IR 05000315/1991028
| ML17329A361 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/15/1992 |
| From: | James Gavula, Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A360 | List: |
| References | |
| 50-315-91-28, 50-316-91-28, NUDOCS 9201270254 | |
| Download: ML17329A361 (9) | |
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U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/91028 (DRS); No. 50-316/91028 (DRS)
Docket Nos.
50-,315; 50-316 Licenses No. DPR-58; No.
DPR-74 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
D.
C. Cook Nuclear, Power Station, Units 1 and
Inspection At:
American Electric Power Service Corporation, Columbus, Ohio Inspection Conducted:
December
12, 1991 Inspector:
A.
avula Date Approved B
J ac son, Chief ater and Processes Section Date Ins ection Summar Ins ection durin December 10-12 1991 Re orts No.
50-315 91028 DRS No. 50-316 91028 DRS Areas Ins ected:
Announced safety inspection of the licensee's Large Bore Piping Reconstitution Program (LBPRP)
(37701)
and corrective actions for previously identified items (92702).
Results:
No violations or deviations were identified in the.
areas inspected.
Based on this inspection, the following strengths were noted:
The LBPRP is very comprehensive and thorough.
Corporate engineering staff demonstrated a high level of technical competence in the area of piping analysis.
The aggressive use of more rigorous analytical techniques shows a strong commitment to quality.
9201270254 920116 PDR ADOCK 05000315
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I 1.
Persons Contacted DETAILS American Electric Power Cor oration AEP
- W. Smith, Jr., Chief Nuclear Engineer
- N. Ruccia, Manager, Safety and Analysis Design, Nuclear Section
- J. Kingseed, Assistant Section Manager, Nuclear Safety and Licensing
- R. Armstrong, Designer, Safety and Analysis Design, Nuclear Section
- B. Lauzau, Senior Engineer, Nuclear Safety and Licensing A. Dey, Assistant Section Manager, Nuclear Engineering D.
Lam, Engineer, Nuclear Engineering
- Denotes those attending the exit meeting on December 12, 1991.
2 ~
Licensee Action on Previous Ins ection Findin s 92702 a ~
Closed Violation 315 88028-01 316 88032-01 Design control during. implementation of plant modifications was inadequate.
The licensee's responses to the NRC dated June 2 and September 22, 1989, were reviewed and determined to be acceptable.
The corr'ective actions listed in the responses included the efforts of a multi-discipline Design Confirmation Task Group.
Details of the task group recommendations and completed actions were presented to the NRC's Region III office on May 18, 1989.
Based on the reviews of the design efforts during the current inspection, these actions were considered adequate.
See Paragraph 3 of this report for additional discussions related to the closure of this violation.
b.
Closed Violation 315 88028-02 316 88032-02 Procedures for small bore piping design activities were inadequate.
The licensee's response to the NRC dated June 2,
1989, was reviewed and determined to be acceptable.
The corrective action included a survey of 100% of the small bore systems and an ev'aluation of the worse cases based on critical attribute determination.
These cases were analyzed to bound the remaining installed piping.
Also, clear implementing procedures for future safety related field run piping were develope The NRC inspector reviewed relevant portions of EQE Engineering Report No. 50035.06-R-001,
"Small Bore Piping Confirmation Program, D.
C.
Cook Nuclear Plant, Final Report," Revision 0, dated September 16, 1991.
The report concluded that except for two cases, small bore seismic Class I piping designed in acc'ordance with the original alternate analysis criteria, met the Final Safety Analysis Report (FSAR) requirements..
The first, exception concerned the support of air and motor operated valves.
The original criteria were not explicit in this respect and in a number of cases, additional supports were required to resolve an overstressed situation.
In total, 15 supports will either be modified or added.
This is in addition to the support modifications previously performed to, resolve the Copes-Vulcan Valve issue for air operated valves installed on small bore piping systems.
Refer to the licensee's letter to the NRC dated March 13, 1989, for additional information.
The second exception involved the thermal movements imposed on small bore lines connected to the reactor coolant pumps.
The original alternate analysis criteria were not adequate to accommodate these larger movements.
In total, 8 supports had to be'emoved to reduce pipe stresses below the FSAR specified stress
.limits.
Based on the extent of the corrective actions and the results achieved, the NRC inspector considered this item closed.
c ~
Closed Unresolved Item 315 88028-03 316 88032-03 The overall adequacy of the IE Bulletin (IEB) 79-14 program was questionable because of recently discovered piping and pipe support deficiencies.
The licensee's response to the NRC, dated June 2,
1989; was reviewed and determined to be acceptable.
The corrective actions listed in the response included a
reanalysis of a representative sample of the large bore piping systems in order to provide further evaluation of the adequacy of the IEB 79-14 program.
See Paragraph 3 of this inspection report for details related to this effort.
Based on the corrective actions taken by the licensee, this item was considered closed.
d.
Closed Violation 315 89022-03 316 89022-03 Ineffective design verification activities were performed on the analyses for pipe supports CCW-L181 and CS-R541.
The licensee's response to the NRC dated October 6,
1989, was reviewed and determined to be acceptable.
Based on the reviews of the design efforts during the current inspection, these actions wer'e considered adequate.
See Paragraph 3 of this report for additional discussions related to.the closure of this violation.-
Lar e Bore Pi in Reconstitution Pro ram LBPRP Because of discrepancies in piping and pipe support analyses found during plant modifications and component support inservice inspection (ISI) activities, the-
.overall adequacy of the original IEB 79-14 program was questioned by the NRC.
(Refer to Paragraphs 2.a.,
2.c.,
and 2.d. of this report for additional discussion.)
As a result of these issues, the licensee performed'a study, using an independent consultant, to evaluate a representative portion of five large bore piping systems.'his effort was documented in Impell Report No. 09-0120-0361,
"Summary of Results of the 79-14 Large Bore Piping Review Project", Revision 0, dated April 11, 1990, and was summarized in a meeting with staff of the NRC's Region III office on June 7,
1990.
The study found that all five of the piping systems and necessary pipe supports were able to perform their design functions.
However, one of the piping systems exceeded the piping design criteria and all of the systems had at least one support that exceeded the structural design criteria limits.
The discrepancies that caused the design limits to be exceeded were restricted to only a few problem areas.
Based on this, the consultant recommended:
(1)
a non-dimensional walkthrough of'he plant to verify general piping arrangement and support configuration; and (2)
a review of all piping analyses and support drawings for the specific problem areas identified by the study.
Since no system operability issues were identified during this study or other related activities, the schedule for these actions was not considered critical.
Instead of performing the non-dimensional walkdowns and calculation reviews recommended by the consultant, the
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licensee decided to implement a much'ore rigorous and comprehensive reconstitution program.
This program consisted of detailed walkdowns of piping and pipe supports and a complete re-'analysis of the large bore piping systems including new support calculations and updated piping isometrics.
The licensee considered that there would be long term benefits from the more
comprehensive program compared to the originally recommended actions.
b.
Review of Calculations The NRC inspector reviewed the following calculations for compliance with licensee commitments and regulatory requirements.
As-built documentation was compared to analytical inputs and results and reconciliation of overstressed items were reviewed.
Calculation No. DC-D-l-ESW-09, Revision 0, dated December 9,
1991,
"LBPRP Analysis of ESW Piping and Pipe Supports for EBASCO Walkdown Package No.
ESW-09 No discrepancies were noted while comparing the as-built documentation and computer code inputs.
The results indicated that a 1/4 inch reinforced branch connection and three supports had to be modified to meet the applicable design criteria.
, Calculati'on No. DC-D-2-JW-3, Revision 0, dated December 7,
1991,
"Jacket Water Piping Between Diesel Generator Outlet and Jacket Water Cooler."
No discrepancies were noted while comparing the as-built documentation and computer code inputs.
The results indicated that two rigid supports needed to be changed to spring hangers, one spring hanger needed to be changed to a stronger spring, one new spring hanger support needed to be added and one rigid support needed to be removed to meet the applicable design criteria.
For both calculations, all questions were adequately resolved by the licensee's technical staff during the inspection.
The noted modifications were to be implemented during a future outage.
Although both systems did not meet the design criteria, the operability of the systems was demonstrated by the licensee.
The well organized calculation packages and extremely rigorous analytical approach used by the licensee were significant improvements in the quality of the piping and pipe support analyses.
Use of this rigorous approach may result in modifications which would not be warranted if the previous analytical techniques were used.
No violations or deviations were identified during the inspectio Exit Interview The Region III inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on December 12, 1991, The inspector summarized the purpose and findings of the inspection.
The licensee representatives acknowledged this information.
The inspector also discussed the likely informational content of the inspect'ion report with regard to documents or processes reviewed during the inspection.
The licensee representative did not identify any such documents)processes as proprietar l
)