IR 05000443/1986051

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

ML20207N166
Person / Time
Site:	Seabrook
Issue date:	12/31/1986
From:	Kamal Manoly, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207N160	List: IR 05000443/1986051 ML20207N158 ML20207N166
References
RTR-REGGD-01.029, RTR-REGGD-1.029 50-443-86-51, IEB-79-14, NUDOCS 8701140025
Preceding documents:	ML20212K845 (9 January 1987)
Download: ML20207N166 (28)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-51 Docket N License No. CPPR-135 Category A Licensee: Public Service of New Hampshire P.O. Box 330 Manchester, New Hampshire 03105 Facility Name: -Seabrcok Station, Unit #1 Inspection At: Seabrook, New Hampshire Inspection Conducted: October 28-31, 1986

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Inspectors:

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/YTC/86 K. Manoly, Lead Reactor Enginelir date Approved by: ,, /2/J//84 Strosnider, Chief, Materials and date yProcessesSection,EB,DRS

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Table of Contents Page Executive-Summary 1 Persons Contacted 2 Inspection Objective and Scope 2 Allegation Description (RI-86-A-0113) 3 Safety Related Piping Systems As-Built Inspection 4 4.1 Overview of the Piping As-Built Program 4 4.2 NRC Walkdown verification of Piping Installations 8 4.3 Findings 9 4.4- Conclusion 10 Review of Other Program Activities 11 5.1 General 11 5.2 IBuilding Beam Verification Program 11 5.3 Seismic II/I Interaction Program 12 5.4 Failure Modes and Effects Analysis (FMEA) Program 13 5.5 Conclusion 14 Exit Meeting- 14 Attachments Appendix I

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EXECUTIVE SUMMARY Region I performed a special inspection to evaluate alleged discrepancies at Unit I of Seabrook Station related to the as-built drawings of safety related piping and support systems. The NRC inspection also covered several other programmatic activities which included the Building Beam Verification, the Seismic II/I Interaction and the High/ Moderate Energy Pipe Break Whip and Jet Impingement Load Verification Program The allegation was made by a former licensee contractor and it primarily dealt with concerns over the accuracy of the measurements provided on the as-built drawings and their impact on the adequacy of the piping stress reconciliation effort and other programs that interfaced with as-built conditions. Details of the alleged discrepancies in the as-built piping and support drawings and the NRC evaluation of these discrepancies are provided in Appendix I of this repor The processes of piping installation and as-built verification had been examined and-reviewed by the NRC throughout the construction phase. This special NRC inspection, in response to the allegation, consisted of:

(1) re-examination of the programs which governed the piping as-built verif-ication effort (Section 4.1) and the other activities mentioned by the alleger as potentially deficient (Section 5), and (2) verification of final as-built piping drawings by performing independent measurements of piping sections addressed in the allegation and other randomly selected piping systems (Section 4.2).

The NRC review of the programs for piping as-built verification and stress reconciliation were found to be consistent with accepted industry practice and were in compliance with NRC requirements set forth in I.E.Bulletin 79-14 for as-built verification of safety related piping system Based on NRC independent measurements of plant systems, it was found that the final as-built piping drawings were within acceptable tolerances set by the reconcilation criteria. The as-built drawings supplied by the alleger were not consistent with the plant as-built final drawings and apparently were drawings used in earlier evolutions of as-built verification The approach used by the alleger in performing the interference evaluation relies on very precise and accurate measurements and a reference system that is primarily used as a construction aid. It is not necessary, nor is it common industry practice that measurements of this precision be made to support the pipe stress reconciliation effort. The use of building reference points introduces errors because this information is not updated and only utilized to aid construction forces in locating supports in a general areas. It has no bearing on final interferences or stress calculation Based on the NRC evaluation of licensee programs for the performance of safety related activities, it was concluded that the programs had met the intent of the regulations and were substantially in conformance with established industry standards. The NRC concluded, therefore, that the allegation involving the adequacy of safety related piping as-built drawings and other safety related activities at the Seabrook Station is unsubstantiated. No violations were identified during this inspectio _

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1.0 Persons Contacted 1.1 New Hampshire Yankee (NYH)

• J. DeVincentis, Director of Engineering

• T. Pucko, Senior Licensing Engineer

• T. Cizauskas, Lead Mechanical Engineer

• D. Perkins, Licensing Engineer

• S. Sadosky, Manager EAR Program

• Sullivan, Senior QA Engineer 1.2 United Engineers and Constructors (UE&C)

8. Huselton, Project Engineering Manager G. Tuday, FMEA Group Engineer D. Mehta, Seismic Coordinating Engineer J. Parisano, Piping Engineer 1.3 CYGNA Energy Services

• P. Baughman, PAPSCOTT Coordinator 1.4 Computerized Interference Elimination (CIE)

S. Mitchell, President S. Nicholson, General Manager U.S. Nuclear Regulatory Commission (NRC)

• A. Cerne, Senior Resident Inspector

• D. Ruscitto, Resident Inspector D. Haverkamp, Reactor Project Engineer

• Denotes personnel present during the exit meeting on October 31, 1986. Inspection Objective and Scope The objective of this inspection was to evaluate alleged discrepancies in

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

Westinghouse (W) and United Engineers and Constructors (UE&C), and to assess the potential effect of utilizing these drawings in the performance of activities involving Building Beam Verification, Seismic II/I Interaction and Failure Mode and Effects Analysis. To achieve this objective, the inspection focused on the examination of programs which govern the above activities and on the performance of independent measurements of piping sections addressed in the allegation and other randomly selected piping systems.

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

The Region I (R-I) Office of the NRC was notified by the Region III office of an allegation involving as-built drawings of safety related piping systems at the Seabrook station. The Region III staff was informed of the allegation on August 5, 1986 while conducting an interview with personnel from Computerized Interference Elimination (CIE), a former contractor to New Hampshire Yankee (NHY), regarding alleged discrepancies in as-built drawings of piping systems in Units 1 & 2 of. Byron Station. A copy of the allegation interview transcript was transmitted to the R-I Office on September 19, 1986. Two lead Reactor Engineers from the R-I Office traveled to Redmond, Washington on October 21, 1986 to interview the two principal allegers from CIE identified abov The allegers identified certain concerns regarding the existence of discrepancies in as-built drawings of safety related piping systems designed by Westinghouse {W) and United Engineers and Constructors (UE&C)

at the Seabrook Station. CIE provided the NRC staff with copies of piping drawings prepared by W and UE&C relating to the systems involved in the allegation and six other drawings prepared by CIE depicting the alleged discrepancies. The discrepancies were noted during the performance of interference verification utilizing drawings provided by the licensee (NHY)

and information obtained by telephone from NHY, W and UE&C. Five of the six alleged discrepancies involved walkdown, marked-up drawings by W which were not approved as final. The allegation primarily dealt with concerns over the accuracy of the measurements provided on the drawings and the impact on the adequacy of the licensee's pipe stress reconciliation effort It also referenced other design activities which could potentially be

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affected as a result of using input data from as-built drawings containing discrepancies. These activities included Building Beam Verifications, Seismic II/I Interaction, and High/ Moderate Energy Pipe Break Whip and Jet Impingement Load Verification Program The alleged discrepancies in the as-built piping drawings involved apparent offsets in the location of certain piping sections or supports. The offsets were noted as the alleger attempted to trace. piping system configurations and related supports from information provided on drawings of walkdown isometerics, penetration sleeve details, building steel floor layout, concrete wall penetration location, and pipe supports detail / reference location. The magnitude of the maximum alleged dimensional discrepancy was approximately I'-6".

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The specific discrepancies, according to the alleger, are summarized in Appendix I of this repor .-

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4. Safety Related Piping Systems As-Built Inspection 4.1 Overview of the Piping As-Built Program The scope and controlling procedures for the as-built program of Safety Related (S/R) piping systems differed according to the organization responsible for the erection or the design and reconciliation of com-pleted installations. Though the majority of S/R piping and support installations (except for the primary coolant loop) were fabricated by DRAVO and erected by Pullman Power (P-H), the responsibility for the design and reconciliation of ASME Class I piping was that of W and for Class II, III and ANSI 831 piping was UE&C. As-built verifi-cation of completed piping installation was conducted twice, first by P-H as part of the ASME code "NA" certification prior to turnover and second, by W and UE&C in support of the stress reconciliation effort of their respective pipin The inspector conducted interviews with cognizant licensee representa-tives and reviewed procedures (Attachment 1) established by Westinghouse (W) and UE&C which governed some of the activities performed by the Piping and Pipe Support Closeout Task Team (PAPSCOTT). These activities included the as-constructed walkdowns and the stress analysis reconcil-iation and pipe support verification tasks in support of the ASME N-5 certification progra The flow chart in figure 4-1 depicts the sequence of activities involved in the ASME completion program for piping systems from the design phase through code certification. The numbers in the flow chart blocks identify the sequence of certain activities performed by the engineering / design and installing organizations. The as-engineered piping was typically shown on design isometrics by W or UE&C (block 1). The desigr. isometrics were transmitted to the fabricator (DRAVO)

for preparation of piping spool drawings. These drawings were used by the installer (P-H) for the preparation of erection drawings and subsequent piping erection (block 2). Field verification of piping and related components installed in accordance with ASME Section III was performed by the installer prior to turnover to satisfy code certification requirements. Data verified during the installer's walkdown were either incorporated in revised erection drawings or red-lined on current isometrics (block 3). Walkdown verification of as-built piping installations was subsequently conducted by the engineering / design organization for the purpose of piping stress reconcilation. Though some of the verification attributes were common to both walkdowns, the piping data verified during the recon-cilation effort were pertinent to piping stress analysis and code acceptance limits. Results of the latter walkdown were recorded on marked up isometrics (Block 4). These isometrics were considered final when the marked walkdown drawings were signed as approved, as in the case of W drawings, or when stamped "As-Constructed", as in the case of UE&C drawing . . . _ - - -

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- The significant features.cf the piping as-built program which related to the allegation concerns are presented belo As-Built Walkdown Prior to Turnover-

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Interface activities between P-H, UE&C and the startup test department, relative.to the release and turnover of systems were described in P-H Procedure X-2 Documentation of field verifications, final inspection and final _ review of ASME III piping was governed by P-H Procedure X- The walkdown was conducted by P-H field engineering in. accord-ance with walkdown_ implementing Procedure No. X-30 for field verification and recording of piping linear measurements and elevation Field verification of supports was conducted to P-H Procedure JS-IX- Walkdown packages including as-built isometric drawings and walkdown verification forms were transmitted to P-H/QC fo _ performance of final piping and support inspection ~

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Walkdown packages were transmitted to P-H/QA for review of completeness prior to the sign off on ASME Code "NA" certi-ficatio Data recorded during the as-built walkdown were either_incor-porated in revised erection isometric drawings (prior to mid-1984) or red-lined on current erection isometrics (after mid-1984).

II. ' Piping Qualified by W

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W generated the piping design isometrics using original UE&C j isometrics, and performed the piping stress analyses of record, f --

As-built piping walkdowns were performed by teams including engineering and surveying personnel to' record piping config-i uration on the design drawings in accordance with Procedure l- SSP-1. Angular measurements were recorded at elbows and pipei l bends, though no specific tolerance was provided in procedure

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

noted in a correspondence between W and NHY.

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Marked-up walkdown drawings were reviewed against change documents and other design information for evaluation of discrepancies identified during the walkdown process.before final approval of the drawin Reconciliation of as-built installations addressed five categories involving piping configuration, pipe supports, pipe properties, loading conditions and interference The acceptance criteria for the reconciliation effort were stated in Procedure SSP- Piping neasurements which exceeded the reconciliation accept-ance criteria were reconciled either by hand calculations or computer re-analysis, and noted on final analysis isometric drawings. However, measurements which fell within the accept-ance criteria were not noted on these drawing Final piping as-built packages consisted of approved walkdown isometric drawings containing three signatures, final analysis isometric and stress analysis repor III. Piping Qualified by UE&C

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UE&C generated piping isometrics which were used by Pullman Power for the preparation of installation drawing Location of piping supports during the installation phase was based on measurements provided on each support drawing from nearby building elements such as walls, beams, columns, et These dimensions were provided in addition to location plan measurements which were intended for reference purpose only.

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

, to update the piping isometric The elements of the piping as-constructed walkdown data collection were described in procedure FAEP-1. Design drawings and checklists were used to record walkdown data which include: (1) location of pipe supports relative to the piping; (2) location of floor / wall sleeve and gaps relative to piping; (3) pipe support function; (4) pipe support gaps; (5) location / orientation of welded attachments; and (6) build-ing location dimension Additional requirement regarding the walkdown data collection and the accuracy of measurements was provided in Technical Procedure TP-2 _ - . .--

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Verification of piping as-built angle data was not addressed in the walkdown procedures. The rationale for not performing angular measurements during this phase included consideration of very stringent tolerances in the location of end components and the fabrication and erection of pipe support components and piping spools. Variations in piping segments length due to cutting or addition of sections during fit-up of spool pieces were verified and reconciled during the walkdown effor Results of a confirmatory walkdown conducted in 1983-1984 were provided in support of the above rationale. The walkdown involved approximately 500 drawings for verification of piping bend angles as well as end-components and support location Evaluation of the results from 130 drawings indicated that angles were within 5 tolerance of drawings or ECA' Dimensions verified in the walkdown effort were circled on the final as-constructed drawing The evaluation criteria and acceptable tolerances used for the reconciliation of as-constructed installation were stated in Appendix "C" of Procedure PGL-7. The tolerances were consistent with the recommendation in a technical position paper on piping installation tolerances sponsored by the PVRC technical committee on piping systems and published in Bulletin 316 of the Welding Research Counci Firal as-built packages consisted of isometric "As-Con-structed" drawings reflecting walkdown measurements, final analysis isometrics and stress analysis report .2 NRC Walkdown Verification of Piping Installations A physical inspection was conducted, by the NRC inspector of piping installations referenced in the allegation and other randomly selected systems. The inspection included several piping segments of the RHR system inside and outside the containment (by W and UE&C) in addition to segments of the piping system from the accumulators (No.1 & 2).

The inspection utilized W stress isometric and UE&C as-constructed drawings. Piping segments and drawings used in this effort are identified in Attachment 2 to this repor The purpose of this effort was to examine the conformance between installed piping systems and the information recorded on walkdown and analysis isometric drawings. Though the processes of piping installa-tion and as-built verification were examined and reviewed by the NRC throughout the construction phase until completion, this effort was undertaken primarily to assess the specific discrepancies identified in the allegation and to further examine piping installations in general, for potential non-conformances of a type which would invalidate the piping stress reconciliation effor Examples of previous NRC inspections of piping as-built verification inspections can be found in Inspection Report Nos. 50-443/85-09, 85-15, 86-14, 86-43 and 86-4 .

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The verification walkdown included visual inspection and performance of independent measurement of selected piping installations. The attributes of the inspection included the following:

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Checking actual configurations against piping drawing Performing linear measurements between components and supports along the piping using a tape measur Checking piping angles either visually or by trigonometric correlation of linear measurements on piping legs where possibl Checking valve types and taggin Checking support types to verify restraint functio Checking clearances between piping and supports where require A total of 153 linear measurements were verified during the piping walkdown, of which 98 were performed on W piping and 55 on UE&C piping. It should be noted that the majority of piping inspected was insulated; thus, measurements which were difficult to perform were considered acceptable if within 2" of recorded dimension Measurements performed on W piping which exceeded the walkdown acceptance tolerance were later compared against recorded measure-ments on walkdown isometric drawing .3 Findings The following findings are based on the NRC review of the piping as-built program, walkdown verification of selected piping installa-tions, and examination of alleged discrepancie . The procedures established for the performance of piping as-built walkdown verification and stress reconciliation efforts were found to be consistent with accepted industry practic Further-more, the licensee's approach to the as-built process met the requirements and intent of the NRC's I.E.Bulletin 79-14 in that it provided the needed verification of the attributes and dimen-sions, within acceptable tolerances, which define the relative

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configuration of piping and are considered critical to design and the validity of the piping stress analysis. Verification of reference dimensions which affect the global position, relative to the building structure, of piping and supports in three dimensional space was not generally included in the as-built program and is not required to be included. Verification of dimensions between piping systems and building structures is not required for stress reconcilation since the piping stresses are determined by the piping system geometry not the piping to building structure dimension . - _ . _ . _ . _ __ _ __

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10 The alleged discrepandes in as-built drawings of safety related piping systems were for the most part incorrect due to:

a) use of W walkdown drawings which were not final, b) introduction of erroneous values of piping dimensions at flued head sleeve anchors in the attempt to correlate dimen-sional information from sleeve detail drawings by UE&C and walkdown drawings by W (apparently the result of miscommuni-cation between the alleger and field personnel),

c) use by the alleger of several values beyond their intended accuracy, particularly with regard to support location reference dimensions and location of both building steel members and wall penetrations, and d) reliance by the alleger on exact values to be recorded on piping walkdown drawings while ignoring linear and angular tolerances which were inherent in the field walkdown proces Detailed evaluation of the specific alleged discrepancies is provided in Appendix I of this repor . Minor dimensional discrepancies were noted between linear measure-ments performed during the NRC piping walkdown and dimensions recorded on the walkdown drawings. A total of eleven (11) discre-pancies was found, of which eight (8) were within 3" of the walk-down drawings and the remaining three within 3.75", 5.5" and 6" respectively. It should be noted, however, that three of the dimensions with discrepancies involved measurements which were difficult to perform due to insulation and inaccessability of the piping system. Furthermore, in all of the dimensions involving discrepancies, the difference between the design and measured dimensions were well within the acceptable tolerance set by the reconciliation criteria. Thus, a re-analysis of associated piping would not have been require .4 Conclusion The inspector concluded that the program for the as-built and reconcil-iation process of safety related piping and support systems, qualified by W and UE&C at the Seabrook Station, were consistent with accepted industry practice and no items of non-compliance were identified with regard to NRC requirements set forth in I.E.Bulletin 79-14. Further, upon review of the alleged discrepancies and performance of walkdown verification of completed piping installations, it was apparent that the as-built drawings had reasonably depicted the piping configurations as required for performing the stress reconciliation effor It was also concluded that the approach utilized by the alleger in performing the interference verification relies on very precise and accurate

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measurements of piping components and building element Some of these measurements are recorded with tolerances (as in the case of piping and support systems), and the remaining are not typically verified in the as-built walkdown (as in the case of support reference dimensions, penetration and building steel locations, etc.). It is not necessary, nor is it common industry practice, that these precise measurements be made to support the pipe stress reconciliation effor Based on the above, it is concluded that the allegation involving the adequacy of as-built safety related piping systems at the Seabrook Station is unsubstantiate .0 Review of Other Programmatic Activities 5.1 Gereral The NRC review included an assessment of several other programmatic activities performed by the licensee which were addressed by the alleger as potentially deficient due to the alleged dimensional discrepancies. The programs covered in this effort included the Beam Verification, the Seismic II/I Interaction, and the Failure Mode and Effects Analysis Programs. The review focused primarily on the scope and implementation of these programs to verify their conformance to acceptable industry standards and their compliance to NRC regulation The review also covered the interface between these activities and the piping as-built verification effort to assess the alleged potential for ineffective evaluations as a result of using the piping as-built drawings in the performance of these program .2 Building Beam Verification Program The purpose of this effort was to verify that the design of category I structural steel, which was based on assumed loads, was adequate for final as built system loads. The program was managed by UE&C, and described in technical procedure TP-16. It was initiated in 1983 with the establishment of a data base of all appropriate loads required for the beam verification effort. The original design was based on consideration of assumed uniform loads in addition to known heavy attachment and equipment loads. During this design phase, the intent was to maintain flexural beam stresses below 18 ks The beam verification program was carried out in two phases. The scope of the first phase included an initial verification of framing systems using discrete design loads and locations for major attach-ments, such as large bore pipe supports and equipment, and appropriate (envelope) uniform loads for attachment of cable tray, conduit, I&C, and small bon pipes. Structural weights and live operational loads were also considered in this phase. The magnitudes of selected envelope uniform loads in different plant zones were based on walk-downs performed in 198 .

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Beams evaluated in the first phase whose flexural stresses fell between 18 and 22 ksi were designated as heavily loaded beams. Those which exceeded 22 ksi were designated as critically loaded beams and painted with an orange paint. The painting was intended to prevent any attachments to these beams without prior approval from the structural group. Re-evaluation of critically loaded beams was performed using more refined analytical techniques and actual attach-ment loads in lieu of assumed conservative uniform load The second phase in the verification program involved the incorporation of PAPSCOTT reconciled piping support attachment loads. The following three categories of beams were considered in this re-evaluation:

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Typical beams (stressed below 18 ksi) were re-analyzed if the magnitude of uniform loads had increased significantly or if attachments of piping 4" in diameter or larger were adde Heavily loaded beams were re-evaluated for any additional loads to ensure that flexural stresses were below 22 ks Critically loaded beams were re-evaluated if the applied loads from the first phase had increased. A walkdown was typically performed to verify the as-built geometry, loading and boundary conditions for these beam This second phase of the beam verification program was completed in July of 198 .3 Seismic II/I Interaction Program The program, described in Technical Procedure TP-4 (Review of Non-Safety Related Equipment, Systems, and Supports located in Safety Related Buildings) was conducted by UE&C to meet the requirements of Regulatory Guide 1.29, Position C2. The Regulatory Positions was implemented by

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either of the *-llowing approaches:

(a) Providing seismic supports to non-safety related systems and sup-ports (such as piping, ducts, cable trays, conduits, bus ducts, and I & C trays and tubing) located in safety related baildings to prevent their failure and damaging of safety related systems and components during a seismic even (b) For items which were not seismically supported, Failure Modes and Effects Analysis (FMEA) was performed to assure that they were isolated by their location and their postulated failure would not impact on safety related components during a seismic event.

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-The procedure (TP-4) provided a tabulation of non-safety related items which were installed in safety related buildings. These items (generally considered large equipment) included tanks, instrument racks, seismic

• ccceders, cooling units, dampers, cooler fans, louvers, sump pumps, chtlier pumps, cabinets, unit heaters, radiation monitors, etc. This equipment was listed by the building in which it was located and was identified by its classification, tag number, type of anchorage and relative location to other safety related equipment. Support for non-safety related and seismically mounted equipment identified in TP-4 was provided in special detailed drawings by the manufacturer or UE& D.her small non-safety related items such as instruments, wall mounted electrical boxes, switches, etc. were not addressed in procedure TP- These were seismically mounted in accordance with typical notes and details for I&C and conduit support drawing A two phase confirmatory field walkdown was instituted in early 1986 for al) non-isolated, seismically anchored and all isolated, non-seismically anchored equipment listed in TP-4. The walkdown was completed in the Diesel Generator, Fuel Storage, Service Water Pump House and Service Water Cooling Tower. This effort was discontinued, however in other safety related areas due to lack of finding Licensee evaluation of the seismic II/I interaction was substantially complete except for a walkdown which is currently being performed of all hose reels and fire extinguishers in safety related areas for isolation and requirement for seismic mountin .4 Failure Modes and Effects Analysis (FMEA) Program This FMEA program was initiated by the licensee to address the require-ments of 10 CFR 50, Appendix A, General Design Criteria 4 which requires that structures, systems, and components important to safety be designed to accommodate the effects of postulated accidents, including appropriate protection against the dynamic and environmental effects of postulated pipe ruptures. The program provided evaluation of pipe whip, jet impingement, and flooding effects on safety-related plant systems, structures and components. The evaluation was documented in eighty-three (83) zone reports which contained the information required to evaluate the consequences of piping failures within the zone on essential plant systems and component The program was managed by UE&C and was performed in accordance with Technical Procedure TP-3. The procedure adopted the guidance for postulated rupture locations, types and sizes presented in the Standard Review Plan (NUREG-800), Sections 3.6.1 and 3.6.2. The criteria estab-lished the specific rupture conditions to be evaluated including the consequential effects of the ruptures.

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The evaluation effort was accomplished in two phases. The first phase (1982-1985) was performed using plant design drawings, such as struc-tural, general arrangement, piping, HVAC, etc., for detection of targets to be evaluated. The second phase consisted of plant walkdowns to verify actual as-built conditions of safety-related systems and components evaluated in the first phase, and to identify other safety related systems, components and field run commodities which were not previously addressed. The inspector was informed that the Seabrook scale model was not utilized in the conduction of either phas Prior to performing the plant walkdown, an evaluation was performed of as-constructed piping drawings by W and UE&C.to identify systems which had changed in configur-ation to assess the likelihood of revised postulated break locations and potential targets. Criteria for acceptability of interaction involved considerations of system operability and/or structural functionalit The second phase of the FMEA activities was completed in April, 198 .5 Conclusion Based on the NRC evaluation of licensee programs for the performance of safety related activities addressed above, it was concluded that the programs had met the intent of the regulations and were substantially in conformance with established industry standards. Further, upon review of the interfaces between the piping as-built program and the Beam Verification and Failure Mode and Effects Analysis programs, it was concluded that they were adequate for performing these activitie Based on the above, it is concluded that the allegation involving the adequacy of these safety related activities at the Seabrook Station is unsubstantiate . Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)

at-the conclusion of the inspection on October 31, 1986. The inspector summarized the purpose and the scope of the inspection arid the^ finding At no time during this inspection was written material provided by the inspector to the license .

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ATTACHMENT 1 DOCUMENTS REVIEWED The following documents were reviewed, in part, during the course of inspection:

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

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

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

Procedure No. PGL-7 for AMSE and NNS-IA Piping and Pipe Support Reconciliation Program by UE&C

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

Technical Procedure No. TP-26 for As-Constructued Requirements of Piping Systems by UE&C

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

Technical Procedure No. TP-33 for "As-Constructed" Verification Program for ASME Piping System Installed by UE&C

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

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

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

Specification No. 9763-006-248-51 for Assembly and Erection of Piping and Mechanical Equipment by UE&C

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

Procedure No. TP-3 for Conducting Failure Modes and Effects Analysis (FMEA) Piping Failure by UE&C

Procedure No. TP-4 for Review of Non-Safety Related Equipment, Systems and Supports located in Safety Related Buildings by UE&C

Technical Procedure No. TP-16 for Beam Verification Program l

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ATTACHMENT 2 Piping Qualified No. of Description of Piping Line N By Measure- Section Verified Drawing N ments RHR1-W0013 (Sh.1) RC-13-13-601-12" W 10 Between penetration and sleeve No. 13 A RHR1-W0013 (Sh.2) 180-1-2501-8" W 11 Between line 160 and penetration No. 34 RH4-W-0058(Sh.1) 58-13-601-12" W 12 Between penetration X-10 and 10-lh" horizontal run beyond hanger N SG-07 RH4-W-0058(Sh.2) RH-160-3-2501-12" W 17 Between penetration X-13

& 160-4-2501-8" and 1-5" horizontal run beyond hanger N SG-05 ACC1-W0155 (Sh.1) SI-201-1-601-10" W 26 Between ACC. Tank.9A and 2'-10 " horizontal run beyond hanger N RM-15 ACC2-W0162 (Sh.1) SI-201-1-601-10" W

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22 Between ACC. Tank 9B :

and I'-9" horizontal run beyond hanger N RM-09 F-800160-542.01 160-1-601-8" U&EC 35 Between penetration X-13 and 7'-0" horizontal run beyond sleeve No. 1558 D-800014-491.70 RC-14-1-601-3" U&EC 20 Between line No.

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

'

10 " horizontal run before hanger No.

'

14-SG-8 l

l

.. . . - _ _ - . . .. . __ _ _ , .

_ _ ._

.

.

Appendix I Details of the alleged discrepancies in as-built piping drawings are given belo For each of the six descrepancies, the description, according to the alleger's drawings, is followed by the results of the NRC evaluatio Simplified figures, projected from the allegers drawings, are included to illustrate the configuration and geometry of piping, supports and building sections involve Descrepancy Drawing No. 53-A Details: W piping No. RC-13-13-601-12" shown on sheet 1 of Dwg. N RHR1-W0013: The piping runs from penetration No. X-9 to sleeve No. 13A (incorrectly referenced as sleeve No. 33). The piping was shown by the allegers analysis to be interfering with the concrete wall as it penetrates sleeve No. 13A. An offset of approximately 4" was shown between the piping and sleeve centerlines. (See attached Dwg. No. 1)

NRC Evaluation: The l'-0" dimension between the inside face of the con-tainment at penetration No. X-9 and the weld line is irrelevan The 12'-8 3/4" starting dimension shown on the run of piping (No. RC-13-13-601-12")

from the weld line to the bend is incorrect. The measurement should be from the penetration guide at the face of the lug. The incorrect assumption introduced-an additional 6 3/4" to the piping run length towards the east directio Further, the opening for sleeve No. 13A was shown to be approxi-mately 16" in diameter, whereas it measured approximately 23". Correction of both errors in the alleger's analysis would eliminate the discrepancy ana allow the pipe to pass through the sleeve with no interferenc Discrepancy Drawing No. 53-B Details: UE&C piping No. RC-14-2-A7-4" and support No. 14-SG-7 shown on Dwg. No. D-800014-491-70: The piping branches off W piping header N RC-13-13-601-12" identified in (a) above. The piping at the location of the support was shown to be offset by approximately 9". (See attached-Dwg No. 2)

!

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

~

the incorrect point of line No. RC-13-13-601-12" from penetration No. X-9, identified in "a" above, which resulted in the introduction of a 6 3/4" erro The second and third involved two dimensions on east-west runs of piping No. RC-14-2-A7-4" by UE&C. The dimensions which were shown on Dwg. No. 538 as 2-6 1/2" and 2-11" were recorded on UE&C "as constructed" drawing No.

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

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

l The three errors collectively resulted in the alleged offset of 9" between the piping and the support.

,

j l

. -

. . _ , -_

_-

.

.

Appendix I 2 Discrepancy Drawing No. 53-C Detail: Two related discrepancies in: (1) W piping No. RH-160-3-2501-12" shown on sheet 2 of Dwg. No. RHR4-W0058; (27 W piping No. RH-180-1-2501-8" shown on sheet 2 of Dwg. No. RHR-1-W0013; (3) UE&C piping No. RH-182-1-2501-3/4" shown on Dwg. No. 800182-S43.00; and (4) UE&C piping No. RH-181-1-2501-3/4" shown on Dwg. No. 800181-543.01. The four piping lines e.re connected in a closed loop in the same sequence listed above where line No. 181 connects back to the main header No. 160. The first discrepancy involved an offset in the connection between lines No. 181 & 160 of approximately 10". The second discrepancy involved an offset in the location of support No. 180-SG-4 on line No. 180 from its designated location on the building stee (See attached Dwg No. 3)

NRC Evaluation: The dimension 6'-8 9/16" between-the elbow on line N RH-180-1-2501-8" and the junction to branch line No. RH-182-1-2501-3/4" is incorrect. The dimension was shown on W stress isometric as 7'-7 7/8" and

-

was measured during the NRC walkdown as 7'-81/4". The alleged offset discrepancy of 10" could be substantially eleminated if the difference between the correct and the alleged dimensions is multiplied by the cosine of the angle between the line and the east-west axis (20 ). The alleged offset in the location of support No. 180-SG-4 on line no. 180 could be substantially reduced if the 24'-3 7/8" dimension on line n RH-160-3-2501-12" is corrected to 25'-10", and the starting point of the same line from the lug at penetration no. X-13 to the elbow is corrected to 2'-91/2". This is addressed further in the next alleged discrepancy. Further, it is significant that the second alleged discrepancy was based on correlation of piping as-built verification measurements with dimensions obtained from the pipe support reference location and the building steel layout drawing Since neither the support reference nor the building steel location dimension was verified (or required to be verified), the alleged discrepancy is deemed erroneou Discrepancy Drawing No. 53D Details: W piping No. RH-160-3-2501-12" shown on sheet 2 of Dwg. N RHR4-W005 Two discrepancies were noted: The first involved an offset in the location of supports No. 160-SG-5 and 160-RM-6 on the above line from their designated location on the location plan of the respective support drawings. The offset was approximately 18" on both supports. The second discrepancy involved an offset in the connection of line N " to line No. 160-5-2501-8". The offset was shown as 11 13/16" in the east-west direction and l'-3 7/8" in the north-south directio (See attached Dwg No. 4)

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

.

a Appendix I 3 NRC Evaluation: The alleged offsets in both support locations and the branch line connection were caused by two dimensional discrepancies on the piping run in addition to the use of reference centerline dimensions from structural drawings in locating pipe support attachments. The starting 2'-9 1/2" dimen-sion of piping No. RH-160-3-2501-12" from penetration No. X-13 to the first elbow should be measured from the face of the lug rather than from the piping-to-sleeve weld line as shown on Dwg. No. 53-D. The other dimensional discrep-ancy involved the length of the piping run from the elbow (near penetration X-13) to the first piping bend. The dimension was noted as 24'-3 7/8" on Dw No. 53-D and on the W preliminary walkdown drawing. The correct dimension was shown on the final W isometric drawing as 25'-10". Since the dimensional error in the W drawing involved a walkdown drawing which was still in process, the inspector could not determine with certainty whether the internal checks by W had independently identified the error. Nevertheless, the alleged off-sets can be substantially eliminated when the above dimensional corrections are incorporate Discrepancy Drawing No. 53-E Details: UE&C piping No. 160-1-601-8" shown on Dwg. No. F-800160-542.0 The piping is routed through six penetrations. The discrepancy involved an offset between the piping and penetration No. 1416 by approximately 3.5" towards the north direction. It also involved an offset between the same piping and penetration No. 1584 by approximately 3.5" towards the south'

directio (See attached Dwg No. 5)

NRC Evaluation: The alleged discrepancy was determined to be erroneous because it was based on inherently incorrect assumptions and misunderstand-ings of the as-built process. The relative locations and orientations of the six penetrations involved in this discrepancy were neither verified with respect to each other nor with respect to a fixed reference point, and are not required to be, during the as-built process. In addition, penetration centerlines were not necessarily parallel to, or concentric with, centerlines of piping which passe through these penetrations. Any possible angularity, within the 5 tolerance, between the centerline of the piping run (No. 160-1-601-8") and the penetrations involved will eliminate this apparent discrepancy. % NRC inspector's walkdown of the piping involved between penetrations Ro. !-13 and 1558 confirmed the adequacy of measurements on the dv >nr * ucted" drawing by UE&C within specified tolerance Discrepancy Drawing No. 53-F Details: Configuration of W piping No. RC-13-13-601-12" from penetration No. X-9 or sheet 1 of Dwg. No. RHR-1-W0013 (incorrectly identified as piping No. RC-13-1-2501-12"): The piping configuration was shown twice using dimen-sions from W drawing above, and Pullman Power erection Dwg. No. RC-13-0 The two configurations were offset by approximately 5'-0" in the east-west direction primarily due to the difference in length of the piping run from the penetration. The other discrepancy in the same drawing depicted the distance between the two legs of a U-bend as 2'-9" according to W drawing and as 3'-6" according to Pullman drawin .

I

'

, .

Appendix I 4 NRC Evaluation: The dimension of piping No. RC-13-13-601-12" from penetra-tion No. X-9 to the first bend was consistent between W and Pullman erection drawings, contrary to the 5-0" offset shown on Dwg. 53-F between the two layouts. Further, the apparent discrepancy in the piping dimension, between the two legs of the U-bend, was resolved since it was noted and verified as 3-6" on both W final isometric and Pullman erection drawings.

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