ML18054B405
| ML18054B405 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/22/1990 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18054B406 | List: |
| References | |
| NUDOCS 9001300126 | |
| Download: ML18054B405 (24) | |
See also: IR 05000255/1990002
Text
Docket No. 50-255
..
Consumers Power Company
ATTN:
David P. Hoffman
Vice President
Nuclear Operations
1945 West Parnall Road
Jackson, MI
49201 *
Gentlemen:
JAN 2 2 1990
This refers to the Enforcement Ctinference conducted by Dr.-C. J. Paperiello
and other members of the NRC staff on January 8, 1990, at the Region III Office
in Glen Ellyn, Illinois, regarding the apparent violations identified in NRC
Inspection Report No. 50-255/89024(DRS) of activities at the Palisades Nuclear
Generating Plant authorized by NRC Operating License No. DPR-20.
The enclosed copy of our'report identifies those matters discussed during the
conference.
In accordance with 10 CFR 2.790 of the Commi~sion
1 s regulations, a copy of
- this letter and the enclosures will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning the Enforcement
Conference.
Enclosures:
l. Inspection Re~ort No.
50-255/90002(DRS)
2.
Licensee Presentation
Material
See Attathed Distribution
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Sincerely,
H. J. Miller, Director
Division of Reactor Safety
RIII
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Danielson
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Consumers Power Company
Distribution
cc w/enclosures:
Mr. Kenneth W. Berry, Directo~
Nuclear Licensing
Gerald B. Slade, General Manager
DCD/DCB (RIDS)
- Licensing Fee Management Branch
Resident Inspector, RIII
James R. Padgett
Michigan Public Servite *
Commission
Michigan Department of
- Public Health
- 2
JAN 2~ 1930
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/90002{DRS)
Docket No. 50-255
License No. DPR-20
Licensee:
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
(/ J ."'* d:'.
Inspectors: r,/l-
C
~£-(_.
w. c. Liu
.
Approved By:
U:- A. Danielson, Chief
Materials and Processes Section
Meeting Summary:
/ //E/9c::
Date
/- /t"- C/()
Date
Meeting on January 8, 1990 {Re~ort No. 50-255/90002{DRS)) * ..
Matters Discussed:
Apparent violations of lO CFR SO, Appendix B, Criteria .III,
V and XVI
associat~d with piping and pipe support activities were discussed.
Examples of a programmatic 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 communication.
1 .*
DETAILS
Persons Contacted
Consumers Power Company (CPCo)
G. Heins, Senior Vice President, Energy Supply
D. Hoffman, Vice 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 Commission (NRC}
C. Paperiello, Deputy Regional Administrator
H~ Miller, Director, Division of 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 ~nd 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
2.
Enforcement Conference
As a result of apparent violatfons of NRC requirements, an Enforcement
Conference was held in the NRC Region III Office on January 8, 1990.
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, 1990.
The attendees
at this conference are not~d in Paragraph 1 of this report.
The purpose~ of this conference were:
(1) to discuss the apparent violations,
th~ significance, cause, and the licensee's corrective actions; (2) to
determine whether there were any mitigating circumstances; and (3) to
obtain other i.nformation which would help determine the appropriate
enforcement action.
The NRC representatives identified the three apparent violations* and the
deficiencies indicative of an apparent programmatic breakdown in the
controls for piping and pipe support engineering activities. The apparent
violations identified included: (1) inadequate design control as
2
demonstrated by overstressed structural components identified as Detail
A-A for supports EB1-S2 and EB1-S3 which were modified in 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 13) inadequate corrective action as demoristrated
by not initiating a corrective action doctiment in 1987 for significant
defici~ncies in pipe supports EB1-S2, EB1-S3, EBl~S5, and EB1-S6.
Causal factors involved with the above deficiencies included:
inattention to detail on th~ ~art of the preparer;
inadequate design verification activities;
limited efforts toward solving and determining the root cause
of identified problems; and
potential lack of techn.ical reviews during quality assurance audlts~
The lic~nsee
1 s 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 inspectioh with an
assessment of the significance, root causes and corrective actions, both
immediate and long term.
Based on evaluations of each deficiency, the
licensee concluded that although the safety margins were less than
standard, the piping involved would not have failed and the pu~lic. was
not at risk.
The licensee's root cause determinatiori for the design control
deficiencies was the failure to identify the boundaries and interfaces of
the modificatioris in question.
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 noted in the IEB 79-14 program.
This evaluation will
determine whether other programs or engineering areas were similarly_
affected. *
Correcti~e acti-0ns presented by the licensee included:
completed all modifications tequired for the specifically identified
deficiencies;
reiterated recent programmatic changes to the design control process
which resulted from the recent NRC Engineering Team Inspectton
findings;
committed to have third party revi.ews 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 ac~uracy;
~ubmitted Interim Operating Crite~ia for as~essing the operability
of piping and supports fo~nd to be outside FSAR stress allowables;
developed detailed.specifications for the conduct of piping and
support design analysis which are currently under review; and
outlined the safety-related piping reverification program.
3
3.
Conclusion
The evaluation ~nd disposition of these apparent violations will be
presented in subsequent communication.
4
.
.\\
ENCLOSURE 2
ENFORCEMENT CONFERENCE REGARDING DESIGN CONTROL
RELATIVE TO IE BULLETIN 79"'."14 .
MI0190-1711A-TC01
CONSUMERS POWER COMPANY/
U S NUCLEAR REGULATORY CO...ISSION
£LEN ELLYN, ILLINOIS
JANUARY 8, 1990 .
. ENCLOSURE 2
ENFORCEMENT CONFERENCE REGARDING DESIGN CONTROL .
RELATIVE TO IE BULLETIN 79-14
CONSUMERS POWER COMPANY/
U S NUCLEAR REGULATORY- CO ... ISSION
GLEN ELLYN, ILLINOIS
. JANUARY 8, 1990
MI0190-1711A-TC01 -
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 REVERIFICATION PROGRAM
CLOSING REMARKS
G B SLADE
D J VANDEWALLE
D P HOFFMAN
ATIACHMENT 1:
EXAMPLES OF BECHTEL ANALYSIS ERRORS NOTED BY PIPING
ANALYSIS PERSONNEL
.,
MI0190-1711A-TC01
. JULY 1979
APRIL 1980
DECEMBER 1981
NOVEMBER 1983
NOVEMBER 1987 - .
MI0190-1711A-TC01
HISTORICAL PERSPECTIVE
IEB 79-14 ISSUED BECAUSE NRC CONCERNED THAT
PIPING AND SUPPORT SEISMIC ANALYSES MAY NOT
NECESSARILY REFLECT AS-BUILT CONDITIONS.
- . NUMEROUS NRC INSPECTIONS WERE CONDUCTED DURING
PROJECT (IR 50-255/79-12, 79-18, 80-07).
NO
ITEMS OF NON-COMPLIANCE WERE IDENTIFIED.
- NRC LEITER ( 1SAFETY ASSESSMENT") FROM NRR
NOTED
11REASONABLE ASSURANCE THAT PIPING
SYSTEMS AS MODIFIED WILL NOT FAIL DURING OBE
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 111-6.
NRC SER CONCLUDES:
11PIPING
SYSTEMS ARE CAPABLE TO WITHSTAND THE
POSTULATED SEISMIC EVENT.
11
.NRC. INSPECTION REPORT 50-255/83-25 NOTED ALL
IEB 79-14 ITEMS CLOSED.
.
CONFIGURATION CONTROL PROJECT SCOPE OF WORK
DOCUMENT IDENTIFIED NEED FOR WALKDOWN AND
REVERIFICATION OF PIPING WHICH WAS MODIFIED
SUBSEQUENT TO IE BULLETIN 79-14.
HOWEVER *
ELECTRICAL AREAS DEEMED PRIORITY.
1
HISTORICAL PERSPECTIVE
(CONTINUED)
APRIL-JUNE 1989
NRC ENGINEERING TEAM (89007) INSPECTION CON-
. DUCTED.
IDENTIFIED THREE 79,...14 DOCUMENTATION
ERRORS.;
AUGUST 1989
CPCO RESPONSE TO IR 89007.
CC>>l4ITTED TO A
SAMPLE REVIEW OF 79-14 DOCUMENTATION.
AUGUST 1989
CPCO MEETS WITH REGIQN I I I MANAGEMENT TO PRE-
SENT IR 89007 RESPONSE.
APPARENT AGREEMENT
WITH ACTION PLAN *.
AUGUST-SEPTEMBER-
. NRC SNUBBER REDUCTION_ PROGRAM/IEB 79-14
OCTOBER 1989
INSPECTION (89024) CONDUGTED.
REPORT PEND- .
ING.
ADDITIONAL 79-14 DOCUMENTATION ERRORS
IDENTIFIED.
OCTOBER 1989
CPCO LETTER TO NRC PRESENTING PLANNED
CORRECTIVE ACTIONS IN RESPONSE TO INSPECTOR
CONCERNS.
OCTOBER 1989
CPCO MEETS WITH NRR TO DISCUSS SIGNIFICANCE
OF IEB 79-14 ISSUES~
NOVEMBER 1989
NRR_AUDIT TEAM REVIEW AT PALISADES.
NOVEMBER 1989
CPCO SUBMITS PIPING REVERIFICATION PROGRAM.
INTERIM OPERABILITY CRITERIA*.
NOVEMBER 1989
CPCO MEETS WITH NRR TO DISCUSS PIPING
REVERIFICATION PROGRAM AND JUSTIFY PLANT
RESTART.
NOVEMBER 1989
.CPCO SUBMITS LETTER CONFIRMING NOVEMBER 17,
NOVEMBER 1989
MI0190-1711A-TC01
1989 REVERIFICATION PROGRAM.
CPCO SUBMITS REVISED INTERIM OPERABILITY
CRITERIA RESOLVING NRC COfil4ENTS FROM CPCO'S
NOVEMBER 13, 1989 SUBMITTAL *
.2
..
. .
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 SIGNIFICANT.
- 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
IDENTIFIED.
SIGNIFICANCE
- ANALYSIS INDICATES PIPING WOULD NOT HAVE FAILED AND PLACED THE
PUBLIC AT RISK, BUT ANALYSIS HAS LESS MARGIN THAN STANDARD
METHODOLOGY.
.
CONSUMERS POWER COMPANY IDENTIFIED ROOT CAUSE .
- ANALYSIS/REVIEW FAILED TO IDENTIFY BOUNDARIES OF AFFECT OF THIS
CHANGE.
.
- ANALYSIS/REVIEW FAILED TO IDENTIFY INTERFACES WITH OTHER COMPONENTS
OF HANGER.
MI0190-1711A-TC01
3
SNUBBER REDUCTION PROGRAM/IEB 79-14
INSPECTION (89024)
CONTINUED
CORRECTIVE ACTIONS
. - ALL REQUIRED MODIFICATIONS ARE COMPLETED
- PROGIWl4ATIC 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 APPROPRIATE AS-BUILT WALKDOWNS AND- REANALYSES TO CONFIRM
RECORD ACCURACY
- DEVELOPED AND AGREED WITH C0"4ISSION 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 PROGRAM .
MI0190-1711A-TC01
'
.
. .*
DEFICIENCIES REQUIRING MODIFICATION TO MEET FSAR
ITEMS CORRECTED PRIOR TO START-UP
ITEM DESCRIPTION
DEFICIENCY
. MODIFICATION/REPAIR
NRC *IDENTIFIED
MAIN STEAM LINE SUPPORT
U-BOLT CONNECTION TO
,REPLACED AFFECTED ASSEMBLIES
I-BEAM ASSEMBLY
. UPPER STRUT ATTACHMENT
ADDED WELD MATERIAL AND
WELD CONFIGURATION
REMOVED ECCENTRIC CONDITION
(ECCENTRICITY)
EXCESSIVE FLEXIBILITY IN
ADDED THREE SUPPORTS
. LINE (NOT IN 79-14
SCOPE)
.
STEAM TRAP DRAIN LINE
CPCO IDENTIFIED
HIGH PRESSURE SAFETY
BENDING MOMENT AT BASE
ADDED STIFFENER PLATES
INJECTION LINE TO
PLATE BEYOND FSAR
PRIMARY COOLANT SYSTEM
MI0190-1711A-TC01
5
ENGINEERING INSPECTION TEAM
. (89-007)
3 OF 19 IDENTIFIED DEFICIENCIES WERE RELATED TO 79-14 ISSUES.
THE EIT CORRECTIVE ACTIONS REMAIN UNCHANGED.
LISTED ACTION ITEMS HAVE BEEN COMPLETED. .
- 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 LACK
CLARITY
- - WELD. ENGINEERING DEFICIENCIES
CLEAR DESIGN BASIS AND ENGINEERING INVOLVEMENT LACKING
- ~ DOCUMENTED ENGINEERING JUDGEMENT
- LACKS CONSISTENCY AND PROGRAM GUIDANCE
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
6
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 CCM4UNICATIONS
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 OUTAGE.
- - REV-ISED DESIGN CONTROL PROGRAM PROCEDURALLY (ADMIN 9~03, 9.04, .
9.11)
.
.
MI0190-1711A-TC01
7
ENGINEERING INSPECTION TEAM
(CONTINUED)
- CORRECTIVE ACTIONS (CONTINUED)
ADMINISTRATIVE PROCEDURE 9.11 uENGINEERING ANALYSIS" NOW PROVIDES:
- VENDOR INFORMATION RECC>>l4ENDATIONS ARE RECONCILED
- BASIS FOR SELECTING THE GOVERNING DESIGN BASIS
- -ASSURE ALIGNMENT BETWEEN ANALYSIS, DRAWINGS AND' AS-BUILT CONFIG-
URATION
- - REQUIREMENT THAT ANALYSIS ASSUMPTION BE CONFIRMED PRIOR TO
EQUIPMENT BEING 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 COtl4ENTS
o JUSTIFICATION 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-tCOl
8
ENGINEERING INSPECTION TEAM *
(CONTINUED)
,CORRECTIVE ACTIONS (CONTINUED)
ADMINISTRATIVE PROCEDURE 9.04 usPECIFICATION CHANGE"
THE ENGINEERING ANALYSIS FOR THE SPECIFICATION CHANGE ADDRESS THE
FOLLOWING ADDITIONAL REQUIREMENTS:
- ASSURE THAT THE REASON FOR THE CHANGE IS CLEAR *
. - DESCRIBE HOW THE CHANGE WILL AFFECT THE SYSTEM.
- - DESCRIBE HOW THE CHANGE WILL AFFECT THE SPECIFIC COMPONENT
OPERABILITY AND AFFECT ON INTERFACING COMPONENTS.
- - 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 SPECIFlED AS PART OF SC*
ENGINEERING AND REQUIRE THAT THIS TESTING ALIG~ WITH THE CRITICAL
FEATURES IDENTIFIED AS PART OF THE SC ENGINEERING.
ADMINISTRATIVE PROCEDURE 9.03 uFACILITY CHANGE
11
REVISE DESIGN INPUTS TO IDENTIFY SEISMIC RESPONSE SPECIFICATIONS
(C-175 AND M-195) AND THEIR POTENTIAL APPLICATIONS.
REVISE DESIGN CONTROL TO FURTHER CL,ARIFY THE REQUIREMENT FOR
STRICT ALIGNMENT BETWEEN ENGINEERING ANALYSIS AND ASSOCIATED
DRAWINGS.*
REVISE INSTALLATION PROCEDURE TO REQUIRE AS-BUILT CONDITION MUST
BE VERIFIED AND DOCUMENTED PRIOR TO DECLARING MODIFIED SYSTEMS/
EQUIPMENT OPERABLE.
Ml0190-1711A-TC01
DEFICIENCIES IDENTIFIED BY CCP
PRIOR TO INTERIM OPERATING CRITERIA
- NO.* HANGERS/SYSTEM
8/HPSI
11/AUX FEED
. WALKDOWN RESULTS
4 MINOR DIMENSIONS
2 INACCESSIBLE .
2 SATISFACTORY
5 MINOR DIMENSIONS .
3 INACCESSIBLE
3 SATISFACTORY
MINOR DIMENSIONS FALL WITHIN.NCIG ACCEPTANCE CRITERIA.
CALCULATION PROBLEMS DID NOT MEET IMPELL SPECIFICATIONS.
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
10
- '
NO. HANGERS/SYSTEM
5/SHUTDOWN COOLING
5/HPSI
.l/PRESSURIZER SPRAY
DEFICIENCIES ItiENTIFIED BY CCP
AFTER INTERIM OPERATING CRITERIA
WALKDOWN RESULTS
5 MINOR DIMENSIONS
2 PHYSICAL DISCREPANCIES
1 REPAIRED
1 TO BE REPAIRED
. 5 MINOR DIMENSIONS
1 PHYSICAL DISCREPANCY -
REPAIRED - MET OPERA-
Bl LITY
1 MINOR DIMENSIONS
1 PHYSICAL DISCREPANCY*-
REPAIRED - MET FSAR
MINOR DIMENSIONS FALL WITHIN NCIG ACCEPTANCE CRITERIA.
- CALCULATION PROBLEMS DID NOT MEET IMPELL SPECIFICATIONS *
. MI0190-1711A~TC01
CALCULATION REVIEW RESULTS
5 CALCULATION PROBLEMS
3 RECALCULATIONS - OK
2 RECALCULATIONS - MEET
5 CALCULATION PROBLEMS
1 RESOLVED AS OK
- *
4 RECALCULATIONS
3 OK
1 MEETS OPERABILITY
MINOR CALCULATION PROBLEM -
RESOLVED AS OK
11
. I
SAFETY-RELATED PIPING REVERIFICATION PROGRAM
PROGRAM CONSTITUENTS
- WALKDOWNS TO VERIFY AS-INSTALLED CONDITIONS
- TO COMPARE AS-INSTALLED TO AS-ANALYZED AND
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! 0 AND LARGER
- - SYSTEMS TO BE INCLUDED:
HIGH PRESSURE SAFETY INJECTION
PORV PIPING TO QUENCH TANK
(ABOVE SYSTEMS SELECTED CONSIDERING PRA IMPORTANCE)
CLASS 1 PIPING TO SECOND ISOLATION VALVE
- INCLUDES VERIFICATION OF BASE PLATES AND ANCHOR BOLTS
- REVIEW OF WELDED ATTACHMENTS
- SOME SUPPORTS MAY NOT BE INSPECTED DUE TO ALARA AND ACCESS
CONSIDERATIONS
MI0190-1711A-TC01
- 1
.*
12
SAFETY-RELATED PIPING REVERIFICATION PROGRAM
{CONTINUED}
PROJECT MILESTONES
. ITEM
DATE
FINALIZE PROJECT PROCEDURES
JANUARY, 1990
BEGIN WALKDOWNS OUTSIDE CONTAINMENT
MARCH 1990
CONTINUE WALKDOWNS INSIDE CONTAINMENT
CONCURRENT. WITH ..
SPRING OUTAGE
BEGIN PIPE STRESS AND SUPPORT
WITHIN 2 WEEKS OF
CALCULATION VERIFICATIONS
. STARTING WALKDOWNS
COMPLETE WALKDOWNS OUTSIDE CONTAINMENT
JULY, 1990
COMPLETE REMAINING WALKDOWNS INSIDE
CONCURRENT WITH
CONTAINMENT
S/G REPLACEMENT OUTAGE
-
EVALUATE PHASE I RESULTS AND
DECEMBER, 1990
IDENTIFY PHASE II SCOPE
MI0190-1711A-TC01
13
STRESS PACKAGE 3342 REVIEW *
DURING A REANALYSIS OF THIS SYSTEM, IT WAS DETERMINED THAT AN
. INPUT ERROR IN THE SEISMIC INPUT. HAD BEEN MADE *. THAT ERROR
RESULTED IN A SIGNIFICANT NARROWING OF THE SEISMIC INPUT. A
CORRECTION OF THE INPUT RESULTED IN UNACCEPTABLE PIPE STRESSES
. AND SUPPORT LOADS.
- .
THE SYSTEM WAS RERUN SEISMICALLY WITH ASME CODE CASE N-411.
THE
RESULTS WERE ACCEPTABLE.
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 EXISTED.
.IN ONE CASE, THE PRIOR ANALYSIS HAD THE
SUPPORT PLACED FIVE FEET AWAY FROM ITS.ACTUAL ORIENTATION. *1N
ANOTHER CASE, LARGE PIPE THERMAL MOVEMENTS SUGGESTED. THAT THE
PIPE SUPPORT PROVIDED MORE RESTRAINT THAN INCORPORATED IN THE
ANALYSES.
'
THE SUPPORT LOCATION PROBLEM WAS EVALUATED DIRECTLY.
THE
POTENTIAL ADDITIONAL RESTRAINT WAS EVALUATED BY TEST RUNS AND
SENSITIVITY ANALYSES.
THE CONCLUSIONS WERE THAT THE SYSTEM WAS
ADEQUATE. *
MI0190-1711A-TC01
- ~
..._'
- I ** **
STRESS PACKAGE 3320 REVIEW
DURING THE REVIEW OF STRESS .*PACKAGE 3320 FOR SNUBBER REDUCTION,
TWO. SUPPORTS WERE VIEWED TO BE OF MARGINAL DESIGN BASED u*PON
IEB 79-14 LOADS.
FOR ONE SUPPORT, THE SUPPORT WELD STRESSES
WERE NOT PROPERLY EVALUATED. * FO.R 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 Is.* IT WAS UNDERSTOOD,.HOWEVER,
THAT THE SUPPORTS *wERE IN CLOSE PROXIMITY TO ONE ANOTHE'R AND WERE
REACTING TO ONE ANOTHER.
.
IN 1989, THE TOTAL PIPING SYSTEM RESPONSE WAS IMPROVED SIMPLY BY
ELIMINATING ONE SUPPORT.
. .
STRESS PACKAGE 3379 REVIEW
DURING THE REVIEW OF THIS PACKAGE FOR SNUBBER REDUCTION, IT WAS
CONCLUDED THAT PIPE SUPPORT CALCULATIONS WERE NOT.WELL DOCUMENTED.
PIPE STRESS RESULTS AND SUPPORT LOADS.WERE DOCUMENTED.
THE LACK
OF DOCUMENTATION WAS ASSOCIATED WITH PIPING WHICH COULD BE VIEWED
AS NOT SAFETY RELATED.
DOCUMENTATION DEFICIENCIES WERE RESOLVED BY MEASURING WHIP
RESTRAINT GAPS AND BY DOING STRESS/GAP C~OSURE SENSITIVITY
ANALYSES.
THE CONCLUSION WAS THAT WHIP RESTRAINTS PROVIDED
SATISFACTORY SEISMIC BOUNDARY .1so'LATION AND THE SUPPORT
DOCUMENTATION WAS NOT REQUIRED TO ENSURE THE INTEGRITY OF THE
CONTAINMENT PENETRATION.
MI0190-1711A-TC01