ML20136J080
| ML20136J080 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/07/1985 |
| From: | Wilson R GENERAL PUBLIC UTILITIES CORP. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8601130178 | |
| Download: ML20136J080 (8) | |
Text
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GPU Nuclear Corporation Nuclear
- g = 888 Forked River,New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Nurnber:
November 7, 1985 Mr. Stewart D. Ebneter, Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Ebneter:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection Report 85-14 Attachment I to this letter provides our responses to the Notice of Violation and Notices of Deviation contained in Appendices A and B of your letter dated September 4,1985.
Due to the scope and complexity of the response, and the preparation required to respond to the SALP, this submittal has been delayed. The NRC Senior Resident Inspector has been kept informed of our progress in this area. By discussion and telecon an extension to November 8, 1985 was granted.
GPUN's preliminary responses to the concerns addressed by the identified Notice of Violation and Notices of Deviation were presented in a management meeting between the NRC staff and GPUN on May 20, 1985. This meeting was documented in IE Inspection Report 50-219/85-15. A second meeting was held on June 13, 1985 and documented in IE Inspection Report 50-219/85-19. As a result of this second meeting, a letter was sent from Mr. P. R. Clark, President - GPUN to Dr. Thomas E. Murley, Region I Administrator on June 14, 1985. A follow-up meeting between GPUN and the NRC staff on GPUN's completed and proposed corrective actions was held on June 25, 1985. This third meeting was documented in IE Inspection Report 50-219/85-22.
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1 GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation g
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I Mr. Stewart D. Ebnet:r, Director Division of R: actor Safzty Page 2 In the event that any additional comments or questions should arise, please contact Mr.'_ John Rogers of ray staff at-(609)971-4893.
Very truly yours, R. b
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F. Wils n Vice President Technical Functions RFW/JR/ dam (OlllA)
Attachments
. 'cc : Mr. Harry B. Kister, Chief Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region'I 631 Park Avenue King of Prussia, PA 19406 Dr. Thomas E. Hurley, Administrator Region I U.S. Nuclear Regulatory Comiss' ion 631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.
U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue, Phillips Bldg.
Bethesda, MD 20014 Mail Stop No. 314 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 L'
e ATTACHMENT I In response to IE Inspection 50-219/85-14, a project was establisned to verify both the seismic acceptability of the Oyster Creek Nuclear Generating Station piping and pipe supports, and the validity of the results obtained from the original 1979/1980 inspection effort. A field walkdown of piping and pipe supports produced two (2) significant and related results:
1.
The Oyster Creek piping within the scope of IE Bulletin 79-02/14 has no identified inadequacies, except as noted herein for the Emergency Service Water (ESW) System.
2.
Conclusions drawn from the original 1979/1980 effort were correct, but the effort was weak in scope and especially in the documentation of the specifics of the work which was accomplished.
Over 700 supports have been inspected to criteria which encompass and exceed those defined in IE Bulletin 79-14. Less than 2% of the inspected hangers have had discrepancies which required immediate repairs. Only one hanger was found which had significant deficiencies resulting in the implementing of Technical Specification time limits for repairs. A recent inspection of the ESW system identified the need for installing additional shims to minimize seismic gaps.
The 1985 reinspection effort is being conducted with fully approved procedures by personnel qualified to ANSI N45.2.6 (1978) including supplemental training in ASME section XI VT-3 or ASNT SNT-TC-1 A, (June 1980)
VT-3.
Discrepancies between the as-found plant and respective as-designed drawings are being identified and evaluated on three (3) levels. Firstly, a conditional evaluation of the individual support is performed for acceptability.
Secondly, an anchor to anchor analysis is performed for portions of piping systems to assure that no combination of adjacent or
-proximate hanger discrepancies affect the operability of the system.
Thirdly, a computer analysis of the piping system and detailed pipe support calculations will integrate all of the identified discrepancies to detennine the aggregate effect on an entire system.
The reverification program (and any responses to the identified IE Bulletins) is being conducted in accordance with a quality assurance program as outlined in the GPUN Quality Assurance Plan, Section 2.3.1.1.
Reinspections for IE Bulletin 79-14 are now completed inside the drywell with the exception of certain Recirculation Piping and pipe supports and outside the drywell with the exception of 5 supports and associated piping on the ESW system below the intake structure. The remaining Recirculation pipe and pipe supports are scheduled to be reinspected during the llR refueling outage, currently planned to commence in April 1986. Refer to GPUN letter R. F. Wilson to S. D. Ebneter dated October 28, 1985. The remaining ESW pipe and pipe supports will be completed prior to restart from the 10M outage. The reverification for IE Bulletin 79-02 will commence following the 10M outage and is scheduled to be completed prior to restart from the llR outage.
Violaticn:.
Criterion III of Appendix B to 10 CFR SO requires the establishment of measures to assure that applicable regulatory requirements and design bases for important to safety structures and components are correctly translated into specifications, drawings, procedures and instructions.
Section IV, Part 1, Subsection A, of Revision 2 of the Jersey Central Power and Light / General Public Utilities (JCP&L/GPU) Operational Quality Assurance. Plan, the plan in effect at the time of the work, states, in part, "the Manager-Generation Engineering is responsible for controlling design work and administering the design control activities relating to modification or addition of structures, components, and systems."
Section X, Part 1, Subsection F, of Revision 2 of the JCP&L/GPU Operational Quality Assurance Plan stated, in part, "the Manager-Generation Engineering is responsible for the issuance and approval of specification, drawings and installation requirements associated with modifications and additions..."
Contrary to the above, activities relating to IE Bulletins 79-02 and 79-14 were performed either:
(1) with no documented engineering procedures and specifications, or (2) witn procedures and instructions which were not controlled in accordance with the Operational QA plan.
Examples of the first category include: Calculation No. 8.13.309 -
tnermal expansion analysis of line No. 6-ND-10; Calculation No. 8.31.208
- containment spray system pipe support calculations; calculation for thermal analysis of emergency condenser line 10-NE-S from the reactor to NE01-A, B.
Examples of the second category include: Field walkdown check list for implementation of IE Bulletin 79-14; 80-44 procedure for the modification and repair of pipe supports; 80-4S procedure for the relocation of pipe supports; PP-001 procedure for the implementation of IE Bulletin 79-14; Special Procedure No. 79-31 for inspection, test and installation of concrete expansion anchor bolts in seismic piping systems at OCNGS.
This is a Severity Level IV-violation (Supplement 1) applicable to License No. DPR-16.
Response
GPUN concurs in the violation.
1.
. Corrective actions which have been taken and the results achieved:
a.
GPUN has contacted Burns & Roe, Oyster Creek Nuclear Generating Station's Architect / Engineer, and acquired copies of documents and records relating to the 1979/1980 IE Bulletin 79-02, 79-14 field walkdown and seismic acceptability verification. The procedures and specifications which were utilized during the original 1979/1980 effort are now available.
b.
Specific criteria and procedures relating to the 1985 reverification effort for piping and pipe supports have been drafted by GPU Nuclear and reviewed by the NRC. These procedures are currently either approved and in use, or are in the final review and approval cycle.
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- c. _ All checklists and marksd up drawings related to or resulting from the 1985 field walkdowns have been indexed and retained
- to provide the requisite documentation of.the reverification -
effort.
2.
Corrective actions which will be taken to avoid further violations:
a.
Pipe. support specifications and acceptance criteria are being formalized and will. be approved and released through the Engineering Design and Configuration Control (ED&CC) document control system.
- Date when full compliance will be achieved: Scheduled to be released in November 1985 b.
Anchor bolt testing specifications and acceptance criteria are being formalized and will be approved and released through the ED&CC document control system.
- Date when full compliance will be achieved: Scheduled to be released by Myember 15, 1985.
c.
Configuration control piping isometric drawings will be generated and GPUN procedures will be revised to assure future system modifications have documented and readily retrievable
- design basis calculations ~ and drawings supporting the as-installed plant configuration.
- Date when full compliance will be achieved: Presently
. projected to have: 1) a realistic estimate of the scope of the redrawing effort; and 2) a draft schedule for completion presented to GPU Nuclear upper management for funding, by
. August 31, 1986. This date is contingent upon the actual completion dates of the 1985 reinspection sub tasks. Further, an. interim program to control piping and pipe support design will be in place to support the llR outage.
. Deviation No.1:
Action Item No. 4 of IE Bulletin No. 79-02 specifies a design requirement verification for each concrete anchor bolt with respect to anchor bolt preload, design size and type, and proper installation.
If these requirements cannot be met from existing quality control documentation, a testing program should be initiated to assure that each seismic category I system will perform its intended function. This action item suggests two sampling techniques for testing of concrete expansion anchors. The licensee s-IE Bulletin 79-02 response dated July 6,1979, states, "An in-plant inspection and test program has been initiated to verify proper anchor bolt installation and correct size and type." It also states, "The test metnod involves a pull test of the anchor bolt to a minimum test load of 125% of the calculated bolt design load. The sampling technique being used is the first method listed in Appendix A of the supplement to the bulletin", i.e. testing one bolt per base plate. -
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- C:ntrary to th2 abava information centain2d in Attachment 8 of Burns C
and Roe document " Review of Confcrmance to USNRC IE Bulletins 79-02 and 79-14" indicates that bolts were. tested on only seven of the twelve seismic Category I piping systems. The five systems which were excluded from the anchor bolt testing were the Cleanup Demineralizer, Control Rod Drive, Feedwater, Main Steam and the Shutdown Cooling Systems.
' Therefore, the functionality of these five untested systems was not assured. - Furthermore, the anchor bolt testing on the seven tested systems was neither conducted-according to the first sampling method proposed by the bulletin and committed by the licensee in the July 6, 1979 response, nor according to the second sampling method which requires a _ statistical sampling of anchor bolts on each safety related system such that a 95 confidence level is provided to establish an evidence of operability of these systems.
Response
. Notice of Deviation No. I contains an error. Although JCP&L originally proposed inspecting twelve safety related systems, subsequent evaluations in 1979 determined that one system (Reactor Building Closed Cooling Water) was not a safety related system. This yields a total scope of eleven systems. These systems are: Liquid Poison, Shutdown Cooling, Core Spray, Isolation Condenser, Emergency Service Water, Control Rod Drive / Scram Discharge Volume, Containment Spray, Feedwater, Main. Steam, Cleanup Demineralizer, Recirculation. JCP&L notified the USNRC of our intent not to test the five systems identified in Notice of Deviation No. 1'due to'the high success rate of the seven tested systems by letter dated December 7,1979. GPUN was not notified by the USNRC of the unacceptability of this decision until May 1986.
GPUN concurs in the deviation.
1.
Corrective actions which have been taken and the results achieved.
The IE Bulletin 79-02 records resulting from the original 1979/1980 inspection effort have been acquired from the architect / engineer and reviewed for completeness and adequacy of record traceability.
Although the majority 'of work which was performed is accurate, an expanded scope of reinspection has been planned and is in the final stages of development prior to implementation.
2.
Corrective actions which will be taken to avoid further deviations, a.
Completion of the requisite anchor bolt and baseplate inspections will be conducted to verify their acceptability.
- Date when full comformance will be achieved: The reinspection is presently projected to be completed prior to restart from the llR refueling outage.
b.
Individual anchor bolt pull tests will apply a load equal to or greater than 125% of the calculated tensile loads and determine the acceptability of slip behavior in this range (less than 1/8" slip for shell type anchors and less than 3/8" for wedge type. anchors). These specifications will be controlled and proceduralized.
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. Data when full comformance will b'n achieved:. = The specifications are presently. scheduled to be approved and
. issued by November 15, 1985 Deviation No. 2:
IE Bulletin 79-14 states that the licensee should as'sure that seismic analyses of safety related piping systems accurately reflect the as-built configuration of the plant. The design specifications, drawings,.and other data used for these analyses should be considered in this investigation. Among the bulletin statements are the following:
Identify the piping system parameters which were input into the seismic analyses.
Identify the specific design document from which values of these parameters were obtained for the seismic analyses.
Establish acceptance criteria which as-built values of the parameters must meet.
.In addition, action items No. 2 and No. 3 require that, for each safety related system, the licensee should verify by physical inspection that the inspection elements meet the acceptance criteria.- In the August 31, 1979, and the February 22, 1980, letters to the USNRC, the licensee provided reports of inspections conducted at the plant in accordance with the IE Bulletin 79-14.. These reports state, "The inspection consisted of comparing the as-found condition of piping, valves, s'upports, and restraints with the design documents used as input to the seismic analysis." The licensee also provided the scope of what would be considered in the inspection with a general summary.
-Contrary to the above:
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No specific design documents applicable to the seismic evaluation of as-built safety related piping could be located.
Although an inspection checklist.was established, it provided only one acceptance criterion regarding hanger' location which was not substantiated by analysis. The enecklist presented was not sufficiently' complete to compare the as-found conditions with a specific acceptance criteria. -In' addition, no evidence was provided, during the inspection, to show that the checklist was applied in a controlled and consistent manner.
Furthermore, the licensee did not provide, during the inspection, such documentation as marked-up walkdown drawings, field inspection data sheets or other first generation documents resulting from a physical inspection.
Response
GPUN concurs in the deviation.
1.
Corrective Actions which have been taken and the results achieved:
i a.
Th; identified missing documentation was acquired from the architect / engineer and evaluated for completeness and acceptability. All first generation documents resulting from the original field walkdown are available for inspection and
- audit, b.
Two GPUN specifications, SP-1302-12-208 "1985 IE Bulletin 79-02/14 Inspection Program Design Input for Piping Stress Analysis" and SP-1302-12-212 "1985 IE Bulletin 79-02/14 Inspection Program Design Input for Piping Support", have been originated identifying tne design document applicable to the seismic analysis and are presently in the review and approval cycle.
c.
All inspectors and maintenance personnel involved in the 1985 reinspection effort have received training in the use of the inspection procedures and detailed explanations of the acceptance criteria.
2.
Corrective actions which will be taken to avoid further deviations:
a.
The 1985 inspection criteria exceed those required by IE Bulletin 79-14 and have been well documented and approved.
They will be indexed and filed with the respective reinspection packages.
- Date when full conformance will be achieved - The identifed documents will be placed in duplicate storate as they are completed, presently projected, except for Recirculation Piping supports, for after the llR refueling outage, b.
Marked up first generation field walkdown copies of records will be retained in duplicate storage as they complete the review and approval cycle.
- Date when full comformance will be achieved - All records will be indexed and stored after tney have received final approval, presently projected for after the llR refueling outage.
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