ML20235L958
| ML20235L958 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/09/1987 |
| From: | Brown W, Russell Gibbs, Portwood G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20235L948 | List: |
| References | |
| CO11305-SQN, CO11305-SQN-R08, CO11305-SQN-R8, NUDOCS 8707170005 | |
| Download: ML20235L958 (31) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REPORT TYPE: Seguoyah Nuclear Plant Element
-REVISION NUMBER:
8 (Final Report)
TITLE: Anchors Cut Off As Related To Construction PAGE 1 0F 16 1
i REASON FOR REVISION:
Revision 1 To incorporate applicable SRP comments and TAS comments.
Revision 2 i
Clarification of Section IV.E.1.
Revision 3 To update listing of concerns Revision 4 To incorporate line mana6ement response and include-additional evaluation To incorporate line_ management response to C/A and Revision 5 l
finalize report To add corrective actions for CATDs and finalize report.
Revision 6 To incorporate NRC comments and refinalize report.
Revision 7 To incorporate additional NRC comments, delete one Revision 8 concern, and refinalize report.
PREPARATION PREPARED BY:
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MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are'in files.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
8 PAGE 2 0F 16 I.
Introduction This evaluation will examine the scope, parameters and overall adequacy of SQN's concrete anchor program with respect to NRC IE Bulletin 79-02.
The 27 concerns identified in this element will be specifically addressed to insure that all issues related to the subject concerns have been adequately resolved / answered by the results of the 79-02 and subsequent program (s).
The issue which addresses documentation for areas where rebar could be cut (section IV.E.4 of this report) has been evaluated by the Engineering Category, SQN Element Report Numbers 215.2(B) and 215.6(B).
II.
Summary of Perceived Problems A.
Shell-Self-Drilling (SSD) type anchors were cutoff when rebar was encountered; nuts were welded to the back of baseplates.
B.
SSD type anchors have been improperly installed and are subject to pulling out of the wall.
C.
Abandoned SSD holes with the shells installed were not filled with grout.
D.
Baseplate holes have been made oversize and ancuors installed outside of perpendicularity criterion.
III.
Evaluation Mett34 ology A.
Reviewed the Sequoyah Nuclear Plant (SQN) Generic Concerns Task Force (GCTF) Report on Anchor Installation and Inspection for content with respect to the subject concerns, adequacy and findings.
B.
Reviewed the Watts Bar Nuclear Plant (WBN) Employee Concerns Task Group (ECTG) Element Report (Anchors Cut Off - C011305) for content and generic applicability to SQN.
C.
Reviewed Nuclear Regulatory Commission (NRC) IE Bulletin 79-02 and IE Bulletin 79-02, R1, to detertaine what actions were required by SQN to verify adequacy of their concrete anchor program.
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
8 PAGE 3 0F 16 1
-l III.
Evaluation Methodology (Continued)
I D.
Reviewed SQN (units 1 and 2) final response (s) and inspection j
report (s) to NRC IE Bulletin 79-02 to determine what. methodology H
was used, to include sampling program (s) adequacy and what l
corrective actions were required (to include applicable nonconformance reports (NCRs), significant' condition reports (SCRs), problem identification reports (PIRs) and other existing documentation) to insure compliance with the aforementioned bulletin.
E.
Reviewed Nuclear Safety Review Staff (NSRS) investigation report I-86-120-SQN to determine methodology used during the.
investigation, the findings, recommendations.and overall adequacy with respect to the issues addressed by the concerns.
Reviewed applicable Field Change Requests (FCRs). Engineering Change Notices (ECNs) and other relevant documentation as required to. determine whether recommendations in the NSRS report were implemented.
Reviewed applicable SQN/TVA procedures and construction specifications as required to insure compliance with the 79-02 Bulletin.
F.
Interviewed knowledgeable personnel in responsible units as required to obtain information relevant to the subject of this element report.
G.
Performed field evaluation to determine if concerns expressed with respect to anchor removal in specified locations were valid.
IV.
Summary of Findings A.
The first methodology employed in the SQN-GCTF report was to compare TVA General Construction Specification G-32 pull test data-with the results of the 79-02 sampling program and with the results of an extensive reinspection program conducted in. response to the Quality Technology Company (QTC) investigation of a specific employee concern (XX-85-010-001).
This comparison revealed acceptance rates of greater then.95 percent for each inspection / reinspection program.
The fact that these 3 comparisons l
reflect comparable results (the results of the.QTC reinspection program are initial.results only) with very high acceptance percentages is especially significant when the timeframes of each program and the anchor installations are considered.. The G-32 pull test data reflected tests performed from day 1 through approximately mid-1980. The 79-02 sampling program included anchors that had been installed from day 1 through early 1981. The reinspection program performed as a result of the aforementioned QTC investigation started in 1985 and is still in progress.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
8 PAGE 4 0F 16 l
IV.
Summary of Findings (Continued)
The GCTF report also addressed the reinspection performed as a result of concern IN-85-037-001, but this concern resulted in approximately 426 reinspection at WBN, not at SQN. The report addressed the issue of sampling programs instead of individual testing and referenced the NSRS investigation (I-85-439-WBN)-
performed which determined this to be an acceptable practice..The GCTF report also addressed two open issues that were not researched
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by-the SQN-GCTF:
base plate flexibility and overtorquing. The evaluation' performed on issues generic to SQN by the WBN-ECTG addressed the aforementioned sampling program issue and the i
overtorquing issue-in the element report titled " Testing of l
Anchors" (C011306) and the base plate flexibility issue in the element report titled, " Design of Plates" (C011301).
B.
The WBN-ECTG Element Report for Anchors Cut Off (C011305) employed methodology that addressed the WBN 79-02 program as a whole, instead of addressing specific issues raised by each concern. The conclusion of the report states, " concerns identified for this element are generally factual and examples of the referenced deficiencies have all been previously identified per NCRs."
The report referenced specific Division of Nuclear Engineering (DNE) comments and reports which verify the adequacy of the-79-02 and General Construction Specification G-32 sampling programs. The report concluded that there was no generic applicability because 79-02 had been addressed by each nuclear plant.
C.
NRC IE Bulletin 79-02, 79-02, R1, and 19-02, R2 required inspection
. l R8 and verification of the following con'iitions with respect to anchor l
bolts in Seismic Category I systems-1.
For SSD anchors, insure that the shell is not contacting the back of the baseplate before the pull testing.
2.
Specified size and type of anchor is correctly installed.
3.
Preload (pull test / torque test values).is equal to or greater
.i than bolt design load.
A sampling program was required when sufficient documentation did not exist to verify the three areas described above.
One recommended sampling technique was to randomly select / inspect one anchor bolt in each base plate - if this bolt failed, inspect all other bolts on that base plate.
The final comment was that, "the test program should assure that each Seismic Category I system will perform its intended function." Revision 1 of the 79-02 Bulletin l
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
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.i PAGE 5 0F 16 IV.
Summary of Findings (Continued) addressed additional inspection parameters that included verification of leveling nut installation during testing, anchor l
embedment depths, thread engagement, plate hole size, bolt spacing,-
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plate and concrete edge distances and full shell expansion (cone-l depth). An additional requirement was that each site maintain sampling documentation of anchor bolts for NRC inspection. Also, an j
alternate sampling method was described which addressed statistical sampling that would provide a 95-percent confidence level that less i
than five-percent defective anchors were installed in any one Seismic Category I system. This sampling program was to be done on j
a system by system basis.
(Note: The requirements listed.here address inspection type parameters only - the design / analysis requirements are not considered in this report. These I
design / analysis requirements are addressed in SQN Element Report IR8 C011301-SQN and Construction' Subcategory Report 10400).
I D.
The SQN unit 1 and 2 79-02 Anchor Inspection Program Procedure, Evaluation Criteria and Work Plan, Program for Verifying Correct Installation of Self-Drilling Anchors and the applicable Data Sheets for recording of required information were reviewed, With deviations l
approved and accepted by the NRC, SQN fully implemented the l
requirements of NRC OIE Bulletin 79-02, as stated in the SQN Safety IR8 Evaluation Report, Supplement 2 Section 3.9.2.
This was. determined.
I from a review of the mechanisms / processes used to implement the requirements of 79-02 as described.above.
l1 The results of the SQN Anchor Inspection Progrem for 79-02 are found in the final response to TVA Nuclear Regulation and Safety Manager for transmittal to the NRC (NEB 810324 276) and in the Final Inspection Report to the NRC (A27 810403 011).
The summary of the conclusion in each report was that SQN had complied fully with the 79-02 requirements because:
1.
The failure rates compiled by the 79-02 inspection data were comparable to those in SQNs G-32 pull test / inspection program I
which reflected the adequacy of the existing G-32 inspection program.
2.
The NRC had previously reviewed the 79-02 inspection results as well as the G-32 data and determined that SQN was in compliance j
with 79-02 requirements.
l 3.
Failure rates for the 79-02 inspection program were less than
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1 percent - failure rates for the G-32 program were also less than 1 percent.
(These failure rates included evaluations performed at the design level.)
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.IVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
8 PAGE 6 0F 16 IV.
Summary of Findings (Continued)
In addition, the SQN memorandum from H. L. Abercrombie to K. W. Whitt of April 24, 1986, concerning the NSRS Investigation Report XX-85-010-001 contains reference to a telephone conversation from C. R. Brimer, SQN Site Services Manager to J. Burke,-NRC Region II, which verified that SQN compliance with 79-02 was not a NRC issue.
However, further evaluation has identified a specific deficiency in i
the qualification and use of Rawl self-drilling anchors at SQN. -The i
specific details of this subject as well as the CATD initiated lR8 subsequent to this finding are addressed in the Construction l
Category, SQN Element Report C011301-SQN, Design of Plates.
l E.
A detailed review was performed of.NSRS Investigation Report I-86-120-SQN which addressed seven concerns specific to SQN (SQP-5-005-001 thru SQP-5-005-007).
Each issue is applicable to NRC IE Bulletin 79-02 and/or TVA General Construction Specification.
G-32.
1.
Modified Support Plates - Work Request (WR) 114789 was initiated to sample supports in the affected plant area for torched or beveled holes in baseplates. In addition, this sample was a mechanism to reveal anchors it.italled outside of the G-32 requirements with respect to anchor perpendicularity.
This condition was described in concern SQP-05-005-004. The results of the sample program revealed no evidence of the alleged condition (s) and the concern was determined to be~not substantiated.
(To further verify anchor acceptance to the G-32 perpendicularity requirement, SMI-0-317-21 which was written to determine anchor bolt length as described in section IV.E.8 of this evaluation report is referenced.
This SMI randomly selected 111 baseplates for inspection and revealed 6 plates had discrepancies with respect to G-32 anchor inspection requirements.
None of the identified deficiencies were due to anchor perpendicularity.) However, the NSRS sample did identify two bolts that were damaged because of anchor / plate misalignment (A0318R004 and A0508R005).
These deficiencies are being tracked by SQN compliance as an open item and are being evaluated according to-SQN-FCR-4651 and ECN L6744.
2.
Abandoned Anchor Holes - during the sample program of WR 114789 several abandoned anchor holes.were found. The NSRS report concluded that the concern was factual but no violations of current G-32 criteria were noted. This evaluation performed a review of G-32 to determine the requirements for abandoned anchor holes and found no criteria which required abandoned
1:
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM i
REVISION NUMBER:
8
'I PAGE 7 0F 16 1
IV.
Summary of Findings (Continued) holes to be dry packed or grouted. The present criteria state, "the minimum clear distance between the hole for the working L
anchor (anchor in use) and the hole for an abandoned anchor
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shall.be equal to the diameter of the larger of the 2 holes.
g the distance may be reduced for SSDs, wedge bolts and grouted anchors if the abandoned anchor is removed ano the. hole is grouted or dry packed." To.further verify the NSRS findings on i
this issue a field evaluation was performed in the Motor Operated Valve Board Rooms la and IB.
This evaluation i
revealed the majority of the abandoned anchor holes had been grouted.
Those abandoned anchor holes that were-not grouted did not violate current G-32 criteria with respect to spacing between working anchors and abandoned' anchors. Therefore, this evaluation agrees with the findings of the NSRS investigation report, to wit: no violations of G-32 criteria occurred and no conditions adverse to quality (CAQ) were identified.
l 3.
Shortened Anchor Shells - cone expander.(plug) depths were checked as a part of the WR 114789 sample program and sixteen anchors were found to have plug depths outside current G criteria; another three anchors had questionable plug depths.
It was noted in the NSRS report that inspection of plug depth was not a requirement during the concerned individual's (CI)-
timeframe. The recommendation was made that the Division of Nuclear Engineering (DNE) evaluate the long/short plug depths.
The DNE response (B45 860507 008) stated that initial-indications showed some anchors may have a small reduction in the factor of safety.
However, the factors of safety will still be substantially above the values required for operation.
DNE coordinated these facts with the SQN Compliance Staff and agreement was reached that this issue did not require resolution before restart. The logic for this was that no discrepancies-had been found by the NSRS sample which had not been addressed previously by site NCRs or NRC IE Bulletin-79-02.
DNE also took exception to the NSRS sample in that
' current G-32 criterion was used to evaluate installations made in 1976.
This statement was supported further in a memorandum
.(C23 860618 006) from DNE'to the SQN - Site Director.
It was noted that the G-32 criterion had been enhanced over-the years and that in 1981 G-32 had been revised to incorporate the requirements of 79-02.
The final comments were "although each of these instances require review and, in some cases, an.
engineering evaluation, we see no programmatic brecidown or generic implication." This evaluation agrees with that comment.
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4 TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
8 PAGE 8 0F'16 IV.
Summary of Findings (Continued)
In addition, DNE is continuing to evaluate the results of the NSRS sample as referenced in the aforementioned DNE memorandum to determine additional = action (s) that may be required to I
ensure compliance with current' requirements of a safety factor lR8 of 5.
It was also stated-in the DNE response that the. anchors I
not meeting the plug depth requirements would be proof tested.
This action is being tracked as an open item in the SQN Commitment Action Tracking System (CATS).
l 4
Damaged or Cut Reinforcing Steel (Rebar) - the'NSRS sample program of WR 114789 included the use of a ground fault j
indicator (GFI) device to determine if rebar was contacting the j
SSD anchor shell. Three anchors were found to be contacting rebar, one of which appeared to be in an area not approved for cutting by OE.
The NSRS recommendation (I-86-120-SQN-4) was to recreate rebar sketch sheets and appropriately document, evaluate and correct the potentially cut rebar.= The SQN response to this recommendation (memorandum from H. L.
Abercrombie to R. P. Denise dated May 30,-1986 on the NSRS Report I-86-120-SQN) noted that SQN Mechanical Modifications Section had also inspected the area to determine if any rebar had, in fact, been cut. The results indicated that no rebar had been cut or damaged and recreating the rebar sketches was not justified based on these results. The reinspection was verified with the SQN Mechanical Modifications responsible
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engineer who indicated that his reinspection of the areas 1
1 identified had been performed using a Geophysical Survey-Systems instrument which was more accurate than the GFI unit.
I The Subsurface Interface Radar System he used had provided results wnich-indicated that no rebar had been cut or damaged and the unit was equipped to provide a printout of the inspection results. This evaluation agrees that the results of the rebar inspection performed by SQN Modifications was considerably more accurate than the NSRS inspection which used a GFI unit.
However, this evaluation does not agree with the l
SQN response that recreating the rebar sketches is not justified. The fact that SQN Modifications verified no rebar was cut or damaged does not justify the inability of the site to provide the color-coded sketches which established the areas where rebar cutting was allowed without written approval by the Office of Engineering (OE).
These sketches (Office of Civil Engineering sketches 12-11-8-76-0 thru -16), as'a minimum, provided documentation for the areas, if not each specific i
instance, where rebar could be cut without written approval.
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM REVISION NUMBER:
8 PAGE 9 OF 16 IV.
Summary of Findings (Continued)
The NSRS investigation was able to retrieve the memorandum (R.
M. Pierce to G. G. Stack dated September 15, 1976) which.
transmitted the aforementioned sketches to the site, but the sketches were not found. Therefore, this evaluation agrees with the NSRS report findings that SQN may, in fact, be'in-violation of 10 CFR 50, Appendix B, Criterion XVII.
5.
Incorrectly Sized Anchors - the performance of WR 114789 revealed only two of the anchors inspected to not be the size required by the 47A056 typical drawing series, one.being larger than. required and one being smaller. The support with the undersize anchor installed.(1000HCAB749-A0519R015) is being tracked by the SQN Compliance Section as requiring correction / documentation, and is being handled by SQN l
l Electrical Modifications. The fact that an undersize anchor I
was installed (5/16" instead of 3/8") was verified in'the memorandum C23 860618 006 from B. R. McCullough, Director of DNC. Also, the statement made in the same memorandum, "0E acceptance of variances from typical drawings, in effect at l
that time, required OE support design group approval but;did l
not require forcal documentation " was verified with the.
current responsible engineer (site-DNE) as potentially being the reason the undersize anchor was. installed. The SQN Electrical Modifications section indicated that the work plan which will be initiated to "close" Engineering Change Notice (ECN) L6744 will also address further action that may be required on the subject support.
6.
Nonconforming Conditions - with respect to the comments in the NSES report I-86-120-SQN on this subject, the following observations have been made:
a.
The current G-32 requirements, in effect when the WR 114789 sample program was performed. caused discrepancies to be.
identified which were not in violation of G-32 requirements.
at the time of installation / inspection'in 1976 - 1977.
The mechanism for evaluating the newer G-32 criteria and evaluating existing installations to these new criteria was NRC IE Bulletin-79-02 and the subsequent sample programs that were performed (Most of the current G-32 requirements were implemented.in 1981 to incorporate the inspection parameters found in 79-02).
s b.
Further evaluation is performed by DNE in many cases'to determine whether the old installation is acceptable according to the new criteria from an engineering-standpolat.
If the DNE evaluation determines that an'NCR-type condition exists, then a NCR is initiated.
For example, if an anchor is inspected and found to have less
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN l
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8 PAGE 10 0F 16 I
IV.
Summary of Findings (Continued) than 1 nominal bolt diameter of thread engagement (minimum requirement according to G-32) immediate action will be initiated to correct the problem.
However, DNE has proven through detailed engineering evaluation and laboratory 1
'l tests that approximately 3/4 nominal bolt diameter of.
' thread engagement is adequate for the anchor to be considered suitable'for service (perform its intended function without reducing the factor of safety).
Therefore, the DNE evaluation is performed on what has been identified as a potential isolated problem and doesn't mean the entire plant needs to be inspected again for the same
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potential problem. At this point, there is no reason for-4 DNE to believe that the. factor of safety has been reduced l
because sample programs, including'79-02, have proven at
)
least 95 percent adequacy.
7.
WR 114789 Identified Items - much of the same information.
provided in the previous section on Nonconforming Conditions is also applicable here.
It should be s'tated again, however, that l
the SQN 79-02 reinspection program was the mechanism employed to j
evaluate installed conditions to these more recent acceptance.
criteria. Furthermore, the reinspection (sampling) programs l
initiated at SQN according to Quality Technology Company (QTC) investigations, Special Maintenance Instructions-(SMI-2-317-24 R2-addressed in the Element Report on Testing of Anchors), NSRS investigations and several NCRs, Significant Condition Reports (SCRs) and Problem Identification Reports (PIRs) which mainly address DNE considerations each serve to evaluate installed conditions to new criteria, establish.new criteria and document-the process in each case.
1 The memorandum from B. R. McCullough to H. L.'.Abercrombie (C23 860618 006) also addresses specifically the issue.of nonconforming conditions and documentation / accountability.
programs with respect to. evaluating old installations to new
]
criteria. The final comments are directed toward enhancement l
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I of installation and inspection requirements and.the subsequent
.l reviews and engineering evaluations performed to qualify
- existing installations.
Programmatic deficiencies and generic implications were not considered valid problems requiring further evaluation. This evaluation. agrees with these comments.
l 8.
Even though the NSRS sample identified only.one instance of
-j insufficient thread engagement, this evaluation has chosen to
' address this issue since it relates directly to the SQN 79-02 l
- program, i
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i IV.
Summary of Findings (Continued)
It should be noted that the requirement for one bolt diameter of thread engagement =for-SSD type anchors was not incorporated
{
into G-32 until Revision 6 in 1981. The 79-02 reinspection i
program at SQN completed before 1981, was intended to reveal whether specific: anchorage problems existed, to include thread engagement.
Conversation with DNE-CEB engineers revealed that 3
I the G-32 requirement for thread engagement was' based on the need for a simple requirement to be used by the installer in the field, not to establish the minimum engagement required to insure the specified load capacity would be obtained. As l
stated as an example in Section 6.b.,
this report, tests (conducted at TVA Singleton Materials Lab).have proven that the minimum thread engagement required to obtain the required load capacities in SSDs is approximately 3/4 nominal. bolt diameter for most bolts. Therefore, the 95 percent adequacy factor for j
anchor installations according to.79-02 with respect to thread engagement is based on'a very conservative G-32 requirement.
To further support-this methodology, SQN,SMI-0-317-21.was initiated to survey 111 baseplates as a result of employee concern XX-85-010-001 which addressed nuts welded behind' baseplates. Determining installed bolt lengths was the first consideration, and both ultrasonic testing and physical j
measuring was used to determine the' actual bolt length..A1 l
total of 438 bolts were inspected for thread engagement and 1.6 j
percent did not have one nominal' bolt diameter engagement as 1
required by G-32.
After DNE evaluation, only.3 (0.6 percent) were determined to have insufficient thread engagement to-develop the full strength of the anchor.
9.
Anchor Spacing - the NSRS sample identified'27 supports which
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violated some element of the current spacing criteria.
Once I
1 again, it should be noted.that G-32, R10~ criteria were used to evaluate anchors installed to G-32, R4' criteria, as addressed 1
in the memorandum from B. R. McCullough to H. L. Abercrombie dated-June 18, 1986 on NSRS report I-86-120-SQN and recommendation I-86-120-SQN-5.
DNE is also evaluating the anchor spacing deficiencies as described.in memorandum B25 860507 008 from D. W. Wilson to H. L. Abercrombie.
j Conversation with DNE-CEB engineers revealed that preliminary review of the spacing violations had shown all would probably.
i be acceptable, but detailed analysis / calculations would provide final acceptance or rejection. The conversation also revealed i
a NCR (GENQAB 8203 R1) which had been written in July,'1985, to document potential inadequate spacing criteria.
-._.____'____.-____-___.__a
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.C011305-SQN-
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PAGE 12 0F 16 IV.
Summary of Findings (Continued)
In response to this NCR, SQN performed a fie3d. sample in several plant locations which consisted of.114 anchor installations where SSDs were installed at less than G-32 minimum spacing. In addition, field inspections were conducted at-these same locations to identify specific supports with significant loads and spacing less than the minimum. The results revealed all supports to have'an adequate-factor-of-safety as detailed in Revision 1 of 79-02 and the
-spacing violations addressed by the NCR had no significant effect on the actual anchor factor-of-safety.
It.was determined that no further corrective actions were required.
F.
The subject of employee concern XX-85-010-001 was nuts welded to 1
l the back of baseplates. The evaluation of this issue has revealed the following:
1.
Memorandum from H. B. Rankin, SQN Design Services to J. P. Vineyard, SQEP of January 30, 1986 (C01 860115 929) addressed specifically the subject of the concern.
SQN-SMI-0-317-21 was written to conduct a survey of 111 baseplates regarding the allegation of nuts welded behind.
.baseplates to fake anchorage. The aforementioned memorandum referenced six specific drawings that were reviewed; four'of-those were drawings 47A056-40, 47A056-40A, 48N707-26 and I-H47-282.
Drawing (47A050-4) eddressed bars or small spacer plates installations behind the baseplate. Drawing 47A053-151 did show an alternate configuration which allowed-nuts to.be used below the baseplate on the anchor stud to level the' plate, but only on floor attachments. The survey found severel baseplates where nuts were used as a leveling device and SQN-0E was asked to evaluate the installations. The generic review determined that the structural integrity of the support was not compromised (memorandum B25 860218 017).
In addition, documentation was to be initiated to prohibit the use of-leveling nuts in future installations and document on.the i
applicable drawings the past use of the leveling nut method.
This was verified during conversations with responsible Site Services and Electrical Modifications engineers.
FCR 4247 was initiated to accomplish the drawing changes, but was subsequently cancelled because OEP-11, 3.5.C (Exceptions to the ECN Procedure) did not require a FCR to make a " cosmetic" l
drawing change only.
e i
i TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM l
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8 PAGE 13 0F 16 IV.
Summary of findings (Continued)
G.
Conclusions 1
The following conclusions address both specific concerns and generic issues at SQN.
However, the summary is directed toward l
proving the adequacy of SQNs-concrete anchor program and l
therefore, will also specifically address NRC IE Bulletin 79-02:
1.
Four specific concerns addressed the issues of abandoned anchor
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holes, torched / beveled holes in-baseplates, anchors in contact with rebar and anchors installed outside'of perpendicularity requirements. This evaluation revealed:
Abandoned anchor. holes - the concern was verified as being a.
true but no violations of G-32 criteria were identified.
b.
Torched / beveled holes in baseplates - this. concern was not verified as being true, as no holes were found which had been beveled or enlarged with a cutting torch.
c.
Anchors. exceeding perpendicularity - this concern was not verified as being true, as no-anchors were' identified which-exceeded the current criterion for perpendicularity.
d.
Anchors contacting rebar.- this concern was not verified as being true as no anchors were identified which were in contact with rebar.
2.
With respect to other anchorage issues, no deficiencies were found which, after review and engineering evaluation.-caused a
')
condition adverse to quality to be identified. The significance of this statement.is realized when it is recognized that the identified deficiencies were not i
unacceptable in the timeframe of the initial installation /
inspection (1976-1977) but were deficient based on' current, j
present day criteria. This provides the justification for~
l detailed engineering evaluations of old installations ~to new i
criteria as opposed to using the NCR/SCR mechanism for each potential deficiency. DNE'is committed to initiating proper CAQ type documentation only when engineering evaluation methodology fails to qualify or accept the installation "as is."
3.
NRC IE Dulletin 79 the sampling programs performed according to 79-02 were in direct compliance with those I
described by the bulletin. The bulletin listed two specific e
sampling methods that could be employed or, as an alternative, i
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN l
SPECIAL PROGRAM REVISION NUMBER: 8 l
PAGE 14 0F 16 IV.
Summary of Findings (Continued) other methods could be used if justified.
TVA used the random sample technique described in the bulletin which provided a 95 percent confidence level that less than 5 percent defective anchors were installed.
The NRC has accepted the results of the 79-02 program at SQN. The results proved a greater than 95 percent confidence level as previously described.
l 4.
General Construction Specification G the current revision to G-32 includes numerous changes (enhancements) not in effect during the timeframe of the subject concerns. These enhancements were a result of NRC IE Bulletin 79-02 which identified, industry wide, the need for more detailed acceptance criteria and inspection procedures. The bulk of these enhancements were implemented in G-32 according to Revision 6 in 1981.
However, the enhancements were not l
intended to be interpreted as absolute minimum acceptance l
criteria but as conservative requirements and guidelines to be used by the field when the anchor (s) is installed. The revising of G-32 is a process that "will continue" because as new methodology is recognized, areas in need of enhancement are identified and more specific criteria are required, revisions will be made to further improve the anchor program.
l 5.
The following are areas identified by this evaluation that SQN should review as necessary to determine any additional action (s) that may be required:
perform a detailed review of Modifications and Additions a.
Instruction (M&AI) 10, RIO, to include Change Number 86-893, to insure that all applicable G-32 anchor installation and inspection criteria have been implemented.
l b.
review 10 CFR 50, Appendix B, Criterion XVII to determine if violations have occurred with respect to color coded rebar sketches (12-11-8-76-0 through -16) potentially being a "QA record" but not being retrievable for review.
c.
review drawings identified in Section F.1.,
this report, to insure revisions are incorporated with respect to the use of leveling nuts behind baseplates.
l l
TVA EMPLOYEE' CONCERNS REPORT NUMBER: C011305-SQN, SPECIAL PROGRAM.
. REVISION NUMBER: 8 PAGE 15 0F 16 IV.
Summary of Findings (Continued) 6.
Final comments applicable to the subject of this element are as follows:
A significant amount of work has been performed and is a.
still being performed in many areas by SQN Mechanical and Electrical Modifications, SQN OE, SQN compliance and DNE on issues applicable to the subject. concerns.
Documentation initiated by the NSRS, DNE and SQN-GCTF is being tracked and statused by.the SQN Compliance section to. insure resolution of each open issue.
b.
This evaluation has' determined that the necessary programs and procedures are in place and significant emphasis has been'placed on each item to fully answer specific concerns and further prove the adequacy of SQN's anchor program.
1 V.
Root Cause No specific CAQs were identified so no root cause is assigned at this time. However, a potential CAQ exists with respect to 10 CFR 50 Appendix B Criterion XVII.
If this CAQ is verified, root cause would j
be failure to follow procedure and/or failure to adhere to upper-tier l
criteria requirements.
l VI.
Corrective Action 1
The line management response as detailed in CATD No. C011305-SQN-01 was that a detailed review of M&AI-10 had been performed and I.C.86-893 had been incorporated cn August 1, 1986.
The line management response as detailed in CATD No. C011305-SQN-02 was that the referenced sketches were not considered QA records nor documentation. Rather, they were considered field information and processed as such.
j
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011305-SQN SPECIAL PROGRAM r
REVISION NUMBER:
8 PAGE 16 0F 16 i
VI Corrective Action (Continued)
Additional evaluation was performed subsequent to the line response on the subject sketches.
Conversations with DNE civil engineers revealed L
the areas detailed by the sketches to be " low stress" areas where a minimal amount.of rebar was actually required. The intent of the sketches was to serve as a guide for areas where " blanket approval" would be given to cut rebar.
DNE defined the sketches as color-coded-drawings issued to facilitate construction only and were not intended to serve as life-of-plant (LOP) type documentation. However, these l
comments do.not preclude SQN from maintaining records which would allow-evaluation of the cumulative effects of rebar cut in specified areas.
l This subject is being addressed from a generic standpoint by the Engineering Category, SQN Element Report Nos. 215.2(B) and 215.6(B).
The line management response as detailed in CATD No. C011305-SQN-03 was to revise the following drawings to preclude the use of leveling nuts:
47A056-40 and 40A, 1-H47-282, 48N707-26, 47A053-151. Drawing 47A050-4 I
was already revised on June 3, 1986, to address the leveling nut concern.
These corrective actions are not SQN restart items.
The corrective actions for the listed CATD are detailed below:
- C011305-SQN-04 Cle:ure of Recommendation I-86-120-SQN-3 of NSRS Report 1-86-120-SQN.
i
- C011305-SQN Closure of Recommendation I-86-120-SQN-2 of NSRS 3
Report I-86-120-SQN.
]
- C011305-SQN Closure of Recommendation I-86-120-SQN-5 of NSRS l
Report I-86-120-SQN.
VII. Generic Applicability Since NRC IE Bulletin 79-02 affected all TVA nuclear plants, the issues addressed by this evaluation are potentially generic at Browns Ferry.
and Bellefonte.
The overall adequacy of each anchor program, the emphasis being directed toward 79-02, should be evaluated.
VIII. Attachments 4
Attachment A - List of Concerns Attachment B - Listing of Concerns Indicating Safety Relationship and i
Generic Applicability 1
6 11305-SQN ATTACHMENT A LIST OF CONCERNS HI-85-020-N02 HI-85-013-N04 HI-85-113-N02 IN-85-020-001 IN-85-037-001 IN-85-246-003 IN-85-285-001 IN-85-625-002 q
IN-85-664-001 IN-85-982-001
)
IN-86-140-002 IN-86-177-001 IN-86-221-001 IN-86-294-002 i
PH-85-002-026 PH-85-035-007 PH-85-054-N03 BNPQCP-10.35-8-23 SQP-5-005-001 SQP-5-005-002 SQP-5-005-003 l
SQP-5-005-004
)
SQP-5-005-005 l
SQP-5-005-006 SQP-5-005-007 j
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