ML20126K037
| ML20126K037 | |
| Person / Time | |
|---|---|
| Issue date: | 02/24/1981 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Raisden L NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20126K036 | List: |
| References | |
| FOIA-85-301 IEB-79-14, NUDOCS 8105080357 | |
| Download: ML20126K037 (3) | |
Text
i l-
[p arg o,,
UNITED STATES p,
NUCLEAR REGULATORY COMMISSION g
ir WASHINGTON, D. C 20555
\\
/
~
SSINS #9440 FEB R41981 NOTE TO:
evi Baisden, ADM LETTER TO SCHUYLER MITCHELL I have enclosed the correspondence which we discussed by telephone on February 19.
The letter frcm Mitchell to Woodruff is an unsolicited proposal for computer services.
Per Woodruff's discussions with Bob LaGrange, we understand that the services offered are neither innovative nor unique. On this basis, we believe that NRC Manual Chapter 5102 is not applicable.
We have drafted an initial response to Mitchell for Stello's signature which indicates that the proposal is under review. Because Mitchell stated in a meeting with us that he believes that some licensees are not properly responding to IE Bulletin 79-14, the draft letter requests that he report any specific deficiencies that he may be aware of. We plan to se.nd a second letter to him when our review is completed.
1 l/
g%t' e j
e Ed Jord n, IE
Enclosures:
1.
Ltr, Mitchell to Woodruff dated May 1,1980 2.
Draft Ltr, Stello to Mitchell cc:
J. H. Sniezek, IE R. G. LaGrange, NRR J. P. Murray, ELD H. J. Wong, IE s
CONTACT: [W. Woodruff, IE
[
49-28180 q _Ld5d7d357 M
J M-r v
s.
~
d3 1
DISTRIBUTION
.u k 0
\\
IE Files M~
3 IE Rdg Files 33Ig;3 gg440 gg
%(
y RWWoodruff Rdg Files T
RRRI Rdg Files t r;.
4.,
REB Rdg Files
?i o
u '
4 0 5 Mr. Schuyler R. ?!itchell, President TC C,
Computerf 2ed Interference Elimination, Inc.
C t.'(
14230 N.E. Sth Street
.. J 7
?
e Bellevue, Washington 93007
'1 h
1.4
-j
]
Dear Mr. Mitchell:
c-3 As a result of inspections by the Nuclear Regulatory Commission and by some
.d t.
p licensees, several piping nonconformances were discovered in late 1978 and yd 7
carly 1979 which potentially affected the validity of seismic analyses for
'y u
d some nuclear power plants. As you know, the Office of Inspection and Enforcement O:
5 3
subsequently issued Bulletin 79-14 in July,1979. This bulletin required 54.
N licensees to verify the as-built configuration of their safety-related piping f.I i
4 systems and to compare the verified piping configuration to the configuration assumed in the seismic analyses for these systems. Wher,e significant differences v
j 3
were found, licensees were required to redo th'e' analys.f r and to modify the 1<
systems, if necessary, to meet design criteria ^. This effort is essentially A
y 9
complete for operating plants.
T2 s
I, eb d' T In an unsolicited proposal from your company, dated l'.ay 1,1980, and in prior S,
3 and subsequent discussions with me and my staff, your company's capability
- . c.
to identify interferences in piping systems was described.
Interferences
,, s T
are identified by reviewing design drawings and inputing into computer memory n
a mathcaatical description of the boundaries of the space being examined 1 ;-
L Y
t) and the configurations of the systems and structures contained in the space, o !J Y
C The computer then identifies any portions of systems or structures that occupy
.C.Y
{
j the same volume as indicated by the drawings.
m
,.v 5
- o. screc.ted f - cu eT-3 3
In discussions with us, you have advanced the notio that application of an 37,
.J interference analysis t 75,000 -cubic feet of space at ee-operating reactor 2 g
(!
v.ould be helpful in determining the adequacy of licensee'sl responseg to Bulletin j oj t
y 79-14 We have the merits of your proposal under active review.
c.,,'.,:
we y
-j On February 3,1981, during our meeting with you and your associate, you 3{
r expressed your concern that the verification by some licensees of the as-built {i
", L-N B
configuration of safety-related piping systems had not been performed with t
s
+ sufficient precision to meet the intent of the bulletin.
I wish to reiterate $
u?
that,off yau-have= spec 4fie--knodedge~ef-inadequate =perfon..a~e-Ly eny44censtre 3
4 N in-tMs-regardet-any :pecif4glantr Part 21 of Title 10 of the Code of M
)
.mppedeJ briew.i. requires the-t--youTuloit# written A' j. [
R Federal Reg ~ulations ::
(
eroFtsto this of7EoY Part 21.21 offitle 10 defines the information that
-T M
f
%- - ~~TUsT be includeTin such reports.
Fai h rc tc-repori. un resuh in significant
-pcaaltics, f<,If you need assistance in preparing such a report, please contact
. --, 4 my s ta f f.
j i
i "4
...l.
.b
""4...
c e t V..............
i ene resv un.ic sesoccu emo O I f*l c i A l R I"" c o R n E f"112 V
^
r
~
~-
e y-1 ltr. Schuyler R. Mitchell 2
lie share and appreciate your concern for the safety of nuclear power, and we expect to complete our review of your proposal in the near future. Ile will infom you of our decision.
Sincerely, Victor Stello, Jr.
Director Office of Inspection and Enforcement bec:
J. H. Snfezek, IE E. L. Jordan, IE R. W. Woodruff, IE H. J. Wong, IE omery I E : R E Bg...f.........I E : RRR I : D
.....I.E..: D D..
l I E..:.D.....
........s.
" " > RWWq pj r,u,f,f,,: p,km,,,, @ S n,1,e z e k,,,R.C Qe Yo.yn g...
,,V S.t.e U p.....
c " < > !..../. c/. A l........
....... 9 /...../. 01....
.....y...../..A l..........?./..../.81......
- 9
.. c scnu m oc soisacu o24o OFFICIAL RECORD COPY
^ '5 x 'no-n
r-t
'o SSINS /!9440 Mr. Schuyler R. Mitchell, President Computerized Interference Elimination, Inc.
L4230 N.E.
th Street Bellevue, Washington 98007
Dear Mr. Mitchell:
As a result of inspections by-the Nuclear Regulatory Commission and by some Licensees, several piping nonconformances were discovered in late 1978 and 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 configuration assumed in the seismic analyses for these systems. Where significant differences were found, licensees were required to redo those analyses and to modify the systems, if necessary, to meet design criteria.
This effort is essentially complete for operating plants.
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 to identify interferences in piping systems was described.
Interferences are identified by reviewing design drawings and inputing into computer memory a mathematical description of the boundaries of the space being examined and the configurations of the systems and structures contained in tHe space.
(
e be Mr. Schuyler R. Mitchell 2
(
The computer then identifies any portions of systems or structures that occupy the same volume as indicated by the drawings.
I, In discussions with us, you have advanced the notion that application of an interference analysis to a selected space at an operating reactor would be helpful in determining the adequacy of the Licensee's response to Bulletin 79-14. We have the merits of your proposal under review.
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 performed with sufficient precision to meet the intent of the bulletin.
Because of our concern with regard to the validity of seismic analyses for. nuclear plants, we asked that you identify those Licensees whose performance, in your view, has been inadequate. You stated that you were not at Liberty to make that information available to us; however, you also indicated that your company is not qualified to perform or evaluate seismic analyses. Nevertheless, if you do have specific information indicating that specific Licensees have been deficient in responding to Bulletin 79-14, that information could be helpful to us in protecting the health and safety of the public. We wish to reiterate in this regard that your knowledge of defects may subject you to Section 206 of the Energy Reorganization Act and to Part 21 of Title 10 of the Code of Federal Regulations.
9 L
b 4
Mr. Schuyler R. MitcheLL 3
We expect to complete our review of your proposal in the near future, at which time we wiLL inform you of our decision.
i Sincerely, 1
Victor Stello, Jr.
Director Office of Inspection and Enforcement i
bec:
J. H. Sniezek, IE E. L. Jordan, IE R. W. Woodruff, IE H. J. Wong, IE concur:
IE: REB IE:RRRI:DD IE:RRRI:D IE:DD IE:D P
RWWoodruff ELJordan JHSniezek RCDeYoung VStello 2/ /81 2/ /81 2/ /81 2/ /81 2/ /81 e
e e'
e.
/ pater
'o UNITED STATES
~,,
'[ '5 s.,
g NUCLEAR REGULATORY COMMISSION g
.t WASHING TON, D. C. 20655
\\,*****/
SSINS #9440 FEB A41981 NOTE TO:, Levi Baisden ADM LETTER TO SCHUYLER MITCHELL I have enclosed the correspondence which we discussed by telephone on February 19.
The letter from Mitchell to Woodruff is an unsolicited proposal for computer services.
Per Woodruff's discussions with Bob LaGrange, we understand that the services offered are neither innovative nor unique. On this basis, we believe that NRC Manual Chapter 5102 is not applicable.
We have drafted an initial response to Mitchell for Stello's signature which indicates that the proposal is under review. Because Mitchell stated in a meeting with us that he believes that some licensees are not properly responding to IE Bulletin 79-14, the draft letter requests that he report any specific deficiencies that he may be aware of. We plan to send a second letter to him when our review is completed.
g:.
Ed Jord n. IE -
Enclosures:
1.
Ltr, Mitchell to Woodruff dated May 1,1980 2.
Draft Ltr, Stello to Mitchell cc:
J. H. Sniezek, IE R. G. LaGrange, NRR J. P. Murray, ELD H. J. Wong, IE CONTACT:
R. W. Woodruff, IE 49-28180
w
~
COMPUTERIZED INTE ER CE ELIMINATION. INC.
HINC oN 98007 0 PHONE 206 747- 0222 14230 - N.E. 8" STREET a BELLEV %. WAS d
r '
May 1, 1980 Mr. Ro' er Woodruff g
Nuclear Regulatory Comission Office of Inspection and Enforcement Washington D. C. 20555 Sub,1ect:
Proposal for Interference Demonstration
Dear Mr. Woodruff:
Enclosed please find a typical CIE interference demonstration proposal.
If you have any questions please give me a call.
I hope to be in the -
-Washington D. C. area about June 15, 1980. Maybe at that time we could get together and answer any questions.
Sincerely yours, V.
Schuy r R. Mitchell President SRM:lo enc 1.
9 O
L m
2
!~
~:-
1 1.
The subject of this. interference demonstration is 50,000 to 75,000 cubic feet of the Containment Area or Auxiliary Building on any Nuclear Power Plant.
The actual area to be demonstrated on will be selected at a later date by the NRC.
Work bhall commence upon rece4pt of drawings and shall be-concluded in 2.
approximately 30 days after receipt of all drawings (assuming all drawings are timely received).
3.
The NRC will furnish to CIE reproducible drawings (Sepia recomended in lieu of Mylar) of the area to be studied.
These drawings shall clearly depict the necessary X Y and Z coordinates, location from column lines and sizes of the systems.
The NRC will also furnish any additional engineering or vendor infomation as may be required.
4.
CIE shall furnish its own materials, working space, requisite labor, l
including all key-punching and the needed computer time, all as required for the usage of CIE's Decider procedure.
5.
CIE, using its Decider procedure, shall make a complete interference analysis of the subject space (system to sys, tem and system to structure).
l Each interference detected by this procedrue shall be depicted by a sketch showing the interference and included on the sketch shall be all pertinent dimensional information.
6.
CIE, Inc, does not hold itself out as a qualified engineering fim.
It assumes no responsibility whatsoever for any e.ngineering decisions or evaluations.
CIE's function and responsibility is limited to the detemination of space availability for the systems as established by the Working Drawings.
l Although CIE's interference procedure results in virtual 100% detection of interferences, CIE specifically does not guarantee that each and every interference has, in fact, been detected and assumes no responsibility and
, disclaims any liability for any such interference as may in fact develop at the time of construction.
CIE specifically disclaims any responsibility for assuring compliance with the specifications or designs of the project.
Where dimensions are not included on the drawings and CIE has had to derive dimension information by scaling, the scaling shall be done to the best of CIE's ability, but CIE shall not be responsible for dimensions if these exact dimensions are not ascertainable from the scaling procedure.
7.
CIE's charge to the NRC for'this demonstration will be a fixed fee of l
$8,500.00, for work in the Auxiliary Building or $9,500.00 for work in the i
Containment Building, with tems of net 30 days.
l 8.
This proposal contemplates that CIE will make a "one-time-through"
{
interference analysis.
L
6 SSINS #9440 Mr. Schuyler R. MitcheLL, President Computerized Interference Elimination, Inc.
L4230 N.E. 8th Street Bellevue,. Washington 98007
Dear Mr. Mitchell:
As a result of inspections by the Nuclear Regulatory Commission and by some Licensees, several piping nonconformances were discovered in late 1978 and 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 pioing configuration to the configuration assumed in the seismic analyses for these systems. Where significant differences were found, licensees were required to redo those analyses and to modify the systems, if necessary, to meet design criteria. This effort is essentially complete for operating plants.
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 to identify interferences in piping systems was described.
Interferences ere identified by reviewing design drawings and inputing into computer memory a mathematical description of the boundaries of the space being examined and the configurations of the systems and structures contained in the space.
}
c Mr. Schuyler R. MitcheLL 2
4y4' The computer then identifies any portions of systems or structures that occupy the same volume as indicated by the drawings.
In discussions with us, you have advanced the notion that application of an interference analysis to a selected space at an operating reactor would be helpful in determining the adequacy of the licensee's response to Bulletin 79-14. We have the merits of your proposal under review.
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 performed with sufficient precision to meet the intent of the bulletin. Because of our concern with regard to the validity of seismic analys,es for nuclear plants, we asked that you identify those Licensees whose performance, in your view, has been inadequate. You stated that you were not at Liberty to make that information available to us; however, you also indicated that your company is not qualified to perform or evaluate seismic analysec. Nevertheless, if you do have specific information indicating that specific Licensees have been deficient in responding to Bulletin 79-14, that information could be helpful to us in protecting the health and safety of the public.: We wish to reiterate in this regard that your knowledge of defects may subject you to Section 206 of the Energy Reorganization Act and to Part 21 of Title 30 of the Code of Federal Regulations.
a Mr. Schuyler R. MitcheLL 3
We expect to complete our review of your proposal in the near future, at
'which time we will inform you of our decision.
Sincerely, Victor Stello, Jr.
Director Office of Inspection and Enforcement bec:
J. H. Sniezek, IE i
E. L. Jordan, IE R. W. Woodruff, IE H. J. Wong, IE concur:
IE: REB IE:RRRI:DD IE:RRR2:D IE:DD IE:D RWWoodruff ELJordan JHSniezek RCDeYoung VStello 2/ /81 2/ /81 2/ /81 2/ /81 2/ /81 t
Z
?
s
v.
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-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 applicable 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 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 provided 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 completed in 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 technical specification action statement.
Visual Aoproximations l
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, where visual estimates are used, the accuracy of estimation must be within toler-ance requirements.
Further, in documenting the data, the licensee must specif-ically identify those data that were visually estimated.
r D'
%A p
$NfC7 IX 1pp
IE Bulletin No. 79-14, Supplemsnt 2 September 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 j
supports.
Where necessary to determine the location of pipe supports to an accuracy within design tolerances, thermal insulation must be removed.
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.
Offficult 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.
e e
-w 7-m we
-t----
r
,4,-- --
r
.egw wye g
y--,wmm-_
ym
,y--
a y
e--+-m--
+
IE Bulletin No. 79-14, Supplemtnt 2 Enclosure September 7, 1979 Page 1 of 3 a
i LISTING OF IE BULLETINS ISSUED IN LAST SIX MONTHS Bulletin Subject Date Issued Issued To No.
I 79-22 Possible Leakage of 9/5/79 Each Licensee who Tubes of Tritium Gas Receives Tubes of Used in Timepieces for Tritium Gas in Luminosity Timepieces for Luminosity 79-13 Cracking in Feedwater 8/30/79 All Designated (Rev. 1)
System Piping Applicants for OLs 79-21 Temperature Effects 8/13/79 All PWRs with on Level Measurements an operating license 79-20 Packaging low-Level 8/10/79 All Materials Licensees Radioactive Waste for who did not receive Transport and Burial Bulletin No. 79-19 79-19 Packaging Low-Level 8/10/79 All Power and Research Radioactive Waste for Reactors with OLs, Transport and Burial fuel facilities except uranium mills, and.
certain materials licensees 79-18 Audibility Problems 8/7/79
-All Power Reactor Encountered on Evacuation Facilities with an Operating License 79-17 Pipe Cracks in Stagnant 7/26/79 All PWR's with Borated Water Systems at operating license PWR Plants 79-16 Vital Area Access Controls 7/26/79 All Holders of and applicants for Power i
Reactor Operating Licenses who anticipate loading fuel prior to 1981 79-05C&O6C Nuclear Incident at Three 7/26/79 To all PWR Power Mile Island - Supplement Reactor Facilities with an OL 79-15 Deep Draft Pump 7/11/79 All Power Reactor Deficiencies Licensees with a CP and/or OL 1
e e
w---
e,--
~
y~,
pw
,,,,--,www,,w,,,,,wwwm w---,or
-p
-r em c -wp,mm
,mn v-- r w o w-
-a--
en~---,,---
,n--
IE Bulletin No. 79-14, Supple:snt 2 Enclosure September 7, 1979 Page 2 of 3 a
LISTING OF IE BULLETINS ISSUED IN LAST SIX MONTHS Bulletin Subject Date Issued Issued To No.
79-14 Seismic Analyses for 6/2/79 All Power Reactor As-Built Safety-Related facilities with an Piping System OL or a CP-79-01A Environmental Qualification 6/6/79 All Power Reactor of Class 1E Equipment Facilities with an (Deficiencies in the Envi-OL or CP ronmental Qualification of ASCO Solenoid Valves) 79-13 Cracking In Feedwater 6/25/79 All PWRs with an System Piping OL for action. All BWRs with a CP for information.
79-02 Pipe Support Base Plate 6/21/79 All Power Reactor (Rev. 1)
Designs Using Concrete Facilities with an Expansion Anchor Bolts OL or a CP 79-12 Short Period Scrams at 5/31/79 All GE BWR Facilities BWR Facilities with an OL 79-11 Faulty Overcurrent Trip 5/22/79 All Power Reactor Device in Circuit Breakers Facilities with an for Engineered Safety OL or a CP Systems79-05B Nuclear Incident at Three 5/21/79 All B&W Power Reactor Mile Islaad Facilities with an OL 79-10 Requalification Training 5/11/79 All Power Reactor Program Statistics Facilities with an OL 79-06A Review of Operational 4/18/79 All Pressurized Water (Rev 1)
Errors and System Mis-Power Reactor Facilites alignments Identified of Westinghouse Design During the Three Mile with an OL Island Incident 79-09 Failures of GE Type AK-2 4/17/79 All Power Reactor Circuit Breaker in Safety Facilities with an Related Systems OL or CP w,
IE Bulletin No. 79-14, Supplement 2 Enclosure September 7, 1979 Page 3 of 3 LISTING OF IE BULLETINS ISSUED IN LAST SIX MONTHS Bulletin Subject Date Issued Issued To No.
79-08 Events Relevant to BWR 4/14/79 All BWR Power Reactor Reactors Identified During Facilities with an OL i
Three Mile Island Incident 79-07' Seismic Stress Analysis 4/14/79 All Power Reactor
~
of Safety-Related Piping Facilities with an OL or CP 79-068 Review' of Operational 4/14/79 All Combustion Engineer-Errors and System Mis-ing Designed Pressurized alignments Identified Water Power Reactor During the Three Mile Facilities with an Island Incident Operating License 79-06A Review of Operational 4/14/79 All Pressurized Water Errors and System Mis-Power Reactor Facilities alignments Identified of Westinghouse Design During the Three Mile with an OL Island Incident 79-06 Review of Operational 4/11/79 All Pressurized Water Errors and System Mis-Power Reactors with an alignments Identified OL except B&W facilities During the Three Mile Island Incident 79-05A Nuclear Incident at 4/S/79 All B&W Power Reactor Three Mile Island Facilities with an OL 79-05 Nuclear Incident at 4/2/79 All Power Reactor Three Mile Island Facilities with an OL and CP
i
~
' o, Seismic Analyses For As-Built Safety-Related Piping Systems - Supplement 2 to IE Bulletin No. 79-14 2
Advance Copy:
Eric Weinstein, Records Manager, PDR H-1717 (BLUE BAG)
Distribution:
Herbert Fontecilla, Technical Assistant, OCM (Hendrie)
H-1149 i
George Eysymontt, Technical Assistant, OCH (Gilinsky)
H-ll49 l
John C, Guibert, Technical Assistant, OCH (Kennedy)
H-ll49 Hugh Li Thompson, Technical Assistant, OCM (Bradford)
H-ll49 George D. Sauter, Technical Assistant, OCM (Ahearne)
H-ll49 SECY H-ll49 C. Kammerer, Director, OCA H-1159 A. P. Kenneke, Acting Director', PE H-1007 L. Bickwit, General Counsel H-1047 R. F. Fraley, ACRS H-1016 L. V. Gossick, EDO MNBB-6209 J. R. Shea, Dir., OIP MNBB-8103 J. J. Fouchard, Director, PA MNBB-3709 N. M. Haller, Director, MPA MNBB-12105 G. Wayne Kerr, Asst. Dir., SA:SP MNBB-7210A J. Lieberman, ELD MNBB-9604 R. B. Minogue, Dir., SD NL-5650 G. A. Arlotto, Dir, DES:SD NL-5650 W. J. Dircks, Dir., NMSS SS-958 G. McCorkle, Chief, SGPL, SG:NMSS.
55-881 S. Levine, Dir., RES SS-1130 i
H. R. Denton, Dir., NRR Phil-428 D. Vassalo, Acting Dir., DPM;NRR Phil-268 D. F. Ross, Deputy Director, DPM:NRR Phil-278 P. F. Collins, Chief, OLB:DPM:NRR P-357 J. R. Miller, DOR:NRR Phil-216 D. G. Eisenhut, Acting Dir., DOR:NRR Phil-266 R. H. Vollmer, Asst. Dir., SP:00R:NRR P-514 G. C. Lainas, Chief, PSB:00R:NRR Phil-416 B. K. Grimes, Asst. Dir., E/P:00R:NRR Phil-370 R. J. Mattson, Dir., DSS:NRR Phil-202 R. M. Satterfield, Chief, ICSB: DSS:NRR Phil-722 F. Rosa, Chief, PSB: DSS:NRR P-822 W. P. Haass, Chief, QAB:0AO:NRR P-320 V. Stello, Director, IE D. Thompson, Act. Deputy Director, IE G. C. Gower, XOOS:IE R. C. Paulus, XOOS:IE L. N. Underwood, X005:IE (Original)
H. D' Thornburg, RCI:IE G. W. Reinmuth, RCI:IE N. C. Moseley, ROI:IE E. L. Jordan, ROI:IE S. E. Bryan, ROI:IE J. H. Sniezek, FFMSI:IE L. B. Higginbotham, FFMSI:IE E. M. Howard, SI:IE L. I. Cobb, X0MA:IE R. W Woodruff. ROT TF IE Files i
NRC Central Files Phil-016 IE Reading Files
--rwv w-
,-.v.-
w.,e m---
+-------
--,.,,w.
i
IE Bulletin No. 79-14, Supplem:nt 2
_s i Page 2 of 2 SEISMIC ANALYSES FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS Distributionc (Continued)
R. A Feil, RI I. T. Yin, RII L. Mondenos, RII R. M. Brickley, RIV T. W. Hutson, RV.
R. G. LaGrange, NRR R. Lobel, NRR S. S. Giab, NRR S. B. Hosford, NRR C. J. DeBevec, IE J. C.~Glynn, IE n
e 9
J O
6
-a,,
..e
--..n
SSINS:
6820 Mgust 15,1979 Accession No:
g-7908080360 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C.
20555 Supplement IE Bulletin No. 79-14
~
SEISMIC ANALYSIS FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS i
Discription of Circumstances:
IE Bulletin No. 79-14 was issued on July 2, 1979 and revised on July 18, 1979.
The bulletin requested licensees to take certain actio'ns 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 the 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 accordance with Item 2 of the Bulletin, the licensee is expected to verify by physical inspection, to the extent practicable, that the inspection elements meet the acceptance criteria.
In performing these inspectons, 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 thermal 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 Item 4 of the Bulletin to perform an evaluation of the significance of the 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 engineering 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 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-ments for content and schedule as given in Item 2 and 3 of the Bulletin.
3.
Inspect Remaining Piping The licensee is expected to inspect, as in Item 2 above, the remaining safety-related piping systems which were seismically analyzed and to report the results in accordance with the requir Jents for content and schedule as given in Item 3 of the Bulletin.
O V f') G~ M (1 7/
Dd i
e
,.mm
)C i!
a
,4 Supplement IE Bulletin No. 79-14 Page 2 of 2 August l5, 1979 4A.
Evaluate Noncomformances With regard to Item 3A for the Bulletin, the licensee is expected to include in the initial engineering 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 the system may not perform its intended function during a design basis earthquake, the licensee must promptly comply with applicable action statements and reporting requirements in the Technical Specifications.
48.
Submit Nonconformance Evaluations 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 4B of the Bulletin or correct the noncomformances.
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.
Imorove Qualtiy 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 with Item 4D of the Bulletin, the licensee is expected to revise design documents and seismic analyses in a timely manner.
The schedule for the action and reporting requirements given in the Bulletin as originally issued remains unchanged.
r UNITED STATES s
NUCLEAR REGULATORY C0!HISSION WASHINGTON, D.C.
20555 July 2, 1979 IE Bulletin No. 79-14 I
SEISMIC ANALYSES FOR AS-BUILT SAFETY-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 sunmation 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 unconservati.ve 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 configuration.
5 PP
IE Bulletin No. 79-14 July 18, 1979 Revision 1 Page 2 of 3 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 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 piping 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 fifd/d safety-related systems, utilizing pioing 2 1/2 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 ccnfiguration 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 doc.sents.
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 Sulletin 79-02); pipe attachements; and valve and valve operator locations and weights (excluding those covered in IE Bulletin 79-04).
..itnin oO days of the date of this bulletin, submit a description of
.ne results of this inspection.
'lhere nonconformances are found which affect operability of any system, the licensee will expedite completion of the inspection described in item 3.
- Nor:.a.1 accessiole, refers to those areas of the plant wnich can be entered carig reactor operation.
IE Bulletin No. 79-14 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.
Within 120 days of the date of this bulletin, submit a description of the results of this inspection.
4.
If nonconformances are identified:
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: (1) 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 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.
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 systems in accordance with Items 2 and 3 and report the results within 120 days.
Reports shall be submitted to the Regional Director with copies to the Director of the Office of Inspection and Enforcement and the Director of the Division of Operating Reactors, Office of Nuclear Reactor Reguiation, Washington, D.C.
20555.
Approved by GA0 (R0072); clearance expires 7/31/80. Approval was given under a blanket clearance specifically for generic problems.
a e
5 APPENDIX A s
PLANTS WITH SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL DESIGN AND AS-BUILT CONDITION OF PIPING SYSTEMS Plant Difference Remarks Mislocated supports.
As built condition Surry',1 Wrong Support Type.
caused majority of pipe Different Pipe Run overstress problems, not
- Geometry, algebraic summation.
Beaver Valley 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 Snubber 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.
O e
f 5
~n.
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-Bisse Gussets missing'from main Supports would be over-Steam Line Supports.
stressed.
Repairs will be completed prior to start-up.
~0 e
9 e
e d
.