ML16161A875
| ML16161A875 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/10/1987 |
| From: | Blake J, Chou R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16161A873 | List: |
| References | |
| 50-269-87-31, 50-270-87-31, 50-287-87-31, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8709240339 | |
| Download: ML16161A875 (11) | |
See also: IR 05000269/1987031
Text
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RE;(,ZUNITED
STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-269/87-31, 50-270/87-31, and 50-287/87-31
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270,
License Nos.: DPR-38, DPR-47, and
and 50-287
Facility Name:
Oconee 1, 2, and 3
Inspection Conducted:
July 27-31, 1987 at Oconee Nuclear Station
August 3-7, 1987 at Duke General Office, Charlotte, N.C.
Inspector:
C c
q-! D
R.
Date Signed
Approved by:
J. lake, Chief
Date Signed
- erials and Processes Section
Division of Reactor Safety
SUMMARY
Scope: This routine, announced inspection was in the areas of pipe support
base plate designs using concrete expansion anchor bolts (IBE 79-02)
and
seismic analysis for as-built safety-related piping systems (IEB 79-14).
Results:
Two violations were identified.
187O9240339 870917
ADOCK 05CIO0269
G
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- S. B. Hager, Chief Engineer, Civil Engineering Division
- M. J. Tuckman, Station Manager
- C. L. Ray, Principal; Engineer, Civil Engineering Division
- R. J. Brackett, Station QA Manager
- B. W. Carney, Station Maintenance Services Manager
- P. F. Guill, Supervisor, Licensing Engineer
F. Owen, Shift Supervisor and Regulatory Compliance
B. Leatherwoood, Project Engineer
P. Earnhardt, Production Specialist III
W. Davis, Engineering Supervisor, CMD
S. Crews, Supervising Design Engineer
- J.
McLean, Design Engineer I
- T. C. Mathews, Compliance Specialist
- M. R. Hemphill, QA Engineer I
- P.
J. North, Licensing, Assistant Engineer
D. Carpenter, QC Level II, Mechanic Inspector
D. Osborn, QC Level II, Mechanic Inspector
Other licensee employees contacted included engineers,
technicians,
mechanics, and office personnel.
NRC Resident Inspectors
- P. H. Skinner, Senior Resident Inspector
- L. D. Wert, Resident Inspector
- Attended exit interview on July 31, 1987
- Attended exit interview on August 7, 1987
2.
Exit Interview
The inspection scope and findings were summarized on July 31 and August 7,
1987, with those persons indicated in paragraph 1 above.
The inspector
described the areas inspected and discussed in detail the inspection
findings. Dissenting comments were received from the licensee about
issuing Violation 269, 270, 287/87-31-01. The following new items were
identified during this inspection.
Violation 269, 270, 287/87-31-01, As-Built Drawing Discrepancies Compared
)s
with As-Built Conditions.
Unresolved Item 269, 270,287/87-31-02, Additional Information Required to
Evaluate Pipe Supports.
2
Inspector Followup Item 269,
270,
287/87-31-03,
Safety-Related Piping
Systems Maintenance.
Violation 287/87-31-04, Inadequate Pipe Support Qualification
The licensee did identify specification No.
OS-0027.00-00-0001,
Design
Spcification for class A, B, C, D, and F Pipe Supports and Restraints,
which was provided to Inspector, as proprietary during the exit interview.
The proprietary material is not included in this inspection report.
3.
Licensee Action on Previous Enforcement Matters
(Closed)
Unresolved
Item
287/85-31-02,
Evaluation
of
Pipe
Support/Restraint Deficiencies Identified During Inservice Inspection.
The nonconforming item reports (NCI)
were written about pipe supports as
part of the Unit 3 refueling outage inservice inspection (ISI).
Of the
83 pipe supports subject to ISI,
59 NCI's were written.
The previous
inspector reviewed these NCI Reports and disclosed that approximately 25
percent of the NCI documented discrepancies between the as-built hanger/
support drawings and the existing hanger/supports. The as-built drawings
had been prepared during field walkdown inspection preformed for the
seismic analysis of as-built safety-related piping
systems
required
by
The Inspection Report Nos. 50-287/85-31
and
59-287/85-36 documented the above problems and requested that the licensee
determine the cause of the inaccurate as-built drawings and of the
licensee's final corrective actions.
During this inspection, the
inspector identified discrepancies between the as-built drawings
and
as-built conditions.
The licensee stated that similar discrepancies were
found during ISI and documented in the above two reports. After reviewing
the information submitted for Unresolved Item 287/85-31-02 and comparing
discrepancies identified during this inspection, the inspector decided to
close-the above Unresolved Item and open Violation 269, 270, 287/87-31-01,
As-Built Drawing Discrepancies Comparing with As-Built Conditions,
see
paragraph 5.
4. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations.
One resolved item identified during this inspection is
discussed in paragraph 5.
5.
(Open) Pipe Support Base Plate Using Concrete Expansion Anchor Bolts
(IEB 79-02) and Seismic Analysis for As-Built Safety-Related Piping
Systems (IEB 79-14).
a.
Oconee Nuclear Station implemented an IEB 79-02 program which was
based on a factor of safety (FS)
of the expansion anchor bolt
obtained from tests in the field and a review of calculations. There
3
were three conditions for determining the FS.
Condition one:
FS< 2,
the supports were required to be modified immediately to bring
up FS> 4 or 5 (FS> 4 for wedge and sleeve anchors, and > 5 for shell
type anchors) to meet the operability requirements.
Those supports
were modified and completed for all three units in 1981.
Condition
two:
FS> 2 but FS< 4 or 5, the supports which met the short term
operability requirements but required modification to ensure
expansion anchor safety factors > 4 or 5 were deferred and combined
with IEB 79-14. Condition three:
FS > 4 or 5, no modifications were
required for supports. Therefore,
IEB 79-02 will be completed when
IEB 79-14 is completed in each unit.
b.
The licensee provided the summary of status for the activities on
IEB 79-02 and 79-14 for Oconee Nuclear Station.
The IEB 79-14
program resulted in the modification of approximately 5,900 out
of 8,600 supports reviewed.
There are 251 pipe supports with
modification work remaining.
(1) Unit 1
There are about 240 support modifications to be completed during
the upcoming outage scheduled to begin in early September.
(2) Units 2 and 3
Ten support modifications on Unit 2 and one support modification
on Unit 3 are not completed due to being in inaccessible areas;
new revision of drawings based on recent surveillance in areas
previously inaccessible; and new revision of drawings resulting
from nozzle load analysis. Of the supports remaining on Unit 2,
eight can be modified at the next Unit 2 outage and two are in a
high radiation area and it is unknown when these can be accessed.
The support remaining on Unit 3 is in a high radiation area and
will be modified whenever radiation levels drop to an acceptable
level.
To check the licensee walkdown performance and to see if calculations
had been revised using the walkdown information for IEB 79-02 and
79-14, the inspector selected 25 supports including gang support from
component cooling, system 55 and L.P. service water -RC pumps, system
14B, for Unit 1. The walkdown packages were called piping surveil
lance data packages which included system summary sign-off forms,
piping clearance forms,
valve data forms,
support/restraint data
forms,
support/restraint design drawings,
valve vender drawings
and piping design drawings.
Table 1 is the list of the support
partially reviewed for packages or calculations or both.
The
support calculations were also checked against stress calculations
to see if the current loads were used in support design.
4
Table 1
Review of Walkdown Packages and Calculations
Walkdown Package
Calculation
Support No.
Reviewed
Reviewed
1-53-3-0-439C-H27
/
1-55-1-0-439C-SR11
V
1-55-1-0-439A-H37
/
1-55-1-0-437B-H11
/
Gang 1 GH-RS-7172-02
/
1-55-1-0-437B-H10
/
Gang 1-GH-RS-7172-01
/
1-55-1-0-437B-H49
/
Gang 1-GH-RS-7273-01
/
1-55-1-0-437B--HSO
/
V
Gang 2-GH--RS-7374-08
V
1-55-1-0-437B-H-8
/
Gang 2-GH-RS-7374-07
1-55-1-0-437B-H7
/
1-55-1-0-437B-H1
/
1-55-1-0-437B-H16
V
1-55-1-0-437B-H19
V
RJC-14B-439B
V
1-14B-439B-DE004
/
1-14B-439B-DE007
/
1-14B-439B-DE013
V
1-14B-437B-DE023
/
NJB-14B-439C-DE032
V
1-14B-439C-DE034
V
1-14B-439C-DE035
V
5
The gang supports shown
on Table 1 were attached by the support shown
immediately above them. Those supports were found in field to have new
attachments of pipes or supports. The purpose of reviewing the gang supports
were to make sure that calculations for the gang supports had been revised to
consider new attachments found in field.
Support No.
1-14B-439C-DE032,
1-14B-439C-DE034
and 1-14B-439C-DEO35
had been superseded per Section
14.1,
Quality Assurance
Program,
Design
Engineering Department.
No
violations or deviations were identified in this area.
To review the licensee activities on IEB 79-02 and 79-14 during the past
two years, the inspector randomly selected the following 39 supports in
the area of dynamic pipe supports and component support structures that
had been QC final inspected to see if they complied with IEB 79-02 and
79-14.
The restraints were reinspected with the assistance of the
licensee's QC inspectors and engineer.
Table 2 shown the list of the
supports reinspected and the calculations reviewed.
Table 2
Supports Reinspected and Calculations Reviewed
Unit No.
Support No.
Rev. No.
Supports
Calculations
Reinspected
Comments Reviewed
1
1-03-0-551-H57
2
V
1
1-03A-1-0-400A-H38
2
V
Note 1
/
1
1-03A-1-0-400A-H46
1
/
1
1-03A-1-0-400A-H47
1
V
1
1-03A-1-0-400B-H54
1
/
V
1
1-03A-1-0-400B-H59
3
/
1
1-03A-1-0-401A-H44
3
V
1
1-03A-400A-ADM-0200
2
V/
Note 2
V
1
1-03A-401A-DE004
1
V
1
1-03A-401B-MB-0701
1
V
Note 3
/
1
1-07A-0-400A-SR1
2
V
.s
1
1-07A-0-6-0-400A-H41 7
V
Note 4
/
1
1-14B-0-436L-ASR13
1
/
Note 5
/
1
1-14B-0-436L-ASR14
1
V
Note 6
V
1
1-14B-0-444-ASR7
1
V,
6
Unit No.
Support No.
Rev. No.
Supports
Calculations
Reinspected
Comments Reviewed
1
1-14B-437B-DE023
4
V
V
1
1-14B-0-1436D-ASR22 0
V
1
1-14B-4001-LRM-0601 0
V
Note 7
/
1
1-54A-0-444-R14
1
V
2
2-01A-1-1-0-1401B-H3 6
V
2
2-01A-1-4-0-1401B
H19
1
V
V
2
2-01A-1403C-DE083
0
V/
2
2-01A-0-1403B-DE068 1
V
/
2
2-O1A-0-1403D
DE077
2
V
V
2
2-01A-4-0-1400A-H4
1
V
Note 8
V
2
2-07A-0-1400A-SR1
0
V
2
2-14B-1436D-DE003
0
V
2
2-51A-436E-FAC-2803 1
Note 8
2
2-51A-1444-WSS-2902 1
V
Note 8
3
3-07A-1400B-DE032
1
V
3
3-07A-2400A-DE010
1
V
3
3-07A-2400A-DE027
2
V
V
3
3-07A-2400A-OL-0502
1
v/
3
3-07A-0-2400A-R1
1
V
Notes 9 and 11 V
3
3-53B-2435B-DE012
1
3
3-53B-2435B-DE023
1
V
V
3
3-53B-4-2435B-H26
5
V
V
3
3-53B-4-0-2435B-H31
1
V
3
3-53B-5-0-2435B-SR38 0
V
Note 10
V
7
Notes
1. Extra lug at bottom of pipe used for the vertical support not shown
on drawing.
2. (a) 1-1/2" and 1-3/4" bolt edge distances existing in field but
Section A-A of drawing shows 2-7/8" and 3-1/8" respectively.
(b) Vertical support with 1/16" gap between the bottom of the pipe
attachment and the supporting steel.
3.
Sway Strut bent.
4. (a) 1" steel shim blocks under washer not shown on drawing.
(b) One support loose nearby (possibly loosened during work on this
support).
5. Anchor bolt spacing approximately 3" from the adjacent support
No. 1-14B-436L-WJB-1011. Appears to violate the spacing requirement.
(No ladder provided during reinspection).
6. Two rod supports for the nearby pipe (5'-6" North of this support) in
contact with this pipe.
7.
Extra welds in field at connection between top flange of Item No. 13,
TS 3"x2"xl/4" and Item No.
12,
TS 2"x2"xl/4".
8.
Wrong support tag number in field.
9. (a)
Top flange of Item No. 5, W6x2O at south end has 1/4"
gap
between it and the vertical number. Bottom flange rounded off.
(b) Weld around symbol showing drawing is wrong due to item (a)
above.
10.
Hydraulic Snubber Reservoir contacts the vertical member of support.
11.
Computer Model and Analysis (STRUDL)
used the member properties of
W6x2O for Item No.7 to qualify this support.
Actually, the member
size is W4x13 which is shown on drawing and exists in field.
The
above
restraints were partially reinspected against their
detail
drawings for configuration, identification, dimensions,
fastener/anchor installation, member size, welds, rust, maintenance,
and damage/protection. Design calculations were partially reviewed
and evaluated for thoroughness, clarity, consistency and accuracy.
The design calculations were of good quality except as noted in Note
11, Table 2. In general,
the modified portion of restraints or new
restraints were installed in accordance with design documents.
The
majority of the discrepancies noted in Table 2 were due to a lack
8
of detailed check during the walkdown inspection.
The inspector
discussed the above findings with responsible engineers at the
general office.
They stated that the licensee's walkdown inspectors
might not have used a tape to measure dimensions or ladders for
access to inaccessible areas.
The walkdown inspectors might also
have stood away from the support and compared the support configu
ration with the detail drawing and judged the support to be adequate
or not for supporting the required loads. The above statements from
the licensee's engineer were contrary to the requirements of Section
3.5, of Duke Specification
No. OS-0020.00-00-0002,
79-14 and
79-02 Pipe Support Surveillance Procedure,
which was
Attachment #1 of Oconee Nuclear Station,
Revision 1, 30-day Response from the licensee to Region II,
dated
August 1, 1979. Section 3.5.1 of the above surveillance procedure
partially states that dimensions,
gap sizes,
member sizes,
details and general physical configuration conform to the S/R Design
Drawing. Attachment #7, "Guidelines for Support Sketches"; and,
Attachment #8, "Support/Restraint Design Tolerances", in the above
surveillance procedure clearly define the requirements for the
support detail check.
The licensee's stated practice in the
walkdown
inspection to check as-built conditions violated the
surveillance procedure and the bulletin requirements.
This was a
severe program defect.
The similar discrepancies or deficiencies
to those shown on Table 2 were also found during the Inservice
Inspection,
see paragraph 3.
The Unresolved Item 287/85-31-02 is
considered closed by the opening of Violation 269, 270, 287/87-31-01
shown below.
Based on the findings and notes shown on Table 2, plus the Unresolve
Item 287/85-31-02 as stated on paragraph 3, the inspector identified
the following items:
-
(Open) Violation 269, 270, 287/87-31-01, As-Built Drawing
Discrepancies Compared with As-Built Conditions. Oconee Nuclear
Station Spec. No. OS-0020.00-00-0002
required the support
details to be checked as stated above and documentation of
discrepancies for reevaluation or reanalysis.
Discrepancies
identified below indicated that portions of the supports were
not installed and verified in accordance with the design drawings.
-
Support No.
1-03A-1-0-400A-H38 had a lug at the bottom of the
pipe for the vertical support. The lug was not shown on drawing.
-
Support
No.
1-03A-400A-ADM-0200
had 1-1/2"
and 1-3/4"
bolt
edge distances existing in field but Sections A-A of drawing
showed 2-7/8" and 3-1/8," respectively, (This exceeded the 1"
tolerance allowed in Section 8.0, Attachment
No. 8 of Spec.
No. OS-0020.00-00-0002.
This vertical support also had a 1/16"
gap between the bottom of the pipe attachment and the supporting
steel.
10
9
-
Support No. 1-03A-401B-MB-0701 had a bent sway strut.
-
Support No. 1-14B-4001-LRM-0601 had extra welds in field at the
connections between the top flange of Item No. 13 (TS 3"x2"x1/4")
and Item No. 12 (TS 2"x2"x1/4").
-
Support No. 3-07A-0-2400A-R1
had a 1/4" gap between the south
end of the top flange of Item No.
5, (W6x20)
and the vertical
member. The bottom flange at the same end was rounded off.
All the examples indicated above plus the itmes identified in
Unresolved Item 287/85-31-02 constitute a violation of 10 CFR 50,
Appendix B, Criterion X and is identified as a Violation 269,
270,
287/87-31-01.
-
(Open) Unresolved Item 269, 270, 287/87-31-02,
Additional
Information Required to Evaluate Pipe. Supports.
The following
two supports need to be evaluated by the licensee to find out
the cause and the impact on safety.
-
Support No. 1-07A-0-6-0-400A-H41 has 1" steel shim blocks under
the washers. This exceeds the 1/4" maximum shim allowance and
are not shown on drawing.
-
Support
No.
1-14B-0-436L-ASR13
has
an
anchor bolt spacing
of approximately 3" from the adjacent support No. 1-14B-436L
WJB-1011. This appears to have violated the minimum spacing
requirement.
The licensee claimed Support No. 1-07A-0-6-0-400A-H41 just completed
in field and not documented yet.
(The
anchor bolt spacing for
support No.
1-14B-0-436L-ASR13 was estimated since no ladder was
provided during the inspection). The inspector was told during the
calculations check that the licensee's engineer went
with a ladder
to measure and get 4" anchor bolt spacing existing in field.
Even
with 4" anchor bolt spacing in field, it
is still less than the
minimum
anchor bolt spacing required
per Design
Specification
No. OS-0027.00-00-0001, Design Specification for class A, B, C, D and
F Pipe Supports and Restraints which the licensee claimed as a
proprietary document. Pending the licensee resolution, this problem
is identified as Unresolved Item 269, 270, 287/87-31-02.
-
(Open)
Inspector
Followup Item 269, 270, 287/87-31-03,
Safety-Related Piping Systems Maintenance.
The following items involved maintenance in the safety-related piping
systems.
-
Support No. 1-07A-0-6-0-400A-H41
has
one
support loosened
nearby.
The licensee's engineer stated that this loosened
support could have been
loosened for repairing Support
No. 1-07A-0-6-0-400A-H41.
-
Two rod supports for other pipe contacting the pipe supported by
Support No. 1-14B-0-436L-ASR14, see note 6, Table 2.
-
Support
No.
2-01A-4-0-1400-H4,
2-51A-436E-FAC-2803,
and
2-51A-1444-WSS-2902 had the wrong identification tag numbers.
-
Support No. 3-53B-5-0-2435B-SR38 had a Hydraulic Snubber Reservoir
contacting the vertical member of the support.
Pending the licensee's resolution, this problem is identified as
Inspector Followup Item 269, 270, 287/87-31-03.
-
(Open)
Violation
287/87-31-04,
Inadequate
Pipe
Support
Qualification.
Support Calculation No.
3-07A-0-2400A-R1 Used the member properties
of W6x20 in Computer Model and Analysis (STRUDL)
for Item No.7,
W4x13 shown on the detail drawing to qualify the support. The actual
size of Item No.
7 was verified during the inspection as a W4x13,
which was same as shown on the detail drawing.
Criterion V, requires that activities affecting quality shall be
accomplished in accordance with instructions, procedures or drawings
appropriate to the circumstances.
The above misuse of the large
member size to qualify the support is a Violation of 10 CFR 50,
Appendix B, Criterion V and is identified as a violation 287/87-31-04.
Since the modifications on Units 2 and 3 for IEB 79-02 and 79-14 are
essentially complete except for a few support modifications left due to
inaccessibility, and the majority of the remaining supports will be
completed during the Fall 1987 outage,
the licensee should submit
a Final
Summary Report after the completion of the outage which
contains a list of unmodified supports with justification for
continued operation.