IR 05000249/1988006

Insp Rept 50-249/88-06 on 880216-18,22-26,0301-04,10 & 14-16.Final Installations Deviated from Original Specs Reanalyzed,Approved & Corrections Initiated.Major Areas Inspected:Previous Insp Findings from Safety Sys Mod Repts

ML17199V204
Person / Time
Site:	Dresden
Issue date:	04/01/1988
From:	Danielson D, James Gavula, Schapker J, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
References
50-249-88-06, 50-249-88-6, IEB-79-14, NUDOCS 8804060432
Download: ML17199V204 (17)

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-249/88006(DRS)

Docket No. 50-249 Licensee:

Commonwaealth Edison Company P. 0. Box 767 Chicago, IL 60690 Facility Name:

Dresden Station, Unit 3 Inspection At:

Dresden Site, Morris, Illinois License No. DPR-25 Inspection Conducted:

February 16-18, 22-26, March 1-4, 10, 14-16, 1988 Inspectors:

Approved By:

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D. Danielson, Chief Materials and Processes Section Inspection Summary Date '

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Date Date Inspection.on February 16-18, 22-26, March 1-4, 10, and 14-16, 1988 (Report No. 50-249/88006(DRS))

Areas Inspected:

Special announced safety inspection of previous inspection findings from the Safety System Outage Modification Inspection (SSOMI) Reports No.. 50-249/86009 and No. 50-249/8601 (92701)

Results:

To prevent recurrence of deficiencies revealed by the SSOMI, the licensee management effected major changes in Procedure OAP 5-The revised procedure imposes restrictions on the performance of modifications which can preclude recurrence of ~he noted deficiencies. All 23 inspection findings

~ere close Final installations which deviated from original specifications were reanalyzed, approved and corrections were initiated for affected drawings.

8804060432 880401 PDR ADOCK 05000249 q

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• DETAILS Persons Contacted Commonwealth Edison Company (CECo)

• E. Armstrong, Regulatory Assurance Supervisor E. Eenigenburg, Station Manager D. Van Pelt, Assistant Superintendent, Maintenance

• C. W. Schroeder, Services Superintendent

• G. Frizzell, BWRED Site Engineer M. Strait, Master Mechanic

• E. Netzel, QA Superintendent

• R. Dyer, Technical Staff Assistant Modification Group Leader D. Ambler, Lead Radiological Engineer B. Viehl, Principal Engineer, BWRED K. Knudson, Technical Staff Engineer J. Williams, Staff Assistant, Regulatory Assurance B. Christel, Modification Group Leader L. Tapella, BWRED J. Welch, Technical Staff U.S. Nuclear Regulatory Commission (USNRC)

• S. G. DuPont, Acting Senior Resident Inspector Impell Corporation (Impell)

P. Bailey, Senior Engineer T. Wittig, Division Manager Sargent and Lundy Engineers (S&L)

E. Eldridge, Structural Engineer Energy Services (CYGNA)

D. Basile, Section Manager

• Denotes those attending exit meeting on March 16, 1988. Licensee Action on Previous Inspection Findings Although not specifically identified in the items covered in this inspection, the general problems disclosed by SSOMI Inspection Reports No. 50-249/86009 and No. 50-249/86012 were discrepancies in the preparation of work packages, in modifying the work packages when necessary, and in adhering to the instructions provided in the work package To prevent a recurrence of these problems, the Licensee has performed a major revision of Procedure DAP5-This procedure covers all phases of modification The NRC inspector reviewed applicable areas of this substantial document

and concluded that the additional controls outlined in their procedure should materially reduce the possibility of future discrepancies of this typ The use of this document serves as an action to preclude future occurrences of each of the following items: (Closed) Deficiency (249/86009-2):

A modified baffle plate for the Emergency Diesel Generator was procured from the original equipment manufacturer (OEM) based on the recommendation of the OE The new baffle plate was not analyzed to assure that it met original design criteri To correct this condition, the licensee had the modified baffle plate seismically analyze The analysis concluded that the modified baffle plate was acceptable for use in this applicatio The validity of the analysis (Nutech Engineers Calculation Package, File No. CEC009.0306) was confirmed by the NRC inspector. A review of other OEM safety related modifications to original design bases (Nutech letter CEC-89-006 dated April 27, 1987) disclosed no significant safety concern To prevent a recurrence of this deficiency, a letter dated January 30, 1987, was written by J. S. Abel and 8. R. Shelton to inform licensee personnel of the problem and to require that future OEM service bullet1ns be reviewed against the original design basis before implementing the OEM recommendation The requirements of this letter were impo~ed.on the appropriate Architect/Engineer (A/E)

organizations by transmittal of the Abel/Shelton letter via

transmittal letter da~ed February 2, 198 *The NRC Inspector held discussions with licensee representatives and reviewed supp6rting documentation to assure that adequate actions associated with the aformentioned concerns have been implemente This item ts considered close (Closed) Observation (249/86009-05):

Additional p1p1ng and valves were added to the HPCI room cooler under modification M12-3-81-31 and were not analyzed to determine the effect on the piping syste Although the modification did not document the engineering judgement used for the modification, the piping configuration was fncluded as part of the I. E. Bulletin 79-14 seismi~ evaluation As such the existing configuration was evaluated and was determined to be acceptabl The NRC inspector reviewed relevant portions of the following documentation:

Sargent and Lundy Calculation No. EMD-055308 Addendum A, Revision 00, December 11, 1985, "CCSW Pump Vault Cooler Piping" Impell Calculation No. D2-DGSW-078, "Blume Criteria Support Documentation," Revision 1, June 198 ** The existing configuration for the above modification as well as the configuration for the more recent modification M12-3-84-14 were shown to meet applicable design criteri No adverse comments were

~ade during the revie This item is considered close (Closed) Deficiency (249/86009-06):

Deficiencies were noted in the design of the Reactor Building Service Penetratio The NRC inspector reviewed portions of Impell Calculation 0595-218-1, Revision 7, September 198 Based on this review, the NRC inspector reached the following conclusions:

(1) High Energy Line Break (HELB) pressures were shown to be significantly less than originally stated during the previous inspectio The reactor building penetrations are not credited for mitigation of HELBs and therefore need not have HELB pressures applied. *The reactor building penetrations were designed to withstand the negative pressure imposed by the Standby Gas Treatment syste This maintains containment pressure integrity for a Loss of Coolant Accident not HEL (2)

The lead shield plug will not have any relative motion within the pipe penetration and will have no effects during a seismic even (3) Although the note on Drawing SK-5007 did not explicitly specify the blind flange material, the slip on flange material was adequately note Drawing SK-5007 was revised to add the words

"and blind" to the flange material not (4) Although the painting note did not explicitly call for painting the flanges, studs and nuts, the general note referred to the 11 steel entrance pipe.

This note was subsequently revised to add the words "non-embedded, external surfaces of..

flanges, nuts and bolt (5) Although the shear lug edge dimension was not specified on the drawing, the shear lugs themselves were not required for this penetratio The lugs were originally specified to be consistent with similar penetration design Field Change Request (FCR) D-3997, dated November 4, 1985, was processed to evaluate the need for shear lugs for this penetratio Since the contractor had installed and grouted the penetration prior to Quality Control inspection, it was ultimately determined that shear lugs weren't required, therefore, a dimension wasn't necessar The calculation adequately demonstrated this conditio CECo's Procedure Q.6, Revision 15, 11System Interaction Checklist

Exhibits E and D currently have HELB ~onsideration for mechanical interaction, structural issues and mechanical issue *

The corrective actions implemented by CECo, adequately address the identified deficiencies and future occurrences should be avoide This item is considered close Closed Observation 249/86009-07):

The 125 volt battery rack replacement design id not adequately calculate the seismic rigidity of the base stringer The original S&L design concept was based on a previously qualified design configuration from the battery vendo Since the same member sizes and lengths were used for the stringers~

sufficient seismic rigidity was implied by engineering judgemen This aspect was subsequently confirmed in S&L calculation No. 7294-TB-05, Revision 2, dated March 31, 198 It was noted by the NRC inspector that while the fundamenta 1 frequency of the subject stringers was found to be rigid, the veriical direction is a static equivalent "g" level and therefore the actual fundamental frequency will not affect the applied load to the structure. It will be the same load for any vertical frequenc Additional requirements are now in place to provide better definition of engineering judgement as well as the requirements for appropriately documenting this judgement. Also a review was perfonned on a sample of other manufacturers components and no cases were found where they had been modified without adequate evaluatio Based on CECo's corrective actions and actions to prevent future occurrences, this is considered adequate and this item is close (Closed) Deficiency (249/86009-08):

Instrument rack modification

- analyses were not performed in accordance with applicable*

requirements.* The NRC inspector held discussions with cognizant CECo and CYGNA personnel and examined the.corrective actions as stated in the letter of response. It was concluded that CECo had

• performed the necessary followup actions and had developed the necessary corrective actions to preclude recurrence of similar circumstances.. Adequate corrective actions have been implemente This item is considered close (Closed) Observation (249/86009-09~: Several modifications did not identify the pertinent origina design specifications, although these specifications are in existence and available. The licensee's position is that it is not imperative that the original design specification be cited as long as the necessary data are availabl The licensee contends that the governing design basis is the FSAR and all subsequently issued SER' As an alternative to citing design specifications, the licensee uses the Design Basis Reconstitution Program recommended by INPO in a Corporate Evaluatio This was put into effect by an entry into Section 3.0 of the licensee's Architect/Engineer Guide Boo This entry requires that 40 design input areas be reviewed whenever design input data are provided to A/E's. These include all 28 design input requirements listed in ANSI N45.2 for this purpose.

.,

• Internal adherence to this policy is governed by Procedure Q5 At present, Q51 prevents the performance of safety related work by the licensee because reference documents are incomplet When completed, the reference document must include Section 3.0 and ANSI N45.2 checklists. Until then, all safety related work must be done by A/E 1 The NRC inspector held discussions with licensee representatives and reviewed supporting documentation to ensure that adequate actions associated with the subject concern have been or are being implemente The NRC inspector concluded that the licensee is deeply dedicated to this course of action as demonstrated by the extensive work required to implement this plan. This is in contrast to the relatively simple alternative of adding the original design specification to each modification packag This item is considered close Closed) Deficienc (249/86009-10 : Pipe support modification was not performed in accordance wit appropriate procedure Based on the NRC inspector 1s review of CEC0 1 s response, it was concluded that galvanic corrosion between ~ carbon steel pipe clamp and stainless steel pipe would be inconsequentia The NRC inspector reviewed Impell calculation No. M-1200D-10046D3-RRCI-RP02, 11Pipe Support Modification,

Revision 2, May 30, 198 The revised calculation was determined to be adequat No adverse comments were mad Based on this review, the original calculation appears to have bee~ appropriate and the NRC inspector concurred with CEC0 1 s position. This item is considered close (Closed) Deficiency (249/86012-01):

Lead shielding was placed on safety-related piping without a documented lOCFR 50.59 safety evaluation. Also, the method of lead shielding attachment was not procedurally controlled to assure that it was rigidly attached to piping. Without this control, the assumption used in the computer program for evaluation of shielding installation may have been i nv al i date *

CECo issued Dresden Administrative Procedure (OAP) 12-12, 11 Installation and Control of Temporary Shielding, 11 Revision 0, in J.anuary 198 At that time, temporary lead shielding could not be installed without a stress analysis of piping or component configuration with the proposed shielding adde At that time, the procedure required the lead shielding to be adequately attached to prevent it from falling during normal or faulted plant condition Based on concerns expressed by the SSOMI inspection team, this procedure was revised in June 1986 to include specific installation recommendations and a requirement to perform a lOCFR 50.59 review for non-standard situations onl The procedure was later revised on December 11, 1986, to require a lOCFR 50.59 evaluation for all temporary shielding installations.

The current plant philosophy is to minimize the number of temporary shielding installations by reducing the number of "hot spots" in the plant. This approach focuses on the problem as opposed to the symptom associated with the proble Extensive efforts to

"hydro-laze" sections of highly contaminated piping accounts for a significant amount of the work in this are Recent lead blanket installations were reviewed to verify compliances with the newly.revised procedures. Temporary.Permits No. 87-13, No. 87-25, No. 87 26 and No. 87-27 were reviewed by the NRC inspector. The documentation associated with each temporary lead blanket installation was in accordance with the applicable procedure. A field walkdown verified that attachment techniques as specified in the procedure were also follwe Based on the above discussion, CEC0 1s corrective actions have been adequately implemented and should prevent future recurrenc This item is considered close (Closed) Deficiency (249/86012-02):

Shims were erroneously designed and added to pipe whip restraint PWHP-1 for modification Ml2-3-81-4 CECo removed the subject shims to restore the required clearance between the pipe and restraint sleeve for thermal movement An operability evaluation was made and no safety concern existe In addition all of the Unit 2 and Unit 3 pipe whip restraints were walked dow No other deficiencies were found and the identified problem was considered an isolated cas *

Drawing No. B-882, "High Energy Pipe Restraint, 11 Revision G, and ECN No. D-865-31, dated July 31, 1986 were reviewed by the NRC inspecto The new clearances and modifications to PWHP-1 had been incorporated as required. A review of all pipe whip restraint information transmitted between Impell and S&L -was also perfonne All additional information was detennined to be accurat Based on the above discussion, CEC0 1s corrective actions were adequately implemente This item is considered close (Closed) Deficiency (249/86012-03):

A lOCFR 50.59 safety review had not been conducted to evaluate the increase in hydrostatic test pressur~ for the core spray flow switches in modificatio~

M12-3-83-3 The originally specified hydro test pressure was incorrectly specified as 250 psig. This was later corrected to 400 psig. Although the test pressure appeared to be increased it was only corrected and the original lOCFR 50.59 review had already considered the 400 psig hydro test pressur *

The NRC inspector reviewed the documentation associated with the modification package and concurred with CEC0 1s positio No additional actions are required. This item is considered-closed.

• (Closed Unresolved Item (249/86012-11 : A lOCFR 50.59 evaluation was performe, ase on mo i icat1on of three pipe whip restraints, but the final work package modified only two pipe whip restraint A detailed pipe whip restraint analysis, which was performed in response to IE Information Notice 85-05, determined that one of the three pipe whip restraints needed no modification; A revision to the modification approval letter, written by G. Frizzel on January 1, 1986, and approved by J. E. Hausman, identified this change and indicated that the Revision did not change the original lOCFR 50.59 Safety Evaluation or Systems Instruction checklist as performed in the original modification approval letter, dated September, 17, 198 *

The NRC inspector held discussions with licensee representatives, and reviewed supporting documentation to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close.

(Closed) Deficiency (249/86012-12):

This deficiency identified problems in a valve and a sockole The valve was installed in a system which required compliance with Table 110 11 of design specification K*220 The acceptability of the valve w~s established and approved on Discrepancy Report (DR) DR12 No. 86005 The work package was modified to reflect the change, as required by the DR and appropriate changes were initiated on February 23, 1988, to reflect the use of non-rising stems on the affected drawing The work package incorrectly specified the material and pressure class of the sockolet. It also specified a sockolet which required.

modification, but provided no specific guidance for performing the wor The installed fitting was inspected after modification and found acceptable by Quality Contro The installed fittings comply with all requirements of the original design specification. The work package was corrected to reflect the as-built configuratio The piping drawings required no change The NRC inspector hel~ discussions with licensee representative, reviewed supporting documentation, and observed the installation to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close Closed Deficienc 249/86012-15 : This deficiency described two problems:

• 1 the work was classified non-safety related, although it involved drilling two holes in the safety related wall between two units and (2) a pen and ink change was made to Sketch 1 after the modification package was approved and the modification was installed.

• The proper method of modifying approved work packages was reviewed with the personnel involved in the pen and ink change. All analyses normally performed on safety related work were performed on this wor The as-installed penetrations included changes prescribed by the pen and ink sketches, changes in location, and other changes not shown on the drawing The seismic analysis of the as-installed penetrations was confinned to be acceptable by S&L letter dated March 7, 198 The fire protection capability of the as-built penetrations were reviewed and approved by T. Hausheer, Fire Protection Engineer for the licensee, in his letter dated March 9, 1988, to E. D. Eenigenbur That letter referenced the acceptability of the original penetrations described in a prior letter by Professional Loss Control, In That finn had reviewed and approved the penetrations with a slightly different location and constructio In an effort to prevent future errors in classification of structure walls, a letter dated March 15, 1988, was written on this subject by J. Kotowski, Assistant Superintendent of Operations and future meetings on this subject are planne The NRC inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples of work to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close (Closed) DefiGiency (86012-20): Modification Package documents

. specified 150 pound reversing valves and flanges for the Contai~ment Cooling Service Water (CCSW) pump room cooler piping modifications~

The original design specification required the use of 300 pound valves and flange The Piping and Instrumentation Drawing (P&ID),

M-360, showed flow elements and temperature indicators that were not installe The line and cooler designations were in error, and there was no specified orientation of the reversing valves to indicate how they should be set for us Finally, eight of the installed flanges were without documentatio *

The use of the 150 pound class valves and flanges in this application was analyzed and approved by S&L letter dated May 27, *

198 The P&ID, M-360; was changed to delete the extraneous flow elements and temperature indicators. The line and cooler identification is now correct both at the pump room and on the drawin The orientation of the reversing valves was identified on the drawing and at the valve The eight installed flanges without documentation were parts of the original pipin They were not added by the modification, so no documentation was required for them on this modificatio The NRC inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples of work to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close (Closed~ Deficiency (249/86012-34~: Work was accomplished which replace Containment Cooling Service Water System (CCSW) piping and components which were outside the scope of the modification shown on the drawing However, in this case, the drawings which defined the scope of the modification were in error. These drawings have been corrected. Personnel associated with the work have been cautioned to perfonn only the work prescribed in the modification package and to seek assistance through proper channels when errors are suspecte The as-built dimensions of the installation were reviewed and approved by S&L, as reported in a letter to J. E. Hausman dated May 29, 198.

The NRC inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples of work to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close Closed Observation (249/86012-35 : The as~built condition of the CCSW pump room coo er modification was not in accordance with the work package or design requirement Personnel associated with the work have been cautioned to perfonn only the work prescribed in the modification package and to seek assistance through proper channels when errors are suspecte Drawings were modified to conform with

.as-built dimensions and the as-built dimensions were analyzed and approved by S& Changes in piping dimensions, pressure class, and gasket material were reviewed, approved and reported in S&L letters to J. E. Hausman dated May 20, 1986, May 27, 1986, and in CECo Record of Conversation M. Strait/G. Jurkin(S&L) dated August 5, 198 The NRC inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples of work to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close (Closed) Deficiency (249/86012-36):

The removal and reinstallation of interferences associated with the replacement of recirculation system piping resulted in several drawing discrepancie Drawing 181 failed to include the "as-found" setting of a spring hanger that would be used to assume proper reinstallation. The interference program was revised to specify settings typical of spring hangers and the drawing was correcte Drawing 181 also failed to show an existing pipe support on the vertical run of piping attached to both pipes, which was disassembled during pipe remova Removal of this hanger was a violation of paragraph 6.1 of the CB&! Q. C. Manua Resolution of this and all other items in this Deficiency were identified in the R. F. Janicek letter to E. R. Zebus, entitled,

"Resolution of NRC Concerns Identified during Review of RPR Modification." As a general corrective measure, Task Work Procedure (TWP) 1251(A) was revised to _include detailed final inspection of all similar area Drawing 181 was changed to show the hanger and the hanger was installed and verified by existing dimensional requirement An additional remark attributed to Drawing 181 is assumed to be a typographical error, because the components identified are on Drawing 187, rather than 18 The drawing did not indicate that the pipe support on the horizontal run, attached to all three pipes, was to be disassembled to effect pipe removal or installatio Drawing 187 was modified to include the hanger and a subsequent walkdown confirmed that the installation matched the drawin Drawing 190 showed three c_lamp type pipe supports, but only the two that were to be modified were detailed. The drawing did not specify the third hanger for disassembly, however the third hanger was disassembled during pipe removal, with no re~ord of the preremoval condition or instructions for installation. This incident and all similar incidents in_thi~ deficiency were discussed with all parties to e*nsure that no repetition would-occu Details for the third hanger were added to Drawing 190. Additional inspection of the hanger disclosed oversize holes, and no washers or locking device This condition was corrected by TWP 123 *

The NRt inspector held di~cussions with licensee representatives,

• and reviewed supporting documentation.to ensure that adequate acti~ns associated with the aforem~ntioned concerns have been implemente This.item is.considered close (Closed) Unresolved It~m-(249/86012-49): This it~m concerning the CCSW pump room cooler piping modification, consisted of eleven individual concerns:

(1)

A 300 pound flanged joint shown at data point 225 on the design drawing had not been installed. This flange was never installed at this point and was not planned to be installe It was removed from drawing M487 by FCR # DM-38.

. (2) Ten dimensions in the design drawing were not within the three inch tolerance specified by S&L in the Section XI Repair Program details. The as-built dimensions were analyzed and approved for use in this application by S&L (Letter dated May 27, 1986) and drawing M-487 was modified to reflect as-bu.ilt dimensions by FCR # DM-38.

(3)

In two locations, piping shown on the drawings as "existing" had been replace by new pipin (The modification boundary had been expanded).

The "balloon" which identified the modification area was not applied carefully; it did not encompass the full extent of piping for which modification was intende The corrective action performed in this case was revision of the drawing to show the proper limits of modification and a discussion with the personnel involved to reinforce the instructions to perform the work as shown in the modification package or, if necessary, to determine if the package must be change The piping configuration between data points 155 and 165. was revised to eliminate an elbow shown on the design drawin Drawing M 487, Sheet 2 of 2, was revised to reflect the as-built configuration by FCR # DM-3 (5)

Fiber gaskets were installed in all flanged joint S&L Design Specification K-2202 required Fl exita 11 i c type gasket Record of Conversation, M. Strait/G. Jerkin (S&L) dated August 5, 1986, confirmed acceptability of Garlock gaskets in lieu of Flexitallic and indicated that a suitable drawing change request would be issued to document such a substitutio (6)

The design drawing specified and the crafts installed 150 pound reversing valves and adjacent flange Design Specification K-2202 requires installation of 300 pound valves and flanges for this application. Sargent and Lundy letter dated May 27, 1986, confirmed that a review of the piping stress analysis report and ANSI B16.5 had been performed and that the use of these items would have no effect on the design or analysis of the system. Affected drawings and stress analysis were to be changed on receipt of a Drawing Change Request (OCR).

(7)

The P&ID for this system, M-360, indicated that flow elements and temperature indicators were installed between the pumps and the cooler The devices were not reflected in the piping drawings and were not installed in the field. These devices were neither intended to be installed nor desired in the positions show They have been removed from the P&ID. *

(8)

The line and cooler designator letters were in error on both piping drawings. All incorrect designations have been correcte *

(9)

Documentation for eight flanges was not availabl The flanges were not procured for this modification; they were part of the original piping and required no documentation for this modification.

(10) The p1p1ng drawing did not specify any specific orientation of the reversing valves for nonnal and backflush flow path The drawings were changed to reflect normal and backflush flowpaths and these flow paths were also shown at the valve The method for reaching each mode of operation seems to be obvious and unlikely to confuse any operator (11) The visual inspection test (during system operation) specified inspection of welds at the cooler flanges, the four long valve flanges and the pressure gages but did not address any other in-line piping weld This test also stated only to record defects on the test fonn; there was no reference to discrepancy reports on other appropriate deficiency reporting system This test was superseded by KK-4, Revision Weld inspection was actively done on a "Weld Inspection Record," one of which was made for each joint. Samples of these inspection records were reviewed by the NRC Inspector and found acceptable in requirements and conten The NRC inspector held discussions with. licensee representatives, reviewed supporting documentation, and observed repres*entative

• sample~ of work to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered close (Closed) Deficiency (249/86012-50):

Contrary to specification requirements, fiber gaskets were installed in all flanged joints instead of Flexitallic type gaskets. A Record of Conversation M. Strait/G. Jurkin (S&L) dated August 5,. 1986, confirmed that this was acceptable and that the drawing was to be change Fl a*nges

installed were 150 pound class instead of 300 pound class specified on the piping drawing, and three as-built dimensions did not match the configuration dimension Analyses and approval of these conditions was provided by S&L letters to J. E. Hausman dated May 20, 1986, and May 27, 1986. As-bujlt drawings incorrectly identified piping and cooler designation All identificatio_ns of piping and coolers are now correct on as-built drawing The visual observation test included in the modification package did not *specify the purpose of the test or any ac.ceptance criteria. This test was superseded by KK-4, Revision 1, which provided examination of all welds to specific criteri The NRC inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples of work to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered closed *

. 13

• (Closed) Deficiency (249/86012-51~: The installation of the diesel generator cooling water pump suction pressure gage generated six areas of concern:

(1)

The sketches accompanying the package specified a 150 pound sockolet although Design Specification K2202 required a 3000 pound sockolet and a 3000 pound sockolet was installe As-installed sockolets were reviewed by the licensees engineer and found acceptable. A Discrepancy Report (DR) was issued to document the difference between the work instruction and the installed equipment. A memo was placed in the modification package to document the actual equipment installe (2)

The work package specified a i", 2000 pound bronze valv The installed valve was a!", 150 pound brass valv The installed valve was reviewed by the licensee's engineering and found to be acceptable for this installation. A Discrepancy Report was issued to document the difference between the work instruction and the installed equipmen The specification error in the original work instruction has been corrected by inserting a memo into the packag (3)

Two sketches in the package required that the sockolet and reducers be manufactured to ASTM A106, Grade B (a piping specification). The installed fittings were made to ASTM A105 (a fitting specification). A DR was issued to document the discrepanc The specification error was corrected by inserting a memo into the packa~e to document the materials use (4)

The P&ID (M-355) showed the diesel generator pump suction piping, including the instrument tap, up to and including the valve as being safety related. However, there was no indication of any seismic requirements in the modification package. A seismic evaluation which was subsequently performed on this pressure tap by S&L indicated the tap to be acceptabl That analysis was reviewed by the NRC inspector, who concurred with the S&L conclusio (5)

The Station Nuclear Engineering Department (SNED) modification letter stated that the piping and valves shall meet the requirements of S&L Design Specification K-2202, Design Table 110

,

which requires a rising stem valv The installed valve was a non-rising ste The non-rising stem valve was reviewed by the licensee's engineering staff and found to be acceptable for use in this application. A drawing change request was initiated to identify this change from Design Table 110 11 on the affected drawing *

(6)

The sockolet referenced in the sketches was identified only by the size of the socket weld fitting (!"). Documentation for the sockolet indicated that the sockolet was for a 2 to 2!'

pip No instructions were provided for the modification necessary to prepare it for use with an 8 11 pip However, CECO has standard weld preparations which would provide guidance and the modified sockolet was inspected and accepted after modification, in accordance with the General Welding Procedur The NRC inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples of work to ensure that adequate actions associated with the aforementioned concerns have been implemente Th.is item is considered closed.

. (Closed) Deficiency (249/88006-52):. The Reactor Building Hose Penetrations exhibited seven deficiencies:

(1)

The hole locations were not in compliance with the dimensions

• of Sketch 1 of the work packag The as-built penetration sizes and locations were reviewed by S&L and found to be acceptabl (S&L Letter to G. Frizzell, dated March 7, 1988).

(2)

Step 5 of the Traveler stated that any severed reinforcing bars (rebars) be reported to the Tech Staff. The step was signed off, but there was no indication in *the documentation whether or not any r~bar had been cut. A Damaged Rebar Report was generated on May 19, 1986, to report hitting rebar at 8 11 from the west face of the wal The S&L*letter assessing the effect of these two penetrations on the integrity of the wall on May 20, 1986, acknowledged the cutting of one vertical and one horizontal rebar..

• (3)

The traveler ~equired that the installed p1p1ng be grout~d in the wall and packed internally with ceramic fibe In contradiction, the associated statement of work performed on the associated work request stated that the ceramic fiber was installed around the pipe (between the wall and the pipe) and was covered with Vimasc There was no indication that grouting had ever been accomplishe The original fire-barrier capabilities of the penetrations were analyzed by Professional Loss Control and found acceptable in their letter of May 20, 198 The adequacy of the penetrations with the as-built

.

construction was analyzed by T. G. Hausheer, CECo Fire Protection Engineer, and found acceptable in his letter of March 9, 198 *

(4)

(5)

(6)

( 7)

Although the modification package did not specify sizes of pipe to flange welds, the inspection record required 3/8 inch fillet weld Two welds were found to be significantly undersiz A Discrepancy Report was written and Work Request 058347 was written to cover the welding and inspection of the penetration A i inch thick steel plate was used in place of the flange at the wal The effect of the plate in plac~ of a flange was analyzed from a fire barrier standpoint by T. G. Hausheer's letter of March 9, 1988, and found acceptabl The work package indicated that the penetration was of an approved design, however no specific document was referenced, nor could any standard penetration designs be identified. The Professional Loss Control letter of May 20, 1986, and that of T. G. Hausheer of March 9, 1988, provide justification that the penetration design is an acceptable fire sea The S&L structural analysis of the effect of the penetrations differed from assumptions.of the S&L analysis. That analysis assumed core holes of 4 inches instead of 5 inches, different locations, a questionable extent of rebar cutting and the omission of grout between the pipe and the wal The latest analysis by S&L in their letter dated March 7, 1988, included all these changes and still finds the arrangement acceptable.

The NRC inspector held discussions with licensee representatives, and reviewed supporting documentation to ensure that adequate actions associated with the aforementioned concerns have been implemente This item is considered closed.. (Closed) Deficienc (249/86012-53 : Snubber reinstallations were incorrect y performe uring modification M12-3-85-1 As a result of the discovered discrepancies an extensive corrective action program was implemente This program included additional reinspections, revisions to the affected drawings and a revision to the tolerance specification. These actions collectively assured proper snubber installations for those snubbers reinstalled during this modificatio The NRC inspector reviewed the following documentation:

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Impell Specification 0595-010-S-49, Amendment 3, June 19, 1986 Impell Specification 0590-176-S-Ol, Revision 0, August 17, 198 DMP 040-35, Revision 0, January 29, 1988, "Snubber Removal and Reinstallation.

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• The first document clarified the spacer requirements of the specific modification discrepancie The other two documents control the present modification whenever snubbers are removed or reinstalle Based on the above reviews, CEC0 1s corrective actions have been adequately implemented and future occurrences should be avoide This item is considered close Closed Deficienc 249/86012-55 Lugs for a Main Steam system piping support were not proper y installed to produce the specified contact are A OCR was issued to delet~ the requirement for fall contact between the lug and the clam This configuration was evaluated and found to be acceptabl The originally specified lug detail was a generic configuration for axially oriented pipe restraint In this application the pipe restraint was in the lateral direction and the requirement for the lug was only to support the weight of the pipe clamp on a rise For this application, resultant loads are minimal and contact area is irrelevan *

Based on CEC0 1s corrective actions and the lack of safety signifjcance associated with this.deficiency, this item is considered closed. Exit Interview Region III inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 16, 198 The inspector summarized the purpose and findings of the inspectio The licensee representatives acknowledged this informatio The inspector also discussed the likely informational content of the inspection*

report with regards to documents or processes reviewed during the inspectio The licensee representatives did not identify any such documents/processes as proprietar *

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