ML20126K033

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Responds to 800501 Unsolicited Proposal to Identify Interferences in safety-related Piping Sys.Analysis Would Help Determine Adequacy of Util Responses to IE Bulletin 79-14.Requests Info Re Specific Response Deficiencies
ML20126K033
Person / Time
Issue date: 03/17/1981
From: Stello V
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Mitchell S
COMPUTERIZED INTERFERENCE ELIMINATION, INC.
Shared Package
ML20126K036 List:
References
FOIA-85-301 IEB-79-14, NUDOCS 8105080355
Download: ML20126K033 (2)


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i Mr. Schuyler R. Mitchell, President j Computerized Interference Elimination Inc.

14230 N.E. 8th Street Bellevue, Washington 98007 i

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Dear I r. Mitchell:

As a result of inspections by the Nuclear Regulatory Commission and by some

licensees, several piping nonconformances were discovered in late 1978 and j i

early 1979 which potentially affected the validity of seismic analyses for  !

some nuclear power plants. As you know, the Office of Inspection and

Enforcement subsequently issued Bulletin 79-14 in July,1979. This bulletin required licensees to verify the as-built configuration of their safety-related piping systems and to compare the verified piping configuration to the configur-ation assumeQthe scismic analyses for these systems. Where significant i differences cr4 found, licensees ucre required to redo those analyses and to  ;

1 modify the systems, if necessary, to meet design criteria. This effort is essentially complete for operating plants.

t In an unsolicited proposal from your company, dated May 1,1980, and in prior -

and subsequent discussions with me and my staff, your company's capability i to identify interferences in piping systems was descr.f bed. Interferences are identified by reviewing design drawings and inputing into computer memory a i mathematical description of the boundaries of the space being examined and the i configurations of the systcas and structures contained in the space. The computer then identifies any portions of systems or structures that occupy the

sanc volume as indicated by the drawings.

f In discussions with us, you suggested that application of an interference analysis to a selected space at an operating reactor would be helpful in detennining the adequacy of the licensees' responses to Bulletin 79-14.

It is our evaluation that identification of interferences from drawings at j completed facilities for which the as-built piping systems have been compared

! to the seismic analysis and those activities audited by NRC' inspections would l not offer a significant benefit. Since the Bulletin 79-14 did not require verification of as-built drawings of other components which would be involved in an interference analysis such review would likely identify " drawing inter-

! ferences" which have no potential effect on the seismic analysis. Performing an interference analysis would not benefit the health and safety of the public, would impose a substantial burden on the licensee selected, and would i

result in an unnecessary expenditure of NRC resources. Therefore, we must reject your proposal, f M

It is our view the interference analysis technique ased by your company and others could be more beneficially applied by utilities which have faciHHan

in the design and early construction phasesy

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!:r. Schuyler R. llitchell 2 MAR 171981 On February 3.1981, during our meeting with you and your associate, you expressed your concern that the verification by some licensees of the as-built configuration of safety-related piping systems had not been perfomed with sufficient precision to meet the intent of the bulletin. If you do have specific infomation indicating that specific licensees have been deficient in responding to Bulletin 79-14 that infomation would be helpful to us in protecting the health and safety of the public. For that reason, we request that you identify those licensees whose performance, in your view, has been deficient and that you describe the nature of those deficiencies to the extent of your knowledge.

We thank you for your cooperation in this regard.

Sincerely,

, ' Original Signed By, R. C. DeYoung' ,

Victor Stello, Jr.

Director Office of Inspection and Enforconent l

bcc: J. H. Snfezek, IE E. L. Jordan, IE R. W. Woodruff, IE H. J. Wong, IE SEE PREVIOUS YELLOW

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