ML20042F320
| ML20042F320 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/25/1990 |
| From: | Clay Johnson, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20042F317 | List: |
| References | |
| 50-298-90-15, NUDOCS 9005080165 | |
| Download: ML20042F320 (8) | |
See also: IR 05000298/1990015
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APPENDIX _B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-298/90-15
Operating License: DPR-46
Docket: 50-298
Lice.nsee: Nebraska Public power District (NPPD)
P.O. Box 499
Columbus, Nebraska 68602-0499
Facility Name: CooperNuclearStation(CNS)
Inspection At: CNS..Brownv111e, Nebraska
Inspection Conducted: March 26-30, 1990
Inspector:
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4/2f/90
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C. E. Whnson, Reactof Inspector, Plant
Da".e
Systems Section, Division of Reactor Safety
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Approved:
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f/2f/90
T. F. Stena, Chief, Plant Systems Section-
Date
Division of Reactor Safety
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Inspection Summary
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Inspection Conducted March 26-30,1990(Report 50-298/90-15)
Areas Inspected:
Routine, unannounced inspection of safety-related piping supports
and restraint system _ testing and review of the pipe support qualification program.
Results: One violation was identified in paragraph 2.2.3 involving a failure to
comply with the intent of the American Society of Hechanical Engineers (ASME) code
requirementspertainingtotheSectionXIinserviceinspection(ISI) program
for Class 3 nonintegral component supports. This finding indicates a weakness
in the ISI program. Management-involvement should be increased in the ISI area
to assure that required ~ASME code requirements are met and interpretations of
those requirements are adequate.
Review of the pipe restraint (snubber) program indicated that this program is
adequate and encompasses all requirements.
The pipe support qualification program is-a well planned and organized effort
which is considered a strength in the upgrade of safety-related pipe supports.
9005080163 900430
{DR
ADOCK 05000298
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DETAILS
1.
PERSONS CONTACTED
' *Y. Armstrong, Administrative Secretary
- R. Beilke, Radiological Support Supervisor
- B. Crow, Lead Mechanical Engineer
B. Frehrman, Project Manager, Pipe Supports
- J. Flaherty, Engineering Manager-
- S. Freborg . Assistant Plant Engineering Supervisor
- R. Foust, Engineering Program Supervisor
- R. Gardner, Maintenance Manager
- R. Gibson, Quality Assurance Supervisor
- B. Hall, Health Physicist
- G. Horn, Division Manager, Nuclear Operations
- J. Sayer, Radiological Manager
- R. Schultz, ISI/IST Engineer
- G. Smith, t.icensing Supervisor
NRC
- W. Bennett, Senior Resident inspector
- G. Pick, Resident Inspector
- Denotes those present during the exit interview conducted on March 30, 1990.
The inspector also interviewed other licensee employees during the inspection.
2.
TESTING OF PIPING SUPPORT AND, RESTRAINT SYSTEMS (70370)
The purpose of this inspection was to determine that adequate programs and
procedures are established in the area of safety-related pipe supports and
restraint systems for proper installation, examination, testing, surveillances,
and records retention and whether they are in compliance with regulatory
requirements. Technical Specifications (TS), and license commitments.
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2.1 PipeRestraint(Snubber) Program
2.1.1 Procedure Review
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The inspector reviewed seven procedures pertaining to inspection, operability,
removal and installation, disassembly and assembly, and the functional testing
of hydraulic and mechanical snubbers. These procedures contained adequate
-instructions and sufficient acceptance criteria. The inspector also reviewed
-TS Sections 3.6.H and 4.6.H, which provide instructions on limiting conditions for
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operation and surveillance requirements respectively. Procedures reviewed are
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listed in the attachment.
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2.1.2 Observation of Functional Testing
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The inspector observed the functional testing of two snubbers (mechanical and
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hydraulic). The operator performing the testing was knowledgeable of procedural
requirements and acceptance criteria. Observations by the insp3ctor indicated
that both snubbers met the drag test, activation test, and bleed rate. The
operator performing the test followed procedural instructions as required. No
deficiencies were observed.
Snubbers observed for functional testing were:
MS-SNUB-MS-S-9B; Serial No. 449
W/H; Serial No. 8086
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2.1.3 Field Observations
The inspector performed an independent visual inspection of various size
snubbers inside containment. Attributes that were selected for observations in
the visual examination were:
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Deterioration, corrosion, physical damage, or deformations were not
evident;
Threaded connections were secured by locknuts, fasteners, and cotter pins;
Snubber settings;
Extension rods, support plates, and connecting joints were not bent,
deformed, or loose; and
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All required bolts, locking devices, nuts, and washers were installed.
No significant deficiencies were identified.
The supports examined are listed in the attachment.
2.1.4 Records Review
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The inspector reviewed records of snubbers that were visually examined in the
field by NPPD, functional testing performed by NPPD, calibration records of the
functional test equipment, and surveillances of the snubber program conducted
during the refueling outage.
Records reviewed indicated the following:
Equipment was calibrated as required.
Surveillances are performed as required by TS.
Sample size was selected as required by TS.
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Functional test of snubbers were within established acceptance criteria,
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Identified deficiencies were noted end documented on the visual
examination records.
No deficiencies were identified.
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Records reviewed are listed in the attachment.
2.2 InserviceInspectionProgram(ISI)
2.2.1 Procedure Review
The inspector reviewed the following two procedures pertaining to visual
examinations of pipe supports and restraint systems included in the 10-year 151
plan (secondinterval). These procedures were written by General Electric (GE)
Nuclear Energy and included VT-3 and VT-4 visual examination attributes and
acceptance criteria.
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Visual Examination Procedure (VT-3), Revision 3, February 8,1988.
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VisualExaminationProcedure(YT-4), Revision 2, September 18, 1987.
Procedures reviewed by the inspector were adequate.
2.2.2 Visual Examination
The inspector observed GE inspectors perform their VT-3 and VT-4 inspections on
several supports included in the ISI plan for this outage.
In each case, the
GE inspectors performed the visual inspections in accordance with established
procedures. Any deficiencies identified were noted on the inspection
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checklist. Discussions with the visual examiners indicated that they were
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knowledgeable of the required inspection attributes and acceptance criteria.
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The inspector also performed an independent visual inspection of 151 supports.
Some supports examined by the inspector were not included for ISI inspection by
the licensee, The supports examined indicated no significant deficiencies.
Supports examined by GE inspectors and the inspector are listed in the
attachment.
2.2.3 ISI Program Review and Pipe Support Selection
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The inspector rev'iewed the 10-year ISI program and had several discussions
regarding program establishment, ASME code requirement commitments made in the
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Safety Evaluation Report (SER), and the selection process for pipe supports
examined under this program.
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As the result of these discussions and reviews, two concerns were identified.
The first concern was that the number of Class 1 supports selected for
examination appeared to be low in number. This concern ~was expreised to the
licensee. The licensee reviewed the inspector's concern and later determined
'that 20 supports were inadvertently omitted from the schedule for this outage.
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The 20 supports were then added for. inspection this outage. The inspector then
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questioned the number of supports selected the previous outage.
Following a
review, the licensee subsequently informed the insr,ector that the supports from
the previous outage were verified and that no other supports had been omitted.
Since this discrepancy was identified prior to the end of the second 10-year
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interval, the licensee was not considered to be in violation of the ASME code.
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As the result of this discussion, the licensee committed to add an engineering
checklist to a procedure that will preclude the inadvertent omission of
supports for future outages. This commitment will be considered an inspector
follovep item pending the addition and implementation of the checklist.
Inspector Followup Item (298/9015-01): Review the implementation of an
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engineering checklist to a procedere to preclude the inadvertent omission of
pipe supports in future outages.
The second concern raised by the inspector pertained to ASME Class 3 supports.
Review of the 151 program for the first and second 10-year interval indicated
that no Class 3 nonintegral supports were included in the program for VT-3
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examinations,
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Paragraph IV0-1220, " Items Exempt From Examination," winter 1980 Addendum,
addresses the exemption of " integral attachments" only.
It does not exempt
nonintegral attachments such as snubbers and other pipe supports.
Subsection IWF, paragraph IWF-1300 " Support Examination Boundaries," specifies
the support examination boundaries for both integral and nonintegral supports.
Paragraph IWD-2620. " Visual Examinations VT-3." specifies that component
supports and restraints within the boundary of each system specified in
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examination categories of Table IWD-2500-1 shall be subject to the Visual
Examination VT-3. This specification includes non %tegral supports. The
licensee has interpreted paragraph IWD-1220.2a and b, in conjunction with
interpretation X1-1-83-12R-2 to exempt integral and nonintegral attachments
from ASME code examination.
Further investigation by the inspector and several meetings with the licensee
indicated that the licensee had misinterpreted the ASME code requirements on
Class 3 nonintegral supports. A telephone conference call between the NRC and
licensee as held March 29, 1990, to discuss this issue. As the result of this
conference call the NRC informed the licensee that they had misinterpreted the
code requirements for Subsection IWD, " Requirements for Class 3 Components of
Light-Water Cooled Power Plants," winter 1980 Addendum, and that the ASME code
interpretation (X1-1-83-12R-2) did not apply in this case.
Failure to meet the intent of the ASME code requirements for the examination of
Class 3 nonintegral component supports is considered to be contrary to the-
requirements of Section XI of the ASME Boiler and Pressure Vessel Code and
Violation (298/9015-02):
FailuretoincludeASMEClass3(nonintegral)
component supports for examination in both the first and second 10-year ISI
program.
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3.
PIPE SUPPORT UPGRADE OVAL.lFICATION PROGRAM
The inspector received a complete overview and status of the pipe support upgrade
program by the licensee's project manager. The project manager informed the
inspector of the following:
As-built packages are 100 percent complete;
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Final drawing changes are in progress;
Pipe support stress analysis is 100 percent complete by their consultants;
NPPD's engineering has enmpleted 90 percent of the review of the
consultants analysis; and
Modifications are 30 percent complete.
The project manager informed the inspector that all operability concerns have
been taken into consideration pertaining to modification changes. This program
appears to be well planned and organized and is considered to be an enhancement
to the site's pipe support upgrade program.
4.
EXIT INTEPNIEW (30703)
An exit interview was conducted on March 30, 1990, with the licensee
representatives identified in paragraph 1.
During the interview, the inspector
reviewed the scope and findings of the inspection as discussed in this report.
Other meetings between the inspector and licentee management were held
periodically during the inspection period to discuss identified concerns. The
licensee did not identify as proprietary any information provided to, or
reviewed by, the inspector.
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ATTACHMENT
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Snubber Procedures
7.2.34.1, " Snubber Inspections," Revision 2, January 4,1990
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7.2.34.2, " Pipe Snubbers Removal and Installation," Revision 2, January 4,
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1990
7.2.34.3, "Grinnell Figure 200/201 Hydraulic Snubber Disassembly and
Assembly," Revision 1, November 9, 1988
7.2.34.4, " Pacific Scientific PSA-3 and PSA-10 Snubber Disassembly Overhaul
and Assembly," Revision 0, March 30, 1989
7.2.34.7, 'Grinnel Figure 200/201 Hydraulic Snubber Functional Test,"
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Revision 1, February 22, 1990
7.2.34.8, " Pacific Scientific Snubber Functional Test," Revision 1,
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February 8,1990
6.3.10.9.1, " Snubber Operability," Revision 16, September 7, 1989
S_nubbers Visually Examined (Independent)
VR-57B SerialNo.12644)
VR-512 SerialNo.6877)
VR-57A Serial No. 336)
RH-S8C SerialNo.8139M)
RH-S8A Serial No. 6997)
RH-58B Serial No. 5230)
VR-60-7-2(SerialNo.404)
VR-S23B (Serial No. 484)
VR-S32(SerialNo.17204)
VR-56 (Serial No. 17201)
VR-S24B Serial No. 5892
VR-S23A Serial No. 5887
VR-524A Serial No. 4884
RF-SIO Serial No. 15142
RF-S17 SerialNo.5891)
SS-3A2 Serial No. 338)
SS-382(SerialNo.5308)
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SS-3Al (Serial No. 5312)
VR-61-17-X(SerialNo.5310)
ISI Supports Examined (Independent)
RH-H123
VRH-64C
VRR-50-1.1
RF-H70
VR-G21
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t:S-132
RCC-H10
RH-H-32A
RH-H3-X225
VRS-27
VPS-13-1A-1
VR-56-24-X
H-4
VRR-30
H-9
VRH-53
VRS-915
ISISupportExaminationsObserved(GEVT-3 Examination)'
RR-H7-6
RR-H7-A
RF-HIS
Functional Test Records Reviewed
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Hydraulic Snubbers (Grinnell)
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RHR-SNUB-RH-S43(SerialNo.10058
RHR-SNUB-RH-S78A (Serial No. 8565
RHR-SNUB-RH-523 (Serial No. 10053
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RHR-SNUB-BS-S116B(SerialNo.8075)
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CS-SNUB-CS-51(SerialNo.10062)
MechanicalSnubbers(PSA)
RF-SNUB-RF-59 (Serial No. 456)
MS-SNUB-MS-S63 (Serial No. 463)
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MS-SNUB-VR-S1 (Serial No. 17207)
MS-SNUB-VR-60-7-X(SerialNo.15144)
MS-SNUB-VR-62-8-2(SerialNo.406)
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