ML19210E277

Forwards Response to IE Bulletins 79-14 & 79-14,Revision 1, Suppl 1 & 2 Re safety-related Piping Sys.Licensee Has Not Completed Installation of Seismic Category 1 Piping Sys. Analysis of Present Activities Encl

ML19210E277
Person / Time
Site:	Perry
Issue date:	10/26/1979
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
IEB-79-14, NUDOCS 7912040223
Download: ML19210E277 (6)

Text

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ILLUMINATING BLOG e PUBLIC ScuARE e CLEVELAND. OHIO 44101 e TELE

• HONE (216) 623-1350 e VAal ADDRESS P O. 8Cx 5000 Dalwyn R. Davidson ' - ?i WCC

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s <s Eu tso seta so as: ::sseau ct,cs October 26, 1979 Mr. Ja=es G. Keppler, Director Regien III, Cffice of Inspecticn and Enforcement U.S. Nuclear Regulatory CH ssicn Glen Ellyn, Illinois 60137 Re: Ferry Nuclear Power Plant Decket Ncs. 50 kk0; 50 hkl IE Pulletin Uc. 79-lk IE Bulletin No. 79-14, Rev. 1, Supplements 1 and 2.

Dear Mr. Keppler:

The attached has been provided as a resptnse to the referenced ite=3 abcve. Inasmuch as no safety-class piping systems designed to Seismic Category I requirements have bet i ecmpletely installed at .'ur facility, cur respense deals only with present 3CP and N33S activities being cenducted during installatien and future activities pertaining tc cur piping system.

If you require further infcreation, please let me know.

Very truly ycurs,

/ l .,, n k. A h alo '

-iru Dalwyn . Davidsen Vice Fbesident System Engineeri.g and Ccnstruction enc 1Csure cc: 71cter 6tello, Cirecter Cffice of Inspection and Enforcement U.S. Nuclear Regulatcry CH ssicn Washingten, D.C. 20555 349 1A6B NOV131979 79120402 3 3

I. BALA'!CE CF PLA';T PIPING SYSTEMS At this time, no safety-class piping systems designed to Seis=ic Categcry I require =ents are ec=pletely installed. Therefore, this respense only addresses present activities being conducted during installation and future plans to be i=plemented after piping systems are co=pleted. Each Bulletin item is listed belcw and folleved by a respcnse. Sc=e items have been subdivided to spend

=cre directly to specific aspects.

Item #1 A. " Identify inspection elements to be used in verifying that the seismic analysis input information ecnforms to the actual ecnfiguraticn of safety-related systems."

Respcnse: The Engineer, Gilbert Associates, (GAI), prcvides designs and approves all installation drawings used by the Centractor. The Centracter's Quality Centrol crganisation is respcnsible for ersuring that the piping and supports have been installed in acecrdance with the installatien drawings and subject to the tolerances indicated by the Engineer in the installatien specification and design drawings. Eeviations =ust be repcrted to the Engineer through Engineering Change :iotices (EC:T), Field Variance Authorisations (F7A) and :Icn-cenformance Reports (:IR) which are all approved by the Engineer. The Contractor's QC is subject to audit by CEI's Quality Centrol organisaticn. As a final review, the Engineer er other crganisation authorised by CEI will perfer: a walkdown cf the piping systems to determine propet support and restraint loc aticn and that overall configuration meets the design 1 aent.

3. "Fcr each safety-related syste=, sub=it a list of design documents, including title, identificatien numbers, revisien, and date, wnich were sources of input Dr.formaticn fcr the seismic analysis.

Also, submit a description cf the se4-~4a '"alysis input iafer=aticn which is centained in each dccu=ent".

Respense: ECCi2E!T SEISMIC A:IEYSIS I'TFUT

1. Design Specification Pressures, te=peratures, operating =cdes, equipment allevables , input loads, 1 cad cc=binations , applicable codes, etc. (Master Docu=ent for Piping i Support Analysis) 1468 ;50

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DOCUME'IT SEISMIC ANALYSIS INPUT

2. Physical Piping Draw- Pipe Routing, fittings, ings (30h Series) valves, etc.

3 Piping Isc=etrics (Eerived fro Physical Piping Drawings) Pipe routings, fittings, in a format for use with cc=puter analysis.

4 Response Spectra & Earthquake 2nd New Loads Building Movements Adequacy Evaluation (NLAE)

Load Input 5 Pipe Support Drawings Pipe support types, locations and orientations

6. Manufacturer's Valve Valve weights, center of Drawings gravities lengths

7. Pipe & Suppcrt Pipe & fitting sizes =aterial Specification The abcve documents are titled, numbered, dated and do have revicicn numbers.

When the Final resign Verification of a piping system is about to be initiated all the specific documents used in the seismic analysis will be identified and cross referenced with revisions and dates included.

C. " Identify systems or pcrtions of syste=s which are planned to be inspected during each sequential inspection identifitd in ite=s 2 and 3 Sub=it all of thic information within 30 days of the date of this bulletin.

Response: This is considered applicable only to plants with operating licenses.

Items S2 and #3

1. 2. "For pcrtiens cf syste=s which are normally accessible, inspect one syste= in each set of redundant systems and all non-reduncar.t syste=s for ccnformance to the seis=ic analysis input informaticn set forth in design docu=ents. Include in the inspection: pipe run gec=etry; suppcrt er.d restr11nt design, locations, functicn and clearance (including flocr and wall penetraticn); embed =ents (excluding these covered in !E 3alletin 79-0k). Within 60 days of the date cf this bulletin, submit a description of the results of 'his inspection. Where ncnccnformances are fcund which affect operability of any system, the licensee will expedite ec=pletien of the inspection described in ite: 3."

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1. 3 "In accordance with ite: 2, inspect all other nor-al'y accessible safety related syste=s and all normally inaccessible safety related systems. Within 120 days of the date of this bulletin, sut=it a description of the results of this inspection."

Response: The installed syste=s will be inspected as stated in the response to part "A" of ite= #1. This includes inspecticn for pipe run gec=etry; support restraint design, locations, function and clearance; embed ents; pipe attachments; valve and valve cperator locaticns. Valve and valve operator weights will be checked in the Design Verificaticn performed by the Engineer.

Ite: A "If ncnconformances are identified:"

A. Evaluate the effect of the acncenfermance upon syste= operability under specified earthquake leadings and ec=p _y with applicable action statements in your technical specificatiens including prc=pt repcrting."

Respense: This is censidered applicable cnly to plants with cperating licenses.

3. " Submit an evaluatien of identified ncnconformances en the valid'.ty of piping and support analysis as described in the Final Safety Analysis Report (FSAR) or other :EC approved documents. Were you deter =ine that reanalysis is necessary, submit your schedule for: (1) cc=pleting the reanalysis, (ii) cc=parisens of the results to FSAR or other :EC approve.J =ceptance criteria and (iii) sub=itting descriptiens of the results cf reanalysis."

Respence: Engineer evaluation of EC:I, FVA, IIR and any required re-analysis will be ec=plete prior to Functional Testing.

These evaluatiens will censider t..e FSAR and other !!RC approved acceptance criteria ec~_ic=ents. The re=ainder cf this ite: is censidered not applicable to Ferry at this time.

C. "In lieu cf 3, submit a schedule for correcting ncncenfer=ing systems so that they confor= to the design documents. Also a description of the work required to establish conformance."

Respense: Cnly :IR's di.spesitioned for repair or rewcrk apply to this ite=. A work description is indicated en the :E in such cases.

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Dl. " Revise document: to reflect the as-tuilt condition in the plant. . ."

Re:: pence: As-builts, as reported through ECN's, FVA's, and NR's are incorporated intn the Decign Documents when the changes affect future design work.

D2. ". . anc describe measures whim. are in effect which provide assurance that future modificationc of piping cystems, including these supports, will be reflected in a timely manner in design documents and the sei:=ic analysis".

Response: CEI will have procedures which require that changes to safety related systems are brought to the attention of the Piping Analyst. His responsibilities will be to review the changes for effects to existing analysis (including seismic). If analysis are ecncidered comprc=1::ed, they will be re-performed.

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The Ferry NS23 piping (Main Steam and Recire) is supplied by General Electric. Ncne of the 3333 piping or cupport: have been insta'..ed to date. Also the ceismic analysis of these piping system:

is not yet ec=plete. Therefore the conformance of the as-installed piping with the seis=ic analysis input information cannot be evaluated at this time. The follcwing respenses te TE Eulletin 79-lh Items 1 thru k describe the evaluaticn program that will be implenented on Ferry NCSS piping cyste=n inctallation:

Respcnse 1: As portions of the piping syste=c installaticn are ec=pleted, they are inspected by the Centractors' QC ,

to verify that the piping anc cupports have been installed in accordance with the approved ccnctructicn drawings and precedures. Any deviations must be reported to the Project Crganization through the Ncn-Ccnfomance form.

Respence 2 and 3: We intend to perform the inspecticn and ceicnic evaluation of the as-inctalled ccnfiguration of the perry NC2S piping systems prior to the hydrectatic and pre-cperaticnal testing of these systenc. This evaluatien, or reconciliation, will be done in acecrdance with Lec. III cf the ASME Code, and will formally be dccumented in General Electric's final Decign Repcrt.

General Electric has assured us that their final Design Report will incorporate the recult: cf the evaluatienc requested in Itenc 2 and 3 cf the Bulletin. Therefcre, unlecc instructed otherwise, we do not intend to prc' ride additional separate documentatien addrecsing items 2 2nd 3 cf the 3u11etin.

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Response k: Any non-conformances that involve a deviation frc= :ISES construction drawings are evaluated by General Electric and are either reworked to original tolerances or are recorded en a Field Deviation Dispecition Request (FDDR) and submitted to General Electric for approval. All resulting design changes are then originated on General Electric's Engineering Change Notices (EC:I) and Field Disposition Instructions (FDI). General Electric's Furchase Part Drawings, FDDR's, FDI's and EC:I's thus fem a ec=plete record of the as-built figuration, which will be recenciled in General Electric's Final Design Report.

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