IR 05000369/1978035

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IE Insp Rept 50-369/78-35 on 781024-27.No Noncompliance Noted.Major Areas Inspected:Test Program for Safety Related Piping Support & Restraint Sys & Review of Draft Tech Specs
ML19259A615
Person / Time
Site: McGuire Duke Energy icon.png
Issue date: 11/28/1978
From: Cottle W, Robert Lewis, Whitner H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19259A612 List:
References
50-369-78-35, NUDOCS 7901080216
Download: ML19259A615 (14)


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UNITED st ATEs

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ATL ANT A. GEORGI A 30303 o

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50-369/78-35 Docket No..

50-369 License No.. CPPR-C3

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Licensee: Duke Power Company P. O. Box 2178 422 South Church Street Charlotte, North Carolina 28242 Facility Name: McGuire Nuclear Station Inspection at: McGuire Site, Cornelius, North Carolina and ASLB Prehearing Conference at Charlotte, North Carolina Inspection conducted: October 24-27, 1978 Inspectors:

W. T. Cottle H. L. Whitener (October 25-27, 1978)

E. H. Brooks (October 25-27, 1978)

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Approved by.

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Date R. C. Lewis, Chief Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch Inspection Summary Inspection on October 24-27, 1978 (Report No. 50-369/78-35)

Areas Inspected: Routine, unannounced inspection of test program for safety related piping support and restraint systems; review of draft Technical Specifications; plant program for nonroutine event review; conformance to

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Title 10 requirements; and readiness of f acility for issuance of an operating license. The inspection involved 74 inspector-hours on site by three b'RC inspectors.

Results: Within the areas inspected, no items of noncompliance or deviations were identi fied.

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RII Report No. 50-369/78-35 1-1 DETAILS I Prepared by:

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<pn W. T. Cottle, Reactor Inspectot Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Inspection: October 24-27, 1978 Reviewed by:f.C.

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R. C. Lewis, Chief Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch 1.

Persons Contacted

  • M. McIntosh, Station Manager
  • D. Rains, Superintendent of Maintenance
  • T. McConnell, Superintendent of Technical Services
  • H. Sample, Technical Services Engineer
  • D. Franks, QA Engineer
  • G. Gilbert, Operating Engineer
  • H. 4'allace, Construction QA Engineer A. Sudduth, Mechanical Maintenance Engineer T. Meadows, Mechanical Maintenance Engineer M. Getty, Startup Coordinator D. Bradshaw, Operating Engineer R. Leonard, Associate Health Physicist D. McGinnis, Health Physics Supervisor J. Mode, Counting Room Supervisor G. Copp, Project and Licensing Engineer

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T. Keane, Station Health Physicist The inspector also interviewed several other licensee employees including technical support and operations personnel.

  • Present during the exit interview on October 27, 1978.

2.

Licensee Action on Previous Inspection Findings Not inspected.

3.

Unresolved Items No new unresolved items were identified.

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RII Report No. 50-369/78-35 I-2 4.

Management Inte rview A meeting was held at the conclusion of the inspection on October 27, 1978, with the Station Manager and members of his staff as denoted in paragraph 1.

The inspectors summatized the scope and findings of the inspection.

Licensee personnel outlined the status of piping support and restraint installation for Integrated Hot Functional Testidg (HFT) scheduled for November 1978.

Due to late material deliveries, approximately forty (40) safety-related hydraulic snubbers and an as yet undete rmined number of hangers and restraints will not be installed prior to com-mencing heatup for HFT. Since these supports and restraints will not be tested during the HFT thermal expansion and restraint program, committed to in the FSAR, the licensee plans to enter into HTT as scheduled with a modified test program as described in paragraph 5.

5.

Facility Readiness for Operating License Issuance The inspector reviewed the construction status and the status of the testing program for preliminary identification of outstanding items in these areas which could affect the Region II finding on facility readiness for issuance of an operating license. Specific areas examined were as follows:

Completion status of preoperational testing committed to in the a.

FSAR.

b.

Status of development of startup test procedures.

c.

Status of turnover of systems from the Construction Department to the Steam Production Department.

d.

Licensee's methodology for identification and tracking of con-struction punchlist items, status of system turnovers, formal acceptance of systems by the Steam Production Department, and system performance deficiencies identified in the testing program.

The inspector discussed the provisions of la CFR 50.57 with the Plant Manager and the Technical Services Engineer.

The discussion was primarily concerned with the requirement for identification of plant conditions which may require a license provision and the program which the inspector will follow to formulate the Region 11 findinF that the facility has been substantially completed in conformity with the construction permit and application.

There were no items of noncompliance or deviations identifie.

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RII Report No. 50-369/78-35 I-3 As noted in paragraph 4, the licensee has proposed a modification to the HFT thermal expansion and restraint progran described in the FSAP.,

Instead of completing all the rmal expansion and restraint testing during HTT, those supports and hangers not installed prior to HFT will be tested on the initial plant heatup prior to criticality. Licensee's plans to implement this test program modification are as follows:

a.

Licensee's Design Engineering has performed an evaluation of those supports / hangers which must be installed to insure adequate system support and to accommodate ar.ticipated transients during HFT.

b.

For those systems involved in the HFT thermal expansion and restraint program:

(1) All semi-final hangers will be installed to the maximum extent possible.

Where necessary, temporary supports will be installed in the same approximate location as missing semi-final supports. Any temporary supports will be designed with equivalent load and direction capability as the missing permanent support.

(2) All temporary erection supports (not installed to replace a permanent support) will be removed.

(3) All variable spring supports will be installed.

Teepora ry springs may be used.

Construction will identify to Design the characteristics of any temporary springs utilized.

(4) Design Engineering will survey any missing snubbers and take appropriate thermal movement measurements to qualify the results for the expansion program.

Measurements will be taken in both the cold and hot conditions and an evaluation of total displacement performed.

c.

On system heatup prior to initial criticality, all snubbers, supports and hangers not tested in their permanent configuration during HTT will be monitored and evaluated with the same accep-tance criteria as utilized in the HFT program.

Licensee's onsite safety review committee will perform an evalea-tion equivalent to 10 CFR 50.59 on this test program modification prior to implementation.

6.

Review of Draft Technical Specifications The inspector continued a review of the draf t Technical Specifications, Appendix A.

The area of primary concern was the clarity of the Limiting

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RII Report No. 50-369/78-35 I-4 Conditions for Operation (LCO's), Surveillance Requirements, Design Features, and Administrative Controls.

Several items having the potential for misinterpretation were discussed with operations personnel to obtain their views as to the requirements of the specific LCO's.

The inspector discussed general topics in the Technical Specifications with the licensee's Technical Services Engineer. Licensee was encouraged to bring to the inspector's attention specific areas which were felt to be ambiguous.

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7.

Plant Program for Nonroutine Event Review The inspector reviewed licensee's program for the review of off-normal operating events and maintenance activities for identification of safety-related events or violations of LCO requirements.

Specific areas examined were as follows:

a.

Assignment of responsibilities for the prompt review and evalua-tion of of f normal operating events.

b.

Assignment of responsibilities for the prompt review of mainte-nance and testing activities for i entification of violations of LCO requirements.

c.

Assignment of responsibilities for reporting safety-related operating events internally and to the NRC.

d.

Assignment of responsibilities for completion of corrective actions relating to safety-related operating events.

Items a, e and d were found to be addressed in the combination of administrative controls set forth in the following Station Directives:

a.

S/D 2.8.1 Reporting Requirements b.

S/D 3.1.3 Actions to take in case of exceeding of limits c.

S/D 3.1.4 Authority and Responsibilities of Licensed Operators and Licensed Senior Operators d.

S/D 3.1.5 Activities Af fecting Station Operations or Operating Indicators e.

S/D 3.1.6 Notifying Management of Operating Conditions f.

S/D 3.1.13 Unit Supervisor's Logbook g.

S/D 3.2.1 Identifying, Scheduling and Performance of Periodic Testing b.

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'.0 Control of the Maintenance Program For Item b, no controls have been established to insure that licensed operations shif t personnel are promptly notified in the event a safety-related surveillance test fails to meet the acceptance criteria. The

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Rll Report No. 50-369/78-35 I-5 inspector discussed this item with the Technical Services Engineer and the Maintenance Superintendent. They agreed that the establishment of some type of administrative guidance in this area would be taken under consideration. This item is designated as an open item (78-35-06) and will be followed up by the inspector on subsequent inspections.

There were no items of noncompliance or deviations identified.

8.

Conformance with Title 10 Requirements

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a.

10 CFR 20 The inspector reviewed licensee's activities concerning the storage of licensed material in unrestricted areas against the requirements set forth in 10 CFR 20.207. Licensee has designated the fuel two plant areas as restricted areas at this time

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storage area and the instrument calibration room.

All special nuclear material received under licensee's Part 70 license is required to be stored in the fuel storage area. Licensed material received under licensee's Part 30 license is normally stored in the instrument calibration room but may be stored in other plant areas.

A review of the Source Use Logbook indicated that in some instances licensed sources were being stored in the Auxilia ry Building Counting Room.

An examination of the method of storage and the controls in effect in the Counting Room indicated that storage ar.d utilization of licensed material in this area appeared to satisfied the requirements of 10 CFR 20.207. The sources were either under constant attendance or were secured in storage in all instances observed by the inspector. In reviewing the Source Use Logbook, the inspector found four incorrect entries - two sources (non-licensed) logged out to the wrong storage area and two improperly dated entries (non-licensed sources). The inspector discussed the errors found with the Counting Room Supervisor, who took immediate corrective action, and with the Technical Superin-tendent.

The entries involved non-licensed material and were the only errors noted out of approxim ur one hundred entries checked. The inspector had no further q.

ns.

The inspector reviewed licensee's procedures for " Receipt and Shipment of Radioactive Materials" (HP/0/B/1004-01) and " Health Physics Source Handling" (HP/0/B/1004-02).

Comments on the actual practice of implementing some of the more restrictive requirements of these procedures were discussed with the Technical Superintendent. These comments were concerned with the licensee's imposed requirements which appeared to be in excess of the regula-tory requirements and were discussed to insure that the inspector correctly understood licensee's commitment *

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RIJ Report No. 50-369/78-35 I-6 No items of noncampliance or deviations were identified.

b.

10 CFR 50 The inspector reviewed licensee's actions with respect to the evaluation of design problems discovered during the preoperational test program as possible design deficiencies under 10 CFR 50.55(e).

Station Directive 4.4.0 " Processing Design Changes" defines the areas of responsibilities and requirements concerning the adminis-tration and processing of design changes prior to unit licensing.

This procedure req 9 ires that design changes initiated by the Steam Production Department be documented on a Nuclear Station Problem Report (NPR). The NPR ir reviewed by a Group Superinten-dent, Technical Services Engineer and the Plant Manager in all Safety Review Committee cases.

For all safety-related NPR's, a

review is also required. Though not specifically required as a part of each of these review steps, at each step a determination that the problem constitutes a potential 10 CFR 50.55(e) design deficiency can be made. At this point, Design Engineering would be appraised of the problem and a formal determination made.

The inspector reviewed a sample of fifteen NPR's which had been initiated on Unit I systems.

These NPR's were reviewed against the criteria of 10 CFR 50.55(e) for reporting requirements. Of the NPR's examined, the inspector identified one, NPR MC-1-180, as being reportable. The inspector then verified, by a review of Region Il records, that the item identified in NPR MC-1-180 had been reported under the requirements of 10 CFR 50.55(e) as Duke Construction Deficiency Report No. CD-369-370/77-2.

No items of noncompliance or deviations were identified.

9.

Atomic Safety and Licensing Board (ASLB) Frehearing Conference The inspector attended the ASLB prehearing conference on a proposed amendment to the special nuclear material license for the McGuire Nuclear Station.

The amendment would authorize Duke Power Company to trancport spent nuclear fuel from the 0.conee Nuclear Station for storage in the spent fuel pool at the McGuire Nuclear Station.

The conference was held on October 24, 1978, in the Charlotte-Mecklentirg Education Center in Charlotte, North Carolina.

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RII Rpt. No. 50-369/78-35 II-1 DETAILS II Prepared by:

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H. L. Whitener, Reactor /] Inspector Date Nuclear Support Sectiob'No. 1 Reactor erations and Nuclear Sup Branch dab l'b f ?{

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E. H. Bro 5ks, Reactor Inspe or Nuclear Support Section No. 1 Reactor Operations and Nuc ear Support Br ech Dates of Inspection:

ctober 24-27, 1978 Reviewed by:

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g R. D.YMa'Hin, Chief ate Nuclear Support Section No. 1 Reactor Operations and Nuclear Support Branch 1.

Persons Contacted

  • M. McIntosh, Plant Manager
  • H. Sample, Technical Services Engineer
  • D. Rains, Superintendent of Maintenance A. Sudduth, Assistant Engineer, Mechanical Maintenance T. Meadows, Junior Engineer, Mechanical Maintenance M. Eudy, QA Technician, Construction J. McEntire, Construction Maintenance E. Estep, Associate Engineer, Technical Services D. Lampke, Junior Engineer, Technical Services
  • H. Wallace, Har.ger Group, Construction
  • Denotes those present at the Exit Interview.

2.

Licensee Action on Previous Inspection Findings None reviewed.

3.

Unresolved Items

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N oe identified during this inspection.

4.

Exit Interview Areas ia=pected and the inspection findings were discussed with Mr.

McIntosh and members of his staff on October 27, 197 *

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RII Rpt. No. 50-369/78-35 II-2 5.

Snubber Testing and Rebuilding Programs In response to a nonconformance report (No. 6273), which identified the unacceptable condition of many installed hydraulic snubbers, the licensee developed a testing and rebuilding program to functionally test, recalibrate, and repair snubbers as needed.

Approximately 700 snut' ers, identified as unacceptable (mostly due to improper storage, handling or painting), have been processed through this program in the last five months. The inspectors witnessed the purge and calibration of lockup and bleed rate and reviewed construction procedures to verify that adequate procedures and controls were established and implemented.

Procedures were reviewed as follows:

558 Hydraulic Shock Suppressor Purging and Calibration

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Procedure 559 Repair Procedure for Hydraulic Shock Suppressors

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561 Installation and Cold Setting of Hydraulic Snubbers

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562 Purging and Calibration of Hydraulic Snubbers Not

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Stored in Accordance with Construction Procedure 555 563 Method for Installation, Relocation, and Reorien-

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tation of Snubber Reservoirs 564 Removal of Pipe Hangers

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566 Hangers Required for System Testing

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555 Storage and Handling of Hydraulic Snubbers

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1206.00-4.0 Procurement Specifications

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Based upon observations and review of procedurc:, the inspectors had no questions concerning the functional testing of the snubbers, and found the procedures generally adequate.

However, some concerns were identified, and these were discussed with li,censee personnel as follows:

a.

Identification of Seal Material The type of seal material in the snubbers was not defined in Specification 1206.00-4.0.

Further documentation of the seal material could not be produced prior to the conclusion of this inspection. NRC requirements relative to seal material (see paragraph 7.c.) were discussed with Steam Production Department (SPD) saintenance personnel and identified for further inspection (369/78-35-01).

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RII Rpt. No. 50-369/78-35 11-3

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b.

Lockup Velocity and Bleed Rate Testing and calibration of snubbers is currently performed to fixed values of Grinnell production standards.

These values appear adequate for preoperational heatup, but are over restrictive for an operating plant.

NRC requirements for establishing acceptance criteria for lockup velocity and bleed rate were discussed with SPD maintenance personnel (see paragraph 7.d), and these were identified for further -inspection (369/78-35- 02).

Calibration and Test Records c.

Procedures 558 and 559 require certification data sheets which doenrent the testing and calibration of snubbers identified in Nonconformance Item 6273.

In addition to these, approximately 500 new snubbers were received and properly stored, in accordance with Procedure 555, and will be installed without further testing.

Documentation certifying testing and calibration of these snubbers to appropriate standards by the manufacturer could not be produced prior to the conclusion of this inspection. This matter was discussed with construction personnel, and was identified for further review (369/78-35-03).

d.

Items Identified Requiring Further IE Evaluation (1) Field Cuts and Welding In some instances, snubber extension rods have been cut and welded during installation fit up.

The inspectors advised the licensee that appropriate requirements or tests for strength would be reviewed with cognizant IE construction specialists and discussed at a future inspection (369/78-35-04).

(2) Inaccessible Snubbers During the inspection, it was determined that many snubbers are physically impossible to reach,due to piping runs or equipment installations made subsequent to snubber instal-lation (the exact number was not known, but may be as large as 100). Visual examination can be performed from a distance, but actual access to check tightness of fittings or bolts, to replace fluid, or to remove for functional IE will testing would require removal of existing piping.

study the potential impact of this condition on operational safety and discuss this matter at a future inspection (369/78-35-05).

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RII Rpt. No. 50-369/78-35 11-4

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6.

Status of Supports and Restraints for Initial Heatup The inspectors were informed that final installation of supports and restraints will no: :- complete at the time of initial heatup.

Some temporary load bearit g supports will be installed and some seismic restraints will not ' e in place. The licensee stated thau (1) design engineering will identify the load bearing supports and restraints necessary for initial heatup, (2) installation of the required supports and restraints will be verified prior to beatup, (3)

temporary and missing supports and restraints will be identified and tracked to verify final installation per design, (4) during heatup after fuel loading but prior to initiel criticality, system expansion and vibration re-test will be made to verify that no adverse effects occur as a result of changes made subsequent to initial heatup (see Details I for further detail on this matter).

7.

Technical Specifications / Acceptance Criteria /NRC Positions The inspectors discussed NRC positions relative to requirements for establishing the technical basis for snubber inspection and testing acceptance criteria and the intent of the Technical Specifications with the licensee as follows:

a.

Accessible / Inaccessible The inspectors discussed the option of separating the snubbers into accessible and inaccessible categories for the purpose of visual inspection. The licensee was advised that the initial inspection, four to six months after initial critical, is a 100 percent inspection. Subsequent inspections can be separated into accessible and inaccessible categories, and inspected at the frequencies dictated by the inspection findings and Technical Specification frequency table. With 1200 safety-related snubbers, approximately 800 accessible and 400 inaccessible, this approach may avoid unnecessary plant shutdown to meet inspection frequency requirements in the Technical Specifications.

b.

Representative Sample

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The inspector advised the licensee that the term, " Representative sample," as stated in the Technical Specification, requires that the licensee evaluate the conditions of his plant to obtain as nearly as possible a selection of suppressors for functional testing which is representative of all plant conditions.

Written guidelines should be developed which may include such factors as type, size, environment, vibrations, etc. These guidelines will be needed for the selection of a test sample at the first refueling outag *

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RII Rpt. No. 50-369/78-35 II-5

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c.

Seal Material The inspector discussed the NRC position that an expected life-time for seal material other than ethylene propylene (EP) must be established on the basis of an engineering evaluation which considers the effect of hydraulic fluid, operating temperature, moisture and radiation environment on the material, and the compression set characteristics of the material.

Other options available to the licensee were identified as, (1) install EP material in the suppressors and inspect in accordance with the Technical Specification frequencies, (2) replace the seals with the same non-EP material, and establish the material lifetime as that period of time which the suppressors have operated in their environment without adverse effects on the seals and inspect in accordance with the Technical Specification frequencies, (3) inspect the suppressors with non-EP seal material on a 31-day frequency.

d.

Procedure Acceptance Criteria The inspector discussed the acceptance criteria needed for an adequate inspection and testing procedure, and pointed out that the technical basis for the acceptance criteria must be documented.

Areas discussed for procedures on on operating plant included the following:

(1) Visual Inspection (a) Determine the minimum fluid level for an operable snubber.

(b) Determine the limits for piston rod position for operability and verify initially for both hot and cold position.

(c) Delineate all items to be inspected and provide check off on data sheet to ensure a uniform inspection and to document results.

(d) Record as found - as left data for fluid levels.

Items (a) and (b) above must be established through the vendor and documented.

(2) Functional Test (a) Establish the acceptable range for lockup velocity and bleed rate. This requires that the Design Engineering Group determine acceptable velocities on the basis of the piping design and seismic analysi.

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RII Rpt. No. 50-369/78-35 II-6

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(b) Determine the temperature correction factor to adjust seasured lockup and bleed velocities from the ambient test condition to operating temperature and apply this correction to test data.

8.

Inspection of Installed Supports and Restraints The inspectors toured the plant with licensee personnel, and examined a number of installed scabbers, adjustable supports, fixed supports, and associated hardware. Significant deficiencies were identified and discussed with licensee personnel.

It was determined that although some of the deficient snubbers had been through the re-built program, none had received the final QC inspection and approval. Prior to leaving the site, the inspectors gave the licensee a listing of the problems identified for his use in implementing corrective actions.

The licensee's generic corrective action will be reviewed at a future inspection (369/78-35-06). The nature of the problems identified are indicated below:

Identification numbers not adequate (more than ene numoer and a.

system descriptor evident).

b.

Missing reservoirs.

Missing grease fittings (not required, but open to accumulate c.

dirt).

d.

Lock pins / plates not removed (hangers).

e.

Incorrect orientation of snubber reservoirs.

f.

Oil leaks.

g.

Rigid snubber (say be in lockup).

h.

No lubricated surface on some sliding restraints.

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CF 128 had tag indicating, "no sketch."

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Locknuts loose, snubbers would rotate.'.

k.

No shear lugs on pipe clamp on code valve atmospheric discharge piping.

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Piston rod not tight in elevi =

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RI: Rpt. No. 50-369/78-35 II-7

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Extension rod appeared bent.

Feed line from reservoir to cylinder located at top of reservoir.

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Reservoir below control block (poor practice).

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Paint on piston rod.

9.

System Expansion and Vibration Tests Procedures TP/1/A/1'50/07, Reactor Coolant System Thermal Expansion and Restraint Test, TP/1/A/1150/08, Thermal Expansion Testing on ASME Code Piping (draft), and TP/1/A/1200/21, Piping Systems Operation Vibration Measurement, were reviewed during this inspection. The inspectors noted that inspection for interference at specific tempera-ture plateatic is defined and a table of predicted movement for specific points on the Reactor Coolant System piping is provided. The inspectors advised the licensee that this review was preliminary and a detailed review of procedure reouirements versus program commitments in FSAR Sections 14, 3.9.1.1, 3.3.1.2, Supplements 413.16 and 413.23 and the SER would be performed at the Regional Of fice.

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