ML19208D719

Forwards Response to IE Bulletin 79-14.Immediate Implementation of Program Deemed Premature & Would Provide No Useful Info in Evaluating Validity of Seismic Analysis. Will Conduct Analysis as Part of Turnover Procedure

ML19208D719
Person / Time
Site:	Midland
Issue date:	08/30/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
7531, NUDOCS 7909290409
Download: ML19208D719 (5)

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Consumers Power Company si s. 8. so-.i>

Senior Vsce PressJent ceneral offices: 1945 West Parnell Ro6d, Jackson, Michigan 49201 e (517) 788-0453 August 30, 1979 Have 240-79 Mr J G Keppler, Regional Director Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT DOCKET NO 50-329, 50-330 IE BULLETIN 79-14 FILE: 0505 12 UFI: 99802'05'10 SERIAL: 7531 Consumers Power Company believes that at the present state of construction of Midland Plant Unitc 1 and 2 that the it=ediate implementation ef the inspection program outlined in IE Bulletin 79-14. " Seismic Analyses for As-Built Safety Related Piping Syste=s" is premature and would provide no useful information in evaluating the validity of seismic analysis of piping for Midland Plant Units 1 and 2. The attachment to this letter presents a summary and discussion of the factors which support this belief.

Therefore, Consumers Power Company plans to conduct the seismic analysis of piping systems required by this bulletin as part of the normal system turnover procedure for Midland Plant Units 1 and 2. As part of this turnover process, the CPCo Quality Assurance Program vill pay close attention to the inspection requirements of IE Bulletin 79-14 O'

SHH/jm CC: Director, Office of Inspection & Enforcement Director, Nuclear Reactor Regulation 1053 2M 7909298hC9

Attachment to Serial 7531 Response to IE Bulletin 79-lh ,

Coastruction at Midland is insufficiently complete on the majority of safety-related pipirs systems for as-built information to be availabic.

Procedures and cont- 1s have been placed on the construction and design processes specifically to obtain design rectification with as-built configurations. In addition, the system walkdown procedure provides, in the normal course of events, an inspection similar in type and detail to that requested in the subject bulletin, on a schedule more compatible with construction progress, und with no loss of safety or quality assurance. A more detailed discussion of these items follows.

Construction Status been completed T1.c majority of the safety-related piping systems have not but are partielly assembled and erected. Though deviations from the as-designed configuration are reported and evaluated as encountered, many of these deviations are not apparent until the respective piping system is completely erected and supported. The final comparison of as-built with as-designed configurations is not made until af ter system completion.

The schedule for this inspection, known as " system walkdown," extends from late summer 1979 through early 1981.

Design Controls The primary design documents for piping systems are the hanger isometrics and the hanger design drawings.

Hanger isometrics are piping isometric drawings with the Each revision of ahanger hangerlocations and type superimposed on the drawings.

isometric is reviewed and signed by a stress analyst, who determines whether the existing stress analysis is valid. If the analysis is invalid, a reanalysis is done. The analyst's signature on the drawing indicates acceptance of that revision.

Detailed hanger design drawings called " sketches" show the design loads, the configuration and dimensions, and the location of pipe supports and restraints. Each revision of every sketch is reviewed by a stress analyst to verify that the loads are correct, and that the support type, location, and application are in agreement with the stress analysis for that piping system.

1053 279

Additionally, there are other, nore generalized design documentn, such as specificationc for the procurement, fabrication, and installation and of pipe and pipe supports, which provide loads, dimensional limitn, tolcrances. The initial issue and cach significant revision of these documents are reviewed by the stress analysis department.

Construction Controls The installation of ,ipe and pipe supports is governed by the t echnical ifeld specifications provided by the engineering organization and be control proEcdures generated by construction engineering, with qualitv deviation procedures generated by field quality control engineering. A m.

or out-of-tolcrance condition is submitted to engineering for i-view and acceptance by one of the following methods:

1) Field change notice (FCN)

2) Field change request (TCR) ~

3) Nonconformance report (NCR)

4) Field revisions to hanger sketches The selection and use of these forms are delincated in the Bechtel The effect of Quality Assurance Prograr and in impicmenting procedures. When the procedures is to require engineering review of all deviations.

applicable, this review of these documents includes a review by stress analysts to determine whether the existira analysis is valid, and reanalysis if necessary. Reanalysis is frequently dcierred until system installation once. Thus, an is completed, in order to evaluatestatus all of the changes at of piping systems is maintained ongoing awareness of the as-built and recorded by the engineering organization.

System Walkdown Even though a record is maintained and engineering evaluations have been made of significant construction deviations from design, it is conceivable that some deviations remain unreported, or that adverse combinations of singly acceptable conditions may cause questionable applicability ol the stress analysis. Therefore, a system walkdown, which includes the inspection cicments identified in IE Bulletin 79-14, has been implemented specifically to ensure that the stress analysis (not just the seismic analysis) is representative of the as-built design. This walkdown is a joint effort among construction engineering, quality control engineering, and project design engineering (stress analyst or resident engineer),

and is generally performed after completion of a system and prior to release of the system for startup testing. A copy of Form Pel29, used to document the walkdown, is' attached to this response.

1053 280

In addition to verifying that piping, supports, and restraints are properly located and installed, the walkdown is also used to ensure that the system is properly adjusted; i.e. , restraints are properly gapped, rigid supports are properly shimmed, and snt.bbers and spring supports are properly adjusted. (A few spring hangers are specified to be; adjusted in the hot position; these are set by the startup organization.) Although not discussed in IE Bulletin 79-14, verification of system alignment and adjustment is necessary to ensure the validity of the stress analysis.

7/24/14 1053 281

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