IR 05000259/1987007

Insp Repts 50-259/87-07,50-260/87-07 & 50-296/87-07 on 870209-13.No Violations or Deviations Noted.Major Areas Inspected:Seismic Design Status of as-built safety-related Programs Including Cable Trays,Piping & Supports

ML20207T705
Person / Time
Site:	Browns Ferry
Issue date:	03/04/1987
From:	Blake J, Chou R, Vias S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T693	List: IR 05000259/1987007 ML20207T692
References
50-259-87-07, 50-259-87-7, 50-260-87-07, 50-260-87-7, 50-296-87-07, 50-296-87-7, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8703240262
Download: ML20207T705 (10)

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UNITE 3 STATES

/ A afToq*o NUCLEAR REGULATORY COMMISSION

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• MARIETTA STREET. g ATLANTA. GEORGI A 30323

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Report Nos.: 50-259/87-07, 50-260/87-07, and 50-296/87-07 Licensee: Tennessee Valley Authority -

6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52,

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and DPR-68 Facility Name: Browns Ferry 1, 2, and 3

. Inspection Conducted: February 9-13, 1987 Inspectors: b \- l &B 8'l~

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, . ou Date Signed Accomp nying Pe ' 1: J. J. Blake Approved by: 5') t- MVd7 . A~ lake, Section Chief Dats Signed En iq4ering Branch

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D vision of Reactor Safety

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SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of seismic design status of as-built safety-related programs which included overall Seismic Program, Cable Trays, Piping and Supports (IEB 79-02 and 79-14), Conduit and Supports, CRD Piping and Supports, HVAC Concerns, Torus Modifications, Torus Attached Piping and, Small Bore Pipin Results: No violations or deviations were identifie .

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REPORT DETAILS Persons Contacted Licensee Employees

• T. G. Chapman, Acting Project Engineer for Browns Ferry

• T. D. Cosby, Unit 1 Superintendent (Plant Manager Representative)

• T. M. Brothers, Design Nuclear Engineering

• J. R. Norris, Quality Assurance

• J. A. Savage, Licensing

• R. Davis, Licensing

• R. D. Cutsinger, Design Nuclear Engineering B. Baird, Design Nuclear Engineering

• E. Thomas, Project Management B. K. Srinivas, Electrical Modifications Group

• J. E. Swindell, Unit 2 Superintendent Other licensee employees contacted included construction craftsmen, engineers, technicians, and office personne NRC Resident Inspectors

• G. L. Paulk, Senior Resident Inspector

• C. Brooks, Resident Inspector

• C. A. Patterson, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on February 13, 1987, with those persons indicated in paragraph 1 above. The inspector described tr.c areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee. The following new items were identified during this inspectio Unresolved Item 50-259, 260, 296/87-07-01, Discrepancy in Installation of Designed Conduit Supports, paragraph S Unresolved Item 50-259, 260, 296/87-07-02, Pipe Support Discrepancies, paragraph 5 The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _

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3. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tion Two unresolved items identified during this inspection are discussed in paragraph . Seismic Design Program Issues (25528, 25529, 50090)

The following areas that deal with concerns related to the structural adequacy of various safety-related systems have been partially reviewe The issues addressed encompass structural response to all loadings including pressure, temperature, dead and live loads, and seismic loads. The areas of concern include cable tray supports; conduit supports; supports for control {

rod drive (CRD) insert and withdrawal piping; heating, ventilation and air conditioning (HVAC) duct supports; torus modifications, including internal structural components; torus attached piping, both internal and external; small bore diameter piping supports; and pipe supports and associated piping covered by IE Bulletins 79-02 and 79-1 Cable Tray To resolve the cable tray seismic qualification issue, TVA has instituted a two part program consisting of (1) an interim qualifica-tion program to justify operations prior to final resolution of the issue, and (2) a long term qualification program to meet and ensure continued compliance with NRC guideline The interim qualification program was cempleted by United Engineers and Constructions (UE&C), which provided a " reasonable level and assurance that the cable tray / supports will maintain structural integrity and that the cables will maintain functionality during a Design Basis Earthquake (DBE)."

All modifications proposed by the UE&C study have been complete The NRC has reviewed and evaluated the UE&C interim acceptance evaluation and found it to be acceptable for interim operation, as stated in NRC letter to TVA, dated February 5,1987. Modifications recommended by the evaluation will be inspected in a future inspec-tio _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _

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b. Conduit and Supports (1) Status Review Since a 1983 NRC inspection report identified a concern about the adequacy of conduit and supports, the licensee has developed two documents to perform the BFN conduit seismic qualification program:

(a) Seismic Qualification of Existing Electrical Conduit and Conduit Supports, Project Instruction BFEP-PI 85-02, issued October 15, 1986 (b) Seismically Qualify.ing Conduit Supports, Design Criteria BFN 50-723, issued March 28, 1986, based on the full scale dynamic testing of conduit configurations at Wyle Labora-tories and determination of realistic critical damping values at TVA's Norris Test Laboratory, TVA documented results on safety margins, allowable span lengths, damping values used to develop design criteria BFN 50-723 which is supported by test results, response calculations and records of actual earthquake experienc It is projected that approximately 800 modifications will be require Designs for the modifications have been completed and 30%

of field modifications are also complete All field modifications will be completed by April 198 (2) Observation of Installed Conduit Supports The inspectors randomly selected one conduit line which included five supports that had been QC final-inspected. The supports were reinspected with the assistance of QA/QC inspectors, construction foreman, craftman and engineers. The supports were reinspected against their detail drawings for configuration, identification, dimension, clearance, member size, welding, clamp, clamp bolt edge distance in unistrut, baseplate, fastner/ anchor bolt installation and damage protection.

, (3) Summary of Results

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The results were discussed with the QA/QC inspectors and engineers, to determine the effectiveness of the conduit and supports progra Listed below are the comments and discrepancies identified by the inspectors during the walkdown.

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Conduit Support Comment / Discrepancy 48B810-14 Rev. 1 Installed 2 bolt clamp -

3" $ (P2558) instead of 1 bolt clamp - 3"# (P1119)

causing 1/2" edge distance from unistrut bolt centerline to edge of unistru Rev. 0 None 48B810-108 Rev 0 None 48B810-158 Rev. O None 488810-182 Rev. O None The 1/2" edge distance from the center line of the clamp bolt and the edge of the unistrut does not comply with the general note requirement of 1" edge distance minimu This discrepancy is due to the installation of a 2-bolt clamp - 3", (P2558)

instead of a 1-bolt clamp 3"# (P1100) as allowed per the general notes. QC documentation of substituted material in drawing is not specifically required in by general notes and this raises a concern about quality control verification, and documentation of as-built configuration The discrepancy is to be reviewed and evaluated by the license The evaluation and corrective actions proposed and/or taken will be reviewed by the inspectors in future inspections. This matter is identified as Unresolved Item 50-259, 260, 296/87-07-01,

" Discrepancy in Installation of Designed Conduit Supports."

c. Control Rod Drive (CRD) Piping (1) Status Review Investigations by the licensee revealed that the installed configuration of the support systems did not match the original design drawings. Licensee evaluated the installed configuration of the CRD system supports and recommended modifications to provide additional load carrying capabilit Licensee's evaluation consisted of field walkdowns and analytical evalua-tions conducted in accordance with their corporate quality assurance program and written guidelines. Two procedures were established for walkdown inspection and engineering design which were BFEP-PI 86-22, " Control Rod Drive Hydraulic System Insert and Withdraw Lines - Inspection Procedures - Unit 2" and BFN-50-724 " Class 1 Seismic Pipe Support Design" for detailed design criteria. All design work and 40% of modifications have been completed. All modifications on supports will be completed by the end of February 1987. After all modifications are completed, CRD piping supports will meet all safety requirements.

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(2) Observation of Installed Supports The inspectors randomly selected pipe support no. 47W2468-101, which is a complicated frame support and supports 10 lines of CRD insert and withdrawal piping. The support was inspected with the assistance of an engineer, against detailed drawings for configuration, dimension, member size, welding, connections, workmanship, and fastner/ anchor bolt installation on the portion of modificatio (3) Summary of Results The main purpose of inspector walkdown inspection is to see if the licensee field modifications comply with the procedure and new drawing revisions. No discrepancies were found in the above supports. QC documentation for incorporated ECN and FCRs for the drawing, Rev. 1, were also checked and found satisfactory, d. Heating Ventilation and Air Conditioning (HVAC)

HVAC ducts and duct supports at Browns Ferry Nuclear Plant were initially fabricated and installed to industry standards without consideration of seismic loads. Only a few individual support design calculations are available. The duct construction was based on the Sheet Metal and Air-conditioning National Association (SMACNA)

standards with both the pocket-lock and companion-flange types being used. Several field evaluations and modifications had been performed to comply with Seismic Design Criteria BFN-50-721, issued in July 1970. Testing was performed in regard to HVAC seismic qualification and found that the ducts were structurally adequat In 1986, a preliminary program of inspection and engineering evalua-tion was performed due to a Significant Condition Report, (SCR BFNCEB 8603), having been written against Seismic Design Criteria BFN-50-72 Design Criteria BFN-50-721 had been developed for reinspection of safety-related duct systems and provided plans for the interim qualification (for Unit 2 only) and final qualification. Now a final program is to be developed by the licensee to fully address seismic qualification of HVAC Systems. The program will include:

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! (1) Performing further field walkdowns to get as-built information for analysis and design.

l (2) Defining an interim qualification criteria, if renuired.

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i (3) Evaluating the as-built system versus the interim criteria.

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(4) Designing and installing any modifications required to achieve

interim qualification for Unit 2 restar (5) Establishing final qualification criteria and programs to achieve final seismic qualification for HVAC system e. Torus Modification TVA's Long-Term Torus Integrity Program was implemented using Special Mechanical Maintenance Instruction 14.4.1.3-L (SMMI 14.4.1.3-L) for field inspection to gather information for analysis and modificatio As a result of that program, torus modifications were implemented on all units at BFN as documented by the Long Term Torus Integrity Program plant unique analysis report (CEB-83-34). The modifications were inspected according to the guidelines of Modifications and Addition Instruction (MAI-23), " Support and Installation of Piping System in Category I Structures," by Quality Control Inspectors. The licensee completed all modifications and inspection in September 1986

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except the Steam Relief Valve main restraint f. Torus Attached Piping

(1) Status Review

There are a total of 510 supports being modified for Torus Attached Piping. 450 supports have been completed by engineering (this includes walkdown, drawing reissue and calculation requali-fication if required). The design and analyses for all supports are scheduled to be finished by March 15, 1987. The construction for all modifications is expected to finish by April 15, 198 The major procedure for implementation of this reinspection and design modification is "Special Mechanical Maintenance Instruction,14.4.1.3-L, (SMMI-14.4.1.3-L) Inspection Program for Reverification of Correct Support Installation."

(2) Observation of Installed Piping and Hangers

{ The inspectors randomly selected eight supports which had been

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redesigned and modified by the engineering group. The supports were inspected with the assistance of engineering, against their

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modified detail drawings for configuration, identi fication ,

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dimension, member size, welding, baseplate, fastner/ anchor bolt installation and clearance.

Each support had an inspection checklist for reinspection

walkdown and was signed off by inspection team consisted of one design engineer, one QC inspector, and one steamfitter foreman.

All support drawings will be reissued based on walkdown informa-

tion and modifications.

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. (3) Summary of Result

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The results were discussed withs the QA/QC inspectors and -

engineers, to determine the effectiveness of the IEBs 79-02 and

. 79-14 programs. Listed below are the comments and discrepancies 33 identified by the inspectors during the walkdow Il SUPPORT RE DWG N N N COMMENT / DISCREPANCY s

47B458-406 R-5, '1 None 47B458-404 R-12 3- One weld symbol shown incorrectl ~

47B458-189 R-17 5 Redesigned Support Not

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installed ye H-11 4 Redesigned Support Not

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installed ye H-15 'a None

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47B920-91 R-12A / 1 No documentation for

& R-12B abandoned bolts and abandoned hole without grouting, No bolt capacity reduction adjustment in calculation, e

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s 478920-118 R-29 1 None d

. 478920-93 R-14 7 None

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The discrepancies on Drawin'g No. 47B458-404, Support No. R-12 and Drawing No. 478920-91,- Support Nos. R-12A and R-128 are to

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be re9iewed and evaluated by the licensee. The evaluation and l " ~ corrective ictions proposed and/or taken will be reviewed by the l l inspectors ir, future inspections. This matter is identified as l

UnresoYved, Item 50-259, 50-260, 50-296/87-07-02, " Pipe Support l Discrepancies." ,

r Small Bore Piping The majority of the small bore piping at Browns Ferry Nuclear Plant

. was field routed and field supported, with installation in accordance w'ith American National Standards Institute standards. The Design Criteria, BFN-50-7s2, " Criteria for Seismically Qualifying Field Run

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Piping for Size 1/2 through 2 inches", was issued on November 29, 1972

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and was the licensee's first design criteria for seismic design of l,' small bore piping. A Significant Condition Report (SCR BFNCEB 8520),

questioned the adequacy of baseplate, concrete anchors, weld details

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and structural integrity of supports for safety-related small bore n piping. There were three methods used for safety-related small bore analysis; (1) rigorous analysis, (ii) EDS alternative analysis, and (iii) alternative analysis defined in BFN-50-712. The piping systems which used rigorous analysis are being focluded in the IEBs 79-02 and 79-14 program described later in this *voor To gather as-built information and resolve concerns on the safety-related small bore piping systm r, a Project Instruction 4?3P-PI-86-29, " Procedure for Sampling of Clest 1 Samil Bore Piping," ytill be used for preliminary field walkdown and evaluation. From the above walkdown and evalua-tion, the licensee expects to develop a program similar to that mentioned in paragraph 5.d, HVAC for interim and final qualification programs to fully resolve the safety related small bore piping issu h. Piping and Supports (IE Bulletins 79-02 and 79-14)

c Programs to comply with IE Bulletins 79-02 and 79-14 regarding the adequacy of Piping System Anchor Bolts and Supports and as-built condition of safety-related piping systems, is described in Program Plan-BFEP-PI 86-05, "NRC-0IE 79-02/79-14 Program Document for Browns Ferry Nuclear Plant." An initial inspection was performed for the IEB 79-02 program using special Mechanical Maintenance Instruction 5.1-A (SMMI-5.1-A), " Inspection and Repair Program for Verifying Correct Installation cf Concrete Expansion Anchors, Units 1, 2 and 3." For the IEB 79-14 program, the Mechanical Maintenance Instruc-tion 99 (MMI-99), " Instructions for the Implementation of NRC IE Bulletin 79-14" was use Engineering evaluations were performed under project instruction BFEP-PI-85-01, Implementation of NRC-01E Bulletins 79-02/79-14 for Browns Ferry Nuclear Plant," which establishes the method to evaluate discrepancies for interim qualification and code complianc For the IEB 79-02 program, TVA is performing and implementing modifications to provide compliance with the interim requirements of a factor of safety equal to two, prior to the restart of Unit 2 onl A final reinspection and analysis to establish the full compliance for all covered piping and supports with bulletins 79-02 and 79-14 will be completed prior to restart of Units I and 3 and before the end of the next refueling outage (Cycle 6) for Unit 2. The use of the interim requirements for IEB 79-02 is being reviewed by NRR for acceptability.

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The program for the final reinspection process is de cribed in BFEP-PI-86-06, " Implementation of NRC-0IE Bulletin 79-14 Phase II verification for Browns Ferry Nuclear Plant." Any discrepancies identified during this inspection will be corrected as required. No field inspection was performed during this inspection pending further discussions on the acceptability of the interim requirements of the IE Bulletin 79-02 for Unit There were no violations or deviations identified during this part of the inspection.

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