Text

Long-Term Pipe Support Insp & Evaluation Program Plan
	ML20116N688
Person / Time
Site:	FitzPatrick
Issue date:	04/30/1985
From:	; POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	;
Shared Package
ML20116N679	List: ML20116N677; ML20116N688;
References
	PROC-850430, NUDOCS 8505070309
	Download: ML20116N688 (18)
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Attachment No. I to JPN-85-38 Lona-Term Pipe Support Inspection and Evaluation Procram Plan-NEW YORK POWER AUTHORITY James A. FitzPatrick Nuclear Power Plant Docket No. 50-333

. I April , 1985 i h33 '

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g. .8 i POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT I PIPE SUPPORT TASK TORCE PROJECT PLAN a

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,. INDEX I. INTRODUCTION 3

A. Background

8. Plan Summary C. Implementation II. SCOPE III. INSPECTION PROGRAM-DESCRIPTION IV. EVALUATION PROGRAM DESCRIPTION V.- RESTORATION PROGRAM DESCRIPTION VI. ANALYSIS PROGRAM DESCRIPTION VII. MANPOWER AND.SCHED'ULES-APPENDIX A - SAFETY-REL ATED PIPING - 2 1/2" DI AMETER- & GREATER

' APPENDIX 8 - SAFETY-RELATED PIPING - LESS.THAN 2.1/2" D,IAMETER APPENDIX 1C - PIPING DESIGNATED.FOR INSPECTION DUE TO ADDITONAL.

REGULATORY RE,QUIREMENTS-1.

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Page PIPE SUPPORT TASK FORCE PROJECT PLAN I. INTRODUCTION A. Background )

-In a petition dated and filed on September 12, 1983, l the Union of Concerned Scientists (USC) made several l allegations concerning the adequacy of pipe supports in the FitzPatrick plant. This petition essentially requested that FitzPatrick be shutdown until claims of visably damaged supports and incomplete or incorrect ,

design calculations were resolved. The NRC denied UCS's petition finding no basis for their allegations.

During the inspection of several pipe supports to c o n f i r m' o r refute these allegations, several dis-crepancies were noted between the support. drawings _and the actual condition of the support. Most o f. these discrepancies concerned support weld. Further study concluded 'that none of the discrepancies have any generic safety implications.

A committee (The Pipe Support Task Force Committee) was

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formed by the FitzPatrick Resident Manager to identify and correct or evaluate similar discrepancies, with restoration to the original design' preferable.

This program plan-is one of the work products prepared by the Pipe Support Task Force Committee. .This program plan describes the complete plan for ' investigating' the current ' condition of pipe supports on' safety-related piping and assuring that these. supports comply'with applicable installation criteria. This plan also describes the scope of the investigation;- a program to i . repair or restore discrepant ' pipe . supports; and a program'to document both the' investigation and any corrective actions necessary. . After this plan .has been i completed and approved, _the committee will prepare field procedures to implement the program.-

-8. Plan Summary This.section of.the progeam plan will summarize the three . fundamental phases ~ of-the pipe support task force program. .These_three phases'are:

' 1. - Inspection

2. Evaluation

- 3.' . Resolution of Discrepancies. *

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PIPE SUPPORT TASK FORCE PROJECT PLAN (continued)

Inspection i

This is the first phase to be performed.

During the inspection phase, the as-found condition of pipe supports on safety-related piping will be compared with the JAF plant drawings. This comparison will include a number of attributes that are consistent with the level of inspection applied to recent work.at JAF.

Certain att ributes that will not be inspected are specified and justified in.Section III.

Discrepancies. identified during the inspection will be documented and referred to a pipe support field engineer for ev aluation ' and resolution.

Evaluation The evaluation process itself is a two-step process involving an initial evaluation to determine w h e t h e r ..

support operability is affected and a final evaluation 4

to determine'the feasibility of support restoration.

If the result of: the -initial evaluation indicates the pipe support is functional, the final evaluation shall be performed. The final evaluation will describe the most feasible method for resolution of the discrep-ancies. Whenever conditions permit, pipe support will be restored to it s original design condition. Should restoration be impractical, the pipe support will be referred for. stress analysis.

Resolution of Discrepancies As the result of the~ evaluation process, three means of resolving discrepancies - are available' to the pipe support field engineer; restoration, stress analysis, a combination of restoration and. stress analysis.

Restoration is making those physical-changes to-the pipe support: to.make it con fo rm . with the existing design-drawing.- No changes to the design drawing will.

- be necessary in this case.

Stress analysis will be used in those' cases where restoration alone is~ impractical'or not feasible. The '

"as-found"-condition will-be. analyzed and compared to ,

-applicable. design criteria. . Should the "as-found"- i

. condition meet -design criteria,- drawings will be ,

-updated to reflect the "as-found": condition. -

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j PIPE SUPPORT TASK' FORCE PROJECT PLAN (continued)

In those cases where restoration is not feasible and analysis has determined that the support fails'to meet

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i applicable design criteria, a combination of both_may be the most practical-means to resolve the discrepan-cies.

C.- Implementation This' plan has been developed for implementation through normal ~ Authority policies and several new detailed procedures that are identified below. Except for a

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small-group.of personnel-dedicated to this project, work will be performed through " normal" channels (i.e.

restoration of supports to be handled by the.Mainten-ance Department, inspections to be-conducted by the Quality Assurance Department, etc.).

Detailed procedures will be prepared for each phase of this program: inspection,. evaluation, restoration, and analysis.

These procedures will apply'only to person-nel assigned to the pipe support task force project.

. This. plan defines several key personnel p1sitions or groups that form a minimum basis for the program.

Project Manager Field. Engineers Stress Engineers Quality Control Inspectors Maintenance Mechanics These five positions will be dedicated t'o the implemen-tation-of this program. Other personnel'such as a Quality Assurance Engineer, Radiological and Environ-mental Services, . and Drafting personnel required on'a part-time basis. will be A preliminary program schedule is included in Section

-VII of-.the plan.

II. SCOPE.0F PLAN

-This program _will emphasize thefinspection-of safety-related.

system pipe supports within-the FitzPatrick1 Plant. -In

- general, inspections 'will be limited to the :following: .

'a) Safety-related. piping with a size'of 2 1/2 inches or greater'(Appendix A).

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Safety-related piping'containin.g' sizes-smaller than !

-2 coolant 1/2_ inches which normally forms-part of the reactor' pressure. boundary or-is a_small-'high energy line . located :in -the secondary containment as defined in.

SWEC. Document HELB Analysis.-(Appendix-8).

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1g3-6 4 PIPE SUPPORT TASK FORCE bc PROJECT PLAN

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] $, Otherregulatory piping designated for inspection due to addi-9 I l'd tional requirements '

Appendix C).

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)4 hj In general, Bulletin No. the scope of this program is based upon NRC f' - 79-14 " Seismic lated Piping Systems", Analyses fo r As-Built Safe ty-Re-as amended.

's Bulletin limits the scope of this Revision 1 to this safety-related piping 2 1/2 bulletin to"...all 3 and to seismic Category I piping, inches in diameter and greater K was dynamically analyzed by computer." regardless of size which h issued by the NRC on March 13, 1979 specifically A Show Cause Order addressed

only piping analyzed by computer programs.

i f- NRC Bulletin No.

79-07, " Seismic Stress Analysis of Safety-Related Piping" l similarly lated involved piping. only The program the seismic analysis of safety-re-Bulletins 79-02 also uses the guidance of NRC t of the pipe supp, ort 79-07 which and 79-14 must to establish those elements be inspected.

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Small importance high to energy plant lines have been included based on the

{t on the operability of operations and their potential effects other safety-related they fail. equipment should I !

This program does

, not- address safety-related measuring less than 2 1/2 inches in diameter that piping considered is not reactor coolant a high energy pressure line and does not form part of the boundary.

Appendicies.A, B, of systems that willand be C list the piping systems or portions piping line numbers from inspected under the plan. Specific separate document. these systems will reviewed by comparison The supports .be listed fo r these systems willinbe a

of support detail design' drawing.the'as-found support versus the III.. INSPECTION PROGRAM DESCRIPTION It is recognized inspection that the pipe. .suppo rt s t 'o program inspected. This pipe support is applicable have been which this-previously

,the details of the pipe inspect ion program .will verify following items: support with the exception of the ,

a. The. location of supports that

' program.

Bulletin 79-14 will be were not verified per NRC ~

verified as part of this b .-

The tightness verified since of. thisconcrete anchor bolts will not.be 79-02. was . pe r fo rmed .pe r NRC' Bulletin Page. p n

PIPE SUPPORT TASK FORCE PROJECT PLAN (continued) c'. Pipe supports or portions of pipe supports that are determined to be inaccessible for inspection. Pipe supports that are not accessible for inspection shall be brought to the attention of the Pipe Support Field Engineer.

It is intended that the inspections will be conducted over a long term program by Quality Control Inspectors (QCI) from the JAF plant. .

A schedule for performing the inspections will be outlined by the' Pipe Support Project Manager based on plant opera-tions and availability of project manpower. T h e.' s ch e d u le will be provided to the JAF Q.A. Superintendent via the JAF Resident Manager on a monthly basis. The Pipe Support Field Engineer (PSFE) shall have the responsibility of interf acing with the Mechanic Foreman for-installation of lighting, ladders, scarfolding, etc., to pro' vide-accessibility.for the-inspections. When the pipe support is accessible, the PSFE will make a physical check of the support to determine if any other items will obstruct the QCI from inspection of the entire' support. The Mechanic Foreman will be contacted by the PSFE if other items must be temporarily moved.

The-QCI will then inspect the pipe support. A list of the inspection items will include, but is not limited to, the following:

1. Overall configuration of the pipe support structure..

2. Required clearances that permit or restrict movement.

3. Tightness of threaded fasteners except concrete !

anchors.

4'. Piping' welded attachments and welds.--

5. Supplementary steel and component welds.

6. Spring hangers type, size and. setting.

7. Hydraulic and mechanical snubber type, size, and setting, l

8.- Other component items type, size.

9. (If required). pipe support location.

Each inspection' item will be documented by the QCI on a data report ~. Data reports' for acceptable pipe supports will be forwarded to the PSFE~ for. filing. Items ~found to be unacceptable by the QCI- will be documented on a discrepancy report in accordance with the~JAF Quality Assurance Program.

The discrepancy report will be forwarded to the PSFE-for Page- _

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- 4 PIPE SUPPORT TASK FORCE PROJECT PLAN (continued) edaluation. A log of discrepancy reports will be maintained by the PSFE. The discrepancy report.will be returned to the

,QCI'only after the recommended corrective action is accom-plished. The QCI will reinspect the support to assure that the corrective action has been accomplished and that the as-built condition meets the requirement of the JAF design ,

drawing. Completed data reports will be forwarded to the PSFE for filing.

IV. EVALUATION-PROGRAM DESCRIPTION Inspected pipe supports that conform with the detail design drawing will not be evaluated. As stated above.in the Inspec t i'on. P rogram, a pipe support that has been determined to be, non-conforming will have a discrepancy report initiated describing the specific details of the discrep-ancies'and will be forwarded to the PSFE for evaluation and resolution.

After's discrepancy report is received by the PSFE, the affected support normally will be identified and located in the_ field, and the actual discrepancy will be confirmed by '

the PSFE.

The evaluation of the discrepancy shall be performed in two parts:

1. The PSFE _shall determine the significance of the discrepancy affecting the pipe support's ability to

-perform its intended design- f u n c t i o n~. .

I f ,- through ,

engineering judgement or simple field. calculation, it is concluded that the affected pipe sup' port is. func-tional, the second step of this evaluation 'can be performed. If, however, a determination cannot'be made twith sufficient confidence or if the support's func- '

tional capability is questionable, the-support shall be referred to the Pipe Suppo r t St~ress - Engineer for detailed analysis of support and system. operability.

If, as a result of the. detailed operability analysis -

'the piping-system is determined not'to be. functional, then.the^ plant'may be placed on a limiting condition for operation (LCO) in accordance with thn JAF Techni-

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cal-Spccifications. The LCO should-be factored into the

' evaluation and- decision process to mee t -_ the time constraint for continued operation. Restoration of the supp. ort to_its. design condit ion _ or - reanalysis of the support to provide. acceptability-are two methods that j

will_ create an acceptable condition and permit-con-tinued operation.

[2. If _ t h e , d i s c r e p a n c y. does not s i g n'i fi c a n t l y_ affect j support function, a'determinat. ion shal1 be made whether !

,the. support can be restore'd (by _ rework) to its design H condition.; -Restoration ~1sithe preferred. method for J

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PIPE SUPPORT TASK FORCE PROJECT PLAN (continued) e support due to inaccessibility. In this case, a

decision could be made to perform stress analysis of the support with the anticipation that the e x i s t ing l condition would still meet the design criteria. A third decision could result in obtaining an acceptable

} support .by the comb inat ion of restoration and stress t analysis.

The evaluation process is essentially complete at the time when a restoration package is assembled by the PSFE and is forwarded .to restore the support to its original design condition or a request for stress analysis is initiated by the PSFE and is forwarded tc the Pipe Support c Stress 4

Engineer to analyze accept s p'e c i f i c identified din fep-ancies. Further evaluation may be requiredifthesuik(t cannot be restored or if the analytical results that the discrepancies are not" acceptable. indig!}e

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V. RESTORATION PROGRAM DESCRIPTION i After the PSFE has decided to restore a support, a pipe support restoration package will be initiated. The package will contain specific instructions (including requirements for temporary support ) with a copy of the support drawing with deficient areas clearly marked. The package will also contain instructions to complete the restoration. The completed pipe support restoration package will then be reviewed and approved by the cognizant.QA engineer. Upon QA approval, the PSFE will deliver the pipe support restoration i package'to the Installation Supervi'sor in charge of'the mechanics-welders.

It will be-the Installation Supervisor will ensure that the work' outlined in the data package is completed. -The Instal-

, lation Supervisor's responsibilities will include all requirements for lighting, tooling, materials, temporary support, welding' equipment and~other-miscellaneous equipment necessary to complete the work. The Installation Supervisor will be responsible for compiling the required data that it is accurate, and it is attached to the pipe support restora-tion package.

1 Upon. completion of the restoration work', the Installation

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. Supervisor will' sign o f f the data. package indicating that the restoration of the support has been .complet e. The Inst alla t i on Supervisor- will. deliver the completed work i . package to'the PSFE. The PSFE will review and concur with the package.- The PSFE will resubmit the pipe support with

-the completed discrepancy report to the .QCI; for inspection as. required by the Inspection Program.

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PIPE SUPPORT TASK FORCE PROJECT PLAN (continued)

VI. ANALYSIS PROGRAM DESCRIPTION After the evaluation phase has been completed, strass analysis may be performed to verify support acceptability to the design standards. The PSFE will submit a request to perform stress.anlaysis to the Pipe Support Stress Engineer (PSSE). The specific reasons for requiring stress analysis in lieu of restoration of the support will be stated ~1n this request.

A discrepancy is " allowable" if it has been considered in the pipe suppcet analysis and the calculated stresses are within the allowables of the. design code specified.In the JAF Final' Safety Analysis Report. In this case, no physical modification of the support is required. The pipe support drawing, however, will~be revised to reflect the as-built condition. The revised support design drawing will be returned to the PSFE with the completed request for stress analysis.

When the result of th'e analysis shows that the calculated stresses exceed the specified allowables,. an interim operability analysis shall be performed in the following order:

1. Calculate the' ultimate' load capacity of-the support based on ultimate material stress. If the ultimate load .

capacity is equal to or greater than two times the actual- support load, the support i s- considered operable.

2. If the analysis performed in Item 1 does no't confirm support operability, review the pipe stress anlaysis to check whether excessive conservatism was used in the analytical- model,- the thermal condition _ and the applicable amplified response spectrum. . Piping rean-

.alysis should be performed-if applicable. The pipe support load resulting from the reanalysis will be used for further' evaluation of its acceptability or oper-ability.

3. If the analysis performed in Items 1 and 2 does not confirm the support operability, the piping system

'shall be reanalyzed. I f the' maximum pipe stress- does

-noti exceed 2 '. 4 Sh and the adjacent supports _ are -

-operable, the system-is-considered operable.

Although support.or system ope rability .may be verified by satisfying one of the-above, the allowable-.st resses in the design code must be satisfied for support' acceptability.

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.If as'a result of this operability analysis, the system is still-considered inoperable, the PSFE shall be immediately informed of this cbnditidn so that appropriate actions can be taken by! plant. management. After informing the PSFE of l the-condition,-the PSSE will recommend a change to tne [

support to establish an acceptable condition. The changes '

will b e 'i.nco rpo r a t ed - b y a revision to the~ pipe support design drawing.

4 VII. MANPOWER AND-SCHEDULES The. proposed schedule for implementing th.is pipe support program is based on inspecting the total number o f -supports identified in two phases if necessary. This would include. ,

inspecting / restoring all supports located in inaccessible

, areas of the plant (i.e. drywell) during two refueling.

outages.

The first phase will involve a sample inspection of 100 supports from various plant systems. The results of this inspection, in terms of the numbers and types of discrepan-

. cies found, will be reviewed and determined by plant management whether to conduct the second phase. The second

phase would require.the inspection of the remainder of the supports.

Stone _and' Webster has preliminarily estimated that 1750 supports will have to be inspected for completion.of the program. It is further estimated that 1450 o f 'the total supports could be inspected during plant operations..

The. remain'ing 250 supports will be done during two 90-day re fueling - outages . This will require 10' supports to be done per week during refueling outages. The inspection /restora-tion should be. closely coordinated with the ISI program.

'This-_will prevent duplication o f insulation removal /scaf-folding installation. The manpower available.to perform

inspections will have to be doubled during refueling outages at the minimum. Productivity.will: decline when working in the drywell due.to.high radiation -exposure', confined work j area and conflict with:other ongoing-work.-

3-YEAR: PROGRAM DURATION

PHASE.I Number of. Supports - 100-Time Interval - 10' weeks .

. Number.of Supports Per-Week - 10 Page i.

A PIPE SUPPORT-TASK FORCE

-PROJECT PLAN (continued)

PHASE ~II PLANT 0PERATING (NON-0UTAGE)

Number of Supports - 1400 Time Interval - 2 years - 2 1/2 months Number of Pipe Supports Per Week - 12 PLANT SHUT DOWN (OUTAGE)

Numbbr,of Supports - 250 Time Interval - 6 months (2-90 Day Outages)

Number of Supports Per Week - 10 Summary of Responsibilities Project Manager

1. . -Pipe support program coordinator

2. Liaison between the Pipe Support Task Force and JAF-NYPA management.

3.- Schedules, Finances, Budgets, Manloading Pipe-Support Field Engineer a

1. Performs initial pipe support walkdown and initiates

~ ' data reports.

2. Evaluates the effect of discrepancies on support operability.

3. Evaluates discrepancies to determine a resolution, either restoration or-analysis.

4. Processes the required documentation to implement-the resolution.

S. Coordinates the daily activities of the program.

Pipe Support Clerk-

1. Maintains logs.for.all' documentation initiated asia part of the program.

2. ' Maintains files for 'all completed and closed-out documents that are a ,part of ' the program.

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s' PIPE SUPPORT TASK FORCE PROJECT. PLAN (continued)

Quality Control Inspector

.1 . Inspects existing supports per the design drawing and established criteria.

2. Issues data-reports for accepted pipe supports.

3. Initiates discrepancy reports for unacceptable sup-ports.

4. Reinspects supports upon restoration to the design.

drawing or upon analysis / drawing revision to meet the as-built condition.

Quality Assurance Engineer

1. Reviews various aspects of the program for compliance with the JAF Quality Assurance Program.

Pipe Support Stress Engineer

1. Performs detailed operability analysis for the sup-port / piping system due to a discrepant support.

2. Reanalyzes discrepant supports.

3. Recommends modifications to discrepant-supports'if necessary, Designer / Draftsman

1. Revises pipe support drawings based on input from-Pipe ;

Support Stress Engineer.

Installation Supervisor

1. Direct supervision of mechanics / welders.

2. Initiates requests forfRadiation Work Permits and coor- '

dinates.

3. Coordinates materials for welding, other tooling.

Mechanics / Welders

1. Insulation removal and reinstallation.

2. Scaffolding installation and removal.

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PIPE' SUPPORT TASK FORCE PROJECT PLAN

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~ 3. Restoration of discrepant supports.

- Radiation' Protection Technician

1. Perform surveys, assist in processing Radiation Work Permits.

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1 PIPE SUPPORT TASK FORCE PROJECT PLAN (continued)

APPENDIX A SAFETY-RELATED PIPING e 2 1/2" DIAMETER & GREATER NOTE: Inspections will be carried up to the first anchor point beyond the interface of QA Category I and Non-QA Category I piping.

1. Residual' Heat Removal (Includes RHR Service Water From Pumps)

2. High Pressure Coolant Injection

3. Core Spray

4. Reactor Core Isolation Cooling

5. Reactor Building Ventilation - Cooling water to/from engineered safeguards equipment i 1

6. Emergency Service Water

7. Main steam from reactor vessel up to but not including the !

turbine stop valve, and connected piping of 2-1/2 inches or l larger nominal pipe size up to and including the first valve that is either normally closed or capable of automatic closure during all modes of normal reactor operation.

8. Feedwater from reactor vessel up to the first anchor beyond ;

the first isolation valve external to the drywell, and R connected piping of 2-1/2 inches or. larger nominal ~ pipe size up to and including the first valve that.is either normally '

closed _ or capable o f automatic closure during all. modes of normal reactor operation.

9. Control Rod. Drive

10. Reactor Water Recirculation System

11. Drywell Vent.and Purge i

12. Standby Gas Treatment' '

13. Standby Liquid Control Page .

PIPE SUPPORT TASK FORCE PROJECT PLAN (continued)

APPENDIX A SAFETY-RELATED PIPING - 2 1/2" DIAMETER & GREATER (cont.)

14. Emergency Diesel Generator (Exhaust Piping)

15. Fire protection subsystems used to protect safety related systems, components, and structures

16. Fuel pool cooling and cleanup

17. Control Room Emergency Ventilation