IR 05000346/1985033

Insp Rept 50-346/85-33 on 851008-10 & 23-24.No Violation or Deviation Noted.Major Areas Inspected:Hanger Installation Reinsp Program & Licensee Evaluation of Hanger Nonconformance Repts Issued During Reinsp

ML20138R396
Person / Time
Site:	Davis Besse
Issue date:	11/06/1985
From:	Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138R386	List: IR 05000346/1985033 ML20138R385
References
50-346-85-33, NUDOCS 8511180578
Download: ML20138R396 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/85033(DRS)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, Ohio Inspection Conducted: October 8-10 and 23-24,1985

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th b' M Inspector: . . in Hb OI Date Approved By: D. H. Danielson, Chief Lt 4 /98 Materials and Processes Section Date Inspection Summary Special Inspect. ion from October 8-10 and 23-24, 1985 (Report No. 50-346/85033(DRS))

Areas Inspected: Special, announced inspection of the licensee's hanger installation reinspection program; the licensee's evaluation of hanger nonconformance reports (NCRs) issued during this reinspection; and inspection of piping component locations and dimensions. The inspection involved a total of 32 inspector-hours onsite by one NRC inspecto Results: No violations or deviations were identifie PDR ADOCK 05000346 G PDR

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DETAILS Persons Contacted Toledo Edison Company (TED)

+J. Williams, Jr. , Senior Vice President, Nuclear

+ J. Myers, Nuclear Safety and Licensing Director

+ R. Wuokko, Nuclear Licensing Supervisor

+ S. Bloom, Senior Licensing Specialist

• +J. K. Wood, Facility Engineering General Supervisor

• +P. H. Straube, Senior Engineer

• +S. J. Osting, Nuclear Facility Engineer

• +C. T. Daft, QA Director

+M. Shepherd, Code Inspection Supervisor

• 5. M. Quennoz, Group Director, Nuclear Engineering

• R. F. Peters, Nuclear Licensing Manger J. Helle, Director, Nuclear Facility Engineering S. Singer, Senior QC Inspector USNRC

+ Dick, Project Manager, NRR

+ W. Dromerick, Section Chief-EGCB, IE

+J. R. Fair, Senior Mechanical Engineer, IE

+ J. Paperiello, Director, Division of Reactor Safety (DRS),

Region III (RIII)

+ J. Harrison, Chief, Engineering Branch, DRS, RIII

+D. H. Danielson, Chief, Materials and Processes Section, DRS, RIII

• I. N. Jackiw, Chief, Projects Section 28, Division of Reactor Project and Resident Programs, RIII

• + Rogers, Senior Resident Inspector, RIII

• D. C. Kosloff, Resident Inspector, RIII

• +I. T. Yin, Senior Mechanical Engineer, RIII

• Denotes those attending the management exit meeting at the site on October 24, 198 + Denotes those attending the hanger meeting at the site on October 9, 198 . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (346/85013-04): A followup inspection was conducted on September 9-11, 1985,at the site (RIII Inspection Report No. 50-346/85031). The NRC inspector further reviewed TED's hanger reinspection program and the disposition of NCRs generated as a result of the reinspectio The reinspection status, as of October 8, 1985, was as follows:

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Reinspections

• 891 hangers were inspected

• 836 NCRs were issued Engineering Evaluation of NCRs

• 748 NCRs were received by Nuclear Facility Engineering Division (NFED)

• 246 NCRs were determined to be "Use-As-Is"

• 43 NCRs required corrective actions To determine the adequacy of the TED NCR evaluation program, the NRC inspector selected several NCRs for review. See Paragraph 5 for detail The present and future TED actions to resolve the issues were discussed during a meeting between RIII and TED at the site on October 9, 1985 (Paragraph 4).

3. Plant Tour The NRC (NRR, IE and RIII) personnel examined selected areas of the plant on October 8, 1985. Hangers and piping selected for examination included: Worst Case Nonconformances After a cursory review of 673 NCRs that were identified by reinspection, TED determined the following five deficiencies were worst case examples based on deviations from design and possible hardware damag NCR N Hanger N Nonconformance 85-224 EBB-4-H17 Baseplate thickness: 1/2" design; 3/8" installed 85-249 EBD-19-H80 Baseplate thickness: 1" design; 1/2" installed 85-376 HCC-91-H4 Hanger rod not carrying load 85-510 EBD-19-H97 Damage / defect on one of the four pipe stanchions85-524 A08 Inadvertently not replaced by A489 Auxiliary Feedwater Pump Turbine Steam Supply (AFPTSS) System The pipe loops which compensate for AFPTSS system thermal expansion and a few closely spaced rigid restraints were observed on the AFPTSS crossover pipin . Hanger Meeting A meeting between TED and RIII personnel (attendees are denoted in Paragraph 1) was held at the site on October 9, 198 ..- -. - . . .- . -. -- - . . . . - . - .- . . - - . . . - - - - . - . _ _ _ _ _ _ - -

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! a. TED Presentation a

{ TED personnel presented their reinspection and evaluation programs j for safety-related seismic Category 1 as-built piping system hangers

and restraints, including:

1 (1) Reinspections/Walkdowns s

] (a) Scope of inspections

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• Prior to restart

• Post-restart (b) Criteria

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• IE Bulletin 79-14

• AFPTSS system lessons learned f (c) Organization i * Composition

[ * Procedures

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j (d) Status j * Results

* Schedule

) (2) Engineering Review and Evaluations

] (a) Evaluation Results

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• Methodology (cumulative effect as applicable)

• SAR design basis f (b) Modification / Rework (c) NCR disposition and operability evaluation schedules

• Prior to restart

• Post-restart (3) Exemptions from Reinspection

The following number of hangers were exempted from the TED

program:

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1 Exemption Affected N System Justification of Hangers

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Low Pressure Infection High radiation 10 Auxiliary Feedwater Inaccessible 1 i

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! Exemption Affected N System Justification of Hangers High Pressure Injection Inaccessible 1 High Pressure Injection Insulation removal 4 will affect boron water storage tank operation Containment Spray Requires scaffolding 84 to reactor contain-i ment dome i NRC Presentation The NRC RIII personnel discussed the proposed content of a Confirmatory Action Letter (CAL) delineating actions required to resolve pipe

, hanger NCRs issued as a result of the reinspection program and to resolve the Facility Change Request system deficiencies identified

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during a previous RIII inspection (Report No. 50-346/85031). RIII personnel discussed the CAL action items to be completed prior to restart, after restart and prior to the end of the next plant i refueling outag The CAL No. RIII-85-13 was issued on October 17,  ;

1985 (Attachment 1). Review of TED NCR Evaluation

, On October 10, 1985, the NRC inspector selected a number of NCRs for

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review to determine the adequacy of the NCR evaluations conducted by site TED personnel. The hanger deficiencies contained in these NCRs were determined by TED to be acceptable without hardware adjustment or modification l Hanger N l l

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NCR No. l (Load in lb l l l (System) and Direction) Nonconformance(s) Inspector's Comments i 85-0148 l 33B-FCB-2-H1 l * Missing lock nut l * Acceptable j (LPI/CF) l (23,477 Fx) l * Staked threads l * Acceptable l l * "S" dimension on clamp l * Acceptable "S" is

! l l 2 1/8" strut side; I 1 11/16". TED l l 1 9/16" other side l disposition was l l l not justifie j i l * Clamp twisted 1/4" l * Unacceptable l l off center and bound l misalignment l  ! against rod l 1 l l l 85-0155 l 33C-CCB-2-H44 l * Less clearance l * Acceptable (HPI) l (981 Fy & l l l 219 Fz) l l

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,8-- r -- - . - - - - ,,- ,-, , ,,--.r-- ,,c., ,a--- r- ..,v.~< ., , , - - , - -,,-,vv,-,,,

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l Hanger N l l NCR No. l (Load in lb l l Uy_ stem) and Direction) Nonconformance(s) Inspector's Comments 85-0232 l 33C-HCC-124-H4 l * Spacers found between l * TED Calculation (HPI) l (400 Fx) I baseplate and wall at l No. C-ME-52.01-016, l l bolt locations l dated 9/30/85 was l l l acceptable l l * Weld deficiencies l l l 1 85-0314 1 33C-CCB-2-H11 1 * Welding deviated from l * TED Calculation (HPI) l (136 Fy & l design l No. C-ME-52.01-018, l 181 Fz) I * Concrete expansion i dated 9/30/85 was l l anchors (CEAs) - shell l acceptable l l type installed, design l 1 l calls for wedge typ l I I I 85-0366 l 33C-HCC-91-H10 l * Welding deviated from i e Acceptable (HPI) l (500 Fy) I design l l l * Square nut installed, I * Acceptable l I design calls for hex l l l nu l I I I

85-0446 1 33B-GCB-10-H13 i * Hissing lock nut l * Acceptable (LPI) l (580 Fx) l * Staked threaJs l * Acceptable l l * Welding deviated from l * Acceptable -

l l design l Deficient design l l l (3/16" fillet weld l l l on side of pipe l l l stanchion saddle l l l crossing pipe)

On October 23, 1985, the NRC inspector met with TED personnel to discuss the above findings. The following agreements resulted from this meeting: NCR No. 85-0148 should not have been dispositioned "Use-As-Is."

The NCR was subsequently revised to require rework on the clamp spacer and to correct the misalignment problem. Several other NCRs required similar revisio NCR No. 85-0446 was dispositioned properly by TE However, TED agreed that one of the issues ir.volved incorrect welding design or drafting errors / omissions, and that they would track any similar deficiencies and develop a trend analysi The NRC inspector stated that he considered the TED followup actions to be acceptable. Further review of the TED evaluation of NCRs will be conducted by RIII during subsequent inspection )

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6. Piping Dimensional Verification On October 23, 1985, the NRC inspector selected portions of the following piping systems for dimensional verification:

Outside the Containment

• Decay heat (DH) pump No. 1-2 suction and discharge

• High pressure injection (HPI) pump No. 1-2 suction and discharge

• Containment spray (CS) pump No. 1-2 suction and discharge Inside the Containment

• Steam generator drain (SGD)

• Core flooding (CF) piping connecting to tank No. 1-2

• HPI piping from penetration No. 20

• HPI piping from penetration No. 50 The NRC inspector findings were as follows: " DH Pump Discharge (dimensions were shown on Hanger Location (HL) isometric drawing HL-233F, Revision 0, dated November 25, 1981).

Eleven dimensions were measure Five minor dimensional deviations (ranging from 1/8" to 1 1/4") were identifie " DH Pump Suction (HL-2338, Revision 0, dated November 25, 1981). Six dimensions were measured. Two minor dimensional deviations (1/4" and 1") were identified, " HPI Pump Discharge (HL-2330, Revision 0, dated November 25, 1981). Eleven dimensions were measured. Seven dimensional deviations (ranging from 1/4" to 4 1/4") were identifie " HPI Pump Suction (HL-2338, Revision 0, dated November 25, 1981). Seven dimensions were measured. Seven minor dimensional deviations (ranging from 1/16" to 1 1/2") were identifie " CS Pump Discharge (HL-2340, Revision 1, dated August 7, 1984). Four dimensions were measured. One minor dimensional deviation of 1/2" was identifie " and 10" CS Pump Suction (HL-233B, Revision 0, dated November 25, 1981). Nine dimensions were measured. Seven dimensional deviations (ranging from 1/16" to 3 5/16") were identified, " SGO (HL-207A, Revision 0, dated July 10, 1981 and DCN-HL-207A, dated February 24, 1982). Eleven dimensions were measured. Six minor dimensional deviations (ranging from 1/4" to 5/8") were identifie " CF (HL-234A, Revision 0, dated November 25,1981). Thirteen dimensions were measure Eleven dimensional deviations (ranging from 1/8" to 3 7/16") were identifie _ _ _ _

. /2" HPI from Penetration No. 20 (HL-233E, Revision 0, dated November 25,1981). One dimension was measured. A minor dimensional deviation of 1/4" was identified. Some restraint locations were not shown on HL-233E (See Paragraph 7 for discussion.) /2" HPI from Penetration No. 50 (HL-233E, Revision 0, dated November 25, 1981). Four dimensions were measure Four dimensional deviations (ranging from 1/4" to 4 1/4") were identifie Some restraint locations were not shown on HL-233E (See Paragraph 7 for discussion).

The dimensional deviations were checked against the following procedures for acceptability:

• For support locations, the NRC inspector used TED IP-M-002,

"The Piping Support Inspection and Verification Program:

Verification of Support Location and Quantity," Revision 0, dated October 16, 198 * For piping components other than supports, the NRC inspector used Bechtel Power Corporation PDP-2, " Inspection Procedure for As-Built Configuration of Nuclear Safety-Related Piping Components IE Bulletin 79-14," Revision 4, dated May 6, 198 With the exception one dimensional deviation of 4 1/4" described in Item j.above, all (a total of 77) dimensions met the engineering acceptance criteria. In parallel with the NRC inspector's effort, TED also recently conducted piping dimensional verification inspection A number of NCRs were issued to document the deviation TED personnel stated that an evaluation of all findings will be performed prior to plant restar . Design Concerns In conjunction with Paragraphs 6.i and 6.j, piping dimensions between (1) containment penetration anchors and pipe whip restraints (WR),

(2) WRs and seismic restraints, and (3) two WRs were not shown on the HL drawings. The WRs observed during the inspection were of the rigid type which act exactly like seismic restraints. The piping stress analysis that take into account these WRs, the modeling of containment penetration anchors (located in wall recesses), and the completeness of HL drawings will be further reviewed during followup inspection. This '

is an unresolved item (346/85033-01).

8. Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. An unresolved item disclosed during this l

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inspection is discussed in Paragraph i

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O 9. Exit Interview The Region III inspector met with licensee representative (denoted in Paragraph 1) at the conclusion of the inspection on October 24, 198 The inspector sum:narized the scope and findings of the inspectio The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee representatives did not identify any such documents / processes as proprietar ,

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OCT 171985 CONFIRMATORY ACTION LETTER Docket No. 50-346 CAL RIII-85-13 Toledo Edison Company ATTN: Mr. Joe Williams, J Senior Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:

This letter confims the matters discussed during a meeting at the Davis-Besse site on October 9,1985, between Mr. Carl J. Paperiello and others of this office and you and others of your staff and a subsequent telephone discussion between Mr. J. Harrison of my staff and Mr. D. Wuokko of your staff on October 16, 1985, relating to piping systems support inspections /walkdowns and resulting engineering evaluations and corrective actions. The supports covered under this effort are those located on nuclear safety-related and seismic Category 1 piping systems within the scope of IE Bulletin 79-1 With regard to the matters discussed, we understand that you plan to accomplish the following: Phase 1 - Prior to Restart Actions (1) Complete inspections /walkdowns utilizing Toledo Edison Company (TED) procedures on the piping system supports identified in Item 1.b and all other safety-related piping system supports inside containment not listed in Item 1.b and issue nonconformance reports (NCRs) as appropriat (2) Resolve any resulting NCRs for those piping system supports listed in Item 1.b including the completion of any necessary corrective actions to achieve piping system operability based on FSAR ccmitments/IE Bulletin 79-14 interim allowable stresse (3) Screen any resulting NCRs for safety-related piping system supports inside containment not listed in Item 1.b and resolve those NCRs that are detemined to be significant relative to system operabilit (4) Complete and close engineering evaluations for all open Facility Change Requests (FCRs) that relate to completed modifications which could impact piping system operability listed in Item p}D(p>, ^^wnwd p q - ..

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Toledo Edison Company 2 OCT 171985 i

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(5) From the results obtained from actions delineated in Items 1.a.(2) and 1.a.(3), provide a basis for not perfoming inspections /walkdowns and resolution of resulting NCRs for all safety-related piping system supports not listed in Item Systems (1) Outside Containment:

- High Pressure Injection

- Low Pressure Injection / Decay Heat Removal

- Auxiliary Feedwater*

- Auxiliary Feedwater Turbine Steam Supply *

(2) Inside Containment:

- High Pressure Injection

- Low Pressure Injection / Decay Heat Removal

- Auxiliary Feedwater*

- Containment Spray (accessible portion)

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Core Flood

- Hydrogen Dilution

- Pressurizer Relief

• The results of reviews and engineering evaluations for these systems do not have to be considered when detemining the operability basis (see Item 1.a.(5)) of safety-related piping systems not listed in 1.b.(1)and 1.b.(2) abov . Phase II -

After Restart Complete inspections /walkdowns utilizing TED procedures on all safety-related piping system supports outside containment not listed in Item 1.b and issue NCRs as appropriat Resolve all outstanding NCRs issued as a result of the inspections /

walkdowns on all safety-related piping system supports including any necessary corrective actions relating to system operability based on FSAR comitments/IE Bulletin 79-14 interim allowable stresses. All NCR evaluations and corrective actions will be completed as soon as reasonably possible and comply with applicable action statements in the Technical Specifications, including prompt reporting, Complete and close engineering evaluations for all open FCRs that are related to piping system modifications completed as of the date of this letter, which impact the operability of all safety-related piping systems.

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Toledo Edison Company 3 OCT I 71985 Phase III - By The End Of The Next Refueling Outage Restore ell safety-related piping systems to FSAR connitment If TED determines that specific supports should be exempted from inspection / evaluation based on adverse location; e.g., high radiation areas, inaccessability, etc., TED shall request such exemptions for these supports from Region III and provide the bases for the exemption Please advise us immediately if your understanding of these items differs from that set forth abov

Sincerely, James G. Keppler Regional Administrator cc: L. Storz, Plant Manager DCS/RSB(RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health E. L. Jordan, IE A. W. DeAgazio NRR

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