IR 05000346/1985031

Insp Rept 50-346/85-31 on 850909-18.Violations Noted:Failure to Establish Procedure to Delineate IE Bulletin 79-14 Design Interface Between Bechtel & ITT-Grinnell Corp & to Implement Facility Change Request Sys

ML20138F056
Person / Time
Site:	Davis Besse
Issue date:	10/11/1985
From:	Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138F022	List: IR 05000346/1985031 ML20138F019 ML20138F034
References
50-346-85-31, IEB-79-14, NUDOCS 8510250173
Download: ML20138F056 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/85031(CRS)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 -

Inspection At: Davis-Besse Site, Oak Harbor, 0H Bechtel Power Corporation, Gaithersburg, MD (Bechtel)

Inspection Conducted: September 9-11, 1985 at Site September 16-18, 1985 at Bechtel

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Inspector: I. T. Yin /0llll?f Date Approved By: D. H. Danielson, Chief '8 "!M Materials and Processes'Section Date Inspection Summary 5)ecial Inspectio.n f rom Se-)tember 9 through .18,1985 (leport No. 50-356/85031(DRS))

Areas Inspected: Special, announced inspection of the auxiliary feedwater-pump turbine steam supply (AFPTSS) piping _ restraint and structural damag The inspection involved a: total of 34 inspector-hours onsite and at the A-E's office by one NRC inspecto Results: Within the areas inspected, two violations were identified:

(failure to establish a procedure to delineate the IE Bulletin No. 79-14

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design interface between Bechtel and ITT-Grinnell Corporation - Paragraph 5; failure to effectively implement the Facility Change Request system which ,

resulted in corrective actions not being conducted in a timely manner - j Paragraph 6). '

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DETAILS 1. Persons Contacted Toledo Edison Company (TECo)

S. M. Quennoz, Group Director - Nuclear Engineering

• C. L. Mekbel, Civil Structural System Engineer

• P. H. Straube, Senior Engineer

• J. K. Wood, General Supervisor, ~ Facility Engineering T. D. Murray, Assistant Vice President Nuclear

• D. R. Wuokko, Nuclear Licensing Supervisor L. F. Storz, Plant Manager C. T. Daft, QA Director J. Helle, Director, Nuclear Facility Engineering

• R. F. Peters, Jr. , Nuclear Licensing Manager

• S. Osting, Senior Assistant Engineer

• T. J. Myers, Director, Nuclear Safety and Licensing

• D. J. Mominee, QA Superviso Bechtel Power Corporation (Bechtel)

• J. W. Fay, Project Manager R. Kies, Engineering Supervisor

• E. J. Ray, Project Engineer

• V. Marathe, Assistant Project Engineer D. O'Reilly, Mechanical Engineer M. Tolani,. Stress Group Leader R. Zeigler, Civil Engineer J. M. Ogle, Civil Group Supervisor C. H. Abutaa, Pipe Support Engineer M. S._ Wasserman, Mechanical Group Supervisor N. L. Lee, Engineering Supervisor C. M. Foltyn, Project Engineer N. Kalyanam, Assistant Chief Engineer CER Corporation L. O. Ramsett, QA Consultant USNRC - Region III (RIII)

• C. J. Paperiello, Director, Division of Reactor' Safety _(DRS)

• J. J. Harrison, Chief, Engineering Branch, DRS

• D. H. Danielson, Chief, Materials and Processes Section, DRS B. Burgess, Project Inspector

• W. G.. Rogers, Senior Resident Inspector, 0. Kosloff, Resident Inspector-

• Denotes those attending the management exit meeting on September 18, 1985

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2. Action on Previous Inspection Findings

(0 pen) Unresolved Item (346/85013-04): Unidentified pipe support damage could have occurred in other systems that are designed for infrequent use but are subjected to periodic testing. As a result of discussions with Region III and as set forth in a TECo letter to RIII (Serial No. 1-540),

dated June 14, 1985, the licensee selected the (1) LPI, (2) HPI, (3) auxil-iary feedwater pump discharge, (4) AFPTSS crossover legs, and (5) auxiliary feedwater pump turbine steam exhaust piping systems for verification inspection and evaluation. The total number of piping supports and restraints to be inspected was estimated to be 775. The inspector reviewed TECo Nuclear Facility Engineering Division (NFED) Inspection Plan, No. IP-M-001, "The Piping Support Inspection and Verification Program,"

Revision 0, dated August 26, 1985, and had no adverse comment The inspection and evaluation status, as of September 17, 1985, was as follows:

• Out of 356 supports inspected, 337 Nonconformance Reports (NCRs)

have been or will be writte * NFED received 225 NCRs for evaluation, among which (1) 34 NCRs were determined to be acceptable as is, (2) two supports required minor modification - one required shimming; one required snubber bolt tightening, (3) 114 NCRs were being evaluated in detail, and (4) the remaining 75 have not been evaluate * A TECo letter to RIII (Serial No. 1-571) dated September 6, 1985 (a weekly report on inspection findings) documented NCRs written as of September 3, 198 The inspector selected a large number of NCRs for review at the site and noted that there were numerous pipe support welding and configuration deficiencies QC inspection did not identify during plant constructio Further followup on this unresolved item is planne (Closed) Unresolved Item (346/85013-05): TECo was requested to establish a piping system operability evaluation program to determine the cumulative effects of the identified AFPTSS pipe support damage. See Paragraph 3 for detail . AFPTSS System Operability Review of TECo and Bechtel Programs The inspector reviewed TECo Intra-Company Memorandum (ICM)

(File 0294), " Piping System Operability Evaluation and Use of Interim Allowables," dated September 6,1985 at the site on September 10-11, 1985. The inspector had the following comments:

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(1) The program should delineate the nature and the cause of the identified defect / damage and whether or not it resulted from normal system operation, transient ;oading, structural inter-ference, or other adverse condition (2) After the possible cause of the defect / damage is determined, a controlled followup inspection that is tailored to the identi-fied findings should be develope (3) This special inspection should be completed in a timely manner to facilitate a system cumulative evaluation to determine system operabilit (4) Within 30 days after the first defect / damage is identified, TECo should complete Items 1 through 3 above. The evaluation should include proposed measures to preclude recurrence. TEco should submit a LER in accordance with the requirements of 10 CFR 50.7 (5) The program should require the damaged system to be restored to its original or SAR condition within the Technical Specification time limitation. If this can not be accomplished, TECo should report the situation to the NR During this inspection at Bechtel on September 17-18, 1985, the inspector reviewed the revised ICM (File 0294), dated September 13, 1985, and observed that the above comments were incorporated in the progra As a result of this review, the inspector noted that the following two items should be included in ICM (File 0294).

(1) Interim pipe stress allowables should be used in conjunction with Safe Shutdown Earthquake (SSE) analysi (2) Bechtel interim component and equipment acceptance criteria should be deleted from or stated as being such in the TECo progra The TEco staff stated that ICH (File 0294), including the above comments, would be incorporated into a NFED procedure during the week of September 22, 198 During this inspection at Bechtel, the inspector also reviewed Bechtel MGP-04, " Procedure for Control of Interim /Short-Term Allowable Stress Criteria for Seismic Category 1 Piping Systems at Davis-Besse Nuclear Power Station, Unit 1," dated August 16, 1985, and had the following comments:

(1)- MGP-04 should reference the TEco operability evaluation program as being the controlling documen (2) Revise the procedure, such as Paragraphs 4.0 and 5.4, to alle-viate conflicts with the TECo program provision . __ _ . __ _ _

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a l b. Review of Bechtel Evaluation Methodology The inspector reviewed the above subject matter for technical and programmatical adequacy. Areas reviewed included:

(1) Support Damage The determination of modeling of damaged supports in a piping stress analysis was based on

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(a) The stress criteria including engineering judgement, hand

calculations, and STRUDL computer runs.

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(b) The deflection criteria stated that support stiffness will be included in the piping stress analysis when the deflection exceeds 0.0625".

(2) Support Load Increases ,

'The Bechtel in-house review program requires evaluation of load

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increases on undamaged hangers.

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(3) Equipment Nozzle Load Increases The stationary and rotary equipment nozzle interim stress criteria were documented in a Bechtel interoffice memorandum from the Chief Mechanical Engineer to Plant Design Supervisors and Stress Group Leaders, dated May 2, 198 This memorandum was also incorporated into a controlled Stress Group News Letter No.-37, " Nozzle Loads," dated September 3, 198 No violations or deviations were identified as a result of the revie c. Review of AFPTSS Operability Evaluation (1) Hanger Damages and Deficiency Evaluations RIII Inspection Report No. 50-346/85013, Paragraph 11, Tables 1

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and 2, documented a summary of Train 1-1 and Train 1-2 evalua-tions. Within the Tables, a number of hanger deficiencies that involved excessive gaps between the baseplates and the structure were judged by Bechtel engineers to be acceptable; however, calculations were needed to confirm their judgement. During this inspection at Bechtel, the inspector was informed that all backup calculations were performed and the gap deficiencies were

found to be acceptable. The inspector randomly selectea the

following hanger calculation packages for review

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Train N Hanger NA Bechtel Operability Calulation 1-1 H9 C8-41A-3 4 9/16/85

. 1-1 H22- C8-41A-1

9/13/85 i 1-1 H148 C13-408-3 i 9/16/85

1-2 H52 C3-40A-6 -

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1-2 H55 C13-408-4 9/16/85

) No violations or deviations were identified as a result of the

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(2) Piping Operability Stress Analysis Using the established AFPTSS support damage database, the piping ,

system was determined to be in its worst condition (in terms '

of-support damage and deficient conditions) on and prior to-March 17, 1985. The following four Bechtel piping stress

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analyses representing these conditions were reviewed by the inspector:

I' * 40A (C4), " Main Steam System", dated June 26, 1985,  ;

modeled A3 (Trains 1-1 and 1-2), H49 (Train 1-2), and

, H50 (Train 1-2) to be inactiv * 40B (C9), " Main Steam System", dated May 29, 1985, modeled

- A3 (Trains 1-1 and 1-2), H66 (Train 1-1), EBD-20-H1

(Train 1-1), H142 (Train 1-2), H144 (Train 1-2), and H147 t

(Train 1-2) to be inactiv * 41A (CS), " Davis-Besse Steam Supply", dated June 26, 1985,

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(a) H14 (Train 1-1), H32 (Tra.n 1-1), and H34 (Train 1-1)

to be inactive.

. (b) H28 (Train 1-1), and H34 (Train 1-1) to be inactiv * 120F (C2) " Main Steam System", dated July 6, 1985 modeled

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H131 (Train 1-1), H132 (Train 1-1), and H133 (Train 1-1)

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Subsequent to the review, the inspector commented:

• Pipe anchor Al is the connecting point for the Bechtel stress analyses 408 and 41A. The overloading of Al or overstress of the piping at Al could cause Train 1-2 to be inoperabl Since 41A (C5) was not in the most conserva-tive analytically modeled condition, Bechtel should rerun the analysis modeling H14, H28, H32, and H34 to be inactive in a single computer run. 41A (C10) was rerun and approved by Bechtel on September 16, 1985. The Al and piping stresses were not affected due to its remote distance from the damaged support * A snubber at A200 and Snubber H59 modeled in 40B (09) were observed to be located very close to a rigid anchor poin The ability for a snubber to lockup during dynamic loading conditions depends on the shaft being able to travel. The restriction of snubber shaft travel due to its close proximity to a rigid anchor could impair the snubber lockup and load carrying capability. To investigate the effect, 40B was rerun on September 17, 198 The snubber displace-ments during the SSE event were calculated to be 0.043" for A200, and 0.045" for H59 and thus they were considered inoperable. However, even without these two snubbers, the Turbine 1-2 nozzle stress was calculated to be 4282 psi which is within the Bechtel interim stress acceptance limit of 6000 psi. Bechtel engineers further indicated that the system was considered to be safe based on:

(1) The piping analysis used 0.5% damping which was extremely conservative. The NRC-NRR has approved TECo's request to use 5% damping for future analysis conducted in accordance with ASME Code Case N411 provisions, and (2) TECo is planning to conduct a snubber optimization program to remove all inoperable and unnecessary snubber The inspector concurred with Bechtel's analysis and conclusion (3) Evaluation Conclusions Bechtel completed the AFPTSS operability analysis and reported their conclusion to TEco in a letter (BT-15570), " Operability Evaluation Main Steam to AFPTs," dated July 26, 1985. The conclusion was verified by the NRC inspector using the recently developed program discussed in Paragraphs 3.a and 3.b abov The evaluation showed the AFPTSS Train 1-1 to be inoperable up

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to March 17, 1985;.however, Train 1-2 was within the FSAR design /

operating condition during this time. For details, see Para-graph 4 below. Since the identification of the H 28 damaged condition (a major contributor to the Train 1-1 inoperable condition) on March 14, 1985, to when repair was completed on March 17, 1985, which restored Train 1-1 to system operable status, the_ plant Technical Specification requirements were not violate . RIII Questions and Licensee Responses RIII questions relative to the AFPTSS suspension system damages are

included in RIII Inspection Report No. 50-346/85013, Paragraph 1 TECo responded to all questions, except questions c, d, and f in this inspec-tion report. TECo responded to questions c, d, and f during this inspectio Question c

In view of the large number of damaged supports observed in the AFPTSS System, did piping stress exceed FSAR commitments and/or IE Bulletin 79-14 operability criteria?

AFPTSS Train 1-1

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• Inoperable for undeterminable amount of time prior to March 17, 1985 due to support damag ,

• FSAR limits were exceeded.

l * Interim IEB 79-14 limits were exceeded.

j 3 AFPTSS Train 1-2

• Operable with damaged support * FSAR limits on piping were not exceeded.

j * FSAR limits on Turbine 1-2 and pipe anchor A3 were i exceeded, but were within the IEB 79-14 and Bechtel

specific interim stress limit!..

Question d: If the answer to Item (Question) c is affirmative, were there instances where the piping overstress was in other than seismic condition?

Seismic design conditions were always included when piping stresses were compared to the SAR and IEB 79-14 criteri To comply with the Code, seismic stresses are combined with primary stresses (such as weight, etc.) within the piping system and evaluated against the Code allowabl Secondary '

stresses, such as thermal expansion stresses, were at all times within the Code allowabl ,

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Question f: Were composite studies completed to evaluate all of the presently occurring transients?

Yes, composite studies were done in two phases. The first phase considered support damages which could have been present prior to March 1, 1985. The second phase added baseplate gaps to the first phase operability analysi In support of the piping stress analysis, detailed QC inspections were performed. The support deficiencies and

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damage identified through NCRs and surveillance reports were evaluated. Gaps between baseplates and walls were evaluated where applicable. As a result of these baseplate gap evaluations, project criteria for evaluating and accepting baseplate gaps were develope A program to evaluate the cumulative effects of multiple support damage was also developed and implemented by TECo and Bechte All hangers found to be defective will be restored to their design /SAR condition prior to startup of the plan . IEB 79-14 Design Evaluation Interface

! Ouring review of the Bechtel support damage evaluation (Paragraph 3.c(2)),

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the inspector observed that all the original support calculations reviewed (original dates are listed below) were performed several years after installatio Train N Hanger N Bechtel Original Calculation i

1-1 H9 41A-4, 8/16/82 5 (Stress Analysis 41A, ' t

'7 Issue No. 05)

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j 1-1 H22 41A-19, 8/17/82 ". ,

a (NCR 82-413)

1-1 H148 408-10, 8/13/85 -t'

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1-2 H52 40A-23, 5/31/83 ,

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(Effect of steam generator tube rupture analysis 40A, Issue 04)

1-2 H55 40B-11, 8/13/85 (NCR 85-0091) 4 ,

In discussion with the Bechtel engineers, the-inspector was informed that the original support calculations and the IEB 79-14 support' calculations

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were performed by ITT-Grinnell Corporation (ITT-G). A Bechtel Conference t Note (CN) No. 480 documented a meeting held by Bechtel with TEco andc ITT-G at ITT-G on November 29, 1979, to discuss the pipe support deviation

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r evaluation effort to be performed by ITT-G in accordance with IEB 79-14.

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CN No. 480' stated, "Upon completion of the reanalysis, ITT Grinnell will transmit, under cover letter, a copy of their design calculations to l Bechtel for information. In case further analysis is required, originals

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of all' calculations will be retained by ITT Grinnel At some later time, t originals of all calculations will be submitted to Bechtel for permanent i record." Coht ary b the above, as of this inspection, ITT-G calculations

had not been received by Bechtel. Because of this every time Bechtel reruns a stress analysis because of system modification or performs a NCR evaluation, thepffected supports will have to be calculated for their design condition, and then calculated for their revised or damaged

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Upon the NRC inspector's request, Bechtel could not produce the document that controlled IEB 79-14 activities between Bechtel and ITT. The failure

to establish a controlled design interface document to control IEB 79-14 activities between Bechtel and ITT-G is considered to be a violation of 10 CFR 50, Appendix B, Criterion III (346/85031-01). TECo Handling of Facility Change Requests (FCRs)

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a.' FCRs that Affected IEBs 79-02 and 79-14 Closecut Status A TECo letter (Serial No. 1-429) to RIII, dated May.31, 1984 states,

"The modifications for 79-02 and 79-14 were mechanically completed by

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the end of 1983 with the exception of two Non-Conformance Reports

(NCRs). With tpe resolution of the the NCRs (by the end of February 1984) all hanger modifications and physical implementation work activities have been completed with the exception of minor painting

and insulation. The modifications were implemented under various Facility Change Requests (FCRs) and the documentation closeout is in

,, progress. The FCRs closecut will complete Toledo Edison's response i to IE Bulletins 79-02 and 79-14."

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Contrary to the above, the following hardware modifications resulting from FCRs were or will be completed after the completion dealine:

(1) FCR No.80-087, " Reactor Water Make-up and Purification System",

issued on April 1, 198 * Hanger No. FSK-M-CCB-8-25-H, Detail No. 5, work completed on December 21, 198 * Hanger No. FSK-M-HCD-15-18-H, Detail No. 1, work should be

- completed in September 198 I (2) FCR No.80-125, " Main Feedwater System", issued on May 19, 198 w

• Hanger No. SR 33, work completed on May 1,198 '

• Hanger No. SR 35, work completed on March 30, 198 ?

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• Hanger No. SR 37, work completed on March 30, 198 * Hanger No. SR 41, work completed on May 1, 198 * Hanger No. A171, work completed on January 16, 198 FCR That Affected AFPTSS FSAR Status During review of the Bechtel evaluation for H148 (Paragraphs 3.c(2)

and 5), the inspector observed that the hangar calculation was classified as a Committed Preliminary Calculation (CPC). Bechtel Engineering Department Project Instruction No. 4.37-11, " Design Calculation", Revision 4, dated August 2, 1985 states, in part, that "all CPCs must be finalized or superseded prior to startup testing of the associated systems", and " Final calculations are calculations which form the basis of drawings, final specifications, l or other documents which are used to construct the facility or to secure authorization to operate the facility." Subsequent discussions with Bechtel engineers revealed that all damaged hangers (A3, H66, EBD-20-H1, 142, 144, and 147) modeled in stress analysis No. 408 (C9),

" Main Steam System", dated May 29, 1985, were CPCs. Bechtel engineers provided the following explanation as to why these hangers were classified CPCs and not final calculations. FCR No.79-421, " Reroute Auxiliary Feedwater Pump Turbine Exhaust", was issued on November 29, 1979 to provide a redundant system function in case the turbine steam exhaust pipe was crimped by a high energy pipe break in the vicinit FCR No.79-421 is still open even though all work was completed because of drain line problems encountered during other modifications to the system. The rerouting of the exhaust piping caused the auxil-iary feedwater pump turbine nozzle to be overloaded. The use of CPCs to add hangers to the AFPTSS piping and make required modifications would minimize the required QA paperwor Based on the above findings, the inspector concluded that the present TECo FCR system is ineffective. Continually adding supplements to some FCRs (changing the scope of work) partially contributed to some nonconforming or deficient conditions not being corrected in a timely manner (FCR No.80-087 has 11 supplements up to March 29, 1985; FCR No.80-125 has 12 supplements up to September 10,1985). Some FCRs became so large and were contingent upon so many other conditions (such as drainage and support as-built evaluations), that final closeout was difficult, if not impossibl It is estimated that there are numerous FCRs that fall into this categor The failure of the licensee to effectively and timely implement its FCR system is a violation of 10 CFR 50, Appendix B, Criterion XVI (346/85031-02).

7. Exit Interview An exit interview with licensee and Bechtel representatives was conducted, '

on September 18, 1985, to discuss the inspector's findings. The inspec tor discussed the likely informational content of the inspection report with regard to documents reviewed by the inspector during the inspectio The licensee did not identify any such documents as proprietar n

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