Text

Forwards Rept of Outlined Actions & Conclusions Resulting from Util Investigation & Commission Concerns Re Small Pipe Program,Per 820811,18,25 & 27 Meetings
	ML18031A400
Person / Time
Site:	Susquehanna
Issue date:	09/10/1982
From:	Kenyon B; PENNSYLVANIA POWER & LIGHT CO.
To:	Martin T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
	PLA-1288, NUDOCS 8210060391
	Download: ML18031A400 (161)
	v • d • e

Pennsylvania Power 8 Light Company Two North Ninth Street

~ Allentown, PA 18101

~ 215 / 770.5151 Bruce D. Kenyon Vice President-Nuclear Operations 215 / 770-4378 September 10, 1982 Mr. T. T. Martin, Director Division of Engineering and Technical Problems U. S. Nuclear Regulatory Commission Region 1

631 Park Avenue King of Prussia, PA 19406 SUSQUEHANNA STEAM ELECTRIC STATION INVESTIGATION OF SMALL PIPE PROGRAM CONCERNS ER 100450 FILES 841-4, 285 PLA-1288

Dear Mr. Martin:

Docket; Nos:

50-387 50-388 In a meeting on July 30, 1982 and subsequently in PLA 1193 Pennsylvania Power 6 Light Company defined an action plan for the investigation of small pipe program concerns.

Subsequent reviews of the program. by Commission Inspectors and allegations raised about the 'program by various other parties were discussed with the Commission on August ll, 18, 25 and 27, 1982.

Documentation pertaining to the August ll and 25 meetings are contained in our PLAs 1245 and 1275.

No specific documentation pertaining to the August 18 and 25 meetings has been submitted.,

This letter serves to provide the Commission with a report of:

1)

PPGL's actions resulting from its investigation of the small pipe program.

2)

PPGL's actions resulting from Commission concerns.

3)

PPGL's investigation of the various allegations.

4) Additional actions

underway, or to be taken by PPGL to address small pipe program and related generic concerns raised by the PPSL Investigation Team and Review Committe'e.

5)

PPGL's conclusions regarding adequacy of the small pipe program and its impact on safe operation'f Susquehanna Unit. 1.

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In the meeting on August 18, the Commission presented PP&L with a list of 16 allegations and Findings.

1-1, 1-2, 1-3, 1-5, Handout 1

of PLA 1275 and Attachment 1 of this letter contain that list and PP&L's responses, including responses to supplementary questions about, these findings raised during the August 25 and 27 meetings.

On August 18, the Commission also raised three additional questions related to the program.

PP&L responses to these questions have been documented in handouts 2 and 4 of PLA 1275.

Bechtel responses to their three questions are found in responses 17, 18 and 20, Handout 1

of PLA 1275.

During the meetings on August 25 and 27, the Commission presented a

series of additional technical questions which PP&L has responded to in Attachment 2 of this letter.

PP&L's presentation on August 25 outlined the Findings and Observations of the Investigation Team and the Review Committee's Generic Concerns.

Subsequently PP&L and Bechtel have reviewed all Findings, Observations and Generic Concerns and provided specific responses, corrective action plans and schedules for completion.

Attachments 3 and 4 of this letter contain their responses.

The Commission also presented on August 27 a series of general pro-prammatic questions concerning the PP&L'nvestigation.

These questions and PP&L's responses are included as attachment 5 of this letter.

Section V of the Investigation Report (Handout 3 of PLA 1275) contains the conclusions of the Investigation.Team.

PP&L management has re-viewed these conclusions and responded to them in Attachment 6 of this letter.

During August, 1982 the Commission Inspectors raised questions about back dated calculationsand incorrect use of signatures on small pipe drawings.

PP&L has investigated these items and responded in Attach-ment 7 to this letter and in Handout 1, Question 19 of PLA 1275.

F In May, 1982 the Commission received two letters containing allegations about stress intensification factors, reconciliation of nozzle loads and aboutwelder qualifications.

Responses to thefirst two allegations are contained in Handout 1 of PLA 1275 and Attachment 1 of this letter.

PP&L Nuclear Department management requested the PP&L Auditing Depart-ment to investigate the welder qualification allegation.

Their report, is included as Attachment 8 to this letter.

PP&L Nuclear Department management has made an extensive evaluation of the small pipe design/installation/inspection program.and the actual hardware in the Susquehanna Plant.

The conclusions of that investiga-tion are as follows:

1. Small pipe systems are adequate and will permit safe operation of the Susquehanna Steam Electric Station.

2. After a more thorough investigation, there are no piping systems of an indeterminate nature as found by the PPSL Investigation Team.

3.

The investigation found weaknesses in the small pipe program in the areas of design control, use of engineering judgement, organi-zational interfaces and document control.

PPGL Nuclear Department management is aggressively pursuing a resolution of these weak-

nesses, but does not feel that they impact the overall integrity of the installed hardware.

4.

The small pipe program was a unique effort, and the weaknesses found in that program are not applicable to other programs.

We trust that the Commission will find this report and the actions that it describes as a satisfactory means of closing the small pipe issue.

Very truly yours, B.

D. Kenyon Vice President-Nuclear Operations Attachments RJS/ks cc:

G.

Rhoads USNRC R. Perch

.USNRC

1I t

S UEHAHHA ALLEGATIONS AHD FINDINGS 8/18/82 4

@~a cH ~zeT r

1.

Stress Intensification Factor On site simplified calculations did not analyze weldolet/sockolet connections with large pipe.

An SIF of 1.3 was used for fitting/small'ipe interface.

Fitting/large pipe interface was analyzed with large pipe stress analysis.

2.

Nozzle loads on equipment were ignored on all SBP analyzed on site.

If the allowable nozzle loads were supplied by the manufacturer, the piping loads were compared to it. If it was not provided it was not compared.

The licensee contends that pipe load on equipment is not critical for nonsensitive equipment because there is enough conservatism built into the analysis and the placement of the first support.

Licensee will supply a list of all equipment thdt was analyzed for NRC review.

~

3.

The licensee grouted pipe sleeve penetrations after the piping was analyzed CLOSED)for stress.

The licens~w contends that the penetrations have been inspected and documented by the "as-built" verification program.

4.

Small pipe anchors, per Bechtel Detail 600 and SPA 1312, do not provide restraint in three directions (x, y,z).

There are three drawings of this hanger (Detail 600, SPA $00, SFAQ12).

Due to fabrication tolerances, the clamp may not have an interferenc

'o to resist axial and torsional slippage.

5.

A generic bolt size problem exists with all 1" hangers.

The bolt shoulder specified extends through both ears of the pipe clamp.

This causes the bolt to shoulder out before the clamp is adequately torqued.

6.

Bolts specified on Detail 600 are SA-307 but SPA 600 and 1312 are SR-325.

SR 325 bolts are of higher strength.

7.

The upgrade of Detail 600 to the'PA 1312 design caused distortion of the clamp because of welding stresses.

,8210060391

,l.

8.

The "ears" of lar bore pipe hanger clamps were trimmed to prevent interference. 'his has not been incorporated into the design.

Example:

'HBC-101-14-210.

9.

SBP systems on Unit 1

may be too rigid.

The hangers required to Unit 1 were analyzed by the simplified method and resulted in about 700 supports.

The hangers for Unit 2 were computer analyzed and resulted in about 270.

4 10.

Structural. steel beam flange warpage and web damage due to dead loads placed on beams at elevation 749'ear outboard MSIV.

(CLOSED BY NBC) 11.

A design change on December 21, 1981 revised Detail 600 to SPA 600 but the new design was not distributed for work or inspection.

12.

The proposed fix of Detail 600 hangers does not appear to be acceptable.

(Line contact on pipe, not full length).

P 13.

One pipe support attached to two seismically independent structures.

Three I

supports have been identified connected between the reactor building and primary

~

0 containment.

14.

Snubber, SP-HCC-136-H-2003'as instal=led such that the support can be deflected several inches laterally.

15.

Lack of clearance between snubber end and clamp ear.

16.

Site fabricated rear brackets of snubbers did not provide adequate clearance for Iateral movement of the snubber.

V v ~

l)

Stress Intensification Factor (SIF) 2)

Friction Anchors 3)

Snubber Clamps 4)

Non-Rigid Support; SP-HCC-l36-H2003

Sheet' of 2 SIF Item:

Demonstrate compliance with items (a) through (g) of footnote 6

to NC-3673-(b), or a factor of safety of two for worst case analysis.

Response

(1) All lines with calculated high SXF. (using ASME code, 1974 or 1982 Summer

Addenda, table NC-3673.2(b)-1) were reviewed f'r effect of the SIF on state of stress.

Conservatism of simplified design approach (M-241) was demonstrated.

All lines reviewed or analyzed by detailed computer models meet code allowables.

(2)

Profiles of representative branch connections were taken.

(Reference BLP-22366).

(3)

The attached material demonstrates that based on the above two activities the intent of footnote 6 to table NC-3673.2(b)-1 is met.

Two worst case situations are demonstrated.

Branch connection with the highest calculated primary stresses.

Branch connection with the highest calculated secondary stresses.

FOOTNOTE 6 COMPLIANCE (6) (a)

All small piping fittings are purchased in accordance with ANSI B16.11.

Therefore, they meet NC-3643.2 branch connections not requiring reinforcement.

The attached reinforcement calculation demonstrates that adequate reinforcement area exists for the half coupling connection having the highest calculated stresses.

(6) (b).

All branches are normal to, the surface of run'ipe.

Applies to all seismic branch connections.

(6)(c)

All branches are installed to meet these requirements.

(6) (d)

(6) (e) r requirement is exempted for smaller than 4" branch lines.

1 2 weld profiles of branch connections having highest calculated, stresses (one half coupling 6

one sockolet) are evaluated for this requirement.

'Ihey have met the intent of this requirement.

See profile pages in the encloseu attachment.

(6) (f) r is not applicable since for these connections

.a socket weld is used where r3 is shown, and the location of socket weld is 3

remote from the branch weld.

~

~ I Sheet 2 of 2 (6) (g)

These two requirements have been met 50 and.

m

+

0 rl r

(6)(h)

Compliance is not required since weld profiles demonstrate the (S82) existence of an r2 radius.

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~ (7j, + y)/Z..-.a.507.. 3/16 and ( 0.1 a

tn 1.0 Butt weld (1) itn 43/16 ort > 0.1 a

tn 1.0 for flush weld 1.8 for as. welded tn Fillet welded joint, socket welded flange, or single welded slip on flange 2.1 Fig. ND-3673.2(b)-3, sketches (a), (b), (c),

(e) and (f)

Full filletweld 1.3 Fig. ND-3673.2(b)-3, sketch (d) 304 max.

30'apered transition (ANSI 816.25) (I )

1.9 max. or Do

~

1g+ 0.0036

+ 3.6 tn tn'n Do Concentric reducer (ANSI B16.9 or MSS SP48) (7) 2.0 max. or 05+ 0.1 o DI 2t D2 Threaded pipe joint or threaded flange Corrugated straight pipe or corrugated or creased bend (8) 5, (See notes on next page)

FIG. NC-3673.2(b)-1 FLEXIBILITYAND STRESS INTENSIFICATIONFACTORS (Cont'd) 133

~ ~

Fig. NC-3673.2(b)- I I

SE~ON III, DIVISION I SUBSECTION NC NOTES:

(1) The following nomenclature applies.-

r ~ mean radius of pipe, inches (matching pipe for tees and elbows).

r~ nominal wall thickness of pipe, inches (matching pipe for tees and elbows, see note (9)).

R bend radius of elbow or pipe bend, inches.

8 ~ one. half angle between adjacent miter axes.

s ~ miter spacing at center line, inches.

re ~ reinforced thickness, inches.

8 ~ mismatch, inches.

Do outside diameter, inches.

(2) The flexibilityfactors k and stress in intensification factors i apply to bending in any plant for fittings and shall in no case be taken less than unity. Both factors apply over the effective arc length (shown by heavy center lines in the sketches) for curved andmeter elbows, and to the intersection point for tees. The values of k and i can be read directly by entering with the characteristic h computed from the formulas given.

(3).Where flanges are attached to o'e or both ends, the values of k and i shall be corrected by the tactor c given below, which can be read directly from Fig. NC4673.2(b).5, entering with the computed h.

One end flanged c ~ h /a Both ends flanged c ~ h /s (4) Also includes single miter joints.

(5) When re )

1 5 rn t h ~ 4.05 tn/r (6) The equation applies only if the followingconditions are met:

(a) The reinforcement area requirements of ND-3643 are met.

(b) The axis of the branch pipe is normal to the surface of run pipe wall.

(c) For branch connections in a pipe, the arc distance measured between the centers of adjacent branches along the surface of the run pipe is not less than three times the sum of their inside radii in the longitudinal direction or is not less than two times the sum of their radii along the circumference of the run pipe.

(d) The inside corner radius r, (FIG. ND.3673.2(b)-2) is between 1o and 50% of Tr.

(e) The outer radius, r is not less than the larger of Tbl2, (Tb+ y)/2.(FIG. ND-3673.2(b)'-2 sketch (c)) or Tr/2.

(f) The outer radius, rs, is not less than the larger of (1) 0.0028 do (2) 2 (sin 8)'imes the offset for the configurations shown in Figs. ND-3673.2(b)-2 sketches (a) and (b).

(9) Rm/T~ C 50 and r'rnlRm ( 0.5.

(7) The equation applies only if the followingconditions are met:

(a) Cone angle, e, does not exceed 60 deg, and the reducer is concentric.

(b) The larger of 0, /t, and 0, It, does not exceed 100.

(c) The wall thickness is not less than r, throughout the body of the reducer, except in and immediately adjacent to the cylindrical portion on the small end, where the thickness shall not be less than r,.

(6) Factors shown apply to bending; flexibilityfactor fo'r torsion equals 0.9.

(9) The designer is cautioned that cast butt.welding elbows may have considerably heavier walls than that of the pipe with which they are used: Large errors may be introduced unless the effect of these greater thicknesses is considered.

134

~ ARTICLE iVC-3000 DESIGiV Fig. NC-3673.2(b)-2 Tb Tb BRANCH PIPE Tb ItTt Tb 2

l'p trm Th rp en ~( O5 OFFSET 2

BRANCH Tbr P

Tt dQ Irm Hn=90'FFSET 2

Rm (b)

BRANCH PIPE do trm

.2 BRANCH PIPE Tb= Tb+0.667 y H.n ( 45o BRANCH do lp rn Ip l2 Tf' t<m Tb

/

2 y

Rm r (c)

(d)

Rm 2 FIG. NC-3673.2(b)-2 BRANCH DIMENSIONS NOTES:

r'm ~ mean radius of branch pipe inches Tfr nominal thickness of branch pipes, inches Rm ~ mean radius of run pipe,inches'~

nominal thickness of run pipe, inches do ~ outside diameter of branch pipe, inches Ty, 8. rrs ~ rff Ip and y are defined in this figure.

135

70 RG. AGQS7M(g-1; he following nomendature applies.

l~~ <<mck7~dius of'pipe,<nÃmatcnlng~pe for teeswnd&bovvs)

~ <<nominal wallWi~ess o',pi~r ~m~irigpipe ~~ and efbows.~ Hate (9)],

~ p <<bend radius af elbow or pipe Mn'".in.

<<.one-halLangie bczween~diacent.mne.'ax~'.

s miter ~='n at center~~~n:
~.reinforced cl'Ic~ess An '
6 <<.rrusmaxdl Mn g, ~ ocmide6ameter.'3n'.
{2) The fiexibiiityfac:ors iand ~intensificavon.a~-,, mopiyco2oending inanyyiane forCitdnasand M~all~nno case be taken Iessman unry.'ath 'a~ ap~y aver ~e~~enr 'le~'2shown ~heavy center iines in theme ~}for nerved.
hand miter elbows, and to the intersection'.pointmr ~~ne values ef Panda can H read direcdy bywnter'ewith me
~-.characterised"* computed tromeewatimjiven.-.
{3)'Where fiances are'amNedto one'oracrAwnc,~ v"Ives oft andisnali~~rrecedby the fa ore gwen be}ow, whl&
canbe read~.reedy
~rom&g.&iC "Si Ab)-5:-amenng~mecompu~-..
(a) ~ endfiange",w
'b)
Bath cods fianged, c << fg'~
(4) Also indudes single miter joints..
(5) When f, > 1.5:h~ 4.05~lr.
{6) The equation applies only if the faUowing cancidonsare me (a) The reinforceme~: area requirements a'. NC.3&V are met.
(b) The axis of the branch pipe is normal to the svr'.ace of tun pipe walL fc) For branch canne
.ions in a pipe. the arc disance measured between t.ie centers of adiacent branches alone the surface c'. the rvn pipe is not less than thre times ~e svm of ieir insioe racii in tne lonaitvdinal direc:ion or is nc:.less than twa times the svm of their radii aiona the cirumferenc af the run pipe.
) The ir.side corner radius r, (Fig. NC-36?3.2{b)-2) for nominal branch pipe size areater than 4 in. shall be between 10% ar C ~'2 TThe radius r, is not reauired 'or nominal branch pipe size smaller than 4 in.
I Tne oute. radius r, is not less than the larger of T,J2.- (T,~+ y}/2 (Fig. NC-367." 2(b)-2 sketch (c)] or T,l2.
If) The c ".er radius r, is not less than the larger of (1} 0.992e d, 0; 2 fsin e)'times the o set for the conRgvraUans shown in Figs. NC-35732(b)-2.sketches (a) and {b).
~
Igi n iT, s 50 and r'~rI=. s C.a.
fh) Tne cute..aci s r; is nc: re"uired provided an additional muttiplier of 2.0 is included in the e"vations for branch end and run end stress intensiYication factors. In tnis case,tne calculated valve ofi forthe branch'or run shall nat be less than 2.1o
{7i The e uaticr. ap"!ies cnly if the followinc c nditiors are met:
(a) Cone anale a aae not exceed 60 deg., and the reaucer is cancentric. ":
"'b)
Tne larae.
cfog
':.. and J-!t-. coo s not exceed 1M.
(c) The wall thi-kness is not leM than., thravchou; the body of the reducer, except in and immediately adjacent to the cylindric-I poricn Gn the small end. where the thickness shall not be less than f,.
{5) Farces shcv n ac" iy la bending; flexibilityfactar for torsion eauals O.K
{9) The cesigner is cautioned that cast butt welding elbcws may have considerably heavier walls tnan that of the pipe wnh vrhich they are used. Lar"e errcrs may be introduc "unless the et'.ect of these greater thicznesses is considered.:
(10) The stress in;ense:ica;Ion!actari shall in no case be taken as less than 2.1.
(11) A stress intensification factori of 12 may be used for %}letwelds provided that both weld leos are greater than or equal to 1.6 z.
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R r ec'i radius C. brancn pipe in.
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~ C', ~ Outaide Ciareter of b~anch pipe. ir T5, fr,i ~ rr, rr and y are dtfineC in tnis figure.
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"i. tnen r'an oe taken CS thC raCIUS to the CCntCr Of i r F1G. NC-3673,2(b)-2 SRANCH DlMENSlOMS 168
FRICTION ANCHORS Item:
Perform study calculation for SPA-1312 with SA-307 bolts and lower torque values.
Verify weld size also.
Response
See the attached copy of the study calculation for SPA-1312.
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SNUBBER CLAMPS Item:
1)
'Field to verify that trimmed clamps for snubbers are shown on the as-built drawings.
Response
1)
Investigation has revealed that trimming of pin-to-edge dimensions on snubber clamps was not an inspection point during the as-builting program in Unit 1; only such dimensions identified during a Field Engineering special inspection of the size 35 snubbers on 12" lines within the containment above elev. 719'ere actually documented on the as-built drawings.
Inspection results are recorded for 129 of 139 snubbers in question (the remaining non gC records have been misplaced).
These records. indicate that 16 of the clamps were trimmed such that they violated Grinnell's (2.85")
minimum specified dimension.
Field Engineering elected to enter the trimming information on the as-built hanger deta'il drawings for Project Engineering review and acceptance or disposition.
As a -result of this special inspection, the drawings were revised to show the 16 clamps having dimensions not meeting Crinnell's criteria.
Field Engineering calculations indicated that the dimensions observed would be acceptable, so further sampling/inspection for this condition was not considered necessary.
As a result of this problem, PP&L is conducting an inspection
,of. snubbers in Unit 1.
Any dimensional discrepanci'es identified during this walk'down vill be reviewed for technical adequacy.
Field Procedure FP-P-20 is being'evised to ensure proper documentation of such trimming on Unit 2.
Item:
2)
Issue identified by NRC on five as-built hangers not indicating trimming; i.e.
DLA-1'02-H9, DLA-102-H2, DLA-104-H9, DLA-104-H14, and DLA-104-H12.
Response
2)
Status of the five hangers identified by NRC.
DLA-102-H9
. This is one of 10 snubbers for which no inspection record is available.
(The inspection record was apparently lost prior to revising the
'as-,built drawings'.).. Recent measurement taken reveals a: 2'/2"..dimension, indicating that the as-built drawin'should have been revised.
DLA-102-H12 (Not H2)
Inspection results for this snubber clamp indicated a
2 1(2" dimension, and the as-built drawing was revised to reflect this.
DLA-104-H9 Inspection results for this snubber clamp indicated a measurement of 2-7/8", therefore, the as-built drawing need not be revised.
Sheet 2 of 2 DLA-104-H14 This is'nother of the 10 snubber clamps for which special inspectS. on records are not available, however,. recent measurement indicated 2-7/8" dimension, so the as-built drawing need not be revised.
DLA-104-H12 Inspection records for this snubber clamp indicated a 2-5/8" dimension, and the as-built drawing was revised to reflect this.
Item:
3)
Justify adequacy of trimmed clamps by calculation.
Response
3)
Project Engineering is. currently reviewing trimmed clamps for adequacy.
The trimmed clamps are identified by the PP&L snubber inspection program and forwarded to Project Engineering for review.
This program will continue until the PP&L inspections are completed.
Item:
4)
Adequacy of snubber's swing angle.
Response
4)
PP&L initiated a walkdown of the snubbers in Unit 1.
The purpose of this inspection is to identify trimming of snubber clamps and verify adequacy of the swing angle.
This program will continue until the PP&L inspections are completed.
0 I
NON-RIGID SUPPORT:
- SP-HCC-136-H2003 Item:
Show by calculation the adequacy of the I beam due to a lateral force in the N-S direction if the snubber is installed within 5'nstallation tolerance.
Response
See attached calculation regarding adequacy, of I Beam due to lateral force in the N-S direction.
0
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1)
Finding 1-3a 2)
Finding 1-3b, 3)
Finding l-ll 4)
Finding 1-12
FINDING 1-3a Item:
The fillet welds on line SP-HBC-78 hangers appear to violate AWS code requirements for '3/4" plate (minimum weld requirements).
These welds were accepted by judgement.
Provide technical justification(s) f'r the acceptability of undersized welds.
Response
The following hangers in calc.
/35418 violate min. weld requirements of AISC/AWS.
SP-HB C-78-H49 SP-HBC-78-H61 SP-HBC-78-H2036 S P-HBC-78-H96 SP-HBC-78-H57"
~ SP-HBC-$ 8-H95 attaches attaches attaches attaches attaches attaches to 3/4" inbed to 3/4" inbed to.582" thick flange to 3/4" plate to.615" thick flange to 3/4" plate It was determined (per technical directive from Bechtel San Francisco Plant Design Staff to SSES Project) that the undersized welds are acceptable if the calculated stresses are within the code allowables and the specified size is not less than 3/16".
See Attachment 1 for commentary on justification of 3/16" welds.
The following is technical justification that the weld stresses are acceptable.
SP-HBC-78-H49.
& 61 Calculation ABH-5418 has a
complete analysis of the weld stresses demon-strating the weld size is acceptable.
SP-HBC-78-H2036 Was qualified by engineering judgement.
For complete stress analysis see attached study calc. for H2036.
(Attachment 2)
II SP-HBC-78-H96 Design loads are Fy 250
& Fz 245.
The allowable load capacity for the formed plate with a 1/4 inch weld is 20008 for two directions.
Since weld size is reduced 25%, the allowable capacity is reduced by 25%.
The new capacity is 1500// in the two directions which is still acceptable for the small loads.
SP-HBC-78-H57 See attached study calc. for weld stress.
(Attachment 3)
SP-HBC-78-H95 Design loads are Fy 250
& Fz 245.
See justification for SP-HBC-78-H96, above.
Attac ment Page 1 of 2
COMMENTORY ON MINIMUMFILLET ~D SIZE FOR PIPE SUPPORTS Susquehanna's pipe supports for nuclear systems are designed to ANSI B31 ~ 7 and for non-.nuclear systems to ANSI B31.1 Codes.
Paragraph 1-720.2.4 of B31.7 and Paragraph 120.2.4 of B31.1 state:
"Where it is necessary to frame structural members between existing steel
members, such supplementary steel shall be designed in accordance with the standards prescribed by AISC or eq uivalen t. "
AISC, in turn, references AWS as the welding Code to be used
~
AWS Dl.l Code, 1975 Edition, has with it an attached Commentary that explains the intent of the various sections of the Code.
Article 2 of the Commentary is on design of Welded connections and para 2.7.1 specifically talks about minimum fillet weld sizes for prequalified joints.
Table 2.7 gives details of minimum fillet weld sizes depen-dent upon the thickness of the thicker part joined, but not to exceed the thickness of the thinner part joined.
The last sentence of para 2.7.1 of the Commentary states:
"Where Table 4.2 stipulates the mandatory preheat, for thick-ness over 3/4 in. (19 mm), then fillet size limitations do not apply."
This comment cracking due metal if the can be noted required for indicates that a small weld size would not cause to fast cooling in either heat affected zone or weld mandatory preheat requirement is followed ~
Also it from Table 4.2 that a higher preheat temperature is thicker members.
Table 4.2 gives a minimum preheat of 50' for AS'IH A-36 material, over 3/4" thru 1 1/2" thickness, using shielded metal arc welding with low hydrogen electrodes.
4 Specification 08856M-213 for installation of pipe supports, para-graph 4.4.1, lists the Bechtel documents to be used for welding of supports'to building steel.
Paragraph 4.4.2e states:
All welding procedures, welders and welding operators shall be qualified in accordance with the requirements of ASME Section IX or AWS D1.1-72 ~
For the Susquehanna project, all small bore hangei details are af-fixed with a stamp signed by the Lead Field Welding Engineer listing preheat to 60' as a weld requirement.,
In addition, all supports have a Quality Control Inspection Report (QCIR) required.
One of the items documented by the QCIR is welding activities Inspection of weld quality is performed on a 100X basis per Spec.
08856-M-213, while inspection of inprocess activities such as preheating are cover'ed on,a surveillance basis.
l
~
Page 2 of 2
The AWS Code exempts the preheat requirement for base metal thickness equal to or less than 3/4 in. provided the minimum weld size require-ment as stipulated in Table 2.7 is met.
As an interpretation to this rule for weld design, 'the mandatory preheat requirement of 50' may be applied to thicknesses greater than 1/2" but equal to or less than 3/4" in order to replace the minimum weld size requirement.
The ac-ceptability and conservatism of this interpretation can be justified by the rationale given above.
There is no problem with thicknesses equal to or less than 1/2" since the smallest weld size specified on pipe support details is 3/16"which is'he same as required by table 2 ~ 7 ~
Based on the AWS Code Commentary stated
above, the interpretation of using preheat for greater than 1/2" but less than 3/4" thicknesses and the documentation required by the gCIR, we have concluded that our design of pipe supports relating to fillet size requirements is in compliance with the Codes.
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FINDING 1-3b Item:
SP-HBC-78-H2036 acceptance by engineering judgement.
Response
SP-HBC-78-H2036, Rey.
OF3 was accepted by Project Engineering based on engineering judgement exercised during the comparison of the as-built drawing to the design drawing.
By inspection it is observed that the installed condition would be adequate if not more conservative than the original.design.
This observation is based on the fact the installed hanger is a cantilevered TS 3 X 3 X 5/16 approximately 2 feet long.
The primary loading is axial with a small moment applied.
Also the design loading of 2398. can be anticipated to produce low stresses and small deflections.
The engineer could also have chosen to qualify the support by either a comparison to a SPA or by a detailed calculation.
A detailed calculation which suppor'ts the engineering judgement that was used in accepting the hanger is shown in Attachment 2 of Finding 1-3A.. Note the low stresses and deflections throughout the structure.
FINDING 1-11 Item:
Differential building movements were not properly accounted for in the design.
Provide justification for the design.
Response
During the Phase III program, the stress engineer requested all supports in calculation 5499 to be attached to the reactor building.
Therefore, the calculation correctly accounted for the differential movements between containment penetration and the first support.
It was found later that one of the supports (vertical support 8H11) was actually attached to the containment wall.
During the as-built reconciliation program.
Resident Engineering reviewed the differential movements between the reactor building and containment wall at this elevation.
The differential movements were found to be less than one thirty second of an inch and were judged to be negligible according to the project criteria.
FINDING 1-12 Item:
The dynamic loads for two valves are concentrated on hanger H2000 (calc.
5268).
1his is beyond the guidelines of Spec.
N-241.
Provide technical justification.
Response
During the Phase IIIprogram, the stress engineer considered support PH2000'in calculation
5268, to act axially for the horizontal run (although the support was at a point 9" from the horizontal run), thereby deviating from the M-241 criteria.
This deviation was considered acceptable by the stress engineer..
During the as-built reconciliation program, a detailed analysis was performed (dated March 25, 1982) and the results showed the stress levels and support loads were acceptable (see attached Calc. for results of the computer run).
Eh
PIPING STRESS
SUMMARY
CHECK ANO COVER SHEET ASME SECT. III, CLASSES 2-6 3
DATE 032482 PAGE 3
PROJECT JOB NO.
8856 PLANT DESIGN GROUP SYSTEM SP-HCB= 109-1 8 2
CALC NO 5268 ISO NO REV NO LOCATION ~
MAXIMUM ALLOWABLE COMPUTED DESIGN OF MAXI MUM COMPUTED STRESS CONDITION LEVEL END ELEMENT STRESS(
PSI)
(
PSI)
ALLOWABLE SUSTAINED LOADS EON.
8 2
4 SH 3617
.203 17800 OCCASIONAL LOADS EON.
9 52 50 E
52 17768 1.2 SH 21360
.832 OCCASIONAL LOADS EON.
9 52 50 E
52 1.8 SH 23014 32040
.718 THERMAL EXPANSION EON.
10 60 M
60 8 60 M
SA 7378
.264 27950 h
REFERENCE CALCULATIONS:
WEIGHT THERMAL EXP SE I SMIC-INERTIA PORTION SEISMIC-ANCHOR MOVEMENT DYNAMIC OTHERS PREPARED BY REVIEWED BY APPROVED BY SIGNATURE
@F IN
STRESS ANALYSIS TITLE SP-HCB-109" 1 '6 2
PROUECT NUMBER
8856 PROBLEM NUMBER 52GB USER L. MYATT LOAD CASES
ALL E 101/12 DATE 032482 (3
PAGE 31 ELEMENT FROM TYPE TO TITLE SUSTAINED LOAD EON 8 PO/4T
. CALC ALLOW PSI PSI PSI PO/4T PS I.,
CODE SC374, CLASS 2
OCCASIONAL LOAD LEVEL 8 LEVEL C EON 9 EON 9 CALC ALLOW CALC ALLOW PSI PSI PSI PSI LEVEL D EON 9 CALC ALLOW PSI PSI THERMAL EXPANSION EQNS 10/11 CALC ALLOW PSI PSI NON-REPEATED ANCHOR MOV EON 10A CALC ALLOW PSI PSI 2
TNGT 4
4 TNGT 6
6 TNGT 8 8 8 8 BEND 8
M 8
M BEND 8
E 8
E TNGT 10 10 TNGT 12 12 TNGT 15 15 TNGT 20 20 TNGT 25 B
25 8 BEND 25 M.
25 M
BEND 25 E
52 200 1831 52 1226 1033 52 1033 1184 52 1184 1298 17800 17800 17800 17800 17800 17800 17800 17800-52 1298 17800 1255 17800 52 36 17 17800 2478 17800 52 2478 17800 1 130 17800 52 1 1 30 17800 569 17800 52 S69 17800 1070 17800 52 1070 17800 1480 17800 52 1480 17800 1 192 17800 52 1 192 17800 200 17800 52 52
~
52 52 52 52 52 52 52 52 1019G 7 'l26 7126 3486 2 '1360 21360 21360 2 1360 3486 21360 1980 21360 1980 2 1360 2588 21360 2588 21360 4097 21360 4097 2 1360 3765 21360 3765 21360 2306 2'1360 2306 10886 21360 21360 5464 5849 21360 21360 5849 21360 7 193 2 1360 7193 6544 21360 2 '13GO 6070 2 1360 5464 21360 15491 10669 10669 5003 5003 2928 2926 4538 4538 6405 32040 32040 32040 32040 32040 32040 32040.
32040 32040 32040 6495 32040 5833 32040 5833 32040 4001 32040 4001 13455 32040 32040 14966 6016 32040 32040 6016 32040 12657 32040 12657 13529 32040 32040 10796 32040 14966 32040 0
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0 0
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0 00.
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0 0
0 0
EXCEEDED ALLOWABLE IN EOUAI'ION 10, EOUAI'ION 11 USED
~ +
EXCEEDEO ALLOWABLE
STRESS ANALYSIS ME 101/ I2 DATE 032402 PAGE 3l ELEMENT FROM TYPE TO TITLE SUSTAINED LOAD PO/4T PSI EON 8 CALC ALLOW PSI PSI I 0/4T PSI CODE SC374.
CLASS 2
OCCASIONAL LOAD LEVEL 8 LEVEL C EON 9 FON 9 CALC ALLOW CALC ALLOW PSI PSI PSI PSI LEVEL 0 EON 9 CALC ALLOW PSI PSI THERMAL EXPANSION EONS 10/11 CALO ALLOW PSI I
PSI NDN-REPEATED ANCHOR MOV EON 10A CALO ALLOW PSI PSI 25 E
TNGT 30 30 TNGT 35 35 TNGT 40 40 TNGT 43 43 TNGT 45 8 45 8 BEND 45 M
45 M
BEND 45 E
45 E
TNGT 50 B
50 8 BEND 50 M
52 54 TtlGT 50 M
BEND 50 E
50 E
Tt!GT 52 52 52 52 52 52 52 1255 1 101 17000 17000 1101 1729 17800 17000 455 909 909 606 606 502 502 579 17800 17800 17000 17000 17000 17000 17800 17000 579 940 940 1052 1052 1119 1119 1347 1577 399 17800 17000 17000 17000 17000 17800 17000 17000 17800 17800 1729 17000 455 17000 52 6544 2 1360 4639 2 1360 4639 21360 6438 2 1360 52 '438 5253 52 62 5253 11347 1 f347 12639 21360 21360 2 '1360 21360 21360 21360 52 52 14304 14355 14355
'1 3 106 13106 13050 13050 13404 13404 17768 2 1360 21360 21360 21360 21360 21360 2 1360 21360 21360 2 'l360 5'2 13311
. 21360 400 1
2 1360 12639 2 1360 14304 21300 13531 32040 8909 32040 8909 9814 90 f4 7701 7701 15782 32040 32040 32040 32040 32040 32040 15508 15674 15674 16271 16271 23014 32040 32040 32040.
32040 32040 32040 10369
'32040 9427 32040 15782 32040 16277 32040 16275 32040 17440 32040 17440 32040 17035 32040 17035 32040 15508 32040 0
0
~
0 0
0 0
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1117 1952 I
,1952 6200 6200 3748 27950 27950 27950 27950 27950 27950 3748 27950 1976 27950 1976 1258 1259 507 27950 27950 27950 27950 507 27950 658 27950 2 108 2204 2204 2151 27950 27950 27950 27950 657 27950 1021 27950 1821 27950 2089 27950 2009 27950 2 108 27950 0
0.
54 lt4GT 54A 54 A TNGT 56 56 TNGT 56A 52 52 399 172 172 167 167 77 17800 17000 17000 17000 17800 17800 52 52 400 1
3262 3262 1951 2 1360 21360 21360 2 1360 1951 21360 27 15 2 1360 9427 7170 32040 32040 7 170 32040 56 12 32040 5612 32040 67 10 32040 625 2088 27950 27950 2088 27950 1458 27950 2151 27950 625 27950 0
0 0
0 0
0 EXCEEOEO ALLOWABLE IN EOUAT'ION EXCEEDED ALLOWABLE 10, EOUATION fl USED
STRESS ANALYSIS
'IE 10 'I/12, DATE 032482 Q
PAGE 3
CODE SC374, CLASS '2 ELEMENT FROM TYPE
'10 T I TLE 75A TNGT 00 15 1NGT 82 82 TNGT 04 04 TNGT 06 06 TNGT 80 52 TNGT 90
- 90 TNGT 92 10/4r PSI EON 8 CAI.C ALLOW PSI PSI 52 52 52 52 52 52 l
155 17000 250 l7800 2992 17000 l07 9 I7800 1079 17800 505 17800 585 17800 163 17000 163 17000 52 17800 2660 17800 157 17000 157 17000 52 17800 SUSTAINED LOAD PD/4T PSI 52 52 52
'52 52 52 4295 2 1360 5583 2 13 GO 15695 2'13GO 6436 21360 64 15 32040 9528 32040 15500 32040 6459 32040 643G 3470 21360 213GO 6459 4055 32040 32040 3478 2 1360 925 21360 925 21360 52 2 'l360 16507 2 1360 914 21360 914 21360 53 21360 4055 32040
'l061 32040 1061 53 32040 32040
'8838 32040 1118 32040 1118 32040 S3 32040 OCCASIONAL LOAD LEVEL 8 LEVEL C EON 9 FON 9 CALC ALLOW CALC ALLOW PSI PSI PSI PSI 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 LEVEL 0 EON 9 CALC ALLOW PSI PSI THERMAL EXPANSION EONS 10/11 CALC ALLOW PSI PSI 152 27950 300 27950 969 27950 312 27950 312 27950 0
27950 0
27950 0
27950 0
27950 0
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27950 0
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NON-REPEATED ANCHOR MOV FON 10A CALC ALLOW PSI PSI
'EXCEEDED ALLOWABLE IN EOUATION 10,.EOUATION 11 USED EXCEEDED ALLOWABLE ~
RESTRAINT LOAD
SUMMARY
T ITLE SP-HCB-109-1 8 2 PROJECT NUMBER :,8856 PROBLEM NUMBER
5268 USER L.
MYATT LOAD CASE ME IOI/I2 DATE 032482 PAGE 30 DATA TYPE PT LOAD FX GLOBAL FORCES (LB)
FY FZ GLOBAL MOMENTS (FT=LB)
MX MY IIZ DISPLACEMENT (IN)
DX DY DZ 2
ANC'2 RAD
~ ~glo 12 RAD
~O 20 RAD
~~~ 0 20 RAD 0
35 RAD VTOI THRM01 SE I SUP SE IS'EM SAM01 SAM02 WTOI THRWOI SE I SUP SEISEM SAM01 SAM02 MTO I TIIRMOI SEISUP SE ISEM SAMO I SAM02 HTOI THRMO I SE I SUP SE I 5'EM SAMO I SAM02 WTOI THRW01 SE I SUP SEISEM SAW01 SAM02 QTO I THRW01 SE I SUP SEISEM SAM01 SAM02
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RESTRAINT LQAD
SUMMARY
TITLE SP -IICB-109-I PROJECT NUhlBER: 8856 PROBLEM NIII4BER: 5268 USER L.
MYATT LOAD CASE ME IQI/I 2
'DATE 032482 PAGE 304 DATA TYPE PT aS Rno
~~'A LOAD WIQ I
'II IRMQ SE I SUP SEISEM SAhlp I SAt402 "12.
17:
155.
333.
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FX FY FZ 5.
49.
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.o"
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RESTRAINT LOAD
SUMMARY
TITLE SP-HCB-109-1 6
2 PROJECT NUMBER
8856 PROBLEM NUMBER
5268 USER L.
MYATT LOAD 'CASE ME IOI/I 2 DATE 032482 PAGE DATA TYPE PT 56 RAD LOAD WTO I THRM01 SE I SUP SEISFM SAMO I SAM02 0.
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RESTRAINT LOAD
SUMMARY
TITLE SP -IICB-109-1 6 2
PROJECT NUMBER : 8856 PRDBI.EM NUMBER
6268 USER L.
MYATT LOAD CASE ME 10 I/I2 DATE 032482 PAGE 75 RAD WT01 TIIRMO1 SE I SUP SEISEM SAM01 SAM02 DATA TYPE
-LOAD PT A
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PP&L INVESTIGATION FINDINGS FINDING 1 USE OF INFORMAL MEMORANDUMS IN THE SMALL PIPE DESIGN PROCESS Small piping system design which was not accomplished by detailed analysis (i.e. ME-101) was performed in accordance with the requirements of Revision 3 of Specification M-241, Desi n Criteria for Sim lified Anal sis of Small Pi e.
Revision 3 of M-241 was issged on 5/21 81.
Since that time numerous informal and uncontrolled memos and notes have been written with the intent that the information -they contain be used in conjunction with or in lieu of the criteria established in M-241.
An initial cursory review of the information contained in these informal documents indicates that Spec.
M-241, Rev.
3 did not provide the Resident Engineering Group with pertinent technical direction in certain areas of small pipe design.
Note:
Revision 4 of Spec.
M-241 was also reviewed.
As of 8/11/82 the spec.
was in a final state, but lacked, final sign-off (per Bechtel).
RESPONSE
Bechtel was asked to address the above finding.
The following is their response:
The changes made to M-241 by way of memorandums can be classified into two basic categories:
a.
Direction to engineers from supervision on alternate refined ways to qualify an as-built.piping system.
b.
Clarifications and amplifications of existing criteria, as it is virtually impossible to cover all as-built possibilities in a criteria such as M-241.
The memorandums covered
items, such as:
o Specific spans for certain pipe sizes in certain locations such as Diesel'Generator Buildings.
o Means of evaluating piping: overh'ang.;;,"
t o
Special cases to 'apply refinements to geometry adjustment factors.
Bechtel's review of these memos indicates that some of them should haye been incorporated into the criteria document.
Action was taken to incorporate all of the memos into M-241, Revision 4.
FINDING 1-1 CONT'D Page 2 of 2
Independent review of the memos was performed at the time of their implementation.
The contents of the memos provide a technically acceptable basis for the small piping systems.
Note, however, that if the piping system is qualified utilizing 8-241, Rev. 3, but without the benefit of some or all of the memorandums the result would be an acceptable system meeting the design criteria with the consequence of having a more conservative design.
The M-241 design criteria and its implementation, represents a unique case in the following ways:
o Wi 241 was issued originally as a typical design criteria.
However, it was in actuali'ty used in a unique manner as an as-built reconciliation document.
o Con'struction requirements necessitated changes to design as issued.
o Engineering had the charter to qualify the as-built piping system to new loads utilizing the design criteria.
This necessitated creation of clarifications, refinements, etc.,
to qualify installed systems and minimize the hardware changes.
o The issue of the memos was an on-going process to resolve different as-built and technical problems as they were identified.
o The normal design criteria feedback process allows for the evolution and refinement of criteria as construction proceeds and problems are identified over a long period of time.
By definition, for small piping, this process was compressed into the post installation p'eriod.
Based on the above, the M-241 issue is unique in its character, circumstances and its usage.
CORRECTIVE ACTION PP&L will require BT Project Management to reemphasize that project procedures must be used to alter design documents and that greater caution must be exercised by engineering supervision in deciding what is a change to the design document and what i.s normal supervision to engineer guidance.
This corrective action will be completed by September 30, 1982.
STATUS-PP&L, with implementation of the above corrective action, considers this finding closed.
FINDING 1-2 As Built Drawin Discre anc As a result of the walkdown of the piping shown on SP-HBD-1538-1 (Rev.
8, 5/7/82) and review of the associated documents several discrepancies were noted which indicate that the design/document control system was not adequate to assure the proper processing of the documents in question.
It appears that the interface between the FE group and RE group was not clearly defined and that communications within the RE group was not uniformly established.
RESPONSE
Bechtel was asked to address the above finding.
The following is their response.
This finding involved the deletion of a hanger between Rev 8 and Rev.
9 of Drawing SP-HBD-1538-1.
The design was reconciled first against Rev.
8 which indicated the hanger was installed.
Later, when Rev 9 of the drawing was issued showing that the hanger was not installed, Project Engineering judged the installation acceptable.
This discrepancy, involving erroneous reissuance of a cancelled detail drawing as "as-built" and reflecting the erroneous "as-built" on the small pipe isometric is considered an isolated occurrence.
Project Engineering has reviewed the situation and confirmed that the error had no adverse affect on the design.
Procedures applicable to similar activities in Unit 2 will be reviewed to ensure adequate direction is provided to preclude future similar discrepancies.
Refer to the response to NRC.Qxestion 18 for FE-RE interface STATUS PP&L concurs that this was an isolated occurrence with no impact on plant safety.
This finding is considered closed.
FINDING 1-3 Use of En ineerin Jud ement The use of engineering judgement to reconcile as-built conditions in the small piping program is not defined in either 3&241 or <&213.
Discussions with R.
E.
Group (Bechtel) indicated that distinction between major and minor changes defined in M-213 Sections
4. 15 and 4. 16 were applied to large piping
( 2") only.
Identification of major and minor changes on small piping is based solely on Resident engineer's conception/judgement.
RESPONSE
Bechtel was asked to address the above finding.
The following is their response:
During the small pipe as-built reconciliation, the as-built pipe support details were compared with the latest engineering design.
The differences between the two were either classified as major or minor changes.
The major/minor classifications and disposition was dictated by the following:
o Engineers involved in the program were indoctrinated in the use of M-241 and its basis; starting with Phase III (hydrodynamic new loads) evaluation performed during late 1981.
%his training has been documented.
o The persons involved in the as-built program are qualified engineers and designers adept in the small pipe analysis and design.
o The judgement exercised was based on review of the back-up engineering calculations and gauging conservation or margin involved.
o The judgment exercised by the engineers was concurred with by a checker and approved by other qualified and experienced engineers.
It is important to reiterate that the H-241 design criteria contains built-in conservatism.
The M-'241 permits use of judgement as demonstrated satisfactorily by performing detailed analyses.
Note:
M-213 Par.
4.15 and 4.17 refer to major/minor revision program for pipe support details.
'Ihis involves the latitude permitted to fiel,d engineering during support installation.
The major/minor changes noted in the as-built calculations are to classify the type of changes and have no relevance to M-213 Par.
4.15
& 4.16.
STATUS PP&L finds the above response satisfactory and considers this finding closed.
FINDING 1-4 Thermal Interference,Walkdown Drawin Discre ancies It was found during review of the thermal interference walkdown (required by M-213) performed by the Stress Engineer (R.E.
Group) that the field ISO 8 SP-HCB-133-1 Rev.
9 was used for the walkdown (done on 10-27-81).
The latest revision of this ISO was Revision 12 (issued 9/28/81).
There is no procedural guidance criteria that requires the R.E.
Group to assure that they are using the latest revision.
RESPONSE
Bechtel was asked to address the above finding.
The following is their response.
The Resident Engineering Plant Design stress group was responsible for performing a visual walkdown of Q-piping systems for thermal interferences per Spec.
8856-M-213.
To perform the walkdown, the stress group would collect the most current isometrics of the piping systems and assemble the drawings into walkdown packages.
The packages would then be logged and assigned to the engineers responsible for completing the walkdown.
In the general flow of work there exists a time frame from the day the drawings were obtained to the actual date the system was walked.
During this time frame, a possibility exists that an upper revision of the drawing could have been issued, by construction.
This possibility,
,however, does not affect the technical adequacy -of the walkdown since the walkdown was based on the installed piping systems in the field and not on the isometric drawings.
The drawings were to be used by the stress engineers for reference only.
The actual results of the walkdown were obtained by reviewing the piping system as installed and how it would behave in relationship to existing components/structures as visually observed in the field.
Based on the results of visually inspecting the installed piping systems the stress engineer completed the "Thermal Interference Walkdown Summary Sheets" indicating the date of the
walkdown, who performed it, piping isometrics
involved, and the results of the walkdown.
These walkdown summaries were reproduced and attached to the RIC's sent to construction.
The EfC's identified the results of the thermal walkdown.
Subsequent to the walkdown F.E.
assumed the responsibility for maintaining and identifying interferences for further resolution.
The field program covered interferences which could be generated from new piping or major reroutes (e.g.,
DCP work).
Thus the thermal interference walkdown and follow-up field program are considered an adequate means to verify design intent.
STATUS PP&L finds the above response satisfactory and considers this finding closed.
FINDING 1-5 Desi n Control Measures
10CFR50, App.
B, Criteria 83 requires that design control measures be established in procedures.
Findings 1-1, 1-2, 1-3, 1-4, 2-1, and several other observations indicate areas that would require procedural definition and areas that there were breakdowns in the implementation of the procedural controls.
RESPONSE
Bechtel was asked to address the above finding.
The following is their response.
Document Control Desi n Direction and Desi n Guidance The SPA's are issued as design direction and not guidance.
In the case of SPA-600 there was a breakdown in the process implementing engineering revisions and this was an improper practice.
In the case of small piping, construction is typically issued a design package consisting of small pipe area drawings, small pipe SDS and summary sheets (wherein SPAs are called out).
Recognizing the need for changes to pipe routing to accommodate local conditions and to avoid interferences with field routed commodities such as conduits, junction boxes, etc.,
a reroute allowance has been provided.
This allowance consists of 20K of the length between anchor points.
Consequently, construction is authorized to make changes to pipe supports that do not affect the intended"design function of the support (Ref. M-213 Para.
4.17).
These changes are shown on the as-built drawings and forwarded to engineering for reconciliation and approval.
Thus, the small pipe
.design issue is considered a direction rather than design guidance.
Bechtel, as a general practice, does not issue design guidance type of design documents for construction.
Specification and drawings define the permissible deviations and, in general, as defined by Specification 8856-G-17 for FCR 6
FCNs.
A review of the design without case by case review by engineering (BLP-22093 Response Xo Question
18) indicates that there are well defined deviations and feedback mechanisms for engineering review.
G-18, G-19 and E-53 represent cases where the design criteria was established for construction use with a built-in programmatic requirement for monthly submittal to engineering for review and acceptance.
A variation to the above documents is the case where a scope document is issued to construction (Unit II 2" and smaller piping design).
Field has generated procedures FP-P-22 for the scope of work delegated.
This procedure has been reviewed and approved by engineering via. a memo.
In conclusion, design output documents issued to construction are considered design direction.
Finding 1-5 Cont'd Page 2 of 4 Corrective Action (for Hangers Only)
Field procedures will be revised as applicable to indicate time constraints on this review by field engineering of engineering designs and also to provide documentation of this review with appropriate approval requirements.
In addition, MAPPER (computerized logs) will be utilized to reconcile differences between engineering issued and field issued P.S. details.
(g will review this documentation to verify if there is any impact on the inspection performed.
Im lementation Field Engineering procedure review and revision by September 30, 1982.
Informalit of As-Built Documentation Transmittal In the case of small piping as-builts, the packages were forwarded to engineering via formal transmittals and receipt duly acknowledged.
Changes to as-builts were forwarded to construction via Red-lines and Action Item Lists transmitted via memos.
These changes in turn were constructed and returned to engineering on as-built drawings via transmit tais.
There were instances where engineering did ask for clearer prints or missing documents from field engineering or the Print Room.
In cases where as-built drawings were obtained from field engineering, it was followed up by formal transmittal as noted above.
In summary, we consider the process of document transmittal between field and engineering to be-proper and controlled.
Use of SPA's b
RE Mhen the SPA's were issued for construction, a determination was made by field engineering as not requiring implementation and distribution through the Print Room.
This resulted in RE not receiving copies of SPA's as part of the Print Room distribution.
However, as part of the engineering distribution from SFHO, the REs did receive the'PA's..
Thus, the use of the latest SPA's during the as-built reconciliation,was',"
ensured Use of Red Line Drawin s for Evaluation During the final as-built reconciliation process, it was a conscious decision to avoid delays and possible drafting.transposition errors by not incorporating g.C. red-line markups on the as-built pipe support details.
Finding 1-5 Con t '
Page 3 of 4 The Q.C. red-line process, however, did not result in lack of as-built drawing control.
The as-built sticker and signature by field engineering prior to transmittal of the as-built drawings to engineering for reconciliation established the Q.C. red-line drawing as the controlled as-built, and this was used for the reconciliation.
Except for the piping as-built program and seismic instrument piping the red-line drawing practice is not employed on the project in engineering and construction.
It should be pointed out that construction sketches are employed during construction, for example, rebar placement.
However, these construction sketches are not used for inspection or for engineering use.
Overview of Desi n Document Control Process Design Document Control within project engineering and field construction are under strict controls" by engineering administration and field procedures.
These documents are transmitted between project engineering and field construction'y a controlled document notably the data transmittal form or an engineering memo to construction (EMC).
When project engineering develops a design document, e.g.,
a drawing, it is assigned an appropriate number and is placed under revision control when it is,to be issued for construction use.
~ -
This design document when approved is sent to project administration for logging and reproduction,, then distribution is made per the master logging and distribution schedule.
A design document that is to be sent to the field will be attached to a data transmittal form which has the requirement that the receiver sign off and return the acknowledgement copy to the sender.
The field construction print room has procedures for the control of design documents (drawings,
FCRs, FCNs, DCNs) sent to them.
They also have the data transmittal form which they use and require return acknowledgment from other organizations.
Field procedures require that engineering design documents be distributed'o specific work areas (stick files) within two days after receiving them.
Bechtel quality assurance department has reviewed and approved these procedures which were developed to meet the requirements of our nuclear quality assurance manual.
These procedures are subjected to audits by quality assuxance'o'erify compliance to the requirements.
Finding 1-5 Cont'd Page 4 of 4 CORRECTIVE ACTION BT Project Mi nagement will reemphasize, with all supervision, the need to comply with document control procedures and the requirements to verify that all quality related activities are being done with the
'urrent revision of controlled documents.
BT supervision will review this information with all affected personnel by September 30, 1982.
STATUS-With implementation of the above corrective action in addition to the corrective action of 1-5i, PP&L considers this item closed.
Finding 2-1:
SP and SPA Drawin Control Contrary to Field Procedure FP-P-ll Rev.
6, the Lead Field Small Pipe Hanger Engineer did'ot forward 274 SPA drawing revisions in a timely manner.
RESPONSE
Refer to the response to NRC Question No.
11.
STATUS Corrective action of Finding 1-5 is also applicable to this Finding.
With the implementation of the above corrective action, PP&L considers this item closed.
FINDING 2 Ins ection of Detail 600 Clam s Bechtel Specification 8856-M-213, Appendix F was issued by Project Engineering to provide Bechtel QC with definition of. the inspection attributes and acceptance criteria required to be verified to assure that hangers are installed correctly.
These are the critical attributes defined by Project Engineering.
A review of Appendix F revealed that it contained no criteria for. clamp ear gap measurements for friction type anchor clamps to assure positive gripping of the pipe by the clamp.
The investigation team concluded that this deficiency resulted 'in PL-NCR-728 which identifies that there are anchor clamps installed'ithout adequate pipe gripping.
The team determined this to be a potential finding with no safety impact because the clamps in question have been identified for correction and the only question remaining regards any other critical attributes that may be omitted in Appendix F.
RESPONSE
Bechtel was asked to prepare a response to the above finding.
Their response is as follows:
The Detail 600 and SPA 600 details have been revised to show, proper bolt
lengths, clearance requirements, contact requirements and other general installation requirements.
On Unit 1 a program for complete reinspection and correction, as required, has been completed by Plant Staff.
To prevent recurrence on Unit 2, SPA's are not being utilized.
Individual support details are being generated (like large pipe supports).
Note:
See also the response to NRC Questions 4; 5, 6, 7,
11, and 12.
See also the corrective action on Finding 2-4.
STATUS-With the implementation of the above corrective action, PP&L considers this item closed.
The generic implications of adequ'ate inspection and verification programs for prefabricated components is covered elsewhere.
k P
r FINDING 2-4 Ins ecti Criteria for Pref b i t d C
ents Specification 8856-M-213, "Technical Specification for Installation, Inspection, and Documentation of pipe supports, hangers and restraints" does not provide criteria with regard to installation and inspection for all vendor fabricated components such as "Detail 600" and sway struts.
Examples:
1.
There is no inspection criteiia regarding the gap requirements on installed "Detail 600. " Some of these were found to have no gap as documented in NCR No.82-728 (PP&L's) 2.
There is no criteria for installation and inspection of sway struts.
These struts are a complete vendor supplied assembly-with jam nut(s).
The vendor has specific requirements covering how to install the sway struts and how to tighten the jam nut(s).
Yet many struts are found that have their nut(s) not tightened properly as is documented in PP&L NCR 82-794.
RESPONSE
Bechtel was asked to address the above finding.
The following is their response:
The basic premise of the Q.C. inspection of the pipe support is to inspect for attributes delineated in the QCI and as shown on the individual pipe support details and as specified in general terms in Specification 8856-M-213.
At the point of installation inspection, the vendor fabricated components are inspected for items such as mechanical
assembly, identifications,
damage, orientation and settings as applicable.
Other attributes are inspected when uniquely shown on the as-built drawings.
In case of piping systems, it is. worthy of note that selected safety related systems are verified during the power ascension program for thermal expansion, steady state vibration and dynamic transients, to afford further assurance of operability.
Corrective Action o
Bechtel will reemphasize that all attributes absolutely necessary for design intent to be met, will be identified on the design drawings.
o Pipe Support fabrication, installation, and inspection Specification M-213 (including Appendix F) will be revised to (1) amplify the need to inspect for vendor specified requirements and (2) identify all critical attributes on hanger design detail drawings thus establishing the need to inspect for these attributes.
o Project Engineering will review and provide input to QC on hanger QCI's including QCI's functional requirements and design intent.
QC will revise QCI's as necessary.
The above corrective action will be completed by September 30, 1982 STATUS With the implementation of the above corrective action, PP&L considers this item closed.
Generic Concern 1-1:
Uncontrolled Changes to Design Specifications (Ref.
Finding Item 1-1)
RESPONSE
Bechtel was asked to address the above item.
The following is their response:
The practice of. communicating design guidance from the engineering supervisor level to the working engineer level is a necessary and fundamental supervisory function that applies to all engineeri:ng disciplines.
I Such verbal or written communication is often directed towards the clarification of design intent or approach in meeting engineering design criteria or requirements.
This communication should be encouraged in that it improves the overall level of knowledge of the engineers
and, hence, the ultimate quality of the design ouput.
Where this communication extends beyond clarification of criteria, into the actual changes to criteria, the intent is to revise the appropriate criteria document.
The
-'udgment as to what constitutes clarification vs. design criteria changes lies with the group supervisor.
However, the chief engineer in each discipline also plays a role with respect to the technical review of Q Design Control Checklist criteria doucments.
One example relates to electrical separation criteria'E-49.
The manner in which this criteria was revised was appropriate even during the final room turnover process when a significant number of construction questions and 'NCRs were being generated in a relatively short period of time.
In conclusion, we have no basis to believe that there has been a
systematic breakdown in the foregoing process.
Corrective Action PPGL will require Bechtel Project Management to re-emphasize that project procedures must be used to alter design documents and that greater caution must be exercised by engineering supervision in deciding what is a change to the design document and what is normal supervisor to engineer guidance.
This corrective action will be completed by 9/30/82.
STATUS With the implementation of the above corrective action, PPGL considers this item closed.
r Generic Concern 1-2:
Current Detail Drawings Not Utilized by Resident Engineering (Ref. Finding 1-2)
RESPONSE
Bechtel was asked to address the above item.
The following is their response:
The hanger as-built verification program was the only program which
~
involved Project Engineering review of red-line drawings.
The'ther red-line programs (small pipe isometrics and seismic instrument tubing involved incorporation of red-lines prior to Project Engineering review of the drawings.
Bechtel's review of other documents transferred between field engineering and project engineering indicates that formal, controlled procedures were used to transmit design and as-built documents.
A case in point is the transmittal of as-built Liner Plate drawings.
In summry, Bechtel considers the process of document transmittal between project organizations to be proper and controlled.
STATUS PPGL considers this item closed.
0
'G NERIC CONCERN 1-3 USE OF ENGINEERING JUDGEMENT NOT DEFINED (REF.
FINDING 1-3)
RESPONSE
As a result of the Small Pipe Investigation conducted by PPGL a concern has been generated by the NRC in regards to what actions are necessary to verify the validity of the judgements
made, what is planned by PPGL to review additional piping systems and what is necessary to obtain similar information in other areas.
In order to address the first two items it is essential that the scope of these engineering judgements be defined.
It is also important to understand that the Design Criteria (M-241) is the result of rigorous engineering analysis and not judgements of the kind that were addressed in the report.
Therefore, the primary design basis of the small pipe simplified design is not the result of "judgement," but is a design output document.
It is further important to understand that this document contains, by design, substantial built in conservatism.
Therefore, both the fundamental design document and all of the initial design is accomplished using engineering documents that are based on proven analysis.
In order to verify that the installation is in exacting conformance to the final design the "As Buil't Reconciliation ABR)" program is used.
During t is tail end fine tuning process the as built pipe support details were pared with the latest engineering design and the differences were recon-ed either by engineering judgement or additional analysis, when required.
Therefore, the issue is that duri'ng the course of the final reconciliation process did the engineer apply proper judgement as to when further detailed.
analysis was required.
It is important to note that the vast majority of the ABR items are extremely minor in nature (such as:
a lardier size beam was used than required, beam is slightly longer than calcu'.aaron calxea for, etc.)
and this helps to further focus this concern to the small number of items in which it is not clear that adequate judgement was used.
It, is PP&L's position that Bechtel has applied proper engineering judgements in the dispositions applied to the ABR program and the existing piping systems at Susquehanna are adequately designed and built.
This position is based 'on the following:
1)
The engineers involved in the program were indoctrinated in the use of M-241 and its basis as far back as 2nd quarter 1981.
2)
The persons involved in the as-built program are qualified engineers and designers adept in the small pipe analysis and design.
3)
The judgement exercised was based on review of the back-up engineering
'calculations and gauging conservatism or margin involved.-
4 The judgement exercised was concurred with.by a qualified checker and approved by other qualified and experienced engineers.
J
5) Whenever the need for additional care was required added measures and cautions were taken (ex. seismic II/I). This was done prior to the ABR program and is indicative of continuing internal testing and
'pdating of the design process on the part of Bechtel.
6 Whenever this judgement has been questioned on specific items and dditional calculations performed, the, original judgements have een verified as correct.
What PP&L has found during the course of the review is that appropriate documentation trails that effectively recreates the engineer/checker/
approver's thought. process during the reconciliation process are insufficient when tested after the fact.
Additionally, some inconsistencies in uniform application of the judgements were noted.
Therefore, PP&L does not consider modifications to further document. the adequate judgements made on the ABR packages for Unit 1 as required and will not pursue it further. It does consider it necessary to modify the docu-mentation path on Unit 2 in order to prevent similar concerns from arising.
The exact nature of this has not been worked out with Bechtel but is expected to be subject of continuing dialogue over the next several months.
In order to assure the NRC that inconsistencies in engineering judgement are the exception and not the rule PP&L will undertake a
100% review of all the engineering judgements made during the ABR process for the two sample systems used in the Small Pipe Investigation study done by R. J. Shovlin. It is expected this report wi;ll be complete in approximately four weeks and the results submitted to the NRC.
We believe in undertaking the above actions, we have provided complete assurance that the engineering judgements used on Susquehanna Unit.
1 have resulted in a safe and acceptable d
gn and adequate corrective action is being undertaken on Unit 2.
Xt is PP&L's position that the issue of extensive use of engineering judge-ment in the ABR program is unique to piping design process.
The other programs that..might be believed to be in the same category, such as:
cable pulling, have been reviewed and it has been determined that specific criteria were establ'ished in the appropriate specifications and where this criteria was not met detailed analyses were performed.
Since the ABR program is unique to.the piping area.
PP&L believe no additional efforts are required and this satisfactorily addresses the concern.
Generic Concern 1-4:
Quality Related Activities Must Be Done To Latest Design Documents (Ref. Finding 1-4)
RESPONSE-In order to ensure that Bechtel programs for quality related activities are performed to the latest revision of the design documents, the following items come into focus:
o Design documents transmitted between field activities and engineering are distributed and controlled through the Field print room by utilizing
'rocedure FP-G-4.
o The distribution through the Print Room ensures up to date stick files and copies to cognizant field organizations for implementation..
o QC, during their inspections of a component and systems ensures that
. the latest engineering documents are implemented and reflected in the hardware.
(e.g.',
QC utulized engineering approved vendor prints for inspection.)
o Field engineering procedures dictate implementation of engineering issued drawings.
o Use of drawing control logs and MAPPER also enhances the assurance that the latest engineering drawings have been implemented.
In summary, it can'e concluded that procedures, methods and controls exist to ensure that the latest drawings are available to be utilized for quality related activities.
Project Procedures and training emphasize that it is the individual's responsibility to ensure he is using current deisgn information for quality related activities.
The document control index (MAPPER) identifies the current design document information.
S'upervision is responsible to ensure these provisions are properly carried out.
STATUS PPGL considers this item closed.
~ f Changes Made After Walkdown Not Checked to Ensure Design Intent is'Met.
(Ref. Observation 1-15)
RESPONSE-Bechtel was asked to address the above item.
The following is their response.
Changes affecting previous walkdowns or inspections prior to turnover of the areas/systems to PP&L were reconciled in an appropriate manner depending on the specific program involved.
For, example, the seismic ll/1 program final walkdowns were linked to final room turnover.
Subsequent changes were screened on a case by base basis and specific walkdowns performed as required.
tr STATUS-PP&L an work erf Afte'r turnover "to y
p ormed by PP&L forces was reviewed by I
II PP&L RE's to determine possible concerns.
Where items were identified, Bechtel FE or RE inspected the work to insure compliance'o design.
Changes made after walkdown or inspections were tracked and reinspected F
to insure design intent.
PP&L considers this item closed.
RESPONSE-Bechtel was asked to address the above item.
The following is their re-sponse:
Field procedures will be reviewed and revised as applicable to indicate time constraints on review by field engineering of engineering designs and also to provide documentation of. this review with appropriate approval requirements.
In addition, MAPPER ( computerized logs) will be utilized to reconcile differences between engineering issued and field issued P.S. details.
QC will review this documentation to verify if there is any impact on the inspection performed.
CORRECTIVE ACTION-Field Procedure review and revision will be completed by September 30, 1982.
STATUS-With the implementation of above corrective action, PP&L considers this item closed.
r
Generic Concern 2-4:
Lack of Inspection/Installation Criteria for Prefabricated Components (Ref. Finding 2-4)
RESPONSE-Bechtel was asked to address the above item.
The following is their response:
It is Bechtel's judgement that, the pipe support QC inspection represents the only case in point where QC inspection was interpreted to be limited to attributes shown on the as-built drawings and as outlined in Specification M-2l3.
This was a conscious decision to have engineering specify specific attributes for QC inspection.
Other areas encompass specific installation instructions and recommendations indicated by vendor and, as outlined on the design documents.
Inspection of other items such as control systems, mechanical systems and electrical systems is based on QCI's which encompass vendor instructions, recommendations and use of engineering approved vendor prints and drawings.
STATUS PPGL considers this item closed.
0 l
~
4
SMALL PIPE INVESTIGATION PROGRAMMATIC QUESTION RAISED BY THE NRC AUGUST 27, 1982 Investi ation of Other Pi in S stems PP&L Nuclear Department management has completed an extensive investigation of all aspects of the small piping system program. 'lthough the Investigation Team concluded that additional investigations were warranted, they did not have the benefit of the extensive dialogue between the Bechtel and PP&L organizations subsequent to this investigation,.
As a result, PP&L does not feel that an investigation of other piping systems is needed to prove out the integrity of installed hardware.
Validit of En ineerin Jud ements PP&L Nuclear Plant Engineering has committed to provide a complete review, by September 30, 1982, of all the engineering judgements used in the reconciliation process for the two piping systems selected by the PP&L Investigation Teams for their walkdowns.
Calculations will be performed to verify that the judgements were accurate.
Other Field Design Activities Potential for Design Control and En ineerin Jud ement T
e Problems Bechtel was requested to investigate the area and provided the following response which PP&L finds acceptable.
"Review af Field-prepared instrument tubing drawings, and discussions with personnel involved, indicates that similar discrepancies did not occur during that operation in Unit 1.
(These drawings are also reviewed and approved by Project Engineering).
Review of the activities (Raceway, Instru-mentation, and HVAC Seismic Support Design*) indicates clear direction concerning design calculation and independent drawing reviews and approvals.
Review of the actual practices utilized indicates that these activities also did not experience the checking/approval anomalies associated with small pipe hangers.
These activ'ities addressed in FP-E-6, J-4, and M-4 represent the only true design performed by the Field in Unit l."
Or anizational Interfaces S lit Desi n Res onsibilities PP&L Nuclear Department Management was aware that the small pipe design/installation/inspection process on Unit 1 was
cumbersome and difficult to manage.
Steps have already been taken to streamline the engineering process and are being used on Unit 2.
In addition, PPGL, has initiated management level discussions with Bechtel to address the organizational aspects and interface responsibi'lities between the home offices, resident and field engineering organizations; PP&L will attempt to provide the Commission with an update on these activities during the fourth quarter of 1982.
5.
Document. Control Deficiencies This area was investigated thoroughly and Attachment 4 of this letter describes PPGL's actions.
6.
Quality Control Activities - Inspection of Pre-fabricated Items Bechtel was requested to respond to this area of concern.
This response is found in Attachment 4, Generic Concern
~ 2-4.
In addition, PPGL QA will perform a complete review of all QCIs'o assure that manufacturer requirements are included
~ in inspection plans.
This activity will be completed by September 30, 1982.
tachment 6
PPsL Nuclear Department Management
Response
to Conclusion of Small Pipe Investigation Team (Handout 3 of PLA-1275)
Small Pipe 1.
See Item 1 of Attachment 4 of this letter.
2.
See Item 4 of Attachment 5 of this letter.
3.
See Generic Concerns 1-1, 1-2 and 1-4 of Attachment 4 to this letter.
These responses, in effect, recognize the need to re-emphasize certain aspects of the programmatic aspects of small. pipe design.
PPGL Nuclear Department Management feels that this re-emphasis in addition to the normal training provided by Bechtel is sufficient to provide adequate training.
4.
See Handout 4 of PLA-1275.
PPGL Nuclear Department Management considers this response acceptable.
No response required.
6'.
No response required.
GENERIC IMPLICATIONS
l. See Items 3 and 4 of Attachment 5 to this letter.
2.
See Attachment 4 to this letter.
3.
See Item 4 of Attachment 5 to this letter.
In addition, it is the opinion of PP&L Nuclear Department management that more than adequate management attention has been given to this issue.
Specific assign-ments were given to PPGL, QA, Nuclear Plant Engineering and Construction to mon'itor these activities recognizing the hectic pace of activities, particularly in the field; The Investigation Teams were unaware of these assignments, since they primarily focused their investigation and inter-
'views on the Bechtel process.
BACKDATED CALCULATION Item:
1)
Generate calculation (to replac'e missing calculation) for the jet pump inst. line anchors.
Response
1)
A new calculation has been generated to replace the missing calculation for jet pump instrument line anchors.
See Attachment 1 for a copy of the new calculation.
Item.')
Generate FCR (PCR) or PL-NCR as appropriate to verify torque on the 18 anchors.
Response
2)
PP&L has generated an NCR (PL-NCR-82-912; see Attachment 2) stating; "Bolts on hanger SP-DCA-144-H2198 are not torqued adequately to support pipe.
Torque records indicate the bolts on this hanger were not torqued to any specified Value."
The disposition should include the following for all 18 anchors utilizing the plate type design per calc.
//RE-J P-ANCH-C:
1.
Insure hardened steel washers are installed on all bolts.
2.
Insure all bolts are torqued to the values shown on Attachment 3.
3.
Inspect all anchors for two inch'ine contact at four points aft'er bolts have been torqued.
4.
Insure there is an adequate gap between the two halves.
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REFERENCES:
P 4
1 966
~
SK'-
~nlQIQ I 0 8 A L Sg
- i -
P'OI2 ORIGiHAi<R / ~~~=
(I )
SFPO Pipe, Supports Oes ign Manua 1
SFPSM Vol.
1.
(2)
Susquehanna P raj ect SFPSM
~
(3)
Susquehanna Project P i pe Support Oes ign,Cr l ter i a.
a)
Pi p ing 5 2 1/2" Ham. Size, Spec.
8856-M-243 Rev.
0 ~
b)
P 1 p i ng ~ 2" Mam. Size,
Spec, 8856&-241 Rev, 2, (4)
AlSC Manual of S tee 1 Construction - 7th Kdit ian.
(5), Computer Programs.
a)
"STRUDL" Program -
( C 901 ) Vers I an 2, 7
( S td.
P rag ram) b)
"BOLTS" P rag ram '
(CEQ50)
Ref.
Ca 1 c'.
4 Ver i f-02 Rev.
0.
c)
"ANCHOR4 "
P rag ram (ME225)
Ref.
Ca 1 c.
P Ver i f-0 1 Rev
~
0
~
d)
!~P I CLAMF'rogram (ME226) Ref; P/S Staff Ca Ic.
g SC-81 1 0 Rev. 0.
e)
'TELOS" P rag r am (MEQOO)
Ref. Ver lf"04 Rev. 0, f)
"STAND" P rag ram (CE425)
Vers ian-01, Verif-05 Rev.
0.
(6)
ITT'-Qrinne 1 1:
a)
Catalog PH '9 b)
Hanger Stds Qct '8 c)
LCD's Rev.
13.
(7)
Oes l gn of Hei ded 5 tructures by Qmer M.
B 1 adgett, (8)
Formulas for Stress and Stra i n, Fi fth Kd i t i an, R. J
~
Roa rk and M ~ C ~ Young; (9)
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DCN 17557'Attachment 2"
1.
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TOGS iiQT:": INSTRUCTIONS FOR
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"Attachment 3" Page 1 of 2,
Torque Summary
~Han er 8
Pipe Dia.
(in)
Tor ue Req'd (ft-lb)
SP-DCA-136-H2052 SP-DCA-136M2053 SP-DCA-144-H2197 SP-DCA-144-H2198 SP-DCA-144-H2199 SP-DCA-144-H2202 SP-DCA-144-H2203 SP-DCA-144 H2204 SP-DCA-144-H2205 SP-DCA-144-H2208 SP-DCA-144-H2210 SP-DCA-144-H2211 3/4 3/4 3/4 3/4
- 3/4 3/4 3/4 60 60 45 45 45 60 60 60 60 45 45 Special case with 307 bolt s 45
Reference:
Calc.
PRE-JP-ANCH-C.
%j
<<,e 4 Page 2 of 2
Torque Summary Enterior Bolts 0,';
Exterior Bolts
~Heu er 8
Pipe'ia.
(in)
Torque Zuterior Exterior (ft-lb)
(ft-lb)
SP>>DCA-136-H20S4 SP>>DCA-144-H221S SP-DCA-144-H2217 SP-DCA-144-H2207 SP-DCA-144-H2209 SP-DCA-144-H2213 3/4 3/4 3/4 3/4 3/4 3/4 135 60 70
Reference:
Calc.
f/RE-JP-ANCHOR
gI R.
D. iI3, Box 151 A
Su~bury, PA 17801 Hay 14, 1982 Harold Keiser, P.
P.
b L. Site Sup rintendent Susquehanna Steam Electric Station Box>>'67
Berwick, PA
'18605
Dear t{r. Keiser:
I was emoloyed as an electrician-welder at P.
P.
h L. 's Susquehanna Stea Electric Station by Bechtel Power Corporation, through the Internet'onal Brotherhood of'lectrical Workers Local f/165.
Hy tenure wiCh the e'ectriciar
~
was fcur (4) vears, and I was a welder with the ircnworkers f'r thre
(>)
yea for a total of seven (7) years employmertt at Susquehanna Steam Electr'c Stat'.
On ApriL 29,
1982, I received a Mestern Union message that I had been terminated eFf'ective that date.
The reason f'r termination was "red cticn in work force."
The termination notice in itself was incorrect because I had be n given total "property clearance";
tools, badge,
keys, etc.
How could t'",
be>>hen I wasn't even on the jobsite?
I suppcse the security reculat'ons ar flexible.
As an electrician-welder at Susquehanna Steam Electric Stat,'cn, I had more weldin qualiFications Chan any other electrician-welder on the jobsite.
As an evample, during the week of Harch 26,
1982, and Aoril 2,
1982, I was sent to the weld test shcp to upgrade for a special welding job.
The upgrade and
{;he job i~as completed successfully--not even a month previous to my termination, I might add that this testing was done at consideraole expense P.
P.
h L. as well as all the other upgrading I comoleted successf'ully.
1{y
welding qualif'cations must have meant something to the people I worked f'r, because on one'ccasion I know of my Foreman, Sterling F'rantz, and my genera~~
foreman, Doe 'lozniak, falsifying "f'ilier metal withdrawal slips" so t{ at would not loo"e my stainless steel deli-arc welding quali ication (i ilier met must be drawn periodically or ycu automatically loose your qualification).
instance I pointed out can be verif'ed with the records, because they assigne
'he welding to a job that did not exist.
This took place n ar'he middle oF the month of Harch, 1982.
It was ass'igned to the General Electric Proje t, we weren't working with at the time, nor did I have in my possession the equ'ent to do this type of welding.
In the seven years I worked at'Susquehanna Steam Electric Station, I was never written up for any jobsite rules infraction, nor were any cf ny welds classified as bad and had to be reworked.
I was on numerous delicate and specialized welding assignments for other superintendents such as Hr. Jack Ha Hr.
Tom Terr ell, and Hr, Bud Pressell, I
am sure they could attest to my we'bility and my competenc as a good employee.
0
P, p,
5 L, -Sx e Supe ~vtendent
y. 14, 1982 e had to be a
~ eouc 'on Ln
- d t' the work force at Susquenanna Steam f ether e ld h v chosen a less qualified person Elec:r~ c Stat t'on I
am sure they cou ave d
t was a personal conflict between lf, As far as I am concerne
, i eman N
and my superintendent, Lo Hickey.
myself, my general
foreman, f
eman Joe
oznia, an m
t P.
P, h L., because now n will onl result in an added'expense o
th ld t
get the qualificat~ ons I already they w'l have to upgrade another we er o ge
.possessed.
ey w' d
Th ill be needing this specialized weld'no again.
n, I ho e you will not consider Thank you for your time andconsid rat'n, h
ld be disoruntled ex-emo oye u
1 b t I thought acme of these facts shou e
I
."ou+,'
o f fact I have more documentation in my brought to licht.
As a matter o
ac na ains of my oossessions where a
o o
I h d t d
"government jobs" for the personal gains o
my
,superiors, at P.
P.
h L. 's expense.
Sincerely,
/+~~ f/ /4i~~
Thomas H. Pickering THP:cp cc:
Oenny Webster, Project tlanager Bechtel Power Corporation Susquehanna Steam Electric Station Box 384
Berwick, PA 18603
'Baiter Ross, Lead F'I eld 'tleld Engineer Bechtel Power Corporation Susquehanna Steam Electric Station Box 584
Serwick, PA 18605 United States Nuclear Regulatory Commission
~iencio Palladino, Commissioner Victor Gilenski, Commissioner c/o NRC
'washington, OC 20555 Susquehanna Alliance
~26%- flarket Street Lewisburg, PA 17837
3 PENNSYLVANIA POWER 8( LIGHT COMPANY REPORT ON INVESTIGATION OF ALLEGATIONS -
THOMAS H.
PICKERING SUS(UEHANNA SES PROJECT AUGUST 12, 1982 JOB 8739888-82 DATE ISSUED:
8/19/82
August 12; 1982 Mr. N.
W. Curtis:
We completed a review of the allegations made by Mr. Thomas H. Pickering of Sunbury, Pennsylvania in his May 14, 1982 letter to PPSL's Susquehanna Plant Superintendent.
Mr. Pickering sent copies of the letter to Bechtel
'Power Corporation (Bechtel),
the Nuclear Regulatory Commission, and the, Susquehanna Alliance.
Mr. Pi ckering subsequently sent the letter to his State Senator and State Representative.
They requested a reply from PP8L.
Mr. Pickering was an electrician-welder employed for about seven years by Bechtel Power Corporation at Susquehanna SES.
Bechtel's records show they terminated him on April 29, 1982 due to a reduction in force.
In his letter Mr. Pickering:
0 stated that on one occasion his foreman and general foreman falsified a welding document so that he would not lose his welding qualification;
~
said he had to do unauthorized work, "government jobs",
for the personal gain of his superiors;
~
questioned why he was terminated since he had more welding qualifications than'ther electrician-welders; and
~
questioned-Bechtel's property clearance pr'ocess and the security procedures regarding his termination.
The purpose of our review was to determine the validity of Mr. Pickering's statements and their implications relative to the construction of the Susquehanna Project.
Our review included a meeting with Mr. Pickering to obtain additional information.
Also, we reviewed Bechtel's records and interviewed appropriate Bechtel supervisors and union employees, Furthermore, we reviewed the records pertaining to the requalification of other welders..
OPINION AND
SUMMARY
Our. review disclosed that the records supporting Mr; Pickering's
'. requalification were improper.
Mr. Pickering indicated and our review
'howed that this practice was not widespread.
Furthermore, he stated that the "government jobs" mentioned in his letter actually was only one potential occurrence and.that it was not performed.
Our review of Bechtel's handling of his-.te'rmination did not disclose any improprieties.
Details of the results of our review of the allegations in Mr. Pickering's letter follow.
FALSIFICATION OF WELDING DOCUMENTS Mr. Pickering stated that on one occasion his foreman and general foreman falsified a weld rod withdrawal slip so that Mr. Pickering would not lose his welding qualifications.
He later explained that he obtained the weld rods and then merely returned them unused.
Mr. Pickering told us that this was the only instance he was aware of and that such occurrences were not widespread.
Bechtel's Welder gualification procedure required that welders periodically use the weld processes for which they were tested and qualified.
Otherwise, they were no longer allowed to do that type welding and had to be retested and requalified.
Bechtel updated welders'ualification records based on completion of a. weld rod withdrawal authorization for a particular filler 'metal.
These authorizations were prepared before a welder withdrew welding rods.
This procedure presumed that the welder would perform welding on an actual job.
Withdrawal of welding rods for non safety-related work only required a craft foreman's signature.
For welding on nuclear apd safety-related
systems, Bechtel's guality Control Engineer and Welding Engineer also signed and authorized the withdrawal of welding rods.
Also, the guality Control Engineers verified the qua'lity of the welding.
Our review disclosed that the records supporting Mr. Pickering's requalification were improper, and one aspect of Bechtel's welder requalification program needed improvement.
Mr. Pickering's foreman prepared and signed the withdrawal authorization.
Mr. Pickering's foreman requisitioned a container of stainless steel welding rods which Mr. Pickering supposedly used on a welding job for General Electric Company.
Our review of General Electric drawings and discussions with General Electric and Bechtel personnel disclosed that this withdrawal was not proper for the job specified on the withdrawal authorization.
THis job did not involve a nuclear or safety-related system.
Our tests of weld rod withdrawal authorizations for the requalification of other welders did not disclose any improprieties.
Based on. ou'r review we are satisfied that the situation mentioned by Mr. Pickering was not a routine practice and did not jeopardize the construction of a safe, reliable plant.
As a result of Mr.
Pi ckering's letter, PP8L's Nuclear guali ty Assurance section audited Bechtel's Welder gualification Program.
The audit recommended a change in the method of updating welder qualifications.
Subsequently, Bechtel changed their procedure to require that when they notify a welder that his qualification wi 11 expire, a Field Welding Engineer must witness and verify the quality of the welding.
We believe that this change will prevent improper occurrences in the future.
PERFORMING "GOVERNMENT JOBS" Mr. Pickering mentioned in his letter that he had documentation showing he had to do unauthorized work, "government jobs", for the personal gain of his superiors.
During our meeting, Mr. Pickering showed us a
memo signed by a craft union foreman requesting the making of a "Branding Iron".
He indicated, however, that it was not made since his foreman refused to authorize the work.
None of the individuals'union electricians) mentioned in the memo recalled who requested the item or its purpose.
They also stated that it was not made.
P Bechtel supervisors informed us that they do not, allow workers to do unauthorized work.
We verified that Bechtel discharged employees for such activities.
REASON FOR TERMINATION Mr. Pickering questioned why. Bechtel terminated him since he had high welding qualifications and that because of his termination, Bechtel would have to qualify another welder, resulting in added expense.
Bechtel hired and terminated craft union employees in accordance with the Project Agreement with the unions having jurisdiction for the area including the Susquehanna site.
The unions normally had a referral system which they used to send applicants to Bechtel.
The persons hired and terminated and the selection of the foremen and general foremen was the responsibility of Bechtel supervisory personnel.
As of July 15, 1982 Bechtel employed 442 electricians of which 31 were welders.
From January 1 to July 15, 1982, Bechtel terminated approximately 141 electricians of which ll were welders.
Bechtel records and our interviews with a number of supervisors for whom Mr. Pickering worked at various times on the project disclosed that he was qualified to do more types of welding than other electrician-welders and his welding was of good quality.
Some of these same supervisors, however, disclosed that his performance in other areas was lacking, particularly his productivity and attendance.
During a meeting with Mr. Pickering he stated that he was terminated because he complained to his foreman and general foreman about unsafe working conditions.
We discussed this concern with Bechtel's Safety Supervisor, Mr. Pickering's Superintendent, hi.s foreman and general
foreman, and other union employees.
Our review of Mr. Pickering's termination did not disclose any deficiencies in Bechtel's termination practices.
Furthermore, we concluded that Mr. Pickering's complaints about unsafe work practices were not the basis for his termination.
Although Bechtel personnel stated that they did not anticipate the need for Mr. Pickering's welding skills at the time they terminated him, Bechtel later trained and qualified another welder at an approximate cost of $ 1,500.
UESTIONABLE PROPERTY CLEARANCE AND SECURITY PROCEDURES Mr. Pickering questioned Bechtel's property clearance process and security regulations regarding his termination.
When employees were not at work at the time Bechtel terminated them, Bechtel procedure was to notify them at home by telegram.
This resulted in reduced labor costs.
On April 29, 1982 Mr. Pickering left
4 work at noon.
Later that day, Bechtel decided to terminate Mr. Pickering and they sent him a telegram notifying him of su(,:h action.
Shortly thereafter, Bechtel mailed a formal Termination Hotice which included a
Property Clearance.
We concluded that the procedures Bechtul used in terminating Mr. Pickering were cost effective and did not violate any site security regulations.
REVIEW OF REPORT On August 12, 1982 Messrs.
M. P.
MormaI, and B. A. Yatko of the Auditing Division reviewed the contents of this i eport with Mr. H.
W. Curtis, Vice President
- Engineering and Construction - Huclear.
Auditing Division R.
F. Lichtenwalner cc:
Ms.
Mr.
Mr.
Mr.
Nr.
Mr.
Mr.
Mr.
Mr.
Mr.
L. C. Bartholomew J.
R. Calhoun R.
H. Featenby J.
T. Kauffman H.
W. Keiser E.
F. Reis A. R. Sabol J.
H. Saeger R. J. Shovlin -'~
G.
F. Vanderslice

PLA-1288, Forwards Rept of Outlined Actions & Conclusions Resulting from Util Investigation & Commission Concerns Re Small Pipe Program,Per 820811,18,25 & 27 Meetings

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PLA-1288, Forwards Rept of Outlined Actions & Conclusions Resulting from Util Investigation & Commission Concerns Re Small Pipe Program,Per 820811,18,25 & 27 Meetings

Text

Dear Mr. Martin:

Response

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SUMMARY

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