ML20114C248
| ML20114C248 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/20/1984 |
| From: | Kalawadia K UNITED ENGINEERS & CONSTRUCTORS, INC. |
| To: | Shewmaker R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20105D114 | List: |
| References | |
| FOIA-84-531 NUDOCS 8501300118 | |
| Download: ML20114C248 (250) | |
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File: 11.5.2 Mr. Robert Shewmaker ' U.S. NRC Office of Nuclear Reactor Regulation 4350 E.W. Highway. East-West Towers h ' West Building, Room 505 F g'Jb - Bethesda, Maryland 20814 Public Service Co. of New Hampshire Seabrook Station - Units 1 & 2 Responses to Potential IDI Findings for Structural Discipline
Dear Mr. Shewmaker:
~
Based on our discussion at the Exit Meeting of December 28, 1983 and various telephone conversations, we are offering additional information for the items listed on Attachment A. Our responses cor-respond to Serial Numbers on Attachment A. We are also confirming our understanding of these items and our responses. It is our belief that our understanding and responses reflects various telephone conversations of the last few days related to this matter. Our responses and/or understanding of these items are as follows: f.s .3 1. See Attachment B. A detailed calculation was performed for eccentric loading
/ 4-d 2. on the member due to bent plate connection and the result was found to be very satisfactory. These calculations will b'e attached to the appropriate calculation set.
ges _.s 3. Our understanding is that the problem does not exist with the liner test program conducted by Prof. Burdette and hence the issue is considered closed. However, the Pipe Support Disci-pline will respond by separate correspondence for the embed-ment plate test program conducted by Prof. Burdette. [4-7 4. We have reviewed Calculation Set CS-15 with respect to the latest input from the Structural Analysis Group and have found that the results are satisfactory. However, the <1cula-tion will be formally revised within a to reflect this iaform-ation. We understand that this will be satisfactory to close any concern on the subject. F #-3 5. Calculation Set WB-61 including reference to SSE condition has been revised to clarify the design of beam B-9 and ccmpletely signed through as a formal revision. This item will br con-sidered closed. , twa 190 470 1267 TELEX 43-4203 f f L E COPit A 21$ 422 3049 T E L E P=ONE 215 422 noo g B501300118 840001 p . ... _ ._.... j PDR FOIA CURRAN 84-531 PDR
l .: 1 January 20, 1984 Mr. Robert Shewmaker Page 2 of 3 jr,4_f,g 6. Calculation Set WB-68 has already been revised with proper use of SP-17. The results of these changes have been found to be satisfactory. -This item will be considered closed.
,c; 4c _f f 7. Calculation Set CI-2 has been revised with proper consider-ation of the SSE load condition. The result of the calculation does not change. This item will be considered closed.
j; g,jg 8. The eccentric connection in annular steel framing was eval-uated as per Mr. Lipinski's request. Proper stiffnesses were utilized in the analysis of this connection and found that the moment carried by the joint and the enbedment plate was comparatively small. - Bolts were found adequate as they are. This analysis and design of the connection wi21 be made part of appropriate calculation sets for further reference. We understand that this should be satisfactory to resolve Mr. Lipinski's concern and will be stated so in a final report.
- 9. Concern about inconsistencies in various documents regarding tank farm design requirements are being reviewed. Appropriate
/I S-2# action will be taken to clarify all ef fected documents such as FSAR, Structural Design Criteria, System Description, etc. at a later date.
jrgef7 10. Re-evaluation and, if necessary, re-analysis will be performed g g,fy for tank farm to resolve Mr. G. Harstead's concern. The work is already in progress with the Structural Analysis Group for this area.
- 11. We have evaluated the eccentric connection of the girder fram-
# ~#9 ing into tne column in annulus steel. We find that the effect of this eccentricity is very nominal at the joint and also on the members. Conclusion of our study indicates that the members and connection is adequate as it is. This calculation study will be filed with the ef fected calculation sets. We understand that this will be satisfactory and stated so in the final report.
- 12. We have not been able to locate a previous copy of Calculation i '2d? Set PB-76 for the design of platforms. However, _ as you have noted during your audit, we do have a final calculation set which proves that the platform steel is adequately designed as it stands. .
---r-
Mr. Robert Shewmaker January 20, 1984 Page 3 of 3 g; cf_g/ 13. A note on UE&C Dwg. F-101402 was revised to clarify the grouping of shear ties as requested by Mr. LipinsLi. However, there was no -change in the existing steel as was furnished by the Bethlehem Steel drawing. This change was done to avoid misinterpretation of terminology. This item is considered closed.
/ ,f 23 14. The NRC's concern about the use of live load along with j; gy-yg seismic event is being reviewed at present by UESC. This 4 item will be responded to at a later date after we have
-adequate information at hand.
In a telecon between K.M. Kalawadia of UE&C, Don Johnson of Yankee, and Robert Shewmaker, R.E. Lipinski and Gunnar Harstead of NRC on January 20th at 10:30 A.M., all of the above items were reviewed and the NRC had accepted these answers. If you have any questions, please call K. M. Kalawadia. Very truly yours, f&~$ vW^ b .'9 K. M. Kalawadia Supv. Structural Engineer - KMK:jg attachments i e - > , , , . , ,
ATTACHMENT'A PUBLIC SERVICE CO. OF.NEW HAMPSHIRE
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SEABROOK STATION - UNITS 1 & 2 i 1 STRUCTURAL DISCIPLINE POTENTIAL IDI FINDINGS
- - -- -"~~~
DESCRIPTION I SERIAL NO. Some of the memos in the Structural Discipline files 1 4 do not have contral numbers. A list of few of these memos have been handed out to the Structural Disc. Inconsistencies in design drawings and vendor drawings 2 exist for connections. Bent plate connection shown on vendor drawing was not properly identified
- on engineairng drawing. -
i Q. A. Requirements were not imposed on testing 3 program Purchase Order with Ed Burdett. Calibra-tion procedures for equipment are in question. Consider violation of GEDP 22 and QA 3.
- 4 Calculation Set CS 15 did not use proper input .
I data from S.'4 reporr. t
' Tank Farm Calculation Sec W361 had 3 designs 5
4 for beam B-9. Design not clear. Consider violation of GEDP-0005. Tank Farm Calculation Set W368 - Design of 6 column line 4.5 and 5.0 using ACI SP17 was not done properly. SP17 procidure was not followed correctly. j Calculation Set CI2 does not address SSE Icading . 7 ' as defined in SD66. 8 Structural Steel connection in annular steel does not account for eccentricity. Tank Farm design basis is not quite clear 9 for the seismic requirement and tornado j requirements. Tank Farm Calculation Set SBSAG SWB does not . l 10 represent proper. stiffnesses for the analysis. Modeling is not dene properly 4 to account for' concrete fill. i In Containment annular steel joint eccentricity 11 to' columns were not considered Ln analysis. f a
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ATTACIDIENT A Pcg3 2 cf 2
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(Cont'd)
~ . .
SERIAL NO._ DESCRIPTION i 12 Calculation Set PB76 did not exist at the time ' of releasing drawings for construction in 1976-1978 - violation of AP22. Inconsistency exists between Bethlehem Steel 13 drawings and Enginaaring drawings in identifying stirrups for the containment reactor pic. Note on the drawing should be revised properly. No live load was considered in design of beam 14 in RER vault with the seismic load conditions. FSAR and design criteria not quite clear re-garding this.
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These items were discussed in pre-exi.t' ~ meet'ing'. If anyone has any cuestions or need further details, please contact K.M. Kalavadia. , 1 t 8 a B
~1 PUBLIC SERVICE CO. OF NEW HM1PSHIRE Paga 1 cf 3 SEARROOK STATION - UNITS 1 & 2 ..,
ATTACHMENT B SERIAL CORRESPONDENCE I NO. DATE FROM / TO SU BJECT CLARIFICATION / REMARKS
, 1 10/15/79 Mehta to Hatwal Tornado loads on Admin. This letter was for information-
& Serv. Bldg. only. No calculations req'd by receiving party. Calculations were already performed by the originat-ing party.
/ 2 6/18/79 Pernice to Hatwal Seismic on Admin. & Serv. Bldg. - ditto -
3 11/23/82, Wilson to Kalawadia MS & FW Pipe Chase Blowout Panels Calculations were performed with 72 PSP. A letter was sent to accept vendor supplied material to the design basis. Corres pondence
. to this effect is attached to the calculation set.
4 2/25/74 ' Scott to Robinson Transmittal of basic Press-Temp- Control Number SBSAG 3CS exists as Time Data for LOCA & Contain- per AP-22. ment Design; Initial Load Combinations for contain. design
& sub-compartments.
5 8/7/74 Karousakis to Rhoads Finalized containment & This meno is written to confirm sub-compartments design para- design parameters. Outcome of meter. these analysis are reported in form of a report SBSAG 7CS which includes this information. 6 2/20/74 Karousakis to Hulshizer Transmittal of Temp. Transients This meno is sent as an additional for Containment Secondary Shield informal transmittal of data from Wall & Wall Temp. Profiles. other reports as it states in the contents of the meno. Hence control number not required. 7 3/17/76 Robinson to Crusetskie Final report for Seismic Analysis Control Number SBSAG-4CS4 exists as per AP-22.
r u a. ult bhKW!Lh LU. UP NcM ltAPit*bstlhc SEA 11 ROOK STATION - UNITS 1 & 2 Paga 2 cf 3 ATTACILMENT B (C ntinund) - SERIAL CORRESPONDENCE NO. DATE- FROM / TO SURJECT ' CLARIFICATION / REMARKS 8 11/3/80 Tseng to Flora Containment Wall Temperature Control Number PIN 9763.06
- Gradient. exists as per AP-22.
9 11/19/75 Robinson to Crusetskie Containment Axisymmetric Analysis Control Number SBSAC-7CS4 exists as per AP-22. 10 11/4/75 Robinson to Crusetskie Containment Analysis Addendum Control Number SBSAG-7CS3 exists to SBSAG-7CS3. as per AP-22. 11 10/22/75 Robinson to Crusetskie Containment Analysis Control Number SBSAC-8CS was assigned as per AP-22. 12 10/13/76 Robinson to Lin Containment Axisymmetric Control Number SBSAC-7CS was (Speed Ltr.) Analysis - Operating Temp. assigned as per AP-22. Gradient. 13 9/18/74 Crusetskie to Robinson Pressure / Temperature Design Control Number SBSAC-7CS as per ! & Analysis Criteria. AP-22. 14 5/29/75 Robinson to Rhoads Preliminary Containment This meno transmits preliminary Displacements. results for initial use.However, final results are sent under con-trol report no. SBSAC 7CS and SBSAC 4CS. Hence it is not neces-sary to have control no. for this nemo. 15 9/12/74 Robinson to Crusetskie Roundary Condition Restraints This meno was written to confirm telecon. We do not see any impact on final design.
'16 6/15/79 Ebner to Sarsten Seabrook Structural Audit This meno contains information for internal management and has no impact on any of our calculation performances. \/ 17 11/19/76 Ifulshizer to Dmytryk Capabilities of Structural - ditto -
Personnel.
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PUBLIC SERVICE CO. CF NEW HAMPSHIRE Pag 2 3 cf 3 - SEABROOK STATION - UNITS 1 & 2 - ATTACllMENT B (Continued) . SERIAL CORRESPONDENCE NO. DATE FROM / TO SURJECT CLARIFICATION / REMARKS g/18 2/3/75 C.F. Cole to Design Review Master List - ditto - Oste rman / 19 12/31/74 Boyle to SDE's Design Review - ditto - 20 9/23/75 Ebner to Hulshizer Chief Engineer's Design Reviewe of Primary Aux. Bldg. - ditto - 21 9/8/75 Kalavadia to Barnes Design Review of PAB (DRR Sil) Design Review of PAB (DRR Sil) is a control number of this building. V22 6/17/82 Rhoads to Aggarwal Sign-off of Electrical ECA's This meno contains information for internal management & has no impact on any of our calculation performance. 3
/ 23 4/2/82 Bhatt to Seabrook Structural Organization Chart This memo contains information for Structural Engrs (Field) and Minor Change internal management & has no impact
& Design Supvs. Definition. on any of our calculation performance.
However, the attachment has a Control Number SM-0053. k 24 3/18/82 Hulshizer to Processing of ECA's originating This meno contains information for All Seabrook Home Office-Structural. Internal management & has no impact Personnel on any of our calculation performance. 25 5/30/78 Hanson to Rhoads Comments on the Implementation - ditto - of Administrative Procedure #34. >
/26 5/5/78 Rothong to Document Review - ditto -
Seabrook SDE's & Design Supvs. 27 3/7/78 - Notes of. Conference regarding This is Notes of Conference which relates Design Change Notices (DCN's) to the DCN procedures only. There was no direct impact on calculations.
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- 8. Why is it not a finding or unresolved item?
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dop,.o, Sg) YYW-Document Name:
. SECTION 4.1 - SEABROOK IDI
/ Requestor's ID: i EILEEN !
Author's Name: R. Shewmaker j Document Conments: Design Information t 2 s . . J t i 9
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.4.1 Dessarr Mm*EM I M Sb The objective of this portion of the inspection was to determine, on the basis
.w] ne+keas desigri of tha material reviewed, if-the = theJ q the procedures 4and the design controls which have been used in the Seabrook project, reflect the requirements of NRC regulations, such as General Design Criteria, Regulatory Guides, Standard retereruced indus+ey Review Plan and othergcodes and standards. Furtha.swe, hevir.;; deteHned
% ed on 4the degree of consistency between the rules and regulations On 0"e Wd and the actual practice by the applicant and his agents, er. the eth;r, a determina-tion could be made$f'the levels quality assurance and~ quality control are acceptable.
Pursuing this goal, the team reviewed the organizational structure of the
, (p .u , we4]
Public Service Company of New Hampshire (23m*), ^ the design and construction (,yw ku AM) effort delegated to its agent, the Yankee Atomic Electric Company (BEC) and the execution of the design by the architect-engineer for the Seabr'ook plant,
; CAM ES United Engineers and Constructors W)T. Part cular attention was feu.m-f.cqe2 en te the interfacing between various organ zations such a and and their subcontractors.
4hs Ingeivil/ structural discipline, the applicant committed to comply with the NRC rules and regulations, the General Design Criteria, Regulatory Guides, Standard Review Plan (NUREG-0800) and other documents as well as the appropriate i commercial codes and standards. The basic document used in design of the , i 3IC. containment structure is the BoilerandPressureVesselCodeSectionp,
/z/rr43
~
4/~2 p i i j Division 2. Code for Concrete Reactor Vessels and Containments (Winter 1975 Addenda for containment liner; Winter 1976 Addenda for reinforced concrete), C. .4-)
; thereinsfter referred to as the ASME Cod . For other reinforced concrete structures, theg318-71, Building Code Requirements for Reinforced Concrete,y f-(with Commentary)'was used. Steel structures have been designed in accordance 4-with the IS 3 Specification for the Design, Fabrication and Erection of-Structural Steel for Buildings, 1969 Edition (including supplements 1, 2 and reyteweh For (Mii-quality cc..t:01 the 3). 4 applicant committed to use ANSI N45.2-1974,4-Quality Assurance Program Requirements for Nuclear Power Plantsg The Final Safety Evaluation Report (FSAR) included all of the pertinent Regulatory Guidesz 2s r&renees d,- % vMoa conmade=n.
i, The organization of the Seabrook project in place at the time of the inspection j is-best illustrated on Figure 1. TheExecutiveVicePresidentoftheh is responsible for all executive functions of the project. He reports directly TAe i to the president of the company. AVice President, Seabrook, (VPS), reports directly to the Executive VP and is in charge of all management functions. Both the Executive Vice President and the Vice President, Seabrook are from theh Working directly under the VPS are: Director of Quality Assurance; , Manager, Start-up Testing; Director of Construction; and Project Manager. These four positions are staffed by the There are three additional positions: the Manager Construction Support and the Construction Manager (both of them are from theh and Vice President of UE&C responsible for j project cessi,+rq -f SS fMW*' ' design and construction managemert. The YAE e,,s...eerir.4 groupAreports to the u r- cy r o o p s kended project manager and it.Sube{welee\ is Wtd by's% the following 4 eve positions:b l l
- M/r7 dry 4%/- 3
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+ + t
- a. Assistant project manager of construction t
- b. Engineering manager i e
- c. Senior project engineer 1 4
- d. Assistant project manager (licensing and operation)
The Engineering Manager has four lead engineers reporting to him:
- a. Systems Lead Engineer
+i .
- b. Mechanical Lead Engineer
- c. Instrumentation and Controls Lead Engineer .
- d. Electrical Lead Engineer ,
4 There are five engineers in the mechanical engineering discipline; three of them are civil / structural and two mechanical.
- ~5 We interviewed the th'ree engineers who are working in the civil / structural a rea. We found that all of them are graduate engineers, of them have master degree in civil or structural engineering. of them are registered professional engineers. Their experience range from seven years to nine with most of it in structural engineering related to nuclear plants. During i
nr/rr/r3 4./- 4 (-
~
the interviews they demonstrated generally good knowledge of their prc,fession, # r [ but their familiarity with NRC rules and regulations was somewhat less than L . would be expected. There was no evidence that YAEC provides any training in this area or encourages an improvement of their knowledge of the current regulatory positions.
\
The entire staff working for the project manager consists of 35 professionals. 1 The professional cross section of the civil / structural staff of the YAEC ' , j employed at the Seabrook Project is included in Table 4-1 which provides data for a representative cross-section of civil-structural engineers working on
.the Seabrook project.
(
- l. ,, .
l In our inspection, considerable attention was given to the interfacing between
! y e ~ son ne! ~~l Smys different effu b h-within the AE organization as well as between the organiza-l 4 tions involved, namely and the and/or It appears that the l
communication 7 ed Mmer- between thehand thehis maintained t throu e ho consnuhicates directly with his counterpart of the AE The AE IDP l reports to the VP of Seabrook project who is on the staff to the utility company, theh The lines of consnunication are depicted on Figure 1. l The inspection team evaluated the documentation of design controls which is i - w.4 l used by th h as the basis for the demonstration of design control exercised pg l by h nd ver the designess. qani*a$on h N 2
}O l A review of an audit report conducted by the h on July 26, 197h at the h
! . offices, Philadelphia, Pennsylvania was conducted. The purpose of this audit,
- conducted in accordance with the requirements of Yankee QC&A Procedure WQ-115, 4
QMg AM 6-4 su m q_
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. paragraphs III.A.1 through 8, was mainly to verify disposition of the open items of the previous two internal a' edits. The report discussed three items
? d identifiedinthepreviousaudit,co,1ductedonMay15,1@e which ha d not '
we -foosd dare fL<Oudb. been satisfactorily resolved. No new coen items h:v 5::: fedq n the-s subsequent letter, dated August 30,19[UE&C discussed the proposed resolution The ZPZ /eam oorkd' of the items covered in the subject audit report. A ch: rvatfer h:: 5::: made that the referencing of the staff in the audit report has not been made nao e . TAe /e.rm by fullgor by their title,name but by heir initials alone. % found that such identification of personnel makes g extremely difficult or even impossible to trace down the people involved.J M o 6 2M M N 0 f M @ ; "!' .
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j Thd principal documents providing for the implementation of all quality
-,Gr />(e W 4ee org.ani2 a&w?
assurance aspects of the Seabrook'plantgare the Project P611cies and the LM4-r
- Seabrook Quality Assurance (Q/A Manuar)hy The Q/A Manual establishes the procedures for the interval and external quality controls of the YAEC such as j the scope and frequency of the audits, interface controls, provides guidelines for the review of specific categories of documents, etc[Tiis Project Policies provide guidelines for implementation of the specific phases of the quality t
assurance system and describe processing of documents such as the Engineering Review Reports (ERR's), filing of documents, handling of engineering. documents etc. 1
& a.
Both3 Project PJicies and the Q/A Manual are under the direct responsibility of the Project Manager (PM). The PM is responsible to assure that both the l . Project Policies, and the Q/A Manual are in agreement. .In case of~a conflict j between these two documents the Q/A Manual takes precedence. The Project ! c
- ' l
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'. 12/27)ry 41-c Policies are reviewed and updated periodically to reflect the current modes of operation and design.
7( se recaiutoy an e'tyne&nf"%
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Specifications are the documents develc ed for specific tasks involved in 1 design of the Seabrook plant. They are developed by the UE&C and forwarded also y1iMy to the YAEC PM for review and approval 3 They are4reviewed on Tre-selected basis by the Quality Assurance Department (QAD) of the YAEC and the document resulting from'the review is called Engineering Review Report (ERR). The
# % ht~ o ,
{ ERR's are filed with the BEE inparateate.wieatm filing system. Onee a spec,!c;pha., A:ns been elevelopetl&M.<iew ad.apprev& k TJfe UE&C provides YAEC with the list of the prospective bidders and recommends t . 44er yeectsthe ess /.y .u v r ec e;e ec/ those bidders who appear to be technically acceptable.4 YAE winning bidder from the list provided by the UE&C, usually on the basis of the lowest price./The authority of approval of the specifications is with t b roject' Manager. Specifications are updated when there is a change in
, the purchase order and their change require review and approval of YAEC. In l
l order to assure that the specifications are up to date, YAEC conducts i interdisciplinary meetings which are, on the average, every two weeks. l l Following are our specific connents resulting from review of some of the documents provided by the YAEC staff. Q/AProcedure3.3"ReviewProcedure"Rev.8-Date3/30/79[R$.4
. The Procedure provides guidelines for the review of specific categories of documents. Specifically the documents covered by this procedure are:
~
. :-. L. . . . . -' . .. . :. . - _ . . a . . . . . . - .
'//'/tf 4 /-7 l
Engineering Specifications, Engineering drawings, purchase documents and QA/QC Program, Manual and Procedures. The documents to be reviewed by yk6h are developed by the agents, such as UE&C or subcontractors and submitted to YAEC Project Office for review. The Project Office is responsible to establish the appropriate reviewer (s). . .4_ Review of Project Policy #1 (PP-1) eveals -that the reviewer is " determined ,
- b. A *m "
- by Section 3.0 of the Seabrook Station (WA Manual and Subsection 17.1 of _ ^ theSeabrook[SAR. When Manual Section 3.0 was reviewed the criteria for selection of a r reviewer could not be found which is a discrepancy from PP-1. The Procedure is vague in the area of resolution of conflicting comments originated by the reviewers. The only statement that could be found is that , if the disagreement could not be settled amongst the reviewers it is referred to the higher management. There are no specific steps or the responsibility to be taken to obtain a satisfactory resolution. The Procedure contains specific guidelines (provided in the Appendices) for preparation of the review of the documents covered by the Procedure. United Engineers and Constructors, Inc. h is organized into several l operating divisions with the nuclear power work in the United States 'being perfonned in the Power Division under the direction of a Vice President. bne of the managers reporting to him is the Manager of Power Engineering. Power
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; dgineering is then subdivided by four technical disciplines each with a chief engineer as.the technical leader for a given discipline. defines four specific disciplines: structural, electrical, instrumentation and control and power. The first three are self-explanatory whereas the fourth requires some explanation. Included with the Chiefy Engineer of Power's group are the i technical disciplines of power systems, piping engineering, process engineering, mechanical engineering, nuclear engineering and fluid / hydraulic engineering.
The engineerin'g personnel involved on a given project such as the Seabrook Project all report technically to one of these four discipline chief engineers. Some may serve on a specialist staff or in a special group under the chief engineer of that discipline. supporting a project. While others may be within the project group under a supervising discipline engineer or other engineering
^
supervisor who reports to a project engineering manager. The staff groups and personnel become involved in project work only at the request of the project engineering personnel. Based cn the team's information this concept has been rather constant within the finn for a number of years. ! The Seabrook Project functions within this framework in the following manner. The Project Manager apparently reports to the Vice President of the Power Division,.just as does the Manager of Power Engineering. In the course of the Seabrook Project there have been numerous changes in the functional organization for the project as well as changes in personnel. The team found some in tracing the organizational changes as well as how responsibilities shifted and were transferred from one group or individual to another. Documentation was obtained in the organizational area,'to indicate the overall project organi-zation since 1976. Numerous changes were implemented about the time the team's 1 [
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, l effort began, adding another change to the list. The team found that the organizational charts obtained in the background study in October were even out of date by the beginning of November when the IDI team beganf /h /nf**I""*
Reporting directly to the Project Manager until'sometime after March of 1981 was the Project Engineering Manager. There also existed at least one Assistant Project Engineering Manager. The Supervising Structural Engineer, called a supervising discipline engineer (SDE), reported through an assistant project engineer to the Project Engineering Manager. The SDE for structural was the same individual from the beginning.of the project until August of 1982 when his assistant became the SDE. During the period of heavy involvement in design for the basic structures the structural group in projects was aligned by structure in that the Containment Shell, for example, had a designated Cognizant Engineer as the lead structural design engineer for that building. A significant number of engineers were assigned in these building groups. As that phase of the project drew to a close the structural personnel have also been formed into specific, task oriented efforts such as the Beam Verification Program. The Cognizant Engineers assigned by building still exist, but have smaller groups and may also now have responsibilities for several buildings. Another change that grew over the life of the design evolution was the 7 importance of site related engineering efforts. Up through March of 1981 there was a liaison { Engineer assigned to the field to perform the site liaison to the home office engineering organization. That function was performed under the supervision of the one Project Engineering Manager for (.. Seabrook. In March of 1981 a separate organization was created under the direction of the Project Engineering Menager (Site) as opposed to the previous
' ^ ' ~ -
kWe4 4./-to position under the Project Engineering Manager for the Project. By January of 1983 four separate Project Engineering Managers positions were in existence in'the home office with some 1100 personnel in the groups. Additionally, t nearly another 1000 were at the site under the control of the Project . Engineering Manager for Site Engineering. No less than six different groups exist working in the structural discipline in different chains of command with three at the site and in the home office. A separate structural group has been set up in' the ome office in the Site Support Engineering Group to interface with the field Site Engineering group so as to minimize impacts on the project Structural group. The implications of this organization will be mentioned later in the report in addressing interfaces for design. L i The team also spent considerable time, out of necessity, in order to try to understand the hierarchy of the multitude of in-house procedures utilized by UE&C so that a proper assessment of what was being done in the project's design and the control of the design process could be made. Figure 4. presents an overall view of the nierarchy that exists for the Seabrook Project with regard to home office engineering and design. In actuality, 4 to 6 layers of documents and procedures precede what might be considered to be an engineering calculation. This is. some what further complicated by the fact i 7
- that in many specific areas, different staff groups have developed and use
- modified procedures where latitude exists under a more general parent procedure.
t The result is a great deal of variation in documents when one begins to review, for example, calculation packages and the associated control sheets. 4 9
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i //r/2f 4./ -// f As a result of the team's review of the various project documents, such as the Project Manual of Procedures, the General Engineering and Design Procedures, several findings and observations were made. The team first reviewed QA-3
- g y M rom the h Manual which s the corporate level document which addresses 6 the regulatory requirementsy - - -
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!(' Document-Name:
SECTION 4.2 - SEABROOK IDI
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Requestor's ID: EILEEN i Author's Name: G. Harstead T I Document Comments: l Static and Dynamic Analyses i / - i, - l I i 1 1 I 4 +
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4.2 StaticMund Dynamic Analyses The objective of this portion of the inspection was to examine the adequacy and coordination of analysis, design, and the resulting floor response spectra
- for the Tank Farm Area which houses the Refueling Water Storage Tank (RWST) and the Spray Additive Tank (SAT).
The team also reviewed the interdisciplinary process leading to the design of _~ the attachments to the sa-containment liner supporting) (geference +. - ducts, pipes and electrical equipment, Calculation,No. CS-22,3as well as the calculations pertaining to the ! subject of the Tank Farm. i e The dynamic analyses of the Tank Farm was performed by the Structural Analysis Group (SAG) in order to detennine the seismic forces needed for the design of structural elements such as the structural steel beams and bracing and the
- reinforced concrete walls and slabs. This analysis also led to the development of amplified response spectra which were used for seismic qualificationf(of equipment,Kanalysisofpipingsystems,andfordesignofstructuralsteel beams.
The Tank Farm Structure is essentially composed of a lower reinforce.d concrete l box-like structure and an upper braced structural steel frame with a reinforced i concrete roof slab and metal siding. The mathematical model consists of lumped l l l l masses connected by massless springs. This type of model is commonly referred to as a stick model. The calculations used for the development of the mathe-Mo. matical model .are contained in UE&C Calculation SBg SAG-5WB (Reference 4.41).
de-Ar9e
- ^
f 2 - 2. ( i The stiffness of the structural steel frame was based entirely on a shear i type response in that the nodes were in general restrained from rotation about l the horizontal axes. The calculations of the area and the bending moment of
- inertia were calculated consistent with the rotational constraints imposed on the model. While the combination of area and bending moment of inertia were
[ consistent with overall shear stiffness, individually the properties were not 4 consistent with the actual structure. The rotational constraints imposed also, in effect, eliminated overall bending from any consideration. This approximation could result in a significant overestimation of the stiffness of the structural steel framing. ! The stiffness of the reinforced concrete portion of the building was considered by as a combination of shear stiffness and overall bending stiffness. Therefore, instead of sununing up the rectangular cross sectional area of l walls oriented in the direction of intergest.h considered each wall i separately in determining the shear deformation. This shear deformation of each wall is composed of pure shear displacements as well as bening characterized as a guided cantilever with a moment of inertia based upon the rectangular shape. Thesum(oftheshearstiffnessofeachwalliscalculated,sothat an area and a bending moment of inertia of the stick is determined consistent , with the shear stiffness. The problem with this method is that if indeed both shear stiffness and overall bending stiffness were important, the method would underestimate the overall bending stiffness particularly since flange effects are not considered. OVE&C made computer runs during the week of Aile %e as p=Yc. .on vaci in-proyess December 5,1983 which indicated that the model was not sensitive to orrors in 3 the moment of inertia.
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F In calculating the stiffness of the structural steel bracing, assumed that all X-bracing was composed of angles 4"x4"x3/4". In fact, the bracing consists of substantially larger members as indicated in UE&C Drawings F-111824 and F-111825 (Reference 4.32). i af2p M Ihs3kCl1 h k of . There is fill concrete under the Refueling Water Storage Tank and the Spray Additive Tank. A three inch gap is provided between the fill concrete q including the mat and the south wall of the Primary Auxiliary Building (PAB) i as shown on UE&C Drawing MF-111818 (Reference 4.32). A concrete curb i j is placed on the top surface of joint as shown in Detail 11181900, UE&C Drawing ! 9 3 hF111819 (Reference 4.32). This joint is shown along the east edge of i the fill concrete on'ly. A field visit indicated no differences with the requirements of the Drawings (Reference 4.32). The mathematical model ! described in CalculationgB SAG-5WB (Reference 4.41) does not account for I the stiffening effect of the fill concrete. The neglect of overall bending used in the development of the stiffness of the stick model were not approximations which significantly simplified calculations,but which might be troublesome and therefore, must be independently justified. 1 Personnel stated the Tank Farm mathematical model was unique and no other mathematical models were prepared in such a way. Additionally, it was stated i { that the usual practice of SAG is to prepare a static structural model and . with the, aid of a computer program, appropriate stiffness properties are calculated without the need for the approximations such as those used in the 1
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s/icf+ 4.2 4 . Tank Farm model. The team had insufficient time to confinn that the Tank Fann Structure is an isolated case; however, the team has no reason to doubt i the validity of that statement. Because of discrepancies between the assump-tions used in the development of the mathematical model and the actual Tank Farm Structure, new calculacions and computer b required. It is the t skovM team's finding that the Tank Fann mathematical modelgbe recalculated incorporating effects of overall bending and the actual structural ! i configuration (Finding 4. ).
- 1
\-Ej i The interfacing between different disciplines is illustrated by Figure .
It shows the major steps taken during the process and is self-explanatory. It "'m i j , should be pointed out.that all transmittals of the amplified response spectra i (ART) from one discipline to another is taking place through the Coordinator ofSeismicDesign(CSD). We were informed that the introduction of. this l position as the focal point of coordination of iriterdisciplinary effort improved the design procedure in a great measure and has prevented the use of obsolete or inapplicable results of seismic analyses. 'We found an instance of such a , ,
,y lack of coordination in the past in case of use of results of the input to i
P X the SHELL I computer program (Finding 4-7). ' Thi:"kfact af sei:-ic =ly:is k tw
, wp1 ha discuecad 12 tar- in tho cactinn A--14=a wi+k A-eiaa ^# +k- ~ *- *
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i h The current system of control of seismic designnfe11-5 +ha dminictrativa . y meedura(AP-36} l of Seismic was ntro uced in May of 1980 and appears to be effective. In the process of reviewing Calculation hes,' (fedrea ce 4: - shook No. CS-22 several observation)s have been made.T(Observations 4.1, 4.2 and 3, j,,f 4.3). l p 1 here In case of Observation 4.1, reversal of the horizontal leg of the angle could ., p. 7 introduce an additional eccentricity, which would cause a torsional moment / *F'd' 9k W ,1 7' v.
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- 4. 2 -5'
^
7 ! / in the plate and therefore increase in the stresses. We pursued our inspection further, and review of the shop drawing revealed that the detailer placed the angle in question with the vertical leg at the center of the plate, thus eliminating any eccentricity which might take place due to the erroneous sketch on Sheet 98. Observations 4.2 and 4.3 have been brought to the attention I of the design office as examples of lack of proper care in preparation of I calculations and checking and would not have a ma,jor bearing on the adequacy '
! of the design.
We reviewed the basic assumptions of the seismic analysis of the containment.
- cer M4 4 % cwM Rw,'s e W.- s;wn s.7,(R4
1 structure from the point of view of the regulatory requirements and found 7 l them acceptable. The containment shell has been represented as a lumped l mass (stick) model fixed at elevation -30 ft. The shell and the internals including polar crane have been uncoupled for the purpose of the final analysis co~p/6
,, (,/c BSAG-4C Ye nalysi assumed that the liner is not a resisting structural r element, but its mass has been included in the lumped masses-of the model.
Since the shell is essentially axisynunetric, and its center of mass and center of rotation coincide, the torsion due to the geometry of the structure has not been considered. . The accidental torsion due to seismic force applied at , an eccentricity of 5 percent of the mean diameter of the containment cylinder was considered and its effect on the stresses of the rebars has been found C; to be negligible (less than 2 percent increase). We agreed with the considera-tions made for torsion. ,, g 4g,g g h4wk a A M @B5^*'" In the case of the internal structures, they have been modeled as a series of concentrated weights, located at their respective centers of mass. These
~
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. 4:2-6 A l weight centers have been located at specific elevations, which in most cases l 1s at the top of the respective slabs. The weights representing the slabs have been connected by weightless, elastic beams representing structural components between the elevations of the concentrated weights. i Since there are no existing earthquake records pertinent to the Seabrook site
, L % M ereA FSht the seismic input has been defined at the,Seeken
.+-
3 7oo Rs[f the design response bedrock in form spectra for the operating basis earthquake (OBE) and the safe shutdown earth-quake (SSE) in compliance with Regulatory Guide 1.60. The duration of the s % P8 /M'- earthquake is estimated at 10 to 15 seconds. The engineers responsible for the i seismic analysis stated that all Category I structures are founded on sound l bedrock or engineered backfill extending to the backfill. The engineered'back- ! fill consists of either fill concrete, backfill concrete, offsite borrow tunnel i ? i cuttings or sound cement. Furthermore, the type of engineered backfill used a.a s4M 0 w A. m p+e e, sa.a)-ow 3 7 (9, under all seismic Category I structure,s is fill concrete, with an exception of l safety-related electrical duct banks, electrical manholes and the service water l pipes which were founded on off-site borrow or tunnel cuttings. Both the time i
- history and the response spectrum analyses were perfonned for the OBE and the i sa sk eh Fsot , sesE~ 3 9(2,$ 4.-)
SSE conditiong. The critical damping ratioi used for the containment structure l are these of 4 and 7 percent for the OBE and for the SSE respectively cadAh uNA. % an.e ~4 Ab y E'f ^3r7 pW.1.G/ ( Q -)
- "w. w e. gs k% a t SLUCm s*<r -4 csa), N . 4 The structural respon e h been determined,using the response spectrum modal
[ analysis method. The total response of the structure was calculated by super-f- position of the responses of each mode by the square root of the sum of the squares (SRSS) method.
&c-k9 62-7
.We reviewed the process by which the basic data pertinent to the design of containment have been gathered. In this connection we have noted that several q'm, %g %%.L.- b T: - M. w,Tm 4If.6.Fh, W N M 3 documentssucbasthosepertain1ngtoth8designtempdatureandpressure,3 e i r e, g which in the opinion of team members should be controlled, have not been included H+-
in the Document Control Center (DCC) serial numbering system and could not be easily retrieved. This matter is described in more detail in Section /,3 Furthennore, examination of the input for the SHELL I computer program revealed S. that the information used was incorrectly referenced in the calculationA The following is the result of our further inquiry in this matter. ~ 'i
}'wiy 4 %.k%.J Stat & Dd ismic forces and moments as used on Sheets 30 through 35 in the Calculation (febence +
No. CS-15,* dated 8/4/75,4were obtained from ified seismic analysis SB, SAG-3 Tni7eciupled del of the containment shell and critical damjin alues of 4% for OBE and 7% for SSE. The preliminary analysis, SBSAG-4CS3[waHise'd on coupled model of the containment shell and critical damping values of 2% for OBE an 5% for SSE. SB, SAG-4CS3 has been superseded by the final seismic et spur analysis G-4CS4,using a decoupled model of the containment shell and critical as ouMared *+ o g 1 damping vads of 4% for OBE ard 7% for SSE fApif L"Crer.s.gted3/17/76g4Gfweq m,_ e , ,s a m esrit A b g,,,,LT.% Q Mm -b> L M. g h dt .d. L.s eh ig gg73 AlthoughcomparisonoftheSBJAG-4CS3andSBpAG-4CS4analysesshowsthattheir
- results are very similar andThat the seisE8E* forces and moments used as input for the SHELL I program are conservative, we determined that this is a violation AP- (fe&rence 4.
of the ' 9 5 htrativa prneedure 22, " Calculations", Appendix Ap "r;. 4, i: tad 60,
,- A L1,09/74 and 10 CFR 3 ppendix A B, Section III, " Design Control", dated 8/1/80
. O r t' \ l #g,/s/l3 (Finding 4.7). ~ l sWW N
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We reviewed the various stages of the static analysis of the containment structure which utilize the results of the static analysis described above. The containment structure (the shell and the dome) has been designed using several computer programs. Some of them such as LESCAL, WILSON I and WILSON
. Se&oe .
II have been documented in the Final Safety Analysis Report (FSAR)g There were others, however, such as SHELL I and SHELL II which have not been included in the FSAR. This is in violation of the Regulatory Guide 1.70, Section 3.8.1.4, Revision 3, November 1978.apffithough we h8sTIer, informed by the-coyder pmrM H.y
, UE&C personnel that the use of these codes.g&s MmQed,we noted ttgas an d observation (Observation 4. ). ! #ms The axisymmetric analyses of the containment structure for dead, load, pressure, f temperature under both operating and accident. conditions were performed using Wilson I computer code. The shell model for the OBE and SSE has been analyzed
! using Wilson II program.- Both the Wilson I and Wilson II use the finite element method. Since the ASME Code does not permit the' liner to be used as a structural element, the containment structure has been analyzed and designed I without participation of the liner plate. The analysis recognized the fact that under thermal conditions, the liner plate will exert forces in the l concrete section which constrains the liner growth. In order to generate proper l Jesign forces for the concrete section, liner stiffness has been included in the Wilson I model but excluded from integration of stresses to obtain section forces and moments. The analysis recognized the fact that the cracking pattern will vary under different loading conditions. In order to simplify the design, the individual loads have been combined linearly despite the difference in cracking. The peak pressure and peak temperature have been assumed to occur l t
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'u.5 simultaneously for the design of concrete section. We agreed with this approach.
In the analysis the input for the SHELL I and SHELL II programs have been obtained from the lump-mass analysis which used the STARDYNE computer code and model described above. The SHELL I and SHELL II programs converted the forces and moments obtained from the STARDYNE analysis into the effective membrane forces and in plane shears and adds them up algebracially. The square root of the sum of squares is applied to determine the combined effects of three orthogonal components of earthquake ground motion, including two horiz6ntal and one vertical motions. Due to the symmetry of the structure, j the maximum meridional and the maximum in plane shears will occur at the same location. The design loads computed by SHELL I and SHELL II were used as input to program LESCAL, Version 1.5, which is used to calculate the stress and strains in reinforcing bars and/or concrete per ASME B&PV Code, Section III, Division 2.
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SECTION 4.3 - SEABROOK IDI i Requestor's ID: EILEEN Author's Name: R. Lipinski Document Comments: Design of Structural Elements D Y l' 4 4 9 4 e l I f l i l t
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4.3. Design of Structural Elements { hl Y The objectives of this portion of the inspection were to examine the adequacy 7 and coordination of analysis, design, engineering drawings, shop drawings and construction of structural elements located in Category I structures which are 9 associated with the containment spray system. The structural element which was selected as an example was the recirculation sump screen structure. I The containment recirculation sump screens and collects the water available l for supplying the residual heat' removal, containment spray safety injection l and high head charging pumps during the recirculation mode of' operation following i [/ an accident. There are two completely independent sumps located in the contain- ! ment, synnetric about an azimuth of 270*, with the top of concrete at elevation . -26'. Heavy particles are prevented from reaching the sumps by sloping the surrounding floor away from the sumps and two screens (one is coarse and considered i ] a trash rack with 1 inch x 3-11/16 inch openings and the other is the fine screen i with 8x8 openings per inch) prevent foreign matter of 0.097 inches or greater
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l from passing through. l ~2 l Both the trash rack and the fine screen are attached vertically to the steel l framing. The structure itself consists of a framework of structural steel i members extending from elevation -26' to elevation -20i'. Each frame is on 4 three elevations, within the limits stated above, and has the area of 1 ,7 9'-6" x 18'-6". ' $d , g. i I l 1
43_, Wuh We reviewed the design calculations for the screen structure which are contained Ww4% FuvRu h h% hr= in thegCaTculation No. CI-2 (Reference 4. ). The structure was designed for the load combination of the dead load, live load and the OBE as one of those required by the FSAR. The computation contained a statement that the equation used was the controlling load combination equation, but there was no comparative analysis or any evidence that both earthquakes (OBE and SSE) have been considered. Additionally, the effects of thennal expansion of the beams had not been taken into account. During the inspection, the temperature was accounted for in W Revision 1 to the calculations. This was after the structural steel hes- been Ry.l c e. k : r J cl ut. , R w w t h w w er Tm Dsk'Ls wdj,peSe'h / installed. The drawing pertinent to this structure, Drawin n I% g (Reference 4. ) was released for construction of embedded anchor plates on September 29, 1978 and for structural steel construction on January 21,
# 1980.yWeconcludedthatconsiderationofbothoftheearthquakeloads,OBE and SSE should be evidenced in the design and that omission of this load is violation of the " Structural Design Criteria" SD-66, Table 5.4-k?), Rev. O, f dated October 19, 1976 (Reference 4. ) (Finding 4-11).) During ourhectio Revision 2 was added (dated November 25,1983) which included an explanatory note that the amplified response spectra tables have been consulted and it appears that the original design was conservative.
Examination of Detail 101486M on Drawing F-101486 (Reference 4. ) revealed that the bent plate connector had not been placed centrally with respect to the CA = L& structuralfmember (4te) to which it is bolted and was moved toward the upper flange of the channel. This was inconsistent with the analysis, which assumed that the connector would be placed so that the center of the bolts on the connecting plate would coincide with the center of gravity of the channel. We l l
t _. . .- . _ . . . _ _ _ . ..-2..,_ .- - . f y_ y && verified that the eccentricity between centroid of the bolts and of the channel Cive4 D = EIoct we(6 toot. g j as described above has been transferred on to the shop dr wingprid during our g + trip to the site,ywe found out that installation was consistent with the drawing. NW Since the members are subject to the movement along their longitudinal axes due to thermal conditions, such a displacement of the connector from the centroidal axis of the beam introduces eccentricity which will result in increased stresses at the connecting plates. This was noted as a finding. (Finding 4-4). The cognizant design engineer perfonned additional calculations during the t hea6e l inspection to account for this4 condition and determined that the resulting stresses are within the code allowables and, therefore, the structure as built I is adequate. The additional calculation sheet has not been listed in the Calculation Revision Control Sheet of Revision 2 which was reviewed by the team. This is contrary to AP-22, " Calculations" b t since the work was done der.i after the inspection's ti:=p review cu+-c4 clE, u wi~'qthis is noted as an observation (Observa-tion 4f3 ). While inspecting the annular steel between the containment shell and the secondary shield in the containment structure, we observed that a number'of steel beams ! framing into the steel plates embedded into the concrete had been modified. The modifications consisted of extending the lower part of the web of the beams and i' providing plates to acconnodate the lower bolt in the plate which had been welded
- to the embedded plate. Upon examination of the pertinent shop drawings and the i engineering drawings we found that this modification had been necessary due to the fact that the embedded plates were installed at the wrong elevation. The
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,, e 43-+ ! plates were installed too low to be compatible with the elevation of the structural. steel in the area of the annulus. In our discussion with the cog-nizant design engineers the modification of the connections was not reflected in the analysis completed using a computer program. We determined this Q be in conformance with the AISC Specification (Reference 4. )andthe Structural Design Criteria, 50-66, Sections 2.1.2 and 6.2.5.1 (Reference 1.3)y (Finding 4-13). j j We requested that an additional analysis be perfonned to determine the adequacy of the connections. Ddring the inspection we were informed that j a program which will re-evaluate connections modified as described above or i in any other way so as to depart from the standard connections contained in 3
- the AISC Specification and not tadsd analyzed via the computer model will be 1
j reviewed. This will be done by selecting a representative sample and analyzing i j the connections in that sample in accordance with the AISC Specification i requirements. We were told by the design engineers of UE&C who have been ! + , intimate 1, involved in design of the annular area cf the containment structural steel that misalignment of the embedded plates with structural beams is wide-j spread in Unit 1. In the case of Unit 2 there was an effort to rectify this , l situation and to install the plates at the proper elevations thus alleviating problems for the as-built conditions. This was not completely successful and i as a result there are cases where beams had to be modified in Unit 2. We also learned that the modifications were not performed in the field, but the beams
- were modified at the fabricator's facility and shipped to the field ready for installation. In view of the evidence that the design engineers are aware of l
l the need for further analysis of these connections and that further action is ; under way we did not pursue this matter. further. 1
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l Another item which is related to this area of containment pertains to the connection of the beams to the columns in the annular steel. Examination of cw x E a n 2. , =*- k s as k or, g ge s. th s op drawings revealed that in order- to accommodate welds between connecting angles and the beams framing into columns, not perpendicular to the columns, the axis of the beams was shifted by one inch from the centroidal axis of the column. This resulted in an eccentricity with respect to the column, which in turn induced torsion in the column. We have fou'nd that this was not accounted for h S8 83 CI d L J oeJ.Ja_4.2.2,19&if in the analysis completed via a computer program /and that it violates the
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Structural Design Crfteria, SD-66 Reference 1.3) %nd Section 1.'15.3 of the -'" N, AISC Specification (Reference 4. ). In our opinion, the effect of torsion induced in the columns is to increase stresses in the members and these stresses should be evaluated to determine the effect on over-all member stresses. We recommended that an appropriate action be taken to assess impact of this eccentricity and an analysis be performed to evaluate the resulti stresses. 3
- IP' (Finding 4-19). '
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+ L J pJ a+r[ e c,t.Au c misni M, A + =l i s W W % & The Structural Design Criteria, SD-66 (Reference 1.3) is the controlling document for the structural design of reinforced concrete and structural steel. With
. respect to the design classification of the seismic category of the Tank Farm structural steel considerable confusion was found. Table 3.3-2 lists the Tank Farm structural steel framing as Non-Category I with a requirement that earth-quake d be in accordance with the Unifonn Building Code with a perplexing 7
note covering manhole covers. Furthermore, a requirement for the design for tornado pressure is listed. Paragraph 4.4.2.6.5 of the criteria states that , the roof shall be considered expendable and allowed to fail during a tornado. l However, Revision 1 to the document, dated November 30, 1982 deleted the Tank
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- Farm structural steel from the listing of Non-Category I in Section 3.2 and listed it under Category I in Section 3.1. This leaves the tornado requirement unclear 'at the present. While it was apparently the intention to change the de sIrvshee designation to Category I in November of 1982,44gwas considered Non-Category I from the original issue date of the criteria document of October 19, 1976. During the time period between October 19, 1976 and November 30 1982, the ( f. b i calculations for the structural steel, Calculation No. WB-61,were perfonnedtro eb. j without a strict adherence to either Non-Category I or Category I ( 4
- i. }.
i ! In the latest revision to the FSAR Table 3.7(B)-22 lists.the Tank Farm steel i . is fishd ( framing over the Refueling Water Storage' Tankj gs Non-Category I with the caveat 1 j that it is designed not to collapse under SSE.
- For most Category I Structures which are exposed to tornado pressure, Table r .
l 3.3-1 in the criteria document requires a design for tornado pressure. This leaves in doubt, the tornado requirements for the Tank Farm structural steel 1 < Alo- . and the associated concrete roof slabs. Calculation WB-61 indicates no design 4
- . for tornado for the structural steel.
The Tank Farm structural steel is Seismic Category -I. The' calculations and 4 drawings are all classified as Category I which is the design intent at this
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time. The design load combinations listed in Calculation No. WB-61, Sheet 10 of 79, dated September 28, 1978 (Reference 4. ) omits load combinations containing the SSE. This violates SD-66, Structural Design Criteria, Table
.5.4-2(Reference 1.3)(Finding 4-& )_ _, _., ,e3 .
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f y- 7 /f/ l'f f UE&C stated that th$lt OBE load combination always controls for the design of the structural steel beams, and that this statement with a justification will be incorporated into the. structural design calculations.
.l A structural steel beam, Mark B9, located on the El. 81' roof along Column Line 0.5 was designed for dead loads, live loads, and seismic OBE loads in Calculation No. WB-61, sheet 17 of 79, checked September 28, 1978 (Reference 4.34). Later a redesign was made to add the sag rod loads .to the dead loads, live loads, and seismic OBE loads (Sheets 9I and 9J of 79, checked November 3, 4
j 1979). The original calculation (WB-61, Sheet 17 of 79, checked on September 28,1976) was not voided as required by GEDP-0005, " Procedure for Preparation, I ( Documentation and Control of Structural Calculations," Paragraph IID, Revision
- 0, May 21,1974 (Reference 4. ). Subsequently, another calculation was made (WB-61, Appendix A, Sheet 10 of 16, Rev. 3, checked on June 17,1981)which I
, added a pipe support load, but neglected the sag rod loads. i Again the previous calculation was not voided. The SSE pipe support load was i incorrectly combined with beam OBE loading and designed for SEE allowable ! stresses. The neglected loads and the combining of OBE and SSE violates SD-66, Structural Design Criteria, Rev.1, (Reference 1.3) and'was noted as a finding (Finding 74 -6 ). I The fact that there was some confusion over whether or not the structural j steel was Seismic Category I probably led to the type of problems described l above. It is the tear's understanding that the beams will be evaluated as Seismic Category I in a systematic application of all load combinations. l l l
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0- e The roof slab of the Tank Farm structure was designed as Seismic Category I, although the Supervising Discipline Engineer stated that the roof was Non-Seismic 1 Category' I. SD-66, Structural Design Criteria (Reference.l.3) is silent on the j matte'r. The calculations for the reinforced concrete walls along Column Lines 4.5 and 5.0 are contained on sheets 8 and 9 of 13. UE&C Calculation No. W8-68 (Reference 4.34). The calculations were based upon the method described on page351ofthe"ACIDesignHandbook,"SP-17(73)(Reference 4. ) in , accordance with the strength design method of ACI 318-71. The method is appropriate for reinforced concrete sections subject to combined bending and axial load when the section is controlled by tension. The calculation procedure [ is described in Flexure Example 3 of ACI SP-17(73) which neglects any compressive reinforcement. The calculations did not indicate an adjustment of the value of 9 The results of the calculations indicated a requirement for reinforcing less than that which would oe required by a correct calculation. The tendency of the designers to provide more reinforcing than actually required by design may mean that sufficient reinforcing is in fact
. present for the revised calculations. This appears to be a systematic error for the Tank Fann walls and; therefore, the team recommends a review of all the design.of reinforced concrete members subject to combined bending and compression.
l This failure to correctly execute the design in accordance with the design I reference was noted as a finding (Finding 47--10 ). Bracing within the structural steel framing is provided for resistance to lateral loads such as tornado and earthquake loads. The calculations for the design of
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. 1 ._ _i_ _ 7 4 h7f!4 bracing are contained in Calculation No. WB-61 (Reference 4.34). Total seismic shear loads.were obtained from Calculation No. SB SAG-SWB (Reference 4.41). The wen > l loads in the bracing w.? established in an approximate ranner. The actual dis- l tribution is more comple:x than that assumed; namely, it is dependent upon j relative stiffness. However, the determination of the distribution of sbaar forces is dependent upon a knowledge of the sizes of the bracing and columns which, of course, were initially not known to the designer. / Additionally, UE&C did indicate the OBE$111 control 'the design of the structural steel beams as bh ,
opposed to the SSE, git is not clear that the OBE vill co' n trol the design of bracing. At this point, a reanalysis and, if necessary a redesign)of the bracing is in order.,lThe team recommends a more accurate determination of shear distribution and a recheck of stresses, based upon the fact that the column and bracing 51zes are now known. The bracing in the Tank Farm should s n be checked with newly calculated seismic forces for both OBE and SSE in accordance in Table 5.4-2 of SD-66 (Reference 1.3). This failure to utilize all required load combinations and actual member properties in the calculations j was noted as a finding (Finding 4g-h
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D h g fh,f UE&C's headquarters in Philadelphia, a group called Structural Site Support Engineerinh has been establishpd on the project independent of'the project b- +
-fa address *4sw destyn changes.
Structural Engineering groupg(This group acts in support of and approves the 5i4e Enfiesetq) . work done by engineering forcesjgn site at the Seabrook Plant.
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! In general, hite kngineering is appkNd of a problem en' countered duri l construction. Site imgineering will either propose;a solu, tion or will request j a solution from Site Support Engineering. The proposed; solution will be l . /. y - xn]
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reviewed for approval by Site Support Engineeringar *M 3 b3'N O ["# A typical example of this process is Engineering Change Authorization, ECA . 01/4217. Several pipe supports were required to penetrate the roof of the Tank Fam at klevation 71'Ad'l. In Rev. A Site Engineering recommended cutting the concrete by scoring the openings and chipping the concrete. Rev. B added reinforcing steel, cutting and replacement details and steel removal and s,e dton s. , replacementandhteelWT's Revisions continued through Rev. E which i' incorporated additional details. During this process there was continuing dialogue between the site and the home. office. _, ! Ths ME #e ca'N d I , Site Engineering also prepares calculations.wh+ehgis now underg Fi eld
' (FACP)
Administration Construction ProcedureN4 o.10, original issue was dated 3/11/83 i and Revision 1 dated 10/27/83 (Reference 4. ). The najority of calculations concerned misalignments of structural steel connections. The. usual case involved en m e. ten w(e a misalignment of bolt holes, which required a replacement w&4h-welding. The 4
- welding was designed to provide the equivalent strength of th bolts, even though the actual forces might be less while this resulted in an overly l conservative connection, it did eliminate several cycles of communication l concerning design load requirements.
g.fsyd . YAEC also participate'd in resolution of NCR's which might have serious impact l- upon the project and which could not be considered routine. Two such issues were being addressed during the early stages of the project. l _ e . _ _ , . _,_...._.,__m. ._-.__,..._,,_.,._m_ s ..-, , - . _
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- i In many pipe support details, it is necessary to butt weld a thick plate at right angles to an embedment plate. In approximately 20 cases the right angle el(ac plate has pulled out a portion of the embedment plate by laminar tearing.
Similar problems occurred previously in welding of annulus steel. The fact i that the problem again came up was that there was no welding or material review, nor was there any general communication issued to alert all designers of supports el\se to the problem of laminer tearing. The problem has not been resolved,but ne tentative $ consideration is k ing gise., to chang h steel from ASTM A-36 to Lukens Fine Line 516. "st.'. .". . Ln '"M4 == and MMLar u Tuvier vi YAEC N P" are involved in the resolution. h are b ng use n the drift eMminator of the Cooling owers. Due to corrosion otential, the Hi ti bolts are sired in Stainless s' eel. However, f the required 1 ngth was not available in stain ess steel; therefore, a greater ! engthisantickated. A meetins was schedule to resolve this matter. Ar.other concern w raised by A. erne of Region I oncerning ba to back an co er installation This item addressed and it as found tIgat for the
- { specif c cases there was no negative effect.
. The overall assessment of the design controls in the area of design of structural elements indicates that the design utilized the design criteria and provided l st .. adequate margins of safety with regard to the code allowabl The staff ; 1 l appeared to consist of experienced engineers thoroughly familiar with sound 1 i knowledge of their profession. We do not expect that the neglect additional stresses produced by the modification of the beams (Finding 4-13) or eccentri-
. - . . . - ..2- .- - . . - . - , _ - -
4,' 3 ~/ z Y7k1 cities of columns (Finding 4.19) will result in a dramatic reduction of the margins with respect to the code allowable. The team concluded that the structural elements examined have adequate capability to resist the expected design loads. . s e 4 e ( ! . o i I .
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.1 M6/Pf . l Document Name:
,; -r. SECTION 4.4'- SEABROOK IDI Requestor's ID: r EILEEN Author's Name:
- G. Harstead -
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$: Design for Supported Mechanical' Systems and Components 4 + 1 i
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. 3 4~. + - / 4.4 Design for Supported Mechanical Systems and Components The objectives of this portion of the inspection were to examine the coordina-tion between the design of the mechanical components, the support structure, and the design of structural elements. The two tanks selected for review were the Refueling Water Storage Tank (RWST) and the Spray Additive Tank (SAT). Both tanks are part of the containment spray system and are located in .the Tank Farmy sfr veihre. Both tanks are supported at their bases and are anchored into the fill concrete by means of high strength anchor bolts. MSAve hb SpeaY was The seismic load for the(SAT) kzobtained by assuming horizontal and vertical accelerations equal to 1.5 times was the peak o/ in grohu f the con d response spectra. 74/sance w,# f equ.vaknf cf>& .2m/ysis Tha, 4, . . ~, , 1 4 t, m s . , , .,~..---.~,,,.41,m co m /e/e1, 31. , . 2 n ,4 um , ,. u m u m s , . . _ _m
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- - cGR5G TV atiV 61y uesigneo. Thereiuse, in 5 pit 6 of the tell COniburation vi ms +=nk not der 9ned rh 7Ke pi-owewenr' :rpeedc2 dun 4- hj]; ric 7%4.
the the tent ;nd 3gppg, b o, c very cgg3ar;;tij;1y de-j n;d, g ,, the_ cethod of sai mic an=1yrf: is in cccordance ,;ith the NRC CRP, it .;; not . listed da the eraeffications. The Refueling Water Storage Tank (RWST) was purchased from Pittsburgh-Des Moines (PDM) under UE&C Specification 9763-006-246-1 (Reference 3.52). PDM prepared design calculations for the RWST (Reference 3.196); however, two errors of omission were noted. One, in calculating the stiffness of the cylinder only the everall bending stiffness was considered,with-the shear stiffness being
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i neglected. Two, only the fundamental frequency was calculated, neglecting higher modes.
b - + +- 2 //4fg A reanalysis could indicate greater design seismic loads; however, it appeared that the thickness of the cylinder could accommodate somewhat greater meridional compressive stresses. Also, there appeared to be additional capacity in the anchor bolts. The team does not expect that there would be a requirement for material changes as a result of a reanalysis; however, such a reanalysis is necessary to meet the requirements of the specifications and good engineering practice. (Finding 4- ) - The review of the tank calculations prepared by PDM was the responsibility of de-w i Ana. s;s Gmge regensibik design A dddvi'*** qa"9 dim of the an or bolts was sp!it "ith PDM spedfyih the fue,a w#[iAG) E&C. T g bolt diameter and steel designation and tne UE&C Seabrook Project, Structural,was responsible for the design of the embedment length and local reinforcing if required. The number, size, and type of bolts required by PDM was observe ~d in the as-built condition. ! The pipe support which was located on the structural steel Beam 8-9 discussed in Section 4.3, was relocated so that the support was anchored into the concrete wall located parallel to and adjacent to Column Line E.7 in the Tank Farm instead of being supported by the structural steel beam. The sketches for the relocated pipe support structure were designed and presented on Drawing ffEr. fr5@r.H-8018335, SupportNo.M/S-1833-RG-04, Sheets 13through17/R^,AS,y
,4l2 (Reference 4. ).
During a field visit, the support was observed. A comparison of the field installation with the design drawings indicated that the several of members were larger than required by the design. The team had no questions relative
4, 4 -3 t/u/. . to these discrepancies in view of the oversized members. By changing the support from the structural steel beam, B-9, to the concrete wall, problems which could be caused in the design of the steel beam were eliminated, however as noted in Section 4.3 a finding was made on this subject.
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Document Name: SECTION 4.4 - SEABROOK IDI Requestor's ID: EILEEN . Author's Name: - G. Harstead Document Connents: Design-for Supported Mechanical Systems and Components l 6.d 9 9 e O 4 i s i I i i l 7 i t
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v Document Name: - SECTION 4.5 - SEABROOK IDI Requestor's ID: EILEEN Author's Name: R. Shewmaker 1 Document Coments: Design for Supported Electrical Systems i J i l Ib. i 1 1 i* 1 4 i 4 Y J A l f i ?
qs4 Y? 4.5 Desicr. lor 2;: ported Electrical Systems The objective of this portion of the inspection was to review selective samples of specific designs related to the structural support of electrical system'. in order to assess the interface between the electrical and civil-structural aisciplines for design. Specifically, a determination was to be made as to whether: - (1) The licensee's design commitments contained in the FSAR and other relevant documents have been met
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(2) Correct design information had been coordinated and complete interfaces [ t made through a logical design process (3) The completed design was adequate The inspection in this area was conducted by a review of the lateral cable uG C tray supports being designed by gar enlgineering design group located just off-site from the Seabrook plant. Organizationally the group is part of the UEjC Site Engineering Group, which is under the supervision of a project engineering manager and a Technical Staff manager. The Group is known as the Cable Tray Bracing Task Group. This Group at the site complets work on the cable tray i support systems which are under the technical control of the Mechanical Analysis Group for Electrical and Equipment in the home office. The home office group reports to a different project engineering manager, known as the project system engineering manager.
- ' 45 -2 fO'/7f
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The home office group is responsible for the development of the detailed design procedures and related guidance and in the current mode of operation, performs the analysis to complete the necessary design for the vertical loads on the tray supports. The site group is then responsible for the analysis $r'Id A wAich is e.,,p/e/c/ by s,>.bnq secess;.xy soc and design for the lateral loadsA The co .,-leted calcul&tions and drawings /#c 'N'9# adx4 da by the site group are then sent to the home of ' ice for final review and the /rea co - incorporationintothefinaldesigndocumentation,whichincludesthedesignfg j for vertical and lateral loads. OIce-The design of cable tray supports for the Seabrook project is governed by the document known as the " Technical Guide for the Design and Analysis of Seismic
- Category I Cable Tray Support Systems" (Reference 4 ). The team's effort in the area of the cable tray support design included a review of the technical content and details contained in this Guide as well as the execution of the design. The Guide is considered to be a controlled design document for the project on the basis that individual copies of the Guide are assigned to specific individuals by copy number. The development of this technical guide was the responsibility of the Mechanical Analysis Group which is a staff group reporting to the Chief Engineer of Power.
The analysis and design procedures provided in the Guide are the result of combining the results of actual test data for various components or elements of the tray support system with analytical procedures and the use, in many instances, a bounding type assumption in order to realize a workable design ( procedure so that each and very design solution is not unique. A review was v i
- ~ -. - . - . - - - - .- - . . - - .
/
. 4. S -3 . /M/F-
- i 1.
cmade of the specific FSAR commitments regarding the design of the cable tray i~ support system. The relevant commitments were noted'to be in Sections 1.8, i i- ! 3.2, 3.7.3, Table 3.7(B)-23, 8.1 and 8.3 of the FSAR. Certain aspects of i- coriformance to these connitments were reviewed and aiscussed by the NRC's i j Office of Nuclear . Reactor Regulation prior to th's team's effort (Reference ,
- 4. ). The team's effort was to interface with completed actions by NRR-l-
j and their understanding of the design execution and to verify that the . j supports to the trays were indeed designed as Category I structures. l t
- Only general and very limited commitments were found in the FSAR with regard h to the manner in which the analysis and-design of the cable tray support system i
j would be executed. Note 5 to Table 3.2-1 in the FSAR stated that " qualification of the conduit and cable tray raceways for the Class 1E safety related circuits j have been confirmed by analysis, and calculations verify the adequacy of the systems based on the properties of the raceways (including tray where appli-- I j - cable) and support components." In Section 3.7.3 of the FSAR one of the methods
- I
~ of seismic analysis for subsystems noted for the project utilized the cable ! l tray' support system as an example of application of the dynamic analysis f method technique using the modf1 response spectrum technique. Diagrams were providedinFSARFigures3.7(B)-31and-32toillustrateatypical(ilingto [ floor cable tray support as well as.a mathematical model representation which - l i was used in the dynamic analysis. This constituted the majority of the l
- analyses and design details provided in the FSAR. .No' inconsistencies between the FSAR and the Technical Guide were found during the review. Thebas(sfor the design of the Category I cable tray support systems judged to be well
' M ho.ve** foundedonacombinationoftest'datagndacceptedanalyticalanddesignprocesses,. I f
- 4. s -4 '/G/*C
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which are hered er test det: fr t;;; cre::, The first area 3 dealt with the actualfStaticfiaxial (combined vertical and horizontal) load testing of cable tray sections and the utilization of the resulting load-deflection curves to determine the load capacity at the tray's yield point, the load capacity at the state of local plastic behavior and then the ultimate load capacity. The team did not review the documents related to the actual test program. We did however establish how the allowable cable tray load limits were developed from the test data. UE&C defined the allowable loads on the basis of tray deflections being limited to no more than 12 inches in any def/ecdon direction based on electrical cable li 4 mitations. The cable tray tests indicated 4 Afkedon wwks- M[ inch kaak atgyined yield. Tray testing much lower values 45uch as under included the two configurations of trays which would be the most flexible
- (the 12" and 24" ladder type). These tests,in addition to the load deflection curves,also provided data on the effective member proper ties which could then be utilized in the structural model for analysis. The timplified structural .
models integrated the cable trays and the tray support tystem, consistent with the actual design configuration. These models were then utilized in standard structural analysis techniques to obtain dynamic responses and internal forces for the structural assemblies. Testing was again utilized by UE&C u nde.~ to establish the ultimate load capacity,4w3 various types of loadings including both levels of seismic,for typical configurations of joints and members. The load capacity of other structural members such as the cold-formed strut material
- or structural steel was established by the manufacturer's data or by use of 4e existing codes such as 3 AISC, Spede.dt= (Giecece 4. ).
- 4'. f - S '//0/
The design criteria for the cable tray support system defines three loading combinations and two stress or behavior levels. The dead weight alone and the dead weight of the t plus the cable and the OBE loading are to maintain the support system in the elastic range. The dead weight of the tray plus the cable and the SSE loading allows some excursion into the plastic range, yet assures structural integrity. The design philosophy also encompasses the use of the largest yet most flexible cable tray configuration so that the resultant loads into the vertical support members are maximized. The bracing members are used to increase the fundamental frequency of the system and therefore e de the response away from the peak response region. Damping has been taken as 4% for the OBE and 7% for the SSE which is as provided for in the FSAR. Section 6.0 of the Guide provides detailed instructions on the execution of the analysis. It was noted that mass points were required to be located no further apart than 36" in order to more accurately reflect the behavior of the tray system which is generally supported at 10 foot spans or less. The various standard configurations are provided as well as the types of permitted lateral bracing and the design details which must be addressed for each type. The various typesinclude the single support transverse bracing, two sided bracing, multiple support transverse bracing and axial bracing. Guidance is also provided on thermal considerations, torsion, buckling as well as welding ' and attachment to concrete. For situations where the cable tray support system is connected to main building structural elements which have different amplified response spectra, provisions are made for using envelope spectra or by a carry-over type analysis from one response spectra area to another. The dynamic analysis can be completed using a equivalent static load using the peak value
4g_g W'/M b+4r of are with a 1.5 factor or utilize a dynamic analysis $hich HAin accordance with approved NRC methods. Documentation requirements are delineated and standard calculation forms for cable tray supports are provided. ( The Appendices to the Technical Guide address in detail the related information necessary to perform the design of cable tray support systems. The sample calculations selected by the team for review to assess the manner of execution of the design and to assess the adequacy of the resulting design Ved .
.was. a series of calculations related to the lateral support of cable trays ,
in the Control Building. They were prepared by the Cable Tray Bracing Group I l , at the Seabrook site in the Site Engineering organization and transmitted by (s , a memo dated August 2,1983 from Site Engineering to the home office (Reference
- 4. ). This submittal contained calculations in the southwest quadrant of the plan for Elevation 21-1/2' in the Control Building as shown on UE&C Drawing F-310449(Reference 4. ). The calculations included the analysis and design for eleven separate sections of multilevel and multibay cable tray supports.
Preliminary calculations for Section SW-3 (Reference 4. )wereselectedfor _ review. All assumptions were noted and those which required future verification were so marked such as the assumption that the amplified response spectra are final. This was found to be consistent with the procedures defining the comple-tion, control and documentation for calculations. Specifically those procedures consist of GEDP-0005, " Preparation, Documentation and Control of Calculations" (Reference 4. )andAP-22," Calculations"(Reference 4. -). AP-22 takes the corporate design procedures contained in GEDP-0005 and defines in more detail how the intent of GEDP-0005 is to be met for the Seabrook Project. It I
b AS-7 h/E was noted that AP-22, Appndix 0 which addresses the requirements specific to the Site Engineering group with regards to types of calculations completed, indicates that the Group is authorized to perform support design modifications to electrical systems. The work being completed by this group is in fact modifications to the vertical support system designed in the home office by the Mechanical Analysis Group (MAG) to accommodate lateral loads. With regard to GEDP-0005 it is noted that AP-22 would require the work being done by the Cable Tray Bracing Task Group to follow FACP-10, " Procedure for Site 'w Calculations"(Reference 4 ) except that it is stated that where required individual disciplines may use separate guidelines for calculations. The references utilized in the calculations, whether specific to the project t such as those providing the details, for example of support type vs. the critical
' ~
vertical and horizontal frequencies of that configuration to those which include standard text books, handbooks and vendor's catalogs on engineering details
. were provided. Two of the three vendor catalog references utilized for strut material and hardware data utilized in the calculations for Section SW-3 were used in the verification process by the team. No discrepancies were found and the interpretation and application of the data was judged to be correct.
It was noted in the calculations that where several individual bents of laterally unconnected support frames are subsequently tied togeker laterally through braces that UE&C utilizes the square-root of the sum of the squares (SRSS) method to combine lateral loads. The team had no disagreement with this concept. In general there appears to be significant margins in the tray support system due to the simplifying assumptions made to minimize the
~
number of unique designs required. For example,the worst tray cross-section
a + S -g $s/M o' is used, supports are designed in general for 10' spans of trays, in most instances the static load of 1,5 times the peak of the enveloping response icused spectra and the member / joint type selected usually has a capacity significantly greater than required. The procedures and execution of the design of the cable tray support system for lateral loads were reviewed against the requirements of Section 4,. Design Process, Section 5, Interface Control and Section 7, Document Control of ANSI N45.2.11-1974 to which the project is commited (see AP-22, Section 1,
- p. 1). The design activities were found to be prescribed in specifications, procedures and the Technical Guide for this task. These documents provide
, adequate control of the design execution to be complete by the individual
('
, _ designers. The design assumptions and design input were clearly defined and the associated calculations clearly identifiable by subject, originator, reviewer and associated dates. The standardized sheets for calculation title l - sheet, calculation control sheet, table of contents, status of revisions, assumptions and references has resulted in complete and fully adequate calculation packages. The interfaces are well defined and understood as the information flows from the electrical group, MAG and the Site Engineering group. The lines of communication were judged to be well defined and established. The documentation examined proved an excellent example of a package of work completed by Site Engineering, Cable Tray Bracing Group and transmitted
, to MAG for final review and concurrence as well as integration into the total package of calculations for the cable tray support system. 4 l
^ ^
o- sps49
+. 5 -9 I
Based on the team's review of this specific area of engineering and design effort,UE&C's design control appeared to be very good. No findings were made. All licensing design commitments selected for review were reflected in the design documents being utilized for the project. In addition, more detailed design criteria and procedures have been developed and are being utilized on the project. The design process has been quite clearly defined and developed in the Technical Guide for the Design and Analysis of Seismic Category.I Cable Tray Support Systems. Correct design inputs and design information have resulted from the systematic application of the Technical Guide based on the team's review. The specific review of Section SW-3 of the cable tray s pport sesAet! tn .r k system in the Control Building gdeterminE&m f 14xF Se Itdesynnaast+-be was apparent that a great deal of engineering effort was expended3 including substantial testing where it was apparently determined that actual test data in 14e evo4% / ;%s ats7n i fedartc6 would add to the reliability of the engineering and design processgWhether this was a joint decision by UE&C and YAEC/PSNH or a singular decision, the project is to be comended for a well organized design process for cable tray support systems and one which is adequately controlled based on the team's limited sample.
Document Name:'
- '*M ;
SECTION 4.6 - SEABR00K IDI' , Requestor's ID: EILEEN 4 Author's Name: R. Lipinski. Document Comments:
; Design of Supportvl&C Systems ed 1 }
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4.6 Design of Supported I&C Systems The objective of this portion of the inspection was to detennine for a sample of instrumentation and control systems whether: (1) Nhe de anal f w$ eg!;rn_ysis sea de*ytr preenn t process 4+gxecuted in accordance with the appropriate procedures and if conformance with the guidelines contained 4 ee cweihenfr w/ /%e in the h fity Assurance Manual, y,Q ,4 de cappel ob Me .Tt'C of$b*** (2)ICorrectdesigninformationghasbeencoordinatedandcompleteinterfaces made in a controlled design process, .md
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(3)fThecompleteddesignwasaYeka/s te. 4 The equipment selected for this inspection was an strumentation rack designated mpd
- as MM-IR-14, located in the equipment vault a levation 3'#, west of Column Line 0 and north of Column Line 1.
- p m s _. , q>6 %ed m p , h. nb '7 Y M Thepurchasingoftheequipmentsuchasthisrackiscontrolledbythehdmint-
., 4. - F strative Procedure;' AP) No.18h, g:1 ":; 1.~.r% This procedure has 4'===*
been
, t*t revised several times, the last being Revision 5. dated November 1,1983( It 4
describes the procedure for preparation of the suggested bidders list, material requisition, bid analysis approval by the L..... m. . . . . . . . . . . __ .., V4EC , issuance of purchase order and change orders.
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* //lo/afA 44-2.
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The provisions of the AP-18 are coordinated with theGP-36/,M1 ;f Ri dc 9 4gn". 1::::d ;a "ey !A. 1990, the current issue being Revision 2 dated (tekenee +: --). October 14,1983 3 This procedure addresses the control of seismic analysis and seismic design of structures, systems and components and defines thc responsibilities of the project personnel and staff groups for the Seabrook project. It also describes the requirements for the development and control of amplified response spectra O?e (WN)Anwe A +.in accordance witbenera and exc Ag F
,q w C(AP-2
[ -%.p_.u'!:;W;;ria;;y Design "C:r:r ! Procedure in 2 4. bu.ept for (GEDP(-0012 deviations rd 5:4:_Pr:::dur: (Sdceek) fe as t' 4, identified 2, a 3gs w+k - A 9& - uto. gr4 --reyw % ~< sr Pwwr-. fj From tne cocuments which we have revie<ad it appears that the pivot figure in,the interfacing between various disciplines is the Coordinator of Seismic Design (W. His role has been mentioned briefly in Section,4.2 in connection with development of h for piping supports. Similarly, in the case of equip-ment supports, the[SD)becomes the nerve center of coordination of the design effort in interfacing between project personnel, Stmter:1 b1yeie c-ep
, Mechanical-An:!yti: Cr::p r and."!?: '"ppert G-e"? The team judged that introduction of this position in the organization of the staff of UE&C greatly improved coordination of the activities related to the design of structures, systems and components since many separate groups are involved in the complete design process. -
m-In case ofgIa-14, the !&C Group issued a Staff Work Request (:SWP) t MAG to r.ne revise response spectra in order to incorporate instrumentation Pee +f which , included Rack No. 14. MAG responded that thehtables are not available and requested the ki::ic N;isc Cecr&cter to originate thehfor
fc-3 b kf the rack at the specified location. Thenextactionwasfromhtothe group requesting that the be generated. Upon receipt of thehfrom the they were distributed to various disciplines, MAG being one of the
~
recipients. Following the provisions of AP-36hdeveloped the loads at the anchor points which have been used, through theh by the structural de discipline in adesign of the structural steel framing at the location of the rack. Meanwhile.hreviewed the vendors seismic qualification report with respect to specification for the rack and was found to be acceptable. We verified that the ARS values used by the-Hechanical N1ysi! Gr~.;p h were those provided b the Stivdurai Analysis Gruuph through the Setsmic-
-Design-Goordinato r as required by the Ap-36. We also verified that the ,
values of the final anchor loads generated by thehhave been based on the information obtained from the vendor's drawings and that they were used by t/e the structural discipline staff in design of the structural members. 4 We reviewed the method of development of the ARS by discussionf(with the f[ cognizant engineers of 3)t[ SAG and by reviewing the method as described in Wij # the Controlled ARS Tables entitled "Amplif)ied Response Spectra for Seismic (/jo"$ Category I Structures (2Meetables g These
+.- undergo controlled updating and distributionjp ccordance wit strative Procedure No. 23, Cr. . s e e +. - n.
The various steps 11Tustrating the complex system of interfacing (Documents" A F '2.Q 4 between various groups and project disciplines is shown in Figure /.,g,.It illustrates the complexity of the problem and also shows the vital role of the coordinator of seismic design h in the prteess. It has been pointed (.-
4,4-+ y ' lc c MM* /tf 6.N""e
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4 N l i i Fi'4' 4- . ffe. . , ! out previously (::: :: L. 4.?) that in the past ackoftheQwasresponsi- ' ble for use of incorrect seismic amplified response spectra. The team found \ l
\
j evidence of such a design deficiency, which occurred as late as in 1979, in i . the areas of seismic design of safety related components supported by the l I containment annulus steel frames. By memorandum 58U-31426, dated November 6/ foferee,ee +_ ..- l 1979(gE4C reported to tn)e, project manager, YAEC., that the amplif~ } N Tf-l spectra used in the design that fo he annular steel)fr which.:ehagSd i a . p . s., - 7 have-beer 1rstd. It has been also found that the amplified response spectra , ! i for the annulus steel frame had "g" values greater than that used in the l . component design. The same memorandum informed the project manager that in ! l ! order to ensure that other discrepancies do not exist in the seismic design, ; ! i ! an audit would.be performed to ensure that the proper amplified response l l spectra were used of all items on the Seabrook project. In the case of the i
- Seabrook project it appears that a satisfactory design has been achieved without !
! i significant changes to the component. We consider the above as an excellent j j illustration of the importance of good coordination of design effort between l various disciplines in a project of the size and complexity of a nuclear j plant. , 1 : Theamplifiedresponsespectra( ) are computed by means of a time-history i th.seismicanalysis. The overall dynamic response of the structure is l ' ! determined by analyzing a model formed by lumping the mass of the structure and the non-movable equipment. These masses are,in most cases ,1 umped at the e k w Ne*ur. j floor 4evey 4The masses are connected by weightless elastic beams which represent the structural members between mass points. Torsion is accounted ; i for by considering the eccentricity betwen the center of mass and the center , i I
h*/14 4(n -6 . y.
,~
of rigidity. Floor slabs are assumed to be rigid in their own pla[e. compuawf Each structure is analyzed for two horizontal components and one vertica1 for 4 and magnitudesofgroundmotion.en+Thecommonresponsefromthethree components are combined by the square-root-of-the-sum-of-squares (SIW6) method. l.ocal amplification of overall response ak computed by one of the two methods. In the first method, the slabs, beams and columns are evaluated for a range of frequencies selected for all local frequencies below 33 Hz. An overall stick model is then generated in such a way that at each elevation examined, the sumation of the weight of the single-degree-of-freedom (4005) modes and the st ck model mode equals the total weight. The single degree of freedom systems, representing the computed range of local frequencies are connected to the overall stick model as if they were all rigid. The stick model ( 5: hd' ; th P^P's) is then analyzed using the ground motion artificial time history as the input forcing function. The other method consists of performing a dynamic analysis, using finite lements, in sufficient detail to predict local modes of vibration. In this case the input forcing function, at the elevation of the ' structural element, is the response time history from the overall stick model. l .. The frequency and time history analyses are performed using the STARDYNE computer program. As a result, the maximum response of a series of oscillators is obtained, over a range of frequencies and the plot of these
- - - - . , - , , . - ,, -m- . .- - -,- . , _ -
b*/ff 46-G I values is the amplified response spectrum, which is generated using the SAG 058 Weference 4. _)- computerprogram4 The SAG 054ytomputer code is then used to generate ARS tables by enveloping raw curves rN$y IG nd spreading the peaks by 10 percent or more in accordance with the requirements of Regulatory Guide 1.122. We found that the methods of generating the amplified response spectra described ahnva are acceptable.
*h *' # ] '
ug.n. A'ed _ While reviewing the se6em6c model usid by SAG to generate the ARS we noted ima/ elf that the location of the platform a evation 3'[was incorrect when compared ' I 6 Vere,ce gomme) - to the structural drawing F-101558, Rev. 6, dated 7/9/82 3 Since the model -
)
iteself was dimensioned correctly, the relative displacement of the model in ; ! relation to the reference points will not affect the results of the SAG's Eh analysis. We found, however, that an observation is in order to point out es p3.,/gm the apparent lack of attention to the details on the part of the SAG analyst
, t WNe'on and the checker (Observation 4.L9). ,,
.) v
@ggf %4.S m Q'i"*~FV O E In our inspection we observed that the structural design drawings Nos. F-101558 SkJ and F-101562 W been released for construction on (eptember 28, 1976 and deb esce sand 4-
- f. the structural desi n calculations, Calculation
<?n ci )
July 6,1978('respectively L AM A._h ,+4- VW. FW A.1'- eue 4. ) that the original PB-76Vhavn been completed on Decdmber 1,198 We reques . . . structural design calculations, from which the above design drawings were prepared and the members fabricated and installed,be presented for inspection. j The original design calculations could not be found and we concluded that 4 . the absence of such computations constitutes violation of AP No. 22 " Calculations" Section 2.3.1, Revision 5, October1975 1,(ferecoce +. -)) (Finding 4.20 .
I . - , j g,7 i i [ Review of the Calculation No. P8-76, Rev. O, dated December 1,1983 revealed that when the designer' considered different load combination equation involving seismic loads (48Eism4sFJ the live load had been omitted. W%s t Yviolation of " Structural Design Criteria" SD-66 Rev.1, November 30, 4 c m ,, #. 3.
- . 1982, Section 4.2.1 and Table 5.4-2qWe discussed this matter with the staff of the Structural Discipline. They presented an argument that this is consistent with sound engineering practice since during operation of the plant there will be no loa'd (such as people or material) which could be classified as live load. Furthermore, the footnote pertaining to Table 4.2-1, of SD-66, i "Unifonnly Distributed Live Load" states that
- "
Uniformly distributed live load" shall not be considered with seismic load conditions except loads which l l are marked " Permanent". Examimination of Table 4.2-1 revea that with two iI apprw;mafely [ exceptions (150psfincontrolbuildingatllevation(+)9'g)theonlylive ' load listed as " permanent" is snow. In our opinion, such a classification j of the live load practically eliminates consideration of live load from ! structural design in combination with seismic. loads. This is contrary to the l l statement in FSAR Section 3.8.4.3.a.1(b), " live loads" which states that
" Live loads are all temporary gravity loads including but not limited to nonnal snow loads, conventionally distributed and concentrated floor loads, j and movable equipment loads, such as cranes and hoists". Additionally, ;
! omission of live loads from load combination equations violates the require-i l ments of Section 4.2.1 of the 50-66 which states that "except for the Administration and Service Buildings the minimum live load shall be 100 PSF". l We do not object to the statement in the same section of the SD-66 which states that "When actual equipment loads are used, unifonnly distributed live loads T' "*. need not be applied to the area covered by the equipment. In the final analyses k, y,.,,-r-r.--, e., -i+..,,,-.,--e., -
-e . + - - - - , - --v----,-.4-.---.--..r--..- y-- w, r e s -- - ---wee .--,, - , . -,,--,- ,m-1
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$=k
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- the actual equipment loads may be used unless estimated uniformly distributed live loads are greater than the actual loads, in which case the members designed with estimated loads may be revised or left as originally designed". We do,
~
however, find it objectionable to remove live loads from the areas away from the equipment. ' We asked the staff if the floor live loads presently are or will be posted in order to prevent an inadvertent overloading on any area and we have been , informed that they are not posted now and that such action is not planned for the future. Cea;;;.eatly to tt,e eLv . . iinaing regaratng live noen . .e te;.. - filwd (F;..J;.3 4.23). From the discussions which we had with the UE&C staff we infer that omission of live loads in combination with seismic loads is a
+4 e wide spread practice and we recommend thatgin resolution of this issue an audit be initiated which would assure that the affected structural members are not overstressed when subjected to the load combinations including live and seismic 10 ads. 7Ee M omissievy *f ave l*d' 'O cdN* '"iN #*i'#
loads M //oev- arre,ps i d e*v & by erufmenfis ms/kW) 4 6e .e v,o rm of n d . d e .s /r ve/vea l ale s, y c/ W e H a ( & dy 9,23 . i During a tour of the plant, we observed that one leg of the ins rumentation - 3
- m. p _ _ .
rackg IR-14 in the Auxiliary Building Equipment Vault atflevatio 3'$ is MavAc i resting on a 1/2 inchglate instead~ of the structural member, C10x15.3 as - ! assumed in the design (Calculation M PB-76, Rev. O, dated December 1 ! S A, hee 4: l 1983). This configuration foms a cantilever with respect to the channel. l We concluded that this is contrary to a sound engineering design and j recomended that a vertical stiffener plate be provided, welded to the channel, , and under the leg of the rack to carry the load to the channel. The reasons l for this reconnendation are as follows:
,~4- 2.---.- . m .,--., ,- ,-% ,,- - - , - v--#- .-, - .,r-e - ar v* - e ,-+-+** me----*+ -t--4er--+. -w -+v d-+----=--v -e+e-- -- -*-e-w-----w- - ~ ~ ~ - - - - e +mi=*- - ------~-
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E-9 a) The ARS have been developed for the supporting structural member not the plat'e and therefore the dynamic response of the plate supporting the rack will be different from what it has been designed for, and
- b) The leg of the rack is situated at the corner of an opening in the plate l' .
s ac/emst/ platfonn which has been cut out to accomodate vertically ::venitg4 cables. This may be responsible for stress concentration.f We reviewed the level 7 of stresses in the plate platf'onn supporting the rack and we found that I L / they are, low with respect to the code allowables. For this reason and
- because the situation just described did not violate any requirements
~ regarding existing codes or procedures we did not consider tht my flis ib be of a finding,wenid bc ;;repriatg. We do believe, however, that providing a stiffener plate as described above would improve the design. ~ In sumary, it appears that the process of procurement, and design of supported instrumentation and control systems is well managed and design controls are
~
handledinaneffectiveandefficienkway.'ItwouldappearfromFigureX that the interfacing between different disciplines and staff groups could be more streamlined,but taking into consideration complexity of the problem one . can run into a danger of oversimplifying the procedures and bypassing important quality controls whf ch might result in serious inadequacies of design. ,
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= i' . ,
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. , _ _ - , _ . ~ . - _ _ ,. .-
'l l
h*/8f 4 Notes on Figure X l Generation of Anchor Loads
. 2p/NaWe f
- 1. I&C requests MAG to provide ARS at a specific location %1ev. 3'4) for W W-IR-14.
MM-
- 2. The ARS for the41R-14 were not available, therefore MAG requested CSD to generate the ARS.
c.1
- 3. CSD transmitted the request to SAG.
- 4. SAG generated the ARS and transmitted the information to CSD.
- 5. CSD distributes the ARS to project discipline and staff groups. Advanced copies immediately, controlled copies approximately every ::ix ' months.
- 6. I&C provides ARS to the vendor for preparation of seismic qualification report (SQR).
- 7. Vendor prepares SQR and submits it to I&C for review.-
- 8. I&C forwards the SQR to MAG for review and approval.
- 9. MAG notifies I&C of acceptability of the SQR.
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- 11. CSD transmits the anchor loads to the structural discipline for design /
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- 12. Structural discipline prepares the design calculation and the drawings and releases it for fabrication and construction.
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Document' Name: 1.9'/.Y SECTION 4.7 - SEABROOK-IDI
' Requestor.'s ID:
y EILEEN 3-Author's Name:-
- R. tipint% S4c vmeder
- . Docurent. Comments:
3 Subcontractors.. . 3-t
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I , .4.7_ Subcontractors Off-Site The objectives of tNis portion of the report were to ascertain: (1) How the licensee's design commitments being implemented by were being transmitted and used as input for implementation by several off-site contractors. (2) The level of control main'tained by over the subcontractor as well as the actual performance of the subcontractor. (3) The manner in which the subcontracto fo eed controlled activities . impacting.the design of the facility. In order to complete this phase of the inspection effort a selection was made from a list of subcontractors doing work in the design, engineering and services area of the project. The first subcontractor selected was Prof. Ed Burdette
- (test verification of certain design assumptions) who was chosen on the basis of an example of direct design related services. The second and third sub-contractors were selected on'the basis of the volume of work as well as the.
fact that both represented the next step in the design process beyond the basic design engineering effort completed by UE&C. These were William J.
. Lester, Inc. (structural steel detailing) and Bethlehem Steel Corporation
_(detailing. furnishing'and fabricating reinforcing steel).
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!!+/gg s 7- 2 Burdette Consulting Contract:
In 1980, United Engineers and Constructors (UE&C) contracted Professor Edwin G. Burdette of University of Tennessee, to perform certain tests to establish the load-displacement relationship of the liner plate anchorage system to be embedded on the concrete containment. The objective o dthese tests was to demonstrate the adequacy of the liner anchorage system to meet the requirements of the ASME Code, Section III, Division 2. We reviewed the 6vailable documents pertinent to the tests provided by UE&C. The test program was administered as a part of the Purchase Order No. H.0. 56971, Change Order No.1, dated 9/29/80 (Ref. ). The Procedure for Containment Liner Anchor Load Test (Ref. ), required that the specimens be prepared on the Seabrook plant site using the procedures and material approved for construction of the containment structures and shipped to the University of Tennessee for testing. These specimens consisted of 3'-4' x 3'-0" x 2'-3" high concrete blocks with the liner plate attached to the 3'-4" x 3'-0" top face. The embedded anchors consisted of tees 12 inches long and the two studs, 3/4 inch diameter and 12 inches long. We concluded that the specimens used in the tests adequately represented the containnent structure and the liner with its embedment system. The test-procedure required that all measuring and test equipment be calibrated before testing and evidence of calibration be available for review. At our request, we were provided with a Testing Machine Veriff' cation Certificate, , (Ref. ) which. stated that the 120,000 lb. capacity machine, belonging to University of Tennessee, had been_ calibrated and the loading ranges have been found accurate with tolerances ranging from 0.42 to 0.83 percent. The cali-
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.bration was performed by the Tinius Olsen Testing Machine Company, Inc., of e Willow Grove, Pennsylvania on June 10, 1980. The load cells output readings found in the report were based on the-load readings from the same testing machine referencing the same calibration date.
We concluded that thera was sufficient evidence of adequate quality control
~
and that the tests were conducted with an adequate standard of reliability. Bethlehem Steel Corporation: l
- The basis of the subcontracted services and in' this case material, to Bethlehem
- l. ( Steel Corporation (Behtlehem) by UE&C was the UE&C document, " Specification
. for Furnishing, Detailing, Fabricating and Delivering Reinforcing Bars" , (Reference 4. ). This document was issued originally as Rev. O, 1/24/74 j and has undergone ten revisions since that time. A detailed review of the
- important design information relative to this specification was made by the team with respect to the design commitments of the FSAR and the' discussion i was noted previously in Section 4.4 of this report. Since the Seabrook project I
- was committed to use the ASME Boiler and Pressure Vessel Code, Section III, Div. 2,- the specification imposed stringent requirements for quality ' assurance.
' No distinction was made in the _ specification so that all work and material
[ supplied by Bethlehem was to conform to the ASME Code. The team placed 1 l specific emphasis on the manner in which Section CC-2700, Materials Manufacturer's Quality Assurance Programs, were reviewed, accepted and imple-mented under the requirements of the specification. The rason for this was due to the fact that the Seabrook Project represents the first incorporation l
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i /; G 4.7-f I of the ASME Code,-Div. 2 into a plant proceeding to completion. Bethlehem,
.pr ior to t ehstart of the Seabrook project, had addressed 10 CFR 50, Appendix B in a quality assurance manual which was undergoing rework early in 1974.
An.early version of the Bethlehem Quality Assurance Manual was submitted with the bid in January of 1974 and subsequently reviewed by UE&C. As a result of this review a series of meetings and discussions ensued in order to obtain conformance with the specification. In addition, to meetings held at UE&C
- . 7: .u,, =.-m-offices on January 23, 1974, meetings and reviews were held g t the Philadelphia Bar Shop of Bethlehem where a QA Audit check list was used to perform a Facility Survey conducted by a QA Audit Engineer from both YAEC and UE&C.
.( The following day similar discussions and audit activities were held at the Steelton, Pa. facility of Bethlehem.
The results of these discussions and audits were documented by YAEC and UE&C as well as by Bethlehem (References and ,respectively). The Bethlehem report highlighted the following items. (1) Interpretations of quality assurance by YAEC and UE&C is more stringent than any seen to date. (2) QA Manual submitted with the Bethlehem bid proposal was considered unacceptable in its form at that time because of: l l s, (a) Separation of QA for steel production and detailing / fabricating not clear.
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J (b) Certain items should be removed from the QA Manual and developed , into written quality procedures including such items as testing, instrument calibration, drawing and detailing standards and document checking, review and approval. (c) Needed improvements in document control. i (d) Needed clarification of stop work authority and chain of command. , (e) Needed clarification on control of non-conforming material and iden-tification of material by heats and controlcf ic'edOobo^ J 5**b '7 (f) Definitive information on the control of quality in the Engineering Department. (g) Needed personnel / position descriptions and individuals' q'ualifications. (h) Needed changes in the Bethlehem Nonconforming Material Report forms. The report ended with the following statements.
"J. W. Singleton (YAEC) invited us to visit their facility for general review of any of the Quality Assurance Manuals in their possession as an aid in our preparation of manuals.
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( It appears that our present thinking of the Quality Assurance Manual ! i', right on line provided we have documentea quality control procedures i available such as described above. I believe they have given us some good pointers which should be to our advantage in the future if we
. implement them now "
FollowingtheseeffortsBeh)lehemcontinuedtoworktowardachievingan
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upgraded quality system including a revised QA Manual and a series of quality procedures based on the interfacing which had been taking place between the three major parties on the reinforcing steel. At the same time Bethlehem was providing comments to UE&C on the specification which
, had been issued for bidding purposes. A series of correspondence was reviewed in the Bethlehem Seabrook project correspondnece file (File Folders 1-4) over the period from January 1974 through the date of the contract, May 15, 1974 to October 25, 1976 when the Bethlehem QA Program for Seabrook 1 and 2, Rev. 2, 9/26/76 was approved for Fabricated Rein-forcing. These documents included other audits performed by UE&C at the various lacations where Bethlehem was doing or was to perform work on
. the Seabrook Project. These documents are included as references to this report (References 4. through 4. ). The first transmittal of engineering drawings to Bethlehem M on July 18,1975 (Reference 4. )
ne Jebdin. 4 (degh eg 1 and reinforting steel was aut.horized by UE&C on June 3,1976 (Reference 4
- 4. ). It was noted in reviewing the information related to work being processed in the various Bethlehem facilities that the-first reinforcing steel shipment was made from Bethlehem's Boston Shop on August 3, 1976 which was prior to the approval of the QA Program by about 3 months.
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.In addition to the detailed review of the controls exercised by UE&C over Bethlehem in performance under the contract and the technical and quality requirements of the specification, the team reviewed selected portions of Bethlehem Quality Assurance Manuai, the Standard Quality Assurance Program Manual for Fabricated Reinforcing Bars, the Facility Manuals and the Quality Assurance Procedures Manual for Fabricated Reinforcing Bars (References 4.
and 4. ). i The QA Manual (Steel Plants) provides the statements of quality policy for the entire Steel Operations Group and functions as a single source document. Quality manuals, procedures and instructions at individual plants and shops , emanate from this QA Manual. The responsibility for quality programs for the corporation rests with the Office of the Chief Metallurgical Engineer of fteel Operations. As part of the Bethlehem Plant Committee System there is j a Corporate Quality Assurance Subcommittee wr.fch serves to develop and l coordinate quality assurance policy. The Bethlehe:c QA Manual is in a form so as to address several MIL Standards, ANSI N45.2, ASME B&PV Code,;Section III j and 10 CFR 50, Appendix B. Section 5 of the Manual includes the specifics of the corporate policy on the quality assurance program as applied to 4 fabricated reinforcing bar. In summary, the following points are addressed ~
- in the Manual..
(1) Fabricated Rebar Quality Program is coordinated by the Reinforcing ) Bar Engineering Group. l l '1
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(2) The QA Program for Reinforcing Bar Fabricating Shops is consistent at all shops in the country. (3) The Chief Metallurgist at each piant coordinates reinforcing bar QA
, policy but at shops (fabrication only) it is addressed by on-site Engineering or a separate quality group.
, (4) Audits, final disposition of corrective action and control of records are performed by the Bethlehem Home Office Reinforcing Bar Engineering Group. n (5) The management review for the Fabricated Reinforcing Bar QA Systems is performed by the Corporate QA Coordinator. The Standard QA Program Manual for Fabricated Reinforcing Bars addresses fifteen of the eighteen criteria of 10 CFR 50, Appendix B, noting that Sections III, IX and XIV which are Design Ccntrol; Control of Special Processes;and Inspection, Test and Operating Status respectively, do not apply to the services or products i of Bethlehem Steel Corporation. The team did not disagree with the exceptions taken by Bethlehem.7 The Manual provides a description of the QA organization & and the authorities, responsibilities and duties of persons performing the QA functions. It also sets forth the Bethlehem policies for satisfying the QA Program requirements and references the other Bethlehem procedure manuals which describe, in detail, the procedures and instructions for accomplishing the activity. 4
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- 4. 7-9 The manner in which the QA Program Manual for Fabricated Reinforcing Bars becomes a specific quality document on a project is that during the proposal
- or bid stage the Standard Manual is submitted as an uncontrolled document l and forms the basis for specific project quality assurance items relative 1
l , to the contract. With contiract award the manual is amended, if required, using { an appendix to provide conformance with the client's specific project quality
- assurance program. At that time, the Manual becomes a controlled quality document.
i
!- Bethlehem's next level of control consists of a series of Facility Procedure Manuals appropriate for a given activity and a given Bethlehem facility. These
- i. / address three basic activities: steel production, detailing reinforcing steel .,
I and fabrication of reinforcing steel. - r The remaining Procedure Manual is known.as the Quality Assurance Procedures I Manual for Fabricated Reinforcing Bars. This is a standard manual'which ' details the procedures required to implement the QA Program Manual for l . Fabricated Reinforcing Bars including the monitoring of the work procedures of the facility manuals for detailing and fabricating reinforcing bars. I The team reviewed selected portions of these manuals in order to assess the y ek h r d ern programmaticaspects'ofBethlehem'sprogremyndthentoassessmannerinwhich , Bethlehem has performed and control ts activities which impacted the design of the Seabrook facility,=tc orinr pium The following sections of the Standard Quality Assurance Program Manual for Fabricated Reinforcing Bars were I 1 - . .. . - = . . - . . .- . __ . _
V+/M 6 7-/o reviewed for conformance to 10 CFR 50, Appendix B for the specific use in reinforcing steel detailing and fabricating activities. Section Title Rev. No. Date 4 Instructions and Procedures 2 1/1/79 5 Document Control 2 1/1/79 8 Inspection 2 1/1/79 12 Nonconforming Materials 2 1/1/79 13 Corrective Action 2 1/1/79 14 Quality Assurance Records 2 1/1/79 15 Audits 2 1/1/79 16 Special Contract Requirements 2 1/1/79 including Appendix A, Special Quality 4 4/26/79 Assurance Requirements for Seabrook Station Several items are of note as a result of the review of these manual sections. Section 8.2 related to the Engineering Department requires a scheduled review to be conducted on the current work of each detailer assigned to nuclear projects. The review is conducted to assure conformance to ACI, CRS'I, Bethlehem Steel Corporation Standard an't the project specifications. Thiswa.]viewedbythe j i team to reflect Bethlehem's full commitment to a quality system and assuring l t l that the detailing of reinforcing steel is being done as required by the Project documents. In Appendix A the special requirements imposed by UE&C in Section 3.2 of the specification related to Cadweld sleeve criteria fit were reflected.
4 7 ,, 'N/94 7.
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The requirement of CC-534 f the ASME Code regarding visual examination for transverse cracks which were part of the-specification were also reflected F in the special requirements of Appendix A. With regard to bar testing,
- Bethlehem included in' Appendix A a procedure defining the mechanical testing ofreinforcingbartomeet'ASTMA615,theASMECode,Regula(Guide 1.lg"?
and the specification. Also contained in the Appendix is a commentary on the Reinforcing Steel QA program, mainly emphasizing the traceability of material l from the time it is produced in the steel mill to the time it is fabricated., ! shipped, received and stored on-site. j With the Quality Assurance Procedures Manual for Fabricated Reinforcing Bars i j the following procedures were reviewed. i e ! i i Procedure Title Rev. No. Date i II Document Control 3 2/1/79
- III Review of Placing Drawings 3 2/1/79
- IV Inspection 4 2/1/79 l VII Nonconforming Items 3 2/1/79 l VIII Corrective Action 2 2/1/79
! X Audits 4 2/1/79 1
{ All of these procedures were noted as being very comprehensive and detailed
- and provide an excellent tool for the personnel who must execute these procedures j 1 as well as those who use them in the review, inspection and audit functions.
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Y"fff 4 77 --/Jr 1Two additional procedures, which were specifically associated with the work completed for the Seabrook project were reviewed. The first was " Quality Control Procedure for Fabricated Reinforcing Bars for the, Bethlehem Plant, Engineering Department, Detailing," Procedure No. I., Rev.1, 6/1/81 (Reference J 4 . ._ ) . The second was the " Quality Control Procedure for Steel Operations For In Plant Shop for Fabricating," Procedure No.1, Rev. O,10/14/77 and the (Referesee 4. ~ ). Addendum for Steelton Plant, Rev. O, 11/28/77 fg These were noted to be adequate to control the detailing and fabricating work that was done and is still unde rway. l In addition to reviewing the specifications and manuals documenting quality control and compliance with the pertinent codes and standards, we also reviewed shop dra' wings, generated at the Bethlehem Steel offices in or. der to verify their conformance with the design drawings produced by( C)
. were 4 We learned from the Bethlehem staff that the reinforcing steel which have-been detailed at the Bethlehem,home office were for the following elements of i the containment structures:
(1) Reactor P.it (2) Containmentslab,El.(-)26' (3) Personnel and equipment hatch
!&!bt 4.7-13 (4)' Containment dome - Unit #1 has been completed, Unit #2 is being worked on.
Exotic bars (around openings and out of plane bending) are detailed at the Philadelphia office.. , (5) . Primary shield wall, approximate elevations (-)25' to (-)2' (6) Containment building slab, El. O' Detailing of reinforcing bars for other structures has been done either at the Boston or Philadelphia offices. During our inspection in Bethlehem, Pa., we reviewed some of the drawings pertaining to the reactor pit and the contain-i ment dome, Elevation 119'[the sprirp I!ne)and pex. fThe list of rawi s ' edduri[theit[ect19r is con ined in ectin7.9.I, which ha been revi {(Refernces4.-t 4. -).] le had$b informed that the major difference between the Unit 1 and Unit 2 drawings is the fact that in Unit 2, by increasing the length of some of the reinforcing bars, the number of caldweld splices has been reduced. (Je vie <Jed NIS -* $ 2 e w , 0!' '? b A s' FA'e c'k'yn b l" h"fraeenh 9%EC w/ US(C mzEiny _ Due to complexity of the reinforcing in the congested area of the reactor pit, the detailing was done using a model, which was built by UE&C, showing all the reinforcing steel in actual position. The Bethlehem detailers studied the model and then generated the shop drawings. While reviewing Bethlehem Drawing No. 017RM31, Rev 4, dated December 5,1978 (Reference 4.__ ) and comparing it with the corresponding UE&C design drawing, Drawing F101402, Rev. 13 dated March 24, 1981 (Reference 4. _), we observed
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that the spacing of the horizontal stirrups which on the design drawing was wheras %e span 9 was 16" apart e s shc'c:a on the detailed shop drawingges 8" apart. The total amount df the reinforcing steel remained unchanged in spite of the change in spacing. The design drawing had not been updated to reflect the change edt - in spacing. The reinforcing steel remain /esignated in the design drawing as 2x4-f6 0 16". We found that this is a violation of Administrative Procedure
#29, " Document Control - Foreign Print System" Section 8.6.2, Rev. 7, dated April 12,1983 (Reference 4..__). In all of the drawings reviewed this cas the only case where a discrepancy between the design and shop drawing e N 4e found. This was noted as a finding, but had no generic implications and k be . to was judged,an isolated instance of lack of consistency and maintain up to datedocuments(Finding 4-21).
A review was made of the nonconformanc.es issued against two of the shops within ~ the Bethlehem organization which provided some of the fabricated material to the Seabrook facility. NCR's for the Albany Shop for 1982 were exa' mined. Four separate reports had been issued, three of which related to incorrect bends which resulted in scrapping the material and rebending from new bar stock and the fourth being an incorrectly recorded heat number which was corrected, i:CR's for the Steelton Shop for 1983 were examined. Eleven separate reports had been issued. Of these eleven, five involved bending errors, three involved cutting tolerances, and one each involved a detailing error, mislabeling and missing bars from a bundle. Based on the size of bar and the tonnage of rein-forcing steel involved the team judged the number of non-conformances to be low. _ In all cases corrective action was taken before any of the non-conforming items had been incorporated into any safety-related structures.
. I 'n &d ;
- 4. 7-/S Based on the review completed and the work cbserved the team concluded that the licensee's design commitments had been clearly transmitted to Bethlehem via the specification and the engine' ring drawings and details. Letter and meeting communications also served as an important part of the total process of providing design interfacing and design input. Bethlehem was viewed to have
-in-place a good quality system with appropriate quality standards and procedures.
The team's sample review indicated that Bethlehem had also executed these pro-cedures well. A system for the review of shop and placing drawings existed as was being effectively implemented in accordance with the Quality Assurance 4 Procedures Manual. A fully adequate system to document and control the records and design changes, thus assuring that all the latest updated input data was being used for the development of shop and placement drawing exists. The Drawing Record Card, the Transmittal Control Form Letter and the Order
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Entry Record Card have been the keys to good document and records control. Based on the team's observations it is evident that the Bethlehem audit system has been effective in identifying some random errors and assuring that corrective action has been taken. As a result of the team's review and observations of the work of Bethlehem Steel Corporation on the Seabrook project it is the conclusion'of the team that the necessary elements of design control have been in existence during , the detailing and fabricating of the reinforcing steel for the plant structures. Additionally, we have concluded that these controls have been adequately imple-mented.se er t :::;r; ;&fe ;tra:tu-es.
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D:cument Name:.- SECTION 4.8 - SEABROOK IDI [ ///EVrF Requestor's ID: - EILEEN Author's Name: G. Harstead Document Comments: As. Built Conditions and Surveys
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?- /)78y 4 8-/ r l 4.8 As Built Conditions and Surveys , i t The objective of this portion of the inspection was to ascertain: I L l (1) How the changes generated in as-built conditions such as structures, i i ! , systems and component are processed by the UE&C and the contractors. l l I
- (2) How the final loads resulting from location of pipe supports, electrical f j cable trays and ventilating systems, including those not specifically j considered in the original design, are verified. !
1 I e ( (' (3) How the drawings and identified supporting documents are updated, main- ; i tained and certified, so that the completed work reflects the'as-built l conditions of the plant for future reference. i The team first reviewed the procedures which were in-place to control this ! ! area of plant design and construction. Among the documents which control ! as-built, conditions of structures, systems and components we reviewed those which seem to be the most essential in the process. Those are: Administrative , Procedure No. 39, "As-Built Documents", issued on November 17,'1980(Reference i 4. ), , Administrative Procedure No. 15. " Changes to Engineering Change i ; , huthorization", issued on September 8,1977. Revision with numerous later isions(Reference 1. ). Technical Procedure No. 11 (TP-11), " Minimum ! As-Built Record Drawing Listing, issued on April 29,1983(Reference 4. ), j [ Field Administration Construction ProcedurefFACPj No.10. " Procedure for old Calculations",' issued on March -11,1983 (Reference 4. fAC+ I _- . _ _ _ , , , _ _ _ _ _ . _ _ _ _ , _ _ . - _ _ _ _ . _ . - , _ , _ _ _ _ _ _ .
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$7Af 48-z r me sad & FAcP -Io q 'LProject Instruction for Handling UE&C/ Contractor Nonconformance scAWo.4 or Deficiency Reports", Rev. B dated July 22,1983feference4. ).
i + . J ! Currently Administrative Procedure No.15 has 18 revisions since the original i issue, the latest being dated August 17, 1983. It describes how questions i l and changes to design documents, deemed critical to support on-going field activities, are initiated, processed and resolved. It provides the criteria . ) which the proposed changes must meet in order to be approved, the flow charts i whichdescribethesequenckbywhichvarioussitequestionsareprocessedand the forms which should accompany questions raised by the contractor. The l questions may require an oral response, the response for information response j; (RFI) or may require an engineering change authorization (ECA), depending on
- complexity of the problem. The classification regarding oral. communication, i
! RFI's and ECA's can be described using the following guidelines: 1 , j only ' ] (1) If the question 4 requires an explanation or clarification, the oral response 4 is sufficient. . cw& j . (2) Request for information is prepared when an oral response is not sufficient hon and design documents are not affected which might$ issued by UEAC[ site or Home Office or drawings issued by die manufacturerar veadoe. t 1 (3) When the question / response requires changes (or exceptions) to engineering documents, such as drawings, specifications, or calculations, the contactor submits a proposed ECA. l i
- - . - - .. . . . - _ - _ , . . _ _ - . - , - _ _ - , - -... ~ , ..-. - - _
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48-3 The.ECA's are subdivided further as follows: (a) On-The-Spot ECA's wtriett may be used to resolve all the items except those involving generic problems and those requiring YAEC approval. AnyMinorECA(seebelow)maybeissuedOn-The-Spot. (b) Minor ECA's which are of repetitive in nature, e.g., involving movement and arrangement of sister splices in congested area to clear interferences of reinforced steel, modification of approved formwork i or substitution of higher strength bolts than the design requirements, I that have been reviewed and concurred with the Home Office Engineering,
, ( YAEC and QA as being appropriate for release.
(c) Major ECA's are those which are not classified as minor and in turn l they are subdivided into two categories: 1 j 1. Major specific case ECA's
- 2. Major generic case ECA's.
i i . ! ECA's and RFI's may be revised or voided by modifying and reissuing the ECA/RFI form or, in certain circumstances, by the use of the Continuation Sheet,. On
]
l the Continuation Sheet the affected documents ic$ listingg on the ECA/RFI
- fcan, ef =11 ** da'r ::t: th:t-must be revised or from which an exception is ,
taken as a result of an ECA issue must be provided. l
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i One of the important differences between the RFI's and ECA's is that the RFI's must not include Affected Documents while the ECA's must include them. Thus when an RFI becomes an ECA (when it has been decided that,the change requires change of engineering documents) a new ECA/RFI form is, issued together with a Continuation Sheet on which all of the Affected Documents must be listed. 4 Interdisciplinary coordination of all disciplines involved in the ECA is assured i by the requirement that all disciplines that are responsible for the documents 1 ! listed under Affected Documents must review the ECA. The AP-15 'is used together with the AP-39, "As-Built Documents". AP-39 identi-
, fies the drawings and other supporting documents to be updated, maintained and certified that the completed work reflects the as-built conditions of the plant.
This assures that the documents can be effectively used for engineering
! reference in the future for various reasons such as future plant operations, start-up testing, maintenance or modifications. The procedure contains a 4
listing of UE&C documents to be revised to reflect as-built conditions as l received from the Construction and Start-up departments. Its Attachment t
. No. 2 provides detailed information in that respect and it addresses inspection elements, including piping configuration, location of supports, as-built UE&C construction drewings and as-built tolerances. The procedure provides very detailed and couplete infonnation regarding the type of documents which must be revised to reflect theYAs5 Built condition. Included in that category l
are vendor documents which must be revised to reflect the "as shipped" l j condition of the item. In case of a modification in the field the drawing l ( must state what is " field modified" and provide the reference to the foreign l l
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print which shows the "as shipped" condition. Any changes should be processed ; in accordance with AP-15. l AP-39 also provides directions to the UE&C design groups such as the V Mechanical Analysis Group (MAG) and the Pipe Support Group (PSG) to perform 3 3 Mk he final configuration verification analysis documentation for pipe stress [, ~
/ analysis for ASME Safety Class 1, 2, 3 and B31.1 Critical Piping and NNS-1 Pipe Supports. The data which should be verified are such as the as-built stiffnesses of supports and restraints, attachment points of supports of
, supports or restraints to the structure, including ARS verification, etc.
As-built documents are processed through the Field Office Document Control t Center (Field DCC) as shown in Figure 4.8-1. Each contractor has the responsibility to provide the As-built documents. Piping and Pipe Support As-builts are handled through UE&C Power Engineering. The Field DCC records the approximate information and processes it further to the Home Office Document Control Center as shown on the chart. We have been informed that the AP-39 is under review and the future revision, No. 5, is expected to be issued by the end of February,1984. 7TE tersewsM 7IIef e b er d#nof
);vrsued b y tAe lem. -
$P-prc:e,h, T..c M in Attachment No. 3, contains the types of conditions or changes which do not require as-built information and incorporation into UE&C drawings.
In this category, we found the reinforcing steel changes. Aga4e N inquired why an important item like reinforcing steel is not required to be recorded to reflect as-built conditions and we $Ne n infonned that this item applies to the cases when the amount of steel.is the same as stated on the design drawings but for some reason, usually because of local interferencesjsome of
2- z.-.... = .. : . . . . . ..------- 4,g_g Yn&i { {' I the reinforcing bars have been moved to one side or the other. We expressed our opinion that the listing does not restrict the discrepancy between the design 4 and as-b'uilt conditions in any way and such a deviation could consist of providing reinforcing bars of smallersn cross-sectional a .n a>qearea, s+ omission
~f of+ inad 0*d reinforcement in some area altogeker or ei;m,wiawy We did not received a satisfactory explanation regarding this matter and we consider this a serious I
shortcoming of the procedure. We do agree that there are many field situations
- where a change in placing of reinforcing bars may be tolerated and even some.-
times necessary. -We believe, however, that the procedure should qualify I this statement to avoid gross deviations from the design requirements which ! could result in an inferior or inadequate structure. . I
- 1. (
e l, The details of processing as-built documentation identified in AP-39 are described in the Technical Procedure No.11 (TP-11), " Minimum As-Built Record i has n.4- been Drawing Listing". This procedure was issued on April 29, 1983 and was-noves. ! revised. It is referenced as Appendix No. 4 in the AP-39 and its purpose is j to interpret the technical requirements of AP-39 and to establish " detailed. l identification of the specific UE&C Construction Drawings and UE&C approved 1 l
, ForeignPrintswhichshallbe/As-BuiltfbytheappropriateSeabrookkield t0rganization. Additionally, the purpose of TP-11 is to organize the drawing i
listing on a Work Package concept to allow effective engineering verification against the design basis condition and subsequent incorporation of theks-i built data into the design drawings. The procedure identifies six disciplines l l and in each of them there are two individuals named as the coordinators: : one in the field and one in the home office. l
._.-_..:_~.-- -
- ....: =-
'/!?!?4 48-7 !
pf f l MV d l Several organizational entities are involved in these programs at UE&C. . The beam verification program, which involves a complete check of the structural steel, Site Engineering located at the Seabrook site is responsible to respond to certain ECA's, RFI's and Nonconfomance Reports (NCR's). If Site Engineering l does not have a proposed solution to offer, the responsibility for resolution of the item is then with Site Support Engineering at the Philadelphia UE&C offices. ; I'n some instances the Structural Group in the home office may become involved. YAEC also part'icipates in resolution of these items when there is a potential for a major impact upon the project or they were responsible for the original
/ ' eview on the items or activities involved.
'l.
g[ a t (1) Structural Steel W= The procedures for this program are described in " Guidelines for Beam Veri-fication", dated September 19,1983(Reference 4. ). The beam verification program was established in order to ensure that all the structural steel beams
,%[ are designed for all the imposed loads. The treatment of live load is in con-e formance with 50-66 (Reference 1.3), Table 4.2-1.
.e r* , Note 1, to Table 4.2-1 states e i#h that unifomly distributed live load shall not be considered with seismic load e l conditions except those loads which are marked permanent are included in the
- calculations.
l The design of the structural steel beams for the Tank Fam Area as provided in Calculation No. WB-61 (Reference 4.34) was based upon using the unifom snow ;
\
load which is considered a permanent live load. In this case the procedure in which temporary unifom live loads are replaced by actual loadings was not j / applied. ,
.s' .. . ._. ,. .1 - _. - --. - - - . . - . - . - - , , - .
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%7/ra 58-6 I. . , hjeg esteewhM The beam verification. program is :ddivided Mt:Awomethods;namely, computer
. and manual calculations. The computer calculations are performed using the STRUDL c'omputer program. The beam to column connections generally are shear type connections which are made by angles welded to the beams web and field bolted to the column or girder. Horizontal forces are taken by means of bracing i thus eliminating the need for beam moment connections. The beam to column connections are; therefore, modeled as hinges.
The loadings used are:
- (1) dead. load (steel and general dead load)
I
~
(2) permanent live load (for seismic inertial loads one-half of the snow massisused) . (3) seismic amplification
, (4) pipe support loads and for piping of 4 inch diameter and larger l
(5) uniforin loads for piping of less than 4 inch diameter- l l (6) cable tray and bus direct loads conduct loads 1 O j ac - l , t sy&e*&s'j y l gt s y'" r y d ' (&,,v",yy aQ if]ar{)AY :
b7/>t 48-9
-s y-
/ g *s~l 5 O dere fW Ne 8VPfoes Ame4
, l b ar1yinal ARS curves in />fe prn '
y The Structural Analysis Group (SAG) has produced Amplified Response Spectra (ARS's) for various elevations of the building. Vertical ARS's were developed which accounted for the vertical response of steel beams. These ARS's are used in order to qualify equipment which may be located on the interior locations. SAG has also directed that the ARS's be used in the design of the steel beams. c2 The vertical accelerations are obtained from ARS's. One ARS will determine the acceleration at the support while the other will be used to find the acceleration at mid-span. These vertical acceleration values are developed from the appropriate vertical ARS's by selecting the 50 Hz frequency response
. for the 4% and 7% equipment damping response curves, for the OBE and SSE, respectively.
I The horizontal acceleration values used for beam design are taken from the
; 33 H: frequency response for the 4% and 7% equipment damping response curves for OBE and SSE. From these values, a uniform seismic acceleration is established for design.
Because the bottom flange of structural steel is used for the attachment of pipe supports, horizontal loads applied normal to the beam axis can'cause torsion in the steel beam. UE&C's procedure calls for checking whether the supported slab remains in contact with the top flange of the steel beam. If the beam were to deflect more than the slab, no capability of transferring torsion to the slab could be assumed. l l 1 i
gg_,o k t The Tank Farm Jtructural steel has not been addressed by the beam verification program as yet. The team would recomend that this be done subsequent to any reanalysis for the seismic loads as described in Section 4.2 and addressed in Finding 47 -17 ). ; (2) Reinforced Concrete No specific overall program currently exists o} assess the final loads resul. ting on concrete structures which would encompass pipe supports, equipment, cable ~ trays, and other systems. ( Under AP-39 certified As-Built rebar drawings are not required. The footnote in the Attachment 2 of AP-39 states that contractor drawings will be site
^2 foreton printed _, marked for information and turned over to Home Office Engineering andy%s.c The method of monitoring and recording of rebars cut or damaged is described in the Administrative Procedure No. 38, " Cutting Reinforcing Steel in Permanent Concrete Structure", issued September 5,1980, i l (Ehe e. +. 3 '
revised on July 31, 1981 4 ur 0 inquiries why the drawings affected by the damaged reinforcing bars are not recorded by the DCC in the field or the As deser/ded Weq // ws.s A"l Home Office did not produce satisfactory results.g AP-38 establishes N ,/- 9/r Ey a. eervwy /s snah
- responsibilities of. organizations for approval of cutting reinforcing steel 4,,,f, doc l*Ni during drilling into permanent plant concrete structures.
K Procedures for curring reinforcing bars can be divided in two categories: A - 1
. . . : .= = = . = . .. .__ .. . . . - . . .
918 -// 'b'7/ f 54cel (a) When Reserve Capacity Forms (the forms which list reinforcing tesgas
- required by calculations, those suppifed on drawings and the reserve
_ excess of the bars). are available for a given location, and (b) When such forms are not available. a.
- When a Reserv$ee Capacity Form for a given area is not available, the approval k OHec of all reinforcing steel bar cutting must be reviewed the " L e;.;; r E ; ; i n: ;e.9; (i OTTicO of UE&c. They check the design calculations to detemine if there is an adequate margin avatlable to pennit the proposed reinforcing bar cutting. If it is permissible, approval of such a cutting is documented by engineering change notice (ECA) or nonconfonnance report (NCR). When a Reserve
; Capacity Form for a given location is available, the Resident-Construction Engineering Group assumes the responsibility for approving cutting of reinforcing steel based on the information contained in the Reserve Capacity Fonn. AP-38 states, in Section 3.1, that when the Resident Construction Engineering Group l approves reinforcing steel cutting, these approvals are documented on the Site ApprovedChange(SAC). We learned that the SAC forms have been since discon-I tinued.::d th:r: r Eoberfai $$$- !$ ;:-ding upd: ting th:
u Revision 1 of AP-38, dated July 31,1981y Jes M /* y d dWM6Fh *f sv'
- es Wq 4- ?).
p(e Q We have been infonned by the UE&C staff that since the time whengCg:: b :: Aos ! discontinued changes resulting from cutting of reinforcing steel have been k treatedasECp's. y. 1 1
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I mk ,j' ey l i l e f'Y4 gd , We reviewed the " Project Reference Manual" (TP-23) Supplemental Information kWerencef- ) i for Design Change Program (,g November 28,1983(dateofRev.O Rev.1, dated not listed) which contains a list of Minor Change List (Section X). Since ! the list does not include reinforcing steel cutting, we concluded and concurred with the UE&C staff that these changes must be treated as major ECA's. This 4
. classification reinforces our believe that Attachment No. 3 to AP-39 (listing
[ of types of conditions or changes which do not require as-built information) should eliminate item 1, " Reinforcing Steel Changes" since such changes migh.t result from cutting of steel rebars. 4 Y In our inspection we selected few specific cases as the examples by which one j i could verify how the process of handling the as-built works. In o e case, (Em4sosace 4.- isupplied Material Deficiency Report (SMDR) #357 4 was filed by .the contractor reporting that a structural steel beam has a tear in toe of flange. The case was processed by the field office and found acceptable. It should be mentioned L that according to Rev. 3 of the FACP-1, dated October 4, 1982, proc'essing of the SMDR would have been using the same procedure as for the Nonconformance. Repcrt (NCR) and Deficiency Reports (DR). The case discussed here was dated
- June 4,1982 and the Revision 2 of the FACP & ence 1 did s not requi)re concurrence of i
the Home Office. The other case, NCR #2584,4was concerning concrete cover l over the reinforcing bars,hme being too lahsyme being too small. Similarly to cre e' the SMDR #357,it.was resolved in the field. In both The third casesanunofficialconcurrenceoftheHome)Officewasobtained. 6!PGreace 4. -
- case examined was RFI d593027A dated June 2, 1982 concerning discrep y l -
(& & b 4.-) - Y is m.
. betweenUE&CDwg.Fy01748gndCivesDwg.FP)5407-13 Sheet E-58 atA El s\6('
, M.
Another question on the same RFI was concerning discrepancy between UE&C t
~
_ _ _ _ _ _ . _ _ _ ~ - _ _ _ _ . _ . _ , , . _ _ . _ . . . _ . , . . _ . m.,. . . _ _ _ . . . - . , _ . . . _ _ . _ . _ . , _ ..m. . , - _ . - _ , , , _ _ .
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_~ de/re 4;8-/3 1 _. We ** } (ederace 4 , b
- Dwg.Fj01750gndCivesDwgFP-15407-13 4 ate 1.63{.6". In this case the disposition was provided by the Field Office.
i (gr_,, 4, ) Thelastcaseofas-builtsreviewedwasECA(5f809,gdeted ;,r ii Zo, 1 72 , concerning vertical bars in line 2.3 wall which caused a bar conjestion. . As required by AP-15, the ECA/RFI.Fors listed the affected document and Home Office concurrence was marked " accepted". l The program which UE&C has embarked upon in order to analyze and control as- ' e built conditions has a lot of good features. The controls documentation, distribution of responsibilities appear to be effective and. practical. It I is regretable that this program was enacted so late ir. the development of the plant. We are aware that in the early stages of construction of the
- plant the control of the as-built conditions was not sa good as could be desired. In the memorandum It is admitted by the UE&C (Arh v officialso w e 4.as)well. -
dated September 6,1983, M-14575A4 ere th is a statement "It is recognized o that there are a good number of historic ECAs which, based on the judgment l of the engineer at the time, were issued for which there may be no calculations." I The project has defined a program to address these historic ECAs and develop calculations for them as necessary"... We thin that this is a worthy effort which when completed will contribute to improve confidence in the level of l quality control of the plant. 4 8 se 4
,. _ , , . ,,m,, n en. p , , ,- , - . - . .n,., , . , , , . v. , , ,,,,n.n..,,. .. _w_,n_. ,_,..,,_,,l . , . _ , , , , - - , a . . - - ,-
_ ~ . : ;-. . . - - .a= . 4 .: ....a.. . . . _ . . . _. _ z . . . . - - - - ; - . .L f 8-14-f 6 To continue to review the process for controlling as-built conditions in reinforced concrete the team selected four Engineering Change Authorizations i j (ECA's)' dealing with coring and cutting of reinforcing steel. A series of four ECA's were selected in the Diesel Generator Building for review. hh, 4:- ) 4 (1) ECA 02/0772D 4 was initiated on (date initiated missing) by the UE&C Area Superintendent. The problem was defined to be an interference of service j air lines as installed with the fire wall partitions. The solution was. issued November 2,1982 and included cutting, capping and grouting the l existing penetration in the floor.at the 51'12" level, core boring two i 2" diameter holes, relcenting the air lines, air connectors and valves,
, deleting pipe supports and grouting the lines into cored holes. The affected
, documents were listed and the backup reference which permitted the cutting of reinforcing was provided. In addition, the requirements for recording and reporting the as-built condition were also provided.. This ECA had been properly reviewed by the Site Review Group and then by the home I office where final concurrence was made on May 18, 1983. The field
~
i personnel reported the work completed on November 16, 1982 and provided
, sketches and details of the cutting and the necessary engineering data.
- One core bore cut no reinforcing and the other cut one #6 bar.
l
~
l A < , <.- - -)
- (2) ECA 06/1670Byas initiated September 12, 1983 as an On-The-Spot ECA by theProjectManagerforGUS~. The core drilling was defined as being i
required in stair walls CAD to allow for installation of new redundant 4 i _ . . . _ _ _ _ _ . _ _ . - - . _ . _ , . _ _ _ - _ . . . . _ . . _ . - ~ .
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fire protection system lines. The request was made for (2)-6 inch diameter cores to be cut through a wall section around the stair-well near Elevation
.26'. Approval was given on October 18, 1983 after telephone concurrence with UE&C's home office and the completion of the actions by the Site' Review Group on October 17, 1983. It was further stipulated that one piece of reinforcing steel could be cut each way at each face for each core location.
In addition, sheets and instructions were provided so that the as-built work would be accomplished in accordance with AP-39 and specific information on actual cuts information would be fonvarded to engineering. The completed forms with the as-built information were completed on September 30, 1983 and received by UE&C Site Engineering on October 3
/ 1983, showed more reinforcing steel cut than allowed. All other aspects of the appropriate procedures had been followed based on the team's review of the information.
3 ($ & Ce k -=~~~~ (4) ECA 59/4010A3 was initiated December 9,1982 by an engineer from Perini Power. This requested authorization to cut rebar in order to install a Hilti bolt for a surface mounted plate on a floor at Elevation 511' due to the relocation of the' bolt to clear the reinforcing would violate l the centerline of bolt to an adjacent embedded plate distance criteria. l Permission was granted at the site on December 17, 1982 and home office concurrence was made on February 1,1983. This allowed cutting of one piece of reinforcing each way, top and bottom and required submittal of data via an attached form after the installation had been completed. y The as-built infonnation was submitted by Perini on May 20, 1983 indicating that 1-f7 bar was actually cut. ' A sketch was provided to establish the
. ... . : :7 -
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4 g -igs, j - J f exact location of the cut, identify the affected UE&C drawing and Bethlehem drawing as well as the bar type. No deficiencies were noted
- by 'the team. -
4 . I (F) ECA 73/4572C was initiated December 3,1982 by a field engineer from Pullman-Higgins.Thr*equested permission to cut reinforcing steel in an [ area near a blockout through a reinforced concrete wall due to the fact that numerous attempts to locate Hilti bolts among the congested rein , forcing had resulted in several abandoned holes. .A relocation of the plate for which the Hilti bolts were to anchor required a redesign of the support which was to be welded to the surface mounted plate. The ,i i
. (
change was completed, reviewed and finally approved on March 23, 1983. i The home office engineering concurrence was completed on. June 27, 1983. Again the field information as a result of the relocation and possible reinforcing steel cutting was requested for review via the coring / cut i reinforcing sheets. The information was provided to Site Engineering on , January 14, 1983 showing the necessary information and indicating that. kar 1-fl1 and 1-#8 reinforcing steel had been cut in the drilling process.
, The team found no discrepancies in the information.
l After completion of the review of the information contained in the records i
- related to these ECA's, the team went into the field to verify all information i
j that could be checked given the current completion status in each of the
- areas. Of particular concern was the information contained in ECA Oh670B
! whichindicatedmorereinforcingthanpermittedhadbeencut.and-76eresolution ! ju esf /godre mns;q j of this was sportant in judg4eg4the actions on the part of UE&C in response i
- . _ , . _ ~ _ , _ . . _ . . _ . _ - - . _ _ , , - - _ . _ _ _ , _
_ . _ . _ _ _ _ . _ _ . - _ , _ . . , _ , . . . _ _ . . _ , , _ , _ _ . - - . ~ . . -
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1 48-/6 o . 4 1 to the data. All locations associated with these ECA's were reviewed in detail, checking dimensions and where possible the insite cut surface if a core were involved except for ECA Sf010A for which the drilled anchor bolt was sandwiched i between panels of fire stop walls at the floor line. f All as-built information which had been sent back to the UE&C Civil / Mechanical 4 Services Engineering Group was field checked and found to be correct. The [ team then followed up to determine that the information provided was being i, systematically recorded and utilized. During this field review questions ) arose on the status of, and apparent incorrect fabrication of support 9276-12G-38whichwasassociatedwith.ECA7f572C. After a review of field L[ b records and discussions it was found the support was onlold"and the support _ ut reid cv>ne . was known to be incomplete. The incomingtElata from the as-built sheets were being logged and then transferred onto reproducibles created from the Bethlehem i
- shop drawings for reinforcing steel so that a permanent, consolidated record i of cut reinforcing is being developed. A review of the infonnation relative l to the team's concr.rn about additional cut reinforcing resulted in establishing that the cutting permission had not been exceeded.h thetThe detailed shop j drawings indicaced the coring was'done in a splice zone and that the pairs of
- cut reinforcing seen in the as-built data represented actually*one bar, but
~
sincethecutwasinthesplkzone,bothlegshadbeencut. Similarly, from theMailedspdrawingsandinformationsubmittedinECA 73/4572C it was l clear that several of the cuts were the ends of supplementary diagonal reinforcing i e ( ! at the corners of the wall blockout for air ducts. The information gathered- l l . in this program can be utilized to compare against known margins of reinforcing l 1 i steel. Where the margins are not sufficient, the procedures require added : l analysis. l
. l
_-_- __ _ - . _ - .__ __ _--.~._- . . _ - - . _ _ _ , _ . _ . _ . _ . .. . . _ _ _ _ _ - . _ . - - _
!!/7/t(
. 4.8-r7 Based on the team's review of t.he control of cut reinforcing, it was determined that this activity is well controlled by procedures and the appropriate inter-
; faces ha've been established and function checks gainst known margins to verify that the original design has not been compro.tised are made and the necessary documentation has been provided. The Technical Assistance Group under the Lead Civil Engineer of Site Engineering was determined to be executing this operation in a very well controlled manner. No findings were identified. ,
i
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7......---- . .. .... .. FIEF.D A5-4Utt.T FIDW OtART . .
, Piping and Ffpe Support As-autit Documence free Centreeters /e As-Guilt Dectmente ,
e
, #" * '. Piping sad F upport As-Suilta 2 Sepise & 6 Prints 2 Sepiae & 6 Printe n o DCC Sende on. (1) print to roepenaufe Site Engineering D.emipline t Aa-Built Coerdinacer , ..
for evaluetten V
- Responsible site Em61neer Discipline As-Built Coordinator evaluatse embaittal, marks traneetttal
" Acceptable" or "Not .
" Acceptable". identifies problems on any prince not g eag , and returae to e
~f *
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~
hV__ Documente Documents . Acceptable Not Aetestable Centractere & Discipline As-Seilt Caerdinatey 1 Sepia 1 Marked print verify correctises. If 6 Printe sent to acceptable, coordinator sent to Meme Centreeter . states en treesmittal
. nfftee sad ititials it.
If M CE 30ft: Beme Office to CONTRACfCR contact $1te Engineering 8* *' Ae-Guilt Caerdinator if Correece merkings le
, g ,
, - "'" **Y 9"*** ****' **** *
- esties Dieciplias.
en Centracter desumente, and resubmits to - Field DCC. I l e This step may be soitted as reeubetttate if Discipitas As-tuilt Coordinator has alreadr 4* ** kT / reviewed and accepted enemstaal. , C l i
- r. .
/ls/g+
l 2 Document Name: SECTION 4.9 - SEABROOK IDI Requestor's ID: . EILEEN Author's Name: R. Shewmak'r e 1-Document Comments: Conclusions . t 4 1 s 1 4 + \ 4 . 5 J r e i i b I k
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4.9 Conclusions k1 /,.....-~) !$9Aof(y)UE&Chasprovidedtechnicalguidelinesandprocedurestob i f p?j Seabrook Project. f.e #. Extensive programs have been put into force in order to l
/ .nsure that the latest and most accurate information is used in the design f f.S ,
structural members. Great efforts have been made in order to obtain e refinements in the vertical ampliciation .of beams for the design of the beams *
- f themselves as 'well as seismic qualification of equipment located away from W
the walls and columns. This refinement results in greater vertical accelera-l tions than would be the case if the beams were assumed to be rigid. i However, UE&C did not account for horizontal torsional effects in the develop-
- (' _ '
ment of ARS. represeM +4e 4%',w/e/div In the case of the PAB, the indications were that 10% for4 locations
- j. at the , extreme periphery. Normal practice for UE&C was development of the I
! r j ARS ,and the mass center. If the torsional effect is only around 10%,'the team ! is of the opinion that it can be neglected. : i i i j Since the team recommends that the Tank Farm dynamic analysis be redone, the j team would recommend that additional attention be paid to torsional effects i j inasmuch as the Tank Farm has little structural symetrf. i f ! Organizationally, the SAG appears to be quite remote from the Seabrook Project, t l and operates in a passive mode. In other words, SAG will be responsible to t I respond to requests from the project but not to take initiative on changes in the structural design which may develop. There should be some mechanism whereby j the SAG will have an oppo,rtunity of making an assessment concerning as-built
+h s r- z conditions rather than leaving these assessments entirely to the project.
In the case of the Tank Farm, the design of the bracing took place five years ago and 'the fill. concrete under the RWST. and SAT was released for construction about four years ago. Up until the time of the IDI these changes which have a direct influence on the dynamic analysis were not acted upon and were unknown to SAG. SAG also does not appear to be subject to the technical audits required by erene GEOP-0025(Refg1.52). The team recomends that SAG also be subject to technical review. The s cou!cl be, compleled h Nhntal pe%oeI who did ecL clo %e enfnal Yot~k. ( From the work observed, it appears that UE&C is conscientious and businesslike
~
\
in the design of safety related structures and has established procedures, guidelines and organization to meet the requirements of NRC. While many of the programs have not been completed and some analyses and designs must be revised, there is no reasons to believe that the as built structure's will be found to be inadequate in light of the exhaustive design efforts currently underway and planned for the immediate future. l 4
, _-.- -. 7 .
, Document Name: /l## d SECTION 4.9 - SEABROOK IDI
- - Requestor'.s ID
- EILEEN Author's Name: , R. Shewmaker Document Comments:
Conclusions-I t l l s 'l 4 4 . o k i i
l M-/ l 4.9 Conclusions The scope and the depth of the inspection was sufficient to r.each certain conclusions regarding the design and engineering aspects of the civil-structural discipline and the related safety features of the Seabrook iplant. Based on the facts, fin reviewed correspondenceped other information acquired nd ke2 during this inspecti*ong+e concluded that design and construction of the safety a,.e. .na 4 related features pertinent to the civil-structural area incorporate g / design wk, ch s!l assse ^ , control process te provideradequate safety to the public. Our inspection encompassed both the technical design and the procedural aspects of the b organizations involved in the development of the plant in order to have a broad perspective of all elements of the design and interdisciplinary coordina-1 tion effort. 1 As a result of the inspection we identified twenty-one findings and ob-
- servations. All of our findings have been discussed with the staff' of th.
h u 6een M en and we have been infor:ned that the appropriate' action g to ascertain that e.;res~ s%ces there will be no-consequencasz which might result in unacceptable margins of safety.has been tden. Finding No. which appears to reflect on the across the board applied approach to application of live load in combination with other loads may require further investigation to assure that the , structural members have load resisting capability in accordance with the i approved regulatory requirements. s There are certain conclusions which appear to be quite obvious as a result of
'e inspection. In our opinion, interdisciplinary coordination of the design
'drofy- ,
I f9-2 q. k effort suffers from the excessive systematization in terms of procedures and manuals. There is an eviden8e effort to document every phase of design, construction, procurement and verification. This is very plausible and has k its merits. The systera of traceability, however, is handicapped by such a number of various steps and is so fragmented that it requires a monumental 0( 4 1 i task to synchronize it in order to produce practical results. This is '( augmented by continuous revisions of various documents which in turn d necessitates u -cA~i updating,of canonp+e/ m mganca.+ all relevant),rocedures s Lroper cross-referencingcs ,-r; p-so that would be effedtive. An example of the above -^y be ^P-38, S::tica 3.1, Rs.1, dated-July-31, 1901, which refers to $ite Approved Change @ which has been discontinued (see Observation 4. ). i
.UE&C has provided technical guidelines and procedures to be followed the Seabrook Project. Extensive programs have been put into force in order to ensure that the latest and most accurate information is used in the design
- of structural members. Great efforts have been made in order to obtain refinements in the vertical ampi ation of beams fdr the design of the beams themselves as well as seismic qualification of equipment located away from the walls and columns. This refinement results in greater vertical accelera-tions than would be the case if the beams were assumed to be rigid.
However, bE& did not account for horizontal torsional effects in the develop-
-Me .r ~o t ed rewonce :rfedw. Pr*m k.1 M % k t MJ J mentofpRS. In the case of the fag, the indications were that 10% f% repre-sented the torsional effec ocations at the extreme periphery. Normal practice for@?iwas development of the@at the mass center. If the torsional effect is only around 10%, the team is of the opinion that it can be neglected.
. -. ~ - - . - ,
'/2*/74 j 9:9-7 I k seismic Since the team recommends that the Tank Farm trynamic analysis be redone, the team would reconinend that additional attention be paid to torsional effects inasmuch' as thekank harm has little structural symmetry.
1 Another observation is the apparent compartmentalization of the organization. We realize that the complexity and magnitude of the project necessitates multi-directional effort, but thers must be a definite gravitation toward an overview of the entire operation in order to achieve a practical efficiency.. 15 An example of this conclusion rey be the case of misuse of the amplified response spectra for the annulaT- ehfr mN5 described 4- Sect hn A { gf ; jg 7g upg. i,, en f As we pointed out previously, establish 1219. of the position of coordination of seismic design improved this situation. Organizationally, the(S[ appears to be quite remote from the Seabrook Project, and operates in a passive mode. In other words,hb will be cesponsible to respond to requests from the project but not to take initiative on ' changes in the structural design which may develop. 4. The program of as-builts and the final load verification, which we reviewed, appears to be effective and provides adequate design controls. As it has Me - es-ka0 been pointed out in4k tie. 4.3 Of th h report, the4 program should be extended to incorporate the engineering change authorizations which have been issued prior to the comencement of the program. There should be some mechanism whereby thehwill have an opportunity of making an assessment concerning as-built conditions rather than leaving these assessments entirely to the project. In the case of thehankharm, the design of the bracing took place
. //20,/?+
. 49-4
& dn hsbrafe TN five years ago and the fill concrete und r the ST and SAhas released for Up until the time76 F ., a G W ve fa wi construction about four years ago. the aat tnese enanges s
Mpee,% which have a direct influence on the dynamic analysis were not acted upon and n, were unknown to (AG'. He S o to t technical audits required by ~ 4 = e w d N'SgC also st n , iw ' we Eryineersj'Geneer/ fny01ees,Ay wm
'(G, EDP-0 Q(ssnotaLeartobesub Ref er'e%ce9.'If) . eamrecommendsthathalsobesubjectto -
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- technical review. This could be completed by technical personnel who did not do the original work.
From the work observed, it appears that@)is conscientious and businesslike in the design of safety related structures and has established procedures, guidelines and organization to meet the requirements of NRC. While many of the programs have not been completed and some analyses and designs must be revised, there is no reasons to believe that the as built structures will be found to be inadequate in light of the exhaustive design efforts currently underway and planned for the immediate future. In final sumary, it is our opinion, that there is sufficient evidence that in civil-structural area the des'ign controls are effective to the extent that they provide a reasonable assurance that the safety related structures will have their expected load resisting capability and will perform their design function without undue risk to public safety.
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7.4.2 Personnel Interviewed flame Title Organization Tom M. Cizauskas Mechanical Lead Engineer YAEC - Seabrook Project (for Civil / Structural aTd'####b 'ce.' 6~., Mechanical Engineering Departmen Engineerin(t~5 , Henry E. Wingate Assistant Project Manager, YAEC - Seabrook Project Construction Department S;;;crei:cr- . Jerome J. Wojcik Structural Engineer, YAEC - Seabrook Project Mechanical Group, Engineering Department Robert Tucker Lead Mechanical Engineer YAEC - Seabrook Project (Cisil-Structurcl}- Mechanical Group, Engineering Department (,DonalcE. Johnson Structural Engineer YAEC - Seabrook Project Mechanical Group Engineering Department Walter K. Perterson Supervisor, Engineering /QA YAEC - QA Department Audits R. E. Guillette Supervisor, Construction YAEC - QA Department Quality Assurance Engineering Janet Allen QA Technician YAEC - QA Department M. H. Ossing Staff Engineer for Assistant YAEC - Seabrook Project Project Engineer of Construction K. M. Kalawadia UE&C - Seabrook Projec.t ((DisciplineEngineerjE cturah W Supervising Jural D. E. Garrigan Manager, Project QA for UE&C - Reliability Seabrook and QA Department V. D. Patel General Design Supervisor UE&C - Seabrook Project. . y , % -d g f0-=eJrTeI.j.2 ", J. K. Cravens Manager UE&C - Seabrook Project ( .. Engineering Project Controls
is/rv/tr 7.4. z - z l Name Titie Organization J.5Connelly Supervisor UE&C - Seabrook Project 0 Calculation Control Center (1 of 5)
- h. P. Sivertsen Leader / Liaison SCAT Team UE&C - Seabrook Project Cognizant Engineer Beam Verification Program and SCAT Team l Jc#Blackman Assistant ManagerJAG UE8C - Power Department, 1 A Mechanical Analysis Group E. Skdnick Lead Engineer, EQ/ COMP UE&C - Power Department.
Qualification Mec@nicalAnalys1.sGroup LC' S. NasciWmento Chief Structural Engineer UE&C - Power Division Anil T. Shah Cognizant Engineer UEAC - Seabrook Project Structural, Major Cat I D. K. Ghosh Cognizant Engineer UE&C - Seabrook Project Structural, Containment rl Pares,Datta Design Supervisor, UEAC - Seabrook Project Engineer II Structural 4 John,Mott Design Engineer UE8C - Seabrook Project Structural Om P. Kalani Weder-Stru tural Supervising UE&C - Se'abrook Project Engineer "enegry Pipe Support Group H. Richard Toland Manager UE&C - Structural Department A Structural Analysis Group c. Noshir,Karanjia Seismic Consultant UE&C - Structural Department Structural Analysis Group K. Dipak Majumder Lead Engineer UE&C - Structural Department A Structural Analysis Group Branko Galunic Engineer I UE&C - Structural Department Structural Analysis Group Z.$ 4 01szewski Mechanical Supervising UESC'- Mechanical Disciplin ngineer Analysis Group i < l M. K. Sanghavi Lead Pip Support Engineer UEAC - Seabrook Pro' ject l Pipe Support Group l l
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- 7. c. 2 3 Name Titie Organization
- c. .
Girish Hatwal Structural Engineer UE&C - Seabrook Project Structural l Amardalawari Engineer II UE&C - Seabrook Project Pipe Supports Duct Supports Thomas F. Clouser Design Supervisor UE&C - Seabrook Project Pipe Supports HVAC Supports J.Alberto.Rios Engineer III UE&C - Seabrook Project I&C l i Al W. Cole Project Administrator UE&C - Seabrook Project Project Controls R ivingston Administrator UE&C - Document Control l Center - Seabrook Project -
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Bob.Bosshardt Administrator !!!, UE&C - Document Control
. Lead, Records Control Group Center - Seabrook Project D. Helitz Supervising Structural UE&C - Document Centrol Engineer Center, Seabrook Project G. G.
.aud.Christina Administrator UE&C un . ..Seabrook Project
? v .. .. g r a- :; ,.;.,.;. Dexter Olsson Senior Metallurgical Engineer Bethlehem' Steel' Corporate QA Manager Corporation Michael Bedics Supervisor, Quality Assurance . Bethlehem Steel Reinforcing Bars, Piling and Corporation Construction Specialty Sales Clarence Redman Contract Administrator Bethlehem Steel Reinforcing Bars, Piling and Corporation Construction Specialty Sales Dennis Reid Chief Detailer - Engineering Bethlehem Steel Corporation Denny Vassa Detailer -~ Engineering Bethlehem Steel Corporation ' L
. N. Desai Engineer ! - Structural UE&C - Field Change Completion Group
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Name Title Organization Rick E. Daniels Cognizant Eng'ineer for UE8C - Beam Verifica-y Program Guidelines tion Program i Rf'I.,(86b)Kuelin Engineering Manager UE&C - Field Systems GroupdTte tngineering?
,,,Jes V 0 4 'G. (Ocug) McClellan Lead Engineer - Civil / UE&C - Civil / Mechanical Structural ServicesQing, Engineer RY'A.,(Dick.)Arell Designer UEAC - Technical Assis-tance Group
. Civil / Structural Engrg.
Civil / Mech. Servic'es Site Engineering C. E. Morales Draftsman UE&C - Technical Assis-tance Group , Civil / Structural Engrg. Civil / Mech. Services ( . Site Engineering , lY R. P. Kosian Lead Field Engineer UE&C - Project Field
'i Engineering Group Civil / Structural Engrg. !
Civil / Mech. Services S. N. Ujed-)' Caruso Lead Engineer UE&C - Ca,ble Tray Bracing Task Group i Site Technical Staff Piping & Supports. Site Engineering JulieDrofd Seismic Analyst UE&C - Structural Analysis Group John Alle ' Structural Engineer UE&C - Structural Analysis Grnup SusanH/yecki Field Engineer - Civil / UE&C - Project Field
, Structural Engineering Group Civil / Structural Engrg.
Civil / Mech. Services Site Engrg. Robert Shappell Civil / Structural Engineer UE&C - Technical.Assis-tance Group Civil / Structural Engrg. Civil / Mech. Services Site Engrg.
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Name Title , Organization l J. R. Lindguist Field Engineer - I&C UE&C - Project Field Engineering Group I AC - I&C Systems Site Engineering l P A e u. Construction Superintendent UE8C ,Censtruction Frankf'adabo Painting Subcontracts Colin H. Coles Design Engineer 4'2 2. UE&C - Seabrook Project
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Document Name: 1
. SECTION 4 - SEABROOK IDI Requestor's ID:
EILEEN Author's Name: R. Shewmaker Document Coments: Civil and Structural O 9 0 i 6M e. m II g e S
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- 4. CIVIL AND STRUCTURAL The ' objectives of this portion of the integrated design inspection were to evaluate the civil and structural engineering practices and technical execution si d uedesMn desivi ,
of the design with specific emphasis upon3controlgand exchange of3 information t within the project. The team inspected areas defining whether:
. (1) tRegulatory requirements and design bases as specified in the license application have been correctly translated and satisfied as part of specifications, drawings, and procedures, (2) 4 Correct design information has been provided both internally and externally to the responsible design organizations including selected off-site subcontractors, (3)4Designengineershadsufficienttechnicalguidancetoperform' assigned engineering evaluations,an/
(4) 4 Design controls, as applied to the original design, have also been applied to design changes, including field changes. l . i-. ... .
.J-~ - _ .
These objectives were accomplished by selecting'a sample of structural elements which make up the building structures or are supporting mechanical, electrical, and instrumentation and control systems being reviewed by team members in those was specific disciplines. This sampling $Fgused to assess the interdisciplinah interface design control exercised on the Seabrook 1 project.
. . _ - _ . . . . . . . . . ..__. ... ._. _ . . . ._.s.. . . . . . . __ .
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. Document Name: l SECTION 4.1 - SEABROOK IDI Requestor's ID:
EILEEN Author's Name: - R. Shewnake.r Document Comments: Design Information P f 4-2 0 9 -t F s-y 0 9-7 G +-/2 C +-,g
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, Pesif The objective ~ of this portion of the inspection was to determine, on the basis and me%ds e-G desiga of the material reviewed, if the . thedq the procedures 4and the design controls which have been used in the Seabrook project, reflect the requirements of NRC regulations, such as General Design Criteria, Regulatory Guides, Standard ceLeeereseed inclus++y Review Plan and othergcodes and standards. N rthe. w e, hevir.g detc H ned
%ed on a and f(the degree of consistency between the rules and regulations en cae M d i the actual practice by the applicant and his agents, sa thm eth;r, a determina-E tion could be made,0f'the levels quality assurance and quality control are acceptable. i ), '
T_.- , Pursuing this goal, the team reviewed the organizational structure of the Public Service Company of New Hampshire (PSNH), the design and construction effort delegated to its agent, the Yankee Atomic Electric Company (YAEC) and i the execution of.the design by the architect-engineer for the Seabrook plant, , 0 United Engineers and Constructors (UE&C). Particular attention was i i i the interfacing between various organizations such as YAEC and UE&C and their be c E ^6<**A N# # E " subcontractors.o~-{/c.[dhg
-the-j Ingcivil/ structural discipline, the applicant comitted to comply with the NRC rules and regulations, the General Design Criteria, Regulatory Guides, Standard Review Plan (NUREG-0800) and other documents as well as' the appropriate
-commercial codes and standards. The basic document used in design of the
'Dr.
l containmentstructureistheASMEBoilerandPressureVesselCodeSectionp, l r l
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41-e - j l l Division 2, Code for Concrete Reactor Vessels and Containments (Winter 1975 ; Addenda for containment liner; Winter 1976 Addenda for reinforced concrete),
$ hereinafter referred to as the ASME Code. For other reinforced concrete structures, the ACI-318-71, Building Code Requirements for Reinforced Concrete (with Commentary) was used. Steel structures have been designed in accordance
~
with the AISC, Specification for the Design, Fabrication and Erection of Structural Steel for Buildings,1969 $dition (including supplements 1, 2 and rewer w eds 3). For Df quality contwa the g applicant committed to use ANSI N45.2-1974, Quality Assurance Program Requirements for Nuclear Power Plants. The Final Safety Evaluation Report (FSAR) included all of the pertinent Regulatory Guides z :: rdrer.a: & de vmous com ~ b e d L.7 g 4 > The organization of the Seabrook project in place at the time of the inspection is h illustrated on Figure 1. The Executive Vice President of the PSNH is responsible for all executive functions of the project. He reports directly . to the president of the company. gVice President, Seabrook,-(VPS), reports directly to the Executive VP and is in charge of all management functions, j Both the Executive Vice President and the Vice President, Seabrook are from , the PSNH. Working directly under the VPS are: Director of-Quality Assurance; Manager, . Start-up' Testing; Director of Construction; and Project Manager. I These four positions are staffed by the YAEC. There are three. additional l- , positions: the Manager Construction Support and the Construction Manager i (b'oth of them are from the PSNH) and Vice President of UE&C: responsible for projeef unsn %g 4 35 / 6*** l design and construction managemeqt. The YAEC eng.nierirg groupAreports to the l l subdMoed ='sto hu r- 1rooPS he*M bc3 project manager and it is he:ded bygthe fol?owing -feve positions: . i
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. a. Assistant project manager of construction j I
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- b. Engineering manager ;
i 4 9
- c. Senior project engineer 1 4
- d. Assistant project manager (licensing and operation)
The Engineering Manager has four lead engineers reporting to him:
- a. Systems Lead Engineer
- b. Mechanical Lead Engineer
- c. Instrumentation and Controls Lead Engineer .
- d. Electrical Lead Engineer There are five engineers in the r..echanical engineering discipline; three of theni N are civil / structural and two mechanical.
m We interviewed the th'ree engineers who are working in the civil / structural area.- We found that all of them are. graduate engineers, of them have master degree in civil or structural engineering. of them are registered . professional engineers. Their experience range from seven years to nine l f with most of it in structural engineering related to nuclear plants. During I 4
- s
afr -fr3 c/-4 the interviews they demonstrated generally good knowledge of their profession, I I but their familiarity with NRC rules and regulations was somewhat less than I would be expected. There was no evidence that YAEC provides any training in
\'
this area or encourages an improvement of their knowledge of the current kc. I regulatory positions. f l The entire staff working for the project manager consists of 35 professionals. j i
\
j The professional cross section of the civil / structural staff of the YAEC } l employed at the Seabrook Project is included in Table 4-1 which provides data j for a representative cross-section of civil-structural engineers working on I 1 the Seabrook. project. e j
/
_ h. I. 5 o In our inspection, considerable attention was given to the interfacing between perrea : m ens different 'offteQwithin'the YAEC organization as well as between the organiza-tions involved, namely YAEC and the UE&C and/or PSNH. It appears that the communication between the UE&C and the YAEC is maintained through the UE&C
? uie:L r. >. n e r. :%jeef VM er The YAEC PDF BM{who communicates directly with his counterpart of the YAEC.
reports to the VP of Seabrook project who is on the staff to the utility company, the PSNH. The lines of communication are depicted on Figure 1.
~
The inspection team evaluated the documentation of design controls which is n-4 used by the YAEC as the basis for the demonstration of design control exercised ug%, by YAEC and PSNH over the designacK:, oqani-EMon h Me %ed.
~._.
A review of an audit report conducted by the PSNH on July 26,19f3 at the UE&C offices, Philade,lphia, Pennsylvania was conducted. The purpose of this audit, conducted in accordance with the requirements of Yankee QC&A Procedure WQ-115,
re/r7/r.s 4/-5 1
. paragraphs III.A.1 through 8, was mainly to verify disposition of the open items of the' previous two internal audits. The report discussed three items
' identified in the previous audit, conducted on May 15, I hich hay ( not were -foosd da ns fLe <Fth$
been satisfactorily resolved. No new open items h:v: b :n f:=d n e e-s 4 sA subsequent letter, dated August 30,197FUE&C discussed the proposed resolution 7Ae Z P Z .Jem ood o' of the items covered in the subject audit report. " Ob:erfatf er S:: 5::: made that the referencing of the staff in the audit report has not been made na me 7Ke /ese by full or by their title,name but by their initials alone. .Wp found that such identification of personnel makes g extremely difficult or even impossible 9 1 b /A' N N
- i" [ 9 '$
to trace down the people involved. I M "' i
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-_ y i .. The principal documents providing for the implementation of all quality !
i*' Jer />(e %videe organi2. aron ,% assurance aspects of the Seabrook plantgare the Project P611cies and the g: SeabrookQualityAssurance(Q/AManual).kTheQ/AManualestablishe procedures for the interval and external quality controls of the YAEC such as h I j-the scope and frequency of the audits, interface controls, provides' guidelines jo l.s; for the review 'of specific categories of documents, etc./ Project Policies f provide guidelines for implementation of the specific phases of the quality h assurance. system and describe processing of documents such as the Engineering
' Review Reports (ERR's), filing of documents, handling of engineering documents /
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- Both3 Project PJicies and the Q/A Manual are under the direct responsibility ~ i of the Project Manager (.PM). The PM is responsible to assure that both the-Project Policies and the Q/A Manual are in agreement. In case of a conflict between these two documents the Q/A Manual takes precedence. The Project i-
R /274.7
+/-c Policies are reviewed and updated periodically to reflect the current modes of operation and design.
receiving .2 n enyneWafre"'N f.%se rce . Specifications are the documents develcped for specific tasks involved in hO '
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l design of the Seabrook plant. They ar i developed by the UE&C and forwarded i
.dso pr.+> y l to the YAEC PM for review and approva1 4 They are4 reviewed on pre-selected r .
[ basis by the Quality Assurance Department (QAD) of the YAEC and the document f resulting from' the review is called Engineering Review Report (ERR). The { i ERR's are filed withthe
%dee or:fxieaifen taEG in a teparate filing system.
t i Cn c e .= yp ce,5 2,s.cn il2S bee., cG ve/o,oe/Q muiss.) u.4. ,opre.gec{
\ T6e UE&C provides YAEC with the list of the prospective bidders and recommends
\ d'cr oeasos& .aec re=e;vel those bidders who appear to be technically acceptable. YAEC selects the winning bidder from the list provided by the UE&C, usually on the basis of
! the lowest price. 'T5Ithority of approval of the specifications is with N
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\,thIProjectManager. Specifications are updated when there is a change in \
l the purchase order and their change require review and approval of YAEC. In , order to assure that the specifications are up to date, YAEC conducts .- f i i
\ interdisciplinary meetings which are, on the average, every two weeks.
's Following are our specific comments resulting from review of'some of the documents provided by the YAEC staff.
), \ }
Q/A Procedure 3.3 " Review Procedure" Rev. 8 - Date 3/30/79 The Procedure provides guidelines for the review of specific categories of documents. Specifically the documents covered by this procedure are: l l
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Engineering Specifications, Engineering drawings, purchase documents and j QA/QC Program, Manual and Procedures. l The documents to be reviewed by p YAEC are developed by the agents, such as UE&C or subcontractors a1d submitted to YAEC Project Office for review. The . Project Office is responsible to establish the appropriate reviewer (s). ' Review of Project Policy #1 (PP-1) reveals that the reviewer is " determined by Section 3.0 of the Seabrook-Station Q/A Manual and Subsection 17.1 of the Seabrook SAR. i i When Q/A Manual Section 3.0 was reviewed the criteria for selection of a
- reviewer could not be found which is a discrepancy from PP-1.
The Procedure is vague in the area of resolution of conflicting comments i originated by the reviewers. The only statement that could be found is that if the disagreement could not be settled amongst the reviewers it is referred to the higher management. There are no specific steps or the responsibility . to be taken to obtain a satisfactory resolution. The Procedure contains specific guidelines (provided in the Appendices) for j preparation of the review of the documents covered by the Procedure.. 4 g { United Engineers and Constructors, Inc. (UE&C) is organized into several t,$ i operating divisions with the nuclear pear work .in the United States being perfon.ad in the Power Division under the direction of'a Vice President. .bne of the managers reporting to hip h the Manager of Power Engineering. Power , l L 1
. . . . .~ . _ - - . _ . __ ._ . . _ . _ _ .
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4/- r lh Engineering is then subdivided by four technical disciplines each with a chief l engineer as the technical leader for a given discipline. UE&C defines four specific disciplines: structural, electrical, instrumentation and control and l power. The-first three are self-explanatory whereas the fourth requires some l t explanation. IncludedwiththeChiefyEngineerofPower'sgrouparethe technical disciplines of power systems, piping engineering, process engineering, mechanical engineering, nuclear engineering and fluid / hydraulic engineering. ' The engineering personnel involved on a given project such as -the Seabrook Project all report technically to'one of these four discipline chief engineers. Some may serve on a specialist staff,or in a special group under the chief engineer of that discipline supporting a project. While others may be within , the project group under a supervising discipline engineer or other engineering supervisor who reports to a project engineering manager. The staff groups and , personnel become involved in project work only at the request of the project j engineering personnel. Based on the team's information this concept has been rather constant within the firm for a number of years. The Seabrook Project functions within this framework in the following manner. The Project Manager apparently reports to the Vice President of the Power Division, just as does the Manager of Power Engineering. In the course of the Seabrook Project there have been numerous changes in the functional organization for the project.as well as changes in personnel. The teari found some in tracing , the organizational changes as well as how responsibilities shifted and were transferred from one group or individual to another. Documentation was obtained in the organizational area, to indicate the overall project organi-J
- zation since 1976. Numerous changes were implemented about the time the team's
.. . :.c 3: . . . . ;: .- .
=-
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'hW2f 4.1-9 lb l effort began, adding another change to the list. The team found that the f organizational charts obtained in the background study in October were even I out of date by the beginning of November when the IDI team begany N N /'*d*"*
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Reporting directly to the Project Manager until sometime after March of 1981 was the Project Engineering Manager. There also existed at least one Assistant Project Engineering Manager. The Supervising Structural Engineer, called a L ' i supervising discipline engineer (SDE), reported through an assistant project engineer to the Project Engineering Manager. The SDE for structural was , the same individual from the beginning of the project until August of 1982
- when his assistant became the SDE. During the period of heavy involvement in design for the basic structures the structural group in projects was aligned by structure in that the Containment.Shell, for example, had a designated Cognizant Engineer as the lead structural design engineer for that building.
A significant number of engineers were assigned in these building groups. i
; As that phase of the project drew to a close the structural personnel have also been formed into specific task oriented efforts such as the Beam Verification
- Program. The Cognizant Engineers assigned by building still exist, but have smaller groups and may also now have responsibilities for several buildings.
j Another change that grew over the life of the design evolution'was the ! importance of site related engineering effort Up through March of 1981 there was a liaison { Engineer assigned to the field to perform the site liaison to the home office engineering organization. That function was performed under the supervision of the one Project Engineering Manager for Seabrook. In March of.1981 a separate organization was created under the direction of the Project Engineering Manager (Site) as opposed to the previous . t 4
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1 7 i 1 position under the Project Engineering Manager for the Project. By January of 1983 four separate Project Engineering Managers positions were in existence in the home office with some 1100 personnel in the groups. Additionally, nearly another 1000 were at the site under the control of the Project Engineering Manager for Site Engineering. No less than six different groups
- exist working in the structural discipline in different chains of command with three at the sith and in the home office. A separate structural. group has been set up in the ome office in the Lite Support Engineering Group to interface-with the field Site Engineering grour so as to minimize impacts on the project Structural group. The implicatione, of this organization will be mentioned later in the report in addressi ig interfaces for design.
The team also spent considerable time, out of necessity, in order to try to - understand the hierarchy of the multitude of in-house procedures utilized by UE&C so that a proper assessment of what was being done in the project's ..,, design and the control of the design process could be made. Figure 4. presents an overall view of the hierarchy that exists for the Seabrook Project with regard to home office engineering and design. In actuality, 4 to 6 layers of documents and procedures precede what might be considered to be an engineering calculation. This is some what further complicated by the fact that in many specific areas, different staff groups have developed and use i modified procedures where latitude exists under a more general parent procedure. The result is a great deal of variation in documents when one begins to review, for exairple, calculation packages and the associated control sheets.
. . . - . - . - - . . . . . . . . . . .. ~. . . . . - . - . . .. . ..
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\e2 As a result of the team's review of the various project documents, such as the f Project Manua1 of Procedures, the General Engin'eering and Design Procedures, y
several findings and observations were made. The team first reviewed QA-3 y ypdromtheQAManualwhich\stheUE&Ccorporateleveldocumentwhichaddresses 6 the regulatory requirementsy - - - 9 9 e f I f 1-
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6 Document Name: a SECTION 4.2 - SEABROOK IDI Requestor's ID: c i EILEEN i Author's Name: i
-G. Harstead Document Comments:
t l Static and Dynamic Analyses t f /* 8 "Y ' r, d -17 4 V h iC~;
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r- h4 bddio 4.2 Stauu andDynamic.An81yses . ch. j',6 N.
/re objective of this portion of the-inspection was to examine the adequacy i p) g Y[4 and coordination of analysis, design, and the resulting floor response spectra
. . t, g, g for the Tank Farm Area which houses the Refueling Water Storage Tank (RWST) b and the Spray Additive Tank (SAT).
.sei sac 3f'\ .
The team also reviewed the interdisciplinary process leading to the4d esign of WA7 ; the attachments to the containment liner supporting) (geferenee 4. - ducts, pipes and electrical ' i equipment, Calculation No. CS-22,3as well as the calculations pertaining to the subject of the Tank Farm. The dynamic analyses of the Tank Farm was performed by the Structural Analysis-Group (SAG) in order to determine the seismic forces needed for the design of structural elements such as the structural steel beams and bracing and the reinforced concrete walls and slabs. This analysis also led to the development of amplified response spectra which were used for seismic qualificationY(of equipment,%analysisofpipingsystems,andfordesignofstructuralsteel beams. The Tank Farm Structure is essentially composed of a lower reinforced concrete
' box-like structure and an upper braced structural steel frame with a reinforced concrete roof slab and metal siding. The mathematical model consists of lumped
! _ masses connected by massless springs. This type of model 'is commonly referred ! to as a stick model. The calculations used for the~ development of the mathe-Wo. matical model are contained in UE&C Calculation SB 4 SAG-5WB (Reference 4.41). l
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f z- e r f, The stiffness of the structural steel frame was based entirely on a shear t 6)), 'I type response in that the nodes were in general restrained from rotation about the horizontal axes. The calculations of the area and the bending moment of (f/ 4 inertia were calculated consistent with the rotational constraints imposed on
. W." the model. While the combination of area and bending moment of inertia were consistent with overall shear stiffness, individually the properties were not consistent with the actual structure. The rotational constraints imposed also, in effect, eliminated overall bending from any consideration. This t approximation could result in a significant overestimation of the stiffness of the structural steel framing.
~
The stiffness of the reinforced concrete portion of the building was considered by UE&C as a combination of shear stiffness and overall bending stiffness. Therefore, instead of summing up the rectangular cross sectional area of walls oriented in the direction of intergest, UE&C considered each wall separately in determining the shear deformation. This shear deformation of each wall is composed of pure shear displacements as well as bening characterized as a guided cantilever with a moment of inertia based upon the rectangular , shape. The sum { of the shear stiffness of each wall is calculated, so that an area and a bending moment of inertia of the stick is determined consistent with the shear stiffness. The problem with this method is that if indeed both shear stiffness and overall bending stiffness were important, the method 7
-would underestimate the overall bending stiffness particularly since flange
! effects are not considered. UE&C made computer runs during the week of l Ade %e raspechon ward in-Proep-ess December 5,1983 which indicated that the model was not sensitive to errors in l 3 the moment of inertia. c f* h =& N, 4)),0 M f b5
+. 2 -3 9&c/e9
' In calculating the stiffness of the structural steel bracing, UE&C assumed that all X-bracing was composed of angles 4"x4"x3/4". In fact, the bracing hg consists of substantially larger members as indicated in UE&C Drawings 4ks F-111824:and F-111825 (Reference 4.32).
- k. -
. approx >dely hd 6P There is fill concrete under the Refueling Water Storage Tank and the Spray Additive Tank. A three inch gap is provided between the fill concrete including the mat and the south wall of the Primary Auxiliary Building (PAB) as shown on UE&C Drawing M F-111818 (Reference 4.32). A concrete curb is placed on the top surface of joint as shown in Detail 111819D0, UE&C Drawing 9 33+F111819 (Reference 4.32). This joint is shown along the east edge of the fill concrete only. A field visit indicated no differences with the requirements of the UE&C Drawings (Reference 4.32). The mathematical model No .
described in CalculationgB SAG-5WB (Reference 4.41) does not account for the stiffening effect of the fill concrete. The neglect of overall bending used in the development of the stiffness of the stick model were not approximations which significantly simplificd calculations,but which might be troublesome and therefore, must be independently justified. Personnel stated the Tank Farm mathematical model was unique and no other mathematical models were prepared in such a way. Additionally, it was stated that the usual practice of SAG is to prepare a static structural model and with the aid of a computer program, appropriate stiffness properties are calculated without the need for the approximations such as those used in the
,' //tw/r+
- 4. 2 -e Tank Farm model. The team had insufficient time to confirm that the Tank Farm Structure is an isolated case; however, the team has no reason to doubt the validity of that statement. Because of discrepancies between the assump-tions used in the development of the mathematical model and the actual Tank Farm Structure, new calculations and computer herequired. It is the skovM team's finding that the Tank Farm mathematical modelgbe recalculated incorporating effects of overall bending and the actual structural configuration (Finding 44 ).
1f4 % </~ A A 4 A W +- M ,3 The interfacing between different disciplines is illustrated by Figure .j 7,. It shows the major steps taken during the process and is self-explanatory. It j.s I should be pointed out that all transmittals of the amplified response spectra (ARS) from one discipline to another is taking place through the Coordinator of Seismic Design (CSD). We were informed that the introduction of this position as the focal point of coordination of interdisciplinary effort improved the design procedure in a great measure and has prevented the use of obsolete or ,
~
inapplicable results of seismic analyses. We found an instance bf i0lih~'a' s p.f;J y'
! iack of coordination in the past in case of use of results of the input to
'y f* ; rs.G sd ? ltheSHELLIcomputerprogram(Finding 4-7). The-sui > ject-of-seismic analysis l 7y, NiMe-discussed-Jater, in the -s e ction-de a l i ng- w i th-d e s i g n -o f-the-con ta-i nme n t . , , kue s[. f is basden FYo g[' The current system of control of seismic designnfellows tha a<iministrativa ;
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8s (fkme f .) preceduce AP-36, " Control of Seismic Design"4which was introd'uced in May of 1980 and appears to be effective. In the process of reviewing Calculation; 70 j Qekten ce 9: - ( aesel SAoA
*No.CS-22severalobservation)shavebeenmade.T(Observations 4.1,4.2and4.3). y ,,,g, p
here / In case of Observation 4.1, reversal of the horizontal leg of the angle could g i introduce an additional eccentricity, which would cause a torsional moment WJMC
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l in the plate and therafere increase in the stresses. We pursued our inspection further, and review of the shop drawing revealed that the detailer placed } the angle in question with the vertical leg at the center of the plate, thus eliminating any eccentricity which might take place due to the erroneous sketch on Sheet 98. Observations 4.2 and 4.3 have been brought to the attention of the design office as examples of lack of proper care in preparation of calculations and checking and would not have a major bearing on the adequacy 4*- of the design. -fo f 3 ,
- - ~
j We reviewed the basic assumptions of the seismic analysis of the containment structure from the point of view of the regulatory requirements and found them acceptable. The containment shell has been represented as a lumped mass (stick) model fixed at elevation -30 ft. The shell and the internals including polar crane have been uncoupled for the purpose of the final analysis ee-p S4 c,4
- BSAG-4CS T$ea~nalysi assumed that the liner is not a resisting structural
!, element, but its mass has been included in the lumped masses of the model. Since the shell is essentially axisymmetric, and its center of mass and center of rotation coincide, the torsion due to the geometry of the structure has notbeenconsidered.[T5e$ciiife'niai"torsionduetoseismicforceappliedat' an eccentricity of 5 percent of the mean diameter of the containment cylinder l was considered and its effect on the stresses of the rebars has been found l to be negligible (less than 2_ percent increase). We agreed with the considera-
.tions made for torsion. fo $tg.D In the case of the internal _ structures, they have been modeled as a series of concentrated weights, located at their respective centers of mass. These 1
L
$"/e4 42-6 i weight centers have been located at specific elevations, which in most cases is at the top of the respective slabs. The weights representing the slabs have been connected by weightless, elastic beams representing structural components between the elevations of the concentrated weights.
E 13)[od Since there are no existing earthquake records pertinent to the Seabrook site U #[ < fe the seismic input has been defined at the bedrock in form of the design G' spectra for the operating basis earthquake (0BE) and the safe shutdown earth- 9 quake (SSE) in compliance with Regulatory Guide 1.60. The duration of the YkV
" p.P } '
V earthquake is estimated at 10 to 15 seconds. The engineers responsible for the seismic analysis stated that all Category I structures are founded on sound bedrock or engineered backfill extending to the backfill. The engineered back-fill consists of either fill concrete, backfill concrete, offsite borrow tunnel 2 j cuttings or sound cement. Furthermore, the type of engineered backfill used under all seismic Category I structures is fill concrete, with an exception of safety-related electrical duct banks, electrical manholes and the service water pipes which were founded on off-site borrow or tunnel cuttings. Both the time history and the response spectrum analyses were performed for the OBE and the SSE conditions. The critical damping ratios used for the containment structure are those of 4 and 7 percent for the 0BE and for the SSE respectively. The structural ' response has been determined using the response spectrum modal analysis method. The total response of the structure was calculated by super-position of the responses of each mode by the square root of the sum of the squares (SRSS) method. l l
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! .We reviewed the process by which the basic data pertinent to the design of y '
A i gontainment have been gathered. In this connection we have noted that several
- - documents such as those pertaining to the design temperature and pressure, $(
! which in the opinion of team members should be controlled, have not been included j- in the Document Control Center (DCC) serial numbering system and could not be l easily retrieved. ~ This matter is described in more detail in Section . , i gi , . 'Furthennore, examination of the input for the SHELL- I computer program revealed S. . that the infonnation used was incorrectly referenced in the calculationA
~
l -The following is the result of our further inquiry in this matter. 4 i I. % ' i Seismic forces and moments as used on Sheets 30 through 35 in the Calculation ! (/e G erce + No. CS-15, dated 8/4/75,4were obtained from mo)dified seismic analysis i [ecupled del of the containment shell and critical daginhalues-l 4CS3 of 4% for OBE and 7% for SSE. The preliminary analysis, SBSAG-4CS3 was based
--f ;
on coupled model of the containment shell and critical damping values of 2% *N - j for OBE a 5% for SSE. SB, SAG-4CS3 has been superseded by the final seismic . e.1 synee l analysis G-4CS4 g using a decoupled model of the containment shell and critical damping vaYue*s of 4% for OBE and 7% for SSE , a /T7/ 4 ,,ffe ( l AlthoughcomparisonoftheSBpAG-4CS3andSBJAG-4CS4analysesshowsthattheir
- Spose Jo I
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.results are very similar'and that the seisl8c'* forces and moments used as input' g '
for the SHELL I program are conservative, we determined that this is'a violation AP of the ".t h et n tiva pencedure 22, " Calculations", Appendix Ap ":;. i, d:t;d (2dere.1ce 4.
-)
60s
~n L1/.194Z.4, and 10 CFR g Appendix B, Section III, " Design Control", dated 8/1/80 oor t N 'g/,// y(Finding S 4.7).
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N ! We reviewed the vario'us stages of the static analysis of the containment , setsute structure which utilize the results of the see44e analysis described above. Thecontainmentstructure(theshellandthedome)hasbeendesignedusing : several computer programs. Some of them such as LESCAL, WILSON I and WILSON Se&or .! II have been documented in the Final Safety Analysis Report (FSAR)4 There l were others, however, such as SHELL I and SHELL II which have not been included in the FSAR. This is in violation of the Regulatory Guide 1.70, Section 3.8.1.4, Revision 3, November 1978.apffithough we hdYeeinformed by the-ce ~ p.> ler- rM H .y
, UE&C personnel that the use of these codes.g s mQed,we noted it4as an ge
& h*f observation (Observation 4._).__ The axisymmetric analyses of the containment structure for dead, load, pressure, h temperature under both operating and accident conditions were performed using Wilson I computer code. The shell model for the OBE and SSE has been analyzed using Wilson II program. Both the Wilson I and Wilson II use the finite element method. Since the ASME Code does not permit the liner to be used as a structural element, the containment structure has been analyzed and designed without participation of the liner plate. The analysis recognized the fact that under thermal conditions, the liner plate will exert forces in the concrete section which constrains the liner growth. In order to generate proper design forces for the concrete section, liner stiffness has been included in the Wilson I model but excluded from integration of stresses to obtain section forces and moments. The analysis recognized the fact that the cracking pattern will vary under different loading conditions. In order to simplify the design, the individual loads have been combined linearly despite the difference in cracking. The peak pressure and peak temperature have been assumed to occur -
~
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5 i simultaneously for the design of concrete section. We agreed with this approach. i-d. f .
- In the analysis the input for the SHELL I and SHELL II programs have been 1 r l obtained from the lump-mass analysis which used the STARDYNE computer code ,
! and model described above. The SHELL I ar.d SHELL II programs converted the forces and moments obtained from the STARDYNE analysis into the effective i
- membrane forces and in plane shears and adds them up algebracially.
The-square rool'of 'the sum of squares is appiied to detemine the comb d'- g ! . effects of three orthogonal components of earthquake ground motion, including 9 g(- i +
-s i two horizontal and one vertical motions. ,Due to the symmetry of the structure) 9 f9k j the maximum meridional and the maximum in plane .ihears will occur at the same j location. 4, 3 f --
. . _ L The design loads computed by SHELL I and SHELL II were used as input to program k' i
! LESCAL. Version 1.5, which is used to calculate the stress and strains in ! rainforcing bars and/or concrete per ASME B&PV Code, Section III, Division 2. ry
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a Piping sends verification necessary, to help locate suppts, pack; ige to ARS Review Task Force. g J
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reduced ARS and asks Piping to - - - - . [d closc-out AFS verificarion. If g not possible, asks Piping to .
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/ or (ii) requests MAC reanalysis.
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Piping perforns ARS verification and closes put. , Piping formally releases su'pport modifications to Fabricator.and closes out ARS verification. , V . ! PSG S Ses soPP.Ap Lc40s ,pa ._ _
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'EILEEN Author's Name:
, R. Lipinski Document Comments: Design of Structural Elements 5 4-- // 0 <7 - 3
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1 2 4.3 Design of Structural Elements Ol h The obje^ctives of this portion of the inspection were to examine the adequacy
/ Jte 5 l1 7 , and coordination of analysis, design, engineering drawings, shop drawings and construction of structural elements located in Category I structures which are
- ag associated with the containment spray system. The structural element which was selected as an example was the recirculation sump screen structure.
The containment recirculation sump screens and collects the water available for supplying the residual heat removal, containment spray safety injectic1 and high head charging pumps during the recirculation mode of operation following an accident. There are two completely independent sumps located in the contain-ment, symmetric about an azimuth of 270*, with the top of concrete at elevation
-26'. Heavy particles are prevented from reaching the sumps by sloping the 4
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surrounding floor away from the sumps and two screens (one is. coarse and considered a trash rack with 1 inch x 3-11/16 inch openings and the other is the fine screen with 8x8 openings per inch) prevent foreign matter of 0.097 inches or greater from passing through. 2 Both the trash rack and the fine screen are attached vertically to the steel framing. The structure itself consists of a framework 'of structural steel members extending from elevation -26' to elevation -20i'. Each frame is on three elevations, within the limits stated above, and has the area of 9'-6" x 18'-6".
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We reviewed the design calculations for the screen structure which are contained in the Calculation No. CI-2 (Reference 4. ). The structure was designed for the load coabination of the dead load, live load and the OBE as one of those !
. required by the FSAR. 'The computation contained a statement that the equation used was the controlling load combination equation, but there was no comparative analysis or any evidence.that botn earthquakes (0BE and SSE) have been considered.
Additionally, the effects of thermal expansion of the beams had not been taken into account. During the inspection, the temperature was accounted for in W f l Revision 1 to the calculations. This was after the structural steel hes- been e no b installed. The drawing pertinent to this structure, Drawing F-101486, (Reference 4. ) was released for construction of embedded anchor plates s on September 29, 1978 and for structural steel construction on January 21, 1980.}Weconc]udedthatconsiderationofbothoftheearthquakeloads,dBE and SSE should be evidenced in the design and that omission of this load is violation of the " Structural Design Criteria" SD-66, Table 5.4-1(?), Rev. O, dated October 19, 1976 (Reference 4. ) (Finding 4-11).[ During our inspection, Revisien 2 was added (dated November 25,1983) which included an explanatory
~
ncte that the amplified response spectra tab't aave been consulted and it appears that the original design was cw s w e. e _..a . Q.non %k . Examination of Detail 101486M on, Drawing F-101486 (Reference 4. ) revealed j that the bent plate connector had not been placed centrally with respect to the chan structural member to which it is bolted and was moved toward the upper flange of the channel. This was inconsistent with'th'e analysis, which assumed
! that the connector would be placed so that the center of the bolts on the connecting plate would coincide with the center of gravity of the c nnel. We ,
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=
f33 4 e I f verified that the eccentricity between centroid of the bolts and'of the channel as described above has been transferred' on to the shop drawing and during our trip to'the site, we found out that installation was consistent with the drawing. Since the members are subject to the movement along their longitudinal axes due to thennal conditions, such a displacement of the connector from the centroidal axis of the beam introduces eccentricity which will result in increased stresses at the connecting plates. This was noted as a finding.
~
(Finding 4-4). The cognizant design engineer perfonned additional calculations during the kve inspection to account for%'t4 tis 4 condition and determined that the resulting stresses are within the code allowables and, therefore, the structure as built is adequate. The additional calculation sheet has not been listed in the Calculation Revision Control Sheet of Revision 2 which was reviewed by the i team. This is contrary to AP-22, " Calculations" but since the work was done 2ess after the inspection's ti=p review cu+-oM cfd 9 t gthis is noted as an observation (Observa-tion 4f 3 ). , While inspecting the annular steel between the containment shell and the secondary shield in the containment structure, we observed that a number of steel beams framing into the steel plates embedded into the concrete had been modified. The 1 l modifications consisted of extending the lower part of the web of the beams and I providing plates to acconnodate the lower bolt in the plate which had been welded to the embedded plate. Upon examination of the pertinent shop drawings and the engineering drawings we found that this modification had been necessary due to the fact that the embedded plates were installed at the wrong elevation. The t
. . _ . . ~ . .. .._ . . _ _ _ . . _ _ . _ . . _ . _ _ .
. s/tr/rpt 43-4 plates were installed too low to be compatible with the elevation of the structural steel in the area of the annulus. In our discussion with the cog- l nizant d'esign engineers the modification of the connections was not reflected in the analysis completed using a computer program. We determined this Q be in conformance with the AISC Specification (Reference 4. ) and the Structural Design Criteria, SD-66, Sections 2.1.2 and 6.2.5.1 (Reference
, 1.3)y (Finding 4-13).
We requested that an additional analysis be performed to determine the adequacy of the connections. During the inspection we were informed that a program which will re-evaluate connections modified as described above or in any other way so as to depart from the standard connections contained in the AISC Specification and not tak6 analyged via the computer model will be reviewed. This will be done by selecting a representative sample and analyzing the connections in that sample in accordance with the AISC Specification requirements. We were told by the design engineers of UE&C who have been intimately involved in design of the annular area of the containment structural steel that misalignment of the embedded plates with structural beams is wide-
. spread in Unit 1. In the case of Unit 2 there was an effort to rectify this situation and to install the plates at the proper elevations thus alleviating problems for the as-built conditions. This was not' completely successful and as a result there are cases where beams had to be modified in Unit 2. We also
- learned that the modifications were not perfonned in the field, but the beams 4 were modified at the fabricator's facility and shipped to the field ready for installation. In view of the evidence that the design engineers are aware of the need for further analysis of these connections and that further action is under way we did not pursue this matter further.
i l
_ . . s... _ . . _ ' - . ._ . . ....1...___ _. . eg d"N I Another item which is related to this area of containment pertains to the connection of the beams to the columns in the annular steel. Examination of the shop drawings revealed that in order to acconnodate welds between connecting angles'and the beams framing into columns, not perpendicular to the columns, the axis of the beams was shifted by one inch from the centroidal axis of the column. This resulted in an eccentricity with respect to the column, which in turn induced torsion in the column. We have found that this was not accounted for in the analysis completed via a computer program and that it violates the Structural Design Criteria, SD-66 (Reference 1.3) and Section 1.15.3 of the AISC Specification (Reference 4.' ). In our opinion, the effect of torsion induced in the columns is to increase stresses in the members and these stresses should be evaluated to determine the effect on over-all member stresses. We recommended that an appropriate action be taken to assess impact of this - eccentricity and an analysis be performed to evaluate the resulting stresses. (Finding 4-19). y k.I 1 The Structural Design Criteria, SD-66 (Reference 1.3) is the controlling document i for the structural design of reinforced concrete and structural steel. With j respect to the design classification of the seismic category of the Tank Farm structural steel considerable confusion was found. Table 3.3-2 lists the Tank Fann structural steel framing as Non-Category I with a req'uirement that earth-leafy s quake shall be in accordance with the Uniform Building Code with a perplexing 3 - z note covering manhole covers. Furthennore, a requirement for the design for tornado pressure is listed. Paragraph 4.4.2.6.5 of the criteria states that the roof shall be considered expendable and allowed to fail during a tornado. However, Revision 1 to the document, dated November 30, 1982 deleted the Tank .
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d.\ Farm structural steel from the listing of Non-Category I in Section 3.2 and listed it under Category I in Section 3.1. This leaves the tornado requirement unclear at the present. . While it was apparently the intention to change the
-de s4rv4re designation to Category I in November of 1982,44.gwas considered Non-Category I from the original issue date of the criteria document of October 19, 1976.
During the time period between October 19, 1976 and November 30 1982, the I calculations for the structural steel, Calculation No. WB-61 gwere perfomed f- b l& Cot e without a strict adherence to either Non-Category I or Category I ,,cferen:r
. ).
In the latest revision to the FSAR Table 3.7(B)-22 has. the Tank Farm steel
- is hsled framing over the Refueling Water Storage Tankgs Non-Category I with the caveat that it is designed not to collapse under SSE.
For most Category I Structures which are exposed to tornado pressure, Table 3.3-1 in the criteria document requires a design for tornado pressure. This leaves in doubt, the tornado requirements for the Tank Fam structural steel A4 and the associated concrete roof slabs. Calculation WB-61 indicates no design 4 for tornado for the structural steel. v The Tank Fam structural steel is Seismic Category I. The calculations and drawings are all classified as Category I which is the design intent at this time. The design load combinations listed in Calculation No. WB-61, Sheet 10 of 79, dated September 28,1978(Reference 4. ) omits load combinations containing the SSE. This violates SD-66, Structural Design Criteria, Table 5.4-2 (Reference 1.3) (Finding 4- G ) .
/k W 43-7 UE&C stated that th$t OBE load combination always controls for the design of the structural steel beams, and that this statement with a justification will be inco@ orated into the structural design calculations.
A structural steel beam, Mark B9, located on the El. 81' roof along Column Line 0.5 was designed for dead loads, live loads, and seismic OBE loads in Calculation No. WB-61, sheet 17 of 79, checked September 28, 1978 (Reference 4.34). Later a redesign was made to add the sag rod loads to the dead loads, live loads, and seismic OBE loads (Sheets 9I and 9J of 79, checked November 3, 1979). The original calculation (WB-61, Sheet 17 of 79, checked on September 28,1976) was not voided as required by GEDP-0005, " Procedure for Preparation, Documentation and Control of Structural Calculations," Paragraph IID, Revision 0, May 21,1974 (Reference 4. ). Subsequently, another calculation was made (WB-61, Appendix A, Sheet 10 of 16, Rev. 3, checked on June 17,1981)which added a pipe support load, but neglected the sag rod loads. . Again the previous calculation.was not voided. The SSE pipe support load was incorrectly combined with beam OBE loading and designed for SEE allowable stresses. The neglected loads and the combining of OBE and SSE violates SD-66, Structural Design Criteria, Rev.1, (Reference 1.3) and was noted as a finding (Finding 74 -6 ). The fact that there was some confusion over whether or not the structural steel was Seismic Category I probably led to the type of problems described above. It is the team's understanding that the beams will be evaluated as Seismic Category I in a systematic application of all load combinations.
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l l<'/ - The roof slab of the Tan Fann structure was designed as Seismic Category I , -
, / l although the Supervist g Discipline Engineer stated that the roof was Non-Seismic
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Category I. -SD-66, Structural Design, Criteria (Reference 1.3) is silent on the
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matter. l -- p The calculations for the reinforced concrete walls along Column Lines 4.5 and 5.0 are contained on sheets 8 and 9 of 13, UE&C Calculation No. WB-68 (Reference 4.34). The calculations were based upon the method described on page 351 of the "ACI Design Handbook," SP-17(73) (Reference 4. ) in accordance with the strength design method of ACI 318-71. The method is appropriate for reinforced concrete sections subject to combined bending and axial load when the section is controlled by tension. The calculation procedure i is described in Flexure Example 3 of ACI SP-17(73) (Pe1Frence$ 1 which
. neglects any compressive reinforcement. The calculations did not indicate an 1
adjustment of the value of 9 The results of the calculations indicated a requirement for reinforcing less than that which would be required by a correct calculation. The tendency of the designers to provide more reinforcing than actually required by design may mean that sufficient reinforcing is in fact present for the revised calculations. This appears to be a systematic error for the Tank Fann walls and; therefore, the team reconnends a ieview of all the design of reinforced concrete members subject to combined bending and compression. This failure to correctly execute the design in accordance with the design i reference was noted as a finding (Finding 4y-10 ). Bracing within the structural steel framing is provided for resistance to lateral loads such as tornado and earthquake loads. The calculations for the design of .
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4g ) t/I7/84 bracing are contained in Calculation No. WB-61 (Reference 4.34). Total seismic shear loads were obtained from Calculation No. SB SAG-SWB (Reference 4.41). The loads in' the bracingMstablished in an approximate manner. The actual dis-tribution is more complex than that assumed; namely, i,t is dependent upon relative stiffness. However, the determination of the distribution of shear forces is dependent upon a knowledge of the sizes of the bracing and columns which, of course, were initially not known to the designer. Additionally, UE&C did indicate the OBE will control the design of the structural steel beams as b# opposed to the SSE,Ait is not clear that the OBE will control the design of bracing. At this point, a reanalysis and, if necessary a redesign)of the bracing is in order. The team recommends a more accurate determination of shear distribution and a recheck of stresses, based upon the fact that the column and bracing sizes are now known. The bracing in the Tank Farm should be checked with newly calculated seismic forces for both OBE and SSE in accordance in Table 5.4-2 of SD-66 (Reference 1.3). This failure to utilize all required load combinations and actual member properties in the calculations j was noted as a finding (Finding 4g-fp - UE&C's headquarters in Philadelphia, a group called Structural Site Support e Engineering has been established on the project independent of the project
-fo address e4mr desrgn c4anges.
Structural Engineering groupA This group acts in support of and approves the sile. Enyacena ) work done by engineering forces (jgn site at the Plant. eabrook g m Jo E-In general, hite kngineering is apphsed of a problem encountered duis construction. Site itngineering will either propose a solution or will request .I a solution from Site Support Engineering. The proposed solution will be i
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reviewed for approvtl by Site Support Engineeringsr- Jh a b M UN Pd '! A typical example of this process is Engineering Change Authorization, ECA I 01/4217. Several pipe supports were required to penetrate the roof of the Tank pci Farm at felevation 71'/#1. In Rev. A, Site Engineering recommended cutting the 4d concrete by scoring the openings and chipping the concrete. Rev. B added reinforcing steel, cutting and replacement details and steel removal and sedt ons. replacement andkteel WT's Revisions continued through Rev. E which incorporated additional details. During this process there was continuing dialogue between the site and the home office. Tlas eskoN %e eS E Site Engineering also prepares calculations.wMeh41s now underg Fi eld GAcP) Administration Construction ProcedureN4 o.10, original issue was dated 3/11/83 and Revision 1 dated 10/27/83 (Reference 4. ). The majority of calculations concerned misalignments of structural steel connections. The usual case involved I wire. ten m =de a misalignment of bolt holes, which required a replacement 4 welding. The welding was designed to provide the equivalent strength of the bolts, even though the actual forces might be less while this resulted in an overly l conservative connection, it did eliminate several cycles of communication i I concerning design load requirements.
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g.c w d . YAEC also participated in resolution of NCR's which might have serious impact upon the project and which could not be considered routine. Two such issues were being addressed during the early stages of the project.
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4, 5 - h7hf . In many pipe support details, it is necessary to butt weld a thick plate at 'N
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right angles to cn embedment plate. In approximately 20 cases the right angle eHar plate ha~s pulled out a po.-tion of the embedment plate by laminer tearing. l 3 Similar problems occurred previously in welding of annulus steel. The fact 1 i that the problem again came up was that there was no welding or material review, . i nor was there any general comunication issued to alert all designers of supports ; eller to the problem of 1aminer tearing. The problem has not been resolved,but %e tentativeft consideration is k ing giver, to chang"les. steel from ASTM A-36 to Lukens Fine Line 516. "stli ". . Ken ',;iM4 === and M W uerg Tuder vi .AEC N P"""' are involved in the resolution. I h ts are being use the drif minator of the Cooling owers. Due i to corrosionhotential, the Hilti bolts are siredinStAinlesssteel. However, the required ihngth was not avai able in stai ess steel; therefore a greater i I ' ngth is antic ated. A meeting was schedule to resolve this matter. Arother concern we raised by A. erne of Region I oncerning ba to back an
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co er installation This item w addressed and it asfoundthatforthe { specif c cases there was no negative effect-The overall assessment of the design controls in the area of design of structural l elements indicates that the design utilized the design criteria and provided adequate margins of safety with regard u the code allowables. The staff appeared to consist of experienced engineers thoroughly familiar with sound knowledge of their profession. We do not expect that the. neglect additional stresses produced by the modification of the beams (Finding 4-13) or eccentri-
- f. .
Y' 9 4, 3 ,g cities of columns (Finding 4.19) will result in a dramatic reduction of the margins with respect to the code allowable. The team concluded that the structural elements examined have adequate capability to resist the expected design loads. d .i O 6 9 l
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f ,' l ' . . . _ - Document Name: SECTION 4.4 - SEABROOK IDI' Requestor's ID: $ EILEEN 1 5 i Author's Name: s j - G. Harstead i - Document Comments: 4 i Design for Supported Mechanical Systems and Components C 4 -/c, i l i s t t s' d i 1 1 4 i t ) 4 e i j i i i ~ ,v.. - , , - - - - , , , . - - - . , . _ - , . _ _ - . , . , _ _. - . - - -
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4.4 Design for Succorted Mechanical Systems and Components The objectives of this portion of the inspection were to examine the coordina-tion between the design of the mechanical components, the support structure, and the design of structural elements. The two tanks selected for review were the Refueling Water Storage Tank (RWST) and the Spray Additive Tank (SAT). Both tanks are part of the containment spray system and are located in .the Tank Fara x s rf ve/vre. Both tanks are supported at their bases and are anchored into the fill concrete by means of high strength anchor bolts. S,,,,Y A/4was Ave 7~ed The seismic load for the(SAT) h4obtained by assuming horizontal and vertical accelerations equal to 1.5 times the peak of the grou3d response spectra. 74/5 y equivaknf s.4ric w.alysis "__2s .,s.41m / ec~/ ch',d in 'onformence
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conse rvetivel.y doigned. Therefore, ni spite of the tell ceni; i i WM no'- de;9ne d Or /Me oo.vemenf :rpee derdun 4 pi n on vric had, the t d 4e tarMnd suppe. s,,iedvery conserve.tively de:f gn;d. ' mile the-method of sai m4c analyst; i; i cccordance ,;ith the ':nc crf , it .2: net Msted 4a the-spaci fic"4 c ns The Refueling Water Storage Tank (RWST) was purchased from Pittsburgh-Des Moines (PDM)underUE&CSpecification 9763-006-246-1 (Reference 3.52). PDM prepared design , calculations for the RWST (Reference 3.196); however, two errors of omission were noted. One, in calculating the stiffness of the cylinder only the.cverall bending stiffness was considered,with the shear stiffness being neglected. Two, only the fundamental frequency was calculated, neglecting higher modes.
4.+-z '/4N A reanalysis could indicate greater design seismic loads; however, it appeared that the thickness of the cylinder could accommodate somewhat greater meridional compressive stresses. Also, there appearea to be additional capacity in the anchor bolts. The team does not expect that there would be a requirement for material changes as a result of a reanalysis; hcwever, such a reanalysis is necessary to meet the requirements of the specifications and good engineering practice. (Finding 4 4 ) - The review of the tank calculations prepared by PDM was the responsibility of We-ea k f uec t , [I 1AGl ho/ s sC. G T e design
<ee,wsabib av was of the anb' or bolts dOh"" sp?it"9"'"WM uith-PCM specifyiap th g
bolt diameter and steel designation and the UE&C Seabrook Project, Structural,was responsible for the design of the embedment length and local reinforcing if required. The number, size, and type of bolts required by PDM was observed - in the as-built condition. The pipe support which was located on the structural steel Beam B-9 discussed in Section 4.3, vas relocated so that the support was anchored into the ccncrete wall located parallel to and adjacent to Column Line E.7 in the Tank Farm instead of being supported by the structural steel beam. The sketches for the relocated pipa support structure were designed and presented en Drawing $
@ M-8018335, SupportNo.M/S-1833-RG-04, Sheets 13through173'XE,vf@r 4 (Reference 4. ).
During a field visit, the support was observed. A comparison of the field i 1 installation with the design drawings indicated that the several of members were larger than required by the design. The team had no questions relative
s/islr. E;<- , 4 _, o b to these discrepancies in view of the oversized members. By changing the support from the structural steel beam, 8-9, to the concrete wall, problems which could be caused in the design of the steel beam were eliminated, however as noted in Section 4.3 a finding was made on this subject. e' \ n' l af
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44c.fr4 Document Name: . SECTION 4.5~- SEABROOK IDI i Requestor's ID: EILEEN i Author's 'Name:
~ R. Shewmaker
- Document Comments:
Design for Supported Electrical Systems J 1 1
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4.5 Design for Supported Electrical Systems
-The objective of this portion of the inspection was to review selective samples of. specific designs related to the structural support of electrical systems in order to assess the interface between the electrical and civil-structural disciplines for design. Specifically, a determination was to be made as to whether: -
(1) The licensee's design commitments contained in the FSAR and other relevant documents have been met (2) Correct design information had been coordinated and complete interfaces
- made through a logical design process 4
(3) The completed design was adequate The inspection in this area was conducted by a review of the lateral cable vejC tray supports being designed by argengineering design group located just off-site from the Seabrook plant. ' Organizationally the group is part of the 05f C Site Engineering Group, which is under the supervision of a project engineering manager and a Technical Staff manager. The Group is known as the Cable Tray Bracing Task Group. This Group at the site complets work on the cable tray support systems which are under the technical control of the Mechanical Analysis Group for Electrical and Equipment in the home office. The home office group reports to a different project engineering manager, known as the project system engineering manager.
f5/7f 4.5 -2 The home office group is responsible for the development of the detailed design procedures and related guidance and in the current mode of operation, performs the analysis to complete the necessary design for the vertical loads on the tray supports. The site group is then responsible for the analysis f wAich is c ,.y/e/c/ by inknq necess;.nry socl+ajM g
; and design for the lateral loadsA The completed calculations and drawings d e ' N 'F #
adx4 4as by the site group are then sent to the home office for final review and the /ceo cae p /e ph rf by incorporation into the final design documentation, which includes the desjgn fje jg for vertical and lateral loads. OIce-The design of cable tray supports for the Seabrook project is governed by the document known as the " Technical Guide for the Design and Analysis of Seismic Category I Cable Tray Support Systems" (Reference 4. ). The team's effort in the area of the cable tray support design included a review of the technical centent and details contained in this Guide as well as the execution of the design. The Guide is considered to be a controlled design document for the project on the basis that individual copies of the Guide are assigned to specific individuals by copy number. The development of this technical guide was the responsibility of the Mechanical Analysis Group which is a staff group reporting to the Chief Engineer of Power. The analysis and design procedures provided in the Guide are the result of I combining the results of actual test data for various components or elements of the tray support system with analytical procedures and the use, in many of instances, a bounding type assumption in order to realize a workable design procedure so that each and very design solution is not unique. A review was
- 4. 4. S -3 ///G/2?
made of the specific FSAR comitments regarding the design of the cable tray support system. The relevant comitments were noted.to be in Sections 1.8, 3.2, 3.7.3, Table 3.7(B)-23, 8.1 and 8.3 of the FSAR. Certain aspects of conformance to these comitments were reviewed and discussed by the NRC's Office of Nuclear Reactor Regulation prior to the team's effort (Reference
- 4. ). The team's effort was to interface with completed actions by NRR and their understanding of the design execution and to verify that the, supports to the trays were indeed designed as Category I structures.
Only general and very limited comitments were found in the FSAR with regard to the manner in which the analysis and design of the cable tray support system would be executed. Note 5 to Table 3.2-1 in the FSAR stated that " qualification of the conduit and cable tray racewaos for the Class IE safety related circuits have been confirmed by analysis, and calculations verify the adequacy of the systems based on the properties of the raceways (including tray where appli-cable) and support components." In Section 3.7.3 of the FSAR one of the methods of seismic analysis for subsystems noted for the project utilized the cable l l tray support system as an example of application of the dynamic analysis methodtechniqueusingthemodflresponsespectrumtechnique. Diagrams were providedinFSARFigures3.7(B)-31and-32toillustrateatypicalfilingto A floor cable tray support as well as a mathematical model representation which was used in the dynamic analysis. This constituted the majority of the analyses and design details provided in the FSAR. No inconsistencies between e the FSAR and the Technical Guide were found during the review. Thebas(sfor the design of the Category I cable tray support systems @ judged to be well in dao .cre-M foundedonacombinationoftestdatagndacceptedanalyticalanddesignprocesses,
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4-which are hned Or, test d:t: tw: Orc::t The first area g dealt with the actual [Staticfiaxial (combined vertical and horizontal) load testing of cable -tray sections and the utilization of the resulting load-deflection curves to determine the load capacity at the tray's yield point, the load capacity at the state of local plastic behavior and then the ultimate load capacity. The team did not review the documents related to the actual test program., We did however establish how the allowable cable tray load limits were developed from the test data. UE&C defined the allowable loads on the basis of tray deflections being limited to no more than 12 inches in.any deZ/ecdon direction based on electrical cable 1i4 mitations. The cable tray tests indicated 4- de&cdon nke Me had ined yield. Tray testing much lower values 45uch as under 1 inch a included the two configurations of trays which would be the most flexible (the 12" and 24" ladder type). These tests,in addition to the load def]ection curves,also p'rovided data on the effective member properties which could then be utilized in the structural model for analysis. The simplified structural modelsintegratedthecabletraysandthetraysupportsystem,consiItentwith the actual design configuration. These models were then utilized in standard structural analysis techniques to obtain dynamic responses and internal forces for the structural assemblies. Testing was again utilized by UE&C uncled-to establish the ultimate load capacity,4w4various types of loadings including both levels of seismicy for typical configurations of joints and members. The. load capacity of other structural members such as the cold-formed strut material or structural steel was established by the manufacturer's data or by use of
-Me existing codes such as g AISC g Spec;6dte C2/ereece er.
).
.g_5 hh The design criteria for the cable tray support system defines three loading combinations and two stress or behavio,r levels. The dead weight alone and the dead weight of the t plus the cable and the OBE loading are to maintain the support system.in the elastic range. The dead weight of the tray plus the cable and the SSE loading allows some excursion into the plastic range, yet assures structural integrity. The design philosophy also encompasses the use of the largest yet most flexible cable tray configuration so that the tesultant loads into the vertical support members are maximized. The bracing members
,0f are used to increase the fundamental frequency of the system and therefore M i the response away from the peak response region. Damping has been taken as 4% for the OBE~and 7% for the SSE which is as provided for in the FSAR.
Section 6.0 of the Guide provides detailed instructions on the execution of the analysis. It was noted that mass points were required to be located no further apart than 36" in order to more accurately reflect the behavior j of the tray system which is generally supported at 10 foot spans or less. The 4 l various standard configurations are provided as well as the types of permitted lateral bracing and the-design details which must be addressed for each type. i The various typhinclude the single support transverse bracing, two sided bracing, multiple support transverse bracing and axial bracing. Guidance is also provided on thermal considerations, torsion, buckling as well as welding and attachment to concrete. For situations where the cable tray support system is connected to main building structural elements which have different amplified
' response spectra, provisions are made for using envelope spectra or by a carry-
! over type analysis from one response spectra area to another. The dynamic analysis can be completed using a equivalent static load using the peak value i I k~
t'. t//c./rq f M S -G baof are with a 1.5 factor or utilize a dynamic analysis /Which +sAin accordance with approved NRC methods. Documentation requirements are delineated and standard calculation forms for cable tray supports are provided. y r ( The Appendices to the Technical Guide address in detail the related information necessary to perform the design of cable tray support systems. The sample calculations selected by the team for review to assess the manner of. execution of the design and to assess the adequacy of the resulting design ve.Y was, a series of calculations related to the lateral support of cable trays in the Control Building. They were prepared by the Cable Tray Bracing Group at the Seabrook site in the Site Engineering organization and transmitted by a memo dated August 2,1983 from Site Engineering to the home office (Referenca
- 4. ). This submittal contained calculations in the* southwest quadrant of the plan for Elevation 21)1/2' in the Control Building as shown on UE&C Drawing F-T10449(Reference 4. ). The calculations included the analysis and design for eleven separate sections of multilevel and multibay cable tray supports. 1 Preliminary calculations for Section SW-3 (Reference 4. ) were selected for ,
review. All assumptions were noted and those which required future verification i were so marked such as the assumption that the amplified response spectra are final. This was found to be consistent with the procedures defining the comple- l tion, control and documentation for calculations. Specifically those procedures consist of GEDP-0005, " Preparation, Documentation and Control of Calculations" (Reference 4. ) and AP-22, " Calculations" (Reference 4. -). AP-22 takes the corporate design procedures contained in GEDP-0005 and defines in more detail how the intent of GEDP-0005 is to be met for the Seabreak Project. It ;
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E* 4} S-7 t/M/r4 was noted that AP-22, Appendix 0 which addresses the requirements specific to the Site Engineering group with regards to types of calculations completed, h indicates that the Group is authorized to perform support design modifications to electrical systems. The work being completed by this group is in fact modifications to the vertical support system designed in the home office by the Mechanical Analysis Group (MAG) to accommodate lateral loads. With regard to GEDP-0005 it is noted that AP-22 would require the work being done by the Cable Tray Bracing Task Group to follow FACP-10. " Procedure for Site 1 Calculations" (Reference 4. ) except that it is stated that where required l individual disciplines may use separate guidelines for calculations. l The references utilized in the calculations, whether specific to the project such as those providing the details, for example of support type vs. the critical vertical and horizontal frequencies of that configuration to those which include ' standard text books, handbooks and vendor's catalogs on engineering details were provided. Two of the three vendor catalog references utilized for strut material and hardware data utilized in the calculations for Section SW-3 were used in the verification process by the team. No discrepancies were found and the interpretation and application of the data was judged to be correct. It was noted in the calculations that where several individual bents of laterally unconnected support frames are subsequently tied togeQer laterally through braces that UE&C utilizes the square-root of the sum of the squares ( method to combine lateral loads. The team had no disagreement with this concept. In general there appears to be significant margins in the tray support system due to the simplifying assumptions made to minimize the number of unique designs required. For example,the worst tray cross-section
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.is used, supports are designed in general for 10' spans of trays, in most instances the static load of 1,5 times the peak of the enveloping response
- is used '
spectra and the member / joint type selected usually has a capacity j significantly greater than required. l l The procedures and execution of the design of the cable tray support system for lateral loads were reviewed against the requirements of Section 4 . Design Process, Section 5, Interface Control and Section 7, Document Control of (kkfrrence + ) ANSI N45.2.11-1974 to which the project is commited (see AP-22, Section 1, ; 3
- p. 1). The design activities were found to be prescribed in specifications, procedures and the Technical Guide for this task. These documents provide l
adequate. control of the design execution to be complete by the individual designers. The design assumptions and design input were cl.early defined and
. the associated calculations clearly identifiable by subject, originator, l reviewer and associated dates. The standardized sheets for calculation title sheet, calculation control sheet, table of contents, status of revisions, assumptions and references has resulted in complete and fully adequate l
l calculation packages. The interfaces are well defined and understood as the - i information flows from the electrical group, MAG and the Site Engineering group. The lines of communication were judged to be well defined and - established. The documentation examined proved an excellent example of a package of work completed by Site Engineering, Cable Tray Bracing Group and transmitted to MAG for final review and concurrence as well as integration into the total L packaga of calculations for the cable tray support system. - i i
, ? + s 0) l Based on the team's review of this specific area of engineering and design effort,UE&C's design control appeared to be very good. No findings were made.
All licensing design commitments selected for review were reflected in the design documents being utilized for the project. In addition, more detailed design criteria and procedures have been developed and are being utilized on the project. The design process has been quite clearly defined and developed l in the Technical Guide for the Design and Analysis of Seismic Category.I Cable Tray Support Systems. Correct design inputs and design information have resulted from the systematic application of the Technical Guide based on the team's review. The specific review of Section SW-3 of the cable tray s pport ses A ed in .r A. system in the Control Building gdetermineny t+-h fully adequate. h4 the dessywas It was 4 I apparent that a great deal of engineering effort was expended, including substantial testing where it was apparently determined that actual test data
, in Me evo/.dron e' ;%s e!-cayn fWe4Me-would add to the reliability of the engineering and design processgWhether i this was a joint decision by UE&C and YAEC/PSNH or a singular decision, the project is to be comended for a well organized design process for cable tray l support systems and one which is adequately controlled based on the team's '
! limited sample. l
Document Name:. ,-
//is/g l SECTION 4.6 - SEABROOK IDI
- Requestor's ID:
4 EILEEN Author's Name: R. Lipinski Document Coments: l Design of Supportvl&C Systems ed .- A ? F 4-20 C +-so -1 1 F4-23 4 ] 1 r. 4 1 i i l I . I i i i i
8'l84 46-/ 4.6 Design of Supported I&C Systems The objective of this portion of the inspection was to determine for a sample of instrumentation and control systems whether: (1) ffhe h an2l WS egipr _ysis saneprocess prec'n=r.t *y/r 4+gxecuted in accordance with the appropriate procedures and if conformance with the guidelines contained f essee ew-rWned */ Air in the Quality Assurance Manual, gy ,6 de rappi-/ ob Me T/C Sysk*"* (2)}Correctdesigninformationghasbeencoordinatedandcompleteinterfaces made in a controlled design process, e d , . - 4, /s . (3) IThe completed design was aYe ate. The equipment selected for this inspection was an ,1 strumentation rack designated
+P"T?1 as MM-IR-14, located in the equipment vault a plevation 3W, west of Column Line D and north of Column Line 1.
h t.9 The purchasing of the equipment such as this rack is controlled by the Admini- 9 6 - strative Procedure (AP) No. 18, dated May 31, 1974g This procedure has been 4-revised several times, the last being Revision 5, dated November 1,1983(&4vence ' 4 It ,
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describes the procedure for preparation of the suggested bidders list, material i requisition, bid analysis approval by the Yankee Atomic Electric Company [V4EC), t issuance of purchase order and change orders. a .
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i T The provisions of the AP-18 are coordinated with the AP-36, " Control of Seismic j Design", issued on May 14, 1980, the current issue being Revision 2, dated iMA i (tehve*we +: ). lo N October:14,1983 3 This procedure addresses the control of seismic analysis l
- and seismic. design of structures, systems and components and defines the 1
i responsibilities of the project personnel and staff groups for the Seabrook ! l project. It also describes the requirements for the' development and control I of amplified response spectra (ARS)kwwe (ge +in accordance
), with General Engineering j and Design Procedure (GEDP)-0012 3 except for deviations as identified in ,
AP-2g, " General Engineering and Design Procedure (Seabrook)[fehe fee f l Fromthedocumentswhichwehaverevieweditappearsthatthepivot,#hfigure e 4 . in the interfacing between various disciplines is the Coordinator of Seismic ! Design (CSD). His role has been mentioned briefly in Section 4.2 in connection with development of ARS for piping supports. Similarly, in the case of equip ; i ment supports, the CSD becomes the nerve center of coordination of the design effortininterfacingbetweenprojectpersonnel,StructuralAnalysisGroup 1 i (SAG), Mechanical Analysis Group (MAG), and Pipe Support Group (PSG). The team judged that introduction of this position in the organization of the staff of UE&C greatly improved coordination of the activities related to the design , of structures, systems and components since many separate groups are involved
- in the' complete design process. - --
j MM* i- IncaseofIR-14,theI&CGroupissuedaStaffWorkRequest(SWR)toMAG,to g > reeks revise response spectra in order to incorporate instrumentation Ped 4+( Nhich ! . included Rack No. 14. MAG responded that'the ARS tables are not available -t L and requested the Seismic Design Coordinator (CDS) to originate the ARS for i i. I
ps -3 hSofyy the rack at the specified location. The next action was from CDS to the SAG group requesting that the ARS be generated. Upon receipt of the ARS from the SAG, they were distributed to various disciplines, MAG being one of the recipients. Following the provisions of AP-36, MAG developed the loads at the anchor points which have been used, through the SDC, by the structural de discipline ingdesign of the structural steel framing at the location of the rack. Meanwhile, MAG reviewed the vendors seismic oualification report with respect to specification for the rack and was found to be acceptable. We verified that the ARS values used by the Mcch:ric:1 naDysir Group JMAG) were those provided by the Strwi.urai Anaiysis Group-$5AGi through the Swisinic-Occigr. Coordir.: tor $5DCt as required by the AP-36. We also verified that the values of the final anchor loads generated by the MAG have been based on the information obtained from the vendor's drawings and that they were used by t/e the structural discipline staff in design of the structural members. 4 g/ A' /We reviewed the method of development of the ARS by discus,sionf(with the 7p# g# 4P i j / cognizant engineers of k SAG and by reviewing h# t the Controlled ARS Tables (gKe entitled
+.- "Amplif)ied Response' Spectra for Seismic I f[' q.%Category I Structures3" These tables undergo controlled updating and distribution in accordance with Administrative Procedure 'No. 23, " Controlled (T h ee +. 4 Documents"4The various steps ilTustrating the complex system of interfacing between various groups and project disciplines is shown in Figure X. It illustrates the complexity of the problem and also shows the vital' role of the coordinator of seismic design (&SEF7 in the process. It has been pointed i
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u -g 44, til . out previously (see Section 4.2) that in the past ack of the CSD was responsi-ble for use of incorrect seismic amplified response spectra. The team found evidence of such a design deficiency, which occurred as late as in 1979, in the areas of seismic design of safety related components supported by the containment annulus steel frames. By memorandum SBU-31426, dated November 6, A k ee + 1979(gE&C reported to t e project manager, YAEC, that the amplified resp spectra used in the design was that for the annular steel frame which should have been used. It has been also found that the amplified response spectra for the annulus steel frame had "g" values greater than that used in the component design. The same memorandum informed the project manager that in order to ensure that other discrepancies do not exist in the seismic design, an audit would be performed to ensure that the proper amplified response 2 spectra were used of all items on the Seabrook project. In the case of the Seabrook project it appears that a satisfactory design has been achieved without significant changes to the component. We consider the above as an excellent illustration of the importance of good coordination of design effort between various disciplines in a project of the size and complexity of a nuclear , plant. The amplified response spectra (A ) are computed by means of a time-history hseismicanalysis. The overall dynamic response of the structure is determined by analyzing a model fonned by lumping the mass of the structure and the non-movable equipment. These masses a n 31n most cases 1 3 umped at the c/ewff* *cr. floor 2:=1,4The masses are connected by weightless elastic beams which represent the structural members between mass points. Torsion is accounted for by considering the eccentricity betwen the center of mass and the center J r
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I of rigidity. Floor slabs are assumed to be rigid in their own pla[e. comp ***rf Each structure is analyzed for two. horizontal components and one vertica1 4 for OBEandSSEmagnitudesofgroundmotion.endThecommonresponsefromthethree components are combined by the square-root-of-the-sum-of-squares (SRSS) method. i j l Local amplification of overall response aN computed by one of the two methods. In the first method, the slabs, beams and columns are evaluated for a range of frequencies selected for all local frequencies below 33 Hz. An overall stick model is then generated in such a way that at each elevation examined, the summation of the weight of the single-degree-of-freedom (SDOF) modes and the st ek model mode equals the total weight. The single degree of freedom systems, representing the computed range of local frequencies are connected to the overall stick model.as if they were all rigid. The stick model (including the SDOF's) is then analyzed using the ground motion artificial time history as the input {
- forcing function.
i > i The other method consists of perfonning a dynamic analysis, using finite , lements, in sufficievt detail to predict local modes of vibration. In this case the input forcing functien, at the elevation of the' structural element,
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is the response time history from the overall' stick model. i t l The frequency and time history analyses are perfonned using the STARDYNE computer program. ' As a result, the maximum response of a series of SDOF I - oscillators is obtained, over_ a range of. frequencies and the plot of these ' l . l l
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values is the amplified response spectrum, which is generated using the SAG 058 (febene 4. -)- computerprogram4 The SAG 054ytomputer code is then used to generate ARS tables by enveloping raw curves n r N $y kG058 nd spreading the peaks by 10 percent or more in accordance with the requirements of Regulatory Guide 1.122. I We found that the methods of generating the amplified response spectra described ahnva.are acceptable. ' I a g/ab-u.
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While reviewing the se4smid by S G to generate the ARS we noted ima/ely that the location of the platform a evation3'[wasincorrectwhencompared (Ec:4 re ce yamme) to the structural drawing F-101558 Rev. 6, dated 7/9/82 3 Since the model iteself was dimensioned correctly, the relative displacement of the model in 4 relation to the reference points will not affect the results of the SAG's En analysis. We found, however, that an observation is in order to point out /g the apparent lack of attention to the details on the part of the SAG analyst R.G %d' and the checker (Observation 4.A_P).
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In our inspection we observed that the structural design drawings Nos. F-101558 and F-101562 have been released for construction on Eeptember 28, 1976 and
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July 6,1978(24eaces +;respectively and the structural desi n calculations, e 4. ) PB-76 have been completed on December 1,198 We reques d that the original structural design calculations, from which the above design drawings were prepared and the members fabricated and installed,be presented for inspection. The original design calculations could not be found and we concluded that the absence of such computations constitutes violation of AP No. 22, " Calculations" Aehence +. & Section 2.3.1, Revision 5, October 1,(1975 (Finding 4.20). l I
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M W s Review of the Calculation No. PB-76, Rev. O, dated December 1,1983 revealed that when the designer considered different load combination equation involving ; seismic loads (OBE or SSE) the live load had been omitted. We considered this to be in violation of " Structural Design Criteria" SD-66 Rev.1, November 30, 1982, Section 4.2.1 and Table 5.4-2@Amce f. 3. W q e discussed this matter with the staff of the Structural Discipline. They presented an argument that this is consistent ; with sound engineering practice since during operation of the plant there I I will be no load (such as people or material) which could be classified as
^
l live load. Furthermore, the footnote pertaining to Table 4.2-1, of SD-66,
" Uniformly Distributed Live Load" states that: " Uniformly distributed live load" shall not be considered with seismic load conditions except loads which el are marked "Pemanent". - Examiminationapprw;mafely of Table 4.2-1 reveal 4thatwithtwo exceptions (150 psf in control building at Elevation (+) sur) the only live load listed as " permanent" is snow. In our opinion, such a classification of the live load practically eliminates consideration of live load from
, structural design in combination with seismic loads. This is contrary to the l statement in FSAR Section 3.8.4.3.a.1(b), " live loads" which states that
" Live loads are all temporary gravity loads including but not limited to nomal snow loads, conventionally distributed and concentrated floor loads, i and movable equipment loads, such as cranes and hoists". Additionally, l I
omission of live loads from load combination equations violates the require-ments of Section 4.2.1 of the SD-66 which states that "except for the , Administration and Service Buildings the minimum live load shall be 100 PSF" l We do not object to the statement in the same section of the SD-66 which states that "When actual equipment loads are used, uniformly distributed live loads O need not be applied to the area covered by the equipment. In the final analyses - s
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i the actual equipment loads may be used unless estimated uniformly distributed q l live loads are greater than the actual loads, in which case the members designed ' l with estimated loads may be revised or left as originally designed". We do,
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however, find it objectionable to remove live loads from the areas away from the equipment. We asked the staff if the floor live loads presently are or will be posted in order to prevent an inadvertent overloading on any area and we have been informed that they are not posted now and that such action is not planned for the future. Consequently ts the ebeve . finding regarding live ioas has been-flied (Finding 4.23). From the discussions which we had with the UE&C staff we infer that omission of live loads in combination with seismic loads is a
+4 e wide spread practice and we recommend thatgin resolution of this issue an audit be initiated which would assure that the affected structural members are not overstressed when subjected to the load combinations including live and seismic loads. S e m omissiev, of Ave / ads m combdos, wiM Seismet
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v4 6e a vio/af6n o7' .de ducA>ral g,y crller/2[Nady 923 . During a tour of the plant, we~ observed that one leg of the instrumentation sa- .yynu;makly rackg IR-14 in the Auxiliary Building Equipment Vaultjat Elevation 3'4 is Mich resting on.a 1/2 inchglate instead of the structural member, C10x15.3 as assumed in the design (Calculation A PB-76, Rev. O, dated December 1, Jehce 4: _ 1983). This configuration forms a cantilever with respect to the channel. We concluded that this is contrary to a sound engineering design and reconnended that a vertical stiffener plate be provided, welded to the channel, - and under the leg of the rack to carry the load to the channel. The reasor$s-for this recommendation are as follows:
- 4 1h
- nG-9 a) The ARS have been developed for the supporting structural member not the .
plate and therefore the dynamic response of the plate supporting the rack will be different from what it has been designed for, and b) The leg of the rack is situated at the corner of an opening in the plate orieaW platform which has been cut out to accommodate vertically r-=ning4 cables. This may be responsible for stress concentration.f We reviewed the level N of stresses in the plate platform supporting the rack and we found that they are low with respect to the code allowables. For this reason and because the situation just. described did not violate any requirements Mrs 7b be regarding existing codes or procedures we did not consider that #4 m g ef a finding,wedid bc apprcprietq. We do believe, however, that providing a stiffener plate as described above would improve the design. r In symmary, it appears that the process of procurement, and design of supported instrumentation and control systems is well managed and design controls are handledinaneffectiveandefficienhway. It would appear from Figure X
-d that the 31terfacing between different disciplines and staff gro'ups could be t
more streamlined,but taking into consideration complexity of the problem one can run into a danger of oversimplifying the procedures and bypassing important quality controls which might result in serious inadequacies of design. r: w
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Notes on Figure X 4 Generation of Anchor Loads
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- 1. I&C requests MAG to provide ARS at a specific location %1ev. 3'4') for W N-IR-14.
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- 2. The ARS for the4IR-14 were'not available, therefore MAG requested CSD to generate the ARS.
- 3. CSD transmitted the request to SAG.
- 4. SAG generated the ARS and transmitted the information to CSD. ,
- 5. CSD distributes the ARS to project discipline and staff groups. Advanced copies immediately, controlled copies approximately every six ' months.
- 6. I&C provides ARS to the vendor for preparation of seismic qualification report (SQR). ,
4.s 10
- 7. Vendor prepares SQR and submits it to I&C for review.-
- 8. I&C forwards the SQR to MAG for review and approval.
- 9. MAG notifies I&C of acceptability of the SQR.
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- 10. MAG generat,es anchor loads and transmits them to the CSD.
- 11. CSD transmits the anchor loads to the structural discipline for design /
verification of structural members.
- 12. Structural discipline prepares the design calculation and the drawings and releases it for fabrication and construction.
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I ci . //n!gd Document Name: SECTI0t! 4.7 - SEABR00K IDI Requestor's ID: EILEEN Author's Name: R. Shewmaker Document Ccanents: Subcontractors f 4-2/ \ ( e h
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.4.,7.- Subcontractors Off-Site The objectives of this portion of the report were to ascertain:
(1) How the licensee's des'ign commitments being implemented by UE&C were being transmitted and used as input for implementation by several off-site contractors. (2) The level of control maintained by UE&C over the subcontractor as well as the actual performance of the subcontractor. (3) The manner in which the subcontractor performed and controlled activities impacting.the design of the facility. !. In order to complete this phase of the inspection effort a selection was made $ from a list of subcontractors doing work in the design, engineering and services area of the project. The first subcontractor selected was Prof. Ed Burdette (test verification of certain design assumptions) who was chosen on the basis of an example of direct design related services. .The second and third sub-contractors were selected on the basis of the volume of work as well as the fact that both represented the next step in the design process beyond the basic design engineering effort completed by.UE&C. These were William J. Lester, Inc. (structural steel detailing) and Bethlehem Steel Corporation (detailing, furnishing and fabricating reinforcing steel).
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- q. 7. g Burdette Consulting Contract:
In 1980, United Engineers and Constructors (UE&C) contracted Professor Edwin G. Burdette of University of Tennessee, to perform certain tests to establish the load-displacement relationship of the liner plate anchorage system to be embedded on the concrete containment. The objective of these tests was to demonstrate the adequacy of the liner anchorage system to meet the requirements of the ASME Code, Section III, Division 2. We reviewed the available documents pertinent to the tests provided by UE&C. The test program was administered as a part of the Purchase Order No. H.O. 56971, Change Order No.1, dated 9/29/80 (Ref. ). The Procedure for Containment Liner' Anchor Load Test (Ref. ), required that the specimens be prepared on the Seabrook plant site using the procedures and material approved for construction of the containment structures and shipped to the University of Tennessee for testing. These specimens consisted of 3'-4' x 3'-0" x 2'-3" high concrete blocks with the liner plate attached to the 3'-4" x 3'-0" top face. The embedded anchors consisted of tees 12 inches long and the two studs, 3/4 inch diameter and 12 inches long. We concluded that the specimens
- used in the tests adequately represented the containment structure and the liner with its embedment system.
The test procedure required that all measuring and test equipment be calibrated before testing and evidence of calibration be available for review. At our request, we were provided with a Testing Machine Verification Certificate, (Ref. ) which stated that the 120,000 lb. capacity machine, belonging to University of Tennessee, had been calibrated and the loading ranges have been found accurate with tolerances ranging from 0.42 to 0.83 percent. The cali-9
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bration was performed by the Tinius Olsen Testing Machine Company, Inc., of Willow Grove,. Pennsylvania on June 10, 1980. The load cells output readings found in the report were based on the load readings from the same testing machine referencing the same calibration date. f P> d N .2 )Y Ne concluded that there was sufficient evidence of adequate quality control and that the tests were conducted with an adequate standard of reliability. Bethlehem Steel Corporation: The basis of the subcontracted services and in this case material, to Bethlehem Steel Corporation (Behtlehem) by UE&C was the UE&C document, " Specification t for Furnishing, Detailing, Fabri,cating and Delivering Reinforcing Bars" (Reference 4. ). This document was issued originally as Rev. O,1/24/74 and has undergone ten revisions since that time. A detailed review of the important design information relative to this specification was mad'e by the team with respect to the design consnitments of the FSAR and the discussion was noted previously in Section 4.4 of this report. Since the Seabrook project was committed to use the ASME Boiler and Pressure Vessel Code, Section III, Div. 2, the specification imposed stringent requirements for quality assurance. No distinction was made in the specification so that all work and material supplied by Bethlehem was to conform to the ASME Code. The team placed specific emphasis on the manner in which Section CC-2700, Materials Manufacturer's Quality Assurance Programs, were reviewed, accepted and imple-mented under the requirements of the specification. The rason for this was due to the fact that the Seabrook Project represents the first incorporation i i
- d.s/rq 4.7-9 of the ASME Code, Div. 2 into a plant proceeding to completion. Bethlehem, prior to the start of the Seabrook project, had addressed 10 CFR 50, Appendix
. B in a quality assurance manual which was undergoing rework early in 1974. An.early version of the Bethlehem Quality Assurance Manual was submitted with the bid in January of 1974 and subsequently reviewed by UE&C. As a result of this review a series of meetings and discussions ensued in order to obtain conformance with the specification. In addition, to meetings held at UE&C
= . c , ,. .-
offices on January 23, 1974, meetings and reviews were heldAt the Philadelphia Bar Shop of Bethlehem where a QA Audit check list was used to perform a Facility Survey conducted by a QA Audit Engineer from both YAEC and UE&C. The following day similar discussions and audit activities were held at the Steelton, Pa. facility of Bethlehem. The results of these discussions and audits were documented by YAEC and UE&C as well as by Bethlehem (References and ,respectively). The Bethlehem report highlighted the following items. (1) Interpretations of quality assurance by YAEC and UE&C is more stringent than any seen to date. (2) QA Manual submitted with the Bethlehem bid proposal was considered unacceptable in its form at that time because of: (a) Separation of QA for steel production and-detailing / fabricating not clear.
(N/ff 4 '7-S (b) Certain items should be removed from the QA Manual and developed into writt,en quality procedures including such items as tescing, instrument. calibration, drawing and detailing standards and document checking, review and approval. (c) Needed improvements in document control. (d) Needed clarification of stop work authority and chain of command. (e) Needed clarification on control of non-conforming material and iden-tification of material by heats and controlc4 ic'edEoboo J SN2 '?
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(f) Definitive information on the control of quality in the Engineering Department. (g) Needed personnel / position descriptions and individuals' q'ualifications. (h) Needed changes sn the Bethlehem Nonconforming Material Report forms. The report ended with the following statements.
"J. W. Singleton (YAEC) invited us to visit their facility for general review of any of the Quality Assurance Manuals in their possession as an aid in our preparation of manuals.
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V4/39 4: '?- c. It appears that our present thinking of the Quality Assurance Manual is right on line provided we have documented quality control procedures available such as described above. I believe they have given us some good pointers which should be to our advantage in the future if we
, implement them now."
FollowingtheseeffortsBeklehemcontinuedtoworktowardachievingan
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upgraded quality system including a revised QA Manual and a series of quality procedures based on the interfacing which had been taking place between the three major parties on the reinforcing steel. At the same time Bethlehem was providing comments to UE&C on the specification which had been issued for bidding purposes. A series of correspondence was reviewed in the Bethlehem Seabrook project correspondnece file (File Folders 1-4) over the period from January 1974 through the date of the contract, May 15, 1974 to October 25, 1976 when the Bethlehem QA Program for Seabrook 1 and 2, Rev. 2, 9/26/76 was approved for Fabricated Rein-forcing. These documents included other audits performed by UE&C at the various locations where Bethlehem was doing or was to perform work on the Seabrook Project. These documents are included as references to' this report (References 4. through 4. ). The first transmittal of was ' engineering drawings to Bethlehem were.on July 18, l975 (Reference 4. ) Ke clebili af (de %e 1 and reinforhing stehl was author) zed by UE&C on June 3,1976 (Reference 4
- 4. )'. It was noted in reviewing the information related to work being processed in the various Bethlehem facilities that the.first reinforcing steel _ shipment was made from Bethlehem's Boston Shop on August 3, 1976 which was prior to the approval of the QA Program by about 3 months.
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. In addition to the detailed review of the controls exercised by UE&C over Bethlehem in performance under the contract and the technical and quality requirements of the specification, the team reviewed selected portions of Bethlehem Quality Assurance Manual, the Standard Quality Assurance Program Manual for Fabricated Reinforcing Bars, the Facility Manuals and the Quality Assurance Procedures Manual for Fabricated Reinforcing Bars (References 4.
and 4. ). The QA Manual (Steel Plants) provides the statements of quality policy for the entire Steel Operations Group and functions as a single source document. . Quality manuals, procedures and instructions at individual plants and shops emanate from this QA Manual. The responsibility for quality programs for the corporation rests with the Office of the Chief Metallurgical Engineer of Steel Operations. As part of the Bethlehem Plant Committee System _there is a Corporate Quality Assurance Subcommittee which serves to develop and coordinate quality assurance policy. The Bethlehem QA Manual is in' a form so as to address several MIL Standards, ANSI N45.2, ASME B&PV' Code, Section III and 10 CFR 50, Appendix B. Section 5 of the Manual includes the specifics of the corporate policy on the quality assurance program as applied to fabricated reinforcing bar. In summary, the following points are addressed in the Manual. (1) Fabricated Rebar Quality Program is coordinated by the Reinforcing Bar Engineering Group.
(4 /99
, + 7- y (2) The QA Program for Reinforcing Bar Fabricating Shops is consistent at all shops in the country.
(3) The Chief Metallurgist at each plant coordinates reinforcing bar QA policy but.at shops (fabrication only) it is addressed by on-site Engineering or a separate quality group. (4) Audits, final disposition of corrective action and control of records are performed by the Bethlehem Home Office Reinforcing Bar Engineering Group. (5) The. management review fcr the Fabricated Reinforcing Bar QA Systems is i performed by the Corporate QA Coordinator. 4 The Standard QA Program Manual for Fabricated Reinforcing Bars addresses fifteen of the eighteen criteria of 10 CFR 50, Appendix B, noting that Sections III,
. IX ano XIV which are Design Control, Control of Special Processesfand Inspection,
,(m V 2, Test and Operating Status respectively, do not apply to the services or products of Bethlehem Steel Corporation. The team did not disagree with the exceptions taken by Bethlehem. The Manual p~rovides a description of the QA organization.
and the authorities, responsibilities and duties of. persons performing the QA functions. It also sets forth the Bethlehem policies for satisfying the-QA Program requirements and references.the other Bethlehem procedure manuals which describe, in detail, the procedures and instructions for accomplishing the activity.
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- 4. 7-9 l
l The manner in which the QA Program Manual for Fabricated Reinforcing Bars becomes a specific quality document on a project is that during the proposal o'r bid stage the Standard Manual is submitted as an uncontrolled document 4 'and forms the basis for specific project quality assurance items relative , to the contract. With contract award the manual is amended, if required, using , i an-appendix to provide conformance with the client's specific project quality assurance . program. At that time, the Manual becomes a, controlled quality document. i
- - Bethlehem's next level of control consists of a series of Facility Procedure Manuals aporcpriate for a given activity and a given Bethldhem facility. These address three basic activities: steel production, detailing reinforcing steel and fabrication of reinforcing steel.
The remaining Procedure Manual is known.as the Quality Assurance Procedures Manual for Fabricated Reinforcing Bars.- This is a standard manual which details-the procedures required to implement the QA Program Manual for Fabricated Reinforcing Bars including the monitioring of the work procedures i l of the facility manuals for' detailing and fabricating reinforcing bars. 4 The team reviewed selected portions of these manuals in order to assess the F
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yet.h system programmatic aspects of Bethlehem's peogreegnd then to assess manner in which lecl Bethlehem has performed and control its activities which impacted the design of the Seabrook . facility,=tc Jmir p,v3+am The following sections of the 4
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Standard Quality Assurance Program Manual for Fabricated Reinforcing Bars were i
, ,- n - , - - - , , , . , , , , - + . - - - .
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+ 7- m reviewed for conformance to 10 CFR 50, Appendix B for the specific use in reinforcing steel detailing and fabricating activities.
Section Ti tle Rev. No. Date 1 4~ Instructions and Procedures 2 1/1/79 5 Document Control 2 1/1/79
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8- In~spection 2 1/1/79 12 Nonconforming Materials 2 1/1/79 13 Corrective Action 2 1/1/79 s 14 Quality Assurance Records 2 1/1/79 15 _ Audits 2 1/1/79 16 Special Contract Requirements 2 1/1/79 including Appendix A, Special Quality 4 4/26/79 Assurance Requirements for Seabrook Station Several items are of note as a result of. the review of these manual sections. Section 8.2 related to the Engineering Department requires a scheduled review to be conducted on the current work of each _ detailer assigned to nuclear projects. The review is conducted to assure conformance to ACI, CRS'I, Bethlehem Steel Corporation Standard and the project specifications. This was viewed by.the team-to reflect Bethlehem's full commitment to a quality _ system and assuring - that the detailing of reinforcing steel is being done as required by the Project documents. In Appendix A the special requirements imposed by UE&C in Section 3.2 of the specification related to Cadweld sleeve criteria fit were reflected.
- . ~ - - .-
- 9. 7 ,, '!+!24
< The requirements of CC-5340 of the ASME Code regarding visual examination for transverse cracks which were part of the specification were also reflected in the special requirements of Appendix A. With regard to bar testing, 4g Bethlehem included in Appendix A a procedure defining the mechanical testing Na
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of reinforcing bar to meet ASTM A615, the ASME Code, Regulatory Guide 1.15, , ;,
), '!@rd.,
and the specification. Also contained in the Appendix is a commentary on the - Reinforcing Steel QA program, mainly emphasizing the traceability of material from the twe it is produced in the steel mill to the time it is fabricated, shipped, received and stored on-site. l With the Quality Assurance Procedures Manual for Fabricated Reinforcing Bars the following procecures were reviewed. 1 Proceduce Ti tle Rev. No. Date II Document Control 3 2/1/79 III Review of Placing Drawings 3 -2/1/79 ! IV Inspection , 4 2/1/79 w' VII Nonconforming Items 3 2/1/79 VIII Corrective Action 2- 2/1/79 X. Audits 4 2/1/79 All of these procedures were noted as being very comprehensive and detailed-and provide an excellent tool for the personnel _who must execute these procedures i as well as those who use them in the review, inspection and audit functions. l l
a
~ -
//ulgg 47-/2 Two additional procedures, which were specifically associated with the work completed for the 5eabrook project were reviewed. The first was " Quality Control ' Procedure for Fabricated Reinforcing Bars for the Bethlehem Plant, Engineering Department, Detailing," Procedure No. I. , Rev.1, 6/1/81 (Reference 4.._). The second was the " Quality Control Procedure for Steel Operations For In Plant Shop for Fabricating,". Procedure No.1, Rev. O,10/14/77 and the (2eWence 4. - ).
Addendum for Steelton Plant, Rev. O, 11/28/77fg These were noted to be adequate to control the detailing and fabricating work that was done and is still , unde rway. In addition to reviewing the specifications and manuals documenting quality , control anc ccmpliance with the pertinent codes and standards, we also reviewed shop drawings, generated at the Sethlehem Steel offices in cr. der to verify. their ccnformance with the design drawings produced by UE&C.
. v e e_
We learned frem the Bethlehem staff that the reinforcing steel which-have-been detailed at the Bethlehem home office were for the following elements of the containment structures: (1) Reactor Pit (2) Containnent slab, El. (-)26' (3) Personnel and equipment hatch I i l
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- 4. 7-!]
(4) Containment dome - Unit #1. has been completed, Unit #2 is being worked on. Exotic bars (around openings and out of plane bending) are detailed at the Philadelphia office.. (5) Primary shield wall, approximate elevations (-)25' to (-)2' (6) Containment building slab, El. O' Detailing of reinforcing bars for other structures has been done either at the Boston or Philadelphia offices. During our inspection in Bethlehem, Pa., we reviewed scre of the drawings pertaining to the reactor pit and the contain-ment dome, Elevation 119',f the spring line an[ #pex. The list of drawin5s which lave been reviend during the, inspection is contained in Section 7.4.1 (References 4.._.to 4. _ ). He hNe-f[en informed that the major difference between the Unit 1 and Unit 2 drawings is the fact that in Unit 2, by increasing the length of some of the reinforcing bars, the number of caldweld splices has been reduced. M V'W N"# "O .< ypfC ;.ne/ Of(C malin imywmeb ' We A'y# A' Due to complexity of the reinforcing in the congested area of the reactor pit, the detailing was done using a model, which was built by UE&C, showing all the' reinforcing steel in actual position. The Bethlehem detailers studied the redel and then generated the shop drawings. While reviewing Eethlehem Drawing No. 017RM31,- Rev. 4, dated December 5,1978 (Reference 4.___.) and comparing it with the corresponding UE&C design drawing, Drawing F101402, Rev. 13 dated March 24,1981 (Reference _4._), we observed , k
i,/)~q 4.7-/+ T that the spacing of the horizontal stirrups which on the design drawing was wherds +/seSPJdni Was 16" apart es shcwn on the detailed shop drawingges'8" apart. The total amount df the reinforcing steel remained unchanged in spite of the change in spacing. The design drawing had not been updated to reflect the change ed in spacing. The reinforcing steel remai esignated in the design drawing as 2x4-#6 0 16". We found that this is a violation of Administrative Procedure
#29, " Document Control - Foreign Print System" Section 8.6.2, Rev. 7, dated April 12,1983 (Reference 4._). In all of the drawings reviewed this was ws the only case where a discrepancy between the design and shop drawing eed+
4e found. This was noted as a finding, but had no generic implications and 4 bc !o was judged g an isclated instance of lack of consistency and maintain up to date documents (Finding 4-21). vE / C de'm/ "W N AN
*7'J' 4 r eAre/ chy 47 A review was made of the nonconformances issued against two of the shops within the Bethlehem organization which provided scme of the fabricated material to the Seabrook facility. NCR's for the Albany Shop for 1982 were ex5 mined.
Fcur separate reports had been issued, three of which related to incorrect bends which resulted in scrapping the material and rebending from new bar stock and the fourth being an incorrectly recorded heat number which was corrected. NCR's for the Steelton Shop for 1983 were examined. Eleven separate reports had been issued. Of these eleven, five involved bending errors, three involved cutting tolerances, and one each involved a detailing error, mislabeling and missing bars from a bundle. Based on the size of bar and the tonnage of rein-forcing steel involved the team judged the number of non-conformances to be low. In all cases corrective action was taken before any of the neji-conforming items had been incorporated into any safety-related structures.
4
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- 4. 7-/S
. Based on the review completed and the work observed the team concluded that the licensee's design commitments had been clearly transmitted to Bethlehem via the specification and the engineering drawings and details. Letter and meeting comunications also served as an important part of the total process of providing design interfacing and design input. Bethlehem was viewed to have in-place a good quality system with appropriate quality standards and procedures.
The team's sample review indicated that Bethlehem had also executed these pro-cedures well. A system for the review of shop and placing drawings existed as was being effectively implemented in accordance with the Quality Assurance Procedures Manual. A fully adequate system to document and control the records and design changes, thus assuring that all the latest updated input data was being used for the development of shop and placement drawing exists. The Drawing Record Card, the Transmittal Control Form Letter and the Order Entry Record Card have been the keys to good document and records control. Based on the team's observations it is evident that the Bethlehem audit system has been effective in identifying some random errors and assuring that corrective action has been taken, l d (gf c4 b): As a result of the team's review and observations of the work of Bethlehem Steel Corporation on the Seabrook project it is the conclusion'of the team that the necessary elements of design control have been in existence during the detailing and fabricating of the reinforcing steel for the plant structures. Additionally, we have concluded that these controls have been adequately imple- - mented so as to assure safe structures. f
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Document Name:. .
- ,SECTION 4.8 - SEABROOK IDI .
Requestor's ID:
.EILEEN Author's Name:
G. Harstead Document Connents: As Built Conditions anc Surveys 4 S
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4.8 As Built Conditions and Surveys The objective of'this portion of the inspection was to ascertain: (1) How the changes generated in as-built conditions such as structures, systems and component are processed by the UE&C and the contractors. (2) How the final loads' resulting from location of pipe supports, electrical cable trays and ventilating systems, including those not specifically
- considered in the original design, are verified.
(3) How the drawings and identified supporting documents are updated, main-tained and certified, so that the completed work reflects the as-built conditions of the plant for future reference. The team first reviewed the procedures which were in-place to control this-area of plant design and construction. Among the documents which control as-built conditions of structures, systems and components we reviewed those which seem to be the most essential in the process. Those are: Administrative Procedure No. 39, "As-Built Documents", issued on November 17,'1980 (Reference
- 4. ),LAdministrative Procedure No. 15. " Changes to Engineering Chang ,
huthorization", issued on September 8,1977, Revision with numerous later isions (Reference 1. ). Technical Procedure No.11 (TP-11), " Minimum As-Built Record Drawing Listing, issued on April 29,1983(Reference 4. ), [ Field Administration Construction ProcedurefFACPj No.10. " Procedure for , eld Calculations", issued on March-11,1983 (Reference 4.
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obes) *E- FACP~IO y
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Project Instruction for Handling UE&C/ Contractor Nonconfonnance and/ F4c/%,A/e./, 4 or Deficiency Reports",' Rev. B, dated July 22, 1983 ference 4. ). Currently Administrative Procedure No.15 has 18 revisions since the original issue, the latest being dated August 17, 1983. It describes how questions and changes to design documents, deemed critical to support on-going field activities, are initiated, processed and resolved. It provides the criteria which the proposed changes must meet in order to be approved, the flow charts which describe the sequencf by which various site questions are processed and the forms which should accompany questions raised by the contractor. The questions may require an oral response, the response for infonnation response (RFI) or may require an engineering change authorization (ECA), depending on complexity of the problem. The classification regarding oral. communication, , RFI's and ECA's can be described using the following guidelines: On . j (1) If the question 4 requires an explanation or clarification, the oral response is sufficient. CRF*$ (2) Request for information is prepared when an oral response is not sufficient t ha.vt
- anddesigndocumentsarenotaffectedwhichmightpbegissuedbyUE&C[ site
, or Home Office or drawings issued by $re manufacturerst- veado".
(3) When the question / response requires changes (or exceptions) to engineering documents, such as drawings, specifications, or calculations, the contactor submits a proposed ECA. i s i
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The.ECA's are subdivided further as follows: (a) On-The-Spot ECA's etcfr may be used to resolve all the items except those involving generic problems and those requiring YAEC approval. Any Minor ECA (see below) may be issued On-The-Spot. (b) Minor ECA's which are of repetitive in nature, e.g., involving movement and arrangement of sister splices in congested area to clear interferences of reinforced steel, modification of approved famwork or substitution of higher strength bolts than the design requirements, that have been reviewed and concurred with the Home Office Engineering, YAEC and QA as being appropriate for release. (c) Major ECA's are those which are not classified as minor and in turn they are subdivided into two categories:
- 1. Major specific case ECA's
- 2. Major generic case ECA's.
ECA's and RFI's may be revised or voided by modifying and reissuing the ECA/RFI fom or, in certain circumstances, by the use of the Continuation Sheet. On the Continuation Sheet the affected documents c$ listingg on the ECA/RFI form, of =11 the ace"- -ts th:t-must be revised or from which an exception is , taken as a result of an ECA issue :sst be provided. l
n ._. - 9.e.-# If/Th ~ 2 l l One of the important diffeiances between the RFI's and ECA's is that the RFI's must not include Affected Documents while the ECA's must include them. Thus when an RFI becomes an ECA (when it has been decided that the change requires change of engineering documents) a new ECA/RFI form is issued together with a Continuation Sheet on which all of the Affected Documents must be listed. Interdisciplinary coordination of all disciplines involved in the ECA is assured , by the requirement that all disciplines that are responsible for the documents listed under Affected Documents must review the ECA. The AP-15 is used together with the AP-39, "As-Built Documents". AP-39 identi-fies the drawings and other supporting documents to be updatied, maintained and certified that the completed work reflects the as-built conditions of the plant. This assures that the documents can be effectively used for engineering reference in the future for various reasons such as future plant operations, start-up testing, maintenance or modifications. The procedure contains a listing of UE&C documents to be revised to reflect as-built conditions as received from the Construction and Start-up departments. Its Attachment No. 2 provides detailed information in that respect and it addresses inspection elements, including piping configuration, location of supports, as-built i UE&C construction drawings and as-built tolerances. The procedure provides very detailed and complete information regarding the type of documents which must be revised to reflect theYAs$ Built condition. Included in that category are vendor documents which must be revised to reflect the "as shipped" condition of the item. In case of a modification in the field the drawing
; must state what is." field modified" and provide the reference to the foreign l
I
4,p_g dah print which shows the "as shipped" condition. Any changes should be processed in accordance with AP-15.
- ~.
F AP-39 also provides directions to the UE&C design groups such as the g Mechanical Analysis Group (MAG) and the Pipe Support Group (PSG) to perform sd / s NT g*! ' M @sp the final configuration verification analysis documentation for pipe stress # ,a
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. r P</ /) analysis for ASME Safety Class 1, 2, 3 and B31.1 Critical Piping and NNS-1 'l' I
*p W Pipe Supports. The data which should be verified are such as the as-built stiffnesses of supports and restraints, attachment points of supports of L-supports or restraints to the structure, including ARS verification, etc.
As-built documents are processed through the Field Office Document Control Center (Field DCC) as shown in Figure 4.8-1. Each contractor has the responsibility to provide the As-built documents. Piping and Pipe Support As-builts are handled through UE&C Power Engineering. The Field DCC records the approximate information and processes it further to the Home Office Document Control Center as shown on the chart. We have been informed that the AP-39 is under review and the future revision, No. 5, is expected to be issued by the end of February,1984. 7Te ressesb 7Te c % es M nod
/;vesved 6y tAe kryr.
i $&re, in Attachment No. 3, contains the types of conditions or changes i l which do not require as-built information and incorporation .into UE&C drawings. In this category, we found the reinforcing steel changes. Aga4 eye inquired why an important item like reinforcing steel is not required to be recorded to reflect as-built conditions and we P$c = informed that this item applies to the cases when the amount of steel is the same as stated on the design drawings but for some reason, usually because of local interferencesjsome of . t
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. 48-6 I
the reinforcing bars have been moved to one side or the other. We expressed our opinion that the listing does not restrict the discrepancy between the design and as-built conditions in any way and such a deviation could consist of providing reinforcing bars of smaller cross-sectional area, omission of so e ch*t A*"Q e %=0 "1 Y kV reinforcement in some area altogeker or e~i.6wisq We did not received a %1 satisfactory explanation regarding this matter and we consider this a serious shortcoming of the procedure. We do agree that there are many field situations where a change in placing of reinforcing bars may be tolerated and even some.- times necessary. We believe, however, that the procedure should qualify this statement to avoid gross deviations from the design requirements which could result in an inferior or inadequate structure. The details of processing as-built documentation identified in AP-39 are described in the Technical Procedure No.11 (TP-11), " Minimum As-Built Record has n,+ 6n Drawing Listing". This procedure was issued on April 29, 1983 and w n never-revised. It is referenced as Appendix No. 4 in the AP-39 and its purpose is i to interpret the technical requirements of AP-39 and to establish " detailed identification of the specific UE&C Construction Drawings and UE&C approved Foreign Prints which shall be /As-Builtf by the appropriate Seabrook4 Field (Organization. Additionally, the purpose of TP-11 is to organize the drawing listing on a Work Package concept to allow effective engineering verification against the design basis condition and subsequent incorporation of thetA s-built data into the design drawings. The procedure identifies six disciplines and in each of them there are two individuals named as the coordinators: one in the field and one in the home office.
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- q 0( E Several organizational entities are involved in these programs at UE&C. The beam verification program, which involves a complete check of the structural steel, Site Engineering located at the Seabrook site is responsible to respond to certain ECA's, RFI's and Nonconfonnance Reports (NCR's). If Site Engineering does not have a proposed solution to offer, the responsibility fcr resolution of the item is then with Site Support Engineering at the Philadelphia UE&C offices.
In some instances the Structural Group in the home office may become involved. YAEC also participates in resolution of these items when there is a potential for a major impact upon the project or they were responsible for the original p# eview on the items or activities . involved.
\
f j' (1) Structural Steel keyam [' The procedures for thi's program are described in " Guidelines for Beam Veri-fication", dated September 19, 1983 (Reference 4. ). The beam verification j program was established in order to ensure that all the structural steel beams c'[ are designed for all the imposed loads. The treatment of live load is in con-e', r formance with SD-66 (Reference 1.3), Table 4.2-1. Note 1, to Table 4.2-1 states
'he r that uniformly distributed live load shall not be considered with seismic load ,/ conditions except those loads which are marked permanent are included in the # calculations.
l l The design of the structural steel beams for the Tank Fann Area as provided in Calculation No. WB-61 (Reference 4.34) was based upon using the uniform snow l load which is considered a permanent live load. In this case the procedure in which temporary uniform live loads are replaced by actual loadings was not .
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The beam verification program is ddivided intej$womethods;namely, computer , and manual calculations. The computer calculations are performed using the 1 STRUDL c'omputer program. The beam to column connections generally are shear L type connections which are made by angles welded to the beams web 'and field bolted to the column or girder. Horizontal forces are taken by means of bracing thus eliminating the need for beam moment connections. The beam to column connections are; therefore, modeled as hinges. The loadings used are: i (1) dead load (steel and general dead load)
- (2) permanent live load (for seismic inertial loads one-half of the snow l mass is used) .
(3) seismic amplification (4) pipe support loads and for piping of 4 inch diameter and larger (5) uniform loads for piping of less than 4 inch diameter-(6) cable tray and bus direct loads conduct loads A
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The Structural Analysis Group (SAG) has produced Amplified Response Spectra y
-(ARS's) for various elevations of the building. Vertical ARS's were developed i which accounted for the vertical response of steel beams. These ARS's are used in order to qualify equipment which may be located on the interior locations.
.I l
SAG has also directed that the ARS's be used in the design of the steel beams. l The vertical accelerations are obtained from ARS's. One ARS will detennine the acceleration at the support while the other will be used to find the acceleration at mid-span. These vertical acceleration values are developed i
! j from the appropriate vertical ARS's by selecting the 50 Hz frequency response
- for the 4% and 7% equipment damping response curves, for the CBE and SSE, e
{ respectively. l .
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{ The horizontal acceleration values used for beam design are taken from the l ' \ i 33 Hz frequency response for the 4% and 7% equipment damping response curves i i for OBE and SSE. From these values, a uniform seismic acceleration is established or design. Because the bottom flange of structural steel is used for the attachment of pipe l. !' supports, horizontal loads applied normal to the beam axis can'cause torsion in the steel beam. UE&C's procedure calls for checking whether the supported slab remains in contact with the top flange of the steel beam. If the beam were to l deflect more than the slab, no capability of transferring torsion to the slab could be assumed. l l l
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4g4 I'Y29 The Tank Fann structural steel has not been addressed by the beam verification program as yet. The team would recommerd thit thf s be done subsequent to any reanalys'is for the seismic loads as described in Section 4.2 and addressed in 4 Finding 47 -17 ). (2) Reinforced Concrete
' No specific overall program currently exists o} assess the final loads resul. ting on concrete structures which would encompass pipe supports, equipment, cable trays, and other systems.
Under AP-39 certified As-Built rebar drawings are not required. The footnote in the Attachment 2 of AP-39 states that contractor drawings >will be site
'?
foreign printed, marked for information and turned over to Home Office
@ E.C.
Engineering andy. The method of monitoring and recording of rebars cut or damaged is described in the Administrative Procedure No. 38, " Cutting Reinforcing Steel in Permanent. Concrete Structure", issued September 5, 1980, ( 2ebeae c. 4. ') . l revised on July 31, 1981 4 ur 0 inquiries why the drawings affected by the damaged reinforcing bars are not recorded by 'the DCC in the field or the As efescr/ Led /.rfeq il m.s A"*l Home Office did not produce satisfactory results.g AP-38 establishes N,f Se/cEy/n-eewny is nesh-l^ responsibilities of organizations for approval of cutting reinforcing steel ff,,f , . doe bdk during drilling into permanent plant concrete structures. tr Procedures for curring reinforcing bars can be divided in two categories: A l
-- ....-,.:.... .- : .- - L.. : -
r - 9;8 -// If/7h 1 ha! l (a) When Reserve Capacity Forms (the foms which list reinforcing bangas
. required by calculations, those supplied on drawings and the reserve excess of the bars), are available for a given location, and 1
(b) When such forms are not available. I When a Reservice Capacity Fom for a given area is not available, the approval h 04(cce i of all reinforcing steel bar cutting must be reviewed wifh the ;r ."A.Engt ::9; , ( h e Offi M of UE&C. They check the design calculations to determine if there is an adequate margin avatlable to pemit the proposed reinforcing bar cutting. If it is permissible, approval of such a cutting is documented by
- engineering change notice (ECA) or nonconformance report (NCR). When a Reserve Capacity Form for a given location is available,.the Resident Construction
, Engineering Group assumes the responsibility for approving cutting of reinforcing steel bas,ed on the information contained in the Reserve Capacity Form. - AP-38 states, in Section 3.1, that when the Resident Construction Engineering Group j approves reinforcing steel cutting, these approvals are documented on the Site
. ApprovedChange(SAC). We learned that the SAC forms have been since discon-tinued.: d th ref [obYer7a $ $ !# N $ r:;:-dfag upt tfag th f e Revision 1 of AP-38, dated July 31,1981x Ass #*/ /**' y#d Oh*b
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, fge 4 i WehavebeeninformedbytheUE&CstaffthatsincethetimewhengACg::k:n ean i discontinued changes resulting from cutting of reinforcing steel have been k
treated as EC9's. ' I . l l' I l .
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- i. e n 4*P'bl i We reviewed the " Project Reference Manual" (TP-23) Supplemental Information I (xarAirencef- )
for Design Change Program,3Rev.1, dated November 28, 1983 (date of Rev. 0 l not listed) which contains a list of Minor Change List (Section X). Since
- the list does not include reinforcing steel cutting, we concluded and concurred i
. with the UE&C staff that these changes must be treated as major ECA's. This
-F classification reinforces our believe that Attachment No. 3 to AP-39 (listing of types of conditions or changes which do not require as-built infonnation) j should eliminate item 1, " Reinforcing-Steel Changes" since such changes might result from cutting of steel rebars.
! In our inspection we selected few specific cases as the examples by which one could verify how the process of handling the as-built works. In one case, (& 4verece 4.- -)
- isupplied Material Deficiency Report (SMDR) #357 4 was filed by the contractor -
} reporting that a structural steel beam has a tear in toe of flange. The case was processed by the field office and found acceptable. It should be mentioned that according to Rev. 3 of the FACP-1, dated October 4,1982, processing of i the SMDR would have been using the same procedure as for the Nonconformance J Report (NCR) and Deficiency Reports (DR). The case discussed here was dated + June 4,1982andtheRevision2oftheFACP1didnotrequi)econcurrenceof&eo,ee 4.
- the Home Offico. The other case, NCR #2584,3was concerning concrete cover ;
over the reinforcing bars, same being too large, sjme being too small. Similarly to :::: c' th SMDR #357,it was resolved in the field. In both ! The third cases an unofficial concurrence CiMureece 4.-of the Home) Office was obtained. !' case examined was RFI #593027A dated June 2, 1982 concerning discrepanicy (n.Sd 4 -) .sppra' ",vI % . 1 betweenUE&CDwg.Fy01748gndCivesDwg.FP)5407-13 Sheet E-58 El atA /\6( y t". Another question on the same RFI was concerning discrepancy between UE&C [ ,
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( _ kJerede 4- ) (g h e 4. , ) Dwg.Fj01750gndCivesDwgFP-15407-13atEl.63{#.3 In this case the dispositicn was provided by the Field Office. (W* The last case of as-builts reviewed was ECA(5f809,pted 4. ii 26,1562,
** )
concerning vertical bars in line 2.3 wall which caused a bar conjestion. As rec,uired by AP-15, the ECA/RFI Form listed the affected document and Home Office concurrence was marked " accepted". The program which UE&C has embarked upon in order to analyze and control as-built conditions has a lot of good features. The controls documentation, distribution of responsibilities appear to be effective and practical. It is regretable that this program was enacted so late in the development of the plant. We are aware that in the early stages of construction of the plant the control of the as-built conditions was not sa good as could be desired. In the memorandum ItisadmittedbytheUE&Cofficialsas)well. (.Refwence 4 ---- , dated September 6,1983, MM-14575A4 ere th is a statement "It is recognized that there are a good number of historic ECAs which, based on the judgment of the engineer at the time, were issued for which there may be no calculations." The project has defined a program to address these historic ECAs and develop calculations for them as necessary"... We thin that this is a worthy effort which when completed will contribute to improve confidence in the level of quality control of the plant.
Y
~
i fAC To continue ttr review the process for controlling as-built conditions in reinforced concrete the team selected four Engineering Change Authorizations cenerefe (fCAts7 dealing with coring 4and cutting of reinforcing steel.- A series of four s$- c,y.,,eene,y ckye AMonahans-
-EGA4 3were ' selected in theyDiesel peneratorpuilding f.or review.
(n, r ) (1) 2/0772D 4 was initiated on (date initiated missing) by the h krea iSuperintendent. The problem was defined to be an interference of service air lines as hstalled with the fire wall partitions. The solution was issued November i,1982 and included cuttin , pping and grouting the existing penetratior, in the floor at the l' of e/esa,+orr, boring two - 14velAccre nch 2"f diameter holes, reiocating the air lines, air connectors and valves, He j> deleting pipe supports and grouting the lines into cored holes. The affected 4 I documents were lis'ted and the backup reference which permitted the cutting of reinforcing was provided. In addition, the requirements for recording j andreportingtheas-builtconditionwerealsoprovided'This,had been properly reviewed by the Site Review Group and then by the home i office where final concurrence was made on May 18, 1983. The field nar:;0nnel reported the work completed on November 16, 1982 and provided sketches and details of the cutting and the necessary engineering data. One core bore cut no reinforcing and the other cut one #6'bar. (A 4 c.e 4. - ) . 7 (2) 06/1670Bgas initiated September 12, 1983 as an On-The-Spothby + n~,e// ne A,+c% wwa the Project Manager for GFPS. The core drilling was defined as being required in stair walls C&D to allow for installation of new redundant t {
fr/td 4 6-f5~a.
!~ yko fire protection system lines. The request was made for 4)-6 inch diameter
' lAc
-cores to be' cut through a wall section around the stairgwell near E4evat4cn kkelevakon i 26/1. Approval was given on October 18, 1983 after telephone concurrence ,
with home office and the completion of the actions by the Site Review - Group on October 17, 1983. It was further stipulated that one piece of reinforcing steel could be cut each way N each face for each core location. i In addition, sheets and instructions were provided so that the as-built j work would be accomplished in accordance with AP-39 and specific l ' i retede m Mc4 har' fo r-information on actualpcuts information would be forwarded,ptr engineeringx redeJ-The completed forms with the as-built information were completed on j September 30, 1983 ,and received by Site Engineering on October 3,
; p: m~eemu~
1983, showedim' ore reinforcing steel cut than allowed. All other aspects 4 i of the appropriate procedures had been followed based on the team's i i review of the information. t 5 (febec 4.-------) , 59/4010A was initiated December 9,1982 by an engineer from Perini ([) Power. This requested authorization to cut rebar,in order to install i a Hilti bolt for a surface mounted plate% on a floorgEj. evation 511 feet. je l A / ~4e play had % rTgW mo Wue40 sche-relocation of-the boltsto clear3the reinforcing9 ,ould 3 ,7;violate g u , ,, g /cca re sec , l the centerline of bolt to an adjacent embedded plata distance criteria,u/ eaves '- i fermiss;en h wf reindreinf sfer/, . j Pennission was granted at the site on December 17, 1982 and home office I i concurrence was made on February 1,1983. This allowed cutting of one ' i yee\
, piece of reinforcing each g way.. top and bottom an,d required submittal of l data via an attached form after the installation had been completed. ; foaer j The as-built information was submitted by Perini gen May 20,1983 indicating l ene .
that 4-f7 bar was actually cut. A sketch was provided to establish the 4 4
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N7/8& exact location of the cut, identify the affected drawing and peel rei.Jorewj ded Bethlehemgdrawing as well as the4b ar type. No deficiencies were noted by the team. k 73/4572C was initiated December 3,1982 by a field engineer from (g) Pullman-Higgins.nts deea~enfgequestedpermissiontocutrei area near a blockout through a reinforced concrete wall due to the fact that numerous attempts to locate Hilti bolts among the congested rein-forcing had resulted in several abandoned holes. A relocation of the sene.a$ plate for which the Hilti bolts were tognchors required a redesign of the support,which was toAe7elded-ttrthe_surfacepInted11are. The
. change was completed, reviewed and finally approved on March 23, 1983.
The home office engineering concurrence was completed on June 27, 1983. Again the field information as a result cf the relocation and possible I . reinforcing steel cutting was requested for review via the cor,ing/ cut reinforcing sheets. The information was provided to Site Engineering on January 14, 1983 showing the necessary infomation and indicating that one one be 4 1-#11 and -#8 reinforcing steel had been cut in the drilling process. The team found no discrepancies in the information. After completion of the review of the information contained in the records related to these , the team went into the field to verify all information that could be checked given the current completion status in each of the areas. Of particular concern was the information contained inh 0h6708 tkahrpwtf which indicatedA more reinf cing than pemitted had .ieen cut.ami-7fie resolution co' khe usessins of this wa.> s mportant in judp eg4 the actions on the part of UE& in response ,
. . . ; .: .= =.: . - a ;- . . __
. - .: . 2::.
///7/24;
'=~ 4 8 -is 9 to the data. All locations associated with thes s were reviewed in detail, checking dimensions and where possible the insife cut surface. if a core were
- involved except fo CA)59[010A for which the drilled anchor bolt was sandwic
! between panels of fire stop walls at the floor line. - !- I All as-built information which had been sent back to thehCivil/ Mechanical Services Engineering Group was field checked and found to be correct. The
- team then followed up to determine that the information provided was being
{ systematically recorded and utilized. During this field review questions
- . arose on the status of, and apparent incorrect fabrication of support i e f l 9276-12G-38whichwasassociatedwith(ECA)77572C. After a review of field
- ' records and discussions it was found the support was on"fiold and the support
_ cst re;&ectne was known to be incomplete. Theincoming&datafromtheas-builtsheetswere being ' logged and then transferred onto reproducibles created from the Bethlehem 8#I shop drawings'for reinforcing steel so that a permanent, consolidated record of cut reinforcing is being developed. A review of the'information' relative , to the team's concern about additional cut reinforcing resulted in establishing thatthecuttingpermissionhadnotbeenexceede'd.i-athetThedetailedshop i , drawings indicated the coring was done in a splice zone and that'the pairs of cut. reinforcing seen in the as-built data represented actually one bar, but j since the cut was in the splIgzone, both legs had been cut. Similarly, from ) the detailed shp drawings and information submitted inh 73/4572C it was clear. that several of the cuts were the ends of supplementary diagonal reinforcing at the corners of 'the wall blockout for. air ducts. The information gathered
- in this program can be utilized to compare against known margins of reinforcing
'bl steel. Where the margins are not sufficient, the procedures require added 1 analysis.
. - . . . _ _, ,--,- - . , - -,-.,-,.n. .
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Based on the team's review of the control of cut reinforcing, it was determined that this activity is well controlled by procedures and the appropriate inter-faces hav'e been established and function checks against known margins to verify that the original design has not been compromised are made and the necessary documentation has been provided. The' Technical Assistance Group under the Lead' Civil Engineer of Site Engineering was determined to be executing this operation in a very well controlled manner. No findings were identified. m . . [ b,,- ' - d (p.7d ), V O e 0 0 0 6 4
. ,, - . . . . ., -- .~. . . .. . . , _. -_
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- FIEF D AS-stif t? FicW otaat . .
Piptag and Pipe Suppert As-Gui1t Derveenta f roe Contrettare
, As-Guilt Documente
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. t e Sende one (1) print i ,
to roepensible site Engineerine Oletipline C As-tuilt Cuerdinator .. for evaluetten ! V anesponeihte Site Eastnuar i Diecipline As-tuilt i Coordinator evel.ates 4 subetstal marke tronentstal *
"Actoptable" or "Ilet .
i * "Asseptable" Identilles prstleme se any prince not g esp . . retor.. t. . e V e
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accostsele met Accostacle Centractore 6 Di-1p11ae As-Su11t Coordinatoy i 1 Septa 1 Marked print vertly sortsettene. If 4 Printa sent to acceptable, caerdteater sent to tiene Centreeter - states en tressetttal
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- DdcumentName:
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SECTION 4.9 - SEABROOK IDI Requestor's ID: EILEEN - Author's flame:- R. Shewmaker DdcumentComments:
.. Conclusions 9
0 e i e e
q cj- t h 4.9 Conclusions The scope and the depth of the inspection was sufficient to r.each certain conclusions regarding the design and engineering aspects of the civil-structural discipline and the related safety features of the Seabrookiplant. Based on the facts fi gh reviewed correspondence p other information acquired
'#nd e concluded that design and construction of the safety during this inspectiong%ed .no
,,.e related features pertinent to the civil-structural area incorporate g / design which w;l! ass.i.-e ^
control process -t-e-prov4de.Aadequate safety to the public. Our inspection encompa.csed both the technical design and the procedural aspects of the , organizations involved in the development of the plant in order to have a broad perspective of all elements of the design and interdisciplinary coordina-tion effort. As a result of the inspection we identified twenty-one findings and ob-servations. All of our findings have been discussed with the staff of th.
.%s 6een bien 3and we have been informed that the appropriate' action g to ascertain that orem s%ces there will be no-consequences4 which might result in unacceptable margins of safety,has beer taker. Finding No. which appears to' reflect on the across the board applied approach to application of live load in combination with other loads may require further investigation to assure that the structural members have load resisting capability in accordance with the approved regulatory requirements.
There are certain conclusions which appear to be quite obvious as a result of the inspection. In our opinion, interdisciplinary coordination of the design
'/ZY2f 49-2
,e \
t effort suffers from the excessive systematization in terms of procedures and
+
manuals. There'is;anlevidens effort to document every phase of design, (A construction, procurement and verification. This is very plausible' and has- ) its merits. The system of traceability, however, is handicapped by such a {f , number o'f various steps and is so. fragmented that it. requires a monumental $h 4 1 task to synchronize'it in order to produce practical results. This is *7 augmented by continuous revisions of various. documents which in turn necessitates is 'Ce%g fem updating &cing frieelin.rof ermefce~nen? all relevant proced S?rucMr,"fd~wirk&he , would be effective. An example of the above - y be ^"-38, Sctice, 3.1, Rev.1, 4 dated-July 31,19&b, which refers to ite Approved Change @ which has been oiscontinued (see Observation 4. ). r r -- the gChasprovidedtechnicalguidelinesandprocedurestobefollowed#e Seabrook Project. Extensive programs have been put into force in order to ensure that the latest and most accurate information is used in the design
- of structural members. Great efforts have been made in order to obtain refinements in the vertical ampi ation of beams for the design of the beams themselves as well as seismic qualification of equipment located away from l
the walls and columns. This refinement results in greater vertical accelera-i tions than would be the case if the beams were assumed to be rigid. i However, UE& did not account for horizontal torsional effects in the develop-i -Me w k ec! m ponse ff'ech w.. p r:m.rr.] a w n q 6 w M9 [ ment of4AftS. In the case of the q, the indications were that 10% %. repre-sented the torsional effec ocations'at the extreme periphery. Normal practice l for(&Dwas development of thehat the mass center. If the torsional.effect-l is only around 10%, the-team is of the opinion that it can be neglected. ,
i,/afen
. 69-J
} k setsac Since the team reconrnends that the Tank Farm tynamic analysis be redone, the team would recomend that additional attention be paid to torsional effects inasmuch as thebankharm has little structural symmetry.
Another observation is the apparent compartmentalization of the organization. We realize that the complexity and magnitude of the project necessitates multi-directional effort, but there must be a definite gravitation toward an overview of the entire operation in order to achieve a practical efficiency. i
;5 An example of this conclusion may be the case of misuse of the amplified response gJr v e. 4 r > / in a.
spectra for the annular*g steel framCas described " Sectier A.6 Of this .cpuct. m ent As we pointed out previously, establishtr3g. of the position of coordination of seismic design improved this situation. Organizationally, the h appears to be quite remote from the Seabrook Project, and operates in a passive mode. In other words,hG will be tesponsible to respond to requests from the project but not to take initiative on ' changes in i the structural design which may develop. The program of as-builts and the final load verification, which we reviewed, appears to be effective and provides adequate design controls. As it has
+fe ers-ka0 been pointed out in 4Sectier. ?.S Of thi: report, thefjprogram should be extended to incorporate the engineering change authorizations which have been issued prior to the comencement of the program. There should be some mechanism whereby thehwill have an opportunity of making an assessment concerning as-built conditions rather than leaving these assessments entirely to the project. In the case of thekankharm, the design of the bracing took place
. m ifug 4.9-4 fe:de/Inf h sbrafe $ b five years ago and the fill concrete under the and-SAkhas released for g xMye fade construction about four years ago. Up until the t met [$neftf- these changes Mpeczkn which have a direct influence on the dynamic analysis were not acted upon and er were unknown to BG'.
He
/. h ,also dg ear to be sub t to technical audits required by '49e-ef Vg stger -
ch, P- e Erymeers;'Genere/ hybeering w d'
*(GEDP-0%q/y(.esnota ReYr' eke 9 J.g N eam recommands that h also be subject/ to technical review. This could be comple~ted by technical personnel who did not do the original work.
From the work observed, it appears that h is conscientious and businesslike in the design of safety related structures and has established procedures, guidelines and organization to meet the requirements of NRC. While many of the programs have not been completed and some analyses and designs must be revised, there is no reasons to believe that the as built structures will be found to be inadequate in light of the exhaustive design efforts currently underway and planned for the immediate future. ' In final summary, i is our opinion, that there is sufficient evidence that in civil-structural area the design controls are effective to the extent that they provide a reasonable assurance that the safety related structures will have their expected load resisting capability and will perform their design function without undue risk to public safety. l .
. y D:cument Name: '/r-/#f SECTION 7.4.2 - SEABROOK Requestcr's ID:
EILEEN Author's Name: R. Shewmaker Document Com.ents: Personnel Interviewed
n... 7, +,,g _ f V/3Af
, p,*
7.4.2 Personnel Interviewed e ) W e,, f Cj Title Organization Name [ Tom M. Cizauskas Mechanical Lead Engineer YAEC - Seabrook Project for Civil / Structural-echanical GroV]rjand Mechanical Engineering) - Engineering Department Henry E. Wingate Assistant Project Manager, YAEC - Seabrook Project Construction Department Jerome J. Wojcik Structural Engineer,
- YAEC - Seabro'ok Project Mechanical Group, Engineering Department Robert Tucker Lead Mechanical Engineer YAEC - Seabrook Project Mechanical Group, Engineering Department Donald E. Johnson Structural Engineer YAEC - Seabrook Project Mechanical Group Engineering Department Walter K. Perterson Supervisor, Engineering /QA YAEC - QA Department Audits R. E. Guillette- Supervisor, Construction YAEC - QA Department Quality Assurance Engineering Janet Allen QA Technician YAEC - QA Department M. H. Ossing Staff Engineer for Assistant YAEC - Seabrook Project Project Engineer of Construction K. l=!. Kalawadia Supervising Discipline UE&C - Seabrook Project Engineer - Structural Structural Daniel E. McGarrigan Manager, Project QA for UE&C - Reliability Seabrook and QA Department.
V. D. Patel General Design Supervisor UE&C'- Seabrook Project Structural James K. Cravens Manager UE&C - Seabrook Project Engineering Project Controls 3e < 4 *em
a 7, +. 2 - 2
')s/M l
Name Title Oroanization J. J. Connelly_ Supervisor UE&C - Seabrook Project Calculation Control - Center (1 of 5) H. P. Sivertsen Leader / Liaison SCAT Team UE&C - Seabrook Project Cognizant Engineer Beam Verification Program and SCAT Team Joel Blackman Assistant Manager UE&C - Power Department, Mechanical Analysis Group
~
E. Skolnick Lead Engineer, EQ/ COMP UE&C - Power Department, Qualification Mechanical Analysis Group Leon S. Nascimento Chief Structural Engineer UE&C - Power Division Anil T. Shah Cognizant Engineer UE&C - Seabrook Project I Structural, Major Cat I 1 l D. K. Ghosh Cognizant Engineer UE&C - Seabrook Project Structural, Containment Pares N. Datta Design Supervisor, UE&C - Seabrook Project Engineer 11 Structural UE&C - Seabrook Project John A. Mott Design Engineer Structural Om P. Kalani' Manager UE&C - Seabrook Project Structural Supervising Pipe Support Group Engineer Richard H. Toland Manager UE&C - Structural Department Structural Analysis Group Noshir C. Karanjia Seismic Consultant UE&C - Structural Department. Structural Analysis Group Dipak K. Majumder Lead Engineer UE&C - Structural Department Structural Analysis Grcup Branko Galunic Engineer I UE&C - Structural Department Structural Analysis Grcup Z. B. Olszewski Mechanical Supervising UE&C - Mechanical Discipline Engineer Analysis Group M. K. Sanghavi Lead Pipe Support Engineer UE&C - Seabrook Project Pipe Support Group r
' 7. + 2 -3 f/is/N t
'Name Title Organization f
Girish C. Hatwal Structural Engineer UE&C - Seabrook Project Structural
' Amar S. Dalawari Engineer II UE&C - Seabrook Project Pipe Supports Duct Supports Thomas F. Clouser Design Supervisor UE&C - Seabrook Project Pipe Supports HVAC Supports
-* J. Alberto Rios Engineer III . UE&C - Seabrook ' Project-
, I&C Alan W. Cole Project Administrator UE&C - Seabrook Project Project Controls-R. B. Livingston Administrator UE&C - Document Control Center - Seabrook Project Robert A. Bosshardt Administrator III, UE&C - Document Control i Lead, Records Control Group Center - Seabrook Project i
D. Melit: Supervising Structural . UE&C - Document Control c Engineer Center, Seabrook Project G. B. Christina Administrator UE&C - Seabrook Project Engineering Project l % Controls
$F y Senior Metallurgical Engineer Bethlehem Steel y
)
{,[DexterOlsson Corporate QA Manager Corporation tl l g ;- Michael Sedics Supervisor, Quality Assurance Bethlehem Steel N Reinforcing Bars, Piling and . Co rporation qg Construction Specialty Sales- j l d Clarence Redman Contract Administrator Bethlehem Steel , )
- JW Reinforcing Bars, Piling and Corporation i l t Construction Specialty Sales
/ Dennis Reid Chief Detailer - Engineering Bethlehem Steel Corporation j l.
i. l r I Denny Vassa Detailer - Engineering Bethlehem Steel Corporation- y / l ( N. 1. Desai Engineer I - Structural- UE&C - Field Change Completion Group l
r3,
~ 1,/'ss/g \
Y ,
- 7. +. 2 - +
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- Name Title Organization
' Rick E. Daniels Cognizant E'ngineer for UE&C - Beam Verifica-Program Guidelines tion Program Robert N. Kuelin Engineering . Manager UE&C - Field Systems Group Site Engineering Douglas ~G. McClellan Lead Engineer - Civil / UE&C - Civil / Mechanical Structural - Se rvices ,
Site Engineering Richard A. Arell Designer UE&C - Technical Assis-tance Group Civil / Structural Engrg. Civil / Mech. Services Site Engineering C. E. Morales Draftsman UE&C - Technical Assis-tance Group Civil / Structural Engrg. Civil / Mech. Services Site Engineering R. P. Kosian Lead Field Engineer UELC - Project Field Engineering Group Civil /St'.r; ural Engrg. Civil /Mece.. Services Site sq;aemy
- S. N. Caruso Lead Engineer UE&C - Cable Tray Bracing Task Group Site Technical Staff Piping & Supports Site Engineering Julie Drozd Seismic Analyst UE&C - Structural Analysis Group John Alle Structural Engineer UE&C - Structural Analysis Group l
Susan Hayecki Field Engineer - Civil / UE&C - Project Field ' Structural Engineering Group Civil / Structural Engrg. Civil / Mech. Services SiteEng@ nee *} l
..L Ys/tt y ,6 7.f.2-5
- }l .
J Name ],itle Organization Robert Shappell Civil / Structural Engineer UE&C - Technical Assis-tance Group
< Civil / Structural Engrg.
Civil / Mech. Services Site Engr + laeetng J. R. Lindguist Field Engineer - I&C UE&C .- Project Field Engineering Group
, I&C I&C Systems Site Engineering Frank Dadabo Construction Superintendent UE&C - Field
- Painting Subcontracts Construction Colin H. Coles Design Engineer II .,#e.
UE&C - Seabrook Project '#Y . Structural
'u A. A. Haldar Job Engineer UE&C - Civil / Mech.
Civil-Structural Services
. Site Engineering C. Holt: worth Field Engineer UE&C - Civil / Mech.
Civil-Structural Services
. . Site Engineering
%eA}feoNSheeL
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- Document Name: 1
( SEABROOK TENTATIVE FINDINGS ' ga Requestor's ID: f
* . ,/ ,o KAREN Author' iam ,
Ed nzin - Document ommints: ..
- Sections I- lus - eodonents Qf R f; F T A q
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p_; - . - . . . 1 .. M'10 584
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Seabrook Tentative Findings - -
* ~
I. Mechanic Sv ems II. Mecha ical o..po ts ' .
.M I. Civil .
IV. Elect.rical ~ ntrol V. Instrument'& , , i , n f 6 e ' o
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JAN 101984 q. g.
- 1. Mechanical Systems ,
- 1. FSAR Section 1.8, pa 1.8-31,* Amendment 47, 9/82 states that the sump design conforme , lly t the positions' of. Regulatory Guide 1.82. Furtheri discussic is o ed in AR Section 6.2.2.2.j that states "... stil1
[1 limie the a
" , proach ve ocity to the screens to approximately. 0.2
- ft/sec" emphasisadded). Regu tory Guide 1.82, in..Regulittory Position. ,
C 7 specif d that the des cool t velocity- at' tile inner screen should be approximat ly 6 c sec M t/sec, - VE&C calculation CI-6 sheet 15 of 16 10/2/791sh ws a. oc ty through t -screen of 0.36 ft/sec. This is in conflict with R.G.1.8. The Regulatory Guide. in 'he-sixth e agrap of e Discussion, indicates
- that thb 0.2 ft/sec coclant 'elot, ,,
he screen v 'll allow debris.with
~
a specific gravity of 1.05 or re s settle before re_ hino the screen '
. surface. FSAR Section 6.3.3.3.j tates that.an appro'ach locity of'O.2 ft/sec, all debris w'ith a speciife avity of 1. . or . ore w 11. settle to the floor prior to reachina the sumps. No e'id . e ha meen pr vided to shown that an aporoach velocity of 0.2 ft, ec will Iesult in debr. settling to the floor.,before reaching the screen surf e.
21 . Alden Laborato'r'ies Repo'rt 25-81/M296.HF January 198 Invest' at' f
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Vortexing. and Swirl Within a Containment Rec4 rcula'tio Sum sing a Hydraulic.Model," recommended as a result of phase 3 Tes e on page 22 of the report recommended in Item D that all top cover plates have at least i
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1 I ! l
.. .. . . . .x - .-....- - .- . . . .
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. 5 JAH10 ES4
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3' rows of 1/2" holes on 12" . centers. This ' recommendation was not imp 1e- . mented until after the team discussed, the Alden recommendatio'ns with'UE&C. The memo from_ Flora Valawad'ia (UE&C). dated 12/8/83 requested action to add 1/8" o cents . (1/8" was chosen because of " particle size
~
restrai + 1 l T. Regulato Guide 1.1 recommends S pump NPSH be based on maximum expec~ted temperatur of 'pumped flu' s. UE&C calculation 4.3.5.-11.f dated 7/14/81 assumed 212*F. The .. xi xp cted t mperature accordi~ng to~the "Cen-trifugal Pump'Sp ific ti Sheet No.1" 'n the Specification for the CB'S Pumps Spec No. 9763 06-238-3 Rev. 5 dated /19/79 is 2'80*F.
- 4. CBS NPSH calculation 4,.3. 11, d
- 14/ 'does ot account for' water tnat may be entraped by the eact'or a ty and refue ing canals (5,760 cubic feet). This would chang the ump water level fr m -23.33' to
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(N1/2' loss of NPS .' .
-23.78' , 'a decrease in level of- 0. '5'
- 5. CBS NPSH calculation 4.3.5.1.1 dated 7/1 '81 c - an inlet 10 co-eficient for the CBS ' sump pump . suction pip of 0.37 taken from the Alden study (January 1980). However, the Alden stu calculated the averag
^
valu'e of 0.37 but.also ' calculated a maximum valu of 0.53. *
+
- 6. Alden Labs determined a pressure drop due to swirling low n the sump w
pump suction pipe could occur. This, effect was not inci k in the NPSH calculation 4.3.5.11 dated 7/14/81. UE&C Calculation ~4.3.5.41F dated-f : , , 2 e 4 g e
JAN 10 1924 i 1 1 . L 12/1/83 determined that the effect could result in a decrease in NPSH ' of 0.09 foot. ,
- 7. CBS NPSH calc ~ . on,4. 5.10F' dated'12/1/83 calculated an available NPSH.
of 21.73 eet ?6 *F. C sidering errtrapped water (NPSH .45'), inlet loss oefi 1 .. ' SH ' .45') nd swirling flow (NPSH .09')the s total NPSH A.
- could b '0.99 foot less. The av ilable NPSH could be as low as 20.74 feet.
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'I Required N H is 20.8 acc 1 g to oreign Print 53205, Rev 01. NPSR ma'y not be'conse'r tive ou .
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- 8. The FSAR 6.3-1 indi tes that NPSH availabl for the RPR pumps is 20 feet.
Westinghouse calculati n SD/SA-NAH-114 2'ECCS A lysis" dated 11/10/78 [ indicates available NPJH f 22.3 f . FS' 'tabi 6.3-1 indicates required ~ I Run t iow calculat d in the Westinghouse NPSH is 13.-5 feet at 3800: r . calculation is 4691 gpm:for wh h th required NPSH is 9.5 feet. Con-sidering the factors listed 1n it ms 3 (temp), 4.(entrape water) and 6 (swirling flow) the 'RHR pump may not e conserv ve ough.
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- 9. FSAR'Section 3.6(B).1.3 states that result offaiidremodesandefects analysis pres.ented in Appendix 5A verifies th t the consequences of failures of high and mo'dera,te ' energy lines ~will ot affect the b lity
. of the plant to be shut'down safely. FSAR Appendix C'provi d i ed criteria for evaluating ' jet impingement loads .from hi, en .gy piping.
w failures. However, these evaluations have not been comp Ce'd. Y e 3
- e. eg.e. e*ae
.. _ ... . . .a. . . . _ . . __. ._ ..
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JAN 10 1984 q -
- 10. Two out of -100 zones have had jet impingement analysis performed but th'e '
reports have not been approved. These analyses have not utilized the criteria contained in ppendix' 3C of the FSAR " Procedure for Evaluating Jet Impingeme L ads f m High Energy Piping Failures." ' In the analys.is: performe ,) et ram small ' pes impingi'ng on larger pipes would caus'e no damag . N as' provide for this assumption. We note that SRP 3.6.2
'I allows a sumption of no damage w n a small whios into a larger pipe. -
11.. FSAR Section- 6(B)*.1 hat me sures for protect ~ ion against pipe' , whip are not pro "ded. er the~ whipping ipe cannot cause. unacceptable damage to any essen ial system or component. There is no documentary evidence that whipping ipes have been evaluat over their envelope
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of whip for potential-imp ct at s fied nite istances from targets. I3' of the FSAn indicates- that equip-- Supporting.<focumentation fo Appe'nd-ment is protected.from specifi line breaks by "distanc " but no distances are 9pecified and'no acceptable d. tances are given'.
- 12. The FSAR Section 3.6(B).2.1.b indicates ipe -r in ...oderage nergy
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lines were postulatet to occur in location that result in the max'..um effects.from. spraying.or. flooding, except whe e pipe stress levels ar belo'w a spec'ified valuei .T.her'e is no evidence at spraying an 1 ' es
. s have been done,'
P'. 13 ~. The CBS Pump. Specification requires _ that each pump be in O q,idually tested in the as-built configuratio'n. The motor to be used at Seabrook was not tested with the pump. Further, the FSAR Section 8.'3.1.1-1,Spage 8.3-22 . b 4
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. JAN 101984 s .
\._
s'tates that motor suppliers .are required to verify that actual test data confirm that the torque margin is equal to or greater than tilat of trie, calculated data. UE& has no corresponding data on hand for the CBS - pump motors. . seismic qu ification is incomplete. Qualification is
- 14. The C pu, ,t
- require y Specification 9763 0 -128-1 Rev. 4, 4/23/75. The sei.smic analy. sis is contained in ' e ' stin house " Seismic Analysis of Contai'n-ment-Spray Pu. s ... W t gh use P 0632-L7 (Seismic 7, approved 2/25/81.
The analysis doe not c1 de stress in t e stator end turn ' insulation support system.
.s.
f- -
-15. GEDP-0033 Rev. 2 11/20/78 requira th respo ible engineer ' complete the comment resolution statu 'on 'th D ument Review :,equest form. This was r.ot done on one form conce ing changes to Rev. 5 o 50-20.
~
- 16. A number of technical changes were m e in SD wi "o t an t A or DCN in violatier,of GEDP 0032, Rev. 3, 10/29/7 and "" 4 ev. 1,.10/1 82.
.a. Sump ph changed from 8.5 to 11-(Rev. 5.) 8.5 to 10.5 (Rev. 6).
'b. RWST and SAT min. temp 40 Rev. 5, 50' Rev. 6.
w
- c. Inner screen (sump) particle inclusion size 1/4" Re $5, 0.097 Rev. 6.
C ., 1 5
.2 _ . . . . . .- . -
L
- d. Inner screen .
'" maximum velocity" Rev. 5
" approach locity" Rev. 6
- e. CBS ctu io p 5 3. - ' h" Rev.
"high-high-high".Rev. -
ao/ BSA) o igh:.high" Rev had CN . h . .
- 17. In violation of 2 ev 8, 9/9/83 Se ' ion IV.A.2 some UE&C project personnel had not r cieved indoctrination t ining prior to perform-*ce of safety related acti ities including r.eview nd approval of safety
, ~
related documents. ..
- 18. Calculation CI-2 '.' Design Scree , and upporting Structu for Recirculation Sump" Rev. 1, 8/29/83. assumes no t impingement and missi load required in.the design of screen supporting s ucture. T. s as umpti i~s not supported in violation of GEDP 005, Set ion .TT , .ev. 3, 9/9/. .
e
. (
6
. - . - . . ~ , -
p
JAN 101984
's II. Mechanical Components' ,
- 1. The themal displacem t during the faulted c'ondition of the tube side outlet nozzle s 4o 1.e N of the CBS Heat' Exchanger (CBS-E-16A) is.0.044."
This noz e or le ted in he plant no'rthern diredtion-whigh is the plant + 7C ir i on'. This isplacement was input to the pipe calcu- .
' 0.02, Part A (2/4/81) .a -0.044" instead of +0.044."
l'ation For stress anc ses iD
~
2, Part A (2/4/81) and NCD '55_0.0,3,'Part A (2/4/81) there w e no a Anchor Displa ement Data Sheets which woul.d have provided docum tation for the CBS-E-1 '&B outlet nozzle thermal displacements. This i a violation of S(ction .0 of DEOP-2607, Rev. I 1/19/81. Recently, UEaC s dona _d pla ment alysis for the'CBS. Heat Exhenagers-nozzles (Cal diat'io 4 .5.39F, Rev. 1, 11/15/83) and it ccnfirms the magnitudes ~used in the analysis MCD 550.0c Part A and MCD 550 43, Part A, specifically e 0.044"-referre'd to ab ve.
- 2. In UE&C stress calculation MCD 550.02 2, "/81, 'ae ..te action e ects between an 8" run lin'e (1214-2-301-8" in t. CBS)ar$da4" branch ine D-
.(1218-1-301-A"; .in the CBS) were' not-accounte for as prescribed by Ot 2607'Rev. 1,' dated 1/19'/81. '
3'. In UE&C stress calculation MCD 550.03 2/4/81, -the inte aci_ on effects e between an 8" rdn line (1216-2-301-8" in'the CBS) and a 'IQranchline (1217-1-301-4" in the CBS) were not accounted for as prescribed by DEDP-2607, Rev. I date 1/19/81. S . 7
+messe . *
-. . . - - . . n ..=... .. ... . ..
l JAN 101984 t L In UE&C stress calculation 551.00I (7/30/82) on line.1217-1-301.-4" and 4. line '1218-1-301'-4" on' 3 lines at least, the valve o'perators for the
~
valves (4"-CBSV31, 4kBS-V33 a'nd 4" CBS-U32) and the corresponding operator supports (1217 8, 12 -SG-9, and 1218-RG-3) were exclu'ded '(with, regard. to moment an o9d ) in y lation of DEDP-2607, Rev. 1_,.date 1/19/81. 9 5 ~. CBS sum ' isolation valve er}capsu ation vessel weight..is noted in PX i Engineerin Stress Report the ssel CBS-Tk 101A & 101B Rev. 4 dated
~
2/23/81 as-5, 7 po s d a d 14,1 3 pounds ful1. PX Engineering' -
> General Arrangem t Dr in #578, sheet . Rev. 5, date3 1/13/81 for the vessel states the w ight as 2,900 pounds em 'y and 11,700 pounds full.
.a I ( (" c0, U C Spe ification 9763-006-246-1
- 6. Four project documents;, c e FSAR, and Westinghouse system des iption .e Safety .i1' ection System spec.ify-design temperature for RWST as 6*F FSAR) to 200*F.(W Tna 50-20 and' the UE&C' Specification state 100*.. The code stamp on th vessel says 100*F.
- 7. UE&C' Specification 9763-005-248-47, Rev. date 4/2c/81 states tha the CBS Sump Isol.ation Valve, Encapsulation Vesse, may fill with steam or
~ ~
water. UE&C Specification' 9763-006-248-L:Rev. date 5/23/80 p cifie
-90% relative humidity fhp the valve actuator.
9
?
- 8. SD-3, Main 7.nd Auxiliary Steam. System has had 3 versions Qev. O, dated 7/15/74. Rev. 1, 6/28/77, and Rev. 2, 11/18/81. No DCN or ECA exists.for a number 6f changes between Rev. O and Rev.1 and between Rev.1,and Rev.
8 -
=- . .
.JAN 10 1984 L
2'. This violates GEDP-0032, Rev. 3, 10/29/76 on control, evaluation an'd - implementation of design changes and GEDP-003, Rev. I dated 2/10/75 and-Rev. 2 dated 11/20/7 concerning control, evaluation and implementation of review co o.n de ign documents. . f . 9. Bingh m-Wi an performed thermal transient qualification test'.on a
' 12 x 14 23 type CD pump,.consi red similar in design to the Seabrook CBS pumps that re 6 x' 10 x 1 ty e CD 'mps. Modification of the tested pump (enla rgement - wear' g cl arance ) was necessary f~or sucessful I ,
qualification of he t st pump. Based n review of the test results
~
of the tested pump C&C recommended in SBU- 0320 dated 7/25/77 to YAEC that the Seabrook CBS ' mp.be tested for therm- transient capability, i This recommendation was r 'ected + Ci SB-51 , dated 8/10/77. No data was available on the.c aran'ce f the pump th t was- tested or f_or the clearances on-the Seabrook ump. This vicates YAE Seabrook Station
~
Quality.. Assurance ~ Manual Procedur 3.3 Rev. 6, dated 3/13f 7, Section 4.1 and ANSI N45.2.11 Section 6.3.3.
- 10. The FSAR, Subsection 1.7(b).2.3 states tha the majEr equipment sy tems, whose stiffness, mass, and frequency have sig ificant dynamic interac ion
~
with'the supporting' structure 'are includedlin th detailed mode '
# the.
. s .
structure. The dynamic interaction effects betwee , tfie tri
~
tar, i ing, pipe support and the supporting structural steel at p es port 1201-f P SG-02,fs, given in. calculation set n.o./ support no.1201_kO2, Rev. 2, 9/30/83, were not considered'. As an example, the mass of the component support arid piping is 3,637 pounds, while the lumped mass of.the support . 9
.- 4
JAN I 0 1924 t structure is approxima'tely 16,300' pounds. 'The approximate mass of the , supporting structure is only.five times greater than the mass of the
~ ~
component support an iping. The support steel and associated piping should theref' e e , dyna ically coupled and reanalyzed. .
> l
. 11. Same #1 ex e :
' P'ipe sup ort M/S 1214-SG-63 Calc . set no suppo'rt no. 14-5 -63, Rev. 3, 8/15/83 Component sup,. rt ar pi 6 2 lb. , , ,
Support Structur 937- .
- 12. The top of steel (T.O. ) elevation for.tte (W,12X79 beam at azimuth 270' 1
at elevation -8 ft. 4 ,in, is show as 8 f+. 4 in. on UE&,C Containment
- Steel Framing Plan Drawing.. 63-F'-1 43' , Rev. 6, 3/ 7/82 and UESC Piping .
Isometric Drawing 9763-0-80121 Rev. 7,' 7/7/82. Howev r, the T.O.S.
~
elevatiori.for this W12X79 beam ~is hown as -7 f t. l'0 in. UE&C Piping IsometricDrawing9[63-D-801214,Rev.6,7/7/82 13~. M/S 1214-SG-63 is att' ached to the undersid of a Wi[X79 beam, loca ad at 270 elevation -8.'4" on the inside of the con ainment. The design o the comp'onent support and.t'he supp' ort steel (W12 x i ) does not acc u ' for
'the effect of' the lateral sheer and torsional mome , induc ey e 1 seismic piping loads.
3t.
,14. ITT Grinnell' Technical Specification SS-001, Rev. 2, 7/12/82, concerning reverification of supports, specifies in Section 6.II, temperatures.to be ,
10
^
JAN 101984
\,
considered in the design of. lines in containment to be the maximum line c temperature or 370*F whi,chever is greater, an in all other areas, the
~
maximum'line tempera re. UE&C Pipe Support Design Guidelines, Rev.1, date June 17, . ' s.peci ies, on page 2-14, that a temperature of 550*F. be used. } l
'f5 . A' sample of 12 reverification pa ages prepared by~ ITT Grinnell were reviewed t detbrniine if mp ter p gram coding (STRUDL) for the componsnt sup rt g net d oads h d been signed'by t'he preparer' _
and checker. The package for suppor 1201-RG-07, Rev '/ , ru 1 of 2 had been signed 1 by the preparer but not t.e checka s
. .I The package for support.1201-S .1, R v. 3, run #1 (of 1 was not signed.
by prepe.rer or checker. These 2 examples viblate procedure QCES .3. _ I.i Grinne. Corporation Engineerfhg Services QA Manual . Rev.1, dated 2/14/83.
~
- 16. Pullman Power Products Piping ' Isometric Drawings that were plac d nder ~
. s.~
-UE&C control after 1/17/83 were subsequently issue by UE&C itF P.E. stamp.
. b Two such examples of these drawings are Pullman Power Products Isometric l , ,
l Drawing f;o. CBS-1213-01, Rev. 9, dated 11/1/83, which carries. the? note
- i 11 W MN.WD
s . . .
=
4 sg JAN 101984 "lJ.E. & C. Drawing as of Rev. 7," 'and' Pullman Power Products I'sometric , Drawing No. CBS-1213-02, Rev. 2, dated 4/14/83, which carries the note,:
"U.E. & C. Drawing as f Rev. 12."
This is y at lo of the U.E. & C. N'uclear QA Manual,' Subsection 3.'2, which and es tification- piping erection drawings by a regis'tered. professi qal engineer.
- 17. The ITT Grinne 1 en., ne 'n st ndards DesignPolicyProc.e.du,res,anb Rework Procedure that o".ed the technic 1 basis for the.ITT Grinnell reverification prog m, and which were liste in ITT Grinnell Technical 5"ecification 58-001, v re. not examined 3'v YAE .
This is. contrary to the requ ement of tange Order i . 42'to UE&C , Purchise Order 248-8, dated Jun 1,1982, which require that "the technical'. specification coverifig verification (mea ing -001) shall be reviewed and accepted by Purchase prior to rk " The pu chaser is YAEC.
.This is- also c~o .trary. to Subsec' tion -2.1.1.5- o. the YAEC QA Manual , Re 2, dated 3/31/78, which requires that: " Pro 9isions of technical d t. ents by the vendor'shall be examined."
. 18. The component support reverification packages prepared b*e(IT Grinnell
. . for UE&C did not consider frictional effects for thermal moments less' E
than 1/16 inch. - 12 e er - .m en a
_.- .... . . .2. o o - JAN 101984 6 - L Two such examples are' contained in the UE&C calculation sets for support nos. 326-SG-01,.Rev.-1, 5/12/83, and 179-SG-04, Rev. 3, 9/22/83, which
~
contain both ,the ITT calculat' ions and~ the UE&C closecut calculations. This is nte y to Subsec on 5.I of Technical Specification SB-001, Rev. ,7 ja, ich requir that friction be evaluated for all T cases-w re thermal movement doe not equal zero. -
- 19. ITT Grinnell ppor al bio for mponent suppo't'no.r 1203-RG-8' Rev. 8, 9/3/82, s re le for technic content by the team- . The calculations for th principal moments of i rtia and section moduli for the 6X4X1/2 inch angle detailed on page 10 of his calculation are incorrect. For examphe, he cale' aed va e of he principal moment y I of inertia -is 17.33 in 4, wile the or ect value is 20.07 in f.
v This data is subsequently input to e e Si,UDL run dated 9/7f 2, which forms a part of this calculation packag
- 20. ITT Grinnel support calculation for com nen pr . t . 1203- 9-3, Rev. ~ 5, dated 9/3/82,' was reviewed for tec. nical cor$ tent. The cal u-lation for, the support stiffness in-the negat've direction given on age 6 is~inadeqaute and pos'sibly i'ncorrect, due to e use of dispi c ment data generated 'by a STRUDL run which specifies an suffici t
.e of significant figures.
- b The specific stiffness in th'e negative Z direction is- the ratio of the. _
1000 lbs applied as a load in the negative Z. direction in the STRUDL , i 13 e pee e
JAN 101984 (_ model to the resultant displacement of 0.001 inches output by the STRUbl model. This ratio yields a stif.fness in the negative Z direction of , 1X10 6 lb/in which is the magn'itude of the minimum stiffness allowed for
.this support. ev.e r , ue to'roundoff, the magnitude of the disp,lacement could be sh n )s 10 0014 inches, which would yield a correspondirig 6
f.tif, ess v.o 0 'lbs/in, ausing the support to fail the minim' m u 6
'I s'tiffne criterion of 1X10 lbs in. This apptars +o be a systematic error beca e the'STRUDL p t on1. prints out thousanths and in these
- cases only on sign car'hgue. , ,
/* ,
b D O
\
- L -
4
.5 i "4
14
JAN 101984 l 1 III. C~ivil . 1.6 .
- 1. P.O. #210-9, Februar 12, 1982 from UE&C to E. G. Burdette, " Test of.
Anchorages to rmine ffects of Prying" did not include QA requ.ireme.nts in viol ' on U & , QA-1 "Cortrol of Measurement & Test Equipment ,"' . Rev. , 12 % , arigraph I A&B; QA-3, " Design Control," Rev. 14., 8'/16/76, IV, E.7.C and GEDP-0022. As a result, no requirement for control of calibras'en and adjust nt of me urement and test equipment; used ~to confirm the p ing f tor o um d by &C. , , 4-6 ~
- 2. The Tank- Form struc ral steel is Seismic C egory I. The Design Load Combinations listed on Structural Steel . Design alculations, Tank Fam US-61, Sheet 10 of 79,,9 8/78 om i oad rbina ions containing'SSE.
W Inis violates SD-66, Struct al D'es n riteria, Rev 1, 11/30/82, Table 5.4-2 ar.d Rev. O, 10/19/76. pg .
- 3. Structural steel beim Mark B9 locate on the El 4 Roof 'ong Column Line 0.5 was designed for dead loads, 1 e1 e , . ,d eismic 0 e loads.
in calcuation WB-61 steet 17 of 79, checke on9/2Ef79. Later, a .adesign was made to and the sag rod loads to the dea loads, live. loads, and igina
~
seismic OBE ' loads.(sheets 9.I and 9J of 79:checke 11/3/79). Th . calculation (WB-61 Sheet.17 of-79, 9/28/78) was noe voided sr 3 i d by GEDP-0005, " Procedure for Preparation, Cocumentati &. ntrol of w0 Structurals Calculations", original.. issue 8/21/74, Parag h II.D. Subsequently another calcula' tion was made (WE-61, Appendix A, Sheet 10.of 16,' Rev. 3, checked 6/17/81) which added a pipe support load, but neglected 15 e* 6 6gumm 6 4 *= *
..- - . ..= . . . . .. . ..- .
- =
\_
the sag rod loads. Again the previous calculation was not voided. The , SSE pipe support load was incorrectly, combined with' beam OBE' loading and designed for SSE allo able str' esses. The neglected loads and the combining of the OBE an ., viola es SD-66, Stiructural Design Criteria, Rev,1,
~
11/30/8 } l 4-/O
- 4. R'einforc d concrete walls in the ank Farm along column lines 4.5 and 5.0 are sub'ect'to' moment an axia forces. ACI-SP-17(73) Design Handbook, Volt. ,e I, dD in , Marc 1974 presents th~e , design pro- ,
cedure for accou 'ing or ..ese moments a d axial forces. -Calcula tion - WS-68, Sheets 8 and of 13 checked 2/10/79, did not follow the procedure quired area of" steel of ACI-SP-17(73) corre tly. in determining" the reinforcing. ,.
- 5. Pittsburg-Des Moines calculati , Ju .e 1981, PDM Contra t 14'084, concerning
~
~
design of the refueling water sto ge tank contains'two c.,issions. In
~
calculating the fundamental frequenc of the ta , she r flex'bility was neglected. ~ Vibration freque.ncies highe tha
- e ' nde... ental fr quency.
were' neglected in violation of.2.3.3.1.7 o UE&C Spec. 9763-50-246 1 . 4-/7 The tank foWn modeling of stru'ctural steel'.is nc representativ
~
- 6. # the actual structures Size and shape.of bracing used 1 the mo . ,e from actual' structure arid drawings. Model does not a ouns for overall v
bending. Incorrect shear area used .in model. Reference ( calculation SB SAG 5WB Rev. O, 7/10/76. , 16 l
-- - - - . . . ..=. . . . . - ...
* -s
- JAN10 gg4 G
4-/t .
- 7. Overall bending stiffness of the reinforced concrete. in the tank farm was .underestima'ted. Idded stiffness due to orthogonal wall's in calcula.ting moment of inertia of 'ndividual walls was neglected. The calculation of
.t.he equivalen' .
ent o inertia in the mathematical mode'l uses a forumla-tion tha+ res us u derest tion of the overall bending. stiffness for this ase. The mathem 'icai rdadel wa= pare ignoring the ef'fect of the 15'-0" ft. thick concret fill ' der M R 'ST an the SAT. 4-//
- 8. 50-66 Structural De ign Criteria, Rev. O,1 19/76,-specifies in Table 5.4-1 that separate 1 d combinations utilizin both OBE and SSE loads i c be considered for struct al steel '. side ntai nt. The design of I
the screen..and supporting s ructure ior he contain, nt sump as docu-mented in calculation CI-2, Re . O, /29/80 sheet 5 ci 6 and Appendix A, page A2,'Rev.1, 2/2/82, do not a count for.the OBE load ombination'. 4 - 21
- 9. UE&C Drawing F101402, Rev.13, 3/24/81 " Mat se ' .
..ows do "le stirrups at 16". Shep drawing (Bethlehem teel) #C'.7RM31, Rev. 4 (12/5/7,8).WaB Stirrups, Layer-#7, shows tha these bars have bedn changed to single. stirrups at 8". separation. i e UE&C drawing h not been updated to reflect' this change,in . violation AP 29, um t
~
Control - Foreign Print' System, Rev. 7, dated 4/12/8.
*o 27 - L
- 10. 50-66 Structural' Design Criteria, Section 4.2.1, Rev. O, 0/19/76 ind Table 5.4'-2 require consideration of live loads concurrentgwith dead
~
17
" - em>wiempseep e, g a a
loads and seismic loads except where known equipment loads are considered in place of live loads. In the . primary auxiliary building eduipment l
. ~
vault (Calc Set P.B. 6, Rev. 0, 11/18/83) as shown on UE&C drawings F101562, Rev. , 2.3/8 and F101558, Rev. 6, 7/9/82, the live loads were no on er ed in com ' nation with' seismic loads for beam B3 for e ampi e B3'does no carry equipment load. 4' -/
- 11. Project Ma al of"Procedu 'E&C), Section 1, Exhibit A,-8/22/80, Rev. '13 contains the - rres de D cument Distribution Inde'x. This.is incon-~
sistent with a s. ilar ma x contained T AP-1, Correspondence - Reproduction and .Di +ribution, Rev.16, 8/1 83. The matrix contains over 800 entries, appr imately 15 inconsisten es were found (Shewmaker . has details). ; 4-l2-1E. Tne Structural Subject File In x in the Structural Gro o has been
. periodically. update'd as requ' ired AP-7, " Subject ' File Sy tem". However, AP-7, Rev. 12, 8/18/83 has not been dated to Gan he su iect file index for structural items in AP-7 for ver 4 y . s.
h- 3
- 13. Twenty-six project design related documents. t at should have been con rolled under the requirements'of AP-2, Correspondence .
ntrol System,. e' '2, 10/1/75, or subsequent revisions, were found in th Structu . ie t File, which-is not. controlled. These documents had n cor spondence e serial . number.s. FourofthesedocumentswereselectedtQeterminewhether or not the Document Control Center could locate them. None of the four E 18 N. eet- pa
I JAN 101934
~
1 . could be located in spite of the subject to correspondence ser.ial numbe~r ! cross reference' system. 4-/$ -
- 14. A number of er were ound in Admin'istrative Procedure's. (Shewmaker' has deta . ) ,
4-/f .
-16. Two con olled copies of the AP (#38 and 46) were found with errors. .
(Missing p es end missin cedu s) .
~
4-43 . .
- 16. Structural steel conne lor in the cont inment annular ste.el which were
~
errors in the location of
~
fabricated as non-s andard connections due steel embedment plate in the concrete .structu es have not been designed s for the eccentricities i 'roduced. .e ho 'zonta centroidal axis of the team an'd the connection do. t cc-n 1 The beams re required to transmit axial ' loads as a resu t of .nermal loading. . glection of the' eccentricity is in violation of SC Specification for th Design, Fabri-cation and Erection of Structural St el for Buil ngs, 1969, Section 1.15.3. This Specification is referen d in SD St .ctural esign
- Criter.i a , Rev. 0, 10/-19/76', Section 2.1.2 s the goferning design ocument for~ structural. steel. Also see 18,.which f,o ows.
4-? . . . D. Procedures which. governed the design control of th proj ect .ert
~
available (today) for the entire time span of .the pro 'ect . therefore an audit to ascertain whether the procedures were follow
~
is not possible .for certain time spans, for specific. procedures. The proc'edures involved are both corporate procedures (GEDP's) and project. procedures; 19
- e,
. . . .... . . 1. : . . .w: ? ..
.s (AP's). This is considered.to.be~a violation of ANSI N45,2,11, Quality Assurance'Requir.ements for the Design.of Nuclear Power Plants',1974. ,
+1
- 18. Also see prec di . item 16. Inconsistency exists between the actual connecti ar desi n cale tions for a' connection between a beam and an imbed ad p te u g a' bent p te. The calculations assume that the h'orizont 1 centroidal axis of t.h connector (the bent plate) and the be'am coinc.ide. 'owever, the s p awin. and installation -in the field sh'ow .
the as-built % 'th a ec t ct . AIS Specification for the, Design, Fabrication and t ecti n Structural St el Buildings,1969, requires in Section 1.15.3 that uch' eccentricities be a alyzed. They were not. d-19 ..
- 19. Geometry and structura;l s el det ' 1 cc ideraEons for struct' ural steel in the containment ann lar 'st ac ral steel ha ,
resulted in the . creation.of connection eccentri ities which were not an lyzed as required by AISC, Specificat' ion for the De 'gn, Fabrication and Ere tion of Structural Steel for Buildings,.1969, Section . 5 . The e entricities arise at the junction of columns and be ,s w> .i ...er ect_non- thogonally.
. With the beams subjec'ted to thermal loads s Sich introduce an axial oad
.into the beans, the approximately one inch o accentricity will impos a tens'ional load on the. column. The designJcalcui tions do not r f ct the eccentricities as . required b'y AISC.
~
4 so ,
- 20. No calculations'have been located which supported the en keering drawings released for ccnstruction and fabrication of' structural steel for an area in the Primary Auxiliary Building as required b) .AP-22,, ,
F 20 l _ . - . . .
JAN 101984 Calculations. The drswings.were rele~ased in.1978'and calculation was perfonned' 11/18/83. . P1 *
- 21. Input .for the 1.I Co puter program (Sh. 30 throug,h 35 of 289, .
Calcula n( C B- 5 date 8/4/75, Rev'. 0) referenced' calculation set! SBSAo 4CS4 " e s Arialysis # Containment Structure" -as the sourc'e
'I o'f info ation. Actual,1y,.the.i ormation used for Shell'I input was taken from ~BSAG-dCS3 da 6 2/75 hich was superseded by the. memo -
from SAG date. 3/17/ , 1 ue 3/29 5. In this memo ' SAG i,ndicated that "since the crea es d decreases 1 respons'e vary greatly depending on location of resp se, earthquake directic , equipment damping, and frequency range of int est, the detailetr effe s will have to be evaluated by each of ddsc line e- e e ' case asis." There 'is no , evidence that such an evalua ion ha b n made. . e The note which appears on Sh'. 30 o ~ 289 of calculati n set CS-15 dated 8/4/75 referencing SBSAG-4CS4 is err eous. It no 'd refere ce calculation set SBSAG-4CS3. .
*t D
1 1 l
. 1 21
,e. -e e
.. .. . .=- . . . . . - .
JAN 101984
~
IV. Electrical
'? -
- 1. UE&C drawings,9763-F- 0028 and'29 (Rev. and date) illustrates anchoring methods for s' gear elding details for welding cabinet to floor).
The swi gea ma nu acture (Brown-Bovdri)~.in their letter to UE&C,
#BBEL PMT - 16/83, sta d that UE&C's anchoring method of electric 3 e'quipme is adequate for seismi loading of switchgear. UE&C specifi-cation 976 50-146-2, Rev . Seis ic requirement for 5 KV Switchgear requires that quipr t " hun ed as losely as possible to the inservice' _ ,
orientiation dur g te si .. However, t Brown Boveri seismic certifica-tion report #33-50 0-SSA, Rev. 1, Oct. 198 does not provide details of the inservice orientat'on during testing.' In dition, the test report of a seismic test of 4t ical sw ' ar binet performed by Wylie Lab in 1976, that.is referenced 'n th'e ro ' Boveri cer- fication, does not. provide mounting details. Thu., th e is no apparent sis basis for Brown Boveri's asse'rtion that the quipment. anchoring is equate and no basis for meeting the UE&C specifica ion appeare so h avail le with regard to mounting details. -
- 2. DCN 030303B,.. dated 7/6/78 changes a. delayed n-synch transfer scheme to a residual voltage.permi.ssi've transfer schem involving chan e in ~
. s .
relays'and wiring. The DCN does not list the'asso dated SK wi er specification (9763-006-145-2) and 4160 volts distrib *ico ystem e . description (.SD-74.) as a document to, be changed as a res *{ of this DCN. This is a violation of GEDP-032, Rev. 3, dated 10/29/76 and AP-15, Rev. 7, dated 3/6/78 regarding control of design changes. E ,
. 22 mm e e ** e 6
...4 . . . . . . ..
.JAN 101984 i
( Revision 4 dated 6/9/80 of SD-74 incorporated this change, but.the spec'i-
~
fication (present revisica 6, da.ted 1/31/83) was not changed'despite'
' ~
subsequent revisions.
- 3. The FSAR ' ste 4 l rips w ch can tripr the D-G breaker. The SKV switchgear SD ( 1-74, s .o 5/1S/83)1 ts 5 trips. The Diesel Generator SD
'c (50-76, ev. 1, 7/13/76) li,sts o ly 3 trips.
verspee Gen. v0
'fferb- ial 'urr.nt 1.ube Oil s re j Eus ult .-
S' Signal and Offpis Skr cl ~ .a
~
- f. . Drawing 9763-F-300219, Service "nvi nment Chart, Rev. 3, 6/24/83 refers to two documents,Thich as listed an the drawing co'not ed st. These documents, that exis't under other nao s and numh s, ntain 'ata on integrated radiation dose values and tei era 'r , r.ss . e profi s cutside cor.tainment. No technical errors were fou d on the chart.
- 5. UE&C Service Environment Chart, Rev. 9, 6/26/79 pecifies a ma ~m m
. external temperature of 148 F. for .the PX Enginee 'ng CBS wia n valve encapsulation vessel. UE&C Spec.ification 97'63- 6-4 , Containment e
Recirculation Sump Isolation Valve Encapsulation, Rev. 3 Og28/81, specifies 140' F. maximum external temperature. 23 - esa-e. a
JAN.10 1984 L
- 6. 'E&C U Drawing 9763-M-505300,. Class'1E' Equipment List, Rev. 10, 4/27/83.was not signed, reviewed or approved in accordance with.QA Proce' dure QA-3,:
Design Contro_l, Rev. 1,2/14/83. Previous versions were apparently not .
. controlled ei ' e ,(Al .see I&C #2) .
~
f
- 7. UE&C alcu u n 63-3-ED-00 3-F Power Cabl.e Application and Sizing
~
'I Criteri Rev.-4, 8/12/83 uses 4
- for the maximum ambient temperaturd' in the Mai Fee'dwater - M n team iping Enclosure Building (Main Steam-
~
Feedwater Eas- VE& ra h973-F-3 219, Service 'Environme,nt' Chart, Rev. 13, 6/24/83 peci ie 30 F. (54.4 C.) as the maximum ambient.
- 8. UE&C Specification 97 -006-248-47, 4/28/81, R r. 3, specifies in Sections 2.7.4.1 and 2.6 that the lectric-1 p etr uions f the CBS sump' isolation valve encapsulation vessels ill 'ce u ected s to ste m or water. The penetrations, purchased from C ax, are not qualified r steam or water as far as we can tell. Have'requ ted P.O./ spec. t'o Conax but not received yet.
- 9. .UE&C' Weld drawing 300209, Rev. 5, 8/31/83 . ecifies. held configura 'on for motor control centers, 3/16" fillet x 2" ng. The seismic quali i-cations ' report SC-275, Rev. -3, dated 3/10/82, At chment C, drasi, R344-4 Rev. 2, .' dated 10/24/79 specif-ies' a 1/4" fill t weld 3" oe The welds are installed'in accordance with the 300200 rawy g.
m
. k
- 10. Seismic qualification docunentation (Report SC-275, %v. 3 dated . )
for motor ' control centers purchased to UE&C Specification 9763-006-143'-1, , 24 aga es N *-
- I
. , . . . . . . . = . ..: . .- *
- JAN 101gg4
~
Rev. 8, 11/30/82 does 'not comply with the requirements of IEEE Std. - . 344-1975, Section 8.5 "Entropolation of Data". The' equipment tested' was not'the s,ame as e equipm'ent supplied.
) j Test Actua.I
. 'i Height 9" 12"
- b. Ground Bus Size . 1 x 1" 1 x_2"
- c. eak'ers 'one JL Type. Frame Installed
. h . .
~
- 11. Welds specified sei mi qualification eport SC-275, Rev.' 3, 3/10/83 (i" x 3" long) does not meet American Weldi, a Society (AWS) Std. D.1.1.-81 that specifies for 1" bickor less wel+ fille be the same size'as the plate. The plate is 4/1 '. Hen he we d spe 'fication is incorrect but.UE&C weld. drawing speci, es 3/1 " at is corre ' (see item 9 above).
Per 9 above, qualification was ase on 1" . The welds re 3/16".
- 12. Weld drawing R-344-4,.Rev. 2, dated 0/24/79 w ch c d an approved by the same individual in violation of th FSA,c .. .en. in SecJon 17.1.1.3 that commits to sepa? ate checkers and. app vers.
~
Thiis also viola s Gould
,d-QA manaul Section 3.3.10 that requires diffe nt pecple as checkers approvers. .
- 13. Brown-Boveri Qualification reports RCC-323.74-64 Re 3,. 'ated 3/10/82 for_MCC's and R33-50750-QS, Rev. 8,,9/29/83 for Swgr in 9; ate that control wiring is GE type SIS #or ITT Surprenant (s milar to GE SIS). Th'ese reports centain data supporting the qualification. ,The Bill .
25 l .
^
~~ ~
. JAN 10 35g4
~
l - i of Material (5HK-350,'S.0. No. 703-50750 sh 1 thru 9) for swgr and UE&C. FP-31151-03, Rev. 3, 1/29/80.and FP-31151-04, Rev. 6, 5/25/80 for MCC',s;
' ~
indicate that, control iring in both sugr and MCC'.s is GE type SIS Vulkene. GE i r ,to uld of 1/22/78 (included in the qualifica. tion
- report) at th lt the SI wire is not' qualified to IEEE Std. 383 and 323.
The actua,1 'n'sthll'ation ic I Vulk ne wire in' Swgr and SIS Vulkene Suprem$ in th MCC' eve ug the B'll of Material says, it, is- Vulkene' Supreme in both aces _15 . The Class IE battery s ing calculation -9763-3 'D-00-14F, Rev. 5,12/29/82
< t uses a capacity rating; fa tor for e it x 120 battery wherea~s an NCX 2250 battery is.actually use . ' A's r term tapacit margin of 21% was.
present,(n the calculation whe as u ing the actual bat 'ery only a 16% rr.argin i.s.present. Long term cap ities of both ba'tterie is about the same and long term c'apacity is contr ling in b ter" elect 1 n at present. W
=
- 16. CBS pump motor outline drawing, Rev. 3, 10/9 8 states bearing operat'ng temp'eratures"should not' exceed 95"C.
The;CBS pu.o instruction .a al FP52764, 5/9/83 states the bearing temperature sho 'd not . ee ., and that the unit should be shutdown.if oil temperatu re ches 71*C. P Meeting notes. between W and UE&C att. ached to UE&C letter (W SBU-78480,, i 9/20/83 states that maximum allowable oil -temperature ~ is 85* to 90*C. Bearing temperature is alarmed at 80 C. on the stati'on computer. ~
- 1 1
h i k !
,i 26 .
. . . - . . . 3- . - ur .
.n
a y .
? -
V. I&C ,
- 1. Two errors, one a su traction error that produces a result with more
~
significant fio es tha the original values and, secondi a transcription.. error sub + tu ' . 8.3% r 78.8% resulted in a setpoint calculation erro for 1 - w-1 leve alarm setpoint on the RWST. The correct answer 'as 11 .32'and the answe (110.25)'given on.' Sheet 19 (8/12/83)~ of UE&C ca culati.on 4.3.5.3 was error. The calculation was checked on' 8'/25/83.. p -
- 2. . Two UE&C equipment list , the standard Equ ment List, and the Standard Instrument Schedule h ve no provisions ,fo,r th signature of the preparer
~
sign docusents.and not
- or a reviewer or checker and are app .. El not centro 11ed in accordance w1 h.de~ , I ol proce res QA-3, for example.
The documents are not st'amped 'for .ormat' ion only." This'is a violation' of GAP-0007, Rev. O 6/25'/75.e'.d
-27 Rev. 4 5/18/82 for. he Standard Ecuipment List.
- 3. Tobar, a Westinghoust, subcontractor for s- ply of pressure transm tiers approved' exceptic's to a subcontractor spect ication 5519A54, Rev. c ,
8/3/83 for tantalum. capacitor .without an indepe dent technical view c
- approval. 'Th.
e exceptions'. involved how many capac ors would I t s ad l involved . (50 or 100) and for how.long (2000 or 1000 hours). e oc , l a possible waiver of elevated temeprature leakage tests.$This violates - 4 TOSAR Procedure PI-1 Section 3 on Desion Control. i ti . 27 ,
+eme ee- =e 1
.. . . . . . . ...=. . - . . . . . . . .-
JAN 101984
~
L ITT Barton test plan 9999.3155.2,'Rev. 1, 1/29/82 has not been-accepted
~
- 4. ,
by UE&C because test temperature and ;adiation dose (integrated) have not. been agreed tp. The st covers pressure switches. These switches have been delivere an a.ccep ed by UE&C Field QA. No qualification report has
~
been pro ide o 1E C and Environmen'tal Qualificationker IEEE 3[Qt Repor has e - tte'n . Thi violates QA-10., Inspection Control, Rev. 3,
' l'0/23/7 Section IV, Procedure
- 5. Tobar Inc., t. t su ie el transm'tters for Seabrook _(inc1'CBS)'hai changed their or niza io structure to make engineering and QA in-sufficiently indepe ent. This is related e Finding *3 above. The change in organization 1 structure violat'es To' r's Product Integrity Manual PI-1 Section 2r2 w ich re dic ating of PI-1 Nuc Cual Programs and PI-2 with orm ation of nges to holders cf controlled ~ copies of the Man 'al.v Group A transmitte. have not yet
~
been,shi.pped for Seabrook' Unit 1.
- 6. UE&C Drawing C509037, Rev. 0 10/5/81 "B ek
- rc ,
ontains fety related equipment but'is not marked in acc dance w th IEEE Std 49 -1974. This is. in. viqlation of GEDP 0013 Rev. 3', 3/3 81 and AP 28, Rev. 6, ! 1/4/83. Num'erous Westinghouse' drawings, Tobar a d Barton (W su drawings also' do not contain the nuclear safety re ted id ai
~
ui f. . P
- 7. Barton model 351 bellows pressure tr.ansmitter is used toOtansmit a
~
pressure signal representative of containment pressure to a tranducer-placed outside containment WCAP-8687, July 1981 indicates that th'e , 28
. em e. m e
agy 3 g gg4
. w S .
i s'ensing line must be filled.with Dow Corning 702 rilicon oil to be . qualified'for the expected environmental conditions'. The Westinghouse specification, sheet a licable' to these. devices allows either oil or. water. (Spec t 325 AH 1141, Rev. 1, 10/17/79, Rev.'7, 6/9/82,and Rev. 9, ' 24/ . f esting use drawing 8765052~ Rev. 3,.9/1/82 specifies Dow rnin euc icdn oil. The instruments are iiot installed. UE&C
' h'as not pprovedRev.3of.thehdrawing. Rev. 2, 2-/20/78 of the drawing l speciifes ter' fill and s pro d by UE&C 1/4/83. Hence, the currentiy app ved ;m wi hd he re ired instrument l'ine fill. material' are inconsistent.
- 8. Westinghouse P0 546-AL -285480-BN 7/26/-78 spec'fies 10 CFR 21 as applicable i (' ITT Barton to ITT Barton pressure t nsmitter ior co vainme t pressure.
Y of 5 "Baseli e Parts List Engineering Instruction EI. 16,.s'he t Preparation Instructions" orig al issue date 3/25/81 ecifies required entries.o.n the bill of material I ts. On ITT Barton bil of material lists a space is provided for indica ing that 1r cFR appl as. Six bill of material' lists for the transmitter w re r v 4 _w . .. ne, cont ined refe'rencerto 10 CFR 21.
~
- 9. On 11/12/81' Westinghouse submitted environ' m enta, and seismic t u repor (WCAP-8687, Supplement 2', Rev. 1,'E16A~& E16Bda'te 7/81) e th lid state protection system'. This report was not.entere into e e foreign print system.in violation of AP-29, Rev. 7, 4/12/83 Sec P - IV, Procedure,
~
Step 3. -(It was logged in after being discovered during the inspection.) 29
, me
.. ...... . .2 . ..
JAN 101984
.0 t
- 10. VI&C CBS Senematic Diagram M-310900 Rev. 9'6/29/83 does not agree with
~
Westinghouse Solid State Protection System Interconnection Diagram, . Sheets 20, 26, and 3 Revision 4, 6/21/83, foreign print 70073-7. 23' solid sta ou ut re ay contacts were checked, 3 differences were found, f I
\ -
~
T1. G'ould Qu lification Report CC-3.2 74-93 Rev. 1, 11/9/82, states that
~
"foll.owing eisinic, test er cond ted to confirm the' Class 1E
- functions of s riou_ dev' e in luding thermal element t' rip s,ettings("
A review of this epor d s not provide irect evidence that Class IE'
~
and non-class IE ty E22 and B0 circuit bre kers used in control circuit applicstions e been verified -f"o_r f t current interruotion (. z ca'cability following the ismi .. in ests. YAEC has state'd that associated circuit fault- cur. ents', s+ lated from f 41ure on non-Class-, IE loads,. are interrupted by c1 cuit breaker operation; however, this
~
statement cannot be confirmed fro. material present t UE& . UE&C has reviewed Gov'd proprietary qualifica #on docum s d has st ted their acceptability, but has not explicitly c fi r , t. fau t curre inter-ruption aspect in the' breakers. subjected t seismic. tests.
- 12. FSAR' Appendix 8A, Secti n-5J1[2 and IEEE Std 384 974 require e ed Class 1E raceways to be ' marked distinctly and in a emaner ma e
\
identify Class 1E separation groups at 15 foot interva s ano at points- l
%~
of entry to and ' exists from enclosed. areas. This is not ne for conduits. Conduits are marked at each end. In a telecon between YAEC and UE&C on 6/20 and 23/80 UE&C argued that the 15' maYkings were - , 30 1
. . . . . . = . . - .. .
JAN 101984
.c .
L riot needed. YAEC concurred.and requested UE&C provide written justifi-cation. Sech justification was not provided. Note that the FSAR Section 8.3.1.4 state that raceways are identified at each end and at both sides of a 's, fl rs and in-line tioxes in conflict with Appendix 8A,'Sec 'on .2L o\ . I
~i3. W Syste.. Description NAH/NCH-284, Rev.1, date August 1976 requi.res in '
Secti,on 3. 4.3'.d that y es HCV-6 6 and HCV-607 be left in the full open position urin _ no pe ation a maximize flow from t,his system to the reactor c lant sy em during the 'njection phase of safety injection system op ation. However, the v 'ves are controlled by manual hand switches with two os.itions , open 'an'd mod ' ate. In the modulate
! i position, the valves are ontro ' s cur ent to ir converters. No.
automat.ic, protection system i gna'l s ovided to ca e the valves to, move to full open- position whe , nee ed. This is consic red a violation.
~
of IEEE Std 279-1971 Section 4.12. Failure to move oth v lves to the full open position will degrade-the rformanc fF t. RHR ains simultaneously. .
,Similarly bypass- valves RHHCV 618 and 619 p.ro ide bypass around the _R.9
~
heat exchangers. Hand switches without automat 1 protection sy t override are 'provided for these switches also. Fa1 ure to . v en s valves to the close position results in reduction of , R c. oling. e f I 31 :
- I
o - o JAN 101984
~
Q - . Failure to move valves 606 and 607 to the open position and failure ~ to move l valves 618 and 619 to the close posit. ion could seriously degrade RHR , performance.. The^ cur nt + ai convert s for all four valves are-not safety-related. Failu e of + e ani! 607 co erters can cause loss of flow through the-
'I RHR hea exchanger. If at.the.s .e time the 618 and,619 converters do' not fail, Rf'loYislo in the e fected trains.
~
la. UE&C Specificati 976 -0 -171-1, Instru ent Racks , Rev.. 3, 3/14/80,. requires Mercury of 'forwood to procure na' d 1 stall safety-related. terminal blocks in jun tion boxes for i'nf onta, ment and ex-containment ( locations. The UE&C spec'ficat'" ca s f r Stat Co, ZWM terminal blocks. The Mercury of Nork rd B'il o Material DW ,19691'-702, Rev.: 3 12/3/82 requires the States Co. terminal. blocks. The B'll of Material .is labe. led Seismic Nuclear Safety' Re t ted. The Mercury of No cod purchase requisition specified the States Co. WM termir i b' c. and 'dentified the purchase as " Nuclear-NO," Mercury P cha. xe 1si6 ion.6830 N1969 5/10/82 and 66180-N1f691, 12/12/80. Mercu ' QA reviewed and appro d the .
. Purchase Requisitions. .
~
~
A letter from~ States to Mercury dated 3/23/77 state the Z ' . t .1 blocks arenot qualified IEEE Std. 323'. w 32 m eeee.e .e.ne o- . * -
o . JAN 101ce4
~
p-- On 6/9/80 Mercury informed UE&C that the terminal ' blocks were Tiot qualified'(by telecon). (Mercury telecon note) UE&C directed Mercury , , to use the terminal b ocks. . On 3/30/ 1 Ma urkHotifie UE&C by let'ter that the States terminal blocks
-were ot q 1 . dn 4/13/ UE&C letter SBV 43972 to Mercury to . buy
' t'he te ..'nal blocks and submit,q lification documentation. For blocks' inside con inm'ent PSNH 1 -1452 11/18/82 recommended replacement' of the States'bl ks'w'. 11 r Bloc s. We have 'not r'eviewed'qualifi-cation of these plac me s.
, ,15. UE&C 1pecification 976 -006-171-1 Instr Went R ks, Rev. 3, 3/14/80 i
requiris procurement of w'res for oe n-c tainm t and outside' con-tainment and specifies an: ac iden't m _rature, pres re and radiation environment. Mercury of Norwoo purchase order #66166 /9/80.to Rockbestos and 66165 12/9/80 to D oron did not specify th temperature, pressure, or radiation listed in the 'E&C speci ~ cat o Me ury cited IEEE Std. 383 that references IEEE Std 3.
~
.. imum temper 'ure/
time profile in the IJE&C specification exc ds that specified in I CE Std 383/323-1974. The radiation specified .in the UE&C spec exceeds t at spec'ified in" IEEE.Std. 383. ,
- 16. UE&C specification 9763-006-171-1, Instrument Racks, v. , 3/14/80, w
requires wires in accordance with IEEE 383 and 323. Upo keceipt of the_ wire Mercury QA receiving inspection report 66165 dated 1/12/81 accepted the wire documentation as acceptable. The documentation re'ceived only
~
33 eeup e- e am.
- r .c- . . . _ _ . . _ - _. _ . __.
o
. JAN10 39e4
+ .
a'ddressed the wire flame retardance and not environmental qualification , as required by IEEE-Stds 383.and 323.
- 17. UE&C Specifi i (sa as #16) requires submittal of qualification documen io ron ercury f Norwood to UE&C (Section's 2.7 3 and 4.6).
The alif a 10 documentati was not provi.ded to UE&C. Further'the T UE&C ven or surveillance check .p n for the Mercury ' contract, Rev. 2 9/15/82 do not' list en on. ental qualificati,on reports to be. reviewed by VE&C in~vi atio of ' ' QA 7-2, v. 15, 10/31/81. _,
- 18. The containment, enc sure emergency exhaust ilter system is an ESF.
system that starts aut matically after 1rf acci nt to maintain -1/4" WC pressure in the Contai. ment b 's e. ontro. hand switches '(one.
- per train) are-provided with two'po it' ns (open and uto). The switches ,
are normally in the auto positi n so that when the syst m starts it wil.1 be able to maintain the prescribe negative presiiure In he auto
~
position these sWiches allow curren to air pr sur ntrot ers to adjust the fan vortex inlet. damper that ont ' s the prescri d negative ~ pressure. These current to air p ssure controllers are t safety related and are unqualified. If they re exposed to a severe environment'or seismic even.t t' hey can fail'and c use the fan vo t inle
. .s .
' dampers to close. If both I/P converters fail in t at manr b n t ains ,
are rendered inoperable. This is a violation of IEEE td c 9-1971, IEEE Std 379-1972 and Reg. Guides 1.52 and 1.53.- w( 34
, .= "- ~ ~
o ..- JAN 101934 ;
~
- 19. UE&C Specification 9763-006-170-1; Main Control boards, Rev. 5, 11/2/81 requires York Electric Panel to'.submi,t to UE&C for ' approval documentation ,
. ~
to support wire flame retardance and environmental qualification par.IEEE Std 383-74 an ~E.Std 23-74. York received ' certificates of con,ftrma.nce and some .est at),;all of hich was ndt.submittedito UE&C in violation. of the a ove ' e .
- 20. UE&C Qualis Control Vend rveil ance Check Plan for specification 9763-006-170- Mai on 65)hords, v. 5, 11/2/81', identifies.that IEEE 323 quali.fi tion coc' ..entation and 'EEE Std 383 flame test reports' for wiring be sent UE&C for review and a roval as specified in Section 3.14 of the sp cification. This'docum tation was not submittec i t' '
.d UE& QA procedure QA-7-2, te UE&C in violation qf t e QC cha" lan Rev. 15., 10/31/81. .
- 21. A seismic event could cause simul neous fai. lure of~both 6 ains of the primary component cooling water syst m.
Contributing causes are:
- 1. Use of non-safety current' to air converter for valve cont o
~
in the PCCW. C/I converters are TY~2171 4 and 5, and TY ' 1 n 5. Th .
- 2. Lack of . separation of safety and non-safety wiring 9[ wire bundles contained in panels CP108A and B.
ee m .. eere s
c ..- _ -_ ..a - _. . . , JAN 101984 o ., l
.- l Lack of separation of safety and non-safety wiring on terininals of' '
~
3.
'2 transfer' switches (SS-2171 and SS-2271).
The safety sig used position primary component cooTing water . system va es * ;h ir sa position is defeated by the,above.
- 21. A Primary "omponent Cooling. water eat exchangers operability is controlled by non-saf ty current to a ressu e controllers' in b.oth. trains. _ Control t tdr press e controllers is physically tied -
~
wiring-for th se cur together (in eac tral , wi n safety rel ted wiring for safety.related - solenoids (one each trai ) which are used t control ~the position of the heat exchanger outlet nd bypass valves.,,Thes safety,and non~ safety - wires ars connected to_'~ t .same rern- e tran fer s itch in each train. Failure, cf .the non-stfety; r 'atec ,e 1pr.nt q can cau incorrect control signals, grounds, hot shorts,b twee, conductors, open 'rcuits, or hot shorts b,etween transfer switch' te inals. S.uch failures uld cause energization of the / safety related s 'lenoids on + ie h t exc. anger valves simultaneously in both trains. Energi tion of .ee enoids will to the failed non-saf y
^
revert control of the. heat exchanger valv current to air, converters that cause the. va,1 s to close. Closin'g t se valves causes failure of'the PCCWS (both trains,
- 22. UE&C Specification 9763-006-U4-2 Rev. 10, 7/1/83, El ctro, i Contrcliers and Racks, requires isolation devices be previded to ins that any mal-functions of non-safety related instrument loops will not effect sa'fe"ty related instrument loops. No isolation devices were provided in parei-36
o + JAN 101934
.e CP-152B where non-safety instrument loops are in the same pane.1 as safe'ty '
related instrument loops.
- 23. UE&C Spec 170 , .ev 5, 11/2/81 requires York Electric Panel to procure ,
and inst M e r q pecial ies Co. Series 90k backlighted push button - swit ~es o s. m n control ard for use with safety related status
't monitor 'ights. These switches re required to be seismically qualified.
i York did n
- obtain seism' 'alif1 ation documentation for these switches as r ui re y he ificas'en, sections 2.5.2.5, 3.11.3.5 ~ -
and 3.1a. 24 UE&C Spec 170-1, Main ontrol Boards Rev. 5,1 2/81 requires York Electric Panel to procure and i,ns 11 safety elate seism'cally qualified terminal blocks 'for .use with safety latet i its. York ocured i'TC termina.1 Diocks as NON safety related a wi .. out seismic quali . 4 cation. These teminal blocks are used as shipp g split points on the in control board sections. This involves Class 1E circuite .cr s Ive p ition status lights, Class 1E valu.e controlle pow r e ie., Class E system status. lights, status lights for the reacu r trip circuit breakers SI cross connect valve control circuit, and pneu atic-operated containn t isolation valve control solenoids. 4
- 25. RHR valves IRH-HCV-606 and 607 have non-safety limit switches wired to the Class 1E main control board system status monitor light. panels 37 me .-e S.
r . .: - . - . . . .. -. . . .. O .. e
- JAN 10 1984 i
- . l
\_ 1 l
MM-UL-2 and 4 (Trains A and B). These lights display status o.f ECCS injection valves and pumps and c.ontainment isolation valves. The RHR
~
valve position switc s do not' have seismic qualification documentation.. The same thin' true r associated push.to. test button's and terminal
~
blocks (r qu dipc q. Gro d faults in these circuits could disable the Clas 1E s . . . . s* tus monito panels fo.r both A and B trains, if a-
'I s'eismic vent were to occur.
- 26. PSflH. prepared main a+h.pters cification #146-01, Rev. 9, _
6/3/82 (Foreign rint ' 13 . Standard sign control provisions have not been used. fio signature indicatin preparer, review and
, approval are given on he document. .-.
9 s g .
. t t
l 38
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