ML20203N324

Responds to Re Mitchell Allegations Re as-built Drawings at Byron Station.Allegations Will Be Vigorously Pursued.Recommendation to Pursue Investigation at Byron 2 & Braidwood 1 & 2 Premature

ML20203N324
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	09/17/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Lash T ILLINOIS, STATE OF
References
NUDOCS 8609230314
Download: ML20203N324 (2)

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BEP 1 7 1986-Illinois Department of Nuclear Safety ATTN: Dr. Terry R.-Lash, Director 1035 Outer Park Drive

- Springfield, IL 62704 _

Dear Dr.. Lash:

This is 'in -response to your letter of August 22,1986, concerning l Mr. Schuyler Mitchell's recent allegations regarding Consonwealth Edison

. Company's (CECO) as-built drawings at the Byron Station. During the Springfield .

meeting of August 12, 1986, members of my staff emphasized to you the importance placed on this allegation by the NRC. Let me personally re-emphasize this point to you. Mr. Mitchell's allegation, like the many other allegations received by this office, will be vigorously pursued to determine whether there are any.

• safety concerns or violations of NRC regulations governing the construction and/or operation of a nuclear power facility.

Your letter expressed the -view that the proposed NRC investigation of Mr. Mitchell's allegations is too narrow and-limited in scope to sufficiently address the concerns. Specifically, you recommend that the initial investigation should involve a complete quadrant in the containment for Byron 1 and that similar investigations should be considered at Byron' 2 and at Braidwood 1.and 2. In our view, it is premature to implement the extensive program you suggest until the relative technical significance of Mr. Mitchell's allegations can be established. As you know we initiated an inspection, .

which is being observed by your staff of Byron Unit 1 on September 15, 1986. .!

In addition to potential areas of concern identified to us by Mr. Mitchell (about 20' dimensions) we plan to expand the inspection sample considerably. .

The expanded sample will be safety-related systems (such as safety. injection '

and component cooling water) located inside Unit 1 and Unit 2 Containment Buildings as well as those' located in the Auxiliary Building. The resulting

,. dimensions checked will be in the range of 400 to 600. This, of course,

. is in addition to the inspections-performed during the period of -

t' August:13, 1984 through April 2, 1985,'where similar issues were inspected and l l reported in Inspection Report Nos. 50-454/84-51 and 50-455/84-35-(we previously ,

j provided you a copy of this report). .

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, The dimensions'obtained from these inspections will be compared to as-built

_ drawings and any significant discrepancies will'be evaluated. Once this effort

! ' is completed and the relative safety significance is determined, a decision will i be made either to continue to expand or to terminate our as-built verification efforts. This represents a logical and pragmatic approach to resolving the allegation based on the infonnation now available, and is consistent with NRC's

! handling of past similar allegations.

! With regard to your questions about NRC's requirements for the accuracy of l "as-built" drawings at the time a plant is licensed to operate and thereafter ,

L l 8609230314 860917 l

PDR ADOCK 05000454

SEP 171986 Illinois Department of Nuclear 2 Safety throughout the plant's operating lifetime", enclosed is a copy of IE Bulletin 79-14 for your review. Paragraph 4.D of the enclosure states:

. 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.

It has been our policy to have each licensee develop as well as defend accuracy requirements on a case-by-case basis. The NRC evaluates these requirements also on a case-by-case basis using best engineering judgement.

As you are aware, a member of your staff is accompanying us during our inspection efforts on this allegation. We look forward to his participation until final resolution has been achieved. We hope that this information alleviates your concerns and explains our position.

. Sincerely, Ortstant n)gnng by L*.ws G. Kapptog.

James G. Keppler Regional Administrator

Enclosure:

As stated cc w/ enclosure:

V. Stello, ED0 G. W. Kerr, OSP G. H. Cunningham, OGC J. M. Taylor, IE J. W. McCaffrey, Chief, Public Utilities Division i

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U.S. NUCLEAR REGULATORY COMMISSION

• OFFICE OF INSPECTION AND ENFORCEMENT REGION III July 2, 1979 IE Bulletin No. 79-14 SEISMIC ANALYSES FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS Description of Circumstances:

Recenty tv., issues were identified which can cause seismic analysis of safety-related piping systems to yield nonconservative results. One issue involved algebraic summation of loads in some seismic analyses. This was addressed it.

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 documento 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-i figurations. Where subsequent use, damage or modifications affect the con-l dition or configuration of safety-related piping systems as described in documents from which seismic analysis input information was obtained, the l

licensee anast consider the need to re-evaluate the seismic analyses to con-t sider the as-built configuration.

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4 July 18, 1979 )

IE tulletin No. 79-14 -

Page 2 of 3 Revision 1 Action to be taken by Licensees and Pemit Holders:

All power reactor facility licensees and construction pemit holders are requested to verify unless verified to an equivalent degree within the last 12 months. that the seismic analysis applies to the actuaT configura-tion of safety-related piping systems. The safety related pipin Seismic Category I systems as defined by Regulatory SeismicGuide 1.29. g 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 pipinc 21/2-inches in diameter and creater and to seismic Category I piping, regarclass 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 Aldid safety-

.related systems, utilizina 01pina 21/2 inches in diameter and areater, meets design requirements.

Specifically, each licensee is requested to:

1. Identify inspectior, elements to be used in verifying that the seismic analysis input infomation conforms to the actual configuration of safety-related systems. For each safety-related system, submit a list of design documents, including title identificaticn msnber, revision and date, which were sources of input infomation for the seismic analyses. Also submit a description of the seismic analysis input infonmation 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 infonnation within 30 days of the date of this bulletin.

2. For portions of systems which are nomally accessible *. inspect one system in each set of redundant systams and all nonredundant systens for con-fomance to the seismic analysis input infonnation set forth in design documents. Include in the inspection: pipe run geometry; support and restraint design, locations, function and clearance (including floor '

and us11 penetration); estiedments (excluding those covered in IE i

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 nonconfonnances are found which affect operability of any system, the licensee will ex;iedite coupletion of the inspection described in Item 3.

'Homally accessible refars to those areas of the plant which can be entered during reactor operation.

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IE Bulletin No. 79-14 July 2, 1979 Page 3 of 3

3. In accordsuce with Item 2, inspect all other normally accessible safety-related system: 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 marthquake 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 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 periait 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 i

Director of the Office of Inspection and Enforcement and the Director i of the Division of Operating Reactors, 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.

Enclosures:

1. Appendix A

2. Listing of IE Bulletins Issued in Last Twelve Months i

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i APPENDIX A PLANTS WITH SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL DESIGN AND AS-BUILT CONDITION OF PIPING SYSTI!MS Difference Remarks Plant Surry 1 Mislocated supports. As built condition 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."

IE inspection identified Licensee is using as Fitzpatrick built configuration differences similar to 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.

Pipe supports not built Supports were repaired Ginna during refueling outage.

to original design, St. Lucie Missing seismic supports. Install corrected Supports on wrong piping. supports before start up from refueling.

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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: 6820 Accessiee No:

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UNITED STATES

, NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT f

, WASHINGTON, D.C. 20555 -

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August 15, 1979 f

. k Supplement IE Bulletin No. 79'-14 SEISMIC ANAI.YSIS FOR AS-3UILT SAFETY-RELATED PIPING SYSTEMS Discription of Circumstances:

l 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. l To comply with the requests in IE Bulletin 79-14, it will be necessary for licensees to do the following: ,

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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

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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 l 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

l. is not practicable, e.g., for valve weights and materials of construction, I l

the license is expected to verify conformance by inspection of quality

, assurance records. If a nonconformance is found, the licensee is expected l

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 evalustion shows that system operability is in jeopardy, the licensee is expected to meet the applicable

! g technical specification action statement and complete the, inspections required by Item 2 and 3 of the Bulletin as soon.as possple. The licensee

• 9:.S must report the results of these inspections in accordanch with the . require ,

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ments for content and schedule as given in Item:2 and 3 y the Bulletin.

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Supplement IE Bulletin No. 79-14 Page 2 of 2

,- August 15, 1979 .

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, I3. Inspect Remainina Pipina -

The licensee is expected to inspect, as in Item 2 above, (he remaining safety-related piping systems which were seismically analized and to

. report the results in accordance with the requirements fos content and

( schedule as given in Item 3 of the Bulletin.

. Evaluate Noneoeformances 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.

4B. 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 Ites 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 Ites 4C of the Bulletin.

4D. Improve 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.

he schedsle for the action and reporting requirements given if the Bulletin gas originally issued remains unchanged. .L Approved by CAO, B180225 (R0072), clearance expires 7/31/80. 4pproval was given vnder a blanket clearance specifically for identified generic $roblems.

Enclosure:

Listing of IE Bulletins Issued in 1.ast 6 Months

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SSINS: 6820 Accesstion No.: J800000609=-

UNITED STATES l

NUCLEAR REGULATORY COMISSION '

0FFICE 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 Approximations 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-ante requirements. Further, in documenting the data, the licensee must specif-ically identify those data that were visually estimated.

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IE Bulletin No. 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, i.e. attachment welds, saddles, support configuration, etc. In some areas, the presence of thermal insulation may result in unacceptably large ur) certainties for determination of the location of pipe supports.

W6ere themal 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 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 i

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

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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 Bulletin as originally issued remains unchanged.

Enclosure:

List of IE Bulletins Issued in the Last Six Months i