ML20206J617

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Insp Rept 50-271/86-12 on 860512-16.Violation Noted:Failure to Document Visual Exam Repts for Restraints R6A & R9B
ML20206J617
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 06/18/1986
From: Kamal Manoly, Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206J602 List:
References
50-271-86-12, IEB-79-02, IEB-79-2, NUDOCS 8606270216
Download: ML20206J617 (14)


See also: IR 05000271/1986012

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-271/85-12

Docket No. 50-271

License No. OPR-28 Priori ty --

Category C

Licensee: Vermont Yankee Nuclear Power Corporation

RD 5, Box 169

Ferry Road

Brattleboro, Vermont 05301

Facility Name: Vermont Yankee Nuclear Power Station

Inspection At: Vernon, Vermont

Inspection Conducted: May 12-16, 1986

l Inspectors: # Y/7M b

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K. A. Manoly, Lead Reactor Engineer date

Approved by.

T

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, Materials and Processes

M

'date'

. Viggins,[R

ction, EB,

Inspection Summary: Inspection on May 12-16, 1986 (Report No. 50-271/86-12).

Areas Ir.spected: Routine announced inspection by a region-based inspector

of licensee actions regarding several outstanding and unresolved items in the

area of piping, supports and restraint systems. The items included:

--

Confirmatory Action Letter (CAL) 271/85-06 and unresolved item 271/85-04-01:

Implementation of IEB 79-02 to dead weight pipe supports.

--

Inspection followup item 271/85-08-03: Testing of small bore pipe supports

--

Unresolved item 271/85-40-07: Failure of service water dead weight support

No. RSW-H0164E

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Inspection follow-up items 271/85-40-03, 04&05: Failed weld on whip

restraint #R108

--

Unresolved item 271/85-40-06: Failure of embedded plate for HPCI pipe

anchor MS-HD-22G

Results: One violation was identified.

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8606270216 860623

PDR ADOCK 05000271

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DETAILS

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1. Persons Contacted

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l 1.1 Vermont Yankee Nuclear Power Corporation

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! J. P. Pelletier, Plant Manager

J. K. Thayer, Engineering Manager
R. J. Wanczyk, Technical Services Support
R. P. Oliver, Lead Mechanical Engineer

1 J. R. Hoffman, Project Engineer

A. Roudenko, Senior Engineer

C. L. Greeno, Mechanical Engineer

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J. M. DeVincentis, Mechanical Engineer

! 1.2 USNRC

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j W. Raymond, Senior Resident Inspector

{ 2. Followup on Outstanding Inspection Findings

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j 2.1 (Ciosed) Confirmatory Action Letter (271/85-06) and Unresolved Item '

l (271/85-04-01)

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The Confirmatory Action Letter (CAL) and the unresolved items are '

related to the implementation of I.E. Bulletin 79-02 requirements

for dead weight supports in safety related piping systems. Review

of licensee action relative to I.E.B 79-02, during NRC inspection

No. 271/85-04 and the followup meeting on May 23, 1985 in Region I,

revealed that the bulletin requirements regarding the verification

] of pipe support base plate flexibility and minimum factors of safety

i were not implemented for dead weight pipe supports in the original

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effort by VY in response to the bulletin.

k. During this inspection, an evaluation of the licensee action to the ,

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CAL was performed through the review of activities conducted as part '

of the seismic Re-analysis Program (SRP) of piping systems outside

i containment and the Mark-I torus modification for torus attached

! piping. The evaluation included review of records and design calcu-

lations in addition to walkdown inspection of selected modifications.

$

The inspector reviewed document No. EDCR-S4-402 which addresses the

7 seismic piping re-analysis ard identified the following: '

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support construction schedule including identification of

) supports modified, changing function or requiring removal

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design criteria in the QA and technical area

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pipe support mark and drawing numbers -

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piping isometrics affected 1

--

list of all analysis by calculation numbers

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The SRP was carried out by VY to upgrade the seismic category I

piping systems to the requirements of Regulatory Guide 1.60 and 1.61.

The program included all piping systems external to the drywell. Not

included in this program' were the recirculating piping system, torus

attached piping modifications and scram discharge piping modifica-

tions. Evaluation of pipe support base plate flexibility and anchor

bolt factors of safety was addressed during the SRP effort for safety

related seismic and dead weight large bore and connected small bore

piping. Some small bore piping was evaluated using the chart method.

The inspector was informed that replacement of Red Head concrete l

anchors by Hilti expansion anchors was completed for all large bore l

and some small bore support base plates. Small bore pipe supports l

which did not require anchor modification as a result of the re-analy-

sis were included in the testing program to verify the adequacy of

their installations. The testing program included 243 small bore

supports and is addressed in section 2.2 of this report. Other dead

weight supports with Red Head anchors not covered by the SRP were

identified in the torus attached piping systems. These included 26

spring hangers. The inspector reviewed the factors of safety for the

concrete anchors for the spring hangers. The lowest factor of safety

was found to be 7.75 which exceeds the minimum allowable of 5.0. The

licensee indicated that these hangers are supporting their design

loads, which are oparational loads. Thus they did not require test-

ing to higher loads. The inspector also reviewed a list of all dead

weight pipe supports evaluated in the SRP effort which included iden-

tification of the piping systems and the status of each support.

Evaluation of SRP design calculations during this inspection,

included sampling review of selected pipe support design packages

from the SRP and torus modification activities. Calculations from

the SRP were reviewed for conformance to design criteria procedures

and applicable codes and standards. Pipe support spring hanger

packages for torus attached piping were reviewed to verify incorpo-

ration of seismic deflections in the selection and evaluation of

l spring settings in the cold and hot conditica.. Calculations reviewed

are identified in attachment 1 to this report. Visual walkdown

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inspection of piping and supports analyzed in the SRP effort was

performed for a portion of the HPCI piping system and associated

supports. The walkdown was conducted to verify the conformance of

piping and support installations to design drawings. Table I of

attachment 2 identifies piping and support systems inspected.

Further, the inspector performed a visual examination of several

spring hangers from the torus attached pipine for identification of

concrete spalling or excessive base plate deformation. Supports

examined are identified in Table II of attach:nent 2.

Based on review of licensee actions in this trea, the above items

are closed.

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2.2 (Closed) Inspection-Followup Item (271/85-08-03)

This item involved the test program for small bore piping to

! satisfy the requirements of I.E. Bulletin 79-02 concerning the

j adequacy of existing concrete anchor installations.

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! The inspector reviewed the licensee test program outlined in corres-

i pondence No. FVY 85-112 to the NRC Region I office in November 26,

1985. The testing included 243 supports from stress analyzed and

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chart method supported piping. The testing was done in two phases.

The first phase included 13 supports from stress analyzed piping in

the HPCI and RCIC systems and 48 supports primarily from chart method

l supported piping. The inspector reviewed the list of tested support

to verify that they represented samples from a variety of systems at

several locations. The magnitude of test loads was 10% over the

thermal plus seismic SSE loads. The loads were applied in the

directions of restraint of the support. The inspector also verified

the proceoure used for the random selection of the 48 supports tested

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in the second phase. A random number generator function utilizing

3 the " Lotus-Symphony" program was used in this process. Both phases

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of the testing were documented in Special Test Procedures No. STP

85-01 and STP 85-02 respectively. The inspector reviewed procedures

and test packages which included: (1) Safety evaluation per 10 CFR

50.59(a)(2) for unreviewed safety questions, (2) test procedures

check list, (3) support drawings identifying magnitude and direction

of applied test loads, (4) QC sign-off for witnessing of load appli-

, cations and determination of supports meeting the pass / fail criteria,

! and (5) load arrangement and test data sheets for test supports.

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A review of the test results indicated that all 61 supports had

passed the acceptance criteria. This represented 25% of the

total population of small bore supports requiring verification

. and provided a confidence level of more than 95% established by

j I.E. Bulletin 79-02. This item is therefore closed.

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2.3 (Closed) Unresolved Item (271/85-40-07)

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} This item is related to the identification of failed dead weight pipe

support No. RSW-HD 164E on the service water piping line 20" SW 12,

I during the performance of piping and support modifications associated

1 with the Seismic Re-analysis Program (SRP). The inspector reviewed

j the licensee evaluation (VYM 07/86) of the findings and the probable

j reasons for the support failure. The support was of'the trapeze

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type, which was modified during original construction due to inter-

I ference with electrical cable tray support. The failure was attri-

j buted to the pour design'and installation of the field m.dification.

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Th: supp6rt 1

tant) on thel.s located

piping line. in close

The proximity

licensee's of an anc'

~ evaluation hor (2'-9"

indicated thatdis-  ;

an apparent o.vertightening of the nuts on the trapere rods had led to

the failure'of two welds on the ends of an intermediate vertical

channel connected to two horizontal channels from above and below.

Tfie vertical channel was found resting.on a 12"' pipe (SW158).

Evaluation of results fra the SRP activity indicate that the support

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was not requires at this location due to its proximity from the

anchor. The support, was classified as " inactive" and is not included

in the analyses of record. After the support failure was identified

it was reclassified as'" Removal" and/was removed per ECN #12 of EDCR

'84-402. Three walkdowns by the licensee 'and other walkdowns by the

NRC inspectors did not identify damage to the 12" - Sw ISB line where

the channel re sted of to the supported 20"- SW12 piping line. The

inspector bd no funther comments regarding the licensee's evaluation

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and re.salution. cThis item is therefore closed.

2.4 [ Closed) Inscection Followup Items (271/85-40-03, 04 and 0Q

These items are eclated to an identification of weld failufe between

recirculation discharge line loop 'B' whip restraint No. R10B and the

support plate. NRC inspection report No. 271/85-40 addressed the

whip restraint weld . failure and identified areas requiring further

review. These 'ncluded: recirculation piping break evaluation by GE;

licensee's as-built inspection, dispgsitico of unacceptable

restraint; ana repairs; and overall resolution of' wntp restraint

problem. -

The inspector reviewed recirculat-io4 pipe bredk postulation in GES

report No. 23A5478 which provides 'tho postulateo p'ipe break locations

in loops A&B of the recirculation piping system based on criteria

provided in Standard Review R!an (SRP) s~ection 3.6.2. The report

identified eight and nine postulated break locations in locas A&B

respectively, for which nineteen existing whip restraints are

required. The remaining thirteen existing whip restraintstat pre-

viously postulated breaks were considered unneeded and are classified

as inactive in the modificat' ion drawings. In addition the inspector

reviewed the engineering evaluation of as-built restraint install-

ations, performed by VY in document No. 006820 MEM-PT-MIS. Comparison

of whip restraint weld sizes required to restrain pipe; rupture loads

with as-built weld sizes identified four non-conforming restraints.

The non-conforming restraints (R6A, R7A, R6B & R98) required weld

build-up and were subsequently modified. Four other non-conforming

restraints were among the thirteen inactive restraints based on GE

report identified above. The calculation of piping whip loads

accounted for the piping pressure and cross-sectional area. Though

the methodology for determining rupture loads was found not to be i

consistent with the approach outlined in the SRP section 3.6.2, it l

was in agreement with the original-design provisions shown in G.E. 1

drawings. Evaluation of the whip restraints at VY was performed in '

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accordance with the provisions of NRC Generic Letter 84-07 and the I

requirements of SRP Section 3.6.2. When factors associated with the

state of flow exiting from a ruptured pipe and the dynamic impact of

whipping pipe against the restraint are considered the magnitudes of

whip loads (based on SRP formulation) could increase. This item is t

unresolved pending licensee evaluation and NRC review (271/86-12-01). l

Other documents reviewed by the inspector included the following: I

Licensee memorandum No. VYM 02/86 addressed a walkdown inspec-

tion by the licensee of other pipe rupture restraints and

barriers outside the drywell. The walkdown was conducted in

response to the concern identified by the NRC in inspection No.

85-40. The inspection was done on January 2, 1986 of pipe

rupture restraints and barriers for the HPCI, Feedwater and

Reactor Cleanup Systems. The report did not identify any

construction defects in the inspected installations.

Disposition of LER No. 85-13 (Rev. 1) attributed the probable

root cause of the weld defect in whip restraint R10B to person-

nel error. VY could not determine whether a system to review

less than complete welding was used to approve cases where it

was not performed. Discussions related to the analysis of the

event and corrective action reiterated the conclusions from GE

report and VY engineering evaluation and walkdown inspections

previously discussed in this section.

A review of quality inspection records related to weld repairs and VY

surveillance is addressed in section 3 of this report. These inspec-

tions followup items are therefore closed.

2.5 (0 pen) Unresolved Item (271/85-40-06)

This unresolved item was related to the identification of an embedded

plate which was not connected to the building column. The HPCI pump

discharge piping anchor No. MS-HD-22E.was connected to the plate.

The following licensee documents relating to the embedded plate

failure were reviewed by the inspector:

Memoranda Nos. VYM 305/85 and VYM 326/85 addressed the stress

analysis for the HPCI piping to verify the adequacy of piping

and supports adjacent to the failed anchor MS-HD-222. The

analysis involved four stress runs with variations to the

boundary conditions in the analytical model. The analysis was

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performed using SRP criteria discussed in Section 2.1. In all

cases piping stress levels were considerably below allowable

ANSI B31.1 code limits. Adjacent support loads were also well

within the capacity of the hangers.

Memoranda No. VYM 322/85 and VYM 10/86 provided an evaluation

of normal loads associated with embedded plates in the Torus Room

and HPCI Corner Room walls. Enclosed with the first memorandum

was a tabulation of embedded plates at elevation 226'-3",

232'-8" and 241'-0". The tabulation included identification

of attachments to the embeds, magnitude of normal operating

loads and the ratio of normal to maximum design loads for these

attachments The majority of the attachments were subjected

to their maximum design loads as they supported dead weight

hangers. The second memorandum provided a status of the

embedded plates *n the above designated areas.

Disposition of LER No. 85-13 (Revision 1) identified the pro-

bable cause of the embedded plate failure as a result of per-

sonnel error by the contractor responsible for the installation

during original construction. The apparent reason for the

deficiency was the difficulty of installing the lugs connected

to the plate due to the density of the rebar in the area. QA ,

records specific to the embedded plates could not be found by -

either VY or the original architect-engineer. The LER also

addressed the corrective action which involved visual inspec-

tion of all embedded plates of the design that failed with no

evidence of concrete spalling or plate pullout that could be

attributed to improper installations.

The licensee provided the inspector with a breakdown of the various

types of embedded plates and the rationale used cf their disposition.

Cateaory I: (144) torus area wall plates which include (19) seismic-

piping supports, (22) piping gravity supports, (84) unused plates,

(5) electrical cable tray supports, (13) restraints on non-seismic i

systems and one failed plate (anchor MS-HD-22E). Disposition of the l

nineteen seismic supports included the re-analysis of the piping i

systems involved using the damping coefficient recommended by the

PVRC and ASME code case N-411. Some supports are adequate without

the embedded plate, other supports were not needed and considered

inactive and the remaining will be modified without reliance on the

embedded plate anchorage. The licensee indicated that the nineteen

embedded plates above will be administratively controlled such that

they would not be used for providing support for future safety

related installations. Gravity supports were considered acceptable

as they supported the design loads without failure. The plates

supporting electrical installations were considered acceptable based

on the visual inspection of the plates and the concrete.

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Category II: (52) specialty support plates for spider penetration

anchors and whip restraints. These plates were dispositioned based

on:

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Visual inspection with no identified distress

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Historical summary of dynamic events involving three major

transients affecting 60% of these anchors and an earthquake

event in 1982 measuring between 28% to 43% of the OBE loading

without distress or failure

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Cyclic normal operation loads without failure

Category III: (555) miscellaneous ceiling plates which include

(5 seismic supports, (27) gravity supports, (449) unused plates,

(33) plates not installed, (2) electrical cable tray supports,

(38) restraints on non seismic systems and one plate which failed

during original construction. The probable cause of the plate

failure was the attempt to use the plate in the lifting of heavy

motor generator sets in the east side of the reactor building.

Plates of this category were dispositioned based on:

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87% of the plates are not installed or used

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gravity hangers are supporting their operational loads without

exhibiting distress or failure

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remaining supports sustained no damages during the seismic

event in 1982.

The inspector noted that the disposition of the nineteen plates

which support seismic piping in category I above involved the

re-analysis of the piping system using higher damping coefficient

than that described in the FSAR. The licensee indicated that a

request to use the damping values recommended by the PVRC and ASME

code case No. N-411 was submitted to the NRC office of NRR. The

licensee anticipates to receive approval for the use of ASME code

case N-411 in the seismic re-analysis of piping. systems. This item

will remain open pending:

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NRR approving the use of code case N-411 in the piping

re-analysis

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completion of modifications required for the seismic supports

in category I

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licensee's implementation of the administrative control of the

nineteen plates in category I addressed above.

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2.6 (0 pen) Unresolved Item (271/86-01-11)

The unresolved item was related to the identification of gaps between

surface mounted base plates and walls. In NRC inspection No.

271/86-01, two piping support base plates for the RHR and HPCI systems

were found to have gaps greater than 1/16" in one case and approxi-

mately 1/8" in the other. Three other supports in the SW and SLC

systems were identified in NRC inspection No. 271/86-04 to have

excessive gaps between the base plates and wall of up to 0.153".

The licensee performed walkdowns for the inspection of base plate

installations and the assessment of gaps identified between support

base plates and walls. The licensee's review identified several

cases of support installations with gaps of varying sizes. The

approach selected for the resolution of those findings included the

evaluation of three different categories of base plates:

1. Generic evaluation of three standard base plate installations

which were used in the seismic re-analysis program.

2. Evaluation of nine standard base plate configurations which

represented bounding cases of several other support installa-

tions.

3. Specific evaluation of non-standard base plates from twenty (20)

supports which could not be qualified under the above category.

Detailed evaluation packages pertaining to the above cases were not

provided to the inspector in sufficient time to perform the review on

site. The review was therefore performed in the regional office.

Results of this review are addressed below.

The first category of base plates included three different generic

configurations commonly used in conjunction with the Red Head and

base plate replacement in the piping and support up grade program.

Evaluation of these configurations was performed with gaps varying up

to 1/8" (calculation No. BPG-001). Only plates subjected to applied

moment loads had experienced significant increases of bolt loads.

Increases of up to 56*; were computed depending on the extent of gap

width and area under the plate. The results were obtained from

finite element analyses performed by CYGNA using computer code

"EPLATE". The report indicated that applied moment loads are

typically accompanied with axial tension and lateral shearing forces.

Bolt loads and plate stresses were found not to be affected by the

presence of gaps for tension and shear loads. The evaluation con-

cluded that the increase in bolt forces and plate stresses due to

moments alone would not have a significant increase since bolt

qualification considers interaction of moment, tension and shearing

loads.

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The second category (standard base plates) involved nine cases

which were qualified using hand calculations utilizing what was

considered in the evaluation reports as conservative assumptions

(calculation No. VYC-446). The cases evaluated included base

plates with multiples, eccentric and non-symmetric attachments.

The licensee evaluation concluded that in all cases bolt

interactions were acceptable.

The third category (non-standard base plates) were qualified

using specific finite element analyses of the twenty cases

identified. The evaluation was performed by CYGNA in calcula-

tion No. BPG-002.

During the course of review of the above calculation packages,

the inspector noted the following:

1. Calculation No. BPG-001 of the three generic base plate

configurations concluded that increases of bolt loads due

to gaps between plates and the walls could be as high as

56% for cases where support designs are governed by moment

loads. Conclusions drawn regarding the insignificant

increase in plate stresses appeared not to be substantiated

in the analysis since increases in bolt loads could be

significant for bolts subjected moment loads.

2. The evaluation performed for plates in category 1 did not

specify whether the analyzed models represented worst case

loads or configurations. Also, the evaluation report did

not identify whether a walkdown of support installations in

this category was performed and the extent of findings in

various plant locations affected by the SRP upgrade. ,

3. Base plate configurations evaluated in the second category

involved multiple, eccentric and non-symmetric structural

attachments. The hand calculations performed contained

simplifying assumptions to facilitate the calculations.

These simplifying assumptions do not consider factors that

can contribute significant increases to the bolt loads and

plate stresses.

4. Documentation pertaining to specific evaluation of non-

standard base plates (category 3) was incomplete and '

illegible.

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5. The extent of the licensee's walkdown of safety related

supports in the second and third categories was not speci-

fic with regard to the identification of areas inspected,

number of supports examined and type of supports (i.e.,

piping, cable tray or HVAC).

Based on the above, this unresolved item will remain open

pending resolution of the foregoing items. The licensee's Lead

Mechanical Engineer was informed of the above five concerns and

indicated they would be addressed in a timely manner.

3. Review of OA/QC Interface

The inspector performed a review of quality assurance records related to

outstanding items addressed in subsections 2.2 and 2.5 above. Auxiliary

re.ards related to testing of small bore pipe supports included:

QC calibration reports by Mercury Company of pressure gauges (TE-629

and TE-631) and Tensionmeters (TE 283 and TE 284)

Qualification of inspection and test personnel certification records

including eye examination report

Quality records relating to inspection of modifications of recirculation

piping whip restraints included:

Morrison Knudsen (M/k) visual weld examination report (Inspection

No. 5030-24-1-A-X) for weld No. FW-1 or whip restraint No. R7A

M/k Nonconformance Report No. 223 for whip restraint No. R7A

M/k visual weld examination report (Inspection No. 5080-24-2-A-X)

for welds No. FW-2A and FW-3A on restraint No. R6B

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M/k Inspection Report No. 5080-24-5-A-X and non-conformance report

No. 232 for field weld No. FW-5 on restraint R98

M/k Weld History Card No. WHC-5080-24

VY Vendor surveillance report No. 85-52-8 or M/k on January 17,18,

20/1986.

The inspector identified that M/k quality control personnel had documented

a final weld examination sign-off in the weld history card for weld build-  !

up on all four whip restraints which required modifications. Documenta- .

tion for visual weld examination was available for welds on two restraints l

only (R7A and R6B). Documentation for visual weld examination on res- l

traints R6A and R98 was not available.

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Section 4.9.2 of M/k Visual Weld Examination Procedure No. FQP-9.1

requires technicians to complete the Visual Weld Examination Reports on

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required examinations. Also, M/k General Instructions Procedure for

Conduct of Inspection (FQP-10.1) requires in Section 4.3 that inspection

results be documented in accordance with instructions of specific proce-

dures or, in their absence, to the requirements of FQP-10.1. M/k QC

indicated that an apparent misunderstanding by personnel of the require-

ments in FQP-10.1, regarding documentation of inspections, in the absence

of specific procedure, could have resulted in the failure to complete the

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proper documentation. The inspector expressed his concern about the

extent of QC personnel's failure to perform and document their activities

in recirculation piping replacement. The failure of M/k QC to document

the visual examination reports for restraints R6A and R98 is a violation

of procedures FQP-9.1 and FQP-10.1 and Technical Specification 6.5.A.5

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(271/86-12-02).

4. Unresolved Items

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Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable, violations or

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deviations. i

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Unresolved items identified during this inspection are discussed in

paragraph 2 above.

5. Exit Interview

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The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on May 16, 1986, at Vermont Yankee

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Nuclear Power Station. The inspector summarized the findings of the

inspection. The licensee acknowledged the inspector's comments. At no

time during this inspection was written material provided to the licensee

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Attachment 1

Design Documents Reviewed

Work Instruction for Pipe Stress Analysis

Work Instruction for Pipe Support Analysis

Design Criteria for Pipe Stress Analysis

Design Criteria for Pipe Support Analysis

Design Calculation for Support No. HPC-HD28

Design Calculation for Support No. CST-HD478

Design Calculation for Support No. CST-H19

Design Calculation for Support No. MS-HD8A

Design Calculation for Support No. SA-H18N

Design Calculation for Support No. RCIC-HD85

Design Calculation for Support No. RHR-HD235

Design Calculation for Spring Hanger No. ACSP-HD30C

Design Calculation for Spring Hanger No. ACSP-HD22A

Design Calculation for Spring Hanger No. ACSP-HD26A

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Attachment 2

Table I: SRP Piping and Support Installation Inspected

High Pressure Coolant Injection Piping No. 10"-MS-48,

Isometric No. 8005-Drawing No. PI 1061, Sheet 1 of 1

Support No. HPCI-HD103FN

Support No. HPCI-HD103A

Support No. HPCI-HD103B

Support No. HPCI-HD103C

Support No. HPCI-HD103GN

Support No. HPCI-HD102A

Support No. HPCI-HD102EN

Support No. HPCI-HD102D

Support No. MS-H13

Table II: Torus Attached Piping-Spring Hanger Supports Inspected

Support No. HPCI-HD103

Support No. HPCI-HD108B

Support No. HPCI-HD39

Support No. HPCI-HD107A

Support No. HPCI-HD109A

Support No. HPCI-HD1078

Support No. HPCI-HD1078

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