IR 05000352/1977015
| ML19275A890 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/10/1978 |
| From: | Fasano A, Mattia J, Mcgaughy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19275A881 | List: |
| References | |
| 50-352-77-15, NUDOCS 7910220181 | |
| Download: ML19275A890 (12) | |
Text
{{#Wiki_filter:U.S..';UCLEAR REGULATORY CC'7tISSIO:3 - OFFICE OF ItiSPECTIOil Ai;0 E.*WCRCEME:li . Region I Report :o. 50-352/77-15 Cocket tio. 50-352 Category A - License tio. CPPR-106 Priority -- Licensee: Philadelchia Electric Coccany 2301 !'arket Street Philcdelt:hia, Pennsylvania 19101 Facility ?;ame: Licarick G:qerating Station, L' nit I gg h Inspection at: Limerick, ?ennsylvania
t Inspecticn conducted: December 7-9, 1977 % s I J d 'b -,I' i / Il ~7 3 Inspectors: J. Matt a, Reactor Inspector date signed b. f? caG i/7/ J J , A. Fasano, Reactor Inspector / oate signed %. %% ikin 'N Finkel, Reactor Inspector date signed ~
h /\\ h A)l' WLa du 1 l 9l1 Y" R. Mc3rearty, Reactor Irf pec:or cate signed t . /// T/7 2 Approved by: )?/M T'o b <t ..- R.' N. McGaugny, Shier' Projects Section < date signed RC&ES Branch Inscection Surmary: _
- ns:ecticn en Cecarber 7-9,1977 (Reccet '!o. 50-352/77-15)
Aru s Insnec.ed: .acutine, unanncuncac inspection of Quality Assurance Procedures and work activities asscCiated with safety related pipe su;perts and restraint systems, containment cenetrations and electrical items. The ins;ectors :J so parformed a plant tour, reviewed licensee's acticn en previous inspection findings.
The inspection involved 92 inspector-hcurs on site by four :iRC in-spactors.
- Resul ts : tio items cf nonccepliance were identified.
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DETAILS 1.
Persons Contacted ' Philadelphia Electric Cccoany
- W. T. Baxter, QA Engineer
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- J. J. Clarey, Resident Engineer gu 0)
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- J. P. Evans, CA Engineer 0. A. Marascio, QA Engineer u
- P. L. Sauk, QA Engineer
. Sechtel Power Corcoration
- R. J. Baldv.in, QA Engineer
- M. H. Brown, Project Field Quality Control Engineer R. Camp, QC Engineer T. F. Fallon, QC Engineer 0. Kelleg, Field Engin~ er e
- E. R. Klossin, Project QA Engineer J. Gearhart, Material Supervisor G. Lauderbeck, QC Engineer K. Quinter, Receiving Inspector
- J. R. Reiney, Jr., Project Construction Manager J. Reynolds, Maintenance Storage Supervisor
- M. H. Shanbhag, QA Engineer
- R. E. Sevo, QA Engineer G. 'lorce, Materials Supervisor
'A. G. ',leedman, Project Field Engineer
- denotes those present at the exit intervie.
The inspector also intervie.;ed craft, supervisory and quality cen-trol personnel of the Reacter Centrols Incorporated, Eechtel Cor-paration and General Electric Ccr.pany during the plant-tcur in-spection activities.
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Plant Tour The inspectors observed work activities in progress, completed work, and plant status in several areas of the plant during general - inspection of the plant. The inspectors examined work items foe any obvious defects or noncompliance with regulatory requirements of license conditions where more detailed inspection of an area,as conducted.
The inspection scope and findings are described in other paragraphs of the report.
3.
Licensee Action on Previous Inscection Findinos (Closed) Unresolved Item (352/76-08-36) - During previous inspection (352/77-01 - Paragraph 3) all unresolved itams discussed in in-specticn report 352/76-06 P.ragraph 3b were considered resolved except for the review of Sechtel's investigation and evaluation of possible hidden voids oc honeyccmb in concrete of the containment.
The inspector reviewac 3echtel's report titled " Investigation, Evaluation and Repair of Ccncrete Voids in Unit 1 Containment," dated June 9, 1977.
The report covers the detection, investigation, evaluation and repair of concrete voi, in the Unit - 1 primary containment at the 254 ft. and 275 f t. elevations for the areas above the personnel and equipment hatches.
The report indicates that ultrasonic sound was attempted to locate voids but that th~e testing was inconclusive. The liner plate was then cut at four locations (10" x 12" holes). The locations were determined by sounding with a hammer.
?;o voids were found at these locations. An analysis '.eas perfor ed assuming voids of 10". and 20".
The modeled calculations indicate that the stresses for these assumed voids were insigni-ficant. This item is considered to be resolved.
Containment Pioine Penetrations The inspector selected the following centainment piping panetrations for review to determine that requir2ments were met with respect to matericls, installaticn and inspection: Penetration X-13B, S/?1001, type 316 SS, RHR Shutdown Return -- Penetration X-239, S/?l, Carbon steel, RHR Relief Yalve -- Discharge ,g3e .
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a.
Materials and Ccmoonents Bechtel Specification 2031-P-310, ' lev. 3 dated May 12, 1976 , and entitled " Technical Specification for Flued Head Fittings for Primary Containment Penetratica for the Limerick Generating Station Units 1 & ?." and Bechtel Ortwing fi-391, Rev. 8, " Flued Head Details," were reviewed by the inspector in order to determine the design criteria for the ecve piping penetraticns.
The inspector fcund that the 1974 ASME Code, Secticn III Subsection ':3, and Section III Subsecticn NC e.as invoked for the materials, design, fabrication, ex.mination and certificaticn of the flued head fittings, and that we' ding activities were governed by Section IX of the 1974 15PE 3&PV Ccde.
No items of noncompliance. vere identified.
b.
Installaticn and Inscection The inspector determined that procurment requirements were met and that inspections associated with the receipt and installation of penetration X-138, S/N 001 and penetration X-239, S/N C01 were performed as required.
The items reviewed to make this determination included the follcwing: QA Shipping Release and Certificate of Confermance sup- -- plied by Sargent Industries Procass Certification supplied by Lindberg Heat Treating -- C:mpany Paterial Test Repcets supolied by Cameron Iron Werks -- Sargent Industries Receiving Incection Reports -- Stress Analysis Acceptance Re;crts -- 3echtel Corporatic ;<aterial Raceiving Reports -- Bechtel Corporation Maintenance Legs P125 AC-1750 and -- P126 AC-1289 Certification for Cleaning ar.d Packacing supplied by -- Sargent Industries t fQehp.{$
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The above records indicated that the materials confermed to the applicable lections of the 1974 ASME Code and that the required proces:es and inspections were perfor ed satisfac-torily.
- fio items of ncnc cpliance were identified.
c.
- delding and Nondatructive Examination (NCE) Activities The inspector visually examined the welds associated with penetrations X-133 and X-239 and observed that the.. eld sur-faces had been prepared for radiography by grinding.
In addition, the inspector observed that openings were covered with polyethelene and that humidity renitcring devices were affixed to the polyethelene.
The inspector reviewed the welding specificaticns, procedure ' qualification records, welder perfor-ance recceds and selected records associated with welding and nondestructive examinaticn of welds related to penetrations X-138 and X-239.
Items re-viewed included the following: -- 'ielding Procedure Specification Pl-AT-LH, Rev. O, dated . January 22,1973 for P1 material using a combination of GTAll-SPX,1 processes for thicknesses fecm 3/16 to 1 inch.
'delding Procedure Specification P8, Pl-AT-AG, Rev. 5, -- dated March 8,1977 for P1 to P8 Taterial using a cccbi-nation of GTA'd-SPXJ for thicknesses frcm 3/16 to 1 3/4 inches.
-- Welding Precedure Qualificati..n Recceds fer the above specification cualified in 23 and SG positions.
'leid Cards ('ARS, Rev. 3) and associated uald filier T.atal -- . wi thdrawal authorization fccms ('. IRS, Rev.8). Radiography Reports P57-RT-ll20 and ?37-RT-il35 supplied -- by Peabody Testing X-Ray Engineering Ccmpany.
3echtel Corporation Radiographic Review Fcrms.
-- Eachtel Corporaticn Radiographic Precedure RT-XG-2, Rev.
-- 1, dated July 1, 1974 h uDb o g'%e \\
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Peabody Testing Procedure 3.20.A.1, Rev. O, dated March -- 1,1975 and entitled " Test and Inspection Procedure Radiographic Examination of 'delds."
Peabody Testing Serial Letter No. P99 dated September 9, . -- 1977 which is the submittal of Radiographic Technique .. ;.. , Sechtel approval of the Peabody Radiographic Technique.
-- Serial letter P99 describes the technique to be used when .erforming e.adiography using Iridium 192 on circumferential
butt welds wner7 2 smaller pipe runs within the pipe to be inspected and the radiaticn passes through one wall of the weld to be inspected plus :ne wall of the inner pipe.
The technique meets the raquit ments of Par. T-243, Section V, Article 2 of the 1974 ASME Code.
The inspector fcund that v elding activities were ccnducted in accordance with the requirements of the 1974 ASME Ccde, Section IX and radiography was conducted in accordance with Section V, Article 2 of the 1974 ASME Ccde.
In addition to the abcVe, the inspector raviewed the certifi-caticn records of four individuals who participated in radio-graphy and film interpretration asso iated with penetrations c X-138 and X-239.
The personnel cartificaticn records reviewed indicated that the individuals were certified to NDE level II and NDE Level III, radiogra;; hic technique, and the certificaticns were in accordance with the 1958 Editicn of SNT-TC-lA.
. o itams of ncncompliance were identified.
5.
Safety - Related Pice Su: cort and Restraint Systems - Procedural A : rov 11, Scr< Procecure Scoce and.ior< Accivities The inspector interviewed licensee perscnnel, reviewed specifica-tiens, pr cedures, check sheets and drawings relative to: approved working docucents, centrols for rawcrking supports, and checks on supports prior to installaticn.
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The inspector examined the following documents relative to the above: Specification 8031-P-319, Specification for Installation of -- Critical Pipe Supports, Hangers and Restraints, Units 1 and . 2, Revision 4, approved July 28, 1977.
Specification 8031-P-321, Specification for Field Fabrication -- of Critical Pipe Supports, Hangers and Restraints for :..o inch and Smaller Pipe, Revision 0, approved April 22, 1976.
Project "anagement Precadure: Lirerick Generating Station -- Units I & II Mechanical Rpeorting and Control System - Hanger Rework, Revision 0, Cecember 1975, approved.
Quality Cgntrol Inspection Records - Pipe Hanger. Opport, -- Restraint and Shock Suppressor Installation - Master QC Instruction No. P-2.10 Revision II, Project QC Instruction "o. 8031/P-2.10 Revision 3.
- Drawings: HBC-ll2-H14, H8C-il2-H15, and HBC-ll2-H16, Revision -- 0.
Based on documents reviewed, discussions with licensee representa-tives and visual observation the inspector noted that rework of pipe supports for material or design consideration is controlled, inspection of snubbers and restraints are checked for piston move-T.ent and deformation prior to installaticn.
The following five mechanical snubbers were visually inspected prior to installation: Support Load - Founds E33-ill - HS E58-111 - H5 dual unit 650 G39-113 - H13 5000 G38-119 - H47 15000 C23-101 - H-1 1500 , k b - e 4, '
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The shaft travel and unit actuation was checked.
The units checked - were located in a site warehouse awaiting packaging for transfer to the main off-site storage facility.
. The following spring supports were visually inspected: Support Load - Pounds G38-109 - H6 100 DCC-103 - H3 100 GEB-109 - H3 -- HSB-112 - HI 6000 HBS-ll8 - H1 dual 6000 GSS-lla - HT9 3C00 G58-il6 - H36 100 G33-ll6 - H26 100 G83-103 - H10 -- G33-102 - H6 -- G88-103 - H4 -- The hanger rod dimension were checked and found to be equal to or greater than 1/2 inch diameter.
The scring suc; orts are provided with hot and cold position.arkings.
The setting as marked on the supports were checked against current drawings.
It was noted that the level settings in the last three supports listed above efid net correspcnd to the drawings.
Further checks and discussion with the field and staff 2ngineers shewed that ccn rol over corrective actions for the abcve di:crepancy is being maintained.
?!c items of noncomoliance were identified.
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6.
Receivina Inscettion, Handling and Starage Peccedures The inspector reviewed the folicwing procedures for receiving, handling and stcrage of electrical equipment during long term and . in-place storage.
2031-JR-G-7 Revision 13, " Storage Maintenance and In-Place -- Maintenance of Installed Equipment".
fluclear Quality Assurance "anual Pcwer Division, San.e -- Section IV, '! umber 4, Revision 5 " Material, Receiving, Storage rancisco, and Control.
Maintenance Reference Manual 6C23602, dated May 28, 1975.
-- The Material Storage Engineer MSE) using the above precedures and vendor specification, issues a(Maintenance Action Card whic the equipment storage requirements.
< The inspector selected the folicwing electrical equipment in icng term storage at the Adwin Warethouse (Offsite Location) and verified that maintenance action cards were issued ad inspecticr3 performed except as noted.
Tag :lo. 1C8215, Motor Control Center.
-- Tag tio. ICB216, Motor Centrol Center.
-- Tag tio. 10B201, 480 Vol t Switchgear.
-- Tag ?tos. 103212/211 aG0 Volt Fotcr Centrol Center.
-- Tag ':os for Primary Containment Electrical Penetraticns.
-- ICJX103 A & 3 20JX103 A 3 3 10dX105 A thru 0 10JX105 E 20JX105 A thru O 20JX105 0 10JX106 A thru C 20JX1C6 A 10JX230 A 20JX1C6 3 and C 10JXiC0 A thru O 20JX230 A 10JX222 20JX100 A thru D 20JX222 h % % @- - oh ~
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. The maintenance action card required the resistance reading of the penetrations listed above to be taken by November 9,1977. As of this inspection which was frca Cecember.7 thru 9,1977, the re- - sistance readings were not taken.
These penetrations tag t'es were issued as overdue in the Maintenance Acticn Required List (MAR 1 which is issued by the maintenance.gecup.
Procedure 3031-JR.G.7 titled, " Storage Maintenance and In-Place Maintenance of Installed Equipment," does not define the action to be taken when an item is overdue and is listed en the MAR list.
This matter is considered to be unresolved pending definitien of action recuired for overdue items.
(352/77-14-01) 7.
Electrical Ecuitmant Stcrice The inspector examined the storage of electrical equipment at the Adwin Warehcuse, Limerick Site '.larehcuse and In-Place Eterage en sit'. At the Adwin Warehcuse the Motor Control Centers and Switchgear equipment was c0vered as required.
Tne lights on the wall receptacles were gicwing indicating that pcwer was on and the heatars of the equipment were energized.
The inspector examined the heaters in the motor control center and switchgear equipment and established that the 120 volt /60 hertz heaters were reduced in Ocwer to 60 volts /60 hertz.
The 240 veit / 60 hertz heaters installed in some of the equi; ment were reduced in ?cwer to 120 volts /60 hertz.
The inscector reviewed the codinc requirements on the Maintenan :e Action Card (MAC).
The MAC re-ferenced Operation 03, Reference 03 of the Maintenance Reference Manual 6C23602.
Ccde 03, 03 is fcc motors and states tha: cc'..e r for motor heatars will be 1/2 of the required voltage during stcrage.
. The inspector informed the Material Storace Engineer that Ccde 03, 03 of the Maintenance Reference (MR) t'anual was not apolicable to motor control centers or saitchgear equipment.
The "R Manual 6C23607 does not define the requirements for heater voitace of electrical equipment other than motors.
' Ccde 03, 03 also recuires that the case temperature be above ambient , while the voltage of the heaters is reduced by 1/2.
The me'.hed for recording temperature of case vs ambient was not defined.
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The Potor Control Centers and Switchgear equipment at the Limerick Site '.13rehouse were in a heated buildino, but did not have any voltage applied to the heaters.
The electrical ecuipment stored - in-place had full power on the heaters.
The above items were discussed with the licensee and they will review the situation.
The definition of heater voltage require-ments for electrical equipment other than motors and case temperature measurement requirements is censidered unresolved.
(352/77-14-02) 3.
Electrical Feccedures The inscector reviewed the folicwino electrical procedures for 'cm-c pliance with codes and regulatory requirements.
l'edium Voltage Petal Clad Switchgear, 3031-E-7, Revision 8 -- 480 Volt Lead Enter and Substations, 3031-E-10, Revision 6 -- 5000 and 15,000 Volt Pcwer Cables, 3031-E-29, Revision 7
-- SCO Volt '?cwer Centrol and Instrumentation Cable, 8031-E-28, -- Revision 6 Electrical ?enetrations, 3031-E-49, Revision 3 -- Storace, Maintenance and In-Place, 3031-JR-G-7, Maintenance of -- Installed Equipment, Revisica 13 !!o items of ncnccmpliance were identified.
9.
Relav Ccordinaticn Study The inspector verified that the Limerick Relay Ccordination Study is being performed by 3echtel at their San Francisco Engineer's Office.
The inspector in_fo_rme..d the. l_ ice.n_see tha t :RC. wil _l. perform a review . __. __ . . _ _.. _ ..... _ _ _.. _....... _...... .. _. _ This item will be examined during a subsequent inspection.
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Unresolved Items Unresolved items are cratters about which nore infomation is re- , quired in order to ascertain whether they are acceptable items, items of nonccmpliance, or deviations.
Three unresolved items disclosed during this inspection are discussed in Paragraph 6 and 7.
11.
Exit Interview.
The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on Cecember 9, 1977. The inspector summari:ed the purpose and the scope of the inscection and the findings.
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' . . . ENCLOSURE 2 . UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.
20555 IE Bulletin No. 79-14 ' Date: July 2, 1979 Page 1 of 3 SEISMIC ANALYSES FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS Description of Circumstances: Recently two issues were identified which can cause seismic analysis of safety-related piping systems to yield ncnconservative results.
One issue involved algebraic summation of loads in scme seismic analyses.
This was addressed in show cause orders for Beaver Valley, Fitzpatrick, Maine Yankee and Surry.
It was also addressed in IE Bulletin 79-07 which was sent to all power reactor licensees.
The other issue involves the accuracy of the information input for seismic analyses.
In t.4is regard, several potentially unconservative factors were discovered and subsequently addressed in IE Bulletin 79-02 (pipe supports) and 79-04 (valve weights).
During resolution of these concerns, inspection by IE and by licensees of the as-built configuration of several piping systems revealed a number of nonconformances to Cesign documents which could potentially affect tne validity of seismic an>'ssas.
Nonconformances are icentified in Appendix A to this bulletin.
'acause apparently significant non-conformances to design documents have occurred in a number of plants, this issue is generic.
The staff has determined, where design specifications and drawings are used to obtain input information for seisraic analysis of safety-related piping systems, that it is essential for these documents to reflect as-built con-figurations. Where subsequent use, damage or modifications affect the con-dition or configuration of safety-related piping systems as described in documents frem which seismic analysis input information was obtained, the licensee must consider the need to re esaluate the seismic analyses to con-sider the as-built configuration.
Action to be taken by Licensees and Permit Holders: All power reactor facility licensees and construction permit holders are requested to verify, ur' cts serified to an equivalent degree within the last 12 months, that '.fv seismic analysis appiies to the actual configura-tion of safety-rel:5 2,,)ing systems.
The safety related piping includes Seismic Catecor' i -j', :s as defined by Regulatory Guide 1.29, " Seismic . -?-91-0 41&O .4
.. . IE Bulletin No. 79-14 Date: July 2, 1979 Page 2 of 3 Design Classification" Revision 1, dated August 1, 1973 or as defined in the applicable FSAR.
For older plants, where Seismic Category I require- - ments did not exist at the time of licensing, it must be shown that the actual configuration of these safety-related systems meets design require-ments.
Specifically, each licensee is requested to: 1.
Identify inspection elements to be used in verifying that the seismic analysis input information conforms to the actual configuration 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 information for the seismic analyses.
Also submit a description of the seismic analysis input information which is contained in each document.
Identify systems or portions of systems which are planned to be inspected during each sequential inspection identified in Items 2 and 3. Submit all of this information within 30 days of the date of this bulletin.
, 2.
For portions of systems which are normally accessible *, inspect one system in each set of redundant systems and all nonredundant systems for con-formance to the seismic analysis input information set forth in design documents.
Include in the inspection. pipo run geometry; support and restraint design, locations, 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 inspection. Where nonconformances are found which affect operability of any system, the licensee will expedite completion of the inspection described in Item 3.
"Normally accessible refers to those areas of the plant wnich can be entered during reactor operation.
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. . IE Bulletin No. 79-14 Date: July 2, 1979 Page 3 of 3 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.
4.
If nonconformances are identified: A.
Evaluate the effect of the nonconformance upon system operability under specified earthquake loadings and comply with applicable action statements in your technical specifications including prompt report-ing.
B.
Submit an evaluation of identified nonconformances on the validity 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: (i) completing the reanalysis, (ii) comparisons of the results to FSAR or other NRC approved acceptance criteria and (iii) submitting descrip-tions of the results of reanalysis.
C.
In lieu of 8, submit a schedule for correcting nonconforming systems so that they conform to the design documents.
Also submit a descrip-tion of the work required to establish conformance.
D.
Revise documents to reflect the es-built conditions in plant, and describe measures which are in effect 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.
Facilities holding a construction permit shall inspect safety-related systems in accordance with Items 2 and 3 and report the results within 120 days.
Reports shall be submitted to the Regional Director with copies to the Director of the Office of Inspection and Enforcement and the Director of the Division of Cperating Reactors, Office of Nuclear Reactor Regulation, Washington, D.C.
20555.
Approved by GA0 (R0072); clearance expires 7/31/80.
Approval was given under a blanket clearance specifically for generic problems.
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. . , APPENDIX A PLAfGS WITH SIGNIFICANT DIFFERENCES BETWEEN CRIGINAL DESIGN AND AS-BUILT CONDITION OF PIPING SYSTEMS ~ Plant Difference Remarks Surry 1 Mislocated supports.
As built conditicn Wrong Support Type.
caused majority of pipe Different Pipe Run overstress problems, not Gecmetry.
algebraic summation.
Beaver Valley Not specifically identified.
As built condition resulted Licensee reported "as-built in both pipe and ' support conditions differ signifi-overstress.
cantly from orginal design."
Fitzpatrick IE inspection identified Licensee is using as differences similar to built configuration Surry.
for reanalysis.
Pilgrim Snubber sizing wrong.
Plant shutdcwn to restore Snubber pipe attachment original design condition.
welch and snubber support assembly nonconformances.
Brunswick 1 and 2 Pipe supports undersize.
Both units shutdcwn to restore original design condition.
Ginna Pipe supports not built Supports ware repaired to original design.
during refueling cutage.
St. Lucie Missing seismic supports.
Install corrected Supports on wrong piping, supports before start up frcm refueling.
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. . .. Page 2 APPENDIX A Plant Difference Remarks - Nine Mile Point Missing seismic supports.
Installed supports before startup frcm refueling.
Indian Point 3 Support location and Licensee performing as support construction built verification to be deviations.
ccmpleted by July 1.
Davis-Besse Gussets missing frem main Supports would be over-Steam Line Supports.
stressed.
Repairs will be ecmpleted prior to start-up.
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. SSINE: 687.0 . .ugu:t.i :, I 3.,<.: , - . . .. e.ccessten uo: 79C8080360 D % @!D [k @"[hi-l hI A L UNITED STATES " NUCf. EAR REG'JLATCRY CCMMISSION 0Frtre Or-r.,45 c.:. T r. e.J. ra..3 cr vnc..:.3.ia.h- - ar .v.
... WASHINGTON, D.C.
20555 .
Supplement IE Sulletin Uc. 79-14 SEISMIC ANALYSIS FOR AS-EUILT SAFETY-RELATED PIPING SYSTEMS Discription of Circumstances: % .
IE Eulletin NO. 79-14 was. issued on July 2,1979 and revised on 'uly 13, 1979.
..ene cul,.etin re uasted..1censees to take certain actions t: '.eri,,y that seismic . . analyses are applicable to as-buil: 31 ants.
This su:p'ement to tne tulletin crevices additional guidance and definition of Action Itams 2, 3, anc 4.
T0 cceply with the recuests,in IE Sulletin 79-14, it will ce necessary for licensees to do the folicwing: 2.
Inscoct Sart of the Accessible Picino F0r eacr. syster selected by the licensee in accor:ance with Its: 2 of the Eu!1etin, the licen:ee is expected to verify by pnysical inspection, to the extent practicaole, that tne inscection elements meet One :ceptance criteri1.
in :erscrming these inspectons. tne licensee is ex:ectec tc use measuring tecnniceat of suffici=nt accurscy to cer:nstrate tha; acr.ctance criteria are cet.
'?here ins:ectice . elemen 3 ir:cr: ant to One seismic analysis cannet te viewed cecaus2 Of thernal insulaticn or location of the piping, tne licensee is 2xpected to -e ve thermal insulation or provice access.
Where crysical ins:ic-40n . is not practicable, e.g., for valve weights and materiais of c:ns ruction, the licance is ex:ectec c verify conformance by ins ectien of cuality assurance recorcs.
If a acoconformance is found, the 'icensee is ex:ected in accorcacce wita Item 4 of the Bulletin to cerform an evaluatier of Ire sicnificance of tne nor.confermance as racidly as ossicle to determire wne-her er no: the coeracility of the syst:m mignt te fec:arci:ec cur'ng a safe snu ccwn earthcuake as defined in t.*e Regui2:icns.
Inis evaluati:n is ex;ectec to ce done in two :nases involvinc an initial engineering ,iucgemen- (witnin 2 days), folic ec by an analytical engineering eva:uat on i (wi nin 30 c3ys).
Wn2re eitner : nase of n2 evaluatic, s.nws nct y.
e: 0: era:ility is in feccardy, the licensee is ex:ec ec :: ee; tre 3; :icacie .e.S....i3.
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The ficansee i '"st Pe:Crt *.ne results cf these inicections in acc0rdar:e witn til "etuir?- ments Tor c0ntent and scnecu,ie as given in.ytem 4 and 4 0* thi ;uted i' . . . . . . 3.
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. . . . _ iupplcment IE Sulietin No. 79-14 ? age 2 of 2 August 15, 1979 ah.
Evaluate Honce.:formances With regard to Item 3A for the Bulletin, the licensee is expected to , include in the initial engineering judgement his justification for continued reactor operation.
For the analytical engineering evaluation, the licensee is expected to perform the evaluation oy using ti:e same analytical tecnnique usec in the seismic analysis or by an alternate, less complex cechnique provided that the licensee can thew that it is conservative.
- If either part of the evaluation shcws that the system may nct perform its intendec functica curing a design basis earthquake, the licensee must promptly c:mply with acplicable action statements anc reporting recuirements in the Technical Specifications.
43.
Submit Nonconformance $ valuations The licensee is expected to sucmit evaluations of all nonconformances and, where the licensee concluces tnat the seismic analysis may not be conservative, submit scnedules for reanalysis in accordan;a with Item 45 of the Bulletin or correct the nonccaformances.
-C.
Correct Uncont.reinces " If the licensee elects to correct nonccafermancas, One licensas is ex;ected to sutr.rit schecules and work cascriotions in accordance ith Item aC of the Bulletin.
40.- Irareve Qualtiv Assurance If concomformancts are icentified, the licensee is expected to evaluate anc 'mareve cuality assurance precedures to assure tnat future mocifica-tions are handled efficien:.ly.
In accorcance witn Itea 40 of the Eulletin.
the licensee is expected to revise design documsnts and seismi: analyses in 3 timely manner.
The schecule for tne action and reporting recuirements given in the Bulletin as criginel'y issued remains uncnsnged.
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Accession No.: 7:02220102 UNITED STATE 5 NUCLEAR REGULATCRY CCF!ISSION OFFICE OF INSPECTICN AND ENFORCEMENT . .e u.. r.v - i 1, an .m c.
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c ::: c... , Scota:ber 7, 1979 ' IE Bulletin No. 79-14 Supplement 2 SEISMIC ANALYSIS FOR AS-EUILT SAFETY-RELATED PIPING SYa. EMS - Description of Circumstances: IE Eulletin No. 79-14 was issued on July 2, revised on July 18, anc first supplemented en August 15, 1979.
Tha tulletin requested licensees to take certain actions to verify that seismic analyses are acclicable to as-built - plants.
Supciecent 2 provides the following additional guidance with regard to implementatica of the bulletin requirements: N0nconformances One way of satisfying the requirements of the bulletin is to in:pect safety-relatec pioing systars against the specific revisions of drawings whien were used cs input to the seiscic analysis.
Scme architect-engineers (A-E) however, are reccc ending that their custccers inspect these systems against tne latest revisions of tne crawings anc mark thoc as necessary to define ne as-built ccnfiguration of the systems.
These drawings are then returned :s the AE's effices for cc parison by the analyst to the seismic analysis input.
For licensccs taking this accroach, the seiscic analyst will Oe the person wno will identi fy nonconfor.mances.
The first stopler.1ent to the bulletin provideo guidance wita regard to evaluatica of nonconformances.
That guidance is apprcpriate for licensees inspecting against later drawings.
The licensee shculd assure that he is peceptly notifiec when the AE identifies a nonconformance, that the initial engineering jucgment is c: pleted in twn cays and tnat tne analytical engineering evaluatica is ccmoleted in 30 days.
If either the engineering jucgement or the analytical engineering evaluation incicates that systec ;cer::ility is in jeopardy, ne licenses is expecte: to est the apolicacle tecnnical specification action statement.
"isual Arc cri ations Sc e licencees are visually estinating pice 1ergths and other inspection. elements, and nave not c0ct:antec which cata have been octainec in tnat way.
Visual estication of dimensions is nct encouraged for ces: easurements; r.:-eve", wnere visual esticates are usec, the accuracy of estimation must be within ::ler-ance recuircrents.
Further, in docu er. ting the ca:a. the licensee must specif-ically icentify those cata that were viscally esticated.
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. . . . IE Bulletin !:o. 79-14, Supp!: ment 2 Scatember 7, 1979 Page 2 of 2 - Thermal Insulation In many areas, thermal insulation interferes with inspection of pice support details, i.e. attachment welcs, saddles, supcort configuratien, etc.
In some areas, the presence of thermal insulati0n may result in unacceptably large - uncertainties for determination of the location of pipe su; ports.
'4here thermal insulation obstructs inspection of support details, the insulation should be removed for inspection of a ninimum of IC% of the obstructed cipe supports in both Item 2 and 3 inscections.
In the Item 3 response, the licensee should include a schacule for inspecting the remaining . . supports.
'lhere necessary to determine the locati n of pipe supports to an accuracy within , o design tolerances, thernal insulation must be removed.
Clearances . For exposed attacaments and penetrations, licensees are expected tc measure er estimate clearances between piping and supports, integral piping attacaments (e.g. lugs and gussets) and supcorts, anc piping and penetrations.
Licensees are not expected to do any disassembly to measure clearances.
Leose Bolts Loose anchor bcits are not covered by this bulletin, but are covered by IE Sulletin No. 79-02.
Any icose ancnor bolts identified ciring actions taken for tnis culletin should be dispositioned under the requirements Of Sullatin No. 79-02.
Other icose bolts are to be treated as nonconformances if they invalicate the seismic analysis; hcwever, torquing of belts is not requirec.
Dif ficult Access Areas uneae inspections are required by the Bulletin but are :ensicered impractical even wita the reactor shutcown, sncula be accressed on a case by case basis.
Information ccncerning ne curcen of performing tne inscec-ion and the safety c:nsequence of not performing the inspection shcuid be c0cumentec by tne licensee and forwardec for staff review.
Schedu12 The schedule for the action and reporting requirements given in the Buile. tin as originally issued remains unchanged.
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. . _ ENCLOSURE 3 PECO Report (June 13, 1978) . . }}