IR 05000271/1985004

Insp Rept 50-271/85-04 on 850409-12.No Violations Noted. Major Areas Inspected:Actions Per IE Bulletins 79-02 Re Pipe Support Base Plate designs,79-07 Re Seismic Stress Analysis of safety-related Piping & 79-14 Re as-built Piping

ML20127A903
Person / Time
Site:	Vermont Yankee
Issue date:	06/11/1985
From:	Varela A, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127A852	List: IR 05000271/1985004 ML20127A849
References
50-271-85-04, 50-271-85-4, IEB-79-02, IEB-79-07, IEB-79-14, IEB-79-2, IEB-79-7, NUDOCS 8506210288
Download: ML20127A903 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-04 Docket N License N DPR-28 Priority -

Category C Licensee: Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Framingham, Massachusetts and Vernon, Vermont Inspection Conducted: April 9-12, 1985 Inspector: / J Wv M $.7arela, Lead Reactor Engineer Jme //, /9 95 date NRC Contract Personnel: M. E. Nitzel, EG&G, Idaho S. L. Morton, EG&G, Idaho Approved by: 1

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dat'e J. 9 Wiggins(4rocesses Matdials and Section, EB, DRS

Rsgetion Summary

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M spection on April 9-12, 1985 (Report No. 50-271/85-04)

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Areas Inspected: Special, announced inspection by one region-based inspector l and two NRC contractor personnel of licensee actions in response to NRC/IE Bulletins 79-02, Pipe Support Base Plate Designs Using Expansion Anchor Bolts; j 79-07, Seismic Stress Analysis of Safety Related Piping; 79-14, Seismic Analyses for As-Built Safety Related Piping Systems; and verification of design analyses and work performed in modifications affected by these bulletins. The inspection involved 54 inspector-hours at the Framingham, Massachusetts office, 45 inspector-hours at the plant, and 12 inspector-hours of in office review by the inspection team.

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Results: No violations were identified.

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DETAILS Persons Contacted Vermont Yankee Nuclear Power Corporation and Yankee Atomic Electric Company

• L. X. Bozek, QA Supervisor, Operations

• P. J. Donnelly, Technical Service Superintendent

• J. M. DeVincentis, Engineer Support, Plant

• C. Greeno, Mechanical Engineer

• R. Hoch, Maintenance Superintendent

• A. C. Kadak, Project Manager

• R. J. Ludwick, Operations Support Manager

• R. Martin, Supervisor, Quality Design, Procurement

• H. M. Mete 11, ESD

• R. Mossey, Construction Supervisor

• R. P. Oliver, Lead Mechanical Engineer

• J. Pelletier, Plant Manager

• D. Pike, Manager, Operations Quality

• D.'A. Reid, Operations Superintendent A. Roudenko, Senior Engineer CYGNA Energy Services (CYGNA)

• G. Dyckman, Project Manager

• S. J. Stratis, Regional QA Manager J. White, Division Manager S. C. Tumminelli, Engineer Inspection Purpose and Scope The purpose of this inspection was to review with cognizant and.respon-sible licensee representatives at the corporate engineering office and at the plant the completeness of their responses to NRC/IE Bulletins 79-02, Pipe Support Base Plate Designs Using Expansion Anchor Bolts; 79-14, Seismic Analysis for As-Built Safety Related Piping Systems; and 79-07, Seismic Stress Analysis of Safety Related Piping. The scope of the inspection included a review of engineering design and quality assurance documentation relating to inspection, testing and modifications satisfying requirements and licensee commitments with respect to the bulletins. A walkdown inspection of the plant verified repairs relating to IEB 79-02, 79-14, and 79-0 . Review Criteria The latest revisions of the subject bulletins were used to define required actions by the utilit In addition, Temporary Instructions (TI) 2515/28 and 2515/29 were used to further define inspection requirements relative L

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to IEB 79-02 and 79-14, respectively. Applicable sections of the Code of Federal Regulations (10 CFR 50) were used to provide guidance regarding regulatory requirement . Review of Licensee Responses The inspection team reviewed bulletin responses available from NRC files prior to the inspection. Any items requiring further discussion were noted as items to be addressed while at the corporate engineering office or plant sit The inspection team reviewed additional material provided by the licensee during the inspection. The material relating to IEB 79-02 consisted of additional procedures governing inspection, testing, maintenance and modification of piping supports, base plates and concrete anchor bolt Sample calculations of concrete anchor bolt loads were reviewed and samples requiring modification were chosen for detailed field inspection and QA/QC documentation followup. The additional material relating to IEB 79-14 consisted of special procedures governing the field walkdown of piping systems and current piping system isometric drawings. Samples of engineering evaluations of nonconformances found during the IEB 79-14 effort were also reviewed. No additional information specifically dealing with IEB 79-04 or 79-07 was examined at the corporate offices. In addi-tion, results of the licensee's seismic reevaluation program (SRP) were also reviewed since this program will be encompassing the conclusion of the IEB 79-02 and 79-14 bulletins. The pertinent documents described above for IEB 79-02 and 79-14 are listed in the following table TABLE 1 ENGINEERING DOCUMENTATION REVIEWED Document Description l BM 9002/WI-4 Cygna Energy Services (Cygna) work l instruction regarding collection of field l data for IEB 79-14 t

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BM 9002/WI-5 Cygna work instruction regarding non-conformance report (NCR) . processing for IEB 79-14

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Cygna piping evaluation criteria for IEB 79-14

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Cygna design criteria for modification of l pipe supports under IEB 79-02 BM84018/WI-2 Cygna work instruction for pipe stress analysis

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Document Description BM84018/WI-3 Cygna work instruction for pipe support analysis BM84018/DC-1 Cygna design criteria for piping stress analysis BM84018/DC-2 Cygna design criteria for pipe support analysis CS-8 IEB 79-14 field walkdown package for the core spray system, part 8 FDW-5 IEB 79-14 field walkdown package for the feedwater system, part 5 FDW-5A IEB 79-14 field walkdown package for the feedwater system, part SA 79-14-412 NCR regarding a discrepancy on the core spray system, part 8 79-14-413 NCR regarding a discrepancy on the core spray system, part 8 79-14-126 NCR regarding a discrepancy on the feed-water system, part 5 79-14-127 NCR regarding a nonconformance on the feedwater system, part SA BM9002/WI-1 Cygna work instruction regarding field walkdowns of piping and supports 0.P. 5200.16 Yankee Atomic Electric Company (YAEC)

concrete expansion anchor test procedure 0.P. 5200.18 Mercury Company concrete expansion anchor removal and replacement procedure SP-49974-700 Revised Mercury Company concrete expan-sion anchor removal and replacement procedure FVY 85-32 YAEC to NCR letter describing the status and results of the small bore pipe support testing program

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Document Description 79-14-336 NCR regarding a discrepancy on the high pressure coolant injection (HPCI) system, part 7 79-14-239 NCR regarding a discrepancy on support RSW-H260 located on the service water system, part 9 79-14-245 NCR regarding a discrepancy on the -

service water system, part 9 79-14-337 NCR regarding a discrepancy on support HPCI-H47 located on the HPCI system,

, part 7 BM-9002-79-14-HPCI Piping field verification package for HPCI piping BM-9002-79-14-RCIC Piping field verification package for RCIC piping

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TABLE 2 IEB 79-02 SUPPORTS REVIEWED Field Calculations System Support Number Inspected Reviewed SW RSW-HD178A No Yes SW RSW-HD1788 No Yes SW RSW-H179 Yes Yes SW RSW-H178 Yes No SW RSW-H262 Yes No SW RSW-H260 Yes No RCIC RCIC-HD95C No Yes t RCIC RCIC-HD95D No Yes RCIC RCIC-H84 Yes No RCIC CST-H67 Yes No HPCI HPCI-H152 Yes Yes HPCI HPCI-H47A Yes Yes HPCI HPCI-H478 Yes Yes HPCI HPCI-H50 Yes Yes HPCI HPCI-H46 No Yes

~RHR RHR-H173B Yes Yes RHR RHR-H174C Yes Yes NOTE: SW = Service Water RCIC = Reactor Core Isolation Cooling HPCI = High Pressure Coolant Injection RHR = Residual Heat Removal l

" Field Inspected" indicates that the support was verified to agree with current drawings during the plant walkdow " Calculations Reviewed" indicates that structural adequacy calculations, walkdown data sheets and other related documentation were examined.

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4.1 Inspection Findings IEB 79-02 had several requirements. Among these were: Verify that pipe support base plate flexibility was accounted for in the calculation of anchor bolt load Verify that the appropriate factors of safety as stated in the bulletin were me The licensee's original efforts on Bulletin 79-02 applied only to seismic supports on Seismic Category I systems; thus, the bulletin requirements stated above were not applied to the nonseismic pipe supports which used concrete expansion anchors on Seismic Category I systems. This issue was addressed to the licensee because of the possibility that any support failure during a seismic event could have a cascading effect of overloading and failing adjacent support A demonstration of adequate safety factors would add assurance that the possibility of failures had been minimize The inspectors noted that the seirmic reanalysis program (SRP) which had been initiated by the licensee addressed all piping supports on Seismic Category I systems. A limited sample of calculations per-formed as-part of the SRP were reviewed and found to be acceptabl However, further information was requested to demonstrate that appropriate factors of safety exist for all supports using concrete expansion anchor bolts on Seismic Category I piping system This is Unresolved Item (50-271/85-04-01).

The licensee's representatives acknowledged the unresolved item described above and agreed to submit additional information in a timely manne . Verification Walkdown Inspection

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A physical inspection of portions of plant systems selected by the inspection team was conducted. The purpose of this walkdown was to verify samples of piping systems and supports for compliance to as-built conditions as described in the licensee's documentation and to verify repairs or modifications to piping, pipe supports and/or baseplates required by the subject bulletins. The following piping

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TABLE 3 PIPING SYSTEMS FIELD VERIFIED System Line Drawing Location "-SW-158 PI-1178-S Reactor Building RCIC 6"-CST-3 PI-1101-S Reactor Building HPCI 4"-HPCI-6 PI-1065-S Reactor Building RHR 4-RHR-248 PI-1138-S Reactor Building

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Findings: No violations were identifie . REVIEW OF LICENSEE QUALITY ASSURANCE RECORDS A review was performed of the licensee's administrative controls and quality assurance activities relating to the subject bulletins. These major categories of quality assurance actions performed by YAEC were evaluated for conformance to their QA progra Vendor evaluation reports of CYGNA for engineering services related to subject bulletins and the VY Seismic Reanalysis Program (SRP)

initiated in July,1980

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Surveillance inspection reports of CYGNA field engineering activities at the VY plant

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Triennial reevaluation of CYGNA CYGNA's surveillance inspection reports (SIR) of VY plant activities relating to NRC/IEBs 79-02 and 79-14 were reviewed and evaluate Approximately thirty reports, covering inprocess inspection, testing and as-built verification between August,1979 and April,1980 were covere The Surveillance Report Status by CYGNA dated August, 1981 presented closecut of all unsatisfactory findings identified in the SIR Additionally, VY plant maintenance audits and surveillance reports of contractor QC actions and documentary reports on maintenance work under 79-02 and 79-14 were reviewed and evaluated for conformance to VY's operational QA department manual. Final support documentation on pipe hanger modification work performed by the Mercury Company between July,1979 and May,1980 was observed to be indexed, well organized and readily retrievable. Job order completion forms by the engineering sup-port supervisor and the QA coordinator provided turnover documentation and completion check-off for each purchase order, its corresponding MPR and resolution of NCR No violations were identifie _

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7. Conclusion Based on the review performed during this inspection, the inspectors considered the licensee's actions regarding IEB 79-07 and 79-14 to have been. acceptable. .These IEBs are closed. Additionally, pending completion of the analyses and tests to be performed on anchor bolts for deadweight supports, the inspectors considered IEB 79-02 close . Definition of Unresolved Items

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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, violations or deviations relative to the bulletin requirements. Unresolved items identified during this inspection are discussed in Paragraph /

9. Exit Interview The inspectors met with licensee and A-E personnel (denoted in Paragraph 1). The NRC inspector summarized the inspection findings. The licensee acknowledged the inspector's comments and committed to provide additional documentation relating to the IEB 79-02, as identified in Paragraph 4. At no time during the inspection was written material pro-vided to the licensee by the inspectors except a request for technical a informatio '

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