ML20064N788

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Responds to NRC Re Violations Noted in IE Insp Repts 50-315/82-07 & 50-316/82-07.Corrective Actions:Util Reviewed Consultant Procedures for Analysis in Effect at Time Work Was in Progress & Conducted Audit
ML20064N788
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/29/1982
From: Hering R
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20064N598 List:
References
AEP:NRC:0691A, AEP:NRC:691A, IEB-79-14, NUDOCS 8302160338
Download: ML20064N788 (5)


Text

INDIANA & MICHIGAN ELECTRIC COMPANY 3

P. O. BO X 18 BOWLING GREEN STATION N EW YORK, H. Y.10004 October 29, 1982 AEP:NRC:0691A Donald C. Cook Nuclear Plant Unit Nos. I and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE INSPECTION REPORTS No. 50-315/82-07 AND NO. 50-316/82-07 Mr. James G. Kept ler, Regional Administrator U.S. Nuclear Regulatory Cottmission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Reference:

Letter No. AEP:NRC:0691 Dated June 7,1982

Dear Mr. Keppler:

This letter and its Attachment are the interim repovt on the verification program being performed in rerponse to Item 1.C of the subject Inspection Report. The final report will be submitted by January 31, 1983 as noted in the above reference.

This document has been prepared following Corporate Procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

1 Very truly yours,

/NA~;

/os R. F. Hering Vice President ec: John E. Dolan - Columbus R. S. Hunter M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff i

Joe Williams, Jr.

NRC Resicent Inspector at Cook Plant - Bridgman 8302160339 830211 PDR ADUCK 05000315 G

PDR NOV 1 082 j

Heat Removal - Pump Disharge System in the Auxiliary Building), was affected.

Correction of the code error resulted in higher loads on two supports. These higher loads are within the allowable limits of the hanger. No changes to the hangers are required and the affected drawings have been updated to show the revised loading.

References:

(1) Letter No. AEP:NRC:0691 Lated June 7, 1982 (2) Letter Nc. AEP:NRC:0691A Dated October 29, 1982 e

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Attachment to AEP:NRC:0691A 1.0 Introduction The following actions have been taken in order to ensure that all outside vendors who performed calculations for AEPSC as part of the IEB 79-14 cffort, did so under.a QA program comparable to that existing in AEPSC for the same purpose:

a)

AEPSC has re-reviewed the consultant's procedures for analysis which were in effect at the tt=c the work was in

progress, b)

Tbc qualifications of personnel who performed the work have been reviewed.

c)

An audit was conducted to ver,1fy that calpulational procedures were followed and that problem inputs and outputs are correct.

The above three actions have bcon carried out for the four outside consultants discussed in IE Reports No. 50-315/82-07 and No.

50-316/82-07, i.e. ATI, EDS, Harstead and Teledyne.

The following list of problems were randomly selected and audited as per (c) abovie to verify that they were performed in an acceptable manner.

Firm Performing Problem No.

_ System Identification The Analysis 1-030 Containment Spray EDS 1-111 Essential Service Water EDS 2-146 Essential Service Water EDS 2-154/154X Reactor Letdown & Charging EDS 1-055 Component Cooling Water ATI 1-207 Chemical & Volume Control ATI 2-274 Reactor Coolant Temp. Instrumentation ATI 2-1013 Hydrogen Skimmer ATI 1-136 Auxiliary Feedwater Telodyne 1-133 Auxiliary Feedwater harstead The nunber of problems audited for each consultant to consistent with Mr. I. Yin'a recommendation.

2.0 Verification Program Discussion and Resultc As explained in Section 1.0, the purpose of this program was to ensure that our concultants had performed their calculations following acceptable QA ptccedures and to verify the results in a selected sample.

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a) During the original IEB 79-14 re-evaluation progran, EDS cocrdinated their work with AEPSC in accordance with approved

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instructions. EDS performed the couputer re-analysis of those s

problems evaluated by their team, following instructions 1

entitled "D. C. Cook Plant NRC. Bullatin 79-14 Reanalysis".

EDS evaluated pipe supports following instructions entitled

" Criteria and Procedure for Evaluation of Supports and Restraints for Donald C. Cook Nuclear Plant." These instructions are in our files, have now baan re-reviewed and l

found to be acceptable in accordance with AEPSC criteria. The final reports of tha other thras consultants contained specifications that were applied during their analysis work and which are consistant with the AEPSC requirements for such work. During the period when the work was being performed, we held meetings, provided verbal instructions and discussed the problems and progress via frequent telephone conversations with these consultants. AEPSC design specifications, original stress summary and load summary sheets were provided to these consultants at the start of their evaluation program. This documentation provided our consultants with the design requirements.

We are now in the prccess of securing written stataments from the above consultants stating that they did follow our criteria for re-analysis when performing the original IEB 79-14 analyscs. These written statements will be documented as part of the I.E.Bulletin 79-14 program in Procedure No.

79-14-5A, " Procedure and Specifications for Consultants for Piping System Salacted for Computer Re-analysis".

b)

Personnel qualifications were found to be adequate for all consultants.

c)

The ten problems noted in Section 1.0 were each verified in accordance with AEPSC Procedure No. 79-14-10 ar.a found to have incorporated proper calculational proceduras.

Input and output were found to be acceptable. Details of each verification are documented with the exception of supervisory approvals which are in progress.

Small variations were fc2nd in the analyses and are noted below:

1)

In most cases design temperature was used in the thermal analysis instead of the system operating temperature.

Use of these values produced conservative results.

2)

In one case a deviation of 23% in the pipe unit weight input was found. This isolated case was due to the weight of the insulation which was based on the design temperature (650,F) instead of the operating temperature (130 F).

Input of this larFer mass value gave conservative results.

3)

Small root valves for vents and drains were omitted from the analyses by ATI, based on the typical industry

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practice for systems built to ANSI 331.1 1967 code.

Discussions with ATI disclosed that engineering judgement was used to evaluate the impact of thess appendages in each particular case, and that omitting them does not have any significant effect on the main system.

AEP's verification concurs with this engineering judgement.

4)

For dead-weight analyses, EDS did not include horizontal restraints. This followed the practica established for the original analyses, which was based on the L

industry-wide approach of installing piping by " hanging" on vertical supports and then adding the horizontal restraints afterwards. While this is not typical of current practice, the effect on the anslytical results is insignificant.

5)

In probism No. 1-030, EDS inputted an existent " gap" at a

" rigid" support to reduce thermal restraint effects in one location. This gave lower thermal stresses at that location than a conventional input, which assumes full rigidity at all " rigid". supports. EDS considers that this will not adversely (a,ffect the, pipe stress analysis.

We consider all these variations to hava no effect on earlier results and, therefore, consider at this point that the consultants' work was performed in an acceptable way. A final report will be transmitted to you by January 31, 1983.

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