IR 05000326/2008002
| ML20137M633 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, University of California - Irvine  |
| Issue date: | 08/27/1985 |
| From: | Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137M613 | List: |
| References | |
| 50-346-85-13, IEB-79-14, NUDOCS 8509130289 | |
| Download: ML20137M633 (32) | |
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' U.S. NUCLEAR REGULATORY COMISSION
REGION III
Report No. 50-346/85013(DRS) Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: ' Davis Besse Site Oak Harbor, OH Bechtel Power Corporation, Gaithersburg, MD (Bechtel) Inspection Conducted: March 26-27, April 24-26, May 28-31, and July 8-11, 1985 at site
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July 29-August 2,1985 at Bechtel
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Inspector:
.
. T. Yin
/ 2d Ps-Date Approved By: D. H. Danielson, Chief 8!*' K Materials and Processes Section Date Inspection Summary Special Insaection from March 26 through August 2, 1985'(Report No. 50-356/35013(DRS))
Areas Inspected: Special, announced inspection of the auxiliary feedwater pump turbine steam supply (AFPTSS) piping restraint and structural damag The inspection involved a total of 116 inspector-hours on site and at the A-E's office by one NRC inspecto Results: Within the areas inspected, four apparent violations were identified (failure'to issue nonconformance reports when-hanger damage was identified - Paragraph 6; inadequate corrective actions were taken to determine the cause of-hanger damage so that preventive measures could be initiated ---
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Paragraph 7; inadequate QC and IE Bulletin No. 79-14 inspections were performed to verify hanger installations were per design requirements - Paragraph 8;
- failure to report the . total extent of damage to the AFPTSS to the NRC per 10 CFR 50.73 requirements - Paragraph 13).
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+ Denotes those attending the management exit meeting on August 2, 1985,
at Bechtel.
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2. LGeneral Description of the Events i ;In March 1985 the inspector was informed that a number of restraints installed on the AFPTSS piping system were found damaged. The affected ' restraints and structures were largely located on Line 6-EBD-19, downstream of the two auxiliary steam line check valves and downstream of the two crossover. leg check valves to Auxiliary Feedwater Pump Turbines 1-1 and 1-2. Component and structural damage was also identified on a tie line between the two turbines. In response to the inspector's
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requests, pertinent flow diagrams, piping isometric drawings, damage descriptions, and' details for those damaged restraints were sent by the licensee to the inspector for review on March 20, 198 , Damage Reported on March 20, 1985
; Train No. 1-1 1 Date Licensee
- Hanger N Identified Findings
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H 132 03/15/85 . . gaps between base-
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plate and wall H 34 03/13/85 . deformed pipe stanchion i
H 32 03/15/85 . loosened bolts '
. pipe clamp moved i
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H 28 03/15/85 . pipe saddle deformed
H 25 03/15/85 . bolt head sheared of i
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H 14 03/16/85 . snubber
- misalignment
! H 135 03/15/85 . one loosened bolt j . gaps between base plate and wall
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H 66 03/15/85 . Same as H 135 l h k
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, Train No. 1-2 Date Licensee Hanger N Identified Findings H 50 03/14/85 . loosened bolts
. gaps between base plate and wall H 49 03/14/85 . bolts pulled from wall
. gaps between base plate and wall A3 03/13/85 . loosened bolts H 142 03/14/85 . same as H 49
, H 144 03/01/85 . snubber piston rod sheared H 147 03/01/85 . strut pulled from wall 4. Snubber Functional Tests In accordance with the corrective action agreements between RIII and TEco, the licensee tested all AFPTSS snubbers (except those installed on the crossover legs) to check their functionabilities. The testing was conducted in accordance with Bechtel procedure M-618, " Piston Settings, Locking Velocities, and Bleed Rates for Mechanical and Hydraulic Snubners," Revision 16, dated May 14, 1985. The tests were conducted from March 25 to April 17, 1985. Among the 21 snubbers tested, hydraulic snubbers Nos. H 52 and H 12 and mechanical snubber No. H 58 were found inope able. The inspector reviewed the test data and found that the snubbers did nat meet the Bechtel acceptance criteria by small amount The Bechtel specification appeared to be very stringent compared to common industrial standards. The inspector agreed with TEco that no further testing was require . Non-Destructive Examination (NDE) of AFPTSS Lines In accordance with the corrective action agreements between RIII and TECo, the licensee performed NDE on the portions of the AFPTSS lines that are:
(a) in the vicinity of snubber and strut failures, (b) in high stress areas determined by analysis, and (c) at pipe fittings with high stress intensification factors. The NDE program and result evaluations are documented in TEco Surveillance Report No. 85-M-09 dated March 28, 198 The MT and PT performed by Exam Corporation on the weld locations specified by Bechtel did not reveal any rejectable indication The inspector reviewed the pertinent documentation, and did not have any adverse comment ,
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l 6. Documentation of Nonconformances Failure to Issue Nonconformance Reports (NCRs) On April 24-26, 1985, the inspector reviewed NCRs documenting the AFPTSS restraint failure problems. The H 144 and H 147 deficiencies were identified by craft personnel working in the auxiliary feedwater pump room on March 1, 1985. NCR No. 85-0016 was issued on March 3, 1985. On March 13, 1985, a general inspection of the area was performed by QC personnel. During this inspection the A 3 and H 34 deficiencies were observed, and NCR Nos. 85-0018 and 85-0019 were issued on the same date. In NCR No. 85-0019, QC personnel
" ... suggested to station that a walk-down of both trains be done to determine if other damage may be present." The site Facility Engineering Department (FED) subsequently performed inspection The deficiencies (those listed in Paragraph 3 above except H 344, H 147, H 34, and A 3) identified by FED were not documented in NCR Use of Sketches In Lieu of NCRs On July 29 - August 2, 1985, the inspector reviewed the Bechtel evaluation of the A 3 damage conditions. The A 3 pipe anchor is an important restraint in that it is the point where Bechtel piping stress analyses No. 40A and No. 40B are separated. The adverse conditions found at A 3 could invalidate these two analyse NCR No. 85-0018 dated March 13, 1985, documented that the top 2 bolts were loosened on A 3, but did not provide dimensional information on the gaps found between the nuts and baseplate or gaps found between the baseplate and wall. Bechtel requested information on these gap For gaps between telephone on March nuts and baseplates 18, 1985, that the gapsTECo informed Bechtel by %"
were approximately '
(based on FED measurements conducted on March 15,1985). Bechtel Calculation No. A 3, File R1, " Anchor A 3," Revision 10, performed on March 16, 1985, and approved on June 7, 1985, showed that the bolt stress safety factor was 2.4 which met the operability safety factor criteria of After the loosened top bolts were torqued, gaps ranging from 1/16" to 3/16" were found between the baseplates and walls surrounding approximately 70% of the plate edges. A sketch of the deficiencies was made by the TEco site staff and was sent to Bechtel for evaluation on May 14, 1985. The sketch did not show the dimensions of the gap Based on Bechtel's request, an additional TEco sketch was sent on May 16, 1985, showing the gap area dimensions. Subsequently, TECo issued NCR No. 85-0065 on May 16, 1985, documenting the proble The failure to document nonconformances and forward them to the A-E's for evaluation rather than the use of uncontrolled sketches is not in accordance with TECo Nuclear QA Procedure No. 2150, "Nonconformance,"
Revision 4, dated April 23, 1976, requirement This is a violation of 10 CFR 50, Appenritx B, Criterion XV (346/85013-01).
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7. Review of TECo Maintenance Work Orders (MW0s) On April 24-26, 1985, the inspector reviewed the following TECo MW0s related to the AFPTSS restraint failures: , Date Date MWO N Issued Closed Restraint N /22/85 04/24/85 H 147 (NCR 85-0016) 1-85-0936-01 03/04/85 03/08/85 H 144 (NCR 85-0016) 1-85-1056-02 03/18/85 03/21/85 A3 (NCR 85-0018) 1-85-1058-00 03/15/85 04/11/85 H 133, 32, 135, 66 1-85-1060-00 03/17/85 03/22/85 H 28, 25 1-85-1076-00 03/19/85 03/21/85 H 32, 14 1-85-1104-00 03/21/85 03/28/85 H 142, 50, 49, 34, 135, 26 1-85-1104-01 03/22/85 Open H 49, 50, 142 1-85-1104-02 03/22/85 04/19/85 H 10, 67 1-85-1104-04 03/23/85 Open H 32, 34, 142, 135 1-85-1104-05 03/25/85 04/19/85 H 49, 50 The inspector reviewed the " Safety Evaluation for Facility Change Request No. 85-0071," dated March 26, 1985, and safety evaluations included in NCR Nos. 85-0016 and 85-0018 for the disposition of the above defective restraints and affected concrete and structure The evaluations did not investigate the cause of the problem and consequently measures to prevent recurrence were not developed.
i ' This is a violation of 10 CFR 50, Appendix 8, Criterion XVI (346/85013-02).
I 8. Piping Suspension System As-Built Evaluations l On May 28-31, 1985, during the inspector's review of NCRs and MW0s he ! identified that the inspections by the TECo staff were conducted without i procedures and acceptance criteria. The inspection areas where procedures , should have been established and followed included torque testing of ! concrete expansion anchor bolts, and inspections for location, l configuration, orientation, component alignment, cold position setting, j and general physical condition of piping hangers. TEco subsequently l
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developed procedures for systematic determination of support and structure damage, and for establishing baseline inspection records so that possible damage resulting from future AFPTSS testing could be easily identifie i The procecures issued for these purposes were:
TECo Maintenance Procedure, MP 1408.01, " Piping Support Expansion Anchor Testing," dated April 25, 198 * TEco QC Section, QCIP-0C6, " Inspection of Piping Hangers, Suppor's, and Restraints," Revision 0, dated May 3, 198 TEco QC Section Checklist No. QCCL-36, " Piping Systems Observation Checklist," Revision 0, dated May 13, 198 The testing and inspections were conducted in May and . lune 198 The inspector reviewed the following NCRs that were issued as a result of the TECo inspections: Train No. 1-2 Type of NCR N Date Issued Inspection Description 85-0042 04/30/85 bolt test H 136 was found having 12 bolts instead of 7 specified by desig /30/85 bolt test H 54 welding not in accordance with desig /30/85 bolt test H 51 bolts out of plum Washer and baseplate lacked full load bearin /01/85 bolt test H 142 one bolt failed torque tes /02/85 bolt test H 59 insufficient bolt embedment dept /08/85 baseline H 59 snubber fluid reservoir installation not per desig (documentation problem) 85-0052 05/08/85 baseline H 51 incorrect spring can settin A 05/08/85 baseline H 51 pipe clamp and wall interferenc _ .
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, Type of NCR N Date Issued Inspection Description 85-0053 05/08/85 baseline H 50 found spalled I (chipped out) concret /09/85 baseline H 143 fire proofing material missin /09/85 baseline H 154 shim size for gap incorrec /09/85 baseline H 62 found missing or damaged fireproofing materia /09/85 baseline H 60 spring can size incorrec /10/85 baseline H 141 torn pipe penetration rubber sea /14/85 after pump H 49 bolts observed test pulled out during tes /16/85 baseline A 3 inadequate wall bearing surface behind baseplat /16/85 baseline H 142, 144, 145, and 147. Similar to NCR 85-006 /17/85 Note 1 H 145 sway strut rod end jam nut found loos /17/85 Note 1 H 62 snubber pipe clamp and rod end jam nut found loos Train No. 1-1 Type of NCR N Date Issued Inspection Description 85-0069 05/17/85 snubber H 20 support not exist inspection on hanger location drawin /16/85 baseline H 1 (EBD-20-H1) bolts loosened due to tes __ _ ._ . . ___ __ __
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f Type of NCR N Date Issued Inspection . Description , ' l
- 85-0070 05/17/85 Note 2 H 14 snubber pipe clamp -l and base plate bolts l i found loose. Pipe '
- clamp found misaligne /22/85 ' baseline H 25-guide angle steel j found ben /22/85 baseline H 132 and 133. Fire f
: proofing material j broke ,
85-0074- 05/24/85 baseline H 13, 13A, 15, 1 Sway strut jam nut
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loosenin H 74, 26, 36, 37.
Insulation missing or damaged, i H 19 3 of 4 sway strut 4 pins have nails instead
- of cotter pin ,
- H 20, 32, and 33.
Misalignmen H 133 pipe clamp loosened.
' Note 1: Deficiencies were found during the 04/18/85 surveillance wal k-down.
l Note 2: Deficiencies were found during the 04/12/85 walkdown 1 surveillance.
, Subsequent to the review, the inspector separated the defective hangers > into the following two groups: Group 1 - Damages Due to Possible Transient Overload * . .
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j Loosened bolts and clamps: i H 142, 50, 49, 1, 145, 62, 14, 25, 13, 13A, 15, 16, 20, 32, 33, i i and 13 * l Fireproofing and seal material damage:
' H 147, 62, 141, 132, 133, 74, 26, 36, and 37.
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Group 2 - Construction and QC Deficiencies H 136, 54, 51, 59, 154, 60, 142, 144, 145, 20, 19, and A . The inspector questioned why so many hangers had not been installed in accordance with the design drawing requirements. As a followup action, the following construction procedures were reviewed to check for program adequacy: ITT-Grinnell (ITT-G) SS-1379C, " Procedure for Field Installation and Inspection for All Q-listed and Seismic Class 1 Rigid Hangers, Variable Supports, Constant Supports, Hydrulic Snubbers, Struts, Seismic Restraints, and Anchors for Piping," Revision C, dated March 3, 197 * ITT-G Pipe Hange'? Department " Instruction for As-Built Hangers," dated December 3, 197 * ITT-G "QA Manual of the ITT-Grinnell Corporation and Subsidiaries Field Construction for Toledo Edison Co. Davis-Besse Nuclear Power Station Q Listed Items Non-Nuclear Code," dated December 12, 1976, including ITT-G QA Manual Field Construction Standard QC procedur The inspector concluded that none of the above procedures provided measures to verify design locatioa, configuration, orientation, condition, and to document nonconforming conditions during hanger construction and irstallatio On May 28-31, 1985, the inspector further reviewed TECo implementation of the actions set forth in IE Bulletin IEB 79-14 for verifying that piping as-built conditions meet design analysis requirements. The inspector's review criteria were based on Bechtel procedure PDP-2, " Inspection Procedure for As-Built Configuration of Nuclear Safety-Related Piping Components IE Bulletin 79-14," Revision 4, dated May 3, 1980. The following Group 2 hangers were reviewed:
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H 136 (3A-EBD-19-H136), QC signoffs on May 28, 1976 and August 22, 1977 The Bechtel IEB 79-14 walkdown identified construction deficiencies on August 21, 1979. Contrary to the PDP-2, Paragraph D.2 requirement that "All noted discrepancies shall be categorized by system on a Master Punch List," the deficiencies were not punch-listed and therefore an NCR was not issued and an engineering evaluation was not conducte * H 54 (3A-EBD-19-H 54), QC signoffs on February 13,1977 and August 22, 1977
The Bechtel IEB 79-14 walkdown did not identify the welding design deviation problem. PDP-2, Paragraph C.2.c.12 states that " Check that the extent of weld such as continuous, intermittent, tack,
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, both sides, all around, etc., is per design. Weld sizes and lengths greater then those specified on the drawing will be acceptable."
That inspection requirement was not implemente H 51 (3A-EBD-19-H 51), QC signoffs on March 17 and May 27, 1976 The Bechtel IEB 79-14 walkdown identified the spring setting I deviation problem on August 21, 1979. As with H 136, it was ! not punch-liste * H 59 (3A-EBD-19-H 59), QC signoffs on March 8 and May 11, 1977 The Bechtel IEB 79-14 walkdown did not identified the snubber reservoir installation deviation conditio PDP-2, Paragraph C.2.c.20 states that "Where weights other than the subject piping are found attached to the pipe supports, they should be noted. The exceptions are: .... " The exceptions did not include snubber reservoir and mounting component structure That inspection requirement was not implemente * H 154 (3A-EBD-19-H 154), QC signoffs on March 31, 1976 and March 30, 1977 Hanger was covered by insulation and the shim size could not be verified. This is allowed by IEB 79-14 (only 10% of all piping insulation was required to be removed for measurements).
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H 60 (3A-EBD-19-H 60) Site Vendor Drawing Change Notice No. 79-421-00 was issued to replace the existing spring hanger ITT-G Figure 82, No. 2, Type F with a ITT-G Figure 82, No. 4, Type F. QC signoff was dated June 3, 1982. The actual spring hanger installed was a Power Engineering Company Size 501. This is a nonconforming installation that was not identified by QC inspectio H 20 (3A-EBD-19-H 20) The Bechtel IEB 79-14 walkdown identified the existence of this hanger in the system. Bechtel design / drafting personnel failed to locate this hanger on the as-built isometric drawin * H 19 (3A-EBD-19-H 19), QC signoffs on May 7, 1976 and September 8, 1976 The condition where 3 of the 4 sway strut pins have nails instead of cotter pins was not documented as part of the Bechtel IEB 79-14 walkdown inspectio The inadequate piping suspension system QC inspection and the ineffective implementation of the IEB 79-14 walkdown inspection program are violations of 10 CFR 50, Appendix B, Criterion X (346/85013-03).
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_ Possibility of Other System Support Damages The AFPTSS piping suspension system damage was initially identified by accident (Paragraphs 3 and 6). TECo has no systematic maintenance provisions to determine hardware conditions after systen testing. The inspector stated that he suspected that other unidentified damage could have occurred in other systems which are designed for infrequent use but are subjected to periodic testing. Subequently, TEco bolt test inspection of the auxiliary feedwater pump discharge line hangers inside the pump rooms identified the following additional hanger damage: NCR No. 85- Hanger No. 6C-EBD-14- Deficiencies 0024 H 87 loosened bolts 0049 H 76 spalled concrete 0050 H 80 spalled concrete 0051 H 90 spalled concrete 0073 H 54 incorrect bolts 0075 H 69 1 loosened bolt 0076 H 68 loosened bolts 0077 H 67 incorrect bolts 0102 H 77 incorrect bolts Not issued at the H 91 incorrect bolts time of inspection Subsequent to the inspection, a TECo letter to RIII (Serial No. 1-540), dated June 14, 1985, presented TECo's proposal to resolve the issues discussed above. This is an unresolved item pending RIII followup inspection (346/85013-04).
1 RIII Confirmatory Action Letter (CAL) Following the Three Mile Island (TMI) incident, the licensee was ' requested by the NRC to improve the operability of the auxiliary feedwater syste A system operation procedure was changed to improve the steam supply for the auxiliary feedwater pumps by simultaneously opening the four motor operated gate valves on the two AFPTSS main supply lines and on the two crossover legs. This could have contributed to the various piping support component and structural damage identified in March 198 During the RIII inspection conducted on March 26-27, 1985, the licensee stated that the AFPTSS mode of operation would be changed back to pre-THI modification mode of operations. Subsequent to the system mode of operation change, the inspector was informed that H 144 and H 145 on Train No. 1-1 and H 14 and and H 58 on Train No. 1-2 were damaged agai This prompted the issuance of RIII CAL No. 85-03 on April 26, 1985 (Attachment 1).
' On May 28-31, 1985, the licensee implementation of RIII CAL-85-03 was reviewed by the inspector at the site. The status of the CAL items are as follows: l
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. Item 1 (Closed)
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H 144 was evaluated in Bechtel Calculation No. 408 (C10) "MS System," dated May 29, 1985. The snubber failure load of , 3,000 lbs. was modelled. The calculated maximum pipe stress ! was 14,132 ps H 145 was evaluated in Bechtel Calculation No. 40B (C6) "MS System," dated May 9, 1985. The vertical rigid restraint failure load of 6,340 lbs. was modelle The calculated maximum pipe stress was 22,751 ps H 14 was evaluated in Bechtel Calculation No. 41A (C4), "MS System," dated May 9, 1985. The hydraulic snubber failure load of 13,000 lbs. (bolt failure) was modelled. The calculated maximum pipe stress was 12,289 ps H 58 was evaluated in Bechtel Calculation No. 40B (C6), "MS System," dated May 9, 1985. The mechanical snubber failure load of 1000 lbs. was modelled. The calculated maximum pipe stress was 9,703 ps Item 2 (Closed) The inspector reviewed concrete expansion anchor bolt test records, and had no adverse comment The tests were conducted form April 29 through May 29, 198 Item 3 (0 pen) The AFPTSS piping test procedures and instrumentation calibration procedures were reviewed and the inspector had the following comments:
* TECo letter to RIII (Serial No. 1-532), dated June 4, 1985, transmitted the following procedures: -
TEco draft test procedure, TP 850.00, " Auxiliary Feedwater Pump Turbine Main Steam Piping Test Program (FCR 85-0087)," dated May 30, 198 MPR calibration procedure, " Test Load Cell Assembly Calibration Procedure Outline," dated May 3, 198 * On June 6, 1985, the inspector discussed his comments with TEco and MPR staff in a telephone conferenc * TEco letter to RIII (Serial No. 1-543), dated June 21, 1985, transmitted the following revised procedures:
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TEco TP850.00.0," Auxiliary Feedwater Pump Turbine Main Steam Piping Test Program," dated June 5, 198 '
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MPR calibration procedure, " Test Load Cell Assembly Calibration Procedure Outline," dated June 17, 198 * On June 24, 1985, the inspector commented on the calibration I procedure during a telephone conferenc * On July 10, 1985, the inspector commented on TP850.00.0, dated June 5, 1985, at the sit * On July 11, 1985, the inspector commented on the revised MPR calibration procedure, " Snubber Load Cell Calibration Procedure Outline," dated June 25, 1985 at the sit The licensee stated that revised procedures will be forwarded to RIII for revie Items 4 and 5 (Closed)
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For Train 1-1, the baseline inspection was conducted in May and June 198 The first monthly pump test after the issuance of the CAL was conducted on May 23, 1985, by four QC and four engineering personnel in accordance with Test Procedure ST 5071.01 requirement The damage observed was as follows:
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H 65 - the sway strut pipe clamp had dropped 3" on the pipe stanchio H 17 - the sway strut jam nut was found loos * For Train Nn. 1-2, the baseline inspection was conducted in May and June 198 The first monthly pump test after the issuance of the CAL was conducted on May 13, 1985, by six QC and three engineering personnel in accordance with Test Procedure ST 5071.01 requirements. The discrepancies observed was as follows:
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H 49 - bolts were found loose
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H 58 - excessive pipe movement (1/4" to 1/2" lateral).
- H 144 - baseplate wall gap enlarge H 147 - baseplate wall gap enlarge The second pump test was conducted on May 15, 1985 by QC and engineering personnel. The damage observed was as follows:
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Line movements were observed and the transient loads were hear H 47 - cracks found at two of the four bolt baseplate grout The above damage was verbally reported to RIII, and written reports were forwarded to RIl! as follows:
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TECo letter to RIII (Serial No. 1-534), dated June 5, 198 TECo letter to RIII (Serial No.1-539), dated June 12, 198 * TEco letter to RIII (Serial No. 1-536), dated June 13, 198 . AFPTSS System Operability Prior to the inspection conducted on May 28-31, 1985, the operability of the AFPTSS system was not an apparent item of major concern to the NRC; however, after an indepth evaluation of NRC previous inspection results, a review of the above TECo reports and the damage continuing to occur from the events described below, operability required further evaluation. Before a determination could be made regarding continued operation while this operability evaluation was performed, the plant was shutdown as a result of the June 9, 1985, loss of feedwater even From the original 14 damaged hangers reported on March 20, 1985 '
(Paragraph 3), additional damaged hangers, excluding those having fire proofing damage, were documented in: (1) MWO issued during March and April 1985 (Paragraph 7), (2) NCRs issued during bolt test and baseline inspections conducted in May 1985 (Paragraph 8), and (3) surveillance reports issued during the monthly system test conducted in May 1985 (Paragraph 10). The large number of damaged hangers (some of them were '
damaged more than once) and gaps behind the hanger baseplates could be attributed to the following system cctivations and tests: Train No. 1-1 Events from January to June 1985 Test Procedure Event Date or Trip (Note 1) Description 01/11/85 ST 5071.02 Full system test after plant refueling to verify that two independent steam generator auxiliary feedwater pumps and associated flow paths are operable.
3 Phase 1: automatic pump start Phase 2: automatic valve actuation Phase 3: Mode 1 minimum recirculation flow at 3600 rpm Phase 4: Valve response from shutdown panel Phase 5 & 6: Check valve forward and reverse flow per ASME Code 01/11/85 ST 5071.01 Monthly system test 01/15/85 Trip 4 valves opened (Note 2) 01/30/85 ST 5071.01 Monthly system test
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Test Procedure Event Date or Trip (Note 1) Description 02/04/85 ST 5071.01 System test request by Station Review Board 02/07/85 ST 5071.01 Valve MS 106 stroke test 02/27/85 ST 5071.01 Monthly system test 03/21/85 Trip 4 valves opened (Note 2) 03/27/85 ST 5071.01 System test requested by Station Review Board (use auxiliary steam) 04/08/85 ST 5071.01 Monthly system test (use auxiliary steam) 04/11/85 ST 5071.01 Monthly system test 04/12/84 ST 5071.02 Phase 1 testing only (to ensure system operability after turbine 1-2 found not meeting the Tech Spec response time) 04/24/85 Trip Valves MS 106 and MS 107 opened (See Note 2) 04/24/85 ST 5071.01 Monthly system test 05/23/85 ST 5071.01 Check minimum pump recirculation 05/23/85 ST 5071.02 Phase 1 testing only. Test was requested by Deviation Report Subcommittee. Licensee staff observed piping during tes Walkdown inspection was completed on 5/24/85 (Report 85-M-37, dated 5/30/85).
06/02/85 Trip Valves MS 106 and MS 107 opened (Note 2). Visual inspection was conducted on 6/2/85. Detailed inspection was conducted on 6/4/85 (Report 85-H-43, dated 6/7/85).
06/03/85 ST 5071.02 Phase 1 testing only. Operability check after ;.mintenance was performed on turbine governor. Licensee staff observed piping during test. Walkdown inspection was completed on 6/4/85 (Report 85-M-43, dated 6/7/85).
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i Test Procedure Event Date or Trip (Note 1) . Description 06/09/85 Trip . Valve MS 106, MS 106A, and MS 107A opened. Visual inspection was conducted on 6/9/85. . 06/09/85 ST 5071.02 Phase 1 testing only. Operability check after plant. trip. Licensee staff observed piping during tes ! Walkdown inspection was completed ; on 6/10/85 (Report 85-M-48, dated ' 6/12/85).
Train No. 1-2 Events from January to June 1985 Test Procedure Event Date or Trip (Note 1) Description 01/04/85 ST 5071.02 Phases 1 to 6 testings
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01/04/85 ST 5071.01 Monthly system test 01/15/85 Trip 4 valves opened (Note 2) 02/01/85 ST 5071.01 Special test 02/13/85 ST 5071.01 Monthly system test ] 03/11/85 ST 5071.01 Monthly system test 03/21/85 Trip 4 valves opened (Note 2) j 04/11/85 ST 5071.02 Phase 1 testing only. Test was
- - suspended because turbine speed '
- failed to meet Tech Spec response time.
' 4 04/12/85 ST 5071.02 Phase 1 testing only. Operability j check after turbine speed bushing l changeout per Facility Change q Request.
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- 04/18/85 ST 5071.01 Monthly system test 04/24/85 Trip Valves MS 106 and MS 107 opened (See Note 2)
i 05/13/85 ST 5071.01 Test suspended because flow was ' ! out of Tech Spec. Licensee staff ' l observed piping during tes Walkdown inspection was completed ' !. on 5/14/85 (Report 85-M-29,
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dated 5/16/85).
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Test Procedure Event Date or Trip (Note 1) Description 05/15/85 ST 5071.01 Re-test after flow instrument recalibration. Licensee staff , observed piping during tes Walkdown inspection was completed on 5/16/85 (Report 85-M-30, dated 5/20/85).
05/21/85 ST 5071.04 See Note 3. Inspection was conducted on 5/22/85 (Report 85-M-36, dated 5/28/85).
06/02/85 Trip Valves MS 106 and MS 107 opened (Note 2). Visual inspection was conducted on 6/2/85. Detailed inspection was conducted on 6/4/85 (Report 85-M-44, dated 6/7/85).
L6/06/85 ST 5071.01 Monthly system test. Licensee staff observed piping during tes Walkdown inspection was completed 4 on 6/7/85 (Report 85-M-48, dated 6/12/85).
06/09/85 Trip Valves MS 106, MS 106A, and MS 107A opened due to operator error. Visual inspection was conducted on 6/9/8 /09/85 ST 5071.02 Phase 1 testing only. Operability check after plant trip. Licensee staff observed piping during tes Walkdown inspection was completed ! on 6/10/85 (Report 85-M-48, dated 6/12/85).
Notes: Trip means steam and feedwater rupture control system (SFRCS) activatio . Prior to January 4,1985, the AFPTSS operation procedure required delivery of steam from Steam Generator (SG) 1-1 to Auxiliary Feedwater Pump Turbine 1-1, and from SG 1-2 to Auxiliary Feedwater Pump Turbine 1-2 or through crossover legs if one of the main steam (MS) supplies experiences a drop in pressure. The power operated valves installed on MS 1-1, MS 1-2, the crossover leg from SG 1-1 to turbine 1-2, and the crossover leg from SG 1-2 to turbine 1-1
. . .
are MS 106, MS 107, MS 107A, and MS 106A respectivel Since January 4,1985, in order to improve the auxiliary feedwater system operability, all four valves were required to open during SFRCS . activation. However, on April 2, 1985, after numerous piping
'
supports and structures were found damaged (could have been caused by dynamic transient overloads), the operation procedure was restored to the original (prior to January 4, 1985) mode of operation . ST 5071.04 is a general test procedure for checking functionability of valves MS 106A and MS 107 On May 21, 1985, the operator should have pushed switch No. HIS 107E to open MS 107A, but erroneously pushed switch No. HIS 107A which opened MS 107 instead. MS 107A has a built-in interlocking device that shuts off the valve as soon as the valve closure light goes out during testing, but MS 107 does not have this interlocking mechanis In this incident, instead of a puff of steam being sent from SG 1-1 to turbine 1-2, a full thrust of steam was rushed from SG 1-2 to turbine 1-2. Some line movement was observed by the TECo testing staff who were in the turbine are In accordance with the plant Technical Specifications, a safety system that is determined to be inoperable should be restored to an operable condition within 72 hours while the redundant system is still in an oparating condition, or the system should be placed in the Mode 4 condition within the next 12 hours. Whether or not this Technical Spe:ification requirement was violated was the subject of a followup inspection conducted at Bechtel on July 29 through August 2,198 During the July 29 - August 2, 1985, inspection, the inspector determined that although extensive evaluations were completed by Bechtel relative to the AFPTSS operability, there were no consistent and systematic ways to assess the system condition prior March 1, 1985 (first identification of gross hanger damage) and the subsequent deterioration or improvement of system in terms of system operability. The need to develop a program covering the following operability criteria were discussed during the inspectio * Analytical methodology to be used for resolving operability issues including piping overstress, hanger load increases and equipment nozzle loading combinations that exceed the manufacturer's allowables.
l ' Justification for using IEB 79-02, IEB 79-14, and the Bechtel developed alternative equipment nozzle stress criteri * Definition of short-term piping system operation prior to restoring piping components to their original (undamaged) conditions.
l l The inspector reviewed Bechtel's case-by-case evaluation of hanger damage j and the resulting deficiencies for AFPTSS Trains 1-1 and 1-2. A summary
- of the reviews are documented in Table 1 and Table 2 which follows:
! I 19
I ! _ __
__ . - _ .._ _ . ._ _ _ _ . --- - _ _ _ _ . _. _ _ ..
. . , . , ' TABLE 1 Summary of Train 1-1 Hanger Damages and Deficiency Evaluations
Hanger i NCR No.:85- / l Bechte I No Description Calc. N Status y 6 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1)
- I I I
! ' 8 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l I l _
- -
'
9 l 90-(6/6/85)/ gaps l l Acceptable (Note No. 1) ;
-l l l
- l 10 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l i l I i i 12 1 90 (6/6/85)/ gaps l Note No. 2 l Acceptable 1
:
i' I l l ' j 13 l Surveillance Report l TEco Review l Acceptable l (SR) 85-79 (6/28/85)/l l ,
' ; I loose jam nut l l j i I l j 13A l 94 (6/11/85)/ strut i 41A, Rev. 5 l Acceptable i l and clamp inter- l 8/20/82 l :
- I ference l l ;
l l l 14 l * 19A (3/14/85)/ l Note No. 2 l Inactive ! l snubber and clamp l l l l misalignment l l i l l l j- l * 92 (6/6/85)/ l 41A-10, 1 Acceptable ; j l threaded rods l Rev. 1 l
!
l in lieu of bolts l 6/28/85 l l 1 l l : i 15 l 74 (5/24/85)/ loose i TEco review l Acceptable , i l jam nut l l
-
i l l 1 i 16 I 94 (6/11/85)/ loose 1 41A (C7), l Inactive i
- I pipe clamp I 7/6/85 i j l l l .
'
18 l 92 (6/6/85)/ loose l TEco review l Acceptable ; 1 l strut l l .
! l- 1 I !
{ 19 l 74 (5/24/85)/ nails l TEco review l Acceptable ,
i l in lieu of cotter I l i l pins l l 4 l l l 1 20 l * 92 (6/6/85)/ l 41A-17, I
'
I threaded rods in l Rev. 1, l i i lieu of bolts l 6/28/85 l i l l I i l * SR 85-73 (5/20/85)/l TECo review l Acceptable l cracked concrete -l l l l l l J
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'
' 20 I
, , . - . -. .- . - - - . .. - - . ..
t
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Hanger l NCR No. 85- / l Bechtel l l
No Description Calc. N Status
! 21 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l I l .
l
,
22 l * SR 85-73 (5/20/85)/l TEco review'l Acceptable
'
! I cracked concrete- l l
'
l l l i l * 90-(6/6/85)/ gaps ~l l Acceptable (Note No.'1)
; l l 1
!
'
23 -l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l 24_ l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) 1 - l l i 25 l 71 (5/22/85)/ bent i 41A-21, l Acceptable for short-term I guide angle l Rev. 2, I use
- I i 6/4/85 I I l l l 26 1 * SR 85-73 (5/20/85)/l TEco review l Acceptable *
l l cracked concrete l l
l l l , l * 90 (6/6/85)/ gaps 1 Note No. 2 l Acceptable
! I l l j 28 l 19A (3/14/85)/ l 41A (CS), I Inactive i deformed saddle 1 6/26/85 l (The saddle was repaired l l l for short-term use) ,
i l 1 l l 32 l * 19A (3/14/85)/ l 41A (CS), l Inactive } l loose bolts, I 6/26/85 1 ! t I misalignment, I l : ! l missing washers l l i l l I ' l * 26 (3/27/85)/ I 1-85, 1 Acceptable
'
'
,
l nonconforming l Rev. 1, ! ,
'
l weld l 6/6/85 l ! l l l l * 74 (5/24/85)/ l l 41A (CS), l Inactive misalignment
'
l l 6/28/85 l ; i l 1 I ' i 33 l 74 (5/24/85)/ strut i Note No. 2 l Acceptable
- I free to rotate l l ,
'
i l 1 l 34 l 19A (3/14/85)/ l 41A (CS), l Inactive 1 l deformed stanchion l 6/26/85 l (The stanchion was repaired
- I l l for permanent use)
l l l l 5 65 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) ! 1 l l j 66 l * 90 (6/6/85)/ gaps i 408 (C13), 1 Acceptable for short-term )j l l 7/11/85 l use ' l * 19A (3/14/85)/ l l ! l loose bolts i Note No. 2 l Inactive ,
'
! l l 1 !.
^
' - - . ,
Hanger i NCR No. 85- / l Bechtel l No Description Calc. N Status , ' 67 l * 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) I I l 1 * 92 (6/6/85)/ gap l 408, Rev. 6 l Acceptable i on restraint l 6/8/81 l l 1 I l * SR 85-73 (5/20/85)/l TEco review l Acceptable l cracked concrete l l l l l 68 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l l * SR 85-73 (5/20/85)/l TECo review l Acceptable . ' I cracked concrete l l l l 1 70 l 92 (6/6/85)/ loose l TEco review l Acceptable l jam nut l l l l l 72 l 90 (6/6/85)/ gaps l Note No. 2 l Acceptable l l l 74 1 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l 131 l 90 (6/6/85)/ gaps l 120F, l Acceptable for short-term l l Rev. C2, l use l l 7/6/85 l l l l 132 l * 90 (6/6/85)/ gaps l 120F, 1 Acceptable for short-term l l Rev. C2, l use l l 7/6/85 l l l l l * 19A (3/14/85)/ l Note No. 2 l Inactive l loose bolts l l l l l 133 l 90 (6/6/85)/ gaps l 120F, l Acceptable for short-term l l Rev. C2, I use l l 7/6/85 l l l l 135 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l 148 l 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l 150 l * 90 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l l * SR 85-73 (5/20/85)/l TEco review l Acceptable l cracked concrete l l l l l A362 l 90 (6/6/85)/ gaps l Note No. 2 l Acceptable l l l EBD-20-H1 1 * 64 (5/16/85)/ gaps i 408, l Inactive l l Rev. C9, ll l l 5/29/85 l l l l * 19A (3/14/85)/ l Note No. 2 l Inactive l loose bolts l l l l l
. _ _ _ _ _ _ _ _ _ - _ - _ - .
! l
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,
. j
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i j Notes: 1 Bechtel staff judged the deficient conditions to be acceptabl Calculations will be performed to confirm the staff's engineering , judgemen , ' Bechtel staff viewed the deficient conditions as either being so l severe or so minor that conclusions can be drawn without calculations.
l TABLE 2 , Summary of Train 1-2 Hanger Damage and Deficiency Evaluations Hanger l NCR No. 85- / l Bechtel l No Description Calc. N Status A3 l 65 (5/16/85)/ gaps i A-3 (R1), l Acceptable for short-term l l 6/10/85 l use l l l 49 l 19A (3/14/85)/ l 40A (C3), l Inactive l strut put out from l 3/25/85 l l wall l l l l l l * 60 (5/14/85)/ gaps l 40A-15, 1 Acceptable l on new plate l Rev. 2, l l l l 5/22/85 l l l I : l * 91 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l 50 l * 19A (3/14/85) l 40A (C3), l' Inactive l I strut put out from l 3/25/85 l : l wall l l l l l
[ * 91 (6/6/85)/ gaps l l Acceptable (Note No. 1)
l l l 51 l * 44 (4/30/85)/ gaps, l 40A-25, l Acceptable for short-term i bolts out of plumb l Rev. 1 l use > l l 5/20/85 l l 1 I l * 52 (5/8/85)/ l 40A-25, l Will reset spring setting l incorrect spring i Rev. 1, l l setting l 5/20/85 I I I I l * 91 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l 52 l 91 (6/6/85)/ gaps l l Accept.sble (Note No. 1) l l 1 , 53/54 l * 91 (6/6/85)/ gaps l l Acceptable (Note No, 1) 7 I l l l * 43 (4/30/85)/ l 40A-13, 1 Acceptable l nonconforming weld i Rev. 1, I i l S/9/85 l l l l 55 l91(6/6/85)/ gaps l l Acceptable (Note No. 1) l I I , 56 l 91 (6/6/85)/ gaps l l Acceptable (Note No. 1) l l l
- . ,
Hanger l NCR No. 85- / l Bechtel l No l Description Calc. N Status I , 58 1 32 (4/8/85)/ frozen 1 40B (CS), l Modelled as rigid strut I mechanical snubber l 5/1/85 and l (Snubber was replaced l l 408 (C9), l on 4/24/85) l l 5/29/85 l l l l 59 l * 48 (5/8/85)/ l Note No. 2 l Acceptable i snubber reservoic l l l attached to A200 l l l l l l 46 (5/2/85)/ longer l Note No. 2 l Acceptable l bolts l l l l l 60 l 58 (5/9/85)/ 1408, Rev. 5 l Acceptable for short-term l incorrect spring l 2/27/81 l use l size l l l l l 62 1 68 (4/18/85)/ loose l TECo review l Acceptable l strut l l l l l 136 1 42 (4/30/85)/ l 40A-11, l Acceptable i nonconforming bolts l Rev. 1, l l l 5/9/85 l 1 l l 141 l SR 85-74 (6/6/85)/ l TEco review l Acceptable l cracked concrete i l l l l 142 l * 19A (3/14/85)/ I 40B (CS), 1 Inactive l strut put out from l 5/1/85 and l l wall l 40B (C9), l l l 5/29/85 l 1 l l l * 66 (5/17/85)/ gaps 1 0-408-1, l Acceptable for short-term l l Rev. C, l use l l 5/24/85 l l l l 144 l * 16 (3/1/85)/ broken l 40B (C3), 1 Inactive l snubber 1 3/21/85 l l l l l * 38 (4/18/85)/ l 40B (C9), l Inactive-l broken snubber l 5/29/85 l l l l l 66 (5/17/85)/ gaps l 408-3, l Acceptable l l Rev. O, l l l l 5/24/85 l l l l l ! l l
l
. , .. -- . . . . . , .
Hanger l NCR No.~85- / l-Bechte I No s .- Description Calc. N Status 145 l * 66 (5/17/85)/ gaps l 408-2, l Acceptable for short-term l l Rev. O, l use I l 5/24/85 l Require flexibility check-1 I l , I 67 (6/12/85)/ loose l 408-2, l Acceptable
l bolts l Rev. 1, l l l 6/17/85 l
.l l l 147 l * 16 (3/1/85)/ strut l 408 (C3), l Inactiva l put out from wall l 3/21/85 and l l l 408 (C9), l l l 5/29/85 l l l l : l * 66 (5/17/85)/ gaps l 40B-1, l Acceptable l l l Rev. 1, l l l 5/24/85 l
. I l~ l i 154 l 56 (5/9/85'/ l TECo review l Acceptable J l incorrect shim size l l
. I I I
! A200 l 48 (5/8/85)/ snubber l Note No. 2 l Acceptable
: l reservoir attached l l
{ l to H59 l l
l 1 l ! A362 l 90 (6/6/85)/ gaps l Note No. 2 l Acceptable 1 1 I I
- Notes: Bechtel staff judged the deficient conditions to be acceptable, i Calculations will be performed to confirm the staff's engineering
! judgemen . Bechtel staff viewed the deficient conditions as either being so severe or so minor that conclusions can be drawn without calculations.
i The inspector stated that he would review the operability program and
, the results of Bechtel's evaluation of the collective analysis of the , identified hanger damage during a future inspection. Subsequently, during '-
discussions with TEco, the middle of September,1985 was established as ] the completion date for these evaluations. This is considered an unresolved item (346/85013-05).
12. RIII Questions and Licensee Responses +- The RIII questions and the licensee responses are as follows: What affect could dynamic transients have on the AFPTSS system? Could it caJse both trains to be inoperable at the same time?
._-_ _ ____ __ _ _ _____ __ ___-__________ _________ - ____________ ____--____ _ _-_ _ _ _ __ _ _ _ _ - _ _ - . . , .
The dynamic transient could have potential affect on both trains
, including (1) if both trains actuate and both trains sustain damage causing inoperability, and (2) if the first train is inoperable and then the second train is declared to be inoperabl The system inoperability could be caused by (1) unanalyzed pipe movements during system actuation, (2) damaged or broken components, and (3) loosened components. The deficient hardware conditions ceuld result in (1) piping overstress, (2) pipe support overload, and (3) equipment nozzle loads that exceed the manufacturers'
allowables, b. After each transient event, what corrective actions (controlled walkdown inspection, 50.59 evaluations, etc.) were taken? l January 1, 1985 through March 13, 1985 - Walkdowns of the AFPTSS piping system were not conducted after each actuation of the system l ' following the completion of the fifth refueling outage ending in January 198 March 14, 1985 through May 7, 1985 - Initial support failures (H144, H147) were identified by QC on March 1, 1985. Subsequent support failures (A3, H34) were identified by QC on March 13, l 198 As a result of QC request, the site engineering staff conducted a walkdown on March 14-16, 1985 (not a controlled, l proceduralized process) of the AFPTSS piping system to identify ! gross failures. Following the plant trip on March 21, 1985, the site engineering staff again conducted a similar walkdown to identify gross failures. For other actuations of the system through May 7, 1985, similar walkdowns were conducted after some of the system actuations, but not after all actuations. A Region , III Confirmatory Action Letter 85-03 was isstfed on April 26, 1985.
! Train No. 1-1 of the AFPTSS piping system was not actuated between i April 26, 1985 and May 23, 1985; Train No. 1-2 was not actuated between April 26, 1985 and May 13, 1985.
. The controlled, proceduralized QC baseline walkdown inspection was - ! conducted from May 8 through June 9,1985, and after each actuation l of the AFPTSS system during this period, with two exceptions, i.e., after the June 2 and June 9, 1985 plant trips. Following these two plant trips, the QC and site engineering staff performed walkdowns (these were not controlled, proceduralized processes) and found
- no gross failures. Prior to these two walkdown inspections, an
- operability verification test (ST5071.02) of the AFW system was performe Surveillance Reports (SRs) were used to document the deficiencies identified by QC and site engineering staff during walkdown inspections. These deficiencies were first evaluated and
- dispositioned by TEco engineering. Significant deficiencies l were then documented in NCRs by QC. NCR dispositions including 10 CFR 50.59 and operability evaluations were conducted by Bechtel and TEco engineering.
l l 26
. . , . In view of the large number of damaged supports observed in the AFPTSS system, did piping stresses exceed FSAR commitments and/or the IE Bulletin 79-14 operability criteria? i
-Response will be provided when Bechtel completes its evaluatio If the answer to Item c is affirmative, were there instances where ,the piping overstress was in other than the seismic design conditions?
Response.will be provided when Bechtel completes its evaluatio Were.all of the damaged supports evaluated in a chronological order? Depending on complexity and interrelationship with other occurring damaged supports, evaluations may not have been conducted in chronological order. Systematic evaluations for the conditions that existed before March 1, 1985, (when the problem was first identified)~and up to June 9, 1985 will be performed by Bechtel Power Corporatio Were composite studies completed to evaluate all of the presently occurring transients? Response will be provided when Bechtel completes its evaluatio After all the years of operation of this plant, why are these transient events just now occurring? TEco does not know exactly if the transients occurred previousl It can reasonably be assumed that other transients may have' occurred after January 1985 when opening of valves MS 106, 106A, 107, and 107A concurrently became a mode of system operation. This increased the amount of ambient piping subjected to hot steam flow and increased condensate accumulation inside the piping. The mixture of steam and condensate created flow turbulence and/or water hamme There was also~a possibility that the adverse hanger conditions could have been caused by a number of lesser transients that-could have occurred prior to January 198 . Licensee Report of Hanger Damages The damage to the AFPTSS system hangers were reported.to Region III by the licensee as follows:
~
Letter to.RIII (Log No.~K85-649), dated April 19, 1985, transmitted LER No. 85007, " Auxiliary Feed Pump Turbine Response Time Problems."
The-LER stated, in part:
"In addition, a Steam and Feedwater Rupture Control System logic change also made during-the 1984 Refueling Outage, was a possible cause of water flow forces in the main steam crossover supply lines which was loosening hangers and damaging supports."
, . . -
. . ,
l
"In addition, AFP 1-1 had been earlier declared inoperable on March 16, 1985, due to a hanger failure. At that time, the hanger ,
problem was thought to be from water flow forces that resulted j from the SFRCS logic change implemented during the 1984 Refueling j Outage. The hanger was repaired the same day." '
" Designation of Apparent Cause of Occurrence: The SFRCS logic change conducted under Facility Change Request 81-178, which opens the cross-connect main steam supply valves MS 106A and MS 107A, in addition to the main steam supply valves MS 106 and MS 107, on a full SFRCS trip has been determined to be a primary cause of the water flow forces. Water flow forces caused some hangers to loosen in both trains; however, an engineering evaluation determined that only one support on AFW Train 1 was damaged to the extent that it affected the operability of that trai That support was repaired the same day, and the train declared operable."
" Corrective Action... Change the logic of the steam supply valves (MS 106A and MS 107A) so that they will no longer open simultaneously with valves MS 106 and MS 10 This was done under FCR 81-178, Revision A, Supplement 2."
Letter to RIII (Log No. K85-934), dated June 27, 1985, transmitted LER No. 85007, Revision 1, same title. The LER stated, in part:
" Additionally, several days prior to the trip a visual inspection of the main steam supply lines to both Auxiliary Feed Pump Turbines identified loose hanger bolts and some hanger damage."
"The cause for loose hanger bolts and hanger damage has not been identified. Four different operating events have been postulated and continued investigation and testing is planned to identify the actual causes." ,
"All loose hanger bolts had been re-torqued and most of the damaged hangers had been either repaired 0r replaced prior to the tri Plant procedures have been modified to' minimize the transient loads placed on the steam-piping due to system' actuation and surveillance ,
testing." -
"In addition, AFP 1-1 had been declared inoperable on March 16, 1985, after the discovery of damage to the folloWing hangers on the main s
z steam piping.to AFPT 1-1: ,
' ' , _ 3A-EBD-19-H14 '
1 3A-EBD-19-H25 's , - 3A-EBD-19-H28 x 3A-EBD-19-H32 t 3A-EBD-19 H34 3A-HB5 19-H135
, .
'
t ( s ,
-
w
' . 1 28 '
_t . - __ _ _ _ _ _ . . _ _ _
. . .
l This was the second time since the beginning of the year that loose , hanger bolts and damaged hangers had been discovered on the AFPT ' steam lines. Investigations initiated following the initial l discovery of hanger damage had not yet identified the cause of the l damage."
"An engineering evaluation of the hanger damage concluded that the damage to hanger 3A-EBD-19-H28 required AFP 1-1 to be declared inoperable. This hanger was repaired on March 17, 1985, allowing AFP 1-1 to be declared operable. Hangers 3A-EBD-19-H25 and 3A-EDB-19-H135 were determined to be operable in their as-found condition. The remaining hangers were restored to their as-built condition by March 23, 198 An operability analysis for AFPT 1-1 assuming hangers 3A-EBD-19-H25, 3A-EBD-19-H28, and 3A-EBD-19-H135 operable with the other three hangers inoperable determined that the steam supply line for AFPT 1-1 met its short term operability requirements. A visual inspection of the AFPT steam lines after the March 21, 1985 trip and SFRCS actuation did not identify any new hanger damage."
"Since plant startup in January,1985, after completion of the 1984 Refueling Outage, loose hanger bolts and damaged hangers have been discovered at several different locations in the main steam piping to the AFPTs. Additionally, damage to a single pipe anchor has been discovere Although the exact cause of damage to piping hangers has not been identified,. the following conditions are being investigated: Use of auxiliary steam to perform testing of both AFPTs during the 1984 Refueling Outag . Use of main steam and auxiliary steam to perform monthly surveillance test on pressure switches PSL106A-106D and PSL107A-107D which are located in the steam line to the AFPT . Opening of valves MS 106A and MS 107A simultaneously with MS 106 and MS 107 to supply main steam to AFPTs. Prior to the 1984 Refueling Outage only valves MS 106 and MS 107 were opened to supply main steam to AFPT 1-1 and AFPT 1- . Vibration from system actuation and monthly testing which over time loosen hanger bolts until they fail to perform their function during the transient event associated with quick starts of the systei Additional testing and evaluations are expected to help determine the exact cause of the hanger problems."
"Both AFPT steam lines have been affected with hanger damage loose hanger bolts due to transients loads. Excluding the one damaged pipe anchor and the damage to hanger 3A-EBD-19-H28, analysis has shown that the hanger damage discovered to date has not affected the sfiort-term operability of the piping-system."
. . .
.
" Corrective Action... Change the logic for steam supply valves MS 106A and MS 107A so that they will no longer open simultaneously with valves MS 106 and MS 10 . Revise the surveillance test for PSL106A-106D and PSL107A-1070 so as to perform the test without use of either main steam or auxiliary stea ,
l Instruct operator to slowly open the supply valve from the I
'
auxiliary steam system using auxiliary steam to test AFW pump . Replace and/or repair damaged hangers and re-torque all loose bolt A test plan is being prepared to perform a systematic test of the steam lines to the AFPTs under Facility Change Request 85-008 Through this test program the transient loads experienced by the steam line due to system actuation will be measured on selected hangers along with the transient pressurization of the steam lines and the piping temperatures. The test program will assist in quantifying the loads experienced due to the initial pressurization and heatup of the cold steam lines. Also, it will help identify the major causes of hanger damage. Until the cause of the hanger damage is identified and corrected, the steam line hangers will be inspected after every initiation of the system including monthly and quarterly surveillance testing."
At the conclusion of the inspection, the inspector's review determined that the licensee failed to report the system adverse conditions in accordance with the requirements of 10 CFR 50.73.a(1), (2)ii(A), and (2)ii(B) as follows: The April 19, 1985, the LER discussed damage to one hanger (H 28) and
"sume hangers to loosen in both trains." The other specific damage as described in Paragraph 3 and listed below were not reported:
Train No. 1-1 Train No. 1-2 H 132 H 50 H 34 H 49 H 32 A3 H 25 H 142 H 14 H 28 H 135 H 144 H 66 H 147 The June 27, 1985, the LER reported the following hanger damage:
. - , - - . . . . . . . . __ .. _ .-. .
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.. %. _, . ,
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A Train'No. 1-1 H 28 ' H 14 H 25 H 28 H 32 , H 34 i H 135
<
The other hanger damage (listed below) was not reported (refer to Paragraphs 3, 7, and 8):
i Train No. 1-1 Train No. 1-2 H 132 H 50 H 66 H 49 H 133 A3 H 10 H 142 H 67 .H 28 EBD-20-H1 H 144
<
H 13 H 147 H 13A H 142 H 15 H 145 ' H 16 H 62 H 33 H 20 ' Gaps found behind baseplates on the following hangers (refer to Paragraph 11) were not reported: l Train No. 1-1 Train No. 1-2 j H 135 H 51 . H 21 H 52-H 22 H 53 i H 23 H 54 < H 24 H 55 H 133 H 56 i H 132 H 144 ! H6 H 145 H8- A3 j H9 H 10 H 12
; . H 26 i H 65 H 66
- H 67 H 68 l H 72
! - H 74 H 131 ,
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Train No. 1-1 H 148 H 150 A 362 Damage observed on the following hangers on the auxiliary feedwater l pump discharge lines was not reported (refer to Paragraph 9): I l 6C-EB-14-H 87, 76, 80, 90, 54, 69, 68, 67, 77, and 9 There are 53 hangers on AFPTSS Train 1-1 of which 19 were found damage There are 27 hangers on AFPTSS Train 1-2 of which 10 were found damage The inspector considers the damage to be substantial and that they should have been reported to the NRC in a more complete manner in accordance with 10 CFR 50.73 requirements. The condensate in the AFPTSS piping created a flow turbulence (dynamic transient) that led to excessive piping movement and caused damage to the piping support The condensate flashing to steam in the turbine could cause turbine overspeeding and pump trip. The use of the IE Bulletins 79-02 and 79-14 operability criteria in lieu of FSAR design commitment to allow continued system operation for a short duration prior to restoration of the support component to the original design conditions is acceptabl However, the licensee is responsible for reporting all significant degradation of systems and unanalyzed conditions that deviate from the FSAR commitments regardless of whether or not the as-found system met or exceeded the IEB Bulletin operability criteri This is a violation of 10 CFR 50.73 reporting requirement (346/85013-06).
14. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 9 and 1 . Exit Interview Exit interviews with licensee representatives were conducted on July 11 and August 2, 1985, to discuss the inspector's findings. The inspector discussed the likely informational content of the inspection report with regard to documents reviewed by the inspector during the inspection. The licensee did not identify any such documents as proprietar .
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CONFIRHATORY ACTION LETTER RIII-CAL-85-03 no se ,,, t'Ntit0 ST At t s 4 . NUCLEAR REGULATORY COMMISslON
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%,. .....s ' ' M 1935 Docket No. 50-346 .
Toledo Edison Company ATTN: Mr. Richard P. Crouse Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:
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This refers to the discussion between Mr. J. Wood of your staff and - -
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Mr. D. Danielson of my staff on April 26, 1985, regarding activities you wi_ll take as a result of the damage recently sustained by several auxiliary Csteam supply 7 Teed pump turbine!(AFPTSS) piping restraints on Davis-Besse Unit 1. With regard to the matters discusstd, we understand you will take the following actions: Complete by May 10, 1985, piping system operability stress analyses local to the following damaged restraints utilizing loads calculated to have been necessary to cause the degraded conditions of the restraints:
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AFPTSS Train No. 1-1: 3A-EBD-19-H144 3A-EBD-19-H145
* AFPTSS Train No. 1-2: 3A-EBD-19-H14 3A-EBD-19-H58 The maximum piping transient stress (St) will be combined with applicable primary pipe stresses utilizing the following formula:
Sp + Sw + Se + St i 2.4 Sh Where Sp = p'ressure stress at operating condition Sw = stress due to piping and attachment dead weights Se = stress calculated based on plant safe shutdown earthquake (SSE) condition Sh = ANSI B31.1 pipe stress allowable for hot operating condition Ch &4%
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+ . . CONFIRMATORY ACTION LETTER RIII-CAL-85-03
. Toledo Edison Company 2 Complete by May 24, 1985, torque tests for concrete expansion anchor bolts installed on all snubbers and rigid supports and restraints shown on the following drawings:
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HL-203F, " Main Steam System, Supply to Auxiliary Feed Pump Turbine No. 1-1", Revision * HL-203H, " Main Steam System, Supply to Auxiliary Feed Pump Turbine No. 1-2 and Exhaust", Revision . Initiate by June 5, 1985 an inservice testing program for the AFPTSS piping system to determine the cause and nature of the system transient that resulted in the degradation of.the restraints identified during previous inspections by Toledo Edison Company (TEco). The program will include load and displacement measurements under cold and hot operating conditions for.the following piping alignments: ,
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Steam supply to auxiliary feed pump turbine (AFPT) No.1-1 from .
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Steam Generator (SG) No. 1- Steam supply to AFPT No. 1-2 from SG No. 1- *
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Steam supply to AFPT No. 1-1 from SG No. 1-2 through crossover le Steam supply to AFPT No.1-2 from SG No.1-1 through crossover le Prior to initiation of the program, TEco will: Develop test procedures including identification of instrumentation locations on isometric drawings and delineation of personnel interface and responsibilities during the test Implement calibration procedures for all instrumentation including the strain gauges installed on snubbers and rigid restraint Establish evaluation criteria for load and displacement measurements based on the calculated SSE value An inservice test that requires steam flow to AFPT Nos. 1-1 and 1-2 from SG Nos. 1-1 and 1-2 utilizing both main and crossover legs will not be conducted until previous tests performed under this program have been evaluated, necessary precautionary measures have been established, and test provisions and measures have been reviewed by Region III, Conduct piping system surveillance during the monthly auxiliary feed pump tests and the quarterly system response tests performed under normal plant operating conditions and during testing conducted as a result of plant shutdowns or maintenance activitie ;
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CONFIRMATORY ACTION LETTER RIII-CAL-85-03 6-Toledo Edison Company 3 Report to Region III verbally within 2 working days, with a followup written report within 72 hours, any defective structures and piping suspension system components discovered during the activities described in Items 1 through 4 above or following any actuation of the auxiliary feedwater syste Such reports will not relieve TECo of the obligation to submit any reports required by 10 CFR 50.7 Please inform us immediately if your understanding of these actions are different from that stated abov & L f,YvvAu-
[*JamesG.Keppler Regional Administrator ,
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cc: S. Quennoz, Station - Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Chio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health R. Baer, IE F. Cherney, MEB, NRR
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