ML20033C738

Request for OMB Review & Supporting Statement Re IE Bulletin 81-01,Revision 1, Surveillance of Mechanical Snubbers. Estimated Respondent Burden Is 96,000-h

ML20033C738
Person / Time
Issue date:	11/17/1981
From:	Donoghue D, Scott R NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20033C737	List: ML20033C736 ML20033C738
References
IEB-81-01, IEB-81-1, NUDOCS 8112040058
Download: ML20033C738 (5)

Text

y RECUEST FOR CMJ REVIEW "2Nm

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(Under th3 Paperw:rk Reduction Act and Executiv? Ord:r 12291), mrr Important - Reid irttructions (SF-83 A) bef!ra compl: ting this Offica cf inform tion cild R guic. tory Affairs form. Submit the required number of copies of SF-83 together Office of Management and Budget with th0 material for which review is requested to:

Washington D.C.20503 1.Dep;rtment/ Agency and Bureau / Office onginating request

3. Name(s) and telephone number (s) of person (s) who can best e

answer questions regarding request U.S. Nuclear Regulatory Comission Pat Woollev 492-8137 I

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fg No (Section 3507 submission) ". ',

I&E Bulletin - Mechanical Snubbers

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2 a Yes.'NPRM.' Expected date of publicationi 30 Yes,tircirule. Espected dateof publication:

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CERTIFICATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the informulon collection or rulemaking submitted for

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e SUPPORTING-STATEMENT FOR I&E Bulletin on Mechanical Snubbers.

Justification I

This. requirement was approved by GA0 with an expirati$n date' of December 31, 1981 (OMB Number 3150-0061).. All' data have not.been received...This request-.

for an extension is for the.information requested as, annotated on page 6. of the attached 1&E Bulletin.on Mechanical. Snubbers that was. issued March 5,.1981.

All other requirements have been. completed.

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NRC has an established program of communication.with its; licensees.

I&E T-bulletins notify licensees / applicants,and requestsuthem to take appropriate action and report to NRC results of inspections,. corrective measures taken-or analysis performed.

This specific request for clearance involves an I&E bulletin on mechanical snubbers.

The background portion of the bulletin identifies a number of failures to mechanical snubbers.which have occurred.

Depending on the mode of failure, this could lead to either their:

(1) not being able.to perform their safety-related function following a. seismic event or.(2)_ imposing;high. stresses on

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piping systems and components during normal operating transients.

In either event, their failure could lead'to a condition which presents a threat to the 4

health and safety of the public.

The primary purpose of the bulletin is to. insure that these snubbers are functional through a program of tests and inspections. The reporting require-ments are to insure that this program is conducted in a timely manner and to identify additional problem areas. The data obtained will be reviewed by regional and headquarters personnel to verify completeness and to determine the need for additional or supplemental tests and inspections.

Since the required tests and inspections have not been performed to date, data concerning their results are not presently available from any source.

Description of Survey Plan The bulletin will be applicable to all. operating nuclear power plants and those plants under construction which are nearing completion.

The remaining plants under construction will be covered through revised licensing criteria y,

being imposed by the Office of Nuclear. Reactor Regulation..

Requirements have been completed by all but E.bf the respondents, This P%

clearance' request is for authority.to continue' to collect 1[he*tnttially.

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requested data from the 22/

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- Tabulation and PublicStion Plans There are no current plans for publication.of the data obtained.

lj; Jime Schedule for Data. Collection and' Publication The time schedule is outlined in the bulletin.

-e-I[..h Consultations Outside the Agency e.u c.

' '*r The Atomic Industrial Forum provided comments prior to the initial distribution

1. f R of the bulletin.

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Estimate of Compliance Burden

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Based on estimates provided by one plant (Summer) estimated burden would be

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3,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for compliance.

Staff agrees that this is a reasonable estimate based on a random sample of a few licensees.

Therefore, 32 plants would impose burden of 96,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

Estimate of Cost to Federal Government The cost to government is half of a staff year for a GS-15 to review the data.

This cost when overhead is also included results in a total of $40,000 to

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the government.

Enclosure:

Sample Bulletin

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.c-l (Draft letter to all power re' actor facilities with the exception of the L.

following: Diablo Canyon riuclear Power Plant, Unit 2; Grand Gulf Nuclear Station, Unit 1; LaSalle County Station, Unit 1; San Onofre Nuclear Station, Unit 2; Susquehanna Steam Electric Station, Unit 1;'and Watts Bar Nuclear Plant, Units 1 and 2)

'IE Bull'etin No. 81'01, Revision 1:

SURVEILLANCE OF MECHANICAL SNUBBERS Addressee:

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IE Bulletin 81-01 has been revised to change the identification of the power 7

reactof facilities with construction permits to which, the builetin.is applicable.

This change does not affect your requirements with respect to the bulletin.

As a result, the enclosed revised pages 5 and 6 are fcrwarded to you for infoi1 nation.

9 Should you have any questions regarding this bulletin revision, please contact this office.

Sincerely, a

Signature (Regional Director)

Enclosure:

IE Bulletin No. 81-01 with revised pages 5 and 6 1:.

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IES 81-01 UNITED STATES NUCLEAR. REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT

-r WASHIrdGTON, D.C.

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January 27, 1981

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IE Bulletin No. 81-01:

SURVEILLANCE OF MECHANICAL SNUBBERS-9.

b Description of Circumstances:

4 y..Several instances of failures of mechanical snubbers supplied by International m

Nucleai Safeguards: Corporation (INC) have been, identified that indicate possible deficiencies in these snubbers.

A summary of the failures that have occurred 3

is provided below:

1 1,

1.

On August 9,1974, the Tennessee Valley Authority submitted event rep' rt o

i BFAO-50-260/741W identifying 11 of 14 INC Model MSVA-1A snubbers that were found inoperable on Browns Ferry Nuclear Power Station Unit 2 and-subsequently identified 5 of 14 inoperable units on Browns Ferry Nuclear Power Unit No 3.

All of these units were found to be frozen, and the cause was attributed to a failure to lubricate the parts during assembly.

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manufacturer.

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The failed snubbers were replaced with new units produced by the same c

2.

On April 12, 1976, the St..Lucie Plant Unit I facility of Florida Power

/c and Light Corporation submitted event report No. 50-335-75-9 wherein five l

INC Model MSVA-1 snubbers were identified as inoperable because they were found to be frozen.

The failures were caused by oxidation on the internals l

and by improper assembly.

All INC mechanical snubbers were replaced with units produced by another manufacturer.

3.

On. April 8,1977, Iowa Electric Light and Power Company submitted event report No. 77-23 for the Duane Arnold Energy Center facility that identi-'

6 fied 13 INC Model 1MSVA-1 Type AS snubbers to be frozen; the cause of s

failure was attributed to large amounts of interior oxidation.

The units 1

were replaced with those produced by another manufacturer.

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4.

On December 5,1979, personnel from the Nuclear Regulatory Commission >

visited Department of Energy (DOE) facilities at Richland, Washington',, to obtain information on DOE experience with INC snubbers at the Fast Flat, Test Facility (FFTF).

The DOE-owned FFTF was equipped with more,tNani s.

4,000 mechanical pipe restraints (snubbers) supplied:by INC.

In51978, J

s FFTF examined more than 800 of these mechanical. snubbers by remo 1'

were frozen.._ The plant was still.under construction >so the sn6chers had *

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L seen no service and had been subjected to 'only normal construction

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environments for 1 to 2 years::

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IEB 81-01 1

~~ January 27,.1981

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- Page 2 of 6 Tests were conducted on three operable snubbers by installing them on a Hanford Engineering and Dev.elopment Laboratory (HEDL) process line.

The three snubbers were subjected to flow-induced low-amplitude vibration (0.003 inches or less).

These snubbers were of both the combined carbon -

steel and s'tainless steel construction and the all stainless steel con-struction.

Detailed test data are not available to the NRC at this time.

However, all three s.tubbers froze after being subjected to the vibration for periods of 3 to 30 days.

The failure modes on all units inspected and tested involved a number of different mechanisms' leading to the freezing of the snubbers.

Following disassembly of some of the snubbers, inspections showed the failures were caused by improper assembly;. overheating of internal components caused by welding (during fabrication); and sensitivity of the design to dirt,'

corrosion, and inadequate or excessive lubrication.

DOE concluded that,

-there were generic deficiencies in the design of'the. snubbers of this specific manufacturer for application to the FFTF facility and for pipes subjected to vibration.

All INC mechanical snubbers in FFTF have been replaced with snubbers produced by another manufacturer.

5.

On May 31, 1980, Gecrgia Power Company reported eight INC snubbers located on instrument and drain.ines at Edwin T. Hatch Nuclear Plant Unit I were-

. identified as inoperable (LER 321-80-55).

The cause of the failures was identified as internal corrosion that caused a frozen condition.

In an attempt to free a snubber (750 pound capacity), forces up to 1500 pounds were applied in both.the " extend" and " retract" directions and the snubber did not move.

The inspection of INC snubbers was completed at the Hatch facility and, on June 30, 1980, NRC received a supplemental report that 45 of the 61 snubbers that had been insoected on Unit I had been identi-fied as inoperable and three of the 42 snubbers that were inspected on Unit 2 were inoperable.

All inoperable snubbers were replaced prior to startup of the affected unit.

Some were replaced with mechanical units produced by another manufacturer, some were replaced with later-model INC snubbers, and three were replaced with rigid restraints.

Plans are being made to replace all INC snubbers during upcoming refueling outages.

Analyses are also being performed on the piping affected by the locked up-snubbers.

t In addition to INC snubber failures, failures of mechanical snubbers by another-

, manufacturer, are identified below:

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C 1.

On deptember 7,1979, Public Service Electric and Gas Company reported the i(

I failure of three Model PSA-3 mechanical snubbers manufactured by Pacific Scientific Company that were located on a m'ain feedwater line of Salem Nuclear Generating Station Unit 1 (LER 79-54).

These three snubbers could va-act be, votated around their spherical rod end bearings.

The snubbers were NC

' removed 'and inspection revealed that the lead screw and traveling nut

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assembly, which translates linear to rotational motion, had failed.

The f snubbers no longer provided seismic shock Testraint under this condition.

J7hes'e' snubbers are dire:tly upstream of the nuclear Class II piping boundary

,,M an'd are included in +he stress calculations for the seismic analysis of the nuclear portion of the main feedwater piping.

Failure of the snubbers tin v

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IEB 81-01

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January. 27,.1981.

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- Page 3 of 6 appeared to result from a force many times greater than the design load of the snubbers.

Tnis force was either an extreme shock load or occurred when the snubber was in the fully retracted condition.

The snubbers were replaced.dth units produced by the same ' manufacturer.

2.

On April 10, 1979, Consumers Power Company reported a failure of eight Model PSA-3 Pacific Scientific snubbers at their Big Rock Point Nuclear Plant facility (LER 79-017/03L-0).

The cause of the failure was improper installation in that a spherical washer was omitted from the transition tube.

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3.

On March 15 and June 11, 1979, Florida Power and Light reported failures of Pacific Scientific Company mechanical snubbers on main steam and feedwater systems at Turkey Point Plant Units 3 and 4 (LER 79 006/03L-0 and r

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79-009/03L-0 respectively). ~ The cause in both cases was attributed to excessive loading.

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'.The nature of the above mechanical snubber fr.ilures is to prevent the piping

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systems, to which they are attached, from moving freely during the normal thermal heat up and cool down associated with plant operations.

Restraining this thermal motion results in higher than normal stresses which, if high enough and repeated frequently enough, can lead to a premature fatigue failure of the piping system.

,These mechanical snubbers have been installed for a number of years without e-any NRC requirements for periodic surveillance to deteroine their condition.

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As a cesult, their current condition is unknown to NRC and therefore NRC is requesting a prompt examination of all mechanical snubbers installed to date.

Because of the high percentage of failures discovered with the INC snubbers, the time frame for their examination is the shortest and additional opera-bility tests are called for.

Actions to be Taken by Licens~ees of Operatino Reactors:

1.

Within 30 days of the issuance date of this bulletin, all normally accessible

• INC mechanical snubbers installed on safety-related systems or in storage shall be visually examined and tested as follows:

a.

Perform a visual examination for damage and, without causing the system to be inoperable except as permitted by the facility technical specificationr, verify that the snubbers have freedom of movement by performing a nianual test over the range of the stroke in both com-(

pression and tension.

J b.

Perform an operability test to confirm that (1) activation-(restraining action) occurs in both compression and tension and u

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(2) the drag forces are within the specified range in both compression- -

and tension.

T 5 tests shall be parformed on all snubbers in storage-and on a representative sample (10% of the total of this. type of ~

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L snubber in use in the plant or 35, which ever is less) of the

""Normally accessible" rr.fers to those areas of the plant that can be entered -

during reactor operation.

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.F J:nu:ry 21, 1981.

Page 4 of 6 normally accessible snubbers that are in. service and can be indiv-idually removed without causing the system to be inoperable, except as permitted by the facility technical specifications.

For each snubber that does not meet the test acceptance criteria, an additional representative sample (as defined above) of this type of. snubber shall be tested.

For each of these additional snubbers that do not meet the

' test acceptance criteria, another representative sample of 'this type of snubber shall be tested. This cycle shall be repeated until no more failures have been found'or until all snubbers of $his type have been tested.

The samples should be made up'of snubbers representing the s

1 various sizes.

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c.

Snubbers which have been examined and tested in a manner comparable to Items-la a. d Ib above' within the.last;six months may be ' exempted.

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If any failures are identified.in Itams la 'or'1b above, take corrective.

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action and evaluate the effect of the failure on the system operability pursuant to the facility technical specifications for continued' operation.

~

e.

If failures are identified in Items la and 15 above, and if INC snubbers are known to be located in any inaccessible areas, a plant shutdown shall be performed within 30 days after the discovery of the first inoperable snubber and inspections conducted in accordance with Item 2a and 2b below, unless justification for continu6d operation has been m

provided to the NRC.

u 2.

Visually examine and test all inaccessible INC mechanical snubbers installed on safety related systems'at the next outage of greater than f.ive days duration as follows:

a.

Visually examine and manually test all inaccessible snubbers described in Item 1.a above.

b.

Perform an operability test on a representative sample of inaccessible snubbers as described in Item lb above.

c.

Snubbers which have been examined and tested in a manner comparable to Items 2a and 2b above within the last six months may be exempted.

d.

If any failures are identified in Items 2a or 2b above, take corrective action to evaluate the effect of the failure on system operability pursuant to the facility technical specifications for resuming operation.

3.

Provide a schedule for an inspection program covering mechanical snubbers produced by other manufactures.

As a minimum, this inspection program h,g.d shall:

m.

a.

Include.all snubbers installed on safety-related systems; gu c

(:t j -

b.

Include the vis'ual examination and manual test described in Item la s...__,_

above for all snubbers; 1-G m-

-e-

Qi ~

.s IEB 81-01, Rev. 1

F W March 4 1981

- Page 5 of 6 i

c.

Snubbers which have been examined and tested in a manner comparable to Item 3b above within the last twelve months may be exempted:

d.

Require the corrective action and evaluations described in Items 1d and 2d above; and e

.e.

Be completed prior to the completion of the next refueling outage.

Plants which are currently in a refueling outage should perform

' T.U.

the visual examination and manual tests of inaccessible mechanical

, 7 snubbers before resumption of operations unless some other basis

,$:l?

for assurance of snubber operability is provided to the NRC.,

n,..

g4;I

' N.NR *

/. 4.

Submit a report of the results of the inspections, testing and evaluation requested in~ Item 1 to NRC within 45_daysiotthe issuance date of this W ^

bulletin.

Report the results of the inspections, testing and evaluation i

/ W,C.;

U requested in Item 2 within 30 days after the inspection and testihg have been completed.

The response to Item 3'shall be submitted within 60. days of the issuance date of this Bulletin.

The results of the inspectiolis performed for Item 3 shall be submitted within 60 days after the completion-of the inspection.

The reports shall contain the following:

I a.

A description of the visual examinations and tests perfor.ed.

=d -

b.

Number of s'nubbers examined and tested.

Grouping by manufacturer f-(

name, model number, and size is acceptable.

c.

Number of failures identified; manufacturer name, model number, size, mode of failure, cause of failure, corrective action, snubber location, effect of failure on plant and system safety, and justification for continuing or resuming operation.

d.

The above information shall also be provided for the snubbers exempted by items Ic, 2c, and 3c above.

Actions to be Taken by the Followino Licensees Holdino Construction Permits:

Diablo Caryon Nuclear Power Plant Units 1 and 2; Grand Gulf Nuclear Station, R1 l

Unit 1; LaSalle County Station, Unit 1; Virgil C. Summer Nuclear Station, R1 Unit 1; and Susquehanna Steam Electric Station, Unit 1 shall perform the R1

.following:

R1 1.

After preoperational and/or hot functional testing and preceding fuel loading, visually examine and test the mechanical snubbers installed on

..i.

safety-related systems as follows:.

.a.

For all snubbers perform a visual examination for damage and verify

~

that the snubbers have freedom of mov'ement by performing'a manual test over the range of.the stroke in both compression and tension.

l

\\

l

m IEB 81-01, R;v. 1 f

March 4, 1981

- Page 6 of 6 b.

For INC snubbers, perform an operability test to. confirm that (1) activation (restraining action) occurs in both compression and tension and (2) the drag forces are within the specified

.p range in.both compression and tension.

The tests shall be performed on a representative sample.(10% of the total of this type of snubber in use in the plant or 35, which ever is less).

g/

For each snubber that does not meet the test acceptance criteria,'

r I woI an additional representative sample (as. defined above) of this type

- pMp of snubber shall be tested.

For each of these additional snubbers

/

that do not meet the test acceptance criteria, another representative g

sample of this type of snubber shall be tested.

This cycle shall be repeated until no more failures have been found or until all snubbers of this type have been tested.

The samples should be made up of, snubbers that represent the various sizes.,

c. ~ If my failures are identified in Items a or b above, take corrective action prior to fuel loading.

2.

The schedule for the inspections and tests requested in Item 1 above, sha.11

~

be submitted within 60 days of the issuance date of this bulletin.* The R1 results of the inspections, testing, and evaluation requested in Item 1 shall be reported to NRC within 30 days after the inspection and testing

,have been completed.

q..;

The reports shall contain the following:

u a.

A description of the visual examinations and tests performed.

b.

Number of snubbers examined and tested.

Grouping by manufacturer name, model number, and size is acceptable.

Number of failures ' identified; manufacturer name, model number, c.

size, mode of failure, cause of failure, corrective action, and snubber location.

~

Reports, signed under oath or affirmation, under the provisions of Section 182a of the Atomic Energy Act of 1954, si.11 be submitted to the Director of the appropriate NRC Regional Office and a copy shall be forwarded to the Director of the NRC Office of Inspection and Enforcement, Washington,. D. C.

20555.

.If you desire additional information regarding this matter, please contact the IE Regional Office.

Approved by GAO B-180225 (S81003) expires December 31, 1981.

t-

"The "issurance cate of tDis culletin" shall be considered to be tne dato R1

. of issuance of revision 1 for the following licensees holding construction R1 permits:

Diaolo Cnayon Nuclear Power Plant, Unit 2; Grand Gulf Nuclear R1 Station, Unit 1; LaSalle County Station, Unit 1; and Susquehanna Steam R1 Electric Station,_ Unit 1.

R1

rg y---

~

f

[/

~'

Attachment IEB 81-01, Rev 1.

- March 4, 1981

+

\\

RECENTLY ISSUED IE BULLETINS Bulletin No.

Subject Date Issued Issued To

'80-17, FaiiureofControlRods 2/13/81 All BWR facilities Supplement 5 to Insert During a Scram

~

with OL or CP

. 81-01 Surveillance of-1/27/81 All power reactor

~ ??~#

Mechanical' Snubbers

' facilities with 0L 74 9,,

& to specified

+1 facilities with CP

,( ' c;D80-25 Operating Problems with 12/19/80 All BWR facilities

' ~ ' ~

' Target Rock Safety-Relief

' Valves at BWRs-with OL &.specified near term OL.BWR f," ^' l I

facilities & all BWRs with a CP Supplement 4 Failure of Control Rads 12/18/80 To specified BWRs to 80-17 to Insert During a Scram with an OL & All at a BWR BWRs with a CP 80-24 Prevention of Damage 11/21/80

'All power reactor Due to Water Leakage facilities with E.1 Inside Containment S

(October 17, 1980 OL or CP Indian Point 2 Event) 80-23 Failures of Solenoid 11/14/80 All power reactor Valves Manufactured by facilities with Valcor Enginee' ring OL or CP Corporation 80-22 Automation Industries, 9/11/80 All radiography Model 200-520-008 Sealed-licensees Source Connectors 80-21 Valve yokes supplied by 11/6/80 All light water Malcolm Foundry Company, Ir.c.

reactor facilities witn OLs or cps l

l l

Supplement 3 Environmental Qualification 10/24/80 All power reactor to 79-01B of Class 1E Equipment facilities with an OL OL = 0perating License h,.

. CP = Construction Permit-l O

e

- +, -

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