ML20210D761
| ML20210D761 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/23/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8702100158 | |
| Download: ML20210D761 (1) | |
See also: IR 05000298/1986030
Text
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JAN 2 31987
In Reply. Refer To:
Docket: 50-298/86-30
Nebraska Public Power District
ATTN: George A. Trevors
Division Manager - Nuclear Support
P. O. Box 499
Columbus, NE
68601
Gentlemen:
Thank you for your letter of January 8,1987, in response to our letter and
Notice of Violation dated December 8,1986. We have reviewed your reply and
find it responsive to the concerns raised in our Notice of Violation. We will
review the implementation of your corrective actions during a future inspection
to determine that full compliance has been achieved and will be maintained.
We have also reviewed your response to the unresolved items identified in the
report. We shall address these issues in a future inspection report.
Sincerely,
8
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f'J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Guy !!orn Division Manager
of Nuclear Operations
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Cooper Nuclear Station
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P. O. Box 98
Brownville, Nebraska
68321
Kansas Radiation Control Program Director
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Nebraska Radiation Control Program Director
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Washington, DC 20555
Subject: Nebraska Public Power District Response to IE Inspection
Report 50-298/86-30
Reference:
1)
Letter from J.
E.
Gagliardo to J.
M.
Pflant dated
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December 8,1986, " Docket 50-298/86-30" -
2)
Letter from
J. M. Pilant
to
W. O. Long
dated
November 25, 1986, " Justification for Interim Operation -
Cooper Nuclear Station"
.
3)
Letter from
J. M. Pflant to
K. V . Seyfrit dated
February 5,1980, "IE Bulletin No. 79-02, Pipe Support
Base Plate Designs Using Concrete Expansion Anchor
.
Bolts"
Gentlemen:
This letter is written in response to Reference 1 which transmitted Inspection
Report No. 50-298/86-30.
Therein it was indicated that one of our activities
was in violation of Nuclear Regulatory Commission requirements.
The
following is a statement of the violation and our response in accordance with
10CFR2.201:
STATEMENT OF VIOLATION
.
Primary Containment Integrated Leak Rate Test
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10CFR Part 50 Appendix J Section III. A.1.(a) requires that:
"If during a
Type A test, including the supplemehtal test specified in III. A.3. (b),
potentially excessive leakage paths are identified which will interfere with
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satisfactory completion of the test, or which result in the Type A test not
meeting the acceptance criteria III. A.4.(b) or III. A.S.(b), the Type A test
shall be terminated and the leakage through such paths shall be measured
using local leakage testing methods. Repairs and/or adjustments to equipment
shall be made and a Type A test performed.
The corrective action taken and
the change in leakage rate determined from the tests and overall integrated
leakage determined from the local leak and Type A tests shall be included in
the report submitted to the Commission as specified in V.B."
Contrary to the above, it was determined from a review of the Cooper Nuclear
Station Summary Technical Report on the second periodic Primary Containment
Integrated Leak Rate Test, that valves IIPCI-MO-19 and RCIC-37 had been
repaired after excessive leakage was identified and that the leakage rate prior
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to repairing the valves was not measured or. documented.
The "as found"
condition of the containment was, therefore, not able to be defined.
This is a Severity Level IV violation.
(Supplement II) (298/8630-01)
Reason for Violation
'
The statement of violation is correct.
Although 10CFR50 Appendix J is
referenced, a specific statement should have been included in Surveillance
Procedure 6.3.1.3 to measure leakage from potentially excessive leakage paths
and to include the results in the Summary Technical Report.
Corrective Steps Taken and Results Achieved
,
Since the leakage from the valves was not measured, it is impossible to amend
the Summary Technical Report.
However, personnel responsible for the
Primary Containment Integrated Leak Rate Test have been made aware of the
importance of local leakage measurement to reconstruct the "as found"
condition.
..
Corrective Steps Which Will Be Taken to Avoid Further Violations
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Engineering personnel in charge of Primary Containment Integrated Leak Rate
Testing are in the process of revising Surveillance Procedure 6.3.1.3,
" Primary Containment Integrated Leakage Test".
This revision will clearly
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state a specific precaution to measure any leakage locally before making
repairs, and to include the results in the Summary Technical Report.
Date When Full Compliance Will Be Achieved
.
Surveillance Procedure 6.3.1 3
Primary Containment Integrated Leakage
Text", will be revised and C 'S wi'l be in full compliance by February 1987.
4
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Reference 1 also requested the District's response to seven (7) unresolved
items that were identified in paragraph 5 of the inspection report.
The
majority of the items have already been addressed in NPPD's submittal to the
Commission to justify Interim Operation until the, next refueling outage
(Spring 1988), with the Standby Gas Treatment System and Control Room
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ventilation ductwork in a functional condition (Reference 2).
Modifications
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will be completed in the 1988 outage to restore full compliance with Class 1
Seismic criteria.
Burns and Roe, the Architect / Engineer for Cooper Nuclear Station (CNS),
has continued their document search for records relating to the Standby Gas
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Treatment System and Control Room Ventilation System.
Recent
)
correspondence from Burns and Roe addresses some of the concerns
highlighted in Paragraph 4 of the Inspection Report.
Each unresolved item is addressed in subsequent paragraphs.
4
Item 298/8630-02 Support Self Weight
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The weight of the support structures (hangers) has been addressed in
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the design / design verification of the hanger supports in the two
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essential HVAC systems (Standby Gas Treatment and Control Room
Ventilation) Ductwork.
The Cygna Energy Services "as-built"
reconciliation calculations performed in 1986 includes the effect of self
weight.
Preliminary sample calculations have been submitted to the
Commission (NRR, Engineering Branch) for review.
Item 298/8630-03 Tension / Shear Interaction
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NPPD has discussed the formula for checking tension and shear
interation as quoted in the " State of the Art Report on Steel
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Embedments," (American Society of Civil Engineers, Nuclear Structures,
and Materials Committee-June,1984) with Burns and Roe.
Burns and Roe advised that the case of the elliptical curve had been
addressed and accepted in the District's response to IE Bulletin 79-02
(Reference 3).
It is concluded that the curve can be applied to Phillips
Redhead anchor bolts.
Item 298/8630-04 Dimensional Errors
.
NPPD commissioned Cygna Energy Services (CES) to perform a walkdown
and seismic verification of the Standby Gas Treatment System as a
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parallel operation to the document investigation.
The urgency of the
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task and the rapid response demanded by NPPD resulted in the
realization of the necessity to ensure adequate check points to identify
errors caused by the rapid pace of work.
As such three separate
checks on documentation were performed:
,
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1.
The "as-build" upon which the seismic verification and
subsequent design modifications were based.
-2.
Before the "For Construction" drawings of the proposed
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modifications were approved and passed to the construction
crews, an additional check was. carried out and if necessary
the design calculation modified.
3.
On completion of the modifications, the system (hangers and
ductwork) was "as-built" and a full as-build reconciliation
calculation performed.
I
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The calculations performed by CES in 1986 from the as-build
reconciliation have been completed.
Sample calculations of the ductwork
analysis and supports have been sent to the Commission (NRR,
Engineering Branch) for review.
Item 298/8630-05 - Welding Procedures
NPPD has not been able to locate all the welding records associated with
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the Control Room Ventilation and Standby Gas Treatment Systems.
,
It is not evident from a review of the Contract E70-19, Section G, which
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welding code was utilized in the construction and installation of ductwork
and duct supports.
The material and installation was in some instances
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procured and installed to Air Moving & Conditioning Associates Codes
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(AMCA).
Discussions with the original A/E (Burns & Roe Company)
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have continued with regard to this topic.
It is considered that the
supporting structures were welded in accorda.nce with AWS Codes using
prequalified procedures.
As such, individual weld records would not
necessarily be held by NPPD.
The ductwork, including ductwork
supporting structures, were installed in accordance with the Standard
Heating and Ventilation Codes using the Ductwork Manual for Sheet Metal
and Air Conditioning and Ventilation Systems per the Sheet Metal and
Air Conditioning and Ventilation National Association (SMACVNA)
Standards.
In the uncertainty of the criteria associated with welding codes, CES was
instructed to perform weld capacity checks on welds in the system.
To
this end, minimum weld size calculations based upon AWS, AISC and
visual surveys were performed using a thickness of 1/16 inch and the
lowest allowable stresses for base metals.
Where transition welds are evident, the lowest base metal allowable stress
has been used.
The preliminary results of these bounding case weld'
capacities were utilized in the reconciled "as-built" calculations for the
Standby Gas Treatment System and in the preliminary calculations of the
Control Room Ventilation System.
These calculations have been
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submitted to the NRR (Engineering Branch) for review.
Item 298/8630-06 Control Room Calculations
Further investigations by the A/E (Burns and Roe) have identified
additional calculations which include the following items:
a.
Anchor bolts were evaluated for both tension and shear.
The
interaction formula was not explicitly applied in the vendor
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calculation since the factors of safety were in excess of the original
contract specification requirements. . A recent check of the original
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results indiented the requirements of the interaction formula were
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met.
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b.
Combined stress checks were, performed in the Waldinger design.
The method used was in accordance with the applicable AISC
requirements during the time of construction.
c.
Class I Seismic Supports were designed by equivalent static
approach, using specified "g"
values.
With this approach,
individual hanger frequencies are not required.
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Weld capacities and as-built drawings are addressed in NPPD's response
to unresolved Items 298/8630-07 and 298/8630-05.
Burns and Roe is preparing a list of documentation which will be used
by NPPD to supplement NPPD construction records.
In addition to pursuing the above course of action, NPPD directed CES
to perform a seismic verification, and if deemed necessary, produce
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modifications to rectify deficiencies associated with the support
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structures of essential ductwork.
Preliminary calculations have been
completed by CES and have been forwarded for review by NRR,
Engineering Branch.
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Item 298/8630-07 Control Room Walkdown
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CES has completed a walkdown of the essential sections of the Control
Room Ventilation System ductwork.
The drawings are in production and
will be reviewed by NPPD in due course.
A preliminary check of the
field sketches has been completed.
Findings from this walkdown were
addressed in Reference 2.
Item 298/8630-08 Class II Seismic Design
dated 07/22/86, Volume V.
Section XII,
Subsection 2.3.5.1.2 states:
" Class II Structures and Equipment were
designed to resist effects of seismic loads with the horizontal base shear
,
coefficient as determined from the Uniform Building Code, Zone 1 or
1
taken as 0.1g, which ever is greater.
The base shear is then to be*
distributed and structures designed in accordance with the provisions of
the Uniform Building Code, with 1/3 allowable increase in basic stress."
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Other subsections in USAR Vol. V,Section XII, address seismic design,
notably 2.3.5.1 and 2.3.5.2.
The design and verification associated in the rectification of the deficiencies
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in the Standby Gas Treatment System and the Control Room Ventilation
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System ductwork hangers will be pursued throughout 1987 and will be
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completed during the 1988 Spring Outage.
The Standby Gas Treatment
System (suction side) modifications are complete and the final as-built
reconciliation will be reviewed by NPPD in due course.
Nebraska Public Power District will continue ,to address any outstanding
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concerns related to these unresolved items.
If you have any further
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questions, please contact me.
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Sincerely,
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G. A. Trevors
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Division Manager of Nuclear Support
GAT /gsm/grh:cbl8/4(2A)
cc:
E. Gsgliardo, Chief
!
Reactor Projects Branch
l
NRC Region IV
i
NRC Senior' Resident Inspector
l
Cooper Nuclear Station
!
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