ML18038B453

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Insp Repts 50-259/95-52,50-260/95-52 & 50-296/95-52 on Stated Dates.Violations Noted.Major Areas Inspected: GSI 40,pipe Breaks in BWR Scram Sys,Mods of HVAC Supports, Large Bore Piping & Supports & CRD Piping Support Mods
ML18038B453
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 10/11/1995
From: Blake J, Lenahan J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18038B451 List:
References
REF-GTECI-040, REF-GTECI-NI, TASK-040, TASK-40, TASK-OR 50-259-95-52, 50-260-95-52, 50-296-95-52, NUDOCS 9510170396
Download: ML18038B453 (28)


See also: IR 05000259/1995052

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIE%IA STREET, N.W., SUITE 2900

ATLANTA,GEORGIA 30323.0109

Report Nos.:

50-259/95-52,

50-260/95-52,

and 50-296/95-52

Licensee:

Tennessee

Valley Authority

6N 38A Lookout Place

1101 Market Street

Chattanooga,

TN

37402-2801

Docket Nos.:

50-259,

50-260

and 50-296

License Nos.:

DPR-33,

DPR-52,

and

DPR-68

Facili.ty Name:

Browns Ferry Nuclear, Power Station Units 1, 2,

and

3

Inspection .Conducted:

August 21-25,

and September

11-14,

1995

Inspector:

J. J.

Lenahan

Date Signed

Approved by:

Jerome J.

ake

Chief

Materi

.and

P ocesses

Section

Engineering

ranch

Division of Reactor Safety

/0 /i

5'5

Date Signed

SUMMARY

Scope:

-This special,

announced

inspection

was conducted

in the areas of Generic

Safety

Issue

(GSI) 40,

Pipe Breaks in

BWR Scram Systems;

modifications of

heating, ventilation

and air conditioning

(HVAC) supports;

large bore piping

and supports;

cable tray and conduit support issues;

long term torus

integrity; platform thermal

growth; moderate

energy line break; control rod

drive

(CRD) piping support modifications; Unit 3 startup issues;

and licensee

action

on previous inspection findings.

Results:

In the areas

inspected,

violations or deviations

were not identified.

One violation was identified for failure to implement installation of a cable

tray support in accordance

with design drawing requirements

- paragraph

3.7. 1.

An unresolved

item was identified regarding

performance of walkdown

Enclosure

2

95ao<70SVS

95<0>2

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2

inspections of the scram discharge

volume system. piping after the first scram

from full power,

and operating temperature,

following a refueling outage-

paragraph

2.

A weakness

was identified regarding errors

made during the drawing rollup

process-paragraph

3.7. 1 and 3.7.2.

The following issues

are resolved for Unit 3 restart:

GSI 40;

HVAC support

modifications; large bore piping and supports;

platform thermal

growth,

moderate

energy line break,

CRD pipe support

frame modifications,

and long

term torus integrity.

REPORT

DETAILS

Persons

Contacted

Licensee

Employees

  • T

R.

¹*J.

¹*D.

  • J
  • J

¹*L.

¹D.

¹P.

  • J

¹*H.

¹*S.

¹C.

Abney, Unit 3 Recovery

Manager

Gilbert, Operations

Procedure

Group Supervisor

Glass,

Acting Lead Civil Engineer

Housley, Site Licensing Engineer

Johnson,

Site guality Manager

Haddox, Maintenance/Modification

Manager

Madison, Unit 3 Civil Engineering Supervisor

Hatherly, Operations

Supervisor

Salas,

Licensing Manager

Valente, Unit 3 Engineering

Manager

Williams, Engineering

and Materials

Manager

Wetzel, Acting Compliance

Manager

Woods, Unit 3 Recovery Field Engineering

Other licensee

employees

contacted

during this inspection

included

craftsmen,

engineers,

technicians,

and administrative personnel.

NRC Resident

Inspectors

  • L. Wert, Senior Resident

Inspector

¹R. Husser,

Resident

Inspector

J.

Hunday,

Resident

Inspector

  • Attended

August

2S exit interview

¹Attended

September

14 exit interview

Generic Safety Issue

(GSI)

40 - Safety Concerns

Associated with Pipe

Breaks in The

BWR Scram System.

On January

3,

1986,

NRC issued

Generic Letter 86-01 which accepted

the

BWR owners'roup

response,

BWROG-8420 to resolve

GSI 40.

BWROG-8420

proposed that leak detection

on the Scram Discharge

Volume

(SDV) system

be performed

once per refueling cycle by a walkdown within 30 minutes of

scram reset after the first scram from full power and temperature

following each refueling outage.

In an

NRC letter to TVA, dated

November 7,

1990,

NRC listed

an outstanding

issue regarding

GSI 40.

The

outstanding

issue

concerned

the fact that the licensee's

emergency

response

procedures

for Units

1 and

3 did not address

the visual

inspection of the

SDV system within 30 minutes of scram reset after the

first scram from full temperature

and pressure,

following each

refuelling outage.

In

a letter to

NRC dated

October

1,

1990, Subject:

BFN Safety Concerns

Associated with Pipe Breaks in the

BWR Scram

System

(GSI 40 and Generic Letter 86-01), the licensee

stated that they revised

their Unit 2 abnormal

operating Instruction

(AOI) to require the

SDV

walkdown to be performed.

The licensee

also revised Unit 3 Abnormal

Operating Instruction 3-AOI-100-1, Reactor

Scram, to include this

requirement.

0

Il

il~

The inspector

reviewed Revision

5 of procedure

3-AOI-100-1, dated

July 10,

1995

and verified the requirement for walkdown inspection of

SDV header

and instrument

volume to check for leakage

is specified

within the procedure.

The requirement

is contained

in procedure

Step

4.2. 15. 11, which states

that

a walkdown inspection of the

SDV header

and

instrument

"should"

be preformed to check for leakage within 30 minutes

following scram reset,

of the first scram from rated temperature

and

pressure,

after

a refueling outage.

The inspector discussed

the need to

revise the procedure

by changing

"should" to "shall" so that it was

clear that the need to perform the walkdown of the

SDV is

a requirement,

and not optional.

The inspector

reviewed Unit 2 procedure

2-AOI-100-1, Reactor

Scram

Revision 40, dated

Hay 12,

1995.

Procedure

2-AOI-100-1, also states

that the walkdown of the

SDV "should" be inspected

following scram reset

after the first scram from full pressure

and operating

temperature

after

a refueling outage.

The inspector questioned

licensee

operations

personnel

regarding whether they have

implemented

the required

SDV

inspection after the first scram from full pressure

and temperature

during each of the three cycles since the

1991 restart of Unit 2.

The first scrams

from full pressure

and operating

temperature

following

the refueling outages

since the

1991 restart of Unit 2 occurred

on

August 2,

1991,

June

6,

1993,

and

December

2,

1994.

The information

provided

by the licensee,

(Unit 2 Reactor Operator Control

room logs for

these dates,)

was insufficient to determine if the licensee

had complied

with the commitment to perform the required

SDV system inspections

in

accordance

with intent of BWROG-08420.

Pending further review by NRC,

this issue

was identified as Unresolved

item 260/95-52-01,

SDV System

Inspection following Reactor

Scram.

This is not

a Unit 3 restart

issue.

Within the areas

inspected,

violations or deviations

were not

identified.

3.0

3.1

Followup on Unit 3 Restart

Issues

Moderate

Energy Line Break

The moderate

energy line break

(HELB) evaluation

was performed to

determine

the effect of internal plant flooding outside containment

from

breaks

in moderate

energy lines (piping)

on safe

shutdown of the plant.

Moderate

energy lines are defined

as

systems

with pressures

less

than

275 psi or temperatures

less

than

200 degrees

F.

The Unit 3 evaluation

was performed in accordance

with the Unit 2 precedent.

The licensee

implemented

the Unit 3 HELB in a two phase

program.

Phase

I consisted

of a detailed

drawing review to identify all moderate

energy

lines which could be sources

of flooding in Unit 3, or common class

1

structures;

identification of flood compartments/areas;

identification

of potential

drainage

paths;

and identification of safe

shutdown

equipment

which could

be affected

by flooding.

The

Phase II evaluation

~

'i

included detailed calculations of flow rates

from various flood sources;

areas

affected

by flooding; maximum depth of water in the area;

and

drainage

paths

from the various flooded areas.

The inspector

reviewed the Bechtel

Report titled: Moderate

Energy Line

Break Flood Evaluation Report For Browns Ferry Unit 3, dated April,

1993.

This report contains

assumptions/conditions

for HELB analysis,

summary of design methodology,

references,

design input data,

design

analysis,

and

summary

and conclusions.

The report contained

a

discussion

on Browns Ferry's original methods for conformance

to AEC

requirements

for evaluating flood from HELB, and justification for not

including some

areas

in the

HELB analysis.

The conclusions of the

HELB

study were that Browns Ferry conforms to the original licensing basis

and that the existing flooding studies

and protective measures

are

adequate.

Considerations

in the

HELB analysis

included control of

flooding by providing drainage

paths

from areas

containing critical

equipment potentially suspectable

to flooding, use of curbs/barriers

to

protect vital equipment,

and mounting equipment

on pads

so that it

located

above potential flood elevation levels.

The inspector

concluded that the licensee's

MELB analysis

adequately

addresses

this issue.

The licensee's

design

assumptions

and design

methodology are technically adequate.

The

HELB program is acceptable

for restart of Unit 3.

3.2

Platform Thermal

Growth

The platform thermal

growth issue

involved the effect of thermal

loads

on structural

steel

platforms.

During review of structural

steel

design

criteria, the

NRC office of Nuclear Reactor Regulation

questioned

the

licensee

regarding their use of non-linear analysis

which predicted

plastic deformation of structures

due to thermal

loads.

As

a result of

these questions,

the licensee

performed

a comprehensive

review of their

design criteria

and concluded that they would revise the criteria to

require steel

members to remain within the elastic limit for all loading

combinations.

The licensee

submitted their revised criteria to

NRC for review.

A

Safety Evaluation Report

was issued

in

a letter to TVA dated

December

7,

1993, Subject:

Browns Ferry Nuclear Plant Supplement

Safety Evaluation

of Structural

Thermal

Growth Design Criteria

(TAC Nos.

M08618,

H80619,

and M80620), which accepted

the licensee's

long-term structural

steel

design criteria'

followup site audit was conducted

by

NRR on March

14

and

15,

1995, to review implementation of the licensee's

long term

design criteria.

During this audit, the

NRR staff examined

completed

modifications

on Unit 2 pl.atforms required

by the revised

thermal

load

design criteria.

The results of the audit are

summarized

in an

NRC

letter to TVA dated April 20,

1994, Subject:

Browns Ferry Nuclear Plant-

Audit of Structural

Steel

Design Criteria Implementation.

0

~i

The licensee

consi'dered

thermal

loads in their analysis of Unit 3

structural

steel

pl'atforms.

Hodifications required

by thermal

loads

included

used of slotted holes in beams,

addition of beam stiffeners,

cover plates,

etc.

These

were implemented

as part of design

change

packages

previously inspected

by NRC.

Issues

regarding modifications to Unit 3 structural

steel

platforms were

closed

by the inspector during the inspection

documented

in

NRC

'Inspection

Report

number 50-259,260,296/95-41.

This issue is resolved

for Unit 3 restart.

3.3

HVAC Duct Supports

'Numerous discrepancies, were identified in 1988 in the design

and seismic

qualification of heating, ventilation and air conditioning

(HVAC)

ductwork.

The licensee

developed

a program to inspect safety related

,HVAC duct work.

for Unit 2 restart,

the ductwork required for Unit 2

operation

was evaluated

to an interim operability criteria.

A safety

Evaluation Report

was issued

by

NRC on August 22,

1990 which concluded

that the Unit 2

HVAC ductwork and supports

were acceptable

for Unit 2

restart.

The Unit 2

HVAC ductwork and supports

were subsequently

qualified for long term requirements

of the .licensees

Design Criteria

BFN-50-C-7104.

For Unit 3,

a review was performed to identify class

I HVAC ductwork

which was not previously required for Unit 2 operation.

The only areas

identified as being specific to Unit 3, were the ductwork associated

.with the Unit 3 residual

heat

removal

(RHR)

and core spray

(CS)

pump

motor coolers.

This Unit 3 ductwork and supports

were evaluated

to the

long term requirements

of Design Criteria BFN-50-C-7104.

A design

change notice

(DCN) number

DCN W28617A,

was issued to implement

modifications to existing Unit 3

HVAC ductwork supports

and

added

one

new support.

The inspector

reviewed

DCN W28617A and performed

a walkdown inspection

to examine the

new support.

The inspector verified the

new support,

number 3-47B923-11,

was installed in accordance

with the design

requirements

shown

on drawing number 3-47B923-11,

Revision

1.

Acceptance criteria for installation of HVAC ductwork supports

are

specified in Hodification and Addition Instruction HAI-4.3,

HVAC Duct

'System,

Revision 9, dated

June

16,

1993.

The existing-support modifications consisted

of increases

in the size of

some fillet welds to

~k inch.

The inspector

reviewed quality control

inspection records

and weld data sheets for HVAC ductwork support

numbers

3-47B923-6,

3-47B923-7,

3-47B923-8,.

and 3-47B923-10

and verified

that the welds were modified as required

by the design drawings.

This

issue is resolved for Unit 3 restart.

0

3.4

Control

Rod Drive Hydraulic Piping System

During inspection of cable tray supports

in the Unit 2 reactor building

the licensee identified an issue regarding

attachment of control rod

drive

(CRD) system piping to the cable tray support structure.

The

licensee

performed

an extensive

design evaluation of the Unit 2

CRD

piping system

and

implemented modifications to the Unit 2

CRD pipe

support frames.

The licensee's

Unit 2

CRD pipe frame design reanalysis

program

was reviewed

by NRC during inspections

documented

in

NRC

Inspection

Report

numbers

50-260/89-20,89-31,

89-39,

89-44,

89-62,

90-08

and 92-01. This issue

was closed for Unit 2 restart

in NRC Inspection

Report 259,260,296/90-23.

A walkdown inspection of the Unit 3

CRD pipe support

frames

showed that

the Unit 3 frames,

were identical to the Unit 2

CRD frames.

Since the

Unit 2 frames required extensive modifications,

due to cost

and schedule

considerations,

the licensee

decided to replace

the Unit 3

CRD frames

with new supports.

The modification which involved installation of 32

new

CRD pipe support

frames

was

implemented

under

DCNs W17652,

W17653,

and W18645.

Three of the

new

CRD pip

support

frames

were inspected

during the inspection

documented

in

NRC Inspection

Report

number

259,260,296/95-03.

During the current inspection,

the inspector

inspected

an additional

five of the

new

CRD pipe support

frames.

The

new frames

were inspected

against

the design drawings for configuration,

member size,

weld size,

type and length connection details,

and other construction

requirements

stipulated

by the licensee's

procedures.

CRD pipe support

frames

inspected

were

as follows:

Support

numbers 3-47E-468-102,-103,-104,-

106,

and -107.

No discrepancies

were identified during the walkdown inspection.

The

inspectors

concluded that the modification .were implemented

in

accordance

with design requirements.

This issue is resolved for Unit 3

restart.

3,5

Large Bore Piping and Supports

The licensee initiated programs

in 1979 to comply with IE Bulletin 79-

02,

Pipe Support

Base Plate

Design Using Concrete

Expansion

Anchors,

and

IE Bulletin 79-14,

Seismic Analysis for As-Built Safety-Related

Piping

Systems.

Implementation of these

programs

was delayed

by other

programs.

In addition,

the licensee did not include portions of piping

systems

covered

by other programs

under the

IEB 79-02/79-14

program.

Numerous deficiencies

were identified by

NRC in 1985

and

1986 concerning

implementation of these

programs.

In order to resolve

these

deficiencies,

the licensee

made various

commitments to

NRC regarding

improvement to design criteria, reinspection of large bore piping and

supports,

reanalysis

of piping and supports,

and implementation of any

required modifications.

Acceptance of the licensee's

design criteria

4I

>

for analysis of piping and pipe supports

by

NRC is documented

in NUREG-

1232,

Volume 3, Supplement

1, Safety Evaluation Report for Browns Ferry

Unit .2 Restart.

For Unit 3 restart,

the licensee

has

completed all 79-02

and 79-14 work

with the exception of a few pipe support modifications

on system

10, the

reactor

head vent.

These modifications will be completed after fuel

load for Unit 3, but prior to Unit 3 restart.

Inspection of the licensee's

79-02

and 79-14 program for 'Unit 3 included

review of pipe stress

analysis,

review of pipe support design

calculations,

and inspection of completed

pipe support modifications.

These

inspections

are documented

in NRC Inspection

Report

numbers

50-

259,260,296/91-34,

91-42,

92-07,

92-32,

92-38,

93-11,

93'-26,

93-29)

94-

15, 94-29,

and 95-03.

This issue is resolved for restart of Unit 3.

3.6

Long Term Torus Integrity

In the early 1980's the licensee

implemented

a series of modifications

to the torus intended to resolve deficiencies identified regarding

the

original design of the Hark

1 containment

system.

These modifications

involved torus attached

piping,

and structural

reinforcement of the.

torus

and torus related structures.

In 1985, discrepancies

were

identified by

NRC during inspections of the as-constructed

torus

attached

pipe support modifications.

The licensee's

corrective actions

included reinspection of the torus attached

piping and pipe supports,

and reinspection of torus structural modifications

and torus related

structures.

The licensee corrective action for Unit 2 restart

were

accepted

by

NRC in Section 2.2.4.4 of NUREG-1232,

volume 3, Supplement

2, dated

January

23,

1991.

In a letter to

NRC dated April 29,

1991, Subject:

Browns Ferry Nuclear

Plant

- Program for Resolving

Long-,Term Torus Integrity Issue Prior to

the Restart of Units

1

and 3, the licensee

provided

NRC their action

plan

and commitments for resolution of long term torus integrity for

Units

1 and 3.

The licensee's

corrective actions

included walkdown

inspections

to identify any discrepancies

in the torus, evaluation of

the discrepancies,

and,performance

of modifications to correct

any

unacceptable

discrepancies.

Inspect'ion of the licensee's

implementation of the long term torus

integrity program included review of design criteria, design

calculations

and completed modificati'ons for torus attached

piping and

pipe supports.

These inspection

are documented

in

NRC Inspection

Report

numbers

50-259,260,296/92-32,

94-15,

and 95-03.

The inspectors

concluded that the installed modifications were acceptable.

This issue

is resolved for restart of Unit 3.

il

0

3.7

3.7.1

Cable Tray and Conduit Supports

guestions

were raised

by

NRC and through the employee

concerns

program

regarding

seismic qualification of cable tray and conduit supports.

The

resolution of this issue

can

be subdivided into two categories:

new

cable tray and conduit supports,

and evaluation of existing cable tray

and conduit supports.

New Cable Tray and Conduit Supports

New supports

are those installed since

1986.

These

supports

are

designed

in accordance

with the licensee's

seismic design criteria and

installed

under the l.icensee's

quality assurance

program requirements.

The inspector

performed

a walkdown inspection

and examined

new cable

tray and conduit supports.

New supports

were inspected

against

the

design drawings for configuration,

member size,

weld size,

type

and

length,

connection details

and other constructions

requirements.

Additional acceptance

criteria utilized by the inspector during the

walkdown inspection

were Hodification and Addition Instruction, HAI-3.9,

Instal.lation,of Cable Tray Cable Tray Supports

and Cable Tray Covers,

Revision 7;

and HAI 3. 1, Installation of Conduit

and conduit supports,

Revision

25.

Cable tray supports

examined during the walkdown were:

Support

numbers

319092-15-B1102-38;

318992-1-81102-145;

318992-2-B830-56;

318992-3-

B1102-32;

318992-8-B1102-174;

3-48B1102-3-21,

-38, -122, -145,-164;

and

W17473-253,

-303,

and-304.

The fol.lowing deficiency was noted

by the inspector during the walkdown:

Two flare-bevel

welds

on the vertical interfaces of Bill-of-Haterial

i,tems

3 and 4,

on cable tray support

number 319092-15-B1102-38,

had not

been

completed

as required

by the design details

shown

on drawing number

DCA W17473-300.

Paragraph

6. 1. 1 of Procedure

HAI-3,.9 requires

cable

tray supports

to be fabricated

and installed according to the applicable

design output documents

(drawings).

The failure of the licensee

to

install cable tray support

number in accordance

with the drawing

requirements

was identified as violati'on item 296/95-52-02,

Failure to

Construct

Cable Tray Support in accordance

with Design Requirements.

The licensee

issued

Problem Evaluation Report

(PER)

number

BFPER 951125

to document

and disposition this problem.

The inspector

also identified three cable tray supports

which had the

incorrect support

number

on the identification tag,

(Support

numbers

3-

48B1102-32,

-38,

and -145)

and

one support which had

a missing

identification tag (Support

number 318992-8-B830-15).

These

items were

also included

on

PER number

1

BFBER 951125.

However, since the mi'ssing

or incorrect tag numbers

have

no safety significance,

these

items were

not included

as. part of the violation.

~

~

During the walkdown, the inspector also

examined

a Kellems-grip cable

support,

support

number 3-4883800-4500,

which provides additional

'vertical support for cables

in vertical cable trays.

The inspector

noted

an 'error in the Bill of Materials

(BOH) for Items

1 through 5.

The licensee

issued

BF

PER 95-1128 to document

and disposition this

problem.

Further review of this problem disclosed that the error in the

BOM for items

1-5 was

due to

a drafting error in the drawing rollup

process.

This problem is similar to that identified in Unresolved

item

296/95-15-02.

Since the support

was constructed

as required

by design

requirements,

a violation was not identified for this problem;

however,

the drafting error was identified as

a weakness.

The following new conduit supports

were also

examined during the

walkdown inspection:

Typical conduit supports

number 0-48B805-010,

0-

48B805-013,

and 0-48B805-014,

installed

on elevation

593; unique conduit

supports

number 3-48B3800-2188,

-4194,

and -4259;

and temperature

switch

support

number 3-47B900-212.

The conduit supports

were constructed

in

accordance

with design requirements;

however,

an additional drafting

error was noted

on drawing number 3-48B38004190,

Revision 0, regarding

incomplete/incorrect

drawing notes.

This problem was also documented

on

BFPER 951

128.

This was identified to the licensee

as another

example

of the weakness

discussed

above.

3.7.2 Evaluation of Existing Cable Tray and Conduit Supports

Seismic verification of existing cable tray and conduit supports

is

being accomplished

using the Generic

Implementing Procedure

(GIP) for

Seismic Verification of Nuclear plant Equipment.

The GIP was issued

by

the Seismic Qualification Utility Group

(SQUG) in response

to

NRC

Unresolved Safety

Issue

A-46 (USI A-46), Seismic Adequacy of Mechanical

and Electrical

Equipment in Operating Plants.

The licensee

committed to

complete the A-46 walkdown for cable tray and conduit supports

in Unit 3

prior to restart of unit 3.

The inspector

reviewed walkdown Instruction

CEB-012,

Seismic Verification and Assessment

of Nuclear Plant

Equipment,

Revision 0, dated August 17,

1994.

This pro 'edure specifies

the

instructions for implementation of the GIP requirements

for personnel

qualifications, precautions,

methodology,

acceptance

criteria,

and

documentation

requirements.

The licensee

has

completed

the A-46 walkdown inspections for existing

cable tray and conduit supports

in all Unit 3 category I structures,

except for the drywell.

During the A-46 walkdowns,

the licensee

evaluate

cable tray fill, spans,

and supports,

including anchorage

and

conduit spans,

supports

and anchorage

using the criteria in GIP.

Cable

trays, conduits,

and supports

which did not meet the GIP acceptance

criteria were designated

as outliers.

The inspector

reviewed the results of the licensee's

A-46 walkdowns

summarized

in a walkdown summary table.

Outliers are documented

on

Outlier Seismic Verification Sheets.

The outliers are addressed

either

through

a plant work request,

or by a design evaluation

documented

in a

calculation using the GIP acceptance

and the licensee's

design criteria.

0

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Items addressed

by 'work requests

included missing or damaged

hardware

covered

by existing plant maintenance

procedures.

Problems (outliers)

which involved questionable

design

and/or construction practices,

e.g.

conduit over-spans,

apparent

inadequate

anchorages,

potential

seismic

interactions,

supports

which do not meet current design practices,

etc.

were evaluated

by the licensee

in calculation

number CD-(0000-931227,

Revision

1, dated

June 8,

1995, gualification of Cable Tray and Conduit

,System

by A-46 program.

Modifications

(DCNs) were issued for outl.ier

which could not be qualified.

The inspector reviewed the calculation for completeness,

accuracy

and

adherence

to design criteria and procedural

requirements.

No

deficiencies

were, identified.

The inspector walked down three,

randomly

selected,

modifications

implemented to resolve A-46 outliers,

and

verified the modifications were implemented

in accordance

with the

DCN

requirements..

Modifications examined

were

as follows:

- Modified Conduit support

on drawing number 3-48B3800-3935,

Revision

1

- Modified. Conduit Support

SL No.

3 on drawing number 3-48B3800-3936,

'Revision 0.

- New conduit support

as

shown

on drawing number 3-48B3800-3938,

Revision

0 ~

No deficiencies

were identified.

The inspector

conducted

a walkdown inspection

in the following Unit 3

areas

to assess

the effectiveness

of the licensee's

A-46 Cable Tray and

Conduit program.

Reactor Building Elevations

565,

593,

and 621; Control

Building cable spreading

room and elevation

593 hallway;

and Diesel

Generator Building.

No significant deficiencies

were identified,

however,

several

(18) minor items, were noted.

These

included missing or

loose lockouts,on cable tray hanger rods,

loose or mixed conduit clamps,

a temporary support still installed in the diesel

generator building,

broken conduits,

and other minor items.

The inspector also noted

housekeeping

deficiencies

such

as debris in cable trays,

missing cable

tray covers,

and .tools

and debris left in various

areas

in the plant.

Licensee

personnel

indicated that the housekeeping

deficiencies will be

addressed

as the work in the areas

is. completed

and the areas

turned

over to operations for restart.

In the areas

examined,

the inspector

concluded that the licensee's

A-46

cable tray and conduit walkdown program meets

NRC requirements

and is

adequate

for Unit 3 restart.

However, this issue will remain

open

pending completion of this program in the Unit 3 drywell.

In the areas

examined,

no deviations

were identified.

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10

4.0

Licensee

Event Report

(LER)

.(Closed)

LER 259/88-37

Inadequate

Design Control

Procedures

,Discrepancies

in HVAC Ductwork.

In October,

1988

a review of open non-

conformance

reports identified several

discrepancies

involving the

design

and seismic qualification of HVAC ductwork.

This

LER was closed

for unit

2 restart

in

NRC Inspection

Report

number 50-259,260,296/91-06.

For Unit 3,

a review was performed to identify class

I HVAC ductwork

that

was not required for Unit 2 operation.

Modifications were

completed

as discussed

in paragraph

3.3,

above.

This

LER is closed for

unit 3 restart.

5.0

5.

1'.2

Licensee Action on Previous

Inspection Findings

(92701

and 92702)

(Closed) Violation Item 259,260,296,85-41-01,

Inadequate

Design Control

for Safety-Related

Cable Tray Supports.

This violation was identified in 1985

as

a result of a review of design

calculation for safety-related

cable tray supports

in various category

1

structures.

Problems identified included improper seismic design

analysis of various supports,

errors

and omissions

in the calculations,

and failure to perform design verifications.

This violation was issued

to the licensee

on September

8,

1986

as part of a

$ 150,000 civil penalty

covering

examples of failure to comply with NRC requirements

identified

in six

NRC inspections

covering the period from August

12,

1985 through

January

31,, 1986.

The licensee

did not contest

the civil penalty.

The licensee's

corrective actions for th'is violation are

stated

in

their letter to

NRC dated October 8,

1986, Subject:

Notice of Violation

and

Proposed

Imposition of Civil Penalty

Enforcement Action EA-86-56.

The licensee's

corrective actions

included preparation of procedures

and

design criteria for design of cable tray supports,

using

an independent

consultant to perform

an interim seismic qualification of Unit 2 cable

tray supports for Unit 2 restart,

and long-term qualification of cable

tray supports

using the Generic

Implementing

Procedure

(GIP) for Seismic

Verification of Nuclear Plant Equipment.

The GIP was issued

by the

Seismic gualification Utility Group in response

to

NRC Unresolved Safety

Issue

A-46 (USI A-46) Seismic Adequacy of Mechanical

and Electrical

Equipment.

The corrective actions for Unit 2 were reviewed during inspections

documented

in NRC Inspection

Report

numbers

50-259,260,296/88-38,

89-21,

89-29,

89-30, 89-32, 89-42,

and 89-62.

The inspections

covered review

of design criteria, design calculations,

and selected

cable tray and

conduit support modifications.

(Closed)

Inspector

Followup Item 259,260,296,85-51,-01,

Inspection of

Existing Cable Tray Support

Systems.

This IFI was identified in 1985 during

a followup inspection

performed

relative to violation item 259,260,296/85-41-01.

The inspector noted

~

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ik~

11

5.3

that the licensee

did not have

a written procedure

to inspect existing

cable tray support

systems

to assure

the as-built cable tray support

systems

comply with applicable

design

documents.

The licensee

is in the

process

of inspecting existing cable tray support

systems,

and other

mechanical

and electrical

equipment,

using the

NRC approved

Generic

Implementation

Procedure

(GIP) for Seismic Verification of Nuclear Plant

Equipment,. referenced

above.

The licensee

issued

walkdown Instruction

CEB-012,

Seismic Verification and Assessment

of Nuclear Plant Equipment,

to implement the walkdown,program using the GIP.

The GIP contains

specific requirements

pertaining to inspection,

evaluation

and

.identification of cable tray support

systems

w'hich do,not meet seismic

design requirements.

(Closed)

Unresolved

Item 296/86-06-02,

Reactor Building Control

Bay

HVAC

Inadequate

Design.

This item concern

the licensee's

identification of inadequate

design of

HVAC support.

'This issue

was reported to

NRC under

LER 259/88-037.

This unresolved

item was closed for Unit 2 in NRC Inspection

Report

number 50-259,260,296/90-08.

For Unit 3,

a review was performed to

identify the class

I HVAC ductwork that was not required for Unit 2

operation.

The only areas specific to Unit 3 were the duct work for the

Unit 3

RHR and core spray

pump motor coolers.

The licensee's

corrective

action for this duct work is discussed

in paragraph

3.3,

above.

URI

296/86-06-02's

closed for Unit 3.

URI 259/86-06-02 will remain

open

for Unit 1.

5.4

(Closed)

Unresolved

item 296/87-26-03,

RHR Pump Suction

and Nozzle

Load

Allowable Are Exceeded.

This item concerned

Residual

Heat

Removal

(RHR) Nozzle load allowables

as identified by the licensee

in deficiency number 87-13-6 of

Engineering

Assurance

Audit 87-13.

The licensee

revised calculation

number 'CD-(3073-920014

(System Nl-373-5R)

and generated

new calculation

number CD-f3074-910631

(System Nl-374-5R)

and CD-g-3074-910400

(System

Nl-374-7R) to evaluate

the

RHR pump suction anchor

and nozzle loads.

The revised

and

new calculations qualified the applied loads

based

on

revised design criteria BFN-50-C-7103,

General

Design Criteria for

Structural

Analysis

and gualification of Mechanical

and Electrical

Systems

(Piping

and Instrument Tubing).

The applied loads

include I.E.

Bulletin 79-14 requirements.

The as-built walkdown information and data

also were used in the analysis.

The inspectors

reviewed the following calculations

which qual.ified the

nozzle loads:

- Calculation

number CD-93074-910631,

Revision 4, dated

February

27,

1995.

- Calculation

number CD-(3073-920014,

Revision

11, dated .February

2,

1995.

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Oi

12

- Calculation

number CD-(3074-9104000,

Revision

5, dated April 5,

1995.

Based .on this review, the inspectors

determined that the calculations

complied with the licensee's

design criteria and were acceptable.

The

piping stresses

are within code allowable values.

This item is closed

for Unit 3.

URI 259/87-26-03 will remain

open for Unit l.

6.0

Exit Interview

The inspections

scope

and results

were summarized

on August

25 and

September

14,

1995, with those

persons

indicated in paragraph

1.

The

inspectors

described

the areas

inspected

and discussed

in detail the

inspection results listed below.

Proprietary information is not

contained

in this report.

Dissenting

comments

were not received

from

the licensee.

Unresolved

Item 260/95-52-01,

SDV System

Inspection

Following Reactor

Scram,

paragraph

2.0.

Violation Item 296/95-52-02,

Failure to Construct

Cable Tray Support in

Accordance Mith Design Requirements,

paragraph

3.7. 1.

0

0

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