ML20207N166

Insp Rept 50-443/86-51 on 861028-31.No Violations Noted. Insp Performed to Evaluate Alleged Discrepancies Re as-built Drawings of safety-related Piping & Support Sys

ML20207N166
Person / Time
Site:	Seabrook
Issue date:	12/31/1986
From:	Kamal Manoly, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207N160	List: IR 05000443/1986051 ML20207N158 ML20207N166
References
RTR-REGGD-01.029, RTR-REGGD-1.029 50-443-86-51, IEB-79-14, NUDOCS 8701140025
Download: ML20207N166 (28)

See also: IR 05000443/1986051

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-443/86-51

Docket No. 50-443

License No. CPPR-135 Category A

Licensee: Public Service of New Hampshire

P.O. Box 330

Manchester, New Hampshire 03105

Facility Name: -Seabrcok Station, Unit #1

Inspection At: Seabrook, New Hampshire

Inspection Conducted: October 28-31, 1986

""

Inspectors:

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K. Manoly, Lead Reactor Enginelir date

Approved by: ,, /2/J//84

Strosnider, Chief, Materials and date

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Table of Contents

Page

Executive-Summary 1

1. Persons Contacted 2

2. Inspection Objective and Scope 2

3. Allegation Description (RI-86-A-0113) 3

4. Safety Related Piping Systems As-Built Inspection 4

4.1 Overview of the Piping As-Built Program 4

4.2 NRC Walkdown verification of Piping Installations 8

4.3 Findings 9

4.4- Conclusion 10

5. Review of Other Program Activities 11

5.1 General 11

5.2 IBuilding Beam Verification Program 11

5.3 Seismic II/I Interaction Program 12

5.4 Failure Modes and Effects Analysis (FMEA) Program 13

5.5 Conclusion 14

6. Exit Meeting- 14

Attachments

Appendix I

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EXECUTIVE SUMMARY

Region I performed a special inspection to evaluate alleged discrepancies at

Unit I of Seabrook Station related to the as-built drawings of safety related

piping and support systems. The NRC inspection also covered several other

programmatic activities which included the Building Beam Verification, the

Seismic II/I Interaction and the High/ Moderate Energy Pipe Break Whip and Jet

Impingement Load Verification Programs.

The allegation was made by a former licensee contractor and it primarily dealt

with concerns over the accuracy of the measurements provided on the as-built

drawings and their impact on the adequacy of the piping stress reconciliation

effort and other programs that interfaced with as-built conditions. Details

of the alleged discrepancies in the as-built piping and support drawings and

the NRC evaluation of these discrepancies are provided in Appendix I of this

report.

The processes of piping installation and as-built verification had been

examined and-reviewed by the NRC throughout the construction phase. This

special NRC inspection, in response to the allegation, consisted of:

(1) re-examination of the programs which governed the piping as-built verif-

ication effort (Section 4.1) and the other activities mentioned by the alleger

as potentially deficient (Section 5), and (2) verification of final as-built

piping drawings by performing independent measurements of piping sections

addressed in the allegation and other randomly selected piping systems (Section

4.2).

The NRC review of the programs for piping as-built verification and stress

reconciliation were found to be consistent with accepted industry practice and

were in compliance with NRC requirements set forth in I.E.Bulletin 79-14 for

as-built verification of safety related piping systems. Based on NRC

independent measurements of plant systems, it was found that the final as-built

piping drawings were within acceptable tolerances set by the reconcilation

criteria. The as-built drawings supplied by the alleger were not consistent

with the plant as-built final drawings and apparently were drawings used in

earlier evolutions of as-built verifications.

The approach used by the alleger in performing the interference evaluation

relies on very precise and accurate measurements and a reference system that is

primarily used as a construction aid. It is not necessary, nor is it common

industry practice that measurements of this precision be made to support the

pipe stress reconciliation effort. The use of building reference points

introduces errors because this information is not updated and only utilized to

aid construction forces in locating supports in a general areas. It has no

bearing on final interferences or stress calculations.

Based on the NRC evaluation of licensee programs for the performance of safety

related activities, it was concluded that the programs had met the intent of

the regulations and were substantially in conformance with established industry

standards. The NRC concluded, therefore, that the allegation involving the

adequacy of safety related piping as-built drawings and other safety related

activities at the Seabrook Station is unsubstantiated. No violations were

identified during this inspection.

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1.0 Persons Contacted

1.1 New Hampshire Yankee (NYH)

• J. DeVincentis, Director of Engineering

• T. Pucko, Senior Licensing Engineer

• T. Cizauskas, Lead Mechanical Engineer

• D. Perkins, Licensing Engineer

• S. Sadosky, Manager EAR Program

• W. Sullivan, Senior QA Engineer

1.2 United Engineers and Constructors (UE&C)

8. Huselton, Project Engineering Manager

G. Tuday, FMEA Group Engineer

D. Mehta, Seismic Coordinating Engineer

J. Parisano, Piping Engineer

1.3 CYGNA Energy Services

• P. Baughman, PAPSCOTT Coordinator

1.4 Computerized Interference Elimination (CIE)

S. Mitchell, President

S. Nicholson, General Manager

1.5 U.S. Nuclear Regulatory Commission (NRC)

• A. Cerne, Senior Resident Inspector

• D. Ruscitto, Resident Inspector

D. Haverkamp, Reactor Project Engineer

• Denotes personnel present during the exit meeting on October 31, 1986.

2. Inspection Objective and Scope

The objective of this inspection was to evaluate alleged discrepancies in

,

the as-built drawings of Safety Related (S/R) piping systems qualified by

l

Westinghouse (W) and United Engineers and Constructors (UE&C), and to

assess the potential effect of utilizing these drawings in the performance

of activities involving Building Beam Verification, Seismic II/I Interaction

and Failure Mode and Effects Analysis. To achieve this objective, the

inspection focused on the examination of programs which govern the above

activities and on the performance of independent measurements of piping

sections addressed in the allegation and other randomly selected piping

systems.

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3. Allegation Description (RI-86-A-0113)

The Region I (R-I) Office of the NRC was notified by the Region III office

of an allegation involving as-built drawings of safety related piping

systems at the Seabrook station. The Region III staff was informed of the

allegation on August 5, 1986 while conducting an interview with personnel

from Computerized Interference Elimination (CIE), a former contractor to

New Hampshire Yankee (NHY), regarding alleged discrepancies in as-built

drawings of piping systems in Units 1 & 2 of. Byron Station. A copy of the

allegation interview transcript was transmitted to the R-I Office on

September 19, 1986. Two lead Reactor Engineers from the R-I Office

traveled to Redmond, Washington on October 21, 1986 to interview the two

principal allegers from CIE identified above.

The allegers identified certain concerns regarding the existence of

discrepancies in as-built drawings of safety related piping systems

designed by Westinghouse {W) and United Engineers and Constructors (UE&C)

at the Seabrook Station. CIE provided the NRC staff with copies of piping

drawings prepared by W and UE&C relating to the systems involved in the

allegation and six other drawings prepared by CIE depicting the alleged

discrepancies. The discrepancies were noted during the performance of

interference verification utilizing drawings provided by the licensee (NHY)

and information obtained by telephone from NHY, W and UE&C. Five of the

six alleged discrepancies involved walkdown, marked-up drawings by W which

were not approved as final. The allegation primarily dealt with concerns

over the accuracy of the measurements provided on the drawings and the

impact on the adequacy of the licensee's pipe stress reconciliation efforts.

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It also referenced other design activities which could potentially be

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affected as a result of using input data from as-built drawings containing

discrepancies. These activities included Building Beam Verifications,

Seismic II/I Interaction, and High/ Moderate Energy Pipe Break Whip and Jet

Impingement Load Verification Programs.

The alleged discrepancies in the as-built piping drawings involved apparent

offsets in the location of certain piping sections or supports. The offsets

were noted as the alleger attempted to trace. piping system configurations

and related supports from information provided on drawings of walkdown

isometerics, penetration sleeve details, building steel floor layout,

concrete wall penetration location, and pipe supports detail / reference

location. The magnitude of the maximum alleged dimensional discrepancy

was approximately I'-6".

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The specific discrepancies, according to the alleger, are summarized in

Appendix I of this report.

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4. Safety Related Piping Systems As-Built Inspection

4.1 Overview of the Piping As-Built Program

The scope and controlling procedures for the as-built program of Safety

Related (S/R) piping systems differed according to the organization

responsible for the erection or the design and reconciliation of com-

pleted installations. Though the majority of S/R piping and support

installations (except for the primary coolant loop) were fabricated

by DRAVO and erected by Pullman Power (P-H), the responsibility for

the design and reconciliation of ASME Class I piping was that of W

and for Class II, III and ANSI 831 piping was UE&C. As-built verifi-

cation of completed piping installation was conducted twice, first by

P-H as part of the ASME code "NA" certification prior to turnover and

second, by W and UE&C in support of the stress reconciliation effort

of their respective piping.

The inspector conducted interviews with cognizant licensee representa-

tives and reviewed procedures (Attachment 1) established by Westinghouse

(W) and UE&C which governed some of the activities performed by the

Piping and Pipe Support Closeout Task Team (PAPSCOTT). These activities

included the as-constructed walkdowns and the stress analysis reconcil-

iation and pipe support verification tasks in support of the ASME N-5

certification program.

The flow chart in figure 4-1 depicts the sequence of activities

involved in the ASME completion program for piping systems from the

design phase through code certification. The numbers in the flow

chart blocks identify the sequence of certain activities performed by

the engineering / design and installing organizations. The as-engineered

piping was typically shown on design isometrics by W or UE&C (block

1). The desigr. isometrics were transmitted to the fabricator (DRAVO)

for preparation of piping spool drawings. These drawings were used

by the installer (P-H) for the preparation of erection drawings and

subsequent piping erection (block 2). Field verification of piping

and related components installed in accordance with ASME Section III

was performed by the installer prior to turnover to satisfy code

certification requirements. Data verified during the installer's

walkdown were either incorporated in revised erection drawings or

red-lined on current isometrics (block 3). Walkdown verification of

as-built piping installations was subsequently conducted by the

engineering / design organization for the purpose of piping stress

reconcilation. Though some of the verification attributes were

common to both walkdowns, the piping data verified during the recon-

cilation effort were pertinent to piping stress analysis and code

acceptance limits. Results of the latter walkdown were recorded on

marked up isometrics (Block 4). These isometrics were considered

final when the marked walkdown drawings were signed as approved, as

in the case of W drawings, or when stamped "As-Constructed", as in

the case of UE&C drawings.

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- The significant features.cf the piping as-built program which related

to the allegation concerns are presented below.

I. As-Built Walkdown Prior to Turnover-

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Interface activities between P-H, UE&C and the startup test

department, relative.to the release and turnover of systems

were described in P-H Procedure X-23.

--

Documentation of field verifications, final inspection and

final _ review of ASME III piping was governed by P-H Procedure

X-4.

---

The walkdown was conducted by P-H field engineering in. accord-

ance with walkdown_ implementing Procedure No. X-30 for field

verification and recording of piping linear measurements

and elevations.

--

Field verification of supports was conducted to P-H Procedure

JS-IX-6.

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Walkdown packages including as-built isometric drawings and

walkdown verification forms were transmitted to P-H/QC for.

_ performance of final piping and support inspections.

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Walkdown packages were transmitted to P-H/QA for review of

completeness prior to the sign off on ASME Code "NA" certi-

fication.

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Data recorded during the as-built walkdown were either_incor-

porated in revised erection isometric drawings (prior to mid-

1984) or red-lined on current erection isometrics (after mid-

1984).

II. ' Piping Qualified by W

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W generated the piping design isometrics using original UE&C

j isometrics, and performed the piping stress analyses of record,

f --

As-built piping walkdowns were performed by teams including

engineering and surveying personnel to' record piping config-

i uration on the design drawings in accordance with Procedure

l- SSP-1. Angular measurements were recorded at elbows and pipei

l bends, though no specific tolerance was provided in procedure

! SSP-1. A tolerance of 5 degrees in angular measurements was

noted in a correspondence between W and NHY.

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--

Marked-up walkdown drawings were reviewed against change

documents and other design information for evaluation of

discrepancies identified during the walkdown process.before

final approval of the drawing.

--

Reconciliation of as-built installations addressed five

categories involving piping configuration, pipe supports,

pipe properties, loading conditions and interferences.

--

The acceptance criteria for the reconciliation effort were

stated in Procedure SSP-2.

--

Piping neasurements which exceeded the reconciliation accept-

ance criteria were reconciled either by hand calculations or

computer re-analysis, and noted on final analysis isometric

drawings. However, measurements which fell within the accept-

ance criteria were not noted on these drawings.

--

Final piping as-built packages consisted of approved walkdown

isometric drawings containing three signatures, final analysis

isometric and stress analysis report.

III. Piping Qualified by UE&C

--

UE&C generated piping isometrics which were used by

Pullman Power for the preparation of installation drawings.

--

Location of piping supports during the installation phase

was based on measurements provided on each support drawing

from nearby building elements such as walls, beams, columns,

etc. These dimensions were provided in addition to location

plan measurements which were intended for reference purpose

only.

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UE&C utilized Pullman drawings and related ECA's and NCR's

, to update the piping isometrics.

--

The elements of the piping as-constructed walkdown data

collection were described in procedure FAEP-1. Design

drawings and checklists were used to record walkdown data

which include: (1) location of pipe supports relative to the

piping; (2) location of floor / wall sleeve and gaps relative

to piping; (3) pipe support function; (4) pipe support gaps;

(5) location / orientation of welded attachments; and (6) build-

ing location dimensions.

--

Additional requirement regarding the walkdown data collection

and the accuracy of measurements was provided in Technical

Procedure TP-26.

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Verification of piping as-built angle data was not addressed

in the walkdown procedures. The rationale for not performing

angular measurements during this phase included consideration

of very stringent tolerances in the location of end components

and the fabrication and erection of pipe support components

and piping spools. Variations in piping segments length due

to cutting or addition of sections during fit-up of spool

pieces were verified and reconciled during the walkdown effort.

Results of a confirmatory walkdown conducted in 1983-1984 were

provided in support of the above rationale. The walkdown

involved approximately 500 drawings for verification of piping

bend angles as well as end-components and support locations.

Evaluation of the results from 130 drawings indicated that

angles were within 5 tolerance of drawings or ECA's.

--

Dimensions verified in the walkdown effort were circled on

the final as-constructed drawings.

--

The evaluation criteria and acceptable tolerances used for

the reconciliation of as-constructed installation were stated

in Appendix "C" of Procedure PGL-7. The tolerances were

consistent with the recommendation in a technical position

paper on piping installation tolerances sponsored by the

PVRC technical committee on piping systems and published in

Bulletin 316 of the Welding Research Council.

--

Firal as-built packages consisted of isometric "As-Con-

structed" drawings reflecting walkdown measurements, final

analysis isometrics and stress analysis reports.

4.2 NRC Walkdown Verification of Piping Installations

A physical inspection was conducted, by the NRC inspector of piping

installations referenced in the allegation and other randomly selected

systems. The inspection included several piping segments of the RHR

system inside and outside the containment (by W and UE&C) in addition

to segments of the piping system from the accumulators (No.1 & 2).

The inspection utilized W stress isometric and UE&C as-constructed

drawings. Piping segments and drawings used in this effort are

identified in Attachment 2 to this report.

The purpose of this effort was to examine the conformance between

installed piping systems and the information recorded on walkdown and

analysis isometric drawings. Though the processes of piping installa-

tion and as-built verification were examined and reviewed by the NRC

throughout the construction phase until completion, this effort was

undertaken primarily to assess the specific discrepancies identified

in the allegation and to further examine piping installations in

general, for potential non-conformances of a type which would invalidate

the piping stress reconciliation effort. Examples of previous NRC

inspections of piping as-built verification inspections can be found

in Inspection Report Nos. 50-443/85-09, 85-15, 86-14, 86-43 and 86-46.

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The verification walkdown included visual inspection and performance

of independent measurement of selected piping installations. The

attributes of the inspection included the following:

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Checking actual configurations against piping drawings.

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Performing linear measurements between components and supports

along the piping using a tape measure.

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Checking piping angles either visually or by trigonometric

correlation of linear measurements on piping legs where possible.

--

Checking valve types and tagging.

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Checking support types to verify restraint function.

--

Checking clearances between piping and supports where required.

A total of 153 linear measurements were verified during the piping

walkdown, of which 98 were performed on W piping and 55 on UE&C

piping. It should be noted that the majority of piping inspected

was insulated; thus, measurements which were difficult to perform

were considered acceptable if within 2" of recorded dimensions.

Measurements performed on W piping which exceeded the walkdown

acceptance tolerance were later compared against recorded measure-

ments on walkdown isometric drawings.

4.3 Findings

The following findings are based on the NRC review of the piping

as-built program, walkdown verification of selected piping installa-

tions, and examination of alleged discrepancies.

1. The procedures established for the performance of piping as-built

walkdown verification and stress reconciliation efforts were

found to be consistent with accepted industry practice. Further-

more, the licensee's approach to the as-built process met the

requirements and intent of the NRC's I.E.Bulletin 79-14 in that

it provided the needed verification of the attributes and dimen-

sions, within acceptable tolerances, which define the relative

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configuration of piping and are considered critical to design

and the validity of the piping stress analysis. Verification of

reference dimensions which affect the global position, relative

to the building structure, of piping and supports in three

dimensional space was not generally included in the as-built

program and is not required to be included. Verification of

dimensions between piping systems and building structures is not

required for stress reconcilation since the piping stresses are

determined by the piping system geometry not the piping to

building structure dimensions.

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2. The alleged discrepandes in as-built drawings of safety related

piping systems were for the most part incorrect due to:

a) use of W walkdown drawings which were not final,

b) introduction of erroneous values of piping dimensions at

flued head sleeve anchors in the attempt to correlate dimen-

sional information from sleeve detail drawings by UE&C and

walkdown drawings by W (apparently the result of miscommuni-

cation between the alleger and field personnel),

c) use by the alleger of several values beyond their intended

accuracy, particularly with regard to support location

reference dimensions and location of both building steel

members and wall penetrations, and

d) reliance by the alleger on exact values to be recorded on

piping walkdown drawings while ignoring linear and angular

tolerances which were inherent in the field walkdown process.

Detailed evaluation of the specific alleged discrepancies is

provided in Appendix I of this report.

3. Minor dimensional discrepancies were noted between linear measure-

ments performed during the NRC piping walkdown and dimensions

recorded on the walkdown drawings. A total of eleven (11) discre-

pancies was found, of which eight (8) were within 3" of the walk-

down drawings and the remaining three within 3.75", 5.5" and 6"

respectively. It should be noted, however, that three of the

dimensions with discrepancies involved measurements which were

difficult to perform due to insulation and inaccessability of the

piping system. Furthermore, in all of the dimensions involving

discrepancies, the difference between the design and measured

dimensions were well within the acceptable tolerance set by the

reconciliation criteria. Thus, a re-analysis of associated piping

would not have been required.

4.4 Conclusion

The inspector concluded that the program for the as-built and reconcil-

iation process of safety related piping and support systems, qualified

by W and UE&C at the Seabrook Station, were consistent with accepted

industry practice and no items of non-compliance were identified with

regard to NRC requirements set forth in I.E.Bulletin 79-14. Further,

upon review of the alleged discrepancies and performance of walkdown

verification of completed piping installations, it was apparent that

the as-built drawings had reasonably depicted the piping configurations

as required for performing the stress reconciliation effort. It was

also concluded that the approach utilized by the alleger in performing

the interference verification relies on very precise and accurate

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measurements of piping components and building elements. Some of these

measurements are recorded with tolerances (as in the case of piping and

support systems), and the remaining are not typically verified in the

as-built walkdown (as in the case of support reference dimensions,

penetration and building steel locations, etc.). It is not necessary,

nor is it common industry practice, that these precise measurements be

made to support the pipe stress reconciliation effort.

Based on the above, it is concluded that the allegation involving the

adequacy of as-built safety related piping systems at the Seabrook

Station is unsubstantiated.

5.0 Review of Other Programmatic Activities

5.1 Gereral

The NRC review included an assessment of several other programmatic

activities performed by the licensee which were addressed by the

alleger as potentially deficient due to the alleged dimensional

discrepancies. The programs covered in this effort included the Beam

Verification, the Seismic II/I Interaction, and the Failure Mode and

Effects Analysis Programs. The review focused primarily on the scope

and implementation of these programs to verify their conformance to

acceptable industry standards and their compliance to NRC regulations.

The review also covered the interface between these activities and

the piping as-built verification effort to assess the alleged potential

for ineffective evaluations as a result of using the piping as-built

drawings in the performance of these programs.

5.2 Building Beam Verification Program

The purpose of this effort was to verify that the design of category

I structural steel, which was based on assumed loads, was adequate

for final as built system loads. The program was managed by UE&C,

and described in technical procedure TP-16. It was initiated in 1983

with the establishment of a data base of all appropriate loads required

for the beam verification effort. The original design was based on

consideration of assumed uniform loads in addition to known heavy

attachment and equipment loads. During this design phase, the intent

was to maintain flexural beam stresses below 18 ksi.

The beam verification program was carried out in two phases. The

scope of the first phase included an initial verification of framing

systems using discrete design loads and locations for major attach-

ments, such as large bore pipe supports and equipment, and appropriate

(envelope) uniform loads for attachment of cable tray, conduit, I&C,

and small bon pipes. Structural weights and live operational loads

were also considered in this phase. The magnitudes of selected

envelope uniform loads in different plant zones were based on walk-

downs performed in 1984.

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Beams evaluated in the first phase whose flexural stresses fell

between 18 and 22 ksi were designated as heavily loaded beams. Those

which exceeded 22 ksi were designated as critically loaded beams and

painted with an orange paint. The painting was intended to prevent

any attachments to these beams without prior approval from the

structural group. Re-evaluation of critically loaded beams was

performed using more refined analytical techniques and actual attach-

ment loads in lieu of assumed conservative uniform loads.

The second phase in the verification program involved the incorporation

of PAPSCOTT reconciled piping support attachment loads. The following

three categories of beams were considered in this re-evaluation:

--

Typical beams (stressed below 18 ksi) were re-analyzed if the

magnitude of uniform loads had increased significantly or if

attachments of piping 4" in diameter or larger were added.

--

Heavily loaded beams were re-evaluated for any additional loads

to ensure that flexural stresses were below 22 ksi.

--

Critically loaded beams were re-evaluated if the applied loads

from the first phase had increased. A walkdown was typically

performed to verify the as-built geometry, loading and boundary

conditions for these beams.

-This second phase of the beam verification program was completed in

July of 1986.

5.3 Seismic II/I Interaction Program

The program, described in Technical Procedure TP-4 (Review of Non-Safety

Related Equipment, Systems, and Supports located in Safety Related

Buildings) was conducted by UE&C to meet the requirements of Regulatory

Guide 1.29, Position C2. The Regulatory Positions was implemented by

,

either of the *-llowing approaches:

1

(a) Providing seismic supports to non-safety related systems and sup-

ports (such as piping, ducts, cable trays, conduits, bus ducts,

and I & C trays and tubing) located in safety related baildings

to prevent their failure and damaging of safety related systems

and components during a seismic event.

(b) For items which were not seismically supported, Failure Modes

and Effects Analysis (FMEA) was performed to assure that they

were isolated by their location and their postulated failure

would not impact on safety related components during a seismic

event.

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-The procedure (TP-4) provided a tabulation of non-safety related items

which were installed in safety related buildings. These items (generally

considered large equipment) included tanks, instrument racks, seismic

• ccceders, cooling units, dampers, cooler fans, louvers, sump pumps,

chtlier pumps, cabinets, unit heaters, radiation monitors, etc. This

equipment was listed by the building in which it was located and was

identified by its classification, tag number, type of anchorage and

relative location to other safety related equipment. Support for non-

safety related and seismically mounted equipment identified in TP-4 was

provided in special detailed drawings by the manufacturer or UE&C.

D.her small non-safety related items such as instruments, wall mounted

electrical boxes, switches, etc. were not addressed in procedure TP-4.

These were seismically mounted in accordance with typical notes and

details for I&C and conduit support drawings.

A two phase confirmatory field walkdown was instituted in early 1986 for

al) non-isolated, seismically anchored and all isolated, non-seismically

anchored equipment listed in TP-4. The walkdown was completed in the

Diesel Generator, Fuel Storage, Service Water Pump House and Service

Water Cooling Tower. This effort was discontinued, however in other

safety related areas due to lack of findings.

Licensee evaluation of the seismic II/I interaction was substantially

complete except for a walkdown which is currently being performed of all

hose reels and fire extinguishers in safety related areas for isolation

and requirement for seismic mounting.

5.4 Failure Modes and Effects Analysis (FMEA) Program

This FMEA program was initiated by the licensee to address the require-

ments of 10 CFR 50, Appendix A, General Design Criteria 4 which requires

that structures, systems, and components important to safety be designed

to accommodate the effects of postulated accidents, including appropriate

protection against the dynamic and environmental effects of postulated

pipe ruptures. The program provided evaluation of pipe whip, jet

impingement, and flooding effects on safety-related plant systems,

structures and components. The evaluation was documented in eighty-three

(83) zone reports which contained the information required to evaluate

the consequences of piping failures within the zone on essential plant

systems and components.

The program was managed by UE&C and was performed in accordance with

Technical Procedure TP-3. The procedure adopted the guidance for

postulated rupture locations, types and sizes presented in the Standard

Review Plan (NUREG-800), Sections 3.6.1 and 3.6.2. The criteria estab-

lished the specific rupture conditions to be evaluated including the

consequential effects of the ruptures.

i

I

,

I

<

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.

14

The evaluation effort was accomplished in two phases. The first phase

(1982-1985) was performed using plant design drawings, such as struc-

tural, general arrangement, piping, HVAC, etc., for detection of targets

to be evaluated. The second phase consisted of plant walkdowns to verify

actual as-built conditions of safety-related systems and components

evaluated in the first phase, and to identify other safety related

systems, components and field run commodities which were not previously

addressed. The inspector was informed that the Seabrook scale model

was not utilized in the conduction of either phase. Prior to performing

the plant walkdown, an evaluation was performed of as-constructed piping

drawings by W and UE&C.to identify systems which had changed in configur-

ation to assess the likelihood of revised postulated break locations and

potential targets. Criteria for acceptability of interaction involved

considerations of system operability and/or structural functionality.

The second phase of the FMEA activities was completed in April, 1986.

5.5 Conclusion

Based on the NRC evaluation of licensee programs for the performance

of safety related activities addressed above, it was concluded that the

programs had met the intent of the regulations and were substantially

in conformance with established industry standards. Further, upon

review of the interfaces between the piping as-built program and the

Beam Verification and Failure Mode and Effects Analysis programs, it

was concluded that they were adequate for performing these activities.

Based on the above, it is concluded that the allegation involving

the adequacy of these safety related activities at the Seabrook

Station is unsubstantiated.

6. Exit Meeting

The inspector met with licensee representatives (denoted in paragraph 1)

at-the conclusion of the inspection on October 31, 1986. The inspector

summarized the purpose and the scope of the inspection arid the^ findings.

At no time during this inspection was written material provided by the

inspector to the licensee.

.

.

ATTACHMENT 1

DOCUMENTS REVIEWED

The following documents were reviewed, in part, during the course of

inspection:

Procedure No. X-30 for field verification of piping by Pullman Power

• Procedure No. X-4 for field inspection by Pullman Power

• Procedure No. X-23 for Turnover by Pullman Power

Procedure No. PGL-7 for AMSE and NNS-IA Piping and Pipe Support

Reconciliation Program by UE&C

• Position Paper on Acceptance Criteria for Piping Installation by UE&C

Technical Procedure No. TP-26 for As-Constructued Requirements of Piping

Systems by UE&C

Procedure No. FAEP-1 for ASME Field Data Completion Program by UE&C

Technical Procedure No. TP-33 for "As-Constructed" Verification Program

for ASME Piping System Installed by UE&C

• Procedure No. SSP-1 for As-Built Reconciliation Walkdown Guidelines by W

Procedure No. SSP-2 for Review of the As-Built Condition of Westinghouse

Analyzed Auxiliary Lines

Quality Control Procedure No. QCP-17-5 for N-5 Data Report by UE&C

Specification No. 9763-006-248-51 for Assembly and Erection of Piping and

Mechanical Equipment by UE&C

Procedure No. JS-1X-6 for Installation and Inspection of ASME III Pipe

Supports by Pullman Power

Procedure No. TP-3 for Conducting Failure Modes and Effects Analysis

(FMEA) Piping Failure by UE&C

Procedure No. TP-4 for Review of Non-Safety Related Equipment, Systems

and Supports located in Safety Related Buildings by UE&C

Technical Procedure No. TP-16 for Beam Verification Program

l

l

-. .

.-- - _ . _ _ _ _ - _ _

.

.

ATTACHMENT 2

Piping Qualified No. of Description of Piping

Line No. By Measure- Section Verified

Drawing No. ments

RHR1-W0013 (Sh.1) RC-13-13-601-12" W 10 Between penetration and

sleeve No. 13 A

RHR1-W0013 (Sh.2) 180-1-2501-8" W 11 Between line 160 and

penetration No. 34

RH4-W-0058(Sh.1) 58-13-601-12" W 12 Between penetration X-10

and 10-lh" horizontal

run beyond hanger No.

58-SG-07

RH4-W-0058(Sh.2) RH-160-3-2501-12" W 17 Between penetration X-13

& 160-4-2501-8" and 1-5" horizontal run

beyond hanger No.

160-SG-05

ACC1-W0155 (Sh.1) SI-201-1-601-10" W 26 Between ACC. Tank.9A

and 2'-10 " horizontal

run beyond hanger No.

201-RM-15

ACC2-W0162 (Sh.1) SI-201-1-601-10" W

-

22 Between ACC. Tank 9B  :

and I'-9" horizontal

run beyond hanger No.

202-RM-09

F-800160-542.01 160-1-601-8" U&EC 35 Between penetration

X-13 and 7'-0"

horizontal run beyond

sleeve No. 1558

D-800014-491.70 RC-14-1-601-3" U&EC 20 Between line No.

l RC-13-2-601-12" and

'

10 " horizontal run

before hanger No.

'

14-SG-8

l

l

.. . . - _ _ - . . .. . ___. _ _ , .

_ _ ._

.

.

Appendix I

Details of the alleged discrepancies in as-built piping drawings are given below.

For each of the six descrepancies, the description, according to the alleger's

drawings, is followed by the results of the NRC evaluation. Simplified

figures, projected from the allegers drawings, are included to illustrate the

configuration and geometry of piping, supports and building sections involved.

a. Descrepancy Drawing No. 53-A

Details: W piping No. RC-13-13-601-12" shown on sheet 1 of Dwg. No.

RHR1-W0013: The piping runs from penetration No. X-9 to sleeve No. 13A

(incorrectly referenced as sleeve No. 33). The piping was shown by the

allegers analysis to be interfering with the concrete wall as it penetrates

sleeve No. 13A. An offset of approximately 4" was shown between the piping

and sleeve centerlines. (See attached Dwg. No. 1)

NRC Evaluation: The l'-0" dimension between the inside face of the con-

tainment at penetration No. X-9 and the weld line is irrelevant. The 12'-8

3/4" starting dimension shown on the run of piping (No. RC-13-13-601-12")

from the weld line to the bend is incorrect. The measurement should be from

the penetration guide at the face of the lug. The incorrect assumption

introduced-an additional 6 3/4" to the piping run length towards the east

direction. Further, the opening for sleeve No. 13A was shown to be approxi-

mately 16" in diameter, whereas it measured approximately 23". Correction

of both errors in the alleger's analysis would eliminate the discrepancy ana

allow the pipe to pass through the sleeve with no interference.

b. Discrepancy Drawing No. 53-B

Details: UE&C piping No. RC-14-2-A7-4" and support No. 14-SG-7 shown on

Dwg. No. D-800014-491-70: The piping branches off W piping header No.

RC-13-13-601-12" identified in (a) above. The piping at the location of

the support was shown to be offset by approximately 9". (See attached-

Dwg No. 2)

!

NRC Evaluation: Three dimensional errors were noted. The first involved

~

the incorrect point of line No. RC-13-13-601-12" from penetration No. X-9,

identified in "a" above, which resulted in the introduction of a 6 3/4" error.

The second and third involved two dimensions on east-west runs of piping

No. RC-14-2-A7-4" by UE&C. The dimensions which were shown on Dwg. No. 538

as 2-6 1/2" and 2-11" were recorded on UE&C "as constructed" drawing No.

D-800014-491.70 and verified by the NRC walkdown as 2'-6" and 2'-91/4".

These two errors introduced an additional 2 1/4" in the east direction.

l The three errors collectively resulted in the alleged offset of 9" between

the piping and the support.

,

j

l

. -

. . _ , -_

_-

.

.

Appendix I 2

c. Discrepancy Drawing No. 53-C

Detail: Two related discrepancies in: (1) W piping No. RH-160-3-2501-12"

shown on sheet 2 of Dwg. No. RHR4-W0058; (27 W piping No. RH-180-1-2501-8"

shown on sheet 2 of Dwg. No. RHR-1-W0013; (3) UE&C piping No. RH-182-1-2501-3/4"

shown on Dwg. No. 800182-S43.00; and (4) UE&C piping No. RH-181-1-2501-3/4"

shown on Dwg. No. 800181-543.01. The four piping lines e.re connected in a

closed loop in the same sequence listed above where line No. 181 connects

back to the main header No. 160. The first discrepancy involved an offset

in the connection between lines No. 181 & 160 of approximately 10". The

second discrepancy involved an offset in the location of support No. 180-SG-4

on line No. 180 from its designated location on the building steel. (See

attached Dwg No. 3)

NRC Evaluation: The dimension 6'-8 9/16" between-the elbow on line No.

RH-180-1-2501-8" and the junction to branch line No. RH-182-1-2501-3/4" is

incorrect. The dimension was shown on W stress isometric as 7'-7 7/8" and

-

was measured during the NRC walkdown as 7'-81/4". The alleged offset

discrepancy of 10" could be substantially eleminated if the difference

between the correct and the alleged dimensions is multiplied by the cosine

of the angle between the line and the east-west axis (20 ). The alleged

offset in the location of support No. 180-SG-4 on line no. 180 could be

substantially reduced if the 24'-3 7/8" dimension on line no. RH-160-3-2501-12"

is corrected to 25'-10", and the starting point of the same line from the

lug at penetration no. X-13 to the elbow is corrected to 2'-91/2". This

is addressed further in the next alleged discrepancy. Further, it is

significant that the second alleged discrepancy was based on correlation

of piping as-built verification measurements with dimensions obtained from

the pipe support reference location and the building steel layout drawings.

Since neither the support reference nor the building steel location

dimension was verified (or required to be verified), the alleged discrepancy

is deemed erroneous.

d. Discrepancy Drawing No. 53D

Details: W piping No. RH-160-3-2501-12" shown on sheet 2 of Dwg. No.

RHR4-W0058. Two discrepancies were noted: The first involved an offset

in the location of supports No. 160-SG-5 and 160-RM-6 on the above line

from their designated location on the location plan of the respective

support drawings. The offset was approximately 18" on both supports. The

second discrepancy involved an offset in the connection of line No.

250-4-2501-2" to line No. 160-5-2501-8". The offset was shown as 11 13/16"

in the east-west direction and l'-3 7/8" in the north-south direction.

(See attached Dwg No. 4)

-_. _ _ - - - - - . _ _ - - - -

.

a

Appendix I 3

NRC Evaluation: The alleged offsets in both support locations and the branch

line connection were caused by two dimensional discrepancies on the piping

run in addition to the use of reference centerline dimensions from structural

drawings in locating pipe support attachments. The starting 2'-9 1/2" dimen-

sion of piping No. RH-160-3-2501-12" from penetration No. X-13 to the first

elbow should be measured from the face of the lug rather than from the piping-

to-sleeve weld line as shown on Dwg. No. 53-D. The other dimensional discrep-

ancy involved the length of the piping run from the elbow (near penetration

X-13) to the first piping bend. The dimension was noted as 24'-3 7/8" on Dwg.

No. 53-D and on the W preliminary walkdown drawing. The correct dimension

was shown on the final W isometric drawing as 25'-10". Since the dimensional

error in the W drawing involved a walkdown drawing which was still in process,

the inspector could not determine with certainty whether the internal checks

by W had independently identified the error. Nevertheless, the alleged off-

sets can be substantially eliminated when the above dimensional corrections

are incorporated.

e. Discrepancy Drawing No. 53-E

Details: UE&C piping No. 160-1-601-8" shown on Dwg. No. F-800160-542.01.

The piping is routed through six penetrations. The discrepancy involved an

offset between the piping and penetration No. 1416 by approximately 3.5"

towards the north direction. It also involved an offset between the same

piping and penetration No. 1584 by approximately 3.5" towards the south'

direction. (See attached Dwg No. 5)

NRC Evaluation: The alleged discrepancy was determined to be erroneous

because it was based on inherently incorrect assumptions and misunderstand-

ings of the as-built process. The relative locations and orientations of

the six penetrations involved in this discrepancy were neither verified

with respect to each other nor with respect to a fixed reference point,

and are not required to be, during the as-built process. In addition,

penetration centerlines were not necessarily parallel to, or concentric

with, centerlines of piping which passe through these penetrations. Any

possible angularity, within the 5 tolerance, between the centerline of

the piping run (No. 160-1-601-8") and the penetrations involved will

eliminate this apparent discrepancy. % NRC inspector's walkdown of the

piping involved between penetrations Ro. !-13 and 1558 confirmed the

adequacy of measurements on the dv >nr * ucted" drawing by UE&C within

specified tolerances.

f. Discrepancy Drawing No. 53-F

Details: Configuration of W piping No. RC-13-13-601-12" from penetration

No. X-9 or sheet 1 of Dwg. No. RHR-1-W0013 (incorrectly identified as piping

No. RC-13-1-2501-12"): The piping configuration was shown twice using dimen-

sions from W drawing above, and Pullman Power erection Dwg. No. RC-13-06.

The two configurations were offset by approximately 5'-0" in the east-west

direction primarily due to the difference in length of the piping run from

the penetration. The other discrepancy in the same drawing depicted the

distance between the two legs of a U-bend as 2'-9" according to W drawing

and as 3'-6" according to Pullman drawing.

.

I

'

, .

Appendix I 4

NRC Evaluation: The dimension of piping No. RC-13-13-601-12" from penetra-

tion No. X-9 to the first bend was consistent between W and Pullman erection

drawings, contrary to the 5-0" offset shown on Dwg. 53-F between the two

layouts. Further, the apparent discrepancy in the piping dimension, between

the two legs of the U-bend, was resolved since it was noted and verified as

3-6" on both W final isometric and Pullman erection drawings.

e

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