ML18033A794

Forwards Program Re Seismic Qualification of Instrumentation Tubing,Per 890105 Seismic Programs Overview Meeting. Significant Condition Repts Written to Address Insufficient Documentation for Tubing Installations

ML18033A794
Person / Time
Site:	Browns Ferry
Issue date:	06/13/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-73408, NUDOCS 8906230129
Download: ML18033A794 (7)

Text

.0 TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place QUID IS mes U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gent leman 1 In the Hatter of Docket Ho. 50-260 Tennessee Valley Authority BROMHS FERRY NUCLEAR PLAHT (BFH) UNIT 2 SEISHIC QUALIFICATION OF IHSTRUHEHT TUBING This letter describes the program for the Seismic Qualification of the Browns Ferry Unit 2 Instrument Tubing. As discussed during, our Seismic Programs Overview meeting of January 5, 1989, the scope of the seismic instrumentation tubing program was increased because more instruments were identified. The HRC asked that TVA again describe it's seismic instrument tubing program and submit a program description for further NRC review. The enclosed is in response to that request.

As a brief background, two Significant Condition Reports (SCRs) were written to address insufficient documentation for tubing, installations at BFN. SCR BFH EEB 8535 was written to address the lack of design criteria for the support of capilla1.y tubing. SCR BFH EEB 8543 was written to address the lack of design criteria for thermally induced stresses for various installed sizes.

The attached report describes our program regarding Seismic Qualification of Instrumentation Tubing. If any questions exist, please contact Patrick P.

Carier, Hanager of Site Licensing, at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY Han er, Nucle Licensing and Regulatory Affairs Enclosures cc: See page 2 8906230129 890613 I pDR ADOCK 05000260 P PNU ho't'I

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An Equal Opportunity Employer

U.S. Huclear Regulatory Commission cc (Enclosures):

Hs. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Huclear Regulatory Commission One Mhite Flint,, Horth 11555 Rockville Pike Rockville, Haryland 20852 Hr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Huclear Regulatory Commission Region II 101 Harietta Street, HM, Suite 2900 Atlanta, Georgia 30323 HRC Resident Inspector Brogans Ferry Huclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

Enclosure 1 Sei-mic Qualification of Instrument Tubing The additional 130 BFH Seismic Class I tubing installations within the Unit 2 design baseline boundary will be evaluated prior to restart. An attribute approach will be used. Attributes for the tubing and tubing supports were developed based on the results of the original evaluations'performed in the completed Phase 1 portion of this program.

An attribute walkdown is being performed to identify tubing and supports which do not meet design criteria requirements.

Hodifications are being, made for those items which do not meet operability criteria requirements. Hodifications are made to the long term design criteria.

Seventy BFH Seismic Class 1 tubing installations outside the design baseline boundary will be evaluated post restart. The attribute methodology will be used for evaluating these installations. All items not meeting long term design criteria will be modified.

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TEHHESSEE VALLEY AUTHORITY BROMHS FERRY NUCLEAR.PLMT UNIT 2 IHSTRUHENT TUBING MD SUPPORTS HAY 1989 This report provides TVA's plan for specific action to qualify BFN Seismic Class I field run tubing.

ISSUE Two Significant Condition Reports (SCRs) were written to address insufficient documentation to assure design adequacy of tubing installations at BFH.

BACKGROUND All Class I Instrument Tubing at BFH was field routed and field supported in accordance with American Hational Standards Institute standards. As a result of a 1981 Nonconformance Report (BFNCEB8102) identifying the lack of a criteria for installing copper tubing, Engineering Design issued criteria BFH-50-713 titled "Seismically Qualifying Field Run Tubing". In 1985, two SCRs were written; one (SCRBFNEEB8535) addressing the lack of any retrievable documentation to verify compliance with the BFN-50-713 criteria and one (SCRBFHEEB8543) identifying that BFN-50-713 did not adequately address thermal considerations.

A" a corrective action to the SCRs, a program was developed to review all installations of BFH Seismic Class I tubing including capillary tubing. By reviewing flow diagrams, a total of 56 installations were identified to require an evaluation which incorporated the corrective action required by these SCRs. These installation- were evaluated and necessary modifications were issued. This task was completed in February 1988. These modifications will be implemented prior to unit 2 restart.

Subsequent to the above evaluations being completed, the Design Baseline Verification Program Boundary Drawings were issued. From the review of these drawings, approximately 200 additional BFN Seismic Class I tubing in..tallations were identified with approximately 130 of these installations falling within the design baseline boundaries requiring evaluation prior to unit 2 re'start.

The tubing qualification program incorporates the necessary corrective actions of applicable Conditions Adverse to Quality Reports (CAQRs) and Employee Concerns (ECs). Melding program characteristics are included in the Phase I evaluations and included in the attribute development for Phase 2 and 3.

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pt RESOLUTIOH The unit 2 and common BFH Seismic Class I tubing will be evaluated in three phases as discussed below:

Phase 1 (Pre-x'estaxt)

The original 56 tubing installations were qualified based on as-built wal'kdown information. Qualification of the tubing and the supports was performed in accordance with design criteria x.equix'ements in force prior to February, 1988.

Tubing ox supports not meeting, design criteria requirements were redesigned to meet design criteria. All modifications ax'e issued for Phase I and will be implemented by the field prior to unit 2 restart.

Phase 2 (Pre-restart)

In February 1989, new seismic criteria changes along with new seismic Amplified Re-ponse Spectra (ARS) required that a re-evaluation of the original 56 tubing problems be made. These re-evaluations are complete and no additional modifications were required to qualify these tubing installations for the new ARS or seismic critex;ia changes.

The additional 130 BFH Seismic Class I tubing installations within the Unit 2 Design Baseline Boundary will be evaluated priox'o restart. Using experience gained in evaluating the small bore piping (which uses an at. tribute approach) and the tubing, in the additional scope being similar to the Phase 1 tubing configurations, it was decided that an attxibute approach was appropriate Eor qualiEication oE the additional tubing runs. The attxibutes for the tubing and tubing supports were developed based on the results of the original evaluations performed in Phase 1 with appropriate consideration of the new criteria requirements (BFN-50-C-7103 R3).

An attribute walMown i.. being performed to identify the tubing and supports which do not meet design criteria requirements. Hodifications are being made for those items which do not meet the operability criteria requirements (BFH-50-C-7303).

Hodifications are made to meet the design critexia (BFN-50-C-7103 and BFN-50-C-7107).

Phase 3 (Post Restart)

The xemaining 70 BFN Seismic Class I tubing installations outside the Design Baseline Boundary will be evaluated post restart. The attribute methodology used in Phase 2 will also be used for evaluating these installations. The exception is that all items identified as not meeting design criteria will be modified. Restart cx.iteria will not be used in evaluating modiEication requirements for these installations.

CRITERIA Design Criteria BFH-~0-C-7103 (Piping Analysis) and BFH-50-C-7107 (Suppoxt Design) ax;e being, used fox. the tubing evaluations. In addition, BFN-50-C-7303 (Operability Criteria) is being used in determining xestaxt modification requirements for the Pha-e 2 tubing evaluation:.

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