IR 05000255/1990002

Enforcement Conference Rept 50-255/90-02 on 900108.Major Areas Inspected:Apparent Violations of 10CFR50,App B, Criteria Iii,V & Xvi Re Piping & Pipe Support Activities

ML18054B407
Person / Time
Site:	Palisades
Issue date:	01/18/1990
From:	Danielson D, James Gavula, Liu W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18054B406	List: IR 05000255/1990002 ML18054B405
References
50-255-90-02-EC, 50-255-90-2-EC, IEB-79-14, NUDOCS 9001300140
Download: ML18054B407 (21)

Text

{{#Wiki_filter:-. ( (..* U. S. NUCLEAR REGULATORY COMMISSION REGION 11 I Report No. 50-255/9Q002(DRS) Docket No. 50-255 License No. DPR-20 Lice~see: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Palisades Nuclear Generating Plant* . ' Meeting At: RegiOn-III Office, Glen Ellyn, Illinois Meeting Conducted: January 8, 1990 ' Type of Meeting: Enforcement Conference Inspectors: td * c-*. ~.{{ - H. c.. L1u . Approved By: D. A *. Danielson,_ Chief Materials and Processes Section Meeting Su1W11ary: - . . / //1i/9c;; Date /- /C-- '!CJ Date

• Meeting on January 8, 1990 (R~ort No. 50-255/90002(DRS))

Matters Discussed: _Apparent violations of 10 CFR 50, Appendix B, Criteria III, . V and XVI associated with piping and pipe support activities were discusse Examples of a progranunatic breakdown in the control of design activities, procedural compliance and corrective actions were given. Disposition of the apparent violations will be presented in a subsequent communicatio.. -. ( ~ DETAILS Persons Contacted Consumers Powe~ Company (CPCo) G. Heins, Senior Vice President, Energy Supply D. Hoffman, Vic~ President, Nuclear Operations G. Slade, Plant General Manager, Palisades D. VandeWalle, Director, Safety and Licensing, Palisades K. Berry, Director, Nuclear Licensing D. Malone, Senior Nuclear Licensing Analyst W. Roberts, Plant Projects, Palisades R. Jenkins, Engineering, Jackson Nuclear Regulatory Conunission (NRC) C. Paperiello, Deputy Regional Administrator H. Miller, Director, Divisi~n 6f Reactor Safety J. Grobe, Director of Enforcement R. Cooper, II, Chief, Engineering Branch, DRS W. Axelson, Chief, Projects Branch 2, DRP W. Schultz, Enforcement Coordinator D. Danielson, Chief, Materials and Processes Section, DRS E. Schweibinz, Project Engineer, DRP W. Liu, Reactor Inspector, DRS J. Gavula, Reactor Inspector, DRS L. Marsh, Branch Chief, EMEB A. Lee, Engineer,, EMEB * _ R. Perfetti, Enforcement Reviewer A. DeAgazio, Project Manager, NRR Enforcement Conference As a result of apparent violations of NRC requirements, an Enforcement Conference was held in the NRC Region III Office on January 8, 199 The preliminary findings which were the bases for these apparent violations are documented in NRC Inspection Report No. 50-255/89024(DRS) and were - transmitted to the licensee by letter dated January 4, 199 The attendees at this conference are noted in Paragraph l of this repor Th~ purposes of this conference were: (1) to discuss the apparent violations, the significance, cause, and the licensee's corrective actions; (2) to determine whether there were any mitigating circumstances; and (3) to obta1n other information which would help determine the appropriate enforcement actio The NRC representatives identified the three apparent violations and the deficiencies indicative of an apparent prograrrmatic breakdown in the controls for piping and pipe support engfneeriQg activities. The apparent violations identified included: (1) inadequate design control as

-. .. ( demonstrated by overstressed structural components identified as Detail A-A for supports EBl-S2 and EB1-S3 which were modified 1n 1987 and were

• not evaluated for design adequacy; (2) failure to follow procedures in the evaluation of pipe supports GC1-Hl37, GC1-Hl40 and in the piping analysis EA-SC-88138-4; and (3) inadequate corrective action as demonstrated by _not initiating a corrective action document in 1987 for significant deficiencies in pipe s~pports EBl-S2, EBl-S3, EB1-S5, and EBl~S Causal factors involved with the above deficiencies inclµded:

inattention to detail-on the part of:the preparer; inadequate design verification activities; limited efforts toward solving and determining the root cause of identified problems; and _ potential lack of technical reviews during quality_assurance audit The licensee 1s presentation material. is included as Enclosure 2 to this report. A historical perspective was initially-given_with regard to IE Bulletin (IEB) 79-14 piping and pipe support work and recent NRC inspection activities for this engineering area. A summary was provided giving_ the deficiencies identified during the recent inspection with an assessment of the significance, root causes and corrective actions, both immediate and long ter Based.on evaluations of each deficiency, the * licensee concluded that although the safety margins were less than standard, the piping involved would not ha~e failed and the public wa *not at ris The licensee 1s root cau~e determination for the design control deficiencies was the failure to identify the boundaries and interfaces of the modifications in questio In addition, as a result of questions posed during previous meetings with the NRC, the licensee is establishing a four member panel to perform a detailed root cause evaluation of the deficiencies not~d in the IEB 79-14 progra This evaluation will

determine w~ether other programs or engineering areas were similarly_ affecte Corrective actions presented by the licensee included: completed all modifications required for the specifically identified deficiencies; . reiterated recent progralllTlatic changes to the design control process which resulted from the recent NRC Engineering Team Inspection findings;

co!l1Tlitted to have third party reviews of structural design related analyses; placed a notice in the IEB 79-14 records regarding the need to conduct walkdowns and reanalyses to confirm record accuracy; submitted Interim Operating Criteria for assessing the operability of piping and supports found to be outside FSAR stress allowables; developed detailed specifications for the ~onduct of piping and support design analysis which are currently under review; an outlined the safety-reJated piping reverification progra ' 3

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• - Conclusion The evaluation and disposition of these apparent violations will be presented in subsequent communicatio.

( ( ENFORCEMENT CONFERENCE REGARDING DESIGN CONTROL RELATIVE TO IE BULLETIN 79-14 MI0190-1711A-TC01 CONSUMERS POWER COMPANY/ U S NUCLEAR REGULATORY Cor..ISSION GLEN ELLYN, ILLINOIS JANUARY 8, 1990

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( \\ OPENING REMARKS HISTORICAL*PERSPECTIVE .SNUBBER REDUCTION PROGRAM/ AGENDA IE BULLETIN 79-14 INSPECTION/ (89024) * ENGINEERING INSPECTION TEAM (89007) CONFIGURATION CONTROL PROJECT INSPECTIONS/ SAFETY RELATED PIPING REVERIFlCATION PROGRAM CLOSING REMARKS (. G B SLADE D J VANDEWALLE D P HOFFMAN ATTACHMENT 1: EXAMPLES OF BECHTEL ANALYSIS ERRORS NOTED BY PIPING ANALYSIS PERSONNEL MI0190-1711A-TC01

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• JULY 1979 APRIL 1980 DECEMBER 1981 NOVEMBER 1983 NOVEMBER 1987

MI0190-1711A-TC01 ~ ( HISTORICAL PERSPECTIVE IEB 79-14 ISSUED BECAUSE NRC CONCERNED THA PIPING AND SUPPORT SEISMIC ANALYSES MAY NOT NECESSARILY REFLECT AS-BUILT CONDITION ' NUMEROUS NRC INSPECTIONS WERE CONDUCTED DURING PROJECT (IR 50-255/79-12, 79-18, 80-07).

NO ITEMS OF NON-COMPLIANCE WERE IDENTIFIE NRC LETTER (*SAFETY ASSESSMENT0 ) FROM NRR NOTED 0 REASONABLE ASSURANCE THAT PIPING SYSTEMS AS MODIFIED WILL NOT FAIL DURING OBE OR SSE.* NRC CONDUCTS DETAILED SEISMIC REVIEW AND ANALYSIS OF PLANT STRUCTURES AND PIPING SYSTEMS (AUXILIARY FEEDWATER, MAIN STEAM, SAFETY INJECTION, ETC) AS PART OF SEP TOPIC III-NRC SER CONCLUDES:

• PIPING SYSTEMS ARE CAPABLE TO WITHSTAND THE -

POSTULATED SEISMIC EVENT."

NRC INSPECTION REPORT 50-255/83-25 NOTED ALL IEB 79-14 ITEMS CLOSE CONFIGURATION CONTROL PROJECT SCOPE OF WORK DOCUMENT IDENTIFIED NEED FOR WALKDOWN AND REVERIFICATION OF PIPING WHICH WAS MODIFIED. SUBSEQUENT TO IE BULLETIN 79-1 HOWEVER ELECTRICAL AREAS DEEMED PRIORITY * -1

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HISTORICAL PERSPECTIVE (CONTINUED) APRIL-JUNE 1989. NRC ENGINEERING TEAM (89007). INSPECTION CON_- . - DUCTE IDENTIFIED THREE 79-14 DOCUMENTATION ERROR ' AUGUST 1989 CPCO RESPONSE TO IR 8900 CCM4ITTED TO A SAMPLE REVIEW OF 79-14 DOCUMENTATIO AUGUST 1989 CPCO MEETS WITH REGIQN III MANAGEMENT TO PRE-SENT IR 89007 RESPONS APPARENT AGREEMENT WITH ACTION PLAN.. AUGUST-SEPTEMBER-NRC SNUBBER-REDUCTION PROGRAM/IEB 79-14 OCTOBER 1989 INSPECTION (89024) CONDUCTE REPORT PEND-IN ADDITIONAL 79-14 DOCUMENTATION ERRORS IDENTIFIE OCTOBER 1989 CPCO LETTER TO NRC PRESENTING PLANNED CORRECTIVE ACTIONS IN RESPONSE TO INSPECTOR CONCERN OCTOBER 1989 CPCO MEETS WITH NRR TO.DISCUSS SIGNIFICANCE OF IEB 79-14 ISSUE NOVEMBER 1989 NRR AUDIT TEAM REVIEW AT PALISADE NOVEMBER 1989 CPCO SUBMITS PIPING REVERIFICATION PROGRAM INTERIM OPERABILITY CRITERI NOVEMBER 1989 CPCO MEETS WITH NRR TO DISCUSS PIPING REVERIFICATION PROGRAM AND JUSTIFY PLANT RESTAR NOVEMBER 1989 CPCO SUBMITS LETTER CONFIRMING NOVEMBER 17, 1989 REVERIFICATION PROGRA NOVEMBER 1989 MI0190-1711A-TC01 CPCO SUBMITS REVISED INTERIM OPERABILITY CRITERIA RESOLVING NRC CCll4ENTS FROM CPCO'S NOVEMBER 13, 1989 SUBMITTA ( SNUBBER REDUCTION PROGRAM/IEB 79-14 INSPECTION (89024) NRC IDENTIFIED DEFICIENCY -* 13 ISSUES IDENTIFIED IN EXIT * . 12 OF 13 HAVE BEEN FOUND TO BE NON-SAFETY SIGNIFICAN SNUBBER REDUCTION ANALYSIS IDENTIFIED THE MAIN STEAM LINE U-BOLT WOULD BE OVERSTRESSED IN A SEISMIC'EVENT, HOWEVER OVERSTRESSED U-BOLT CONNECTION ASSEMBLY AND ECCENTRIC WELD CONDITION NOT IDENTIFIE SIGNIFICANCE - ANALYSIS INDICATES PIPING WOULD NOT HAVE FAILED AND PLACED THE PUBLIC AT RISK, BUT ANALYSIS HAS LESS MARGIN THAN STANDARD METHODOLOG CONSUMERS POWER COMPANY IDENTIFIED ROOT CAUSE - ANALYSIS/REVIEW FAILED TO IDENTIFY BOUNDARIES OF AFFECT OF THIS CHANG ANALYSIS/REVIEW FAILED TO IDENTIFY INTERFACES WITH OTHER COMPONENTS OF HANGER.. . MI0190-1711A-TC01

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( SNUBBER REDUCTION PROGRAM/IEB 79-14 INSPECTION (89024)

• CONTINUED CORRECTIVE.ACTIONS

- ALL REQUIRED MODIFICATIONS ARE COMPLETED , -* PROGRAlfltATIC CHANGES TO DESIGN CONTROL PROCESS (RESPONSE TO 89007 INSPECTION) . . - THIRD PARTY REVIEW OF STRUCTURAL DESIGN RELATED.ANALYSIS - NOTICED THE 79-14 RECORDS SO THAT THEY ARE NOT SOLELY RELIED UPON FOR DESIGN BASIS INPUT, AND TO DIRECT THE ANALYST TO CON- . DUCT APPROPRI-ATE AS-BUILT WALKDOWNS AND REANALYSES TO CONFIRM RECORD ACCURACY - DEVELOPED AND AGREED WITH CC>P+tISSION ON INTERIM OPERATING CRITERIA - DETAILED SPECIFICATIONS FOR THE CONDUCT OF PIPING AND SUPPORT DESIGN ANALYSIS AND THEIR TECHNICAL REVIEW ARE DEVELOPED AND ARE IN REVIEW - - SAFETY RELATED PIPING REVERIFICATION PROG~ MI0190-1711A-TC01 .

DEFICIENCIES REQUIRING MODIFICATION TO MEET FSAR ITEMS CORRECTED PRIOR TO START-UP

ITEM DESCRIPTION MAIN STEAM LINE SUPPORT 111 AUXILIARY FEEDWATER LINE (NOT IN 79-14 SCOPE) HIGH PRESSURE SAFETY INJECTION LINE TO PRIMARY COOLANT SYSTEM MI0190-1711A-TC01. DEFICIENCY NRC IDENTIFIED U-BOLT CONNECTION TO I-BEAM ASSEMBLY UPPER STRUT ATTACHMENT WELD CONFIGURATION (ECCENTRICITY) EXCESSIVE FLEXIBILITY IN STEAM TRAP DRAIN LINE CPCO IDENTIFIED BENDING MOMENT AT BASE PLATE BEYOND FSAR MODIFICATION/REPA REPLACED AFFECTED ASSEMBLIES ADDED WELD MATERIAL AND REMOVED ECCENTRIC CONDITION ADDED THREE SUPPORTS ADDED STIFFENER PLATES

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( ENGINEERING INSPECTION TEAM (89-007) 3 OF 19 IDENTIFIED DEFICIENCIES WERE REL"TED TO 79-14 ISSUE THE EIT CORRECTIVE ACTIONS REMAIN UNCHANGE LISTED ACTION ITEMS HAVE BEEN COMPLETE WEAKNESSES IN DESIGN CONTROL AS INDENTIFIED BY CPCO - PERSONNEL PERFORMANCE INATTENTION TO DETAIL AND LESS THAN STRICT PROCEDURAL COMPLIANCE - PROCEDURES THE FACILITY CHANGE AND SPECIFICATION CHANGE PROCEDURES L"CK CLARITY - WELD ENGINEERING DEFICIENCIES CLEAR DESIGN BASIS AND ENGINEERING INVOLVEMENT LACKING - DOCUMENTED ENGINEERING JUDGEMENT

• LACKS CONSISTENCY AND PROGRAM GUIDANC NRC IDENTIFIED PROGRAM STRENGTHS

- GOOD OVERALL DESIGN PROCEDURES - IMPROVED PERFORMANCE IN PUMP AND VALVE TESTING - COMPETENT AND KNOWLEDGEABLE INDIVIDUALS - GOOD ELECTRICAL DESIGN BASIS DOCUMENTS MI0190-1711A-TC01

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CORRECTIVE ACTIONS ENGINEERING INSPECTION TEAM (CONTINUED) - BRIEFED ENGINEERING STAFF*IN DETAIL ON INSPECTION' RESULTS - PERSONALLY ADDRESSED SPECIFIC CONCERN AREAS TO EACH ENGINEER

• - ADDED REQUIREMENTS FOR WELD ENGINEERING AND FIELD VERIFICATION

~ CONTINUE TO STRENGTHEN INTER/INTRA-DEPARTMENT COM4UNICATIONS WITH SEMI-ANNUAL DESIGN SEMINARS, MONTHLY SUPERVISORS MEETINGS, AND QUARTERLY ALL ENGINEERS MEETINGS

• - FIELD VERIFICATION OF PIPING AS-BUILT DIMENSIONS TO CONFIRM THE ACCURACY OF STRESS ISOMETRIC DRAWINGS FOR A SAMPLE SYSTEM BY

- 1990 REFUELING OUTAG *- REVISED DESIGN CONTROL PROGRAM PROCEDURALLY (ADMIN 9.03, 9.04, 9.11) - MI0190-1711A-TC01 . 7

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( ENGINEERING INSPECTION TEAM (CONTINUED) CORRECTIVE ACTIONS (CONTINUED) ADMINISTRATIVE PROCEDURE 9.11 1 ENGINEERING ANALYSIS* NOW PROVIDES: - VENDOR INFORMATION RECCMtENDATIONS ARE RECONCILED - BASIS FOR SELECTING THE GOVERNING DESIGN BASIS

• - ASSURE ALIGNMENT _BETWEEN ANALYSIS, DRAWINGS AND AS-BUILT CONFIG..,

URATIO *- REQUIREMENT THAT ANALYSIS ASSUMPTION BE CONFIRMED PRIOR TO EQUIPMENT BE-ING DECLARED OPERABLE - A PUNCH LIST TO TRACK ITEMS REQUIRING VERIFICATION WHEN THE ITEMS ARE AVAILABLE TO VERIFY .

• - REQUIREMENT TO DOCUMENT THROUGH AN ANALYSIS REVISION, ANY INPUT THAT WAS JUDGED BY ENGINEERING NOT TO AFFECT THE ANALYSIS

- A TECHNICAL REVIEW CHECKLIST

• - REQUIRE THAT EACH ENGINEERING ANALYSIS AS A MINIMUM INCLUDES:

_ o TECHNICAL REVIEWER COftitENTS o JUSTIFICAlION OF NUMERICAL INPUTS o RECONCILED VENDOR INFORMATION o INPUT ASSUMPTIONS ARE VALIDATED o DESIGN CODES/STANDARDS JUSTIFIED o ANALYSIS OBJECTIVES CARRIED OUT o ALL CALCULATED VALUES VERIFIED-MI0190-1711A-TC01

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( ( ENGINEERING INSPECTION TEAM (CONTINUED). CORRECTIVE ACTIONS (CONTINUED) ADMINISTRATIVE PROCEDURE 9.04 *SPECIFICATION CHANG[* THE ENGINEERING ANALYSIS FOR THE SPECIFICATION CHANGE ADDRESS THE FOLLOWING ADDITIONAL REQUIREMENTS: - ASSURE THAT THE REASON FOR THE CHANGE IS CLEA DESCRIBE HOW THE CHANGE WILL AFFECT THE SYSTE *- DESCRIBE HOW THE CHANGE WILL AFFECT THE SPECIFIC COMPONENT OPERABILITY AND AFFECT ON INTERFACING COMPONENT. .

• - IDENTIFY THE CRITICAL FUNCTION OR PHYSICAL FEATURES THAT MUST BE MET BY THE CHANGE TO ACHIEVE INTENDED AS-BUILT CONDITION *
• REQUIRE THAT PRE-OPERATIONAL TESTING BE.SPECIFIED AS PART OF SC ENGINEERING AND REQUIRE THAT THIS TESTING ALIGN WITH THE CRITICAL FEATURES IDENTIFIED AS PART OF THE SC ENGINEERIN _ ADMINISTRATIVE PROCEDURE-9.03 *FACILITY CHANGE 0 REVISE DESIGN INP-UTS TO IDENTIFY SEISMIC RESPONSE SPECIFICATIONS (C-175 AND M-195) AND THEIR POTENTIAL APPLICATION REVISE DESIGN CONTROL TO FURTHER CLARIFY THE REQUIREMENT FOR STRICT ALIGNMENT BETWEEN ENGINEERING ANALYSIS AND ASSOCIATED DRAWING REVISE INSTALLATION PROCEDURE TO REQUIRE AS-BUILT CONDITION MUST BE VERIFIED AND DOCUMENTED PRIOR TO DECLARING MODIFIED SYSTEMS/

EQUIPMENT OPERABLEQ MI0190-1711A-TC01

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• NO. HANGERS/SYSTEM 8/HPSI 11/AUX FEED DEFICIENCIES IDENTIFIED BY CCP PRIOR TO INTERIM OPERATING CRITERIA WALKDOWN RESULTS 4 MINOR DIMENSIONS 2 INACCESSIBLE 2 SATISFACTORY 5 MINOR DIMENSIONS..

3 INACCESSIBLE 3 SATISFACTORY MINOR DIMENSIONS FALL WITHIN NCIG ACCEPTANCE CRITERI CALCULATION PROBLEMS DID NOT MEET IMPELL SPECIFICATION MI0190-1711A-TC01

CALCULATION REVIEW RESULTS 8 CALCULATION PROBLEMS 3 RESOLVED AS SATISFACTORY 5 RECALCULATED

4 - OK* . 1 - FAILED & WAS REPAIRED 11 MINOR CALCULATION PROBLEMS NO RECALCULATIONS

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• DEFICIENCIES IDENTI~IED BY CCP AFTER INTERIM OPERATING CRITERIA I

NO. HANGERS/SYSTEM WALKDOWN RESULTS 5/SHUTDOWN COOLING 5 MINOR DIMENSIONS 2 PHYSICAL DISCREPANCIES 1 REPAIRED 1 TO BE REPAIRED* 5/HPSI 5 MINOR DIMENSIONS 1 PHYSICAL DISCREPANCY - REPAIRED - MET OPERA-

• BILITY I/PRESSURIZER SPRAY 1 MINOR DIMENSIONS 1 PHYSICAL DISCREPANCY -
• REPAIRED - MET FSAR MINOR DIMENSIONS FALL WITHIN NCIG ACCEPTANCE CRITERI CALCULATION PROBLEMS DID NOT MEET IMPELL SPECIFICATION * MI0190-1711A-TC01

CALCULATION REVIEW RESULTS 5 CALCULATION PROBLEMS 3 RECALCULATIONS - OK

• -2 RECALCULATIONS - MEET
• OPERABILITY 5 CALCULATION PROBLEMS 1 RESOLVED AS OK 4. RECALCULATIONS *_

3 OK 1 MEETS OPERABILITY MINOR CALCULATION PROBLEM - RESOLVED AS OK

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( ( - SAFETY-RELATED PIPING REVERIFICATION -PROGRAM PROGRAM-CONSTITUENTS - WALKDOWNS TO VERIFY AS-INSTALLED CONDITIONS - TO COMPARE AS-INSTALLED TO AS-ANALYZED ANO RECONCILE ANY DIFFERENCES - UPDATED ENGINEERING SPECIFICATIONS FOR PIPING AND PIPE SUPPORT DESIGN AND ANALYSIS - INDEPENDENT REVIEW OF WALKDOWNS AND CALCULATIONS -, - QA INVOLVEMENT FROM CONCEPTUAL PLANNING TO FINAL CLOSEOUT PHASE I BOUNDARIES - SAFETY-RELATED PIPING 2~u AND LARGER - SYSTEMS TO BE INCLUDED: HIGH PRESSURE SAFETY INJECTION AUXILIARY FEEDWATER PORV PIPING TO QUENCH TANK_ (ABOVE SYSTEMS SELECTED CONSIDERING PRA IMPORTANCE) CLASS 1 PIPING TO SECOND lSOLATION VALVE - INCLUDES VERIFICATION OF BASE Pl.ATES AND ANCHOR BOLTS - REVIEW OF WELDED ATTACHMENTS - SOME SUPPORTS MAY NOT BE INSPECTED DUE TO ALARA AND ACCESS CONSIDERATIONS MI0190-1711A-TC01 12' -

/ \\ SAFETY--RELATED PIPING REVERIFICATION PROGRAM (CONT_INUED) PROJECT MlLESTONES ITEM FINALIZE PROJECT PROCEDURES BEGIN WALKDOWNS OUTSIDE CONTAINMENT . . CONTINUE WALKDOWNS INSIDE CONTAINMENT BEGIN PIPE STRESS AND SUPPORT CALCULATION VERIFICATIONS ' DATE JANUARY, 1990 MARCH 1990 .CONCURRENT WITH

• SPRING OUTAGE

.. . WITHIN 2 WEEKS OF STARTING WALKDOWNS JULY, 1990 - CONCURRENT WITH COMPLETE WA.LKDOWNS OUTSIDE CONTAINMENT COMPLETE REMAINING WALKDOWNS INSIDE CONTAINMENT S/G REPLACEMENT OUTAGE EVALUATE PHASE I RESULTS AND IDENTIFY PHASE II SCOPE MJ0190-1711A-TC01 DECEMBER, 1990

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( (. STRESS PACKAGE 3342 REVIEW DURING A REANALYSIS OF THIS SYSTEM, IT WAS DETERMINED THAT.AN INPUT ERROR IN THE SEISMIC INPUT HAD BEEN MAD THAT ERROR RESULTED IN A SIGNIFICANT NARROWING OF THE SEISMIC INPUT. A CORRECTION OF THE INPUT RESULTED IN UNACCEPTABLE PIPE STRESSES AND SUPPORT LOAD THE SYSTEM WAS RERUN SEISMICALLY WITH ASME CODE CASE N-41 THE RESULTS WERE ACCEPTABL STRESS PACKAGE 3358 REVIEW DURING A REVIEW OF THIS PACKAGE FOR A CHANGE IN VALVE OPERATOR 'LOADS, IT WAS DETERMINED THAT SUPPORT LOCATION AND ORIENTATION CONCERNS EXISTE IN ONE CASE, THE PRIOR ANALYSIS HAD THE SUPPORT PLACED FIVE FEET AWAY FROM ITS ACTUAL ORIENTATIO IN ANOTHER CASE,,LARGE,PIPE THERMAL MOVEMENTS SUGGESTED THAT THE PIPE SUPPORT PROVIDED MORE RESTRAINT THAN INCORPORATED IN THE ANALYSE THE SUPPORT LOCATION PROBLEM WAS EVALUATED DIRECTL THE POTENTIAL ADDITIONAL RESTRAINT WAS EVALUATED BY TEST RUNS AND SENSITIVITY ANALYSE THE CONCLUSIONS WERE THAT THE SYSTEM WAS ADEQUAT MI0190-1711A-TC01

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( c STRESS PACKAGE 3320 REVIEW DURING THE REVIEW OF STRESS PACKAGE 3320 FOR SNUBBER REDUCTION~ TWO SUPPORT,S WERE VIEWED TO BE OF MARGINAL DESIGN BASED UPON IEB 79-14 LOAD FOR ONE SUPPORT, THE SUPPORT WELD STRESSES WERE NOT PROPERLY EVALUATE FOR THE OTHER SUPPORT., THE SUPPORT ANALYSIS DID NOT USE FINAL DESIGN LOADS.. DURING THE SNUBBER REDUCTION WORK, THE SUPPORTS WERE 'EVALUATED AS A SUPPORT SYSTEM AND LEFT AS I IT WAS UNDERSTOOD, HOWEVER, THAT THE SUPPORTS WERE IN CLOSE PROXIMITY TO ONE ANOTHER AND WERE REACTING TO ONE ANOTHE IN 1989, THE TOTAL PIPING SYSTEM RESPONSE WAS IMPROVED SIMPLY BY ELIMINATING ONE SUPPOR STRESS PACKAGE 3379 REVIEW DURING THE REVIEW OF THIS PACKAGE FOR SNUBBER REDUCTION, IT WAS CONCLUDED THAT PIPE SUPPORT.CALCULATIONS WERE NOT-WELL DOCUMENTE PIPE STRESS RESULTS AND SUPPORT LOADS WERE DOCUMENTE THE LACK OF DOCUMENTATION WAS ASSOCIATED WITH PIPING WHICH COULD BE VIEWED AS NOT SAFETY RELATE DOCUMENTATION DEFICIENCIES WERE RESOLVED BY MEASURING WHIP RESTRAINT GAPS AND BY DOING STRESS/GAP CLOSURE SENSITIVITY ANALYSES; THE CONCLUSION WAS THAT WHIP RESTRAINTS PROVIDED SATISFACTORY SEISMIC BOUNDARY ISOLATION AND THE SUPPORT DOCUMENTATION WAS NOT REQUIRED TO ENSURE THE INTEGRITY OF THE CONTAINMENT PENETRATIO MI0190-1711A-TC01 }}