View source for GO2-83-870, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-38.Corrective Actions:Deficiencies Reviewed Against Required Hanger Function.Hangers Determined Adequate

{{Adams
| number = ML20080T196
| issue date = 09/26/1983
| title = Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-38.Corrective Actions:Deficiencies Reviewed Against Required Hanger Function.Hangers Determined Adequate
| author name = Carlisle C
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
| addressee name = Martin J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION V)
| docket = 05000397
| license number = 
| contact person = 
| document report number = GO2-83-870, NUDOCS 8310200200
| title reference date = 08-30-1983
| package number = ML20080T177
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 35
}}

=Text=
{{#Wiki_filter:g                                              -
r u    ,
Washington Pul,lic Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 l
Docket No. 50-397 September 26, 1933 G07-83-870 Mr. J. B. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA      94596 Subject     :     NUCLEAR PROJECT 2 NRC INSPECTION REPORT 83-38 NOTICE OF VIOLATION Reference :       Letter D. M. Sternberg to C. S. Carlisle, dated August 30, 1983 Washington Public Power Supply System hereby replies to the Notice of Violation designated "B" in Appendix A of the referenced letter.
!           ' Our reply, pursuant to the provisions of Section 2.201 of the NRC's
              " Rules of Practice" Part 2 Title 10 Code of Federal Regulations, con-sists of this letter and Attachment 1, which contains our response to ;j this Notice of Violation.
!                                                                                    w      !?,
l             If you have any questions or desire further infonnation, please c6ntact]               5 Roger Johnson at (509) 377-2501, extension 2712.                               c3      58 i                                                                                   P[
901A
                                                                                             ~2 Program Director, WNP-2 HAC/fl cc: -Mr. R. T. Dodds, NRC RV Mr. A. D. Toth, NRC Resident, WNP-2 Mr. R. Auluck, NRC 8310200200 831004 PDR ADDCK 05000397 G                     PDR

Attachment 1 WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO. 2 D0CKET NO. 50-397 LICENSE NO. CPPR-93 RESPONSE TO INSPECTION REPORT 83-38 NOTICE OF VIOLATION
           ' Statement of Violation "As a' result of the special inspection conducted by the NRC Construction Appraisal Team on May 16-27 and June 6-22, 1983, and in accordance with the NRC Enforcement Policy,10 CFR Part 2 Appendix C, the following violations were identified:
Criterion V of 10 CFR 50 Appendix B requires, in part, that " Activities affecting quality shall be prescribed by documented instructions, pro-cedures, or drawings of a type appropriate to the circumstances and shall be accomplished-in accordance with these instructions, procedures
           -or drawings. Instructions, procedures, or drawings shall incl;de appro-priate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
The FSAR for the WNP-2 project, Section 17.1.1.5, accordingly describes
           - that activities affecting quality are described in procedures, instrv -
tions, and drawings and that activities are conducted in accordance with these documents.      Procedures, instructions, and drawings include adequate quantitative and qualitative acceptance criteria to ascertain that the prescribed activities have been satisfactorily accomplished."
              "B. Contrary to Criterion V, 10 CFR 50, Appendix B, cited above, the following as-built conditions. were observed during the inspection.
: 1. Three of twelve pipe supports did not include the welds as specified by the approved design drawings as follows:
MWR-429:     Missing two 1/4" fillet welds COND-617: Missing two 1/4" fillet welds COND-614: Missing two 1/4" fillet welds                          '
: 2. Anchor bolts specified to be tight by the approved installa-tion specifications were loose and improperly installed (5 of
: 14) for support COND-608.
: 3. Size M 4x13 H-beams were used for members of the COND-623 sup-port, rather than 3x3x0.375 square tube members as required by the approved design specification.
Page 1 of 4

e
: 4. A horizontal strut'was welded to a plate (added to the side of a vertical member) on support FDR-375 whereas the approved design specification required the. strut to be welded directly to the vertical member.
This is a Severity Level IV Violation, (Supplement II)."
Supply System Response The NRC Construction Appraisal Team (CAT) identified deficiencies with six Quality Class II/ Seismic Category I (QCII/ SCI) hangers: MWR-429, COND-617, COND-614, COND-608, COND-623, and FDR-375.
Two detailed reviews were made of the six hangers. The first review was an engineering evaluationlof the six hangers by the Architect / Engineer (A/E). This review concluded that the deviations identified on the six supports would not impact the design or function of these supports. The six supports all meet the QCII/ SCI criteria that they remain functional during a Safe Shutdown Earthquake (SSE) and would not impact the function of any other items important to safety.                       Additional documentation of l            these reviews, in Project Position Paper No. 26, is appended to this response.
The second review covered the construction. history of each of the six supports. This review showed that each of the supports was installed by 3            a previous contractor (WBG)-and that the in-process, contractor drawings do indicate the as-installed configuration in five of the six hangers.
!            The status as-built drawing prepared by the contractor, however, did not subsequently identify the deficiencies.                        (This shows that the deviation was documented at one time, but not subsequently as-built.) Bechtel did not perform a detailed inspection on these hangers because they did not
           - perform any related work. On hanger COND-623, Bechtel Field Engineers
           - failed to incorporate a design revision to the hanger. This revision f            was unnecessary and has been voided by the A/E. However, since the 7            Stone & Webster subsequent inspection of QCII/ SCI hangers also identi-
;            fied two hangers not conforming to the latest design revision, the project has implemented a re-review of a large sample of this population lof hangers to insure that there is not a generic concern.and that they j-           have been constructed to the latest revision of the design.
1 In addition to the design conservatisms and as-built / reconciliation                                            .l activities discussed in the Project Position Paper, to further confirm project compliance with the requirements of Regulatory Guide 1.29, Stone
             & Webster Engineering Corporation (SWEC) was contracted to perform a third-party assessment.of QCII/ SCI hangers. This review consisted of performing an inspection and evaluation of 60 hangers chosen at random to confirm that the existing hangers met the Regulatory Guide and j-Page 2 of 4 y y         -   -    s,  g g ,-w , .e y e,-. -
w--, y- rm:-,me, e p, %        we.,,,w4w.-e+w=,.w--%+w- w'e-+wvw,r.,.y,...

      'J project requirements. The conclusion of this report is:
The QCII/ SCI pipe supports reviewed by SWEC at WNP-2 meet the requirements of Regulatory Guide 1.29. All deviations found during the SWEC review were determined not to have a significant effect on the structural integrity of the supports. Therefore, it is reason-able to assume that sufficient design margin exists to account for deviations between the as-designed and as-installed condition and that these (all QCII/ SCI) supports adequately meet the requirements of Regulatory Guide 1.29.
The SWEC report is appended to this response.
It should be understood that QCI/ SCI hangers have undergone an addi-tional, complete re-as-built walkdown since the original status as-built program. Additionally, specific elements of the QCI hanger re-as-built program have received another layer of documentation review to enhance the accuracy of the program. -The latter QCI program has received sub-stantial management attention and project overview through various audits and surveillances. Moreover, a third-party review of QCI as-bui) ting has been conducted by SWEC.             The results of this review have been discussed with the NRC at a meeting in Bethesda on September 13, 1983. Copies of this report will be provided to Region V in response to Unresolved Item 397/83-38/02. The applicable conclusions of the SWEC assessment of the QCI as-builting program were:
o    The present QCI as-built program in use at WNP-2 is acceptable and meets the needs of the project.
o    The implementing procedures for the as-built program are satisfactory and meet ASME Section III and NRC I&E Bulletin No. 79-14 requirements.
o    Deviations found during the SWEC review were determined not to have a significant effect.on the structural integrity of the support.
                -This assessment, the QCI hanger re-as-built effort and parallel project
               . reviews of the QCI as-built program have assured the Supply System that deficiencies found in QCII/ SCI' hangers do not indicate a concern for QCI hangers or the QCI as-builting program complying with regulatory require-raents.
Corrective Action to Preclude Repetition The Supply System has reviewed the identified deficiencies against the
               . required hanger function and detennined that the hangers are adequate.
Additionally, the various sample inspections have determined that the Page'3 of 4

c QCII/ SCI hanger designs and as-built configurations are more than ade-quate to perform their required function. Based on this, no further corrective action is required.
Date of Full Compliance The re-review of QCII/ SCI hangers for conformance with the htest design revision and specific deficiencies noted in the inspections undertaken to resolve this Notice of Violation will be dispositioned or corrected by November 1, 1983.
4 1
1 Page 4 of 4
            - .,   , - . . . - - ~ , . . . . . . - , . _ - . - ~ . . , . ,   ,_.._..,._...-.-,___-.-.___-,s.-_., . _ . - - . _ , . - . - ~ _ . - _ , . - , . . - . . . . - - . - . ,

~
      ?l WNP-2 PROJECT POSITION PAPER NO. 26 ADEQUACY OF QUALITY CLASS II/ SEISMIC CATEGORY I PIPING SUPPORTS Prepared by:     . d.(            ,      9 83 D. C. T1mmins Q/'
Approvals:   c((        M                        ,' .. ../74Kw        -
L. T. Harrold                    J. // )h wg6 Assistant Director,               onstruction Manager WNP-2 Engineering                Bechtel Foi    Corporation
                                         ~ Y'D             h$t.ll 9k/73
                      'A. I. Gygelman                   cT'S. Carlisle     ' '
Site Engineering Manager         Program Director, WNP-2 Burns and Roe, Incorporated

g WNP-2 PROJECT POSITION PAPER H0. 26 ADEQUACY OF QUALITY CLASS II/ SEISMIC CATEGORY I PIPING SUPPORTS
: 1. Project Position The design, construction, installation and inspection of Quality Class II (QCII)/ Seismic Category I (SCI) piping supports is more than adequate to assure compliance with the Project's commitment to Regulatury Guide 1.29.
Specifically, piping systems whose function is not required during or after a SSE, but whose failure could reduce the functioning of safety-related structures, systems and components to an unacceptable safety level, are designed and constructed so that a SSE would not cause such failure.
Moreover, previous construction to QCI requirements in conjunction with the current construction program ensure an adequate level of construction quality for the QCII/ SCI piping supports.
II. Issue Description A. History In the Spring of 1983, discussions took place between the Supply System and the NRC, Region V, on the scope of IE Bulletin 79-14, specifically with respect to the inclusion of QCII/ SCI piping supports. After several discussions, in-cluding conversations between the NRC Site Resident Inspector and NRC I&E Headquarters and NRR (MEB), the Resident Inspector stated that IE Bulletin 79-14 did not include QCII/ SCI piping supports, with exception to'the first anchor on the QCII side of the QCI/QCII break and inclusive supports. This was also the position of the Project. As a result NRC Inspection Item 83-05/05 was closed.
To address the general issue of adequacy of QCII/ SCI piping supports to perform their functional requirements, the Supply         i System generated a document entitled Quality Class II Seismic Category I Pipe Supports. This document was provided to the l
umd

f NRC, Region V, in letter G02-83-622, dated July 15, 1983.
This document was intended to address concerns raised by the NRC Construction Appraisal Team, provided in a preliminary manner to that date. The conclusion of that document was that the QCII/ SCI piping supports are assured of perforning their functional requirements. The conclusion was based on:
e      Design conservatisms applied to QCII/ SCI piping supports, e      The performance of a status as-built program with design verification / reconciliation for the 'arge majority of QCII/ SCI piping supports, e      An additional sample reinspection / engineering evaluation to confirm the technical adequacy of the status as-built program, and                                                  ,
e      Installation inspections being performed by Bechtel on in-process work.
Details on the design conservatisms and the sample reinspections/
evaluations-are provided in Attachment 1 to this Project Position Paper.                                                                ,
B. NRC Construction Appraisal Team (CAT) Findings The NRC CAT inspection identified six (6) QCII/ SCI piping supports with deficiencies as compared to the issued for construction drawings. The deficiencies, with exception to the concrete expansion ar.chors on support COND-608, are within the scope of the deficiencies addressed by the earlier sample
          . reinspection / evaluation program and/or within the general knowledge of Burns and Roe (B&R) Engineering due to the deficiency evaluations performed during the status as-built program.
B&R evaluated the CAT findings and concluded all deficiencies were acceptable, within code allowables and QCI design requirements, with exception to the anchors un support COND-608. The concrete expansion anchors did not meet QCI design requirements; however, the st'oport was capable of performing its functional requirement in accordance with Regulatory Guide 1.29.
The NRC CAT findings indicated that there are deviations between the as-installed QCII/ SCI piping supports and the status as-built drawings that comprise the issued for construc-tion drawing for this support category. This con'dition was
                                                                                         ]

known to exist before the NRC CAT inspection. The NRC CAT findings did not change the validity of the previous evaluation (see Attachment 1). It warrants restatement that the as-built                                        i related deficiencies are acceptable in consideration of code allowables and QCI design requirements, far and above the                                            j functional requirement of Regulatory Guide 1.29.
It should also be noted that the large majority of the QCII/ SCI piping supports (>80%) were fabricated, installed and inspected to QCI requirements. The downgrade of applicable supports did not begin until late 1982. Since that time, the field work for QCII/ SCI piping supports has been performed under the                                           <
direction of experienced Bechtel field construction superintendents.
The inspections cre performed by trained field engineers to similar attributes associated with QCI piping supports. The field engineers are responsible for verifying that construction is performed in accordance with the design drawings, specification and code requirements. The previous construction to QCI requirements and the currsnt program ensure an adequate level of construction quality for the QCII/ SCI piping supports.
One related, NRC CAT finding discussed by the NRC Site Resident Inspector was concern for identified missing welds. The                                             {
previous sample reinspection / evaluation program of sixty (60) large-bore supports did not identify missing welds.                             Therefore, there was concern for whether the previous evaluation enveloped this condition. Even though the specific sample of sixty did not include missing welds, B&R had experience with this condition during evaluation of deficiencies identified during the status as-built program. On numerous occasions, missing-weld conditions were accepted and reconciled with the stress analysis, again within code allowables and QCI design requirements.
The missing welds were almost always fillet welds associated
        . with " weld all around" requirements for channel and wide-flange beams. In addition, as stated previously, the missing-weld conditions identified by the NRC CAT were acceptable.
C. Standard Industry Practice The nuclear power 1ndustry has not adopted a standard practice per se to meet the requirements of Regulatory Guide 1.29 for non-safety related systems and components (QCII) that are in close proximity to safety-related structures, systems and components. The following is a composite of practices that reflect the majority of the industry approaches. The details of the practices are plant unique and vary considerably in relation to the degree / sophistication of the engineering and construction. The practices for QCII/ SCI pipe supports at WNP-2 exceed these commonly applied industry approaches.
I

m I, ,; _          .                                                                      <
                                         <h        O
                                   ,/                                ,
o    P    ibenprotection from (physical isolation / separation, hes 'or seismic support of 2" and smaller QCII piping ontyTf)there is a potential for impacting smaller diameter (or smaller schedule) safety-related piping and components, Class lE conduit / valve-motor operator /switchgear/ control panel, safety-related pump or HVAC ducting / fans, or other
                     -      components designed to the rules of ASME Sectior III, Subsection NB.
e     Provide protection from or seismic support of larger than 2" piping only in the vicinity of safety-related structures, systens and components. If the safety-rel:tted piping is of equal or greater diameter or thickness, no protection is provided.
e    Provide rigorous, computer analyse, for seismic events for QCII piping only if the QCII piping is complex or if the volume with safety-related structures, syste.ms and components is large and/or complex and the use of computer analyses is therefore cost effective.
e    Interaction evaluations (QCII/QCI) are perfortred in the design, construction or post-construction phase and many times are more qualitative than quantitative.
III. Current Status The Project previously addressed this issue in a document entitled Quality Class II Seismic Category I Pipe Supports. The document included the successful results of a sample reinspection / evaluation program (60 large-bore /60 small-bore supports).
Tha Project has evaluated the NRC CAT related findings and con-
               . cluded the as-built related deficiencies were acceptable. Deficient concrete expansion anchors associated with piping support COND-608 did not comply with QCI design requirements and were reworked; however, they did not violate the functional requirements of Regu-latory Guide 1.29.
IV. Required Action To provide additional confidence in the construction adequacy of QCII/ SCI piping supports, Stone and Webster Engineering ",orporat.on (SWEC) was contracted to perform an independent, third-party re'iew.
This review consists of performing an inspection and evaluction of                     i sixty (60) large-bore, QCII/ SCI pipe supports chosen at random.
The SWEC review is of a confirmatory nature and is scheduled for completion by September 27, 1983.
i

3 r
A meeting, the week of September 12, is scheduled with the hRC (NRR) to discuss this issue and others.
e t                                                .
P l
0
                                                                                     \
l

             ,,                 ummm                            v                 : -                                               3                             ;
GK Afflerbach ----927M                          h                                '
h;               ~
      ,                       !tA Cri s p   --------901 A                    J         _                           i
                              $A Holmberg ------904A RT Johnson - -----956B WitP-2 Fil es ------917Y
            - - HAC/lb RTJ/lb                                                                                                                                 -- -
CSC/lb/ file
          ~~~
Docket tio. 50-397                                                                       .
AHathment 1.
i July 15,1983 G02-83-622 Mr. J. B. Martin Regional Administrator U.S. tiuclear Regulatory Ccauission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA          94596 4

==Dear Mr. Martin:==

Subject               . NUCLEAR PROJECT 2 C0fiSTRUCTI0tt ASSESSMEiiT TEAM ISSUES Enclosed is a package of infonaation compiled to assist in resolution of issues raised by the Construction Assessment Temn.                            Enclosed in the package are:
o A paper stating the Supply System's position with respect to as-builting Seismic Category I, Cuality Class II hangers, and the rationale supporting that posi tion.
                                          .          o The specification requirement and the documentation relative to the hold-down bolts for the reactor vessel. These bolts are identifiable by traceable records.
o A cackage containing data relative to additional destructive excavation made into concrete at several locaticns in the plant.            The findings are docrented in detail in the package.               Deep excavations were made into Ceam 2B5 an      into an area of congested steel in
                                                         'he spent fuel pool wall. The excavations show no indication of honeycombing or rock pockets behind a
                                          .,f           solid concrete surtace. Grade and number of bars are N' "'                                                                                 -
ip.,                      ..
                  ^umont              HA _ Cri SD                                        t Foa sicnarune of:           CS Carlisl [
sccries                      ipgA               l                      l                           j FOR APPAOvAL CF {qg                    cy       l                      l APPROVED                     l gj@hfyM l                               l                                      ~
j CATE                         l   ll ']llJ/[J l
                                                                                         }                           l V: P.",31
                                                             ,_     ____-.__-.._.-..       - _ _ . _ . . . - .            ;   .       . y -- - . . - - ~
* N/              '
                             $r. J.' B. Martin
  ,                       . Page 2
         ,          ,        July _15, 1983 G02-83-622-in conformance with the drawings and specifications.
Spacing deviations have been observed in some of the locations; analyses are being performed to determine the implications of these deviations.
In addition to the attached information, the Supply System is aggressively pursuing the resolution of other issues raised by the Coastruction Assess-ment Team. Review programs have been established to address the specific issues as well as the overall implications.                  Programs a:e presently establishad and underway for the following areas:
                        ,                      c As-Builting o Non-Destructive Examination o_, Bolts, Fasteners and Tcrquing o Welding
                                    . . . - - o -- Co nc re t e ---------                                       .
o Engineering Disposition of Deficiencies.                                      -c o Site Quality Program Review Against .
                                                                                                                                   ?
Construction. Assessment Team Findings                                         ;
O These programs are being given priority attention to ensure successful resolution of the Construction Assessment Team issues within our licensing / fuel load schedule. To expedite successful resolution we                                                       .'.
request a meeting be convened between Supply System and NRC Region V representatives as soon as practicable to discuss these programs and''---                         - - - - - - - -
cur findings to date.
A copy of this letter and the enclosed package is being sent to Mr. R. F.                                             ..
Heishman fo. consideration in the preparation of the Construction Assess-ment Team report.                      -
ORIGl?tAL SIGNED BY                                                                                                      ,
C. S. Carlisle - 901A Program Director, WNP-2                                                                        .
                                                                                                                             ~
                            - HAC/fl Attacnmen ts: As Statea cc:    Mr. R. F. Heishman, NRC - IE Mr. A. D. Toth, NRC, Resident WNP-2 bcc: Mr. W. S. Chin, BPA - Richland w/o Mr. A. I. Cygelman, BRI - WNP-2
                                   'Mr. J. A. Forrest, BRI - Richland w/o Mr. D. R. Johnson, BPC - WNP-2 Mr. G. N. Kugler, BRI - WNP-2 Mr. T. A. Mangelsdorf, BPC - WNP-2 w/o Mr. J. F. Newgen, BPC - WNP-2 Mr. R. Orr, Westinghouse - WNP-2 t a                                                                                                                                    6     g w                                                                                                             ..n.   .g@
wm                                               _._ m'
                                                                                                  , , . _ _ , .          ,          ~ ~ . -           _
                                ..                  _          . ~-       ,   . . _ , , _      _

m  -
QUALITY CLASS II SEISMIC CATEGORY I PIPE SUPPORTS The purpose of this document is to discuss WNP-2 compliance with Regulatory Guide 1.29 as applicable to Quality Class II (QC-II), Seismic Category I (SC-I) piping supports and the basis for statement of compliance in terms of:
e    Design conservatisms e     Inspecticn of actual field installations, and                          ,
o     Engineering evaluation of status as-built inspection data.
It should first be understood that , specific supports within this general     ;
definition are as-bu lt in accord;nce with the requirements for Quality Class i
I (QC-I) piping supports. This subset of QC-II, SC-I suppoits applies to supports which are part of piping anchor groups which also include safe-ty-related QC-I piping / supports. In other words, for a piping anchor group which has an internal QC-I/QC-II break, all associated piping isometrics and hanger detail drawings are included in the IE Bulletin 79-14 as-built program.
The remainder of this discussion shall focus on QC-II/SC-I pipe supports which are not part of such anchor groups.
Regulatory Guide 1.29, Rev 2, paragraph C.2 states:
            "Those portions of structures, systems, or components whose continued function is not required but wnose failure could reduce the functioning of any plant feature included in items 1.a through 1.q above" (safety-re-lated structures, systems, and components) "to an unacceptable safety level should be designed and constructed so that the SSE would not cause Page 1 of 4

    \
such failure."                                                                -
The WhP-2 program for QC-II, SC-I piping supports is in compliance with the above regulatory position for the related s;cre.
This assuranc.e is provided by:
s    Design conservatisms applied to QC-II, SC-1 piping supports; e    The performance of a status as-built program with design verifica -        .
tion / reconciliation for the large majority of QC-II,       SC-I pipe .
supports;                    -
                                                                                              )
e    An additional sample reinspection / engineering evaluation to confirm the technical adequacy of the status as-built program; and e    Installation inspections being performed by Bechtel on in-process work.
The de' sign methods for QC-I, SC-I pipe supports were also applied to QC-II, SC-I pipe supports (with the exception that in a few instances anchor bolt factors of safety of 3 to I were used rather than 4 or 5 to 1). Conservatisms in pipe stress and hanger design assumptions and methodologies and functional requirements for safety-related pipe supports were,          and continue to be, imposed on the subject QC-II, SC-I supports. A discussion of these conserva-tisms is provided in Reference 1,     attached. This discussion also applies to small bore OC-II, SC-I supports because similar design methods were used for Page 2 of 4
                                                                                                +

                                                                                                      )
all SC-I pipe supports.
i   y-    ,..-           n -
c.s - . :wm c provides r brief discussion with results on design Reference 2, attached, margins for small-bore pipe supports. It should be noted that the listed design margins do not consider the conservatisms discussed in Reference 1, or the difference in structural steel allowables between ANSI B31.1 and Code.                      .   -
                            =.
status as-built programs included QC-II, SC-I piping As previously mentioned, supports. It should be noted that the current construction program for QC-II, :
SC-I pipe supports includes in-process inspections by Bechtel field engineers of the same dimensions and tolerances as that used in the QC-I program. Prior to 1983, QC-II, SC-I supports had been constructed and inspected to QC-I requirements which exceeds both the requirements of Regulatory Guide 1.P the scope of IE Bulletin 79-14. As such, they were included in a construction (IE Bulletin 79-14) and evaluated / reconciled by the status /as-builting program Engineer.
To addr,ess concerns raised by internal audits of the status as-built program a sample comparison of status as-built drawings to the installed configuration was performed. The results, reported in References 1 and 3, attached, provid a high level of confidence that the status as-built programs assured the adequacy of installed QC-II, SC-I supports to perform their function in accordance with Regulatory Guide 1.29 requirements. The sample of small-bore Page 3 of 4

c      .-     .
        ,         ' pipe supports in Reference 3 addresses QC-I, SC-I supports which at the time the status as-built program was performed included QC-II, SC-I supports. The
                   -program clah implemented consistently across the SC-I supports and is therefore representative. As indicated, rework was directed in nine (9) cases considering QC-I design requirements. The basic question of support function was considered adequate in all cases but one (1), again with respect to QC-I design require-ments. The design conservatisms applied to -QC-II,       SC-I pipe supports by
                    . imposing SSE functional requirements (maintain piping system function varms precluding support failure that would affect safety systems) with the small bore status as-built progra.n for QC-II, SC-I pipe supports provides assurance of adequacy.
[
i
      .              In summary, the design conservatisms, the previous status as-built programs, and the inspections performed during construction assure the functional require-ments for QC-II, SC-I pipe supports are met. The majority of this category of pipe supports were constructed to - QC-I requirements and status as-built to QC-I requirements, including all supports constructed by the previous mechani-cal contractor whose QA Program was brought in question by the WNP-2 50.54(f) work stoppage. For the few QC-II, SC-I pipe supports constructed since the quality class downgrade, the design conservatisms and the in-process inspec-tions performed by Bechtel field engineers assure the functional requirements for this category of QC-II pipe supports are met.
References
: 1) BRWP-F-83-3194, dated April 13, 1983,
: 2) GCBR-F-83-213, date May 17, 1983.
: 3) GCBR-F-83-212, dated May 17, 1983.
Page 4 of 4                         ANK/ecmm i
July 11, 1983 1                                                                                                      -

y                                            m v
  =
        .g (b            -
w_v
    ,                                     Durns and Roe.Inc.
  .                           sisztl Nudear Proie<t No. 2 -Washirigton Public Power Suoply Systern . P.O. Box 200 e Richland, Washinran93352 509-07NL01 = 500-943 8200 iUBJECT: Work Order 3900/4000 Washington Public Power Supply System                                           >
WNP-2 Quality Class II, S2ismic Class I Large-Bore Hanger Design                                                                       1 April 13,1983 B RWP-F-83-3194 Washington Public Power Supply- System P. O. Box 968 Richland, WA 99352 Attention: Mr. B. A. Holmberg

==Reference:==
BRWP-F-83-916, February 3,1983                                                                 ,
Gentlemen:                                                                                                              ,
Provided herein is a brief overview of the Burns and Roe (BRI)' Quality Class II, Seismic Class I large-bore pipe support design program. Addressed are the conservatism in the design, the WNP-2 restart requirements for pipe / support review (Special Requirement Checklists), and the acceptability of the status as-built program. This is' submitted at the request of Mr. D. Timmins of the Supply System to support him in discussion with the NRC on this subject.
The initial design of WNP-2 large-bore pipe supports ut. der Contract 215
* did not include any pipe supports classified as Quality Class II (Q. Cl. II)
Seismic Class I (S. Cl. I). This change came about at the request of the constructor (Bechtel} to minimize the complexity of the documentation for                                                            l supports which are not required to be Q. Cl. I. The hangers now classi-                                                    .         l fied as Q. Cl . II, S. C1. I were initially Q. C1. I, S. C1. I.                                All the support systems that have been changed from Q. Cl . I to Q. Cl . II, S. Cl'. I, are supporting ANSI B31.1 piping systems and are classified as Seismic Class I only because they are in an area that may contain other safety-related systems. The downgraded systems are not themselves safety                                                             ,
related.                                                                                                                             l
                                                                                                                    .                                      1 The conservatism in the design of these Q. Cl. II, S. Cl . I supports                                                                l came from the 'following areas: pipe stress and hanger design assumptions                                                            I and methodologies, and the functional requirements of the supports.
I i!
Over Tidity Five Years of Engineering Achievement j
l em

r-  s          . .-     .    -
    . curna gnd Ros.Inc.                                                            April 13,1983 Page 2,of 4           -.i , .                               B RWP-F-83-3194
    .                                                   o   , m.
              .o ,w -:1) :.Pice Stress Analysis Cbaservatism            ,, .
          '~
There aie a number of conservative assumptions, aside from the T definition of seismic spectra loads, which result from using building
                          .g   dynamic analysis.      These conservatisms are both in the Code and NRC                  '
                        ~nimposed- criteria. --They include ~the use of " lower bounded" values for damping (i.e. 0.5%), more restrictive material properties, lower allowable equipment loads and " upper bounded" peak broadening, cut off frequencies and limitation on the number of stress cycles.
                            - Further conservatism related to BRI design methods include conservative simplifications used in the linearized dynamic modelling such as M modelling of masses (valves, supports, etc.), combining wors' case static anchor movements with inertial effects or any other load
                        -Cicombination of two or more dynamic loads, combining modal responses and simplification by worst case combination of spectra imput data                         i
                            ~ :at terminal ends. If such conservatisms are removed, it would in
                   .           general result in substantially lower pipe stress values and support'                  .
loads.                               '
                                                                      .                                            q
: 2) , . Pipe Succort-Design Conservatism                                                     -
sJ    ~The structural ~  s teel o:f most of these i pipe supports.was originally 3 designed to ANSI B31.1 structural-steel allowables.. ..However,. the            -
                              . applicable design code for the structural steel allDwables is AISC
                              ,which have allcwables approximately twice the ANSI B31.1 Code.
Consequently, a significant design margin exists for many supports due to the structural steel allowables. Note that some systems that had
                            - been downgraded (0; C1. I. to Q. Cl . II) had also bet. downgraded recently from ASME Section III, Cl. 3 tot ANSI B31.1. On these systems the above conservatism is not applicable by Code. The amount
                              ,of, ASME dcwngrade represents a small number (less.than 30%) o,f all
                        .-.-- Q. C1. II 5. C1. I supports.        .
F, rom previous project studies of physical "as constructed" weld sizes ccmpared to rvquired weld size it can bc stated that there is additional support design conservatism in the weld Gesign. Especially when a clarge percentage of design welds are sized based on compliance with the AISC Code criteria for minimum weld size and not related to the optimization of stress allowables, i.e. welds larger than needed for strength purposes are specified in many instances. When further             ~
related to~ the electrode material used on WNP-2 the weld is as much as 1.7 times the weld strength assumed in design. See reference 4                               1 for rurther details.
The base plate design previously used a factor of safety of. 4 or 5. More recent designs have been evaluated on these supports utilizing a minimum factor of safety of 3. Note that these supports are not part of IE Bulletin 79-02 scope; however, these supports are reviewed

    . .f ".. " ,',,          Page 3 of 4                                                                                   BRWP-F-83-3194 utilizing the 79-02 criteria (i.e., factor of safety of 4 or 5, flexible plate). . ,0nly:those that do not pass the stringent 79-02 criteria utilize the factor- of safety-of-3-ind rigid plate assumption. This resulted in 85 Jo 90 percent qf the. pl.ates jnecting the 79-02 criteria.
                                                                       ~
A's .a -resu'lt of the conservat'i                                                                                                 .
WNP-2 Q. Cl.. II, S. Cll'I 'hanls.m             ger designs       indicated         in Items 1 and
                                                                                                        ,are considered          to have.''
2 above,.~tbe 20 to           i 50%
margin in their de' sign
                                                                         ,ca'pacity.~. 1.
: 3)   Functional Reauirements of jipe -Supports ~                                     -      -
All the piping systems bei gD addressed were designed for Seismic Class I                                                  '
1 Fad conditi.on. However, the function ~ and integrity of these Q. Cl . II, S; C1. I piping systems need only be maintained to prevent them from
                                                                  ~~
falTing "on safety-related ~ components           ' " ' ' '' ~in         ~ their vicinity:.during
                                                                                                               -        "                     a seismic eve ~n't .                . . - " ~ ~c " . '; .,en#;;r ; 2 ._ ,, ; ,
1..
                                          ~
                                                                                                ~
Ode should ' note that the design crite.ria and B.RI design verification.                                                            .
p,rogram was utilized .for 'these pipe systems and their supports , with the                                                         '
exception of full compliance with'IE Bulletin 79-02 on baseplatcs, and is                                                      -
the same used on all safety-relate.d systems.                                                                                 -
The- above design-procedure-not-only assures the integrity of the pipe system during a Safe 3hutdown Earthquake, out also insures that ,qnly clastic action is ' exhibited by the entim pipe ~ and pipe support system. Tiiis
                              '.' lower bounded" code limit to ' describe a state of failure does not include plastic action of both the pipe and ; pipe support system as well as large deformation criteria. Minimally we can state by ASME Code Section III, Appendix.XI.,-the system is ;approximately.15. to 20% conservative again.
over the current design.                                                                                                             -
Folloding. the WNP _2 Stop Work Order in the Summer of 1981, .the Supply System committed to re-inspect ' pipe supports including the Q. Cl . I pipe hangers supporting Q. Cl . II piping'. In general, this commitment included all t5'e supports that are now designated Q. C1. II, S. Cl . I.
As part of the recently concluded staNs as-built program, all Q. Cl. I.
S. C1. I and Q. Cl . II, S. C1. I large-bore pipe supports addressed by the above commitment were. field walked.to provide the as-constructed status on the status as-built drawing. ~These drawings were then reviewed for design adequacy by BRI. Consequently, these aspects of the commitment have been met. However, there have been questions generated on the project questioning the validity of the status as-built program regarding the accuracy of the field walkdown. To address these concerns, BPC provided information from a re-walk of 60 previously status as-built supports, where BPC re-checked all the information provided on the initial drawing utilized for the status as-built program.
O I

7     ....,7,,-  '
nega yu noe.inc.                                                                                                         April ,13,1983 y       .
B RWP-F-83-3194 g : ...
                                 ....:n           ,. , -
r c i. r . 4. q..
a,.
                                                                                 .:. ;3.
9,, , q.
                                                                                               - . .        . a.
r,. . ., p.ph nr . c.c .
y 9,...:. m .
j; pag  g' j'lgfg "r :.ee-
                                                                            - - at.;           w. . ; - l ; , . ';                                            -
                                . n . t.
e g er y -                  t.v     i . . a; n.e m -                         -
        - s.i . . . .
The'0RI .disign review oD}idsd ;pSckages lound the fol.1owing: .-                                                     n. e .
I4,; .                                 G,           *:.          -'. -
                                                                                                                            *M.           .   .        c.     . t.
                                 "a)' 8 wilds undersized, ranging 1/16" to 3/16", the majority of
                                   ,.... which were 1/167.                                          . . . .
                                 -.b) 6-dimensional changes.
c). I hardware change (plate size and bracket size).                                                                               ,
                                    .d) .1 clearance deviatiori, - .',;. '.                 -
                                                                                                                 .         P                       .
                                                                         . r. .. ro - -
: 3. .. .        --
t.
The ' clearance 'de,v,... v.ciatiQn ;can. re~sult.ef_r.om line.b"alancins.or completion of the piping and hanger systems'a'nd are not necessarily indicative of a                                                                                   -
fault-in the status as-built program. Due to these potential changes during system completion, BRI is not .considering clearances until the final as-built
                                                                                   ~
program a'nd'they.. ire.not cons'idered_. deficiencies in.the status as-built.
progNm.~               i;. . . . :o) "' , .. ~' ' ' . *                           ' ' " '            *                        -" W                    ~~
u..                                                -
Conse'kuently tiiere were -15 deviations tout of an estimated 5800 measurements /                                                                  I, s., .
items confirmed in the. field walk. .These deficiencies were reviewed and .                                                                        -
fourid ~adeep tabTe. It sh6uldTbe'noted that!'these deviations were acceptable without removing any of the con'servatism*is .the design criteria noted above,
                          - i.e.', the original design margin was .not reduced. 'Also,-the less than one.                                                                    .
percent.as-built deviation does .notlseem7ynreasonable based on -human error .
and judgment. BRI therefore concludes that the status as-built program is valid and the Project commitment, to.the NRC to review the potential
                           - fiel'd deviations has been met. '
                                      ..v.
Very truly yours,
:.C.T. 1
                                                        #   ~
f) :.
w: p .
S2 C
                              ,                V''
                                                                                          -..-                      -I.-
A. I. Cygelman
{
Manager, Site Engineering AIC:JBM:co..
j                           CC: .WS Chin, BPA.....
H.,;.Cni s p F904 A '')
                                    'BA Holmberg, 906D i                               - TA Mangelsdorf, Bech.
;                                      J. Newg"n, Bech.
J e
i l
2

  . *9 +}:,v. . ..
     .      e
    'e s.-
  .                                 v ~w-       Burns and Roo.tnc.
ba Nuclear Prciiret No. 2 -Washington Public Power Supply Systern e P.O. Box 200 e Richland, Wnhengton 00352
* 509-377-250t a 509-943-6200

==SUBJECT:==
W.O. 3900/4000 Washington Public Power Supply System WNP-2 Contract C0208                                                   (o Conservatism of QCII, SCI Supports (0                                                 f Responds to: N/A

==Reference:==
: 1. GCBR-F-83-212 g              /4                         ([
WP-F-83-4516
: 2. GCBR-F-83-213 May 24, 1983 Response Reqd:              N/A Washington Public Power Supply System P.O. Box 968 Richland, Washington                          99352 Attention:            Mr. il . Holmberg                                                      .                 .
Gentlemen:
* Enclosed are copics of references 1 and 2 which where studies performed to evaluate the conservatism of OCII, SCI supports in the G/C scope per Mr. Timmins request.
Please advise me if you require additional information.
Very truly yours ,
W A.I. Cygelman Manager, Site Engineering AIC:JMR:caz Attachment cc:      WS Chin - BPA                 901A w/o HA Crisp                      901A w/o TA Mangelsdorf                BECH w/o S     Lalomia                 G/C w/o P     ilarness                WPPSSw/att Over Thirty five Years of Engineering Achievement

7 g-C
      ?.  , _' t ,
Gil b e rt / C o m m o n wea lt h engineers and c0nsuitants GILBERT ASSOCIATES. !NC. d!b/a/ GILBERT / COMMONWEALTH. INC.: COMMONWEALTH ASSOCIATES,INC ,
SEATTLE OPERATIONS CENTER.11400 S E 6th Street. Swte 130, Bellevue. WA 98004/Tel 206-454-0065 GCBR-F-83-212 May 17,1983 Response Due: N/A Responds to: BRGC-F-83-255 Mr. J. M. Raymont Project Engineer Burns & Roe, Inc.
P.O. Box 200 Richland, WA 99352

==Subject:==
Washington Public Power Supply System WNP-2, Contract C-0208 Conservatism of OCII. SCII Supports t                       JCI 3cd 5                        t slisa

==Reference:==
GCBR-F-83-213 dated May 17, 1983                                                                                ,
i 

==Dear Mr. Raymont,==
We have evaluated the as-built CO-500-G/C-AB Requests for Information (RFis) dispositioned as of.May 12,1983, in accordance with the above letter.
                 ' Attachment 1 is a table that summarbs this review. A total of 124 RFis have been reviewed and dispositioned. Only 78 of these dispositioned RFIs were evaluated to the reported construction deviations. The remaining 46 were either voided (5), returned for incomplete information (15), ' returned for resubmittal by Anchor Group (23), or rejected not evaluated (3). The total number of isometrics evaluated was 78 which contained a total of 190 supports.
The evaluated RFIs reported 87 deviations to pipe and pipe routing and 240 deviations to pipe. support:. Two of the 87 pipe deviations (2.3%) and 9 of the 240 support deviatians (3.75%) required field rework to accept the reported conditions. The 9 reworks for supports are further explained in Attachment 2, as requested. The remainder of the reported deviations for both pipe and supports were found to be acceptable af ter engineering review.
We ' have . enclosed the summary work sheets prepared for this evaluation as Attachment 3. Please advise if any other information is required in order to support your effort.
Very truly yours, S. Lalomia, 3 ., P.E.
Project Manager j                  SL:jcs i
Attachment cc:    Al Cygelman.                                             CW Robinson HR Tuthill                                               RL Tynan K. Porter                                                GW Jackson BRI Site Files (2)                                      DC TiminS (WPPSS)
Pnepal 0%ces f 01;cs 144 ReaJ.ag Pe*5ylva+a 1%"3/Tel 215 3.u s 2ts tast nasNogton Aveave Jarswa Echgan 4Wiefel $17 7alLXrA

  %^           .
w May 17,1983" GCBR-F-83-212 Attachment 1 A. _ Number RFis dispositioned                 124
                     . Number returned incomplete                  15 Number returned resubmit                    23
                       - Number voided by Bechtel                    5 Number rejected - not evaluated - 3 TOTAL number evaluated -78 B. RFIs evaluated by Start-up System System           No. of RFIs         No. of Reworks
                           -7.1                  7                   1                                    .
7.2-2                12                   0                                  ,
8.0 -                 6                   0-                                   ,
9.0                  14                   0
                         ' 10.0 -                2                   0 47.1                 37                   8 75                   9 "C..                                                   Number            RFI Number Type of Discrepancy Reoorted Discrep.         Rework      Rework
: 1.       Undersize Weid/ Weld Change            79         1         -080
: 2.       Member Size Change                      5         0
: 3.       Co.1 figuration Change                  3         2   -050 and -037
: 4.     ' Inserts                                 1         0 5: . Baseplate A Conc./B Mod. Emb.               9         0
: 6.        Member Length                          31         0
: 7.       Skewed Welds                           18         0
: 8.       U-Bolt                                  4         3     -041 (all 3)
: 9.       Critical Dim. Change                   53         0
: 16.       Clearances                             10         3  -038,-037,-008
: 11.       Material add by Field Shims /
Couplings, etc.                         6         0 12.'      Hanger typical upgrade                  7         0
: 13.       S/M Revision, Draf ting Error          13         0       ,
: 14.       Deletion / Add. Grout over Tolerance                                1        0 24         9 po)
Jgge ?

                 . May 17,1983 GCBR-F-83-212 Attachment 2 CO-500-G/C-AB RFIs requiring rework:
RFI Number Isometric No.      S/U Discrepancy Type       COMMENTS
                   -003        DSA-2729-2      47.1    10 - Clearance  Deals with 1/16" CLR between support on sides of pipe. PED 215-H-K483 addresses this problem.
This does not affect support adequacy.
                 --037         DCW-2518-1       47.1 3 - Configuration Brace item 14 was not Change      installed as required             ,
construction appears            "
incomplete:
10 - Clearances 1/16" CLR shimmed to be 0" CLR.
PED 215-H-K043
                                                                .      addresses this problem.
This does not affect support adequacy.
                   -038        DCW-2516-1       47.1   10 - Clearances  3/16" CLR on shear lugs.
Rework per PED 215-H-K043 requirements. Does not support adequacy but does affect intended function.
b                  -041         DO-2710-2       47.1      8 - U-Bolt    All 3 - single lock nuts 8 - U-Bolt    installed, field needs 8 - U-Bolt    to upset threads. May have affected support function if nuts worked loose.
                    -050       DCW-2511-1       47.1 3 - Configuration  item 10 - Not welded
!                                                           Change      per isometric. Direction to weld per isometric. May have affected support I
'                                                                       adequacy.
i t
                    -080       HPCS-2%9-1        7.1        1 - Weld    Walkdown did not clarify f
                                   -                        Change      weld installed. Added
!                                                                       weld to replace what was I
I                                                                       installed. Does not appear to affect support adequacy.
L u

m                                                                                             .                  ..
L*. '
   ~
      ?. ' . , .
Gilbe rt / Com rn o n wea lt h enreers ane cons.aanis GLBERT A55001ATES. iNC. e. D/a/ GILBERT /CCMMONWEALTH INC . COMMONNEALTH ASSOCIATES. INC..
SEATTLE OPERATIONS CENTER.11400 S E 6:n Street suce 130. Bellevue. WA 98004/Tet 20rA54-0065 GCBR-F-33-213 May 17,1983 Response Due: N/A Responds to: BRGC-F-83-240 Mr. J. M. Raymont
               - Project Engineer Burns & Roe, Inc.
P.O. Box 200 Richland, WA 99352

==Subject:==
Washington Public Power Supp!y System WNP-2. Contract C-0208                                                                                        '
Conservatism of QCII. SCI L:ccorts

==Reference:==
BRGC-F-83-240 dated May 2,1933                             ,
GCBR-F-33-212 dated May 17,1933

==Dear Mr. Raymont,==

In response to the referenced letter, a random sample study was perfo med m determine the factor of conservatism for QCll, SCI small bore supports. A total of 60 supports randomly selected, out of a total of 1353 supports, were included in the study.
The results of the study are summarized in the attachment. The following parameters were used in the study:
e  ,   Supports which were not evaluated for one reason or another are replaced by another sample per random sampling procedure and the reason identified.
e      The factor of safety for the baseplate and the governing load case is identified.
e      That component or part of the support wnh the least factor of safety and the corresponding load case are identified.
In this sampling study, 90% of the supports are designed to ANSI B31.1 structural steel allowables. However, the structural steel allowable per AISC Code is approximately twice the ANSI B31.1 Code, which in fact increases the factor of safety. This additional conservatism may not apply to 10% of the supports, which carry ASME lines.
The baseplates for the,se supports are qualified utilizing I.E. Bulletin 79-02 Criteria, even though not applicable.
mwewei- e                             **
We eh       $f 4                                                    *
                               -   , . , - , - . .       . . -e. ,c . - - - .           -         ..-.,,.---,,.-r.    - - . - - - . -
                                                                                                                                      ,_y.   , .y-,--,,.

s: -
       , t*
2         4                      p
 }
* Cilbygt/cammtnwxith ev                        i>=cew-i amar.sse.ns                             .ti. c cc .*n.;      .ssm.ns c u ma m w o.scac.n,=,.  . am.i co .o s neu.u.               mse.,m. = i.,a.au
                .. k. y 17,1983 GCBR-F-83-213 Mr. J. M. Raymont Page 2 In conclusion,' these suppor_ts have a higher built-in factor of safety than actually depicted in the attachment.
Please advise if any additional information is needed.
Very truly yours,                    '
g V
: g.                        -
4'          S. Lalomia, Jr., .E.
Project Manager SL:jes Attachments
               - cc: _ Al Cygelman                                           ,bcc: S. Rangaram CW Robinson                                                    RE Mantz HR Tuthill '                                                   RM Yanochko RL Tynan                                                       SOC
                       - K. Porter                                                     File 17 and 55(b)
GW Jackson BRI Site Files (2)

m l
:     -*                                                                                                                                      Attachment 1 of 4 CONTRACT C-0203                                                                   GCBR-F-83-213 Small Bore Piping-QCII, SCI Supports - Factor of Safety pie        S/U -         Sopport Identification                                   Baseplate Load                                               Hanger        Load
       .         NO.            Insert - Type and Size                Location             F.S.             Case                         Component            F.S. Case 69.1-               RCIC-14S4-33                       R-42               22.2                 TN                               Weld         1.77   TN
                                              %" HDI 78.3                 CAS-1084-13                       R-12               6.25                 TF                             Str. Sil.      1.33   TN 5/S" PRH 57.0                 TSW-14 23-24                     R-63                N/A               N/A                               Emb. Pl        1.14   TF 60.0                  DW-1157 16                       R-41                46.5                TF                               U-Bolt         1.3   TF
                                             %"PRH                                                                                                                     .
57.0                 TSW-l l6 2-23                    T-26                                 Verified by G/C-0000-9 Replace with Sample #61 57.0                TSW-1423-54                       R-6 2               N/A               N/A                                U-Bolt       - 1.3   TF 73.3                   SA-l l 32-22                    R-41                N/A              N/A                               Str. Stl.       1.17 TN/TF 60.0                  DW-il 50-53                      R-13 36.0                TF                            Str. Stl.       1.22 TN/TF
                                            %"PRH 11.0               RCC-2039-23A                       R-44               N/A               N/A                              Str. S tl.       6.9 TN/TE Containment i               78.3                  SA-I l67-il                      R-22                16.0               TF                             Str. Stl.       1.%    TN
                                            %" PRH 69.1                  RCIC-1484-53                      R-Il               43.0                TN                                Weld         4.64   TN
!                                        7/S" PRH
                !!.0                 RCC-1971-Il                       R-45               N/A              N/A                               Str. Stl.        1.9 TN/TE Containment 57.0                 TSW-1162-24                       T-26                                        Verified by G/C-0000-9 Replace with sample #62 70.0               COND-1211-Il                        R-72               14.3               TF                                 Weld         1.29   TN 5/8" PRH 11.0                  0W-1159-61                       R-72               5.13               TF                                 Weld         1.15   TN
                                            %" HDI 1
78.3                   SA-l l74-43                      R-6 3              6.45               TF                                 Weld         1.06   TN
                                           %" RRH
;               35.0                 EDR-1329-13                       R-74                                       Hanger Deleted Replace with Sample #63 11.0                 RCC-2039-13                       R-44                                       Hanger Deleted r -. : - -.                                       n . - - - .. .: . 6 c --- .- , . <

3            .a
   . ~ , o.     -
Attachment 2 of 4 v- *''i                                                                        GCBR-F-83-213 CONTRACT C-0208 Small Bore Piping QCll, SCI Supports - Factor of Safety le-      S/U   Support Identification                    Baseplate    Load           Hanger       Load NO. Insert --Type and Size      gcation           F.S. Case   Comoonent -    F.S. Case 78.3          SA-1099-45             D-Il           444.0      TF      U-Bolt       2.17   TF.
                                 %" PRH 62.4         FP-1073-210             R-72           4.44       TF     Str. Stl. 1.09   TN
                               - %" PRH 3.0      ' RC-1552-214 R                         R-43            16.0      TF      U-Bolt       1.03   TF
                                 %"PRH 57.0         TSW-2405-il             R-6 2          10.53      TF    Deflection     1.84   TN,
                                 %" HDI                                                                      ,
78.3          SA-I l95-46            R-73            13.9      TF    Deflection     1.07   TN
                                %" PRH
                $7.0       TSW-il62-511              R-31'           37.7      TF     Str. Stl.      1.0 TN/TF
                                %" PRH 4
69.1.       RCIC-1484-43             T-26          22.22       TF      U-Bolt       3.23   TN
                                %"PRH 60.0         DW-l % 5-44             D-I l           13.9      TF    Deflection     1.07   TN
                                %"PRH 60.0         DW-I l 53-14            R-43           51.0       TF      U-Bolt       1.38   TF
                                %"PRH 70.0      COND-11%-23                R-23           10.26      TF     Str. Stl. 1.%    TN 7/8" PRH 35.6        EDR-127 S-22             R-33                       PED 2% Not Incorporated i                                                                               Replace with Sumple //65 l               60.0         DW-ll57-35             R-41            N/A       N/A     Str. Stl. 1.25 TN/TF 78.2          SA-1711-33            W-41            80.0       TF     Str. Stl. 3.23 TN/TF
                                %" PRH 1
               -60.0         DW-i l 56-55           R-73            48.8       TF     Str. Stl. 2.0  TN/TF
,                               %" PRH 60.0         DW-il 57-24            R-41           24.24       TF   Deflections      1.1   TN
                                %" PRH
;               35.0        FDR-2738-17             R-46            N/A       N/A      U-Bolt       1.14   TE Containment
~
78.3         SA-l ! 95-4 3 -        R-7b             9.3       TF     Str. Stl. 2.4  TN/TF
                                 %" HDI

       - - r-Attachment 3 of 4
          .]".-                                                                            GC8R-F-83-213 CONTRACT C-0208 Small Bore Piping           -
                                        - QCII, SCI Supports - Factor of Safety le     S/U   Support Identification '                     Baseplate   Load           Hanger       Load NO. Insert - Tyne and Size        Location         F.S.      Case   Component      F.S. Case 70.0     . 'COND-1052-12A ~            R-13'          100.0       TF     Str. Stl. 1.85 TN/TF
                                  %" PRH 60.0          DW-I l 56-44'            R-7 3          63.5        TF     Str. Stl. 1.63 TN/TF
                                  %"PRH 60.0           DW-l % 5-42              D-11            13.9       TF    Deflection    1.07   TN
                                  %" PR:1 35.0         E DR-1278-23                                       PED 2% Not Incorporated       ,
Replace with Sample #66 11.0        RCC-24 83-13              R-62           21.9        TF     U-Bolt       1.61   TF b"PRH
              -78.3            S A-Il 81-15            R-31        . N/A        N/A     U-Bolt       1.27   TF 57.0          TSW-Il62-43              R-42                    . PED 2% Not incorporated
                                  %" PRH                                         Replace witn Sample #67 57.0          T5W-I l67-43             R-42           56.0        TF     U-Bolt       1.16   TF
                                 %" PRH
              .60.0           DW-Il 50-46              R-13            9.3        TF       Weld       2.45   TN 5/8" HDI
                 !!.0 ,
RCC-1836-13               R-61           36.0        TF     Str. Stl. 1.22 TN/TF
!,                                %"PRH l
57.0          TSW-2403-15              R-62           6.86        TF       Weld       2.13   TN l
                                  %" HDI 78.3            SA-I l 83-29            R-51           N/A        N/A     Str. Stl. 1.79   TN l
CAS-2076-18              W-42           30.8        TF      U-Bolt      1.28   TF
!              78.2 l                                 %" PRH
                             - DW-2829-24              R-51           N/A        N/A     U-Bolt       1.32   TF f              60.0 CIA-4099-84              R-53            15.4       TN     Str. Stl. 1.09   TN 24.0                                                                       "
l                               . %" PRH DW-I l 50-64             R-13            18.0       TF       Weld        2.7   TN l              60.0 l
5/8"PRH N/A        N/A       Weld       1.33   TN 11.0       R_CC-2007-l l !           _R-56
(                                                          . . - .
PED 2% Not incorporated
;               78.3-          SA-l !7 3-22 l
Replace with Sample #68 i
i

        .3
~.e* ?".   '';                                                                               Attachment 4 of 4
.q                                                                                           GCBR-F-83-213
                                                  - CONTRACT C-0208 Small Bore Piping          '
                                         . QCll, SCI Supports - Factor of Safety sie        S/U       L Support identification                   Baseplate Load                  Hanger           Load NO. _ insert - Type and Size         Location         F.S.      Case    Component - F.S.           Case 78.3.            SA-I l 74-31             R-63           N/A.      N/A     Deflection -        1.45    TN 73.2            SA-1711-71                W-42           N/A       N/A      Str. Stl.          2.25 TN/TF 3.0            RRC-1552-29                R-43          17.73       TF     Deflection          1.93    TN
                                %" PRH 11.0            D W-I l 59-24             R-71          20.0        TF       U-Bolt           2.78     TF 3/4" HDI e
60.0             DW-Il 54-53               R-33                        Upgraded to QCI Hanger Replace with Sample #69 60.0             D W-Il 50-71             R-13           19.0        TF       U-Bolt           3.13    TF 5/8" PRH .
70.0           CON D-I l 96-6.5           R-13          66.67       TF        U-Bolt           1.23    TN 5/8" PRH
             !!.0            DW-Il S9-37               R-71           44.4       TF       Str. Stl.         4.2   TN/TF
                                %" PRH 69.1          RCIC-1484-26, A&B            R-21          11.4 3      TF        Weld             1.20    TF.
                                %" PRH 6 S.2            CO-2209-17                R-37           5.4        TF       U-Bolt            1.16    TF
                       .        4"PRH I1.0            RCC-2036-12                R-47          N/A       N/A         Weld            1.95    TE Containment 78.3           - CAS-1083-16               R-22          13.9        TF     Deflection         1.07    TN
                                %" PRH 70.0           COND-1051-I l               R-13         22.22        TF      Str. St!.         1.77 TN/TF 3/4" PRH 57.0            TSW-Il62-28               T-26            5.5       TF        U-Bolt           1.56    TF
                                %" HDI 60.0              DW-Il 57-14              R-41           18.3       TF       Str. Stl.        1.04 TN/TF
                               %" PRH 35.0            FDR-27[8-15               R-36          N/A        N/A        Weld            1.07     TN Containment

m
* TiBLE III-8 f$= sed CUALITY CLASS Il SUFFCRT/ RESTRAINT AS-Bulli DEVIATIONS S'_'? PORT-RESTRAINT NO.              NRC CAT !.'!SPECTOR OBSERVATIC'N IGR-429                        2 cf 8 beain brace welds not mace.
COND-608                       1. Improper pipe to support clearance.
: 2. Loose and imprcperly installed concrete expansion anchor mounting bolts (5 of 14).
: 3. Plate washer welds undersi:ed (1/16" actual vs. 3/16" specified).
COND-623                      Restraint not reworked to acccmplish major design change on latest drawing revision.
This was not an outstanding item on the Master 'viork List for this turned o er system.
FDR-375                       Spacer plate welced between wall brace
                                                                  ~
MA and vertical beam not shown on drawing.         $37 COND-617                       1. Top horizontal beam not welded on .he bottcm (both ends) as required by drawing (6" of 36" unweided)
: 2. Skewed weld not properly detailed. One skewed weld ground excessively (possibly uncersize).
COND-614                       Spacer rctated 90 degrees which changed weld type used from fillet to an edge.
[E '
III-26

m         '
v i-m e, nurna und Roo, int..
 .                                 Ol!IM nuew recien .w. 2 - wuni.y::.4 runw rom, suwy avsmn - e.o. oo,2oa 2 nsnuna v;nn.c..nn o93    , sco-m mt.m_m.wca_,
1                          ::    -
S t'3dECT: Work Order 3900/4000 l     M         an         $     $
5 Washington Public Pcwer Supply System                                                   e               )
WUP-2 QCII/ SCI Support / Restraint As-3uilt
                                                                                                       +7             L     2'"
Ceviatica Review                                                                   "k .
a   j/ g[j/
B RW P-F-83-6549                                 1-August 16, 1983
                                                                                                                *   '   Pf L'    @
Washington Public Power Supply System P.O. Box 968 fff-"'         "' fLdb-&jy           ;;p
                                                                                                                         .    #(
Richland, Washington 99352 Qp p,/[Mhp)
Attention: Mr. L.T. Harrold                                                    U-              O Reference :      1. Letter, WPBR-F-83-523                                          'dh. \ '!Nn*    ?2d -
: 2. BP.I Cal c. #8.16.5035                                              MIC Gentlemen:                                                                                   V_h Attached are SRI Engineering com.T.ents concerning As-Built deviations for QCII/ SCI Pipe Supports as identified by NRC CAT Team auditors and provided by reference '1. With the exception of Support COND-608, the identified deviations would not result in any design or code allowables being exceeded.
Ident:fied deficiencies with concrete fastners on COND-608 would result in design allowables being exceeded. The support baseplate however is within the ultimate capacity of the inserts but does not meet the normal factor cf safety for QCII/ SCI design. As such no a.t/e rs r. impact on safety related syi.tems is expectec.
(It is noted that fastner integrity is not an as-built review item.)
since rely ,
    .                                                                  ORIGillAL SlGt4E0 BY BM BOYUM Al Cygelman Udnager, Site Engineering AIC:HF:cjm cc: WS Chin, BPA H. Crisp, 904A BA Holmberg, 906D TA Mangelsdorf, Bech.
Over Thirty Five Years of Engineerin] Achiesement

                                                                                                                                       . 4. a:
                                                                                                                                            .i i f        ,
U.       .
I
* HANGER 4
        ! MARK #                            AS-EUILT DEFI CI ENC'.'                                       BRI DISPOSITION L
j MWR-429          2 of 8 beam brace welds not'made.                                  Support' remains adequate after neglectina missing welds.
i 4
COND-623         Restraint not reworked to accomplish major design                  Although drawing f revision Rev.2 i                            change on latest drawing revision. This was~not                    initiated rework, this- rework. was-an outstanding item on the 11 aster Work List for                  subsequently modified by PED 215-H-this turned over system.                                          _ W144, which supports the configuration
;                                                                                               currently installed.
I FDR-375          Spacer plate welded between wall brace and vertical               Additional spacer plate and welding beam not shown on drawing.                                        acceptable per stress analysis.                       ~
1
.           COND-617         Top horizontal beam not welded on the bottom                      Lack of weld on top horizontal beam (both ends) as required by drawing (6" of 36"                     acceptable per s. tress analysis.
unwelded).
i                            Skewed weld not properly detailed. One skewed                     Calculated required effective throat of weld ground excessively (possible underr.ize).                    skewed weld is.03" considering only acute angle skewed weld at flanges and
;                                                                                              right angle fillets cn web. Visual-indications show that this value has
]                                                                                              been achieved.
                                                                                      ' 08- *g
                                                                                                                                                  .d

o dm ; o
                                                                                                     ..                       S ... d
                                     .                                                                                        : ~-
HKiGER KAF.K f                    AS-BUILT DEFICIENCY                                      BRI DISPOSITION
  ' C0HD-614        Spacer rotated 90 degrees which changed weld type           Rotation of spacer resulted in a butt i'                used from fillet to an edge.                               wel d. Loads on weld are quite small
( <; 100#) . Butt weld is qualified.
r CON D-608      Improper pipe to support clearance.                         Clearances are acceptable to engineering.
Loose and improperly installed concrete expansion      . Evaluation of support assembly assuming anchor mounting bolts (5 of 14).                 '
complete failure of the southern plate, Item 13, and partial- capacity of the plate, Item 11, indicates that design margins would be substantially exceeded -
and that deficient fastners would approach E0% of their ultimate capacity. Design and ultimate fastner allowables were derated to 20% of full capacity due to
                                                             ,                 fastner expansion plug underset.       Analysis was linear with no considerations for plastic deformation or load shifting to
:                                                             adjacent structures.
Plate washer welds undersized (1/16" actual vs. 3/16"      Undersize washer w' elds are acceptable.
speci fied) .
                                                                            ?.
                                                           ~                                                       -.           . A}}