ML19253A622
| ML19253A622 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/01/1979 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 79-79-156, NUDOCS 7909100585 | |
| Download: ML19253A622 (22) | |
Text
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ft BOSTON EDISON COMPANY GENERAC OFFICE 5 800 GovtsTON S TR EET BOSTON. M ASSACMuBETTs o2199 August 1, 1979 G. Cank ANDOGNING surEmiNTENDENT BEco. Ltr. #79-79-156 Nuctra. o,E.AnaN. oE*AaTNEa7 Mr. Boyce H. Grier, Director Office Of Inspection and Enforcement.
Region I U. S. Nuclear Regulatory Commission License No. DPR-35 631 Park Avenue Docket No. 50-293 King of Prussia, PA.
19406 RESPONSE TO IE BULLETIN 79-14
Dear Sir:
In a letter dated July 2, 1979, revised by a letter dated July 18, 1979, you transmitted IE Bulletin 79-14 titled, " Seismic Analysis for As-Built Safety-Related Systems." Boston Edison was requested to take the following actions within thirty (30) days to review this issue at Pilgrim Nuclear Power Station. Appropriate responses are provided in this letter.
Item 1.
Identify inspection elements to be used in verifying that the seismic analysis input information conforms to the actual con-figuration of safety-related systems.
For each safety-related system, submit a list of design documents, including title, identification number, revision, and date, which were sources of input infor=ation for the seismic analysis. Also submit a description of the seismic analysis input informntion which is contained in each document.
Identify systems or portions of systems which are planned to be inspected during each sequential inspection identified in Ite=s 2 and 3.
Submit all of this in-formation within 30 days of the date of this bulletin.
Response
The inspection elements to be used in verifying that the seismic analysis input information conforms to the actual configuration of safety-related systems are shown in Attachment A.
The list of d2 sign documents, including title, identification number, revision and date, which were sources of input infor-mation for the seismic analyses are provided as Attachment B.
For those items marked "later", a detailed list is being gen-erated and will be forwarded to you in a supplementary response.
The lists along with copies of the appropriate design documents will be available on-site for reference during your inspection.
A description of the seismic analysis input information is pro-vided as Attachment C.
Those systems or portions of systems which are scheduled to be inspected during each sequential inspection identified in Items 2 and 3 are listed and discussed in Attachment D.
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80 STOA EDISDN COMPANY B.H. G"ier, Director Page 2 Item #2 For portions of systems which are normally accessible *, inspect one system in each set of redundant systems and all nonredundant systems for conformance to the seismic analysis input information set forth in design documents.
Include in the inspection: pipe run geometry; support and restraint design, locatiens, function and clearance (including floor and wall penetration); embedments (excluding those covered in IE Bulletin 79-02); pipe attachments; and valve and valve operator locations and weights (excluding those covered in IE Bulletin 79-04).
Within 60 days of the date of this bulletin, submit a description of the results of this in-spection.
Where nonconformances are found which affect operability of any system, the licensee will expedite completion of the in-spection described in Item 3.
Response
The results of the inspection will be forwarded within the requested time frame.
Item #3 In accordance with Item 2, inspect all other normally accessible safety-related systems and all normally inaccessible safety-related systems.
Within 120 days of the date of this bulletin, submit a description of the results of this inspection.
Response
It is Boston Edison's intent to inspect all other normally accessible safety-related systems within the required 120 days.
However, with regard to the inaccessible systems, we offer the following:
During the outage Pilgrim Station experienced in May, and in accord-ance with the requirements established to all'ow the Station to return to service, a substantial effort was extended in the specific areas of as-builts and the inspections required by Bulletin 79-02.
Speci-fically, all support pads utilizing concrete expansion bolts that are in areas inaccessible during normal operations were inspected.
Further the entire Recirculation System (both loops) and branch pip-ing as well as two of the four Main Steam lines were subjected to a walk-down to verify the following:
1.
Critical dimensions agreed upon by both Boston Edison, NRC:
RI and NRR.
2.
Seismic restraints including applicable snubbers, hangers and guides The walk-down of the system was witnessed by the Region I Inspector; no non-conformances were identified with regards to as-builts.
Additional as-built verification of inaccessible portions of systems had also been conducted previously.
The Core Spray piping was modi-fled during the August 1977 refueling outage; the as-built condition was verified as a result of the design change process.
During the same outage, the Control Rod Drive Return Line was cut and capped at the vessel.
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BasTON EDISON COMPANY B.H. Grier, Director Page 3 The only remaining systems to be inspected included Head Spray (RHR), Feedwater, the remaining two Main Steam Lines and inter-connected branch piping.
Boston Edison believes that the health and safety of the public would not be significantly increased by completing the full 120-day inspection 7.equirements because:
1.
The majority of the inaccessible systems were subj ect to a walk-down previously including a detailed inspection last May.
2.
The next refueling outage is schedule for January 1980 which is only 66 days beyond the required 120 days imposed by the subject Bulletin.
We will, however, commit to develop a plan to conduct the required inspections should the unit experience an outage of sufficient dur-ation such that the inspection of the inaccessible areas can be completed without jeopardizing the inspection schedule for the accessible areas which have not been subjected to a walk-down.
Item #4 If nonconformances are identified:
1.
Evaluate the effect of the nonconformances upon system oper-ability under specified earthquake loadings and comply with applicable action statements in your technical specifications including prompt reporting.
2.
Submit an evaluation of identified nonconformances on the val-idity of piping and support analyses as described in the Final Safety Analysis Report (FSAR) or other NRC approved documents.
Where you determine that reanalysis is necessary, submit your schedule for:
(1) completing the reanalysis, (ii) comparisons of the results to FSAR or other NRC approved acceptance criteria and (iii) submitting descriptions of the results of reanalysis.
3.
In lieu of B, submit a schedule for correcting nonconfornir; sys-tems so that they conform to the design documents.
Also submit a description of the work required to establish ;onformance.
4.
Revise documents to reflect the ar-built conditions in plant, and describe measures which are in ef fect which provide assurance that future modifications of piping systems, including their supports, will be reflected in a timely manner in design documents and the seismic analysis.
Response
Boston Edison will comply with the corrective actions requested including the revision of documents to reflect as-built conditions.
031.Ob.3
80 stun EDISON COMPANY B.H. Grie Director Page 4 Boston Edison has measures in effect which provide assurance that future modifications of piping systems, including their supports are reflected in a timely manner in design documents and the seismic analysis.
These measures, which are described in approved procedures, require (1) an evaluation of the seismic impact of the modification prior to its implementation and (2) the rigid control of official drawings.
Drawings utilized for modifications are treated as controlled documents. After implementation of the modification, the drawings issued for construction are verified to be "as-built" and are submitted to the Records Center for processing.
These as-builts are immed-lately made available within the plant official drawing files with the use of photo-micrographic equipment.
The as-builts are retained in the files until such time as the master copies of the drawing are updated and distributed.
We trust that chis information is res;>nsive to jour requests.
If r.
have any questions or com=ents, please let us know.
Very truly yours, t
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cc: Director, Division of Operating Reactors Office of Nuclear Reqctor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 EJZ/gs bO.$i334
Response to Bulletin 79-14 ELEMENTS OF 79-14 INSPECTION The inspection will include the following items:
- Geometry of the Piping System Type of Insulation
- Talve T^m ti nn
- Valve Operator Orientation
- Support Location, Type and Orientation
- In-Line Equipment Location and Orientation P00R ORG Na
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Attachment A
Response to Bulletin 79-14 DESIGN DOCUMENTS USPD FOR SEISMIC ANALYSIS INPUT INFORFJLTION DOCUMENTS WHlCH ARE COMMON TO ALL SEISMIC ANALYS?'S Description Document No.
Latest Rev.
Date Piping Class Stmmary Sheets 6498-M300 19 2-19-74 Thermal Insulation Specification 6498-M37 1
12-5-69 Reactor Building Seismic Analysis 8-69 Radwaste Building Seismic Analysis 9-69 Turbine Building Seismic Analysis 9-69
?00ROR8NAL A t t a c h:r.e nt E Pg. 1 of 15 o,..
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SYSTEM DESIGN '0CUMENTS HPCI SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-500 SF 2-29-72 4496-600-1 SF 4-13-72 4498-600-2 SF 4-13-72 6498-602 4
3-30-72 6498-604 4F 2-29-72 6498-640 6F 4-4-72 6498-641 3
3-24-72 6498-676 4F 4-13-72 6498-687 1F 2-29-72 Piping and Instrument Diagrams 6498-M243 15 3-6-74 6498-M244 14 3-6-74 6498-M209 El 10-13-79 Velve Vendor Drawings
( Later)
Pipe Support Vendor Drawings
( Later)
In-Line Equipment Vendor (Later)
Drawings (if any)
?g 2 of 15
CORE SPRAY SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-605-1 SF 4-13-78 6498-605-2 4F 2-29-72 6498-606-1 4F 4-13-72 6498-606-2 5
3-24-72 64SB-5D7 4
3-30-72 6496-608 SF 4-14-72 6498-609 4
3-30-72 6498-610 2
3-24-72 Piping and Instrument Diagram 6498-M242 9
3-6-74 Valve Vendor Drawings (Later)
Pipe Support Vendor Drawings (Later)
In-Line Equipment Vendor (Later)
Drawings (if any) 300RORGNAL o
- s) O.<, n, = t ' e
~. t i Pg 3 of 15
RCIC SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-611-1 6F 2-29-72 6498-611-2 8F 4-4-72 6498-612-1 3F 3-24-72 6498-612-2 3F 3-24-72
-6496-613 (F
3-24-72 6498-615 67 3-24-72 Piping and Instrument Diagrams 6498-M245 E2 12-22-77 6498-M246 10 3-6-74 Valve Vendor Drawings (Later)
Pipe Support Vendor Drawings
( Lat er)
In-Line Equipment Vendor (Later)
Drawings (if any)
P00RORG\\JL
= amo Pg 4 of 15
REACTOR BUILDING CLOSED COOLING WATER SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-616 4
3-30-72 6498-617 6F 4-4-72 6498-618-1 3F
-_5-25-22 6498-618-2 47 4-13-72 6498-638-3 4F 4-13-72 6498-619 4
3-30-72 6498-620 4F 3-30-72 6498-621 3
4-4-72 6498-622 SF 2-29-?2 6498-623 8F 2-29-72 6498-624 SF 2-28-72 6498-625-1 2
3-30-72 6498-626 SF 4-13-72 6498-627 4F 4-4-72 6498-628 3F 4-13-72 6498-634-1 3F 4-13 72 6498-634-2 3F 4-13-72 6498-635-1 1F 3-30-72 6498-635-2 4F 4-13-72 Piping and Instrument Diagram 6498-M215 El 4-12-77 Valve Vendor Drawings (Later)
Pipe Surpset Vendor Drawings (Later)
In-Line Equipment Vendor Drawings (Later)
(if any)
P00R OR GXL m un Fg 5 of 15
TURBINE BUILDING CLOSED COOLING WATER SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-629 6F 4-4-72 6498-630 6F 4-4-72 6498-631-1 4F 4-4-72 4498-631-2 3
3-20-72 6498-632-1 3F 3-30-72 6498-633-1 SF 3-31-72 Piping and Instrument Diagram 6498-M216 El 10-24-77 Valve Vendor drawings
( Later)
Pipe Support Vendor Drawings (Later)
In-Line Equipment Vendor Drawings (Later)
(if any) 300R OR GlUL u w'.
Fg. 6 of 15
SERVICE WATER SYSTEM
'9scription Document No.
Latest Rev.
Date Tiping Isometric Drawings 6498-636 3F 2-29-72 6498-637 6F 4-13-72 6498-638 3F 3-30-72 64S8-639 37 4-14-72 Piping and Instrument Diagram 6498-M212 E2 10-21-77 Valve Vendor Drawings
( Later)
Pipe Support Vendor Drawings
( Later)
In-Line Equipment Vendor Drawings (Later)
(if any)
I L
031012 Pg. 7 of 15
FEEDWATER SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-601-1 6F
-72 6498-612-1 SF 3-24-72 6498-642 7
3-30-72 6498-643 7F 4-13-72 4496-644 4F 3-30-72 6498-680 3F 3-30-72 Piping and Instrument Diagrams 6498-M208 El 10-13-77 6498-M252 El 11-3-77 Valve Vendor Drawings
( L2 ar)
Pipe Support Vendor Drawings
( Later)
In-Line Equipment Vendor Drawings (I.a te r )
(if any)
P00RORSNAL 331.013 Pg. 8 of 15
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CONTAINMENT ATMOSPHERIC CONTROL SY" TEM De _r.ription Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-646 SF 2-29-72 6498-647 2F 2-29-72 6498-64B 4
3-30-72 4496-649 2
3-30-72 649B-650 1
3-30-72 6498-651 1
3-3D-72 Piping and Instrument Diagram 6498-M227, Sht.1 1
5-10-77 Valve Vendor Drawings
( Later)
Pipe Support Vendor Drawings
( Later)
In-Line Equipment Vendor Drawings (Later)
(if any) 03 ES.1 I' i
Pg. 9 of 15
1RER Siditn
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Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-608 SF 4-14-72 6498-610 2
3-24-72 f>4SS-637 4F 4-13-72 6498-656 3
3-24-72 6498-657 4
3-24-72 6498-658 5
3-24-72 6498-659.
3F 3-24-72 6498-660 4
3-24-72 6498-661 2
3-30-72 6498-662 3
3-30-72 6498-663 8F 2-29-72 6498-664 llF 3-30-72 6498-665 Sr 3-30-72 6498-666 4-13-72 6498-667 3
3-30-72 6498-668 1F 4-13-72 6498-669 6F 6498-670 4
3-30-72 6498-671 4
3-30-72 6498-672 7F 4-13-72 6498-673 SF 5-15-72 6498-674 3F 5-15-72 6498-675 4F 3-30-72 6498-676 4F 4-13-72 Piping and Instrument Diagrams 6498-M241 13 3-6-74 6498-M242 9
3-6-74 Valve Vendor Drawings
( Later)
Pipe Support Vendor Drawings
( Lat er)
In-Line Equipment Vendor Drawings (Later)
(if any) 300RORGNAL da s. 01 s>
Pg. 10 of 15
REACTOR WATER CLEANUP SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-679 3-30-72 6498-680 3F 3-30-72 6498-681 2F 4-13-72 Piping and Instrument Diagram 6498-M247 El 11-22-77 Valve Vendor Drawings (Later)
Pipe Support Vendor Drawings (Later)
In-Line Equipment Vendor Drawings (Later)
(if any) 200ROR8Na b33.01 p, Pg. 11 of 15
FUEL POOL COOLING SYSTEM Description Document Nc3 Latest Rev.
Date Piping Isometric Drawings 6498-673 SF 5-15-72 6498-682 1F 4-13-72 6498-683 2F 2-29-72 64SB-6B4-1 P
3-30-72 44SS-484-2 2 30-72 6498-685 SF 3-30-72 6498-686 0
3-31-72 6498-686-1 3
3-30-72 6498-691 3F 2-29-72 6498-692 3F 2-29-72 6498-693 3F 4-13-72 Piping and Instrument Diagram 6498-M231 E2 9-13-76 Valve Vendor Drawings (Later)
Pipe Support Vendor Drawings (Later)
In-Line Equipment Vendor Drawings ( T.a te r )
(if any) jl
.o&. n.
.at Pg. 12 of 15
STAFDBY LIQUID CONTR'l SYSTEM D_:scription Document No.
Latest Rev.
Date Piping Isometric Drawing 6498-688 6
3-30-72 Piping and Instrument Diagram 6498-M249 20 3-6-74 Valve ~Pendor DrewiTrgs (Later)
Pipe Support Vendor Drawings (Later)
Lhe Equipment Vendor Drawings (Later)
=y u." s. s.O n aw U0d] 031 H
IFl 4
Pg. 13 of 15
MAIN STEAM SYSTEM f>es cription Document No.
Latest Rev.
Date Piping Isometric Drawings 6498-694 C
5-15-72 6498-694-3 0
5-15-72 6498-694-4 0
5-15-72 6498-694-5 D
5-15-72 6438-694-6 D
5-15-72 6498-695 2
3-30-72 Piping and Instrument Diagram 6498-M252 El 11-3-77 Valve Vendor Drawings
( Later)
Pipe Support Vendor Drawings
( Later)
In-Line Equipment Vendor Drawings (Later)
(if any) s O
.4 Pg. 14 of 15
CONTEOL ROD DRIVE SYSTEM Description Document No.
Latest Rev.
Date Piping Isometric Drawing 6498-677 1
3-30-72 6498-678 0F 4-13-72 Piping and Instrument. Diagram 6498-ff250 J2
_ 1 hll-77 Valve Vendor Drawing
( later)
Pipe Support Vendor Drawings
( Later)
In-Line Equipment Vendor Drawings (Later)
(if any) 300R 03B R sam 2o Pg. 15 of 15
Response to Bulletin 79-14 DESIGN DOC 1DiENT INPU.T,INFORMATION DESCRIPTION Document Inpat Information Piping Class Summary Sheets Pipe Wall Thickness Pipe Ma+av4al T* ipa Design Temperature Pipe Design Pressure Branch Connection Type Thermal Insulation Fpecification Insulation Weight Piping Isometric Drawings Pipe Geometry Valve Locations & Orientation Equipment Locations &
Orientation Pipe Support Locations Piping and Instrument Diagrams Nominal Pipe Diameter Seismic Class I Boundaries Valve Vendor Drawings Valve Weight Valve Operator Weight Valve / Operator Center Of Gravity In-Line Equipment Vendor Drawings Equipment Weight Pipe Support Vendor Drawings Pipe Support Assembly Details Pipe Support Type Pipe Support Orientation Piping Seismic Response Spectra Seismic accelerations as a Curves function of Frequency nn,
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wt Uc 3hm Attachment C
Response to Bulletin 79-14 SYSTEMS OR PORTIONS O'F SYSTEMS WHICH ARE 21ANNFn TO BE INSPECTED AS REQUIRED BY BULLETII: 79-14 Field inspections within the Class 1 functional limits of the fol-lowing Seismic Category 1 piping systems will be conducted as re-quired by IE Bulletin 79-14.
h pro c e,,v o g vnecinn A enn+,irmone a % =7 ora enneral System Main Steam Feedwater Control Rod Drive Hydraulic Core Spray High Pressure Coolant Injection Reactor Building Closed Cooling Water Recirculation Reactor Water Clean-Up Fuel Pool Cooling Salt Service Water Residual Heat Removal Reactor Core Isolation Cooling Turbine Building Closed Cooling Water Standby Liquid Control The systems marked with an asterisk are either entirely or partially within inaccessible areas during normal operation and will be veri-fied either during the January 1980 outage or as outlined in the cover letter to this response.
The..emaining schedule will be consistent with the requirements of Items 1 and 2 of the subject Bulletin.
The schedule is presently being developed to inspect all non-redundant and one subsystem (train) of redundant systems by August 31 and t'e remaining subsystem (train) of the redundant systems by October 31, 1979.
The final schedule will be based on existing plant conditions and ALARA con-siderations.
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Attachment D