ML20212N703

Rev 0 to Temporary Instruction Ri 87-03, Storage of Transient Equipment in Safety-Related Areas

ML20212N703
Person / Time
Issue date:	03/05/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
References
RI-87-03, RI-87-3, NUDOCS 8703130123
Download: ML20212N703 (6)

Text

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RI 87-03 5 MAR 1987 Issue Date Page 1 of 5 Region I Temporary Instruction No. RI 87-03 , Revision 0 STORAGE OF TRANSIENT EQUIPMENT IN SAFETY-RELATED AREAS Purpose The purpose of this temporary instruction (TI) is to provide guid-ance to Region I Resident Inspectors for reviewing the storage of transient equipment having the potential to adversely affect safety-related equipment. This is applicable for reactor sites with operating licenses (0L's) or sites expected to get OL's within the next year.

Objectives The following objectives are to be met by this review:

1. Ascertain the status of licensee administrative controls (or other type of facility procedures) in the subject area.

2. Determine the proper implementation of administrative controls (or other type of facility procedures) for the subject area.

3. Identify if deficiencies exist independent of whether or not facility procedures cover the subject area.

4. Where deficiencies exist, assess the licensee corrective action process with respect to the applicable NRC Information Notice (IN) and use this inspection process to obtain licensee upgrading in this area.

Background

The General Design Criteria (GDC) (10 CFR 50 Appendix A) coupled with the updated Safety Analysis Reports (USAR's) provide a basis to assure that transient equipment does not adversely affect the safety function of struc-tures, systems, and components that are safety related. Transient equip-ment includes: dollies; block and tackle; filled gas bottles; heavy equip-ment, (stationary or on rollers) such as welding machines or tool cabinets; scaffolding, (stationary or on rollers); and, temporary office spaces along with housed furniture, cabinets, etc. GDC Criterion 2 states 0FFICIAL RECORD COPY TMIl RI TEMP INST 87- - 0001.0.0 11/29/80 '

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Issue Date 5 MAR 1987 e .: Page 2 of 5 T that: " structures, systems, and'c9?p6nents ... shall be Wesigned to with-stand the effects of natural phenomena. .. The design basis for these structures, systems, and components shall reflect: ... appropriate com- ,

binations of tha effects of normal or acciient conditions with the effects '

of the natural phenomena....". Criterion 4 states that: " structures, systems, and components ... shall be designed to accommodate the effects of and be compatible with the environmental canditions associated with normal operation ... and postulated accident:, ....These structures, systems, and components.shadl be appropriately protected against dynamic effects, including the Affects bf missiles, pipe whipping, and discharging fluids that may result from equipment failure and from events and conditions out-side the nuclear power plant...."

To meet the criteria, the USAR's generally consider bajor structure design initiatives such as separating redundant safety-related pumps and valves between trains with seismic Category I walls. However, for the more

' subtle issue, stprage of transient equip _ ment, the p!AP's or facility pro-cedures may not provide control of, transient equipment 1,6r temporarily M

stored equipment) that could become a missile ~a ga resu't of a natural phenomenon or industrial. accident ~. ,

The N'RC's Information Noiice Noi 80-21, dated May 16, 1980, " Anchorage and Support of Safety-Related Electr*ical Equipment d ' identified deficiencies with the aychorage of non-seismic Category I ancillary items (transient equipment plus: Installed systems such as non safety-related ductwork).

Further, their locations may be that they could potentially dislodge, im-pact, and damage safety-related equipment doring an earthquake. This TI focuses on the transient equipment, not the non-seismic Category I installed systems.

Recent team inspections corducted by Region I have identified that some licensees appear tu hav6 a general disregard for, and lack of forrt.al controls on, prop'er anchorage of transient equipment temporarily stored in safety-related areas. -

J INSPECTION REQUIREMENTS During the next < full (one month) i spection period after the date of this TI, i the resident inspectors will review the below listed Atens during their facility '

tours. Projects Section Chiefs may authorize substitution of the review for i some elceents of inspect Nn procedures 71707 and 42700. t )

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1. Identify and review for adet;uacy, licensee internal response to Information

. Notice (IN) No. 80-21 with rsspect'to transient equipment.

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2. Identify and review for adequacy established administrative controls or other facility procedures that control the storage of transient equipment in safety-related areas.

3. Verify proper implementation of applicable procedures established as noted in 2 above. If no procedures were established, identify if equipment is properly stored and assess management awareness of the issue and question why procedures do not exist to control such items. {

4. Where significant deficiencies are found, attempt to obtain licensee commitments for upgrading in this area. These commitments should be documented in the inspection report or by separate correspondence from _

the licensee. [

i GUID,uCE i The enforceability of the above-referenced GDC traditionally has been to use 10 CFR 50 Appendix 50 Criterion 3, " Design Control," and the NRC-approved Quality Assurance Plan, which assures that applicable regulatory requirements and design bases are correctly translated into drawings, procedures, and instructions.

However, the main focus of this review is to survey licensee status and to iden-tify deficient licensees along with obtaining commitments for upgrading, as necessary. Inadaquate corre::tive actions in this area could also be enforceable through 10 CFR 30 Appendix B Criterion VVI. Specific guidance for each of the above-noted inspection items is andressed below.

The general guidance to be applied is that all equipment / objects in safety-related areas ihall be securely anchored or removed when permanent plant equipment in that area is required to be operable.

1. Licensee review of IN 80-21 should have confirmed that procedural controls were established for the control of transient equipment in safety-related areas. Further, licensee review should have verified proper implementation of these controls.

2. Little formal guidance is dW=ted on the adequacy of control for the storage of transient equipr. aid.. Considerable inspector judgement is war-ranted. Restraints should be reasonable and substantial for equipment on rollers; i.e., heavy chain or wire rope. Household string would obviously be unacceptable. Free standing equipment (restrained by friction) should be a sufficient distance from safety-related equipment such that if it overturns, it would not impact safety-related equipment; i.e., twice the height of the free-standing object.

OFFICIAL RECORD COPY TMIl RI TEMP INST 87- - 0003.0.0 11/29/80

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Additional initiatives would be to designate storage areas; i.e, for

~ Reactor Building refueling equipment or house store equipment in seismic Category I walls. Ideally, all transient equipment should be removed from safety-related areas. Scaffolding should not be erected over safety-related equipment required to be operable.

Any questionable areas should be discussed with the section chief and documented in the attachment.

3. Licensee failure to follow established procedure controls should be discussed with licensee management. For plants that are in outages, inspector findings should be tempered by safety significance while in cold shutdown. Inspector-noted negative observations from the prior power operation period should be discussed with licensee management with forewarning on the upcoming power operation period. Readiness Assessment Team inspections should focus on this area in preparation for plant startup. Enforcement should be consistent with safety significance.

4. The main focus of this inspection is to survey licensee status in controlling this area. It is also to identify licensees with significant deficiencies in the interest of enhancing safety. As a minimum, outstanding issues should be followed by an unresolved item and appropriately documented in the inspection report.

REPORTING REQUIREMENTS:

1. Upon completion of this review, complete Attachment 1 and forward it to the DRP section chief with a copy for the DRP TI coordinator.

2. Document inspection results in the applicable monthly resident inspection report.

3. The DRP TI coordinator will provide a summary of Attachment I for all plants to the DRP Division Director by June 30, 1987.

TECHNICAL CONTACT:

Richard J. Conte, Chief, Reactor Projects Section No. lA

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RI 87 5 MAR 1987 Issue Date Page 5 of 5 STATISTICAL DATA REPORTING Time expended shall be reported under Inspection Procedure 71707 and/or 42700 as appropriate.

Approved by:

Director, Division of Reactor. Projects

Attachment:

As Stated Distribution:

Director, DRS Deputy Director, DRS Director, DRSS Deputy Director, DRP DRP Branch Chiefs DRS Branch Chiefs DRP Section Chiefs DRS Section Chiefs Resident Inspectors T/I Coordinator DRP Secretary t

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ATTACHMENT SURVEY OF LICENSEE STORAGE OF TRANSIENT EQUIPMENT IN SAFETY-RELATED AREAS Yes No

1. Did the licensee need to establish a procedure in response to IN 80-21?

2. Was the licensee responsive to IN 80-21?

3. Does the licensee have procedures to control transient equipment?

4. Were these' procedures adequate?

5. Did the licensee properly implement procedures established for the storage of transient equipment?

-6. Was tne equipment improperly stored independent of the existence of a procedure (not applicable for

' plants in cold shutdown)?

REMARKS (If possible, describe the safety significance of the N0 cnswers)

Plant Completed by/Date

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