ML19257B941
| ML19257B941 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/09/1979 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| IEB-79-14, NUDOCS 8001210292 | |
| Download: ML19257B941 (6) | |
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e goa STATE Omaha Public Power District 1623 HARNEY a OMAHA. NE5RASMA 68102 a TELEPHONE S36-4000 AREA C O O F.
402 November 9, 1979 Mr. K. V. Seyfrit, Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Reference:
Docket No. 50-285
Dear Mr. Seyfrit:
The attached information is provided in response to a telephone call en November 6, 1979, with Mr. Madsen and Mr. Westerman of your staff.
The information su=arizes the Omaha Public Power District's efforts, to date, in regard to IE Eulletin 79-14.
Sincer.ely,'
b.,1 l
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W. C. Jcnes Division, Manager Production Operations WCJ/KJM/BJH:j=m
- Attach, cc: Director of Nuclear Reactor Regulation ATTN:
Mr. Robert W. Reid, Chief Operating Reactors 3 ranch No. h U. S. Nuclear Regua.atory Cc= mission Washington, D. C.
20555 Director, Office of Inspection and Enforcement U. S. Nuclear Regulatory Cc=ission Washington, D. C.
20555 5774 210' 8001210a.qE
l ATTACHMEITT 1.
Exact Status of All 79-lk Insteetions to Date and 2.
Number of "Discretancy Elements" Analyzed in Detail r_nd Results and the Number in Need of Analysis As of this writing, all inspections required by IE Bulletin 79-14 have been completed, with the following exceptions:
(1) Systems inside of containment.
(2) Fire protection piping eithin the intake structure and piping for the containment hydrogen purge system.
Isometric drawings are presently unavailable for comparison with "as-built" conditions.
The District vill continue to search for these drawings.
However, if drawings are not available by December 15, 1979, frem any source, isemetric drawings vill be generated and a seismic analysis performed.
(3) Uniccated restraint drawings are as follows:
Dravo IC-No.
BP ISO No.
Restraint Nos.
IC 413 377 fACS-252-255-259-238-2h9-244 92 256 ACS-136-137-139-139A-140-1 LOA-lh1 91 255 Ccmpo-ACH-343, ACS-130-131-132-133A 89 253 nent ACS-126 85A 387 Cooling,ACS-292-292(IP)-293-295(IP)
IC-83A 381 System ACS-280-282-283-284 (All IP) 8hA 248 ACS-286-286A-289-238 72 258 DIS-156 73 266
- SIS-lh3(IP)-14h(IP)-149(IP) 74 265 Safety / SIS-136(IP) 78 271 Injec-1 SIS-143(IP)-149(IP)-156(IP), SIH-186 79 26T tion l SIS-1683-1653 16k 269 Systen (SIS-lh9-156-lh3-137 The District vill continue to search for these drawings.
However, if drawings are not available by December 15, 1979, from any source, an analysis vill be performed to determine the adequacy of the as-built condition.
(h) Piping in high radiation areas.
Included in this cate-gory are:
(a) 3" CVCS piping from LCV-218-1 to the volu=e control tank (VCT); k" CVCS piping from the VCT to LCV-218-2';
- 3" VCT makeup line; see FSAR Figure 9.2-2; gen.eral area radiation level =100 mr/hr, contact readings';. - "
to 1 5 r/hr.
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(b) 2-1/2" CVCS piping to and from letdown heat exchanger; see FSAR Figure 9.2-2; general area radiation level
=50 mr/hr, contact readings to 1 r/hr.
- (c) 3" CVCS piping to and from ion exchangers and puri-fication filters; see FSAR Figure 9 2-2; contact readings > 1 r/hr.
(d) 6" waste disposal piping to and from vaste holdup tanks; see FSAR Figure 11.1-4; this piping is located inside of vaste holdup tank vaults with consequent high radiation levels and very difficult access.
(e) 8" component cooling vater piping to and from the letdown heat exchanger; see FSAR Figure 9 7-1; general area radiation level :50 mr/hr, contact readings to 1 r/hr.
(f) 8" component cooling water piping to and frem the spent fuel pool (SFP) heat exchanger; see FSAR Figure
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9 7-1; general area radiation level =600 =r/hr, con-tact readings to 50 r/hr.
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(g) 8" SFP cooling piping downstream of AC-19h; 4" and 3" SFP cooling piping downstream of AC-232; 8" SFP cool-ing piping upstream of AC-186,187; see FSAR Figure 9.6-1; general area radiation level =600 =r/hr, con-tact readings to 50 r/hr.
(5) Piping submerged beneath the surface of the spent fuel pool and the safety injection and refueling water tank.
For the purpose of this discussion, the following definitions apply:
(1) Inspection Eleme,nts - parts and components of piping -
systems which would be defined and quantified as inputs to the seismic analysis.
Included would be valves, large pipe fittings (e.g., reducers), and pipe supports.
("In-spection Elements" as previously reported only referred to piping supports / restraints.)
(2) Discrepancy - any significant difference between the "as-built" condition and the condition depicted in the design docu=ents. Differences vere considered to be significant if the possibility existed of invalidating the seismic analysis or further independent review was desired.
Out of all of the inspection elements examined, caly 230 dis-crepancies were found which were resolved as follows:
1774 212 Total No. of Discrecancies 230 f
I Detailed Analysis Detailed Analysis Complete Returned to Design in Progress 112 Condition, No
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108 Analysis Done 10 I
' Corrective Action Required
' As-Built" Condi' ion Satisfactory t
and Completed 102 10 O
Initial engineering judgement, made by the Plant Review Com-mittee, concluded that system operability was not in jeopardy.
Where a judgement could not be made, field modifications vere performed on an expedited basis, within applicable limiting conditions for operation (LCO's) of the Fcrt Calhoun Technical Specificaticas. All discrepancies were referred to the Dis-trict's A/E for evaluation.
3 Schedule for Completion of Detailed Analysis for Phases I and II All of Phase I discrepancies, except 17, vill be evaluated by November 15, 1979 These exceptions involve special censideratiens and vill be resolved as soon as possible.
All discrepancies of Phase II will be evaluated by November 22, 1979 h.
What is the District's Schedule for the Review of the Gibbs &
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Hill Seismic Analysis to Determine if the Revisien of the ISO's Used for the Field Instection (FI ISO) was the Same Revision Used for the Seismic Analysis To make the above determination, the following must be accom-plished:
(1)
Review and evaluate the data recently obtained from Gibbs & Hill.
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(2) Verify that field inspection isometric drawings were the same
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as those used as input to the seis=ic analysis.
The District's schedule for ccmpletion of items (1) and (2) is November 16, 1979 The determination of the extent of the review of the data vill be made after completion of items (1) and (2) above.
3 Justification and Reasons for Missing 30 Day Evaluation Period The primary reason for not meeting the 30 day requirement for evaluation of discrepancies is the unforeseen ec=plexity of modeling the systems and the analysis required.
In same cases the complexity was recognized only after analysis had begun.
As a result it was necessary to obtain additional information before completion of the evaluation.
Once a problem was recognized, the solution and recc== ended corrective action had to be developed.
The emphasis during this phase of evaluation was to thoroughly evaluate discre-pancies, thereby minimizing modifications which might be required, rather than minimizing the time to obtain a recom-mended solution. This led to iterations in the computer runs and additional time expenditure.
1774 213 Another complication which arose occurred because the field inspection was done in two phases, Phase I and Phase II.
In some instances discrepancies observed during the Phase II in-spection i=pacted on the evaluation of Phase I discrepancies.
The time difference between Phase I and Phase II therefore affected the ecmpletion date of Phase I.
A further scheduling
k-impact was caused by the failure of the computer printer for a two day period, at a critical time.
In general, the lack of resources (i.e., manpower, ccmputer availability, etc.) for all phases of this work contributed to the delay.
6.
What is Beine Done to Extedite Co=uletien of Evaluation Additional Gilbert / Commonwealth manpower was assigned to the team performing the detailed analysis of discrepancies re-ported by OPPD inspectica crews. Manpower was increased when it became apparent that the amount of ec=puter analysis needed exceeded the estimates for which the original tess was sized.
Computer time was found to be a significant amount of the total evaluation time. The priority of all ec=puter runs thereafter was assigned the highest priority number, representing a time savings of about 20%.
Key Gilbert /Com=cnvealth personnel who are responsible for performing the ecmpilation and evaluation of computer results have been verking an average of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> overtime per man per week. Others involved with various aspects of the project have been working an average of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> overtime per man per week.
In addition, all correspondence between OPPD and Gilbert /Com-monwealth has been transmitted via Telecopy or Express Mail Service.
We believe everything practical has been done to expedite this effort; however, the District is re-emphazing to District and A/E perscnnel the need to closely monitor progress to further insure timely completion.
7 What Modifications are Being Dcne in the Field as the Result of the Instections As a result of IE Bulletin 79-14 inspections to date, initial engineering judgements perfor=ed by the Plant Review Committee on field inspection discrepancies concluded that the integrity of associated piping did not appear to be jeopardized and, therefore, the associated system was deemed to be capable of performing its design function.
In the event that a restraint was found to be inadequate, corrective action was proposed and promptly completed to repair or modify the restraint within the Technical Specification LCO.
Within this framework, a further conservative approach was k
utilized by the Plant Review Committee in handling discre-pancies.
In order to insure integrity and to expedite field co=pletion, the plant staff invoked the associated Technical Specification, even though system piping integrity was not initially judged to be adversely affected. Of parti-cular concern vere two restraints en the component cooling vater
system ( ACS-326 and ACH-246), which were analyzed for restraint adequacy and found to be inadequate. When this evaluation was presented to the plant staff, i==ediate corrective action was initiated, even though evaluations of piping integrity were not ecmpleted.
If a failure of these restraints in a seis=ic event would cause a failure of the associated piping, the plant's rav vater system is designed to provide the required safety function in a backup role.
To insure proper consideratica of reportability as a Licensee Event Report, all discrepancies which have been repaired or modified in the field vill be reported, even though the initial engineering judgements in these cases indicated that system operability was not jeopardized.
1-774 215'