ML19210B944
| ML19210B944 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/05/1979 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| IEB-79-14, NUDOCS 7911130071 | |
| Download: ML19210B944 (6) | |
Text
Alabama Power Compaay
/C 600 f4 orth 18th Street Co-3'T [
Post Off::e Box 2641 Birmingham, Alabama 35291 Telephone 205 323-5341 k
U"NRC RE3r:.:
L
/ T'.
- NT/.
F. L CLAYTON, JR.
AlabamaPower Senior Vice President
/30'I9 P3:03 October 5, 1979 NRC IE Bulletin No. 79-14 Docket No. 50-348 Mr. James P. O'Reilly U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 3100 l
Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Alabama Power Company submits the enclosed addit *-ral information on the subject I.E. Bulletin as committed to in my letter to you dated
{
September 4, 1979 for Farley Nuclear Plant Unit-1.
If you have any questions, please advise.
f Yours very truly, f
F. L. Cl,vton, Jr.
1-l FLCjr/TNh/mmb Enclosure I
cc: Mr. R. A. Thomas
,I Mr. G. F. Trowbridge
?
Offica of I&E, Div. of Reactor Operations Inspection 5
Washington, D. C.
'j, -
}
Washington, D. C.
20555 Office of I&E, Div. of Construction Inspection l
1 Mr. M. D. HunP., I&E, Region II j
Director of the Office of Inspection & Enforcement Office of Nuclear Reactor Regulation Washington, D. C.
20555 i
1318
'n I
i 79111go a y/
i i
. - Response to IE Bulletin 79-14 (Unit 1)
As indicated in Alabama Power Company's response to the NRC dated September 4, 1979, Alabama Power Company developed, approved, and imple-mented on July 30, 1979 a program for inspection of elements affecting inputs to seismic analyses of scoped piping systems. Scoped piping systems include the following:
a)
Seismic Category I; Safety-Related 2-1/2 inches and above, b) Seismic Category I; Safety-Related under 2-1/2 inches which were dynamically analyzed by computer.
The systems or portions of systems involved in this verification include the following:
1.
Component Cooling Water System 2.
Service Water System 3.
Sampling System 4.
Chemical Volume and Control System 5.
Residual Heat Removal System 6.
Main Steam System 7.
Containment Cooling System 8.
Emergency Core Cooling System 10.
Main Feedwater System 11.
Emergency Diesel Generator with Fuel Oil System 12.
Gaseous Waste System 13.
Post Accident Containment Hydrogen Control Systen 14.
Auxiliary Feeuwater Syster 15.
Containment Spray System 16.
Condensate Storage Tank 17.
Containment Isolation System 18.
Main Steam Safety and Relief Valve Systems The following inspection elements were used to verify that seismic analysis input information conformed to the actual configuration of safety-related systems. These elements have been verified for the scoped systems by the field inspection teams as required by IE Bulletin 79-14.
a) Piping Configuration riping segment length Piping segment direction b) Valve
($,.'
Valve identification number Location Extended operators' orientation c) Floor and Wall Penetration Piping fixed at the penetration (and fixed direction)
Piping free to move Grouted or sealed sleeve 13i8 7"7
d) Pipe Support Support identification number Location Direction (restriction or load carrying direction)
Type (spring, snubber, rigid, structure frame)
(see page three (3) for pipe support configuration)
The field inspection of inaccessible and accessible areas of the scoped systems has been completed. The initial engineering review of inaccessible areas has identified no discrepancy which affects operability; however, those of a magnitude that would otherwise require additional analyses will be corrected prior to startup. Attachment 1 is a list of these discrepancies or inaccessible areas. No further action is required. A list of accessible discrepancies with indication if further analyses is required will be sub-mitted af ter the initial engineering review of accessibles is completed about October 5, 1979.
t Before Supplement 2 of IE Bulletin 79-14 was issued, Alabama Power Company as a part of its previously implemented IE,79-14 program, removed insulation in order to inspect twenty randomly selected lugs and/or stanchions to verify conformance to design. This is approximately 10% of the lugs ar.d stanchions within the scoped systems. No discrepancies were found. Insulation will be removed from and inspection made of an additional randomly selected 10% of the lugs and/or stanchions on scoped systems during the second refueling outage.
If no discrepancies are found, no further inspection in response to 79-14 will be scheduled.
Some inspection elements of three (3) inaccessible systems had to be in-spected visually (instead of by direct measurement-this visual inspection was sufficient to ensure operability of affected inspection elements) for com-parison to design drawings as indicated below:
a.
The containment spray rings were inspected visually utilizing surveying techniques.
b.
Portions of the RCS systes inside the pressurizer shield wall inac-cessible for direct measurement due to space limitations for physical
-ccess were inspected visually st close range, 4
c.
Portions of the chemical and volume control system that are physically inaccessible because of their location in the pipe trenches were visually inspected at close range.
Note: For certain areas within these trenches (c. above) visual in-spection was impossible without major destruction of plant walls.
In these areas are portions of:
the chemical and volume control system, the residual heat removal system, and the service water system. For these systems in these areas the hanger con-figuration, location and pipe geometry were judged to be correct based on the low discrepancy rate encountered throughout the program.
It should be noted that during the program implemented to respond to IE Bulletin 79-02, analysis on the affected piping systems was performed assuming failure of all inaccessible bolted hangers in the trenches. As a result of this analysis, Q
7pG
-k)
U
hangers on the affected systems adjacent to the trenches were strengthened to be able to carry the higher loade resulting from such failures.
In actuality few if any of these bolted hangers would be expected to fail. Based on the combination of few expected discrepancies for totally inaccessible areas and the adjacent accessible hangers being capable of withstanding higher than expected loads, no adverse safety consequence is anticipated from the inability to inspect these areas.
With respect to pipe support configuration, the as built drawings were used in the walkdown. As required by the IE Bulletin 79-14, the walkdown results are to be compared to the specific hanger configuration used to generate inputs to the seismic analysis. As reported in LER 79-021/0lT-4, there were design control inadequacies during plant construction for certain hanger con-figuration changes for which existing engineering calculations were not sufficient to readily determine the impact of such changes on the seismic analysis inputs.
In order to provide verification and documentation of the adequacyofthesehangersforseismicdesigninputs,thefollowingactionshave been taken:
1.
All hangers (both bolted and welded embedments) on ASME Section III Class 1 piping systems have been rer slyzed and will be modified as necessary prior to plant startup. 71 9 satisfies 79-14 requirements for verification of seismic inputs for C1sss 1 piping systems.
2.
All bolted hangers within the scope of 79-01 F ric *. en reanalyzed and will be modified as necessary prior to plant startup.
3.
The reanalysis of other hengers on Class 2 and Class 3 piping systems within the 79-14 scope F.s been initiated to be completed prior to the next refueling es.sgs.
Based on the number of modifications required in 1 and 2 above, there is a 99% confidence that greater than 95% of these hangers will be found to have no deficiency.
With respect to the action in 3 above, the hangers will be reanalyzed in accordance with the following order of priorities:
containment, auxiliary building, outside buildings and areas.
If the reanalysis of any hanger in-dicates that the hanger does not meet the design requirements, but by further evaluation it is determined that its failure would not affect piping system operability, corrective action will be scheduled for completion prior to the end of the second refueling outage. If the piping system operability is affected, the following actions will be _ taken:
1.
The NRC-Region II will be notif ed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of such determination.
2.
The action statements of the applicable Farley Technical Specifications will be invoked.
4 In addition, Alabama Power will provide to the NRC-Region II quarterly reports concerning the status and findings of the hanger reanalyses.
Operating plant design control procedures now in effect provide assurance for preclusion of future hanger design problems such as those discussed above and in LER-79-021/G1T-4. These are described in Attachment II.
1318 7"'
Attachment I Corrected 79-14 Inaccessible Discrepancies ISOMETRIC NO.
SYSTEM HANGER NO./ ACTION REQUIRED 1.
375 CVCS Remove Temporary Hanger (3"-ECB-1) 2.
1352 SIS Install Hanger SS4621 (3/4"-CCA-26) 3.
659 SIS Install Hanger SS2001 (2"-CCB-21) 4.
3587 CVCS Install Hanger SS4264 (3/4"-GCB-23) 5.
3588 CVCS Remove Hanger SS4264 (3/4"-GCB-23) 6.
1818 SGBD Move Hanger SS2698 (2"-CBB-6) 7.
252 SW Remove Temporary Hanger (6"-RBD-20) 8.
726 CVCS Remove Hanger SS5638 (3/4"-GCB-23) 9.
1192 SIS Remove Clamp (2"-CCA-30) from Hanger SS4766 10.
947 SIS AJd Pipe (3/4"-CCA-30) from Hanger SS4137 11.
490 CVCS Add Anchor (2"-CCB-19) 12.
1430 SIS Add Shims to Hanger SS2014 (2"-CCA-9)
) )) b F
Attachment II Alabama Power Company Design Control Procedures All modifications to safety related items are subject to approved design control measures. Design control measures include design change verification, design review, and a safety evaluation review. These controls assure that design changes mest the specified design inputs, the necessary provisions are included to address the original request, and an evaluation as to whether an unreviewed safety question exists. Safety evaluations are reviewed by the Plant Operations Review Committee (PORC). Any design change which is in variance with the technical specification as incorporated in the Operating License or which constitutes an unreviewed safety question as determined by the PORC review is reviewed by the Nuclear Operations Review Board (NORB) and approved by the Senior Vice President for Power Supply. After NORB review and approval by the Senior Vice President for Power Supply, the design change with its safety analysis is submitted to the NRC for review and/or approval.
Design changes which constitute a variance with the technical specifications or an unreviewed safety question are not implemented until af ter NRC approval has been obtained.
Af ter implementation of design changes, the designer is notified and the appropriate design drawings are subsequently revised.
Organizations that develop design modifications of piping systems, in,1uding their supports are committed to ANSI N45.2.11 " Quality Assurance Requirements for Design of Nuclear Power Plants." This commitment requires that loads such as seismic, thermal, and dynamic be considered in preparation of design changes. Alabama Power Company audits the design organizations to ensure compliance with ANSI N45.2.11.
1318Property "ANSI code" (as page type) with input value "ANSI N45.2.11.</br></br>1318" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 7
-s.
9 9
e