ML20062J910

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Forwards Revision 2 to Util 791101 Response to IE Bulletin 79-14,Revision 1,Suppl 2, Seismic Analysis for As-Built Safety-Related Piping Sys. Design & Erection of Unit 2 Progressed to Near Completion W/Program Similar to Unit 1
ML20062J910
Person / Time
Site: McGuire, Mcguire  
Issue date: 08/05/1982
From: Tucker H
DUKE POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
REF-SSINS-6820 IEB-79-14, NUDOCS 8208160499
Download: ML20062J910 (9)


Text

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Duxu POWER CWWANY

. '[N C O p. e y STEAM PRODUCTION DEI'T.

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GENE 2tAL OFFICES TELEPHONE; AREA 704 P.o,mox sates 422 SOUTH CHURCH STREET 373 4ott CHAltLO'ITE, N. C. 28242 32 4[]C ll Aj0 0I August 5, 1982 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:JPO McGuire Nuclear Station Docket Nos. 50-369 and 50-370 IE Bulletin 79-14, Revision 1, Supplement 2

Dear Mr. O'Reilly:

r Attached is Revision 2 of Duke Power Company's response to IE Bulletin 79-14, Revision 1, Supplement 2.

The purpose of this Revision is to update the status of McGuire Unit 2, and to bring this item to the point where it can be formally closed. Note that the Revision involves only pages six and seven which are new pages.

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Should you have any questions regarding this information, please advise.

Very truly yours, f

d II. B. Tucker i

Vice President Nuclear Production PBN:ls Attachment cc: Director Mr. P. R. Bemis Division of Reactor Operations Inspection Senior Resident Inspector-NRC Office of Inspection and Enforcement McGuire Nuclear Station U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Director Division of Operating Reactors Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.-

20555 8200160499 820805 PDR ADOCK 05000369

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DUKE POWER O W PANY MCGUIIE NUCLEAR STATION IESPONSE 'IO USNRC I & E BULIEFIN 79-14 1

IEB

REFERENCE:

IEB 79-14 Revision 1 Suppleent 2

RESPONSE

REFERENCE:

Original Issue - 11/01/79 Revision 1

.01/27/81 Revision 2

- 08/05/82 e

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Page 1 s

Duke Power Company.

McGuire Nuclear Station

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Response To IE Bulletin 79-14, Revision 1, Supplemnt 2 PART I Described herein is the program for McGuire Nuclear Station which Duke Power Carpany has developcd to provide assurance that design documents which provide input to seismic analyses for safety-related systems reflect the as-built condition of these systers. This response describes those elements which are inportant in verifying the conformance between design documents and the as-built condition as well as details of the inspection program utilized to assure con-fornunce.

The following inspection elanents are im;nrtant:

1.

Pipe run gearetry.

2.

Pipe support and restraint design, including pipe support type, location, function, and clearance for seismic pipe supports.

3.

Pipe support attachment to erbedment.

4.

Pipe attachments.

3 5.

Valve and valve operator identification, location, orientation, center of gravity, and weight.

6.

Orifice flanges and other line flanges.

These inspection elements are covered under an on-going, integral part of the construction program for McGuire Unit 1.

IMtailed description of this program is provided in PART II.

Much of this program is applied during the normal course of McGuire 1 erection, and portions or our inspection program have occurred nore than 12 nonths prior to issue of IE Bulletin 79-14. Caupletion of this inspection program will not occur until near the end of Unit 1 construction which is more than 120 days after the date of this bulletin. tbnconformances are resolved in the nontal course of construction ard of conpleting the inspection program.

Our review of the inspection methods and practices described in PART II confinrs that all elanents of our inspection program completed previously ranain valid.

We are continuing, therefore, with tha program underway and described herein to calplete inspection of safety-related systans and sinultaneously satisfy the requirarents to IE Bulletin 79-14.

A final review of drawings for cquipnent, pipe layout, ard pipe support location is performed for safety-related systems to assure that engineering ard design incorporate the current drawing information. Ibnconformances between design documents and the as-built configuration are considered in this review, and piping systen seismic analyses are revised where appropriate.

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7-Page 2

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Erection of McGuire Unit 2 systems has not progressed to the point that significant ccnpariscns betxecn design docununts and as-built configuration are possible. At the appropriate tine this comparison will be achieved by a program almoct identical to that for Unit 1.

hhile early Unit 2 inspecticns are camencing, carpleticn of this program will be later in the Unit 2 ccnstructicn period.

The described insruction program provides assurance that design documnts reflect the as-built ccnditicns. The nonnal nethods of work control provide assurance that engineering groups performing seismic analyses review design documnts which define the as-built configuraticn to evaluate effect cn seismic input assumpticns. At the ccnpleticn of construction and the inspection pro-gram, we will have achiewd agreement between design docununts (and, conse-quently, seismic analyses) and the as-built conditicn.

PAIC II Duke Poacr Ccnpany has reviewed inspectial nothcds and practices which have been used and are in continuing use in the ecnstruction of McGuire Units 1 and 2.

These inspections are satisfactory, both in present and past use, and provide a high degree of assurance that any deviations frcra design documents will be identified. All identified deviations are either corrected or an evaluaticn is performd by the appropriate engineering group to provide the basis for accepting the deviation and revising the design document. Details of the inspecticn program are sumnurized below.

1.

Pipe run geatetry and ccnfiguration inspections are perfornnd in accordance with QA Procedure M-8.

7his inspecticn includes verifying the general configuratica and that there are no abnor-ml dips, bends, or distorticns. Pipe run gecnetry is determined through visual estimaticn of dimensions with an accuracy of + 6 inches. The piping locaticn is determined by checking elevation changes, verifying that pipe passes through proper cpenings, check-ing branch ccnnecticn locations, and visually verifying arrangenent.

7he pipe support review described in paragraph 2 belcw provides additicnal verificatial of proper piping configuratici.

2.

In June 1979, Duke initiated a program to review each of approx-imtely 14,000 pipe supports of Unit 1 safety-related piping.

This review covers all aspects of desigt including: pipe support type, locaticn, critical dimensiais (including clearances), nember f

sizes, pipe attachnunts, welding, base plate, and ccncreto expansion j

anchors. Pipe support locaticn and dinensions are determined by j

actual measurement. Clearances between piping and support and between l

integral piping attachnunts and supports are nuasured. Clearances between piping and penetraticna are visually estimated. Thenral l

insulaticn is removed to facilitate inspection of all pipe support details. Nonconformances are evaluated and justified by appropriate engineering review and/or analyses as required.

Icose ccncrete expansicn anchor bolts in pipe supports have been corrected as part of the program described herein. Duke will perform nMiticnal testing and inspecticn of self-drilling, shell-type expansicn anchors for pipe supports in accordance with our respcnse to IE Bul-letin 79-02.

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Page 3 A snull number of pipe supports cannot be inspected under the program described in paragraph 2 above because of inac ssibility.

In each such case, the pipe support drawing is nurked as inaccessible.

Failure to review these pipe supports is ac ptable in view of the relatively small number of inac ssible areas; the relatively low probability of a problem with an inacmssible pipe support or part of a pipe support; and earlier pipe support inspecticn during erecticn.

Final detenninaticn of inaccessible support / restraints has been conpleted for FcGuire Unit 1.

Wese support / restraints were inacces-sible for detailed inspecticn as required by the Ibinspecticn Program (started June 1979). All of these support / restraints have been previ-ously inspected and, under the current program, the general ecnfigura-tim, materials, and locaticn have been verified. Table I provides a 1

sunmary of the nunber of support / restraints by system, the reascn for inaccessibility, and notaticn of any supporting informaticn and evalua-ticns sin the original inspecticn. Table II provides a listing of the individual supports / restraints.

The result of this review is a copy of the pipe support drawings, marked as ne ssary to docunent the as-built ccnditicn. 'Ihe as-built pipe support locaticn data are provided to the appropriate engineering groups for evaluaticn of any @ysical changes cn the piping seismic analyses.

A similiar review will be perforned for pipe supports cn Unit 2 safety-related piping as part of the pipe support erecticn process.

3.

The attachnunt of pipe supports to embedments is surified during tha pipe support review described in paragraph 2 abcVe.

4.

Any welded pipe attachnunts are inspected for prcper material and size in accordance with QA Procedures M-4 for Duke Class A, B, and C piping (AS>E III, Class 1, 2, and 3) and M49 for Duke Class F piping. In,dditicn, nozzle reinforcerents are inspected for size, thickness, and length through QA Procedure M-8.

5.

Valves are inspected to verify through valve identificaticn tags that the correct valve is installed, that it has the correct type of oper-ator, and that it is located properly in relaticn to the piping lay-out through QA Procedure M-8.

'Ihe weights and centers of gravity for valves and valve operators are available frczn equipment drawings.

Valve and valve operator are related to the apprcpriate drawings through the valve identificaticn tags.

6.

orifiw flanges and in-line ficw nozzles are inspected for correct ecn-figuraticn and locaticn within the piping system through CA Procedure M-8.

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TABIE I

.4 tmnpr (MIT 1 SimAFY OF TMAOCissimr St1NWrP/RFSTPAltTIS tn.

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SYS7tN DWE CIASS S/R IOCATIOJ INNTFSSTDIT PTA4W MtUCS 13 wreLiquid Waste Becycle Class P In the Pipr Trmch Physically Inaccessible 17 AS-Auxiliary Steam Class F In the Pipe Trench Physically Iruccessible 30 DD-St. Gmerator Blowdown Class F In the Pipe Trench Physically Inaccessible 12 CA-Auxiliary Fea1 water Class F In the Pipe Trmch Physically Inaccessible 2

rn-Boeirculatiry (bolirg Class F In the Pipe Trench Physically Iruccessible unter 2

t:I-Safety Injection Class B In the Pipe case Physically Iruccessible 1

IW-Refueliin mter Class B In Missile Shield Wall Physically Inaccessible 1

2 WZ-GrourL%ater Drainage Class F In the Pipe Trench Physically Inaccessible 1

tv-Onnicalswl. (br. trol Class C Dehind a Support ard Shield Physically Inaccessible Ctrer 1

ta3 - Doron Recycle Class C Dehird Other Support ard Physically Iruccessible Piping 2

KF-Spent Fuel (boling Class C In Spent niel Area High risk of contaminating the Cencral ocnfiguration and location f

storm fuel ard the pool area.

were found to be adcquate frm 20 to 30 feet observation point.

In DG Rxrn Oil Sep

'It S/R's are below the suppmp. General configuration ard location 2

W-DG Run Strp hmp Class F

+

Inspection of the S/R's would were fou:d to be Mcquate frm about reouire rmoval of the pmp or S feet observation point.

drainage of a large amount of oil.

12 IN-Cbntairment Vent.

Class F In Waste Shi ming Area Inspection of the S/R's would ramal configuration anl location Cooling renuire building of a large aunt were found to be Mcquate frcra about of scaffolding ard isolation of 20 feet observation point.

crane power.

102 IS-Cbntairrent spray Class B In Reactor Building Dmo Inspection of the S/R's would Gmeral configuration ard location require building of large arount were fourd to be adcquate from 20 to of scaffolding or use of "scissora 25 feet observation point. Welds platform" on top cf polar crane from base to S N and pipe attac! vent with concern for personnel safety, welds are docunented.

4 KF-Spet Ibel Cbolirn Class C In the Spent niel Canal Craf t work is reglired per the y

latest sketch revision but area D)

, is sccured from Cbnstruction j

Steam Production is res-gaccess.

a ponsible for acccrplistrnent of this revision. Wrk will be accam-piished aftcr cmpleticn of fuel loading.

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TABIE II nxmRs tutT 1 usrns or nac&ssImz steronr/RFSTRAPMS SYSIDt MA'DI PCDEL IWKER 70.

h1 WL.09 K-1683-wL.09-ROM thru R019 M>-1683-WL.16-R016 AS SAA DG-AS-H174 thru,176 ITA-AS-H355 thru 357 ASF DG-AS-H364 thru 369 SAA l!CS-AS-H044 t!ru 46 1MS-AS-H320 1M3-AS-H354 BB BEM IfG-BB-H124 thru 130 BB4 DG-BB-H135 thru 141 BBK DG-BB-H146 thru 152 1

BBL 1.'G-BB-H157 thru 163 BIN IM%-BB-H274 thru 275 CA CAI DG-G-H257 thru 262 4

1MA-CA-H268 thru 273 KR KR-302 DG-KR-2002 KR-301 DG-KR-2003 -

NI 1311/12 DCR-NI-0708 nil 3 DCR-NI-0894 IW IED DCY-fW-I!193 k7.

WZ.02 E-1683-WZ.02-R020 K-1683-WZ.02-R058 IN NtG ht%-NV-5641 NB NB.04 K-1683-tm.04-R059 e

2.05 E-1683-Kr.05-R001 thru R002 j

M4 MC 1M%-NN-H040 NNB DG-WN-H041 RV RVD DCA-W-H062 thru H066 1M2-W-H068 RVF IMA-W-H73 DG-RV-H75 thru H79 NS NS-01 DCR-NS-0517 thru 0529 NS-02 IK R-NS-0567 thru 0587 l

NS-03 IKR-NS-0617 thru 0633 NS-04 DCR-NS-0666 thru 0678

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NS-05 DER-NS-0716 thru 0736 t

NS-06 DCR-NS-0768 thru 0784 EF IIF-001.1 DCA-E-1060 thru 1063 I

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Page 6 PART II (Continted)

This section is to provide an update on Unit 2 activities relatcxl to IE Bulletin 79-14 since the previous response.

Bulletin activities applicable to McGuire Unit I were c2npleted during design and erection, and the item was closed in NRC I.E. Inspection Report 50-369/81-25.

Design and erection of McGuire Unit 2 have progressed to a high degree of empletion. Consistency between design docunents and as-built configuration has been achieved by a program substantially similar to that for Unit 1, with the following differences:

1.

Pipo cpcmetry and configuration inspections as described for i

Unit 1 in Part II, paragraph 1, are slightly different in Unit 2 as described in OA procedure M-8.

This inspection includes verifying dinensions on the layout drawings within 3" per tolerance drawing MC 2676-5. In addition, any abnomal dips, bends, or distortions are identified in such a manner that responuible engineering personnel can evaluate any impact on the analysis. Piping location is verified by measuring pipe dimension (elevations, turns, location of cmponents, etc.),

i verifying that piping passes through the proper openings, and l

ncasuring branch connection locations.

l 2.

A reinspection program as described for Unit 1 in Part II, paragraph 2, was not perforned for Unit 2.

As part of the reinspection of Unit 1, a revised QA procedure (M-15) was developed to assure a fully satisfactory inspection. This procedure was used for the reinspection of all Unit 1 pipe supports. Then, as part of the normal crection sequence all GA condition pipe supports in Unit 2 were inspected with this procedure. Although the term " reinspection" was not applied to Unit 2, any pipe support inpsection dated prior to the issuance of the revised procedure was inspected again using this procedure.

3.

Pipe support location inspections are, performed such that dimensions relative to pipe fittings or cmponents along the axis of the pipe are used, rather than building coordinates.

4.

Unit 2 had full benefit of improvcnents in crection including a) the issue of Construction Procedure #36 which provided simplified instruction based on erection requirements in Specification NCS-1206.00-04-0000, b) cxtensive training of craft, technical support, and QC personnel, and C) formation of a full time on-site Design Ehgineering group to resolve pipe support problems or answer questions arising frm erection QC.

Fevision 2 (New) w

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Page 7 5.

'Ihere are no thit 2 pipe supports that were inaccessible at the tire routine inspection was performed.

Ganges to, or deviations frcm design documents have been handled on thit 2 through the nornal work control procedures. 'Ihe result is assurance of a high degree of congruence between the as-built condition and the design <h ents on which the thernal and seismic analyses are based, thereby cmplying with I & E Bulletin 79-14.

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Revision 2 (New)

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