ML19344A520
| ML19344A520 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/05/1980 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Kostmayer P HOUSE OF REP. |
| Shared Package | |
| ML19344A521 | List: |
| References | |
| NUDOCS 8008210054 | |
| Download: ML19344A520 (2) | |
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C The lionorable Peter 11. K'ostmayer
.THIS DOCUMENT CONTAINS United States-liouse of Representatives -
POOR QUALITY PAGES
!?ashington, D. C.
20515-
Dear Congressnan Kostnayer:
This is in response to your letter of June 20,19R0 to fir. Carlton Kamerer concerning the.possible effect of blasting on " green" concrete at toe Limerick site.
'iRC has requested Philadelphia Electric Congany to look into the potential-effect of-quarry operations on construction at the Limerick site. Their report is in final review and should'be transmitted to the fiRC within the next few weeks. Upon receipt, the fiRC staff util review this report to determine uhether or not the conclusions reached by Philadelphia Electric are justified.
We have also asked for, and received, fro;a Phildelphia Electric additional information uhtch the staff is using in its review.
In this connection ue have asked the U. S. Geological Survey to assist us in this review and have provided the:a with all of the information that ue have received to date.
They ulll require the Philadelphia Electric report to coaplete their analysis.
I have enclosed a copy of a Director's Decision issued in October,1979 which addresses this and other matters raised by a Mr. Frank R. Psomano. With regard to the blasting being conducted at the quarry and its possible effect, the Director's Decision calls for the further investigation which is no'.i underaay and nearing its. completion.
We will provide copies of reports to your office as soon as they are available.
Sincerely, ptsoeO 3, gevin COS*U William J. Dircks, Acting Executive Director for Operations
Enclosure:
As stated
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UNITED STATES OF A ERICA
_ gCLEAR REGULA10RY COMMISSION f
0FFICE OF' NUCLEAR :lEACTOR REGULATION HAROLD R. DFt:;0N, DIRECTOR In the Matter of
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Docket Nos. 50-352 PHILADP. PHI A ELECTRIC COMPANY
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and 50-353 (Limerick Nuclear Generating
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Station, Units 1 and 2)
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CORRECTION AND CLARIFICATIONS TO DIRECTOR'S DECISION UNDER 10 CFR 2.206 The " Director's Decision Under 10 CFR 2.206" dated October 9,1979 is amended to _ reflect the following corrections and clarification:
1.
On Page 1, in the twelfth line of the first paragraph replace -
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" April 14,1978" with " April 14,197f "
2.
The following footnote is added to the bottom of page 1:
1/
" Mr. Romano's May 14, 1979 letter makes reference to an Apr11 11, 1979 letter from "Mr. Karl Kneill" (sic) to Mr. V. Bauer of PECO.
NRC files indicate that the only letter Mr. Kniel sent to PECO in April'1978 was the letter dated April 14, 1973 discussed above."
3.
The footnote on page 2 is renumbered as footnote 2.
4.
On Page 5, in the fifth line, the sentence "PEC0's response was submitted on August 1,1979" is replaced with the following:
"PECO's response is anticipated by the first week in November 1979."
5.
On Page 6 the sentence, " Based on the reanalysis, PECO found that some of the gaps which would be unacceptable under the original analysis were acceptable; the balance of the insufficient gaps were increased to meet the PSAR comitment." is replaced by:
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" Based on the reanalysis, PECO f ound that with the exception of two areas,theconstructedgapsmetthePSA.kcommitment. The factor of safety for the two areas was 1.7 and PEC0 found this to be accept-able. -The reanalysis wa.s also used to evaluate gaps that had not been constructed; the gaps which had a safety factor less than 2.0 were increased. The NRC has not completed its review of PECO's final report on the matter of separation gaps."
7.
The following sentence replaces the final sentence in the first para-graph on page 6:
"Again our review of PECO's final report on the separation gaps and our review of the FSAR for the Limerick plant must conclude that the
-design of the plant is acceptable before the plant can go into opera-tion."
Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 94 day of AwMgg l
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UFITED STATES OF AIERICA NUCGAR REGULATORY COMMSSION OFFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR In the Matter of
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PHILADELPHIA ELECTRIC COMPANY
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Docket Nos. 50-352 (Limerick Nuclear Generating
)
and 50-353 Station, Units 1 & 2)
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DIRECTOR'S DECISION UNDER 10 CFR 2.206 By letter dated April 12, 1979, Frank Romano of Ambler, Pennsylvania, requested that the Comission investigate whether blasting at a quarry near the site of the Philadelphia Electric Company's (PECO) Limerick Generating Station has a deleterious effect on the site. Mr. Romano's letter has been treated as a request under 10 CFR 2,206 of the Cocmission's regulations.
Notice of receipt of Mr. Romano's April 12th letter was published in the Federal Register 44 Fed. Reg. 33987 (June 13,1979). In letters dated May 14 and Jt'ne 12, 1979, Mr. Romano also raised concerns related to (1) concrete void /honexamb in a structure at the Limerick facility, (2) the computer analysis used in the seismic design of safety-related piping, (3) the dis-covery of insufficient gaps between seismic Category I structures, and (4) a request for information from the NRC sent to PECO on April 14, 1978, regarding the design of safety-related components in the containment building.
Mr. Romano requested that repair of concrete void / honeycomb be included in his request for an investigation of blasting near the Limerick site.
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While the subject of the blastina way envarari rieirinn tha
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two particular issues were adequatel, ;
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's SE? 7 ms Philadelphia Electric Company License No. CPPR-106 Attention:
Mr. V. S. Boyer I.1spection No. 76-08 Vice President Docket No. 50-352-Engineering and Research 2301 Market Street Philadelphia, Pennsylvania 19101 Gr.ntlemen:
. This refers to the inspection conducted by Mr. A. Toth of this office on August 16-19, 22, 25, 1976 at the Limerick Generating Station of activi-Lies authorized by NRC License No. CPPR-lC6 and to the discussions of our findings held by Mr. Toth with Messrs. J. Corcoran and J. Clarey of your staff at the conclusion of the inspection.
i Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this
' letter. Withih these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with
. personnel, and observations by the inspector.
Within the scope of this inspection, no items of noncompliance were observed.
In accordance with Section 2.790 of the NRC's " Rules o'f Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this latter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your con-tractor) believe to be proprietary, it.is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or cart sought to be withheld, and which contains a statement of' reasons knich addresses with specificity the items which will be considered by the Commission as listed in subpara-graph (b)(4) of Section 2.790.
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the speci-fied period, the report will be placed in the Public Document Room.
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No reply to this letter is required; however, should you have any questions concerning this inspection,.we will be pleased to discuss them with you.
Sincerely,
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Robert T. Carlson, Chief Reactor Construction and Engineering Support Branch Enclosura:
IE Inspection Report No. 50-352/76-08 e
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U. S.1:UCLEAP. RECUL\\ TORY CC:::!ISSION OFFICE OF I!SPECTIO:: A :D E: 70RCC!E:Tr RECICH I J
IF. Inspection Report Mo:
50-352/76-08
'. Docket No_:.50-352 Liccasce:
Philadelphia Electrid* Company License No: CPPR-106
.2301 Market Street Pdo @**
Philadelphia, Pennsylvania 19101 A
,g Safeguards
' Limerick Unit I Limerick, Pennsylvania'-
Group:
Ty of Licensec:
BWR 1065 MWe (GE) ut ne, an u ed Type of Inspecticn:
Dates of Inspection:
August 16-19, 22, 25, 1976 June 21-25, 1976 Dates of Previous Inspection:
Reperting Inspector: '
e' A. D. Toth, Reactor Inspector DATE Accompanying Inspectors:
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GCT 15 076 License No. CPPR-106 Philadelphia Electric Company Inspection No. 76-09 Attention: Mr. V. S. Boyer Docket No. 50-352 Vice President Engineering and Research 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
This refers to the inspection conducted by Mr. A. Toth of this office on 11, 14-17, 27, 1976 at the Limerick Generating Station of September activities authorized by NRC License No. CPPR-106 and to the discussions
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of our findings held by Mr. Toth with Mr. Corcoran of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of salective examinations of procedures and representative records, interviews with personnel, and observe.tions by _ the inspector.
Bssed on the results of this inspection, it appears that ccrtain of yo::
activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix These items of nonccmpliance have been categorized into the '.evels A.as described in our correspondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisions of Section'2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within thirty (30) days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you at.d-the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full com-pliance will be achieved.
With respect to Appendix A, we note that you have corrected Item No. 3, and therefore you need not address yourself to this matter in your response.-
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Item No. 2, shown in the Notice of Violation enclosed with this letter
. In your response to this letter
'is a recurrent or uncorrected item.
please give this matter your particular attention.
In accordance with Section 2.790'of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy. of this letter and the If this-enclosures will be placed in the NRC's Public Document Room.
report contains any information that you (or your contractor) believe,co be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public Any such application must be accompanied by an affidavit disclosure.
executed by the owner of the information, which identifies the document to be withheld, and which contains a statement of reasons or part sought which addresses with specificity the items which will be considered by The the Commission as listed in subparagraph (b)(4) of Section 2.790.
information sought to bc withheld shall be incorporated as far as If we do not hear from possible into a. separate part of the affidavit.
you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, Af.
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lRobertT.Carlson, Chief--
Reactor Construction and Engineering Cupport Branch
Enclosures:
1.
Appendix A, Notice of Violation 2.
IE Inspection Report No. 50-352/76-09 J
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Licu.: e :.. (,P M:- 106 APPENDIX A NOTICE OF VIOLATION _
Based on the results of the NRC inspection conducted on September 11, 14-17, and 27, 1976, it appears that certain of your activities were not conducted in full. compliance with the conditions of NRC Facility License CPP.R-106 as indicated below. These items are bafractions.
1.
Criterion V of Appendix B of 10 CFR 50 requires that " activities affecting quality.. _. shall be accomplished in accordance with these instructiods,. proce~dures, or drawings." Job specification P-303 requires " protective closures and seals shall be applied to component openings to maintain cleanliness prior to, during, and subsequent to erection, and..
openings and pipe ends shall be sealed at all tLaes except when they must be unsealed to carry out necessary fabrication operations."
Contrary to the above, the CRD penetrations were on September 27, 1976 observed to.be uncovered and dust, particulates, and paint overspray were observed in the open socket weld ends.
2.
Criterion V of Appendix B of 10 CFR 50 requires that " activities affecting quality..-. shall be accomplished in accordance with these instructions, procedures, or drawings." Job specification C-36 part 6.1.4 requires spacing of reinforcement in accordance with ACI-318 which specifies clear distance between bars not less than the nominal bar diameter nor 1 inch.
Contraryfto the above, on September 15, 1976, parallel bars were in contact in the containment drywell wall above the airlock. The licensee initiated corrective action steps banediately.
3.
Criterion XV of Appendix B of 10 CFR 50 requires that "Non-conforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."
Bechtel Field Inspection Manual Procedure G-3 provides the mechanics of obetining and documenting the above actions.
Contrary to the above, the quality control inspection reports for June 23-24, 1976 concrete placement of the containment drywell walls did not reflect that concrete ingredient proportions were suspect for six truckloads of concrete, nor was this' matter identified and reported in the controlled manner provided by the nonconformance report system. The licensee promotly corrected this item by issuance of the required nonconformance report for action per the G-3 procedure.
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U. S. NUCLLiR RECUL\\ TORY CC:!:!ISSION OFFICE OF INSPECTION AND ENFORCC4ENT REGION I IE Inspection Report $$:
50-352/76-09 Docket No:
50-352 Licensee:
Philadelphia Electric Company License No:
CPPR-106 2301 Market Street Priority:
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Philadelphia, Pennsvlvania 19101 Category:
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Safeguards Location:
Li=erick Unit I, Limerick, Pennsvivania Type of Licensce:
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Type of Inspection:
Routine. Unennounced Du.cs of Inspection: September 11. 14-17, 27, 1976 l
Dates of Previous Inspection:
August 16-19. 22, 25. 1976 j
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Reporting Inspector:
- ac" Inspector DATE j
A. D. Toth, /
Acco=p'anying Inspectors:
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W. F. Sanders, Reactor Inspector DATE DA,J,E,,
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U. S. NUCLEAR REGULATORY CCPMISSION OFFICE OF INS?ECTION AND ENFCRCDir,r REGION I II Inspection Repo:: No:
50-352/77-01 Locket No:
50-352 Licensee:
Philadelphia Electric Company License No:
CPPR-106
_ 01 Market Street 7:iort y: _
23 A
Philadelphia, Pennsylvania 13101 Category:
Safeguards Location:
Limerick Unit 1, Limerick, Pennsylvania Type of Licensee:
T3 of Inspection:
Routine, Unannounced Dates of Inspection:
January 24-25, 1977 December 15-16, 1976 Da:es of ?revicus Inspec: ion: '
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Reperting Inspec:or:
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A. A.'Varela, Reactor Inspector DATE Acco:panying Inspec: cts:
None DATE DATE DATE Other Ace psnying ?ersonnel:
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<ino or anuss:A. essusvi.,VANIA 1H06 f..,,.;.e f DocketNo.50-352,/~N JA!i i 156 Philadelphia Electric Company
. ATTN: Mr. V. S. Boyer Vice President Engineering and Research 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
Inspection 50-352/77-15 This refers to the inspection conducted by Mr. J. Mattia of this office on December 7-9, 1977, at Limerick Generating Station, of activities authorized by flRC License No. CPPR-106 and to the discussions of our findings held by Mr. Mattia with Mr Baxter and others of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, no items of noncompliance were observed.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this. report contains any informatfor. that you (or your contractor)
-believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Commission as listad in subparagraph (b)(4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, the report will'be placed in the Public Document Room.
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ilo reply to'this. letter is required; however, s ould you have any ques-h tions concerning this inspection,..e will be pleased to discuss them with you.
Sincerely,.
J c/f. 0}sk Robert T. Carlson, Chief Reactor Constructicn and Engineering Support Bran,ch
Enclosure:
Office of Inspection and Enforcement Inspection Report ; umber 50-352/77-15 e
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U.S. ::UCLEAR REGULATORY CC:NTSSIO:1 0FFICE OF IflSPECTION Afl0 E:! FORCE:'ENT Region I Report flo. 50-352/77-15 Docket tio. 50-352 Category A
License rio. CPPR-106 Priority Licensee:
Philadelphia Electric Company 2301 Market Street Philadelchia, Pennsylvania 19101 Facility flame: Limerick Generating Station, Unit 1 Inspection at: Limerick, Pennsylvania Inspection conducted: December 7-9, 1977 Inspectors:
b-i!4!'73 J. Mattia, Reactor Inspector date signed b! hwe@
i/*/ Ji A. Fasano, Reactor Inspector
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'N. Finkel, Reactor Inspector date signed r ---
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R.' N. McGaughy, pief' Projects Section
/ date signed RC&ES Branch Insoection Summary:
Inscection on December 7-9, 1977 (Recort tio. 50-352/77-15)
Areas Inspected:
Routine, unannounced inspection of Quality Assurance Procedures and work activities associated with safety related pipe supports and restraint systems, containment penetrations and electrical items. The inspectors also performed a plant tour, reviewed licensee's action on previous inspection findings. The inspection involvecM Mr.&'9m m d *p#nor RCJn-spectors.
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Results: No items of noncomplianc i
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ENCLOSURE 2 UNITED STATES NUCLEAR REGULATORY COMiISSION WASHINGTON, D. C.
20555 IE Bulletin No. 79-14
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Date: July 2, 1979 Page 1 of 3 SEISMIC ANALYSES FOR AS-8UILT SAFETY-RELATED PIPING SYSTEMS Description of Circumstances:
Recently two issues were identified which can cause seismic ana'.'ysis of safety-related piping systems to yield nonconservative results.
One issue involved algebraic summation of loads in some 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 this 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 design documents which could potentially affect the validity of seismic analyses.
Nonconformances are identified in Appendix A to this bulletin. Because 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 seismic 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 from which seismic analysis input information was obtained, the licensee must consider the need to re-evaluate the seismic analyses to con-sider the as-built configuracion.
Action to be taken by Licensees and Permit Holders:
All power reactor facility licensees and construction permit holders are requested to verify, unless verified to an equivalent degree within the last 12 mont:, that the seismic analysis applies to the actual configura-tion of safet.y related piping systems.
The safety related piping includes Seismic Category I systems as defined by Regulatory Guide 1.29, " Seismic LA itC 7 m%Mza6 S p.
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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 copfiguration 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: pipe 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; :.nd valvo 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 which can be entered during reactor operation.
o 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.
1 Within 120 days of the date of this bulletin, submit a description of the results of this inspection.
4.
If nonconformances are identified:
u 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 as-built conditions in plant, and describe measures which are in effect which provide assurance that future modifications of piping systems, including their supports, wil.1 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.
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Reports shall be submitted to the Regional Director with copies to the 3irector of the Office of Insnection and Enforcement and the Directer of the Division of Operating teactors, Office of Nuclear Reactor Regulation, Washington, D.C.
20555.
Approved by GAO (R0072); clearance expires 7/31/80. Approval was given under a blanket clearance specifically for generic problems.
APPENDIX A PLANTS WITH SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL DESIGN AND AS-BUILT CONDITION OF PIPING SYSTEMS Plant Difference Remarks Surry 1 Mislocated supports.
As built condition Wrong Support Type.
caused majority of pipe Different Pipe Run overstress problems, not Geometry.
algebraic summation.
Beave'r '! alley 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 shutdown to restore
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Snubcer pipe attachment original design condition.
welds and snubber support assembly nonconformances.
Brunswick 1 and 2 Pipe supports undersize.
Both units shutdown to restore original design condition.
Ginna Pipe supports not built Supports were repaired to original design.
during refueling outage.
St. Lucie Missing seismic supports.
Install corrected Supports on wrong piping, supports before start up from refueling.
t-Page 2 APPENDIX A Plant Difference Remarks Nine Mile Point Missing seismic supports.
Installed supports before startup from refueling.
Indian Point 3 Support location and Licensee performing as support construction built verification to be deviations.
completed by July 1.
Davis-Besse Gussets missing from main Supports would be over-Steam Line Supports.
stressed.
Repairs will be completed prior to start-up.
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SSINS: 6810 August IS,1979 Accession Ho:
7908080360 UNITED STATES NUCf. EAR REGULATORY CDP. MISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C.
20555 Supplement IE Bulletin No. 79-14 SEISMIC ANALYSIS FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS Discription of Circumstances:
e..
IE Eulletin No. 79-14 was-issuad on July 2,1979 and revised on July 18, 1979.
The bulletin requested licensees to take certain actions to verify that seismic analyses are applicable to as-built plants.
This supplement to the bulletin provides additional guidance and definition cf Action Itams 2, 3, ano 4.
To comply with the recuests,in IE Bulletin 79-14, it will be necessary for licensees to do the folicwing:
2.
Inso.ect Part of the Accessible Picing For each system selected by the licensee in accordance with Item 2 of the Bulletin, the licensee is expected to verify by physical inspection, to the extent practicable, that tne inscection alements meet the acceptanca criteria.
In performing these inspectons, the licensee is excected tc use measuring tecnnioves of sufficient accurscy to demonstrate that accootance criteria are met..
Where ins::ectic..
elements ie:ortant to the seismic analysis cannot be viewed becausa of thernal insulation or location of the piping, the licensee is excected to remove thermal insulation or provide access. Where physical ins::9: tion is not practicable, e.g., for valve weights and materials of construction, the-licanse is ex ected to verify conformance by inspecticn of cuality assurance records.
If a nonconformance is found, the licensee is ex::ected in accorcance witn Item 4 of the Bulletin to perform an evaluation of.tne significance of the nonconformance as rapidly as possible to determine whether or not the operability of the system mignt be jeopardi::ec curing a safe;shutdcwn earthquake as defined in the Regulations. This evaluaticn is expected to De done in two phases involving an initial engineering judgement (within 2 days), followed by an analytical engineering evaluation (within 30 days). Where either phase of the evaluation shows tnat synem operability is in jeopardy, the licensee is exoectea to meet tne applicable ~
technical specificatien action statement and comclete the inscectitns
-reccired by Item 2 anc 3 of the Bulletin as soon as possicle.
The licensee must report tne results of these inspections in accordance witn tha ee.uire-ments for content and schedule as given in Item 2 and 3 of the Builetin.
3.
Insnect Re.,aininc ?toi a l
The licensee is expecteo to inspect, as in Item 2 above. the remainiN safety-relatec piping systems wnich were seismically analyzed and :c re;crt -ne results in accordance wi.h the requiremer.ts for conten; an.,
scaedula
>3 gi een in ?.c. I of the su istin.
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1 Succicment IE Gulletin No. 79-14 Page 2 of 2 Aunust 15, 1979 JA.
Evaluate Noncemformances With regard to Item 3A for the Bulletin, the licensee is expected to include in the initial cagineering judgement his justification for continued reactor operation.
For the analytical engineering evaluation,
- the licensee is expected to perform the evaluation by using the same analytical technique used in the seismic analysis or by an alternate, less complex technique provided that the licensee can show that it is conservative.
If either part of the evaluation shows that tha system may not perform its inter.ded function during a design basis earthquake, the licensee must promptly comply with acplicable action statements anc reporting requirements in the Technical Specifications.
48.
Submit Noncenfonaance $ valuations The licensee is expected to sucmit evaluations of all noncenformances and, where the licensee concludes that tne seismic analysis may not be conservative, submit senedules for reanalysis in accordance with
' Item 4B of the Bulletin or correct the noncomformances.
4C.
Correct Nenconform nces If the licensee elects to correct noncenfermancas, the licensce is expected to sub. tit schedules anc work descriptions in accordance with Item AC of the Sulletin.
40.-
Imnreve Oualtiv Assurance If noncomformances are identified, tha licensee is expected to evaluate and improve cuality assurance procedures to assure that future modifica-tions are handled efficiently.
In accordance with Item 40 of the Bulletin.
'the ifcensee is expected to revise design d:cuments and seismic analyses in a timely canner.
The schedule for the action and reporting requirements given in the Bulletin as originally i::ued remains uncnanged.
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6820 Accession No.: 7003220100 UNITED STATES NUCLEAR REGULATORY CCfNISSION OFFICE OF It:5PECTION AND ENFORCEMENT WASHINGTON, D.C.
20555
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Scatamber 7, 1979 IE Bulletin No. 79-14 Supplement 2 SEISMIC ANALYIIS FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS Description of Circumstances:
IE Bulletin No. 79-14 was issued on July 2, revised on July 18, and first supplemented on August 15, 1979. The bulletin requested licensees to take certain actions to verify that seismic analyses are acolicable to as-built plants. Supplement 2 provides the following additional guidance with regard to implementation of the bulletin requirements:
Nonconformances One way of satisfying the requirements of the bulletin is to inspect safety-related piping systems against the specific revisions of drawings which were used t.s input to the seismic analysis.
Some architect engineers (A-E) however,l are. recommending that their custcmers inspect these systems against the latest revisions of the drawings and mark them as necessary to define the as-built configuration of the systems.
These drawings are then returned to the AE's offices for comparison by the analyst to the seismic analysis input.
For licensees taking this aoproach, the seismic analyst will be the person wno will identify nonconformances.
The first supplement to the bulletin provided guidance with regard to evaluation of nonconformances. That guidance is appropriate for licensees inspecting against later draings.
The licensee should assure that he is prceptly notified
-when the AE identifies a nonconformance, that the initial engineering judgment is completed in_ two days and that tne analytical engineering evaluation is completed in 30 days.
If either the engineering judgement or the analytical engineering - evaluation indicates that system operzbility is in jeopardy, the licensee is expected to meet the applicable technical specification action statement.
Visual Accroximations Some licensees are visually estimating pipe lengths and other inspection,
elecents, and have not cecumented which data have been obtainea in that way.
Visual estimation ~of dicensions is not eccouraged for most measurements; however, where visual estimates are used, the accuracy of estimation must be within toler-ance recuirements.
Further, in documenting the cata, the licensee must specif-ically identify those data that were visually estimated.
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o' IE Bulletin'Ho. 79-14, Supplement 2 September 7, 1979 Page 2 of 2 Thermal Insulation In many areas, thermal insulation interferes with inspection of pipe support details, f.e. attachment welds, saddles, support configuratter., etc.
In some areas, the presence of thermal insulation may result in unacceptably large uncertainties for date.rmination of the location of pipe supports.
Where thermal insulation obstructs inspection of support details, the insulation should be removed for inspection of a r.inimum of 10% of the obstructed pipe supports in both Item 2 and 3 inspections.
In the Item 3 response, the licensee should include a schedule for inspecting the remaining E
a supports.
Where necessary to determine the location of pipe supports to an accuracy within design tolerances, thernal insulation must be removed.
Clearances For exposed attachments and penetrations, licensees are expected to measure or estimata clearances between piping and supports, integral piping attachments (e.g. lugs and gussets) and supcorts, and* piping and penetrations.
Licensees are not expected to do any disassembly to measure clearancas.
Leose Bolts
~
loose anchor bolts are not covered by this bulletin, but are covered by IE Bulletin No. 79-02. Any loose' anchor bolts identified during actions taken for this culletin should be dispositioned under the requirements of Bulletin No. 79-02.
Other loose colts are to be treated as nonccnformancas if they invalidate the seismic analysis; hcwever, torquing of bolts is not requirec.
Difficult Access Areas where inspections are required by the Bulletin but are considered impractical even witn the reactor shutdown, should be addressed on a case by case basis.
Information concerning the burden of performing the inspection and the safety consequence of not performing the inspection should be documented by the licensee and forwarced for staff review.
Schedule
.The schedule for the action and reporting requirements given in the Bulle. tin as originally issued. remains unchanged.
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ENCLOSURE 3 PECO Report (June 13,1978) n 6
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PHILADELPHIA ELECTRIC COMPANY 23C1 MARKE7 57REE7 PHILA D ELPHI A.' PA.19101 (21sl e4.4 sCO v.s.sovsn
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sa.c Mr. R yce 0.rier, h ee.cr Cf'i:e of 2 spec.d_
and T. force =ent, Regi =
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' er:. t -scera._ s S.a-1 7:1.s 1 3: 2 Separa:1:n Gaps be-eeen C
.a1==e= and Rea.cr I::1:sure 2.0 C =s :: 1.0 :10: ?er=.- N:s. 1C6 and 1C7 Re'ere=es s (a) Tele ~ Reper. Of Defi:1e 07 frc= E. R. "4al.ars PECC.
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Se; ara:10: C-aps be-seen en-='- e= and Reac. : In:1:sure dated Feb:.:a.r7 16, 1978 Fi.la s q71L 2-1C-2 (SD. A )
near M:. c. eri 2 ::=;11acce w:.-2 1CC3?. ?ar: 3C.35(e ), we s. e hereby s '-- '
.d g -la a. ached 'inal reper
= -le subjec separa-1:n gap de'icie:07 Se
?*d =delphia Ilec ric Oc=;a=7 discussed -lis ite= by taleph: e (Reference a)
- -2 ~2e UIEC Regi:= 2 Offi:e Of 2specti:n and T '---
- e= : Ja=ary 17,
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af':ar 1 was detar-d ed -la: -lis =ay be a reper.able deficies:7 as de-ad by 1CCI?. Part 3C.55(s). 1:
- d..ar:.= re;cr: (Refere::e b)== -de subae -
as filed := Fe'ernary 16, 1973.
2 -2ere are a=7 questicas := -lis =anar, we werld be pleased.c discuss -Anc wi-2 7:u.
l Sincerely,
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NUCLEAR REGULATORY C0tHISSION PHILADELPHIA ELECTRIC COMPANY
)
Docket Nos. 50-352-(Limerick Nuclear Generating Station,
)
and 50-353 Units 1 and 2)
)
(!O CFR 2.206)
NOTICE OF ISSUANCE OF DIRECTCR'S DECISION UNDER 10 CFR 2.206 Sy letter dated April 12, 1979, Frank Romano of A cer, Pennsylvania, requested that the Commission investigate the effects of blasting at a nearby quarry on the site of the Philadelphia Electric Company's Limerick Nuclear Generating Station. Notice of receipt of Mr. Romano's April 12th letter was published in the Federal Register, 44 Fed. Reg. 33987 (June 13,1979).
In letters dated Nay 14 and June 12, 1979, Mr. Romano raised additional concerns regarding the Limerick facility and further requested that repair of concrete voids in structures be investigated.'
On review of the information presented by Mr. Romano, I have determined
-hat the effects'of blasting on the Limerick site should be conducted. Because
- aficiencies associated with concrete voids and their repair have been pre-viously investigated and resolved, I have'also determined that a further inves-tigation into this matter is not warranted at this time.
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e-A copy of-the decision in the matter will be placed in the Comission's Public Document Room at 1717 H Street, N. W., Washington, D. C.
20555 and in the local public document room for the Limerick Generating Station at the Potts-town Public Library, 500 High Street, Pottstown, Pennsylvania 19464.
FOR THE NUCLEAR REGULATURY COMMISSION,
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J. G. Case, Depu:/_01 rector 1ffice of Nuclear Reactor Regulation Dated at Bethesda, Maryland thf s 9th day of October 1979 a
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