ML20031F574
| ML20031F574 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/16/1981 |
| From: | Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Foster R, Kelley J, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| IEB-79-14, ISSUANCES-SP, NUDOCS 8110200163 | |
| Download: ML20031F574 (1) | |
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October 16, 19d1 James L. Kelley, Chairman Dr. Peter A. Norris Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. liuclear Regulatory Conaission U.S. lluclear Regulatory Commission Wdshington 0.C.
20555 Washington, D.C.
20555 DISTRIBUTION Dr. kichard F. Foster Goddard P.dainistrative Judge Reis P.O. Box 4263
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/ 'N tt, Shapar/Engel hardt Sunriver, Oregon 9770.1
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Chri stenbury/Scinto g\\# f[
Olmstead In the Matter of v
Ch iRC cket File: PDR/LPDR Dp 4j Connonwealth Edison Company c
(Quad Cities Station, Units 1 and 2) 6
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Docket lios. 50-254-SP and 50-265-SP g/
(Spent Fuel Pool Hodification s
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Dear Adainistrative Judges:
Enclosed for your information is I&E Bulletin 79-14 and two supplements thereto, wnich was discussed at the Special Prehearing Conference in relation to Intervenor's Proposed Contention 12.
Copies.f IlUREG-0675 will be served upon the Licensing Board and Intervenors as soon us copies can be obtained.
Sincerely, U
g5 Richard J. Goddard i
llff Counsel for flRC Staff
Enclosure:
As Stated cc:
(w/ enclosure)
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel Citizens for Safe Energy Quad-Cities Alliance for Older Americans for Elderly Safe Energy and Survival Rights Robert G. Fitzgibbons, Jr., Esq.
Docketing and Service Section
!!r. iiicholas J. C9rissotinos Mo /7 orrice p OELD fV
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.
20555 July 2, 1979 IE tulletin No. 79-14 I
SEISMIC ANALYSES FOR AS-BUILT S'AFETY-RELATED PIPING SYSTEMS Description of Circumstances:
Recently two issues were identified which can cause seismic analysis of safety-related piping systems to yield nonconservative results.
One issue involved algebraic sumation 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 ir 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 g
discovered and subsequently addressed in IE Bulletin 79-02 (pipe supports) and 79-04 (valve weights). During resolution of these concerns, inspection l
by IE and by licensees of the as-built configuration of several piping i
k systems revealed a number of nonconformances to design documents which could F
potentially affect the validity of seismic analyses.
Nonconformances are identified in Appendix A to this bulletin. Because apparently significant non-h 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
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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 configuration.
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l IE Bulletin No. 79-14 July 18, 1979 Revision 1 Page 2 of 3 Action to be taken by Licensees and Pemit Holders:
All power reactor facility licensees and construction permft holders are requested to verify, unless verified to an equivalent degree within the last 12 months, that the seismic' analysis applies to the actual configura-tion of safety-related piping systems. The safety related piping includes Seismic Category I systems.as defined by Regulatory Guide 1.29, " Seismic Design Classification" Revision 1, dated August 1,1973 or as defined in the applicable FSAR. The action items that follow apply to all safety related 4
oiping 21/2-inches in diameter and greater and to seismic Category I piping, regardless of size which was dynamically analyzed by computer. For older plants, where Seismic Category I requirements did not exist at the time of licensing, it must be shown that the actual configuration of tWid safety-related systems, utilizing piping 21/2 inches in diameter and greater, meets design requirements.
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 Itens 2 and 3. Submit all of this information within 30 days of the date of this bulletin.
j 2.
For portions of systems which are normally accessible *, inspect one system in each set of redundant systems and all nonredundant systems for con-l 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 attachements; 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.
l.
Normally accessible refers to those areas of the plant which can be entered during reactor operation.
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In accordance with Item 2, inspect all other normally accessible. safety-related systems and all nonnally inaccessible safety-related systems.
Within 120 days of the' date of this bulletin, submit a description of the results of this inspection.
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4.
If nonconfonnances are identified:
A.
Evaluate thc effect of the nonconformance upon sy'ste,m 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. Wbna vm' determine that reanalysis is necessary, submit your senedule for: (i) completing the reanalysis, (ii) comparisons of the results to FSAR
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or other NRC approved acceptance criteria and (iii) submitting descrip-tions of the results of reanalysis.
C.
In lieu of B, 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.
L 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, will be reflected in a timely manner in design documents and the seismic analysis.
Facilities holding a construction permit shall inspect safety-related 7;;.?jdi'-
systems in accordance with Items 2 and 3 and report the results within 120 days.
2 si s ce submitted to the fiegional Director with copies to the t
Director of the Office of Inspection and Enforcement and the Director of the Division of Operating Reactors, Office of Nuclear Reactor Regulation, Washington, D.C.
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Approved by GA0 (ROC 72); clearance expires 7/31/80. Approval was given
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under a blanket clearance specifically for generic problems.
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APPENDIX A PLANTS WITH SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL DESIGN AND AS-BUILT CONDITION OF PIPIf4G SYSTEMS l
Plant Difference Remarks
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m Surry 1 Mislocated supports.
As built condition Wrong Support Type.
caused majority of pipe Different Pipe Run overstress problems, not Geometry.
algebraic summation.
- at specifically identified.
As built condition resulted Beaver Valley 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 Snubber pipe attachment original design condition.
F welds and snubber support asca-b1v nonconfomances.
f Brunswick 1 and 2 Pipe supports undersize.
Both units shutdown to restore' original design condition.
Ginna Pipe supports not built Supports were repaired r
1 to original design.
during refueling outage.
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Install corrected Supports on wrong piping.
supports before start up fr - afueling.
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Plant Difference Remarks fiine Mile Point Missing seismic supports.
Installed supports before startup from refueling. ~
Indtan Point 3 Support location' and Lice'nsee performing as support construction built verification to be deviations.
completed by July 1.
Davis-Besse Gussets missing' from main Supports would be over-l Steam Line Supports.
stressed.
Repairs will be completed prior to start-up.
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6820 August 15, 1979 Accession No:
7908080360 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE 10F INSPECTION AND ENFORCEMENT WAS.11NGTON, D.C.
20555 Supplement IE Bulletin No. 79-14 l
SEISMIC ANALYSIS F0R AS-BUILT SA'ETY-RELATED PIPING SYSTEMS F
?lscription of Circumstances:
1 IE Bulletin No. 79-14 was. issued 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 of Action Items 2, 3, and 4.
To comply with..ie requests,in IE Bulletin 79-14, it will be necessary for licensees to do the following:
2.
Inspect Part of the Accessible Piping For each system selected by the licensee in accordr u with Item 2 of the Bulletin, the licensee is expected to veri 7y t. ' physical inspection, to the extent practicable, that the inspection elements meet the acceptance criteria.
In performing these inspt.ctons, the licensee is expected to use measuring techniques of sufficient accuracy to demonstrate that acceptance criteria are met.
Where inspection elements important to the seismic analysis cannot be viewed because of therrnal insulation or location of the piping, the licensee is expected to remove thermal insulation or provide access.
Where physical inspection is not practicable, e.g., for valve weights and materials of construction, the license is expected to verify conformance by inspection of quality assurance records.
If a nonconformance is found, the licensee is expected in accordance with Itera 4 of the Bulletin to perform an evaluation of the significance of.he nonconformance as rapidly as possible to determine whether or not the operability of the system might be jeopardized during a safe shutdown earthquake as defined in the Regulations.
This evaluation is expected to be done in two phases involving an initial engineering judgement (within 2 days), followed by an analytical eng naering evaluation (within 30 days).
Where either phase of the evaluation shows that system operability is in jeopardy, the licensee is expected to meet the applicable technical specification action statement and complete the inspections i
I required by Item 2 and 3 of the Bulletin as soon as possible.
The licensee must report the results of these inspections in accordance with the require-l ments for content and schedule as given in Item 2 and 3 of the Bulletin.
3.
Insoect Remaining Piping The licensee is expected to inspect, as in Item 2 above, the remaining safety-related piping systems which were seismically analyzed ane a report the results in accordance with the requirements for contera schedule as given in Item 3 of the Bulletin.
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Supplement IE Bulletin No. 79-14 Page 2 cf 2 August 15, 1979
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4A.
Evaluate Noncomformances With regard to Item 3A for the Bulletin, the licensee is expected to i
incluce in the initial engineering judgement his justification for l
continued reactor operation.
For the analytical engineering evaluation,
- the licensee is expected to perform.ne evaluation by using the same analytical technique used in the seismic analysis or by an alternate, l
less complex technique provided that the licensee can show that it j
is conservative.
If either part of the evaluation shows that the system may not perform its intended function during a design basis earthquake, the licensee must promptly comply with acplicable action statements and reporting requirements in the Technical Specifications.
48.
Submit Nonconformance $ valuations The licensee is expected to submit evaluations of all nonconformances and, where the licensee concludes that the seismic analysis may not be conservative, submit schedules for reanalysis in accordance with Item 48 of the Bulletin or correct the nonccmformances.
4C.
Correct Nonconformances If the licensee elects to correct nonconformances, the licensee is expected to submit schedules and work descriptions in accordance with Item 4C of the Bulletin.
40.- !.9orove Oualtiy Assurance If noncomformances are identified, the licensee is expected to evaluate and improve quality assurance procedures to assure that future modifica-tions are handled efficiently.
In accordance witn Item 40 of the Bulletin, the licensee is expected to revise design documents and seismic analyses in a timely nianner.
Tne schedule for the action and reporting requirements given in the Bulletin as originally issued remains unchanged.
SSINS:
6820 Accession No.: 7908220109 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 September 7, 1979 IE Bulletin No. 79-14 Supplement 2 SEISMIC ANALYSIS FOR AS-SUILT SAFETY-RELATED PIPING SYSTEMS Description of Circumstances:
IE Sulletin 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 applicable to as-built plants.
Supplement 2 provides the following additional guidance with regard to inplementation 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 as input to the seismic analysis.
Some architect-engineers (A-E) however, are recommending that their customers 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 approach, the seismic analyst will be the person who will identify nonconformances.
The first supplement to the bulletin orovided guidance with regard to evaluation of nonconformances.
That guidance is appropriate for licensees inspecting against later. drawings.
The licensee should assure that he is promptly notified when the AE identifies a nonconformance, that the initial engineering judgment is c:mpleted 'n two days and that the analytical engineering evaluation is completed in 30 days.
If either the engineering judgement or the analytical engineering evaluation indicates that system operability is in jeopardy, the licensee is expected to meet the applicable tecnnical specification action statement.
Visual Acoroximations Some licensees are visually estimating pipe lengths and other inspection,
elements, and have not documented which data have been obtained in that way.
Visual estimation of dimensions is not encouraged for most measurements; however, wPere visual estimates are used, the accuracy of estimation must be within toler-l ance requirements.
Further, in documenting the cata, the licensee must specif-ically identify those data that were visually estimated.
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- IE Bulletin No. 79-14, Supplement 2 Septemoer 7, 1979 Page 2 of 2 Thermal Insulation In many areas, thermal insulation interferes with inspection of pipe support details, i.e. attachment welds, saddles, support configuration, etc.
In some areas, the presence of thermal insulation may result'in unacceptably large uncertainties for determination of the location of pipe supports.
Where thermal insulation obstructs inspection of support details, the insulation should be removed for inspection of a minimum 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 supports.
Where necessary to determine the location of pipe supports to an accuracy within design tolerances, thermal insulation must be renoved.
Clearances For exposed attachments and penetrations, licensees are expected to measure or estimate clearances between piping and supports, integral piping attachments (e.g. lugs and gussets) and supports, and piping and penetrations.
Licensees are not expected to do any disassembly to measure clearances.
Loose 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 bulletin should be dispositioned under the requirements of Bulletin No. 79-02.
Other loose bolts are to be treated as nonconformances if they invalidate the seismic analysis; however, torquing of bolts is not required.
Difficult Access Areas where inspections are required by the Bulletin but are considered impractical even with 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 forwarded 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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