
TVA EMPLOYEE CONCERNS LEPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: ::
PAGE 103 0F 121 WB_!
SCR WBNCEB8623R1 has been initiated by DNE with respect to:
I l
- errors, omissions, or incorrect assumptions in design calculations
- effects of loads on adjacent embedded plates j
- effects of a concrete edge on an embedded plate l
l
- baseplate flealbility for cable tray supports Corrective Actions include:
l l
- Initiation of a verification program for embedded plates used for anchorage of cable tray supports j
1
- Review of cable tray supports on surface mounted j
baseplates which use expansion anchors to determine if baseplate flexibility and
)
i construction tolerances were adequately considered in the design 1
1
- Require new or revised FCRs on embedded plates which reference the wrong plate number or wrong drawing revision level j
i
- Review documentation for identified embedded plates which do not have a required FCR I
- T'erform a complete embedded plate drawing review l
for:
a.
Adjacent embedded plate deficisacies. Based on the population size, determine if a sampling progran or complete review should be performed.
l 1
b.
Embedded plates t.djacent to a concrete edge.
l Perform a walkdown and evaluate the 40 worst cases.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAH REVISION NUMBER: 2 PAGE 104 0F 121
- Revise calculations which contain errors and determine if errors are likely to have occurred in other calculations.
If additional errors are likely, identify a condition adverse to quality, unless the deficiency is covered by an existing CAQ.
- Revise calculations that form the basis for the standard form used to screen the FP-FCRs that involved lightly loaded supports.
To prevent recurrence, N3C-928 will be revised to:
Cover spacing to adjacent plates and concrete a.
edges.
b.
Require a new or revised FCR on the embedded plate if the attachment of the support to the embedded plate was previously approved by an i
FCR and if any portion of an attached support is modified or relocated, Require a location description on all c.
embedded plate FCRs.
In addition, the following actions will also be taken:
CEB-21.46 will be changed to a project specific a.
procedure and will be revised to assure that embedded plates with erroneous plate identifiers are identified and corrected.
b.
Perform a review of the usage of the DNE embedded plate drawings which are revised as a result of embedded plate FCRs.
Retrain designers to revised procedural c.
requirements.
Corrective actions are currently in work to resolve this SCR.
(CATD 10400-WBN-2)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 105 0F 121 The line response to CATD 10400-WBN-2 was:
The four concerns (inaccurate calculations, effects of loads on adjacent embedded plates, effects of a concrete edge on an embedded plate, and cable tray support baseplate flexibility) are addressed in SCR WBNCEB8623R1. SCR WBNCEB8623R1 (completed through Part B) was issued on October 16, 1986.
The following corrective actions have been initiated to document attachments to embedded plates without design review or documentation:
- a.
NCR W-403-P R0 (initiated to respond to PIR WBN CEB8601 and PIR WBNCEB8602) documents attaching a new conduit to an already documented conduit support or the effects of insulating a conduit support. Procedures will be reviswd to require verification that the new addition l
has not altered the configuration of the support from 4
the typical drawings and to verify any existing l
variances. DNE will disposition the acceptability of past installations. Procedural revisions will provide adequate requirements for future installations and insulations.
(CATD 10400-WBN-3)
The line response to CATD 10400-WBN-3 was:
NCR W-403-P was written to address the situation when l
attaching a new conduit to an already documented conduit l
support or addition of free barrier insulation to a conduit support, there were no requirements in plant procedures to verify that new additions did not vary the configuration of the support or review for any existing variance on the I
support. QCI-3.09 R2, addendum 1, dated June 4, 1986, was written to require a work release to perform any rework or additions to any support already inspected and documented.
MAI-13. R3, dated August 5, 1986, was to be revised to have-l existing supports evaluated when new conduits are added to them. KAI-2 is being issued and will address the evaluation of existing supports for load requirements when fire barrier I
insulation is to be added. NCR-W-403-P has been referred to 1
DNE for the disposition of past installations. ' Reference I
I OSIL-R-1472 for MAI-2 issuance.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 106 0F 121
- b.
NCR 6735 RO documents the failure to issue a new support variance sheet when additional attachments are made to an existing instrumentation support. DNC will perform the following:
-issue new SVS's for deficient supports
-Revise QCP 3.11-1 to require SVS for modifications
-Review all multiple supports that have been varied, reinspect and issue SVSs as needed.
l 1
Procedural revisions will provide adequate requirements for future installations.
(CATD 10400-WBN-4)
The line response to CATD 10400-WBN-4 was:
CATD Number 10400-WBN-4 is addressed by NCR 6735RO. DNC has completed a 100-percent review of Instrumentation Support Variance Sheets and Embedded Plate Field Change Requests issued for unit 2 supports and identified two supports that had more attachments than approved by DNE. New Support' Variance Sheets have been issued for these two supports and will be sent tn DilE for approval. Also, a note was added to i
Section 7.5.1 in QCP 3.11-1, Revision 8 to clarify inspection requirements to prevent recurrence.
- c.
SCR 6498-S Revision 0 documents the corrective action initiated by DNC for pipe supports with respect to I
documentation. DNC will review documentation for all hangers attached to an embedded feature. Any hanger attached to an embedded plate that does not have an attachment "G" (reference 4.11) documented shall be reinspected and documented. QCP-1.14 has been revised to require documenting the inspection of attachments to embedded features to prevent future recurrence.
j (CATD 10400-WBN-5)
The line response to CATD 10400-WBN-5 was:
NCR 6498 and SCR 6498-S were initiated to formally identify this problem for unit 2.
NCR W-435-P was initiated to formally identify and resolve this problem on unit 1.
All required actions will be tracked by these NCRs. Action for unit 2 will be completed by fuel load. Actions for unit 1 l
are complete.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 107 0F 121
- d.
WCR 6564R0 DNC-IEU to review documentation for all instrumunt supports attached to an embedded feature that does not have an attachment "G" documented.
Reinspection and documentation will be performed as necessary. To prevent recurrence, QCP-3.11-1 will be revised to require documentation for future attachments.
(CATD 10400-WBN-6).
The Aina r"Pa"^ *^ CiTO 1^ ^^ C -; -==.
NCR ii t
his problem for unit lr.
W-4$ - was stud to formal entif f and hw4r ons
- 111 be reso lve this'arp en uni
.- A trac led by t
-... - w -voeted
'^
Aa*'^-
'- :: h 1 ;- --el m.
by f1La1.. lead -
- e.
SCR 6567-S RO documents the corrective action by DNE to review documentation for structural and miscellaneous
' steel attachments. Any civil feature attached to an embed that does rot have an attachment "G" shall be inspected and documented.
DNC revised QCP-1.14 and QCI-1.40-6 to add the inspection requirement.
l (CATD 10400-WBN-7) i The line response to CATD 10400-WBN-7 was:
NCR 6567 and SCR 6567-S were initiated to formally identify this problem for unit 2.
NCR W-435-P was initiated'to formally identify and resolve this problem on unit 1.
All required cetions will be completed by fuel load. Actions for unit I are complete.
l
- f.
NCR V-a35-P R0 documents all attachments to embedded features for unit 1 (instrumentation sense line suppnets, process pipe supports, and structural steel) l which have been installed without test documentation.
l The Modifications and Additions Unit (M&AU) will review l
unit I documentation. Attachments will be inspected and documented as required. Procedural revisions are
)
in place to prevent recurrence.
(CATD 10400-WBN-8).
l I
The 1, Lag,res.2onse to CATD 10400 _WBN-8 was:
s a
l e
e UATE 3
,8-88 l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 108 0F 121
- g.
NCR 3659 documents attachments to building and i
miscellaneous steel (except embedded plates) without l
consideration of the effects of cumulative loads. A field review of attachments to building and miscellaneous stoel, cable tray supports, and baseplates is being performed. DNC will provide DNE with marked structrual drawings showing attachment locations to potentially overstressed structures and 1
identification of pipe support members. DNE will be l
notified of additional attachments to these structures j
after DNC transmittal of the as-constructed drawings.
DNE will evaluate loeding, generate necessary changes l
and perform a final walkdown with DNC to ensure that no additional unidentified attachments have been added.
Drawing modifications were incorporated on ECN 3255 and DNC revised QCI-1.13 to incorporate this FCR requirement (CATD 10400-WBN-9).
The line response for CATD 10400 'JBN-9 was:
The corrective action specified in NCR 3659R1, addressed the l
problem. The corrective action was as follows:
(1) The Division of Nuclear Engineering (DNE) performed a field review to determine structural adequacy.
(2). DNE identified some areas requiring additional work on ECN 3255.
(3) The Division of Nuclear Construction (DNC) will complete required j
rework identified on ECN 3255. Procedural conteels (QCI-1.13) have been established in DNC which require DNE j
approval of attachments to building and miscellaneous steel.
I This will prevent recurrence.
- h.
SCR WBNCEB8650 documents a Modifications (unit 1) deficiency with the FCR requirement for attaching to steel after system transfer from construction. M&AU has reviewed their installations and corrected the one identified deficient support. DNE incorporated the FCR requirement in the drawing general notes according to ECN 6450 to prevent recurrence (CATD 10400-WBN-10).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 109 0F 121 6 OE
.1 to formally entify ag e this roblem. All required act ions are id mplete.{g,pepp{ @Q
$3 g co g,_. -.- _ _
No problems were identified concerning errors, omissions, or incorrect assumptions in design calculations being identified and not corrected.
I Significant NCR SQNCEB8404 El eddresses the potential that baseplate flexibility and construction tolerances may not have been adequately considered in the determination of loads in expansion anchors for pipe supports. The following corrective actions have been completed:
I a.
A sampling program was initiated and provided adequate j
results with respect to baseplate flexibility and I
factors-of-safety.
b.
SQN construction tolerances were compared to the sampling program performed for WBN. Based on the positive results for WBN and more conservatism in SQN design, SQN tolerances are adequate.
To prevent recurrence of similar problems the following actions have been completed:
1 a.
The May 1982 memorandum was revised to refer j
i designers to requirements of Civil Design 1
i Standard DS-C1.7.1.
]
b.
DS-C1.7.1 was revised to clarify limitations and appilcability of rigid plate analysis.
j i
c.
The 47A050 notes were revised to ensure that j
fabrication and installation tolerances as applied to baseplates do not result in unacceptable inersanes in baseplate stresses or anchor bolt loads.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM l
REVISION NUMBER: 2 PAGE 110 OF 121 d.
G-43 was revised to change the allowable tolerances for fabrication dimensions for baseplates.
I l
~
AmplificationfactorsforconstructiontolerancesforWBNwert-]
e.
investigated for applicability to SQN.
DS-C1.7.1 was revised I to provide a method for accounting for effects of construction tolerances on calculated anchor bolt loads and baseplate j
- stresses, j
This NCR is in the process of being closed.
(CATD C011301-SQN-07:
l SCR SQNCEB8502 addresses programmatic deficiencies with the desigt 1 and installation of seismically designed conduit supports as show )
on the 47A056 drawing series for typical supports. The correctivi!
action will consist of a random sampling program of 60 supports Thesesupportswillbeevaluatedti;]
that have approved variances.
determine their adeguacy. A preliminary evaluation has been performed and it has been concluded that an inaccurate configuration used in the approved variance would not prevent the conduit from performing its design function. The action required to prevent recurrence is pending further evaluation.
(CATD Numbet i C011301-SQN-06) l SCR SQNCEB8607 documents the consideration of the concrete edge o the embedded plate capacity. The following corrective actions will be initiated:
1 a.
A 100-percent review of all Type II embedded plates is l
being performed by the SQN Civil Design Analysis Group.
1 b.
An analysis of the " worst case" sample of 40 embeds installed adjacent to concrete edges will be performed before the restart of SQN. The evaluation of the results l
by DNE will determine if the Type II embedded plates will need to be upgraded to a higher factor-of-safety. No action required to prevent recurrence has been established at this time.
(CATD C011301-SQN-04)
SCR SQNCEB8622 R1, documents deficiencies which may affect i
l the qualification of embedded plates. The following i
corrective action has been initiated:
a.
An evaluation has been performed to identify the thirty worst case supports which will be contained in SQN Civil Calculation SCGIS52X10.
l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 111 0F 121 b.
A field survey (SMI-317-0-36) was performed.on the thirty supports to obtain "as-constructed" information regarding the identified deficiencies, c.
The supports will be evaluated for comoliance with the design basis and applicable criteria required for interim operation.
d.
After start-up, additions 1 cable tray supports will be analyzed to provide a 95 percent confidence level for l
existing designs.
e.
Any failures identified in the evaluation of the worst 1
case supports will require further evaluation.
To prevent recurrence the design criteria whi:h governs the 1
i design of cable tray supports has been revised by DIM-SQN-DC-V-1.3.4-2 and SQN-DC-V-1.3.4-3.
(CATD C011301-SQN-05) 1 PIR SQNCEB8658 documents that some platform calculations do not include qualification for field routed attachments.
These calculations do not include documentation to show that I
the latest revision of pipe supports for rigorously analyzed piping supports have been considered. Also, come field changes affecting platform configuration have not been incorporated into design calculations and drawings (CATD C011301-SQN-08).
The line response to CATD C011301-SQN-08 was:
IR2 Performance of the action (s) required by PIR-SQNCEB-8658 lR2 are sufficient to address this item.
l CAQR-SQF870101, revision 0, documents the qualification and
(
{
use of Rawl self-drilling anchors at SQN.
IR2 (CATD C011301-SQN-09).
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The line response to CATD C011301-SQN-09 was:
IR2 j
l Assignment and performance of corrective action and l
j subsequent closure of CAQR-SQF870101 will address this IR2 l
deficiency. Note: This CATD issued for tracking purposes I
only. This is not.a restart item.
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REPORT NUMBER: 10400 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 112 0F 121 l
BLN No problems were identified concerning errors, omissions, or incorrect assumptions in design calculations that were
)
identified during 1984 and not corrected.
I PIR BLNCEB8518 was initiated to address a potential violation j
After evaluation, j
of a free edge requirement on drawings.
the PIR was upgraded to a significant condition report SCR The following corrective actions arc in process:
BLNCEB8518.
h Issuance of Construction Specification N4C-935, " Locating l
a.
Attachments on Embedded Plates and Strip Inserts."
l Removal of the free area requirements from the conduit b.
support drawings after the issuance of N4C-935.
J Utilize the 48 supports used fn the resolution of NCR GENCEB8208 and an additional 12 samples to evaluate the c.
Zero failures out effects of the fren area requirement.
of the sample of 60 will provide a 95 percent confidence level that less than 5 percent of the population is defect!ve.
The issuance of N4C-935 will preclude deficiencies in future installations.
(CATD 10400-BLN-1)
The line management response to CATD 10400-BLN-01 was:
The final corrective action for this concern will be handled per SCR BLNCEB8518 in accordance with NEP 9.1.
This item adequately addresses the concern This SCR has been entered into TROI for noted.
tracking to completion.
PIR BLNCEB8610 was initiated to investigate the additional attachments made to supports after DNE has approved the actual loading. The following will be performed:
DNE will review ra""it and instrumentation support
.er,inent documentation to determine if a.
calculations ant v-J by using loading that was less supports were ap, than the maximum at.owable design loads.
TYA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 113 0F 121 b.
Where it is determined that less than the maximum allowable design loading was used to qualify the support and drawings do not reflect these restrictions, revise drawings such that no additional loading can be applied without prior approval of DNE.
Pending the results of the evaluation and if it is determined the PIR needs upgrading to significant, kn action required to prevent recurrence will be addressed at that time.
(CATD 10400-BLN-2)
The line response to CATD 10400-BLN-2 was:
The final corrective action for this concern will be handled per PIR BLNCEB8610 in accordance with NEP 9.1.
This item adequately addresses the concern noted. This PIR has been entered into TROI for tracking to completion.
PIR BLNCEB8612 documents the need to evaluate the capacity of 1
embedded plates installed with an edge adjacent to a concrete edge. The following corrective actions will be performed:
Embedded plate drawing's and calculations for plates a.
located adjacent to a concrete edge will be Svaluated, b.
Verification that the edge distance capacity ~ reduction was considered in the structural design of attachments where required, c.
Calculations will be prepared to verify structural adequacy where required and modifications to structural details will be made if the design requirements cannot be met.
If the evaluation from the corrective actions identify a significant condition adverse to quality, an action required to prevent recurrence will be addressed at that time.
(CATD 10400-BLN>3)
The line response to CATD 10400-BLN-3 was:
The final corrective action for this concern will be handled per PIRBLNCEB8612 in accordance with j
NEP 9.1.
This item adequately addresses the concern noted. This PIR has been entered into TROI for i
tracking to closure.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM j
REVISION NUMBER:
2 PAGE 114 0F 121 PIR BLNCEB8616 documents for cable tray supports the effects of baseplate flexibility on the welded stud capacity which may not have the factor-of-safety required by DS-C1.7.1.
The information complied from the samples through the disposition of PIR BLNCEB8518 the FCRs resulting from Construction Specification N4C-935, and utilization of the previous sample results provided through the disposition of GEN CEB8208 will be utilized to verify the existing designs.
O An action required to prevent recurrence will be established I
if conditions adverse to quality are identified in the review of corrective actions.
(CATD 10400-BLN-4)
The line response to CATD 10400-BLN-4 was:
The final corrective action for this concern will be handled per PIR BLNCEB8616 in accordance with NEP 9.1.
This item adequately addresses the concern noted. This PIR has been entered into TROI for tracking to completion.
g[N l
No problems were identified concerning errors, omissions, or incorrect assumptions in design calculations that were identified and not corrected.
NCR GENQAB8203 documents a potential for inadequate minimum spacing in that expansion anchors can be installed which do not meet the minimum spacing requirements when combined action of multiple attachments are considered. BFN has not evaluated the occurrences where expansion anchors may violate G-32 requirements.
(CATD Number 10400-BFN-1)
The line response to CATD 10400-BFN-1 was:
NCR GENQAB8203, revision 2 requires a sample program to be performed on supports with G-32 anchor spacing violations. The sample shall not include anchors installed before February 1981 (issue date of G-32, R6). The anchors will be evaluated to determine factors-of-safety with respect to D.S-C.1.7.1 requirements. This exercise is to be completed before unit 2 restart.
TVA EKPLOYER CONCERNS REPORT NUMBER:
10400 l
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 115 0F 121 SCR BFNCEB8520 documents the qualification of some baseplates and concrete anchors in the typical support details of Design Criteria BFN-50-712 which cannot be verified. Also, according to NCR BFNMEB8406 R1, some supports for field routed schedule 160 piping could be undersized based on their selection using the tables for schedule 40 and 80 piping in BFN-50-712.
(CATD Number 10400-BFN-2, 10400-BFN-3).
The following corrective actions were recommended in the applicable engineering report:
a.
Perform a walkdown review of a representative sample of existing 2-inch and smaller seismic class 1 field-routed pipe support installations. From this walkdown, identify any instances of configurations which cannot be defended on the basis of actual earthquake experience data.
b.
As required from the walkdown review, perform an engineering evaluation of the support installations and, if required, take corrective action.
c.
Prepare DNE output documents as needed for new field-routed pipe support installations.
An action required to prevet;t recurrence has not been established at this time.
The line response to CATD 10400-BFN-02 and l
CATD 10400-BFN-03 was:
A Small Bore Qualification Program has been initiated to requalify the small bore piping and supports required to remain functional following a DBE. Prior to unit 2 startup, the small bore piping in unit 2 and those considered common to unit 2 will be qualified. The small bore piping and supports in units 1 and 3 that are not considered common to unit 2 will be qualified prior to restart of the respective unit. This activity will resolve SCR BFNCEB8520.
SCR BFNCEB8614 documents that the ampilfication of calculated anchor bolt loads and baseplate stress increases when construction tolerances are used but not accounted for in the original design.
The corrective action will be determined by Nuclear Power.
(CATD Number'10400-BFN-4) i 1
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 116 0F 121 In order to prevent recurrence, the following actions will be taken:
a.
The 47B435 notes will be reviewed to ensure that tolerances will be applied as the designer intended.
b.
DS-C1.7.1 will need revising to specify methods for ampitfication of calculated anchor bolt loads and base plate stress to account for field tolerances.
c.
Conduct training on the methods of tolerance consideration in DS-C1.7.1.
l The line management response to CATD 10400-BFN-04 was:
Performance of the disposition and subsequent closure of SCR BFNCEB8614 RO would address this issue.
SCR BFNCEB8617 documents the effects of a concrete edge on the embedded plate capacity. Corrective action will be determined by Nuclear Power.
(CATD 10400-BFN-5)
In order to prevent recurrence, DS-C1.7.1 and G-32 have boon revised to address the design and installation of embedments l
with specific requirements for edge distances.
The line response to CATD 10400-BFN-05 was:
The on-going walkdown program will verify that the proximity k
of embedded plates to concrete free edges has been considered i
in the inspection and evaluation of supports. Present programs include the 79-14 Programs, Conduit Requalification Program, Torus-Attached Piping Support Program, Control Rod Drive Piping Support Program and Control Rod Drive Hydraulic q
Insertion and Withdrawal Piping Program. Future walkdown programs, when it is applicable, will include requirements that free edges on embedded plates be considered during inspection and evaluation. This will be accomplished by the j
issuance of a general walkdown procedure as a Project Instruction. This condition does exist at BFN and has been documented by SCR BFNCEB8617 R0.
The Engineering Category evaluation of the baseplate flexibility issue at BFN revealed a specific support (EllR R159, unit 3) where flexible plate analysis was not performed as required by DS-C1.7.1.
(CATD 10400-BFN-06)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 4
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 117 0F 121 IR2 The line response to CATD 10400-BFN-06 was:
Since 1981. BFEP has had an internal requirement to consider l
plate flexibility in piping support design. This memorandum l
was incorporated in the General Reference Calculation in July l
1984 (BWP 840713 103). Since various calculation reviews by l
TVA as well as a review by Bechtel did not identify other 1
supports with this deficiency, it is TVA's position that the l
is an l
base plate flexibility concern on RHR Support R159 (U3) isolated case caused by designer error. Since no generic l
implications exist BFN will perform appropriate flexible l
piste analysis on the RHR Support 1159. No additional l
l calculation review is required. Piping supports installed l
in 1980 and before will be. analyzed under one of the programs l
described in the Nuclear Performance Plan Volume 3, Section l
III. The recurrence control measures described below will IR2 prevent repetition of this deficiency when calculations are I
generated or revised for these programs. To ensure that the i
personnel involved in support design at BFN are fully aware.
I of flexible plate design requirements a memorandum (with I
training coster) will be distributed to all BFEP piping i
support designers by July 31, 1987, instructing them of the l
requirements of using flexible plate analysis. Requirements I
for flexible plate design are included in the TVA Civil Design l
Standard DS-C1.7.1, titled " General Anchorage to Concrete",
l and will be incorporated in the Pipe Support Design Handbook, I
currently under review before initial issue. When completed, I
these actions are expected to prevent future occurrence of l
this deficiency. NOTE: CAQR-BFP870514 has been initiated to I
document and correct the identified discrepancy on RHR l
l support R159.
7.1.2 Concrete anchor bolt (wedge bolt) allowables are greater for unit 1 than for unit 2 (addressed in section 4.2)
No corrective actions are required for the specific issue.
7.1.3 Visual approval for minor loads on embedded plates (addressed j
in section 4.3) l 1
EBE The following enhancements will be made with respect to the visual program:
. Engineering and construction prot 'ures will be revised to a.
emphasize the necessity of assuri the correct plate l
number is on the FCR.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM i
REVISION NUMBER: 2 f
PAGE 118 0F 121 b.
The engineering procedure will be revised to list some I
standard acceptance criteria.
Listing of examples will I
be,made, however, the visual examination will allow other items to be accepted if justification is given on the FCR form.
j CATD 10400-WBN-2 addresses the corrective actions to be taken.
S_QN.
I No guidelines exist for attachments to embeds that are treated as a minor load.
(CATD C011301-SQN-2).
The line response to CATD C011301-SQN-2 was:
DHE-CEB will develop criteria to provide procedural centrol of the current preliminary approval program for attachments to embeds. This procedure will also:
i
(
Provide genera). guidelines for identifying minor load I
attachments;to embeds.
Require miner loads to be included in the final calculation process.
1 Identify the methodology used to determine the final loadinc for each embed evaluated.
Also, revising N20-937 to delete Section 2.5.2 (Visual Approval of FCRs) will be withdrawn as one of the ECTG recommendations.
Progranvaatic inadequacies were identified concerning the lack of consistency in the interpretation and application of design criteria at the site and engineering level. The current method for evaluation of attachments to embedded plates needs to be expanded and controlled procedurally.
(CATD C011301-SQN-3).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 l
SPECIAL PROGRAM I
REVISION NUMBER: 2 l
l PAGE 119 0F 121 1
The line response to CATD C011301-SQN w :
1.
DNE-CEB does not see the ne o collect sta other than that required to approve e
tachment un er evaluation.
By collecting data in e
- e area f he subject attachment, enough a
dt ider the effect of the subject a e
d plate including the effects o u
tt.
G-32 violations, and m
o:
plate.
location o p
t w e utilizes data in the proximity The curre, g of the 4tt effe e
establishes a baseline concept i
beepes,eAhagtte's ious qualifications are tracked
(
pfaghpmbe as the qualifications are complete.
l The46feire, is required.
s4-l 2.'h11attac ents receiving preliminary approval will it u
y be included in the calculation process.
i 7.1.4 Minimum Spacing Criteria Change (addressed in section 4.4)
No corrective actions are required for the specific issue since the changes were not made for techaical reasons, inadequate requirements, or load bearing capacity for embeds.
7.1.5 Engineering disposition for exemptions of minimum spacing requirements (addressed in section '4.5)
The specific concern was deemed factual. However, no corrective actions are required because of the fact that j
minimum spacing requirements are procedurally controlled to
{
avoid overloading of the embedded plate.
7.1.6 Hollow sounding embedded plates (addressed in section 4.6)
The specific issue was deemed factual. However, as noted in section 4.6., small gaps under embedded plates do not have n significant effect on the structural performance of the embedded plate. Management has failed to recognize the l
employees' need to understand the significance of the hollow sound.
(CATD 10400-WBN-1) f
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 120 0F 121 18aa ro e nn n u to CATD 10400-WBN-1 was:
Thep M
a ie u
1 00
'g,oens@feT fi6 dings o g
' soun g err d@'d p These managers will be in.
M u
11 t ployeel get thiL 'darmation in the Employee Anyvivumw T. d kgl 7.1.7 Embedded plates with 1 or 2 welded studs and cast-in-place anchors supporting loads for which no documentation exists to verify their ability to support the loads (addressed in section 7.7)
NCR 5007 was, initiated to document the deficiency of improperly installed and/or missing anchor bolt nuts. The following corrective actions will be performed:
(CATD 10400-BLN-5)
BLN-CEU will assign unique identifiers to type 49 plates a.
to include in the Civil Documentation Program. These identifiers will ensure all shims and nuts installed inspected.
b.
DNE will evaluate the list of type 49 plates submitted by DNC for possible overload conditions.
The line response to CATD 10400-BLN-5 was:
j The final corrective action plan for this concern has not yet been determined due to manpower limitations on Bellefonto The final corrective action will be handled per NCR BLN 5007 in accordance with NEP 9.1.
This item adequately addresses the concern noted. NCR BLN 5007 has been entered into TROI for tracking to completion.
NCR 5016 documents lact of design drawings and specifications to address restraining nuts of embedded bolts from movement or loosening during concrete pours. The following corrective
)
actions will be performed:
i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10400 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 121 0F 121 l
l a.
DNE to evaluate "uso-as-is" on past installations. This is based on BLN's standard construction practices of setting anchor bolts and anchor bolt assemblies to provide support with a false work template to prevent movement or loosening during concrete pours. Whenever practical, the nuts on the exposed end on the anchor bolts are tightened against the concrete forms to lock the bolts and nuts in position.
If it is not practical to use the exposed nuts to lock the anchors in position, the embedded nuts are caged or clipped within the false work.
b.
For future installations, it is recommended that a drawing rote similar to the following be added to the applicabte documents:
"The embedded nuts of anchor bolts are to be restrained from turning or loosening during concrete pours by lock-nut, wire, stating of threads, welding if allowed, or false work template cage or clips unless otherwise specified by design drawings."
(CATD 10400-BLN-6)
The line response to CATD 10400-BLN-6 was:
The final corrective action plan for this concern has not yet been determined due to manpower limitations on Bellefonte.
The final corrective action will be handled per NCR BLN 5016 in accordance with NEP 9.1.
This item adequately addresses the concern noted. NCR 5016 has been entered into TROI for tracting of resolution.
8.0 ATTACHMENTS 8.1 Attachment A - List of Concerns Indicating Safety Relationship and Generic Applicability 8.2 Attachment B - List of Evaluators 8.3 Attachment C - List of Concerns by Issue
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.e Attscheent B List of Evaluators Watts Bar Nuclear Plant Lead Evaluator: Julie Cromer Evaluator: Gary L. Portwood Alternate: Martin Bailey Sequoyah Nuclear Plant Gary L. Portwood Bellefonte Nuclear Plant James A. Chesney Gary L. Portwood l
l l
Browns Ferry Nuclear Plant l
l James A. Chesney Donald R. Owen Gary L. Portwood l
l l
~1 l
l l
1 l
\\
- 4 Page 1 of 2 Attachment C List-of Concerns by Issue CONCERNS ISSUES Design of Plates:
(a) Incorrect calculations IN-85-031-001 (b) Noncompliance with 79-02 IN-85-103-001 OE-QMS-8 (c) Undocumented loads on WBM-86-009-001 embedded plates HI-85-077-N18 IN-85-110-001 l
Bolt Load Allowables Greater IN-85-109-X04 for Unit 1 than Unit 2 Visually approved FCRs IN-85-033-001 Changes in procedural IN-85-595-002 Requirements Minimum Spacing Requirements IN-85-672-005 I
Hollow Sounding Embedded Plates HI-85-071-002 IN-85-410-003 IN-85-439-002
)
IN-85-678-001 IN-85-693-006 IN-85-693-007 IN-85-305-001 Load Capability for Anchors XX-85-097-001 l
l l
l I
1 1
1 l
I i
- e Page 2 of 2 Attachment C Subcategory 10400 Subcategory 11tle: Embedments NSRS or QTC Report Number Line Response Employee Concern Number (If Issued)
(Organization-If Issued)
- HI-85-071-002 HI-85-077-N18 IN-85-031-001
- IN-85-033-001 I-85-265-WBN IN-85-103-001 I-85-111-WBN IN-85-109-X04
- IN-85-110-001 IN-85-410-003 I-85-692-WBN IN-85-439-002 I-85-665-WBN IN-85-595-002 IN-85-672-005 IN-85-678-001 IN-85-693-006 IN-85-693-007 IN-86-305-001 I-85-666 WBN
- OE-QMS-8 WBM-86-009-001
- XX-85-097-001 Technical issue concerning hollow sounding embedded plates is addressed in this subcategory. Nontechnical aspects are addressed in subcategory report IH-00000-Intimidation and Harrassment.
WBN concern evaluated for generic implications to SQN only.
Lack of proper evaluation and documentation (design calculations) are addressed in this subcategory. Destruction of Bergen-Paterson and EDS Nuclear calculations by TVA is addressed in subcategory EN 20500-Control of Design Calculations and EN22100-Pipe Support Designs.
Effects of baseplate flexibility on anchor loads is addressed in.this subcategory report. Detail methods for welds is addressed in subcategory report EN22200-Pipe Support Weld Design.
- BLN initiated concern. Generic implications for other plants was not appilcable.
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