ML19290C010
| ML19290C010 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/20/1979 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19290C004 | List: |
| References | |
| NUDOCS 8001090034 | |
| Download: ML19290C010 (8) | |
Text
AFFIDAVIT OF DONALD J.
BROEHL ASSISTANT VICE PRESIDENT PORTLAND GENERAL ELECTRIC COMPANY REGARDING LICENSEE'S RESPONSES TO IE BULLETIN 79-14 1729 240 B 0 010 90 0 34
AFFIDAVIT OF DONALD J. BROEHL REGARDING LICENSEE 'S RESPONSES TO IE BULLETIN 79-14 My name is Donald J. Broehl and my title is Assistant Vice President of Portland General Electric Company.
The purpose of this affidavit is to describe briefly Licensee 's inspections pursuant to NRC 's IE Bulletin 79-14, the results of those inspections and subsequent evaluations.
Further, I will explain why the results of Licensee 's IE Bulletin 79-14 inspections are unrelated to the Control Building Proceeding.
NUCLEAR REGULATORY COMMISSION IE BULLETIN 79-14 IE Bulletin (IEB) 79-14 was issued on July 2, 1979; revised on July 19, 1979; and supplemented on August 15, 1979.
IEB 79-14 required all licensees to verify that seismic analyses of piping systems classified as Seismic Category I conformed to the actual configurations by:
1.
Identifying available documentation with respect to as-built configurations and submitting an inspection plan to the appropriate NRC I&E regional office within 30 days (30-day report).
2.
Inspecting one train of accessible piping and reporting the results of such inspection within 60 days of the date of the original Bulletin (60-day report).
3.
Inspecting the remaining piping and reporting the i729 241
results of such inspection within 120 days of the date of the original Bulletin (120-day report).
4.
Evaluating and reporting, where appropriate, any non-conformances discovered.
In my letter dated July 17, 1979, to R.
H. Engelken of NRC I&E Region V, I expressed Licensee 's judgment that no serious safety problems would be discovered in the IEB 79-14 inspections.
This judgment was restated in my letter dated August 1, 1979 transmitting Licensee 's 30-day report.
Nothing has been found in the course of Licensee 's inspections to date to indicate that such judgment was incorrect.
The results of inspections of all Seismic Category I piping outside of Containment, plus one train of Seismic Category I piping and non-redundant piping within Containment, were reported in the 120-day report dated October 30, 1979.
The results to date of Licensee 's reviews are summarized below.
RESULTS OF IEB 79-14 INSPECTIONS During inspections of safety-related piping, any deviations beyond those allowed by tolerances established in piping specifications were identified as deficiencies.
Licensee 's experienced piping stress analysts and engineers evaluated each deficiency onsite to determine the appropriate corrective action.
One of three different existing procedures were utilized to document and resolve each deficiency: a) Maintenance Request (MR) procedure; b) Drawing Change Notice (DCN) procedure; or c) Nonconformance Report (NCR) procedure.
1729 242 The MR procedure is utilized for minor maintenance type
- items, i.e., where the only action needed is the adjustment of hangers or supports or the adjustment of piping to reestablish proper clearances through normal Plant maintenance procedures.
The DCN procedure is utilized for minor, non-essential differences between existing documentation and field conditions, i.e.,
where existing drawings should be corrected to reflect as-built conditions but the deficiency does not have the potential to affect operability of the system.
The NCR procedure is utilized in instances where the deficiency has the potential to affect the capability of the system to perform its intended function.
Licensee 's 60-day report of August 31, 1979 (referenced and quoted in paragraphs 7, 9 and 10 of Intervenors ' Motion of December 8, 1979) reported that approximately 50 DCNs had resulted from the inspection of accessible nonredundant and one train of redundant piping outside of Containment. */
In accordance with IEB 79-14, each of the 50 corrections to drawings **/ has been evaluated, and every such evaluation
- /
Licensee 's 120-day report of October 30, 1979, reported that approximately 75 DCNs had resulted from the inspection of the balance of the piping outside Containment and of one train of piping inside Containment.
Only one train of the redundant piping inside Containment remains to be inspected. That inspection is scheduled to be completed during the Spring 1980 refueling.
- / While the DCNs were being reviewed, four of the piping supports involved were identified as requiring modification for reasons unrelated to correction of the drawings.
None of these four supports were subject to review pursuant to License Condition 2.C.(10)c, nor did they compromise the capability of the systems to perform their intended functions.
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confirmed that the systems involved were capable of performing their ?.ntended functions before, during and after a seismic event.
The NCRs resulting from the IEB 79-14 inspections are discussed below.
NONCONFORMANCE REPORTS RESULTING FROM IEB 79-14 INSPECTIONS As a result of the inspections completed to date (i.e.,
up to and including those described in the 120-day report),
the following ten NCRs have been written:
(a) One nonconformance, described in the 60-day report, involved two damaged supports at approximately elevation 22 ft. in the Auxiliary Building, and was reported in Licensee Event Report 79-13, as discussed below.
(b) One nonconformance, also described in the 60-day report, involved an uncompleted seismic restraint on the Auxiliary Feedwater System in the Main Steam Support Structure (not part of the Complex).
Analysis showed that the system would have performed its intended functions without the support.
- However, installation of the restraint has been completed.
(c) One nonconformance involved two out of four anchor bolts securing a pressurizer relief valve piping snubber inside Containment, which were found to be nonfunctional.
Analysis showed that the remaining 1729 244
nonfunctional.
Ane. lysis showed that the remaining two functional bolts were sufficient to support the restraint; thus, the system would still have performed its intended function.
However, the two nonfunctional bolts were replaced.
(d) One nonconformance involved a feedwater pipe-whip restraint inside Containment which was improperly shimmed, resulting in an overstress and damage to an adjacent seismic restraint.
Reanalysis showed that the adjacent seismic restraint was not required.
Nevertheless, the adjacent seismic restiaint and the improperly shimmed restraint were repaired.
(e) One NCR documented a base plate for a Reactor Coolant System restraint inside Containment which was installed with undersized anchors.
Analysis showed that the undersized anchors were sufficient and did not need to be replaced.
(f) Four NCRs documented missing or incomplete restraints on small lines inside Containment.
The three 3/4-in.
lines and one 3 '... line affected would have performed their intended functions without the restraints.
Nevertheless, corrective action was taken such that each (.2 these four restraints has now been properly 1729 245
-s_
installed.
(g) One nonconformance involved a missing restraint on Containment Spray System piping at elevation 10 ft of the Auxiliary Building.
(This is also discussed in LER 79-13 described below).
Analysis has shown that the system would have performed its intended function without this restraint.
However, the restraint has been installed.
LICENSEE EVENT REPORT 79-13 Licensee Event Report 79-13 (LER 79-13), dated September 6,
1979, reported upon the two damaged supports at elevation 22 ft of the Auxiliary Building mentioned in Item (a), under "Nonconformance Reports" above. */
These supports involved suction piping of Train A of the Containment Spray System.
While performing the IEB 79-14 inspections, Licensee's engineers discovered that a pedestal-type seismic support (SR-2) had slid off its base.
Further inspection revealed cracks in the structural steel for an adjacent seismic anchor (SA-3).
Since analysis of the Train A piping indicated that with SR-2 nonfunctional, SA-3 would be overstressed and Train A would be theoretically degraded following a seismic
- / LER 79-13 was provided to the Board and the parties by the NRC Staff on September 26, 1979. 1729 246
event, the LER was submitted.
The two damaged supports have been repaired.
An inspection was performed to determine if any problems existed with the equivalent supports on Train B.
No equivalent supports were found to be damaged; however, one support was found to be missing at elevation 10 ft in the Auxiliary Building (See Item (g) under "Nonconformance Reports" abovel.
Analysis of the Train B piping showed that, although the piping stresses would exceed code allowables during a seismic event, the piping would not exceed its yield strength and thus the system would perform its intended function.
The missing restraint has been installed.
RELEVANCE TO CONTROL BUILDING PROCEEDING All inspections required by IEB 79-14 within the Complex have been completed.
Of the ten NCRs identified during inspections pursuant to IEB 79-14, eight involved supports or restraints outside of the Complex.
The two NCRs reporting nonconformances within the Complex (Items (a) and (g) above) involved supports which were located below ground level (elevation 45 ft) in the Auxiliary Building and thus were not subject to review during the seismic confirmation reviews 1729 247
required prior to interim operation.
These nonconformances have no relationship to the design deficiencies considered in the Control Building proceeding. *j All of the piping within the Complex subject to addition or modification of supports or restraints pursuant to License Condition 2.C.(10)c (added as required by the Partial Initial Decision of December 21, 1978) has been reviewed, and no conditions have been found which constitute a violation of this Licennee Condition.
The foregoing Affidavit is true.
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/ lb Donald J. Brochl" Assistant Vice President Portland General Electric Company State of California
)) ss County of San Francisco )
TH SubscribedandsworntobeforemethiskO day of December 1979.
m 2
Notary Public or Cal rnia OFFICIAL SEAL FRED BORGMAN
- } NOTARY PUBLIC - CAllFORNIA
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MARIN COUNTY
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- j As described above, one NCR involved two damaged supports, the other involved a single missing support.
1729 248