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MEMORANDUM FOR:
SEE ATTACHED FROM:
Linda L. Robinson, Chief Freedom of Information and Privacy Acts Branch
SUBJECT:
FOIA REQUEST FROM LINDA BAUMAN FOR COPIES OF ALL RECORDS RELATED TO THE WORK OF THE MANAGEMENT REVIEW COMMITTEE ON OIA REPORT NO. 36-10 ON THE COHANCHE PEAK PLANT (FOIA-87-87)
Please find enclosed a copy cf the subject FOIA request.
Please inform Joe Cawley of my staff by February 18, 1987, of your-responses to the questions on the enclosure to this memorandum.
Please provide the FOIA Branch with all agency records subject to this request no later than February 23, 1987 4
When submitting records responsive to the request, a careful review J
should be undertaken to identify (1) any material which should be withheld specifically as classified, safeguards, or proprietary information; and (2) all records received from, or transmitted to, one or more Commissioners, or which contain substantive excerpts from records received froc, or transmitted to, the Commissioners.
Records should be grouped on separate lists as follows:
(A) records in the PDR; (B) records to be placed in the PDR; (C) records to be withheld in part or in whole with exemptions noted; and (D) records to be referred to the Commissioners, other NRC offices, submitters for proprietary review, and other Federal agencies.
Also, inform the FOIA Branch whenever requested records involve a subject for which litigation is ongoing or is probable to ensure coordination with OGC and the Department of Justice.
Special instructions regarding FOIA search requirements are provided on the enclosure to this memorandum.
If you have any questions, please telephone immediately the FOIA Branch co et identified l
- below, Ms
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Lin a L. Robinson, Chief j
Freedom of Information and i
Privacy Acts Branch
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Enclosures:
As stated CONTACT: Joe Cawley X24269 871115 B708270270 870819 PDR FOIA BAUMAN87-A-1. 4.PDR
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y MEMORANDUM FOR:
H. Smith, NRR, ATTN: D. Crutchfield b
W. Mu111 nix, IE, ATTN: P. McKee & W. Collins K. Anderson, RIII, ATTN: C. Paperiello i
G. Beveridge, NMSS, ATTN: J. Davis & R. Erickson I
A. Sumerour, RES, ATTN: G. Arlotto l
J. Bartlett, OGC, ATTN: J. Lieberman & J. G61dberg G. Thompson, AEOD, ATTN: C. Heltemes G. Mulley, OIA i
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- * ' ' t. u.. cc a r. n m following questions within five days of'your reNi[t oEaUOIA
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request:
i 1.
Does your office have agency records subject to this request?. If yes, will significant search time be required? NOTE: If expected search time exceeds two.
hours', do not begin search until first talking to the FOIA Branch contact.
2.
Do you anticipate any significant problems in processing this request and rosponding in the allotted time? If so, infom the F0IA Branch contact immediately.
3.
Is there any other office not listed above which'might have records subject to this request? If so, inform the FOIA Branch contact imediately.
FOI A SEARCH INSTRUCTIONS:
The following instructions are to be used in searching for records and processing FOIA requests:
Scope of Search 1.
As a general rule, a search is adequate when all records are located which individuals familiar with the subject matter of the request can reasonably be expected to find in-a reasonable amount of time.
2.
The staff does not have to look into every conceivable file for records subject to a request, but the staff likely to be familiar WPth the subject matter must be consulted, and those files likely to contain records must be reviewed.
Acency Records 3.
A request applies only to records in exist'ence on.the date the request is received by NRC.
"In existence" includes records in a computer data file.
Even though a copy of the computer data file may be subject, no new programing is required to extract the data. However, if the infomation is retrievable by use of an existing print program the subject information can be provided by printout.
(Records created after a request is received by NRC may be made available as a ratter of discretion with.
the staff, i.e., if the additional records are necessary to provide a complete picture of a situation or to avoid possible ambiguity).
4.
If the requested information does not exist in record 'or computer format at the time a request is received, there is no obligation under the FOIA to create a record in
- order to be responsive to the request.
5.
If records have been destroyed prior to the receipt of the request, there is no obligation under the FOIA to tell the requester what was destroyed, when it was i
destroyed, or why it was destroyed.
Note, however, that%o records may be destroyed af ter 4 request is received.
.4 6.
If a request also asks for all records created in connection with the processing of the request, it is not necessary to make these records available since the records were not in existence at the time the request was received.
The FO!A imposes no obligation on staff offices to retain such records.
(However, there may be a separate, later request, for tgs,e records).
7.
If a request asks for records maintained at a person's residence, and a staff member l
has,any question as to whether the records are personal records or agency records, the !
staff member should contact the FOIA Branch.
(Normally records maintained at a Person's dence ge_no,t, " agency. records").
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1555 Connecticut Avenue, NW, Suite 202 (202)232 8550 i
Wcshington. D.C. 20036 GOVERNMENT ACCOUNTABILITY PROJECT
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MIDWEST OFFICE 3424 MARCOS LANE APPLETON, WISCONSIN 54911 January 29, _987 fR DC. OF INFORM 4Ttosq FREEDOM OF INFORMATION ACT REQUEST ACT RCQUEST
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Office of Administration CY2-/d=f U.S.-Nuclear Regulatory Commission Washington D.C.
'0210 TO ~4HOM IT MAY CONCERN:
Pursuant to th'e Freedom of Information Act (FOIA), 5 U.S.C.
- 552, the Government Accountability Project (GAP) requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calanders, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering analyses, drawings, files, graphs; charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, I
any other data compilations, interim and/or final reports, status reports, and any and all other records relevant to and/or generated in connection with the work of the Management Review Committee of OIA Report No. 86-10 which includes John Davis, Guy Orlods and John Pagliaden (Region III).
This request includes all agency records as defined in 10 C.F.R. 9.3a (b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved Octcber 8, 1980) whether they currently exist in the NRC " official, werking", investigative or other files, or at any other location, including !
private residences.
If any records, as defined in 10 C.F.R. 9.3a(b), and the NRC Manual, supra, and covered by this request have been destroyed and/or removed af ter this request, please provide all surrounding record's, including but not limited te a list of all records which have been or are destroyed l
andf'or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).
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3 GAP requests that fees e waived, because
" finding the information.can.be considered as primarily benefiting the general public," 5 U.S.C.
522 (a) (4) (a).
GAP is a non profit, non-partisan public interest organization concerned with honest and open government.
Through.public outreach, the Project promotes whistleblowers as agents of government accountability.
Through it Environmental Whistleblower Clinic, GAP of fers assistance to local public interest and citizens groups and interveners in the ~ concern for safety at nuclear power plants.
We are requesting this information as part of an ongoing monitoring project of the NRC's efforts to protect public health and safety at and near nuclear processing plants'and radioactive waste facilities.
For any documents or. portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld.
The index should provide a detailed justification of your grounds for claiming each exemption, taxplaining why ea h exemtion is relevant to the document or portion of the document w thheld.
This index is required under Vaughn v.
Rosen (1), 484 F2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S.
977 (1974).
We look forward to your response to this request within ten (10) werking days.
Sincerely, i
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Linda Bauman FOIA Coordinator Midwest Office 1
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Responses to this request should be mailed to :
Government Accountability Project Midwest Office 2424 Marcos Lane Appleton, Wisconsin 54911
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NUCLEAR REGULATORY COMMISSION d
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. MEMORANDUM FOR: File
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JohnG. Davis l Chairman r
y; ComanchePeakReportReviewGroup(CPRRG) 4
,SyJECT:
CPRRG MEETING, JANUARY 27, 1987
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The Comanche Pen Report Review Group (CPRRG) met in the Willste Building, Silver Spring,-at:1:30 PM on January 27, 1987. Participants were: John Davis.
NMSS; Bob Erickson, NNSS; Guy Arlotto, RES; Jack Heltemes, AE0D; James Liebennan, OGC; Philip McKee, IE; Samuel Collins, RI; Richard Hartfield, IRM; Pennis Crutchfield, NRR (who participated by telephone).
'4 HIGHLIGHTS Discussionwith[askGroupLeadersTheCPFP,GbriefedGroupLeaders(McKee, Task T;~EITUis, Task 2; and CrutchtTJTd, Task 3).on~ the background and purpose of g
the CPRRG effort.
It was agreed that Task Groups would review and comment on their respective task.. Statements within a few days, so they can be finalized.
- t Additional Matters to be Addressed The Chairman's memorandum of January 15, 1987 and the ED0's memorandum'Tf7anuary 21, 1987,' require the CPRRG to review the purpose and significance of NRC Form 766 and also to offer a judgment based on its review of Region IV's activities related to Comanche' Peak, whether it is likely.that there are broader implications in Region IV. The Group discussed the NKC' 766 question at length with Richard Hartfield, IRM, who is taking the lesd'in that office to assist in the review.
The CPRRG N111 be requesting OGC thoughts concerning broader implications for Region IV based vpen OGC's review of OIA Report 86-10 and the supporting record. The Task Groups might also be aded for comments in this regard.
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- 4 Tu k Schedules The following were determinei to be the earliest possible dates for respective Groups to complete their reports
Task 1, February 10, 1987 Task P. February 10, 1987 Task 3, February 17, 1987 1
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During the week of February 2,1987, the CPRRG intends to submit an overall schedule to the EDO for approval.
John G.
avis, Chairman Comanche Peak Report Review Gr,oup j
i cc: G Arlotto, RES C. Heltemes, AEOD
.C. Paperiello, RIII J. Lieberman, OGC J. Goldberg, 0GC R. Erickson, NMSS P..McKee, IE S. Collins, RI D. Crutchfield, NRR R Hartfield, IRM l
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.l TENAS l'TILITIES GENERATING CONIPANY Log # TXX-3597 ami say o rona. o utu.Tew ne'"
File # 10115-l Decerter 3,1982 w.,.y,,,(.33.,,,
1 Mr. John T. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV RIV
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. Docket Nos. 50-445/IE Bulletin 79-14 !
Arlington, Texas 76012 4
50-446/IE Bulletin 79-14
SUBJECT:
COMANCHE PEAX STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION IE BULLETIN 79-14
Dear Mr. Collins:
In compliance with NRC IE B'ulletin 79-14, CPSES has initiated a program to insure that the as-built piping and support field conditions have been verified to be consistent with the latest seismic stress analysis.
This letter will serve to formally respond to the Bulletin.
The scope of the program has been established based upon a detailed review of Bulletin requirements and studies initiated to identify applicable piping systems and related components along with the stress analysis problems associated with the subject piping. All related documents pertaining to each stress problem have been identified and the basis for the As-Built Verification Program is fimly established.
The following defines the scope of the piping being as-built verified to satisfy requirements of the Bulletin:
SAFETY CLASS SIZE 1
All sizes 2, 3 Large bore (2-1/2" and larger).
2,3,5 High energy lines over one inch that were computer analyzed.
2,3,5 Designated piping, regardless of size, (up to and including the first anchor or teminal connection) that interacts with safety-related large bore pipe.
Note: Class 5 piping has been defined as non-nuclear safety-related lines contained in Seismic Category I structures.
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Safety Class 2 and 3 small bore (2" and smaller) non-high energy lines
~ (regardless of the analysis method used) have been excluded from the scope of the formal 79-14 verification program for the following reasons:
1..
These lines are analyzed after the piping has been installed and the as-built configuration is known./
7 2.
Support locations used in the'enalysis are field verified prior to completion of the analysis.
3.
Deviations from the as-designed support locations are design reviewed and reconciled with the analysis.
The verification process for a typical stress problem begins by assen611ng into a " package" all related documentation in the fom of piping and support construction drawings, and support location isometrics.
The documents are then field verified by site QA personnel.
Items verified are piping configuration, pipe support location and function, clea,rances between pipe and support, valve operator orientation', and any other infomation necessary to perfom the stress analysis.
Valve weights were previously verified in the CPSES Valve Weighting Program and this infomation is incleded in the document package.
The as-built' verified information is fomarded to the analysis organizations for final code analysis and piping -
certi fication.
NOTE:
_ A stress problem is defined as a stress analysis of a piping system or subsystem whose boundaries are defined by the exsistence of a fabricated anchor, simulated anchor (equipment nozzle, containment penetration), or a system of supports.
In conclusion, we are confident that the ongoing As-Built Verification Program at CPSES fully satisfies all Bulletin requirements.
i Please contact this office if additional information or clarification can be provided.
I Sincerely,
- 17. Gary u
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RJG:grr cc:
U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D.C.
20555
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' movember 26,1979, -
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i Mr Karl V. Seyfrit, Director
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U. i. Nuclear Regulatory Consnission Region IV
,RIV 611 Ryan Plaza Drive, Suite 1000 Docket Nos. 50-445/IE Bulletin 79-14 Arlington, Texas 76011 50-446/IE Bulletin 79-14 COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION RESPONSE TO IE BULLETIN 79-14 FILE NO:
10115 Dear Mr. Seyfrit.
j We are currently finalizing a procedure to address the requirements of IE Bulletin 79-14. The schedule for finalizing the procedure is consistent with the construction schedule and will be ready for implementation by December 15, 1979.
Because construction is not yet sufficiently complete to support a system inspection program, we request a waiver on the 120 day reporting require-ment.
We,'ropose to conduct our inspections and submit our reports consistent with construction progress.
Should you have any questions, please advise.
Very truly yours, l
R... Gary RJG:df cc:
U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D. C.
20555
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In Reply Esfer To RIT Docket Roa. 50-445/II Dallatia No. 79-14, Sapp 1mmast 2 MM Ballatia No. 414. Supplement 2 i <.,, W ugg,.a 7.,4..M... (
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IE Bulletin No. 79-14 Supplement 2 Date: September 7, 1979 Page 1 of 2 SEISE : A'u".75I5 F3R AS-SUILT SAFETY-RELATEI) PIPING SYSTEMS I
Dese-prien of Circumstances:
IE B d e:in 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 A-E's offices for comparison by the analyst to the seismic analysis input. p licopes,taking this approach,,A,7jg g
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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 A-E identifies a nonconformance, that the initial engineering judgment is completed in two da and that the analytical engineering evaluation is M
completed in 30 days.
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'We Visual Approximations Some licensees are visually estimating pipe lengths and other inspection elements, and have not documented which data have been ootained 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.
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Supplement 2 l
Date: September 7, 1979 l
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l Thermal lasulatio-In many areas, thermal insulation interferes with inspection of pipe support details, i.e., attachment welds, saddles, support configuration, etc.
In some areas, he presence of thermal insulation may r,esult in unacceptably large uncer+F9r4 *s for determination of the location of pipe supports.
Where * +. sal insu.lation obstructs inspection of_ support details, the insulation should be removed for inspection of a minimum of 10% of the I
obstru::ed pipe supports in both Items 2 and 3 inspections. In the Item 3 s
respense, the licensee sbeuld 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.
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Clearances l
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. Licenscas 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 i
Bulletin No. 79-02.
Any loose' anchor bolts identified during actions taken for this bulletin should be dispositioned under the requirements of IE Bulletin No. 79-02.
Other loose bolts are to be treated sa nonconformances if they invalidate the seismic analysis; however, torquing of bolts is not required.
Difficult Access Areas where inspections are required by the IE 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 IE Bulletin f
as originally issued remains unchanged.
Approved by GAO (R0072); clearance expires 7/31/80. Approval was given under a blanket clearance specifically for generic problems.
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E UNITED STATES NUCLEAR REGULATORY C0!911SSION.
OFFICE OF INSPECTION AND ENFORCEffENT WASHINGTON, D.C.
20555~
l Supplement IE Bulletin No. 79-14 Date: August 15, 1979 Page 1 of 2 SEISE" ANALYSIS FOR ' AS-BUILT SAFETY-RELATED PINNG SYSTEMS i
1 Descrip;ien of Circumstances:
IE Bulletin No. 79-14 was issued on July 2, 197(, and revised on July 18, 1979.
1 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.
To comply with the requests in IE Bulletin 79-14, it will be necessary for
'l licensees to do the'following:
2.
Inspect Part of the Accessible Piping 1
For each system selected by the licensee in accordance with Item 2 j
of the Bulletin, the licensee is expected to verify by physical 4
inspection, to the extent practicable, that the inspection elements meet the acceptance criteria.
In performing these inspections, the licensee is expected to use measuring techniques of sufficie-t 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 l
to remove thermal insulation or provide access. ' H ere physical inspection is' not practicable, e.g., for valve weights and materiais of construction, j
the license is expected to verify conformance by inspection of quality i
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 deteraine 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). Were 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-1 ments for content and schedule as given in Item 2 and 3 of the Bulletin.
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Date: August 15, 1979 Page 2 of 2 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 repcrt the results in accordance with the requirements for content and I
schedule as given in Item 3 of the Bulletin.
4A. Evaluate.Noaconforaanoea Vi inel rppers or the ana
- ion, l
continueds%" expeEt' pon.ed to perform the evaluation by using the same the licensee is 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 not perform its intended function during a design basis earthquake, 7
must promptly, comply with applicable action statemen *ta.and r +- M g C
requirements inthe Tegg,gcificatti6as; -
4B.
Submit Nonconformance Evaluations The licensee is expected to submit. evaluations of-s and, where the, licensee concisdes'cthet the" i
.mp 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.
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, f
the licensee is expected to revise design documents and seismic analyses j
in a timely manner, j
i The schedule for the action and reporting requirements given in the Bulletin l-as originally issued remains unchanged.
Approved by GAO (R0072); clearance expires 7/31/80. Approval was given under a blanket clearance specifically for generic problems, i
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Staserely, JJ1V.Seyfritll6*v'h
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t IE Bulletin No. 79-14 Revision 1 Date: July 18, 1979 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-l tion of safety-related piping systems. The safety *related piping includes l
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 2-1/2-inches in diameter and greater and to seismic Category I pipina.
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 f)did safety-related systems, utilizing piping 2-1/2 inches in diameter and greater, meets design require-ments.
j Specifically, each licensee is requested to:
I 1.
Identify inspection elements to be used in verifying that the seismic analysis input information conforms to the actual configuration 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 coc-formance to the seismic analysis input information set forth in design documents.
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 Bulletin 79-02); pipe attachments and valve and valve operator locations and weights (excluding those covered in IE Bulletin 79-04).
Within 60 days of the date of this letin, submit a description of the results of this inspection.
- Normally accessible refers to those aress of. the plant which can be entered during reactor operation.
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20555 IE Bulletin No. 79-14 Date: July 2, 1979 Page 1 of 3 i
SEISMIC ANALYSES FOR AS-BUILT SAFETY-RELATED PIPING SYSTEMS e.
Description'of Circumstances:
Recently two issues were identified which can cause seismic analysis of safety-i related piping systems to yield nonconservative results. One issue. involved-algebraic summation 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 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 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 sta'ff 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.
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9 IE Bulletin No. 79-14 Date: July 2, 1979 Page 2 of 3 a
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-rrlated piping systems. The safgty-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. For older plants, where Seismic Category I require-ments did not exist at the tima of licensing, it must be shown that the actual configuration of these safety-related systems meets design require-ments.
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 configuration of safety-related systems. For each safety-related system, submit a list of design documents, including title, identifiestion 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 Lequential 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 documents.
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 Bulletin 79-02); pipe attachments 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 nonconformances are found which affect operability of any system, the licensee will expedite completion of the inspection described in Item 3.
- Normally accessible refers to those areas of the plant which can be entered during reactor operation.
---, ~
6
i i
IE Bulletin No. 79-14 Date: 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.
j Within 120 days of the date of this bulletin, submit a description of the-results of this inspection.
4.~
If nonconformances are identified:
/
b.
Submit an evaluation of identified nonconformances on the validity l
of piping and support analyses as described in the Final Safety l
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 descriptions of the results of reanalysis, c.
In lieu of b, submit a schedule for correcting nonconforming systems I
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 1
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 j
Director of the Office of Inspection and Enforcement and the Director j
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 i
under a blanket clearance specifically for generic problems.
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01523/E7 1002 NRC-WILLSTE NO.012 003 L, %*b
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~, NUCLEAR REGULATORY COMMISSION
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January 21,1987 3
N(MORANDlM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards PHM:
Victor Stallo, Jr.
Executive Director for Operations SU8JtcT:
01A RtPORT REVitW: 0!A FILE #86 ESTA8L!SHMENT OF REV!EW GROUP 1
In order to resolve issues which 0!A Report 8610 has raised, I am taking the following action:
1.
You are assigned as Chairman of a Review Grou$0 and recommend resolution to evaluate the safety signiffeance of CIA findings in CIA File #86-of the items.
G. Arletto, J. 64elteses and C. Papertello are assigned as members of the Group. This effort is not intended to duplicate the CIA effort.
2.
The task of the Review Sroup is to review the technical issues identified in O!A report 8610 and to detemine and document in a re > ort to me
()thesafetysijnificenceofthoseissuesforComancheleak,f.e.,
ther actions s%uld be taken to rectify any unsafe conditions; (2) whether the issues when identified were a appropriately handled as to process and disposition and, (3) detemine wiether the current augmented review and inspection effort at Comanche Peak is sufficient to compensate for any identified weakness in Region IV's Q/A inspection programs.
3.
In addition, you should (1) review the purpose and significance of NRC Fors 766 and make appro priate recommendations concerning its use.
- 2) without expanding tie tasks described in paragraph 2, offer me any nt you may have on whether it is likely that there are broader 1 cations in Region !Y.
4.
You may task other NRC staff or utilire contractors as required, although I recomend that you keep your requirements to the minimum possible.
hecessary funds will be rade available at your request by RM.
T. Westerman and H. Phillips will be catailed to support your independent review on a full-time basist other members of RIY are at your full disposal as you may require. Similarly. IE and NRR staff working on Comanche Peak are available to assist.
Yf0&h?hT
p c1', 23. 'E7 15:04 l4FC-LJILLSTE I40.012 004 W'
2 5.
Copies of the report and enclosures will be provided to you by separate cover.
6.
I would like to have your report in my hands by February 20, SN7.
l l
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Executive Director for Operation cci E. Beckord R. Marttn
- 4. Arlou a I
R. Scroggins J. Taylor H. Denton J. Neppler C. Peperiello C. Heltemes i
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- 15:Cu NRC-(J1LLSTE NO.012 005
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January 21, 1987 l
MEMORANDlM FOR: Robert Martin Regional Administrator FRON:
Vfcter Stello. Jr.
Executive Director for Operations
SUBJECT:
0!A REPORT REVIEW. 0!A FILE #86 10 I have reviewed your meno to me of December 16,1996 which outlines your pnposals for dealing with actions necessary to respond to the points raised 1n the subject report.
ty separate meno (see Enclosure 1) ! have established a Aaview Group with John Davis. Director. Office of Nuclear Material Safety and Safeguards as Chaiman to conduct the review of technical issues as Wu recopenended.
I appreve your suggestion to detail T. Westerman and H. >hillips full-time to be at the disposal of the Review Aroup until their work is complete on or a%ut January 30,1967.
i
! approve the actions you recomeand in regard to initiating remedial action within Region IV staff to assure a proper understanding of regional policies in regard to resolution of staff / supervisor problems supervisory responsibilities and to develop an improved inspection report tracking You will advise me separately of specifics of implementation of j
- system, j
these actions.
I am withholding a decision on Allegation ! (Management issues). Alleestion 11 j
(the adequacy of the inspection program st CPES) and Allegation III (Data documented in Inspectors Reports) until the completion of the Review Group's efforts.
cristeal nasnet by 21stor ste19 Victor Stallo. Jr.
Executive Director for Operations inclosure:
As statad 01str<bution:
Y5tero ED0 2476 JRoe Sniezek TRehm
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- V llo WAME :TRehe DATE :1/21/87
- lls)/87 OFFICIAL RECORD COPY
301 427 4403 r
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01/2347 14:59 PEC-WILLSTE NO.011 001 --
UNITED STATES 4
I t
NUCLEAR REGULATORY COMMISSION l
WA4MINGTON, D C. 30006
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FACSIMILE SERVICE REQUEST k!bb!97 DATE "P1 EASE USE DARK PEN D. c tt UTc4Fler O iMA Y*92 'M*}j"
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MESSAGE TO:
CITY & STATE TELECOPY NUMBER VERIFICATION NUMBER NO. OF PAGES EXCLUDING COVER SHEET RETURN COPIES YES ( )
NO ()
b0 b b It t cK$dA/
Y1/H MESSAGE FROM:
TELECOPY NUMBER RAPIFAX AUTOMATIC 301-427-4403 3M VRC AUTOMATIC VERIFICATION NUMBER 301-427-4072 BUILDING WILLSTE OFFICE PHONE MAIL STOP CLASS OF SERVICE OVER NIGHT 4 HOUR 1 HOUR
__ !> MEDIATE i
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.._._._--.______.___-.---.--w
01'23'E7 1":03 NPC-tJlLLSTE NO.012 002
.COMANC t. /EA_K OIA__ REPORT 86-10 REVIEW GR,,/ (CPRRG) 5520 Local NAME TELEPHONE MAIL STOP Node Name Address
]
John G. Davis, NMSS, Chairman 42-74063 SS-958 NRCADMW BONNIEP l
44-37995 NL-005 NRCRES MCCAUSLA
'. AJ0D 49-24484 EWS-263 NRCIE AEOD 6,#
FTS-388-5517 R III NRCRI!I LEAD 0) t.
49-28679 MNBB-9604 NRCELD CONNIET
/
49-27619 MNBB-9604 NRCELD CONNIIT Legal Advisors Robert A. Erickson, NMSS 42-74194 55-881 NRCADMW BEVER;YC Coordinator
- N' 49-29650 EWS-346 NRCIE LEA 000 i
Task Group 1, Leader h
FTS 488-1225 R-I NRCRI LEAD 09 Task Group 2. Leader
(
49-27492 542 NRCOPLA PAUL Task Group 3, Leader PRINCIPAL CONTACTS FTS-728-8225 R-IV NRCRIV LEADOP 49-27475 110 NRCDPLA SIMS 49-27397 EWW-322 NRCIE IEDIR OTHER CONTACTS AND INTERESTED PERSONS Eric Beckjord, RES 44-74341 NL-005 Lawrence J. Chandler, 0GC 49-28658 NMBB-9604 NRCELD ANNIEB Paul S. Check, R-IV FTS-728-8222 R-IV NRCRIV LEADOP Harold Denton, NRR 49-27691 P-433 Alexander W. Dromerick, IE 49-24784 EWW-507 Ramon E. Hall, R-IV FTS-728 8182 R-IV NRCRIV LEADOP Eric H. Johnson, R-IV FTS-728-8106 R-IV NRCRIY LEAD 0P James G. Kep)1er, R-III FTS-388-5181 R-!!!
NRCRIII LEADOP James E. Kon clin IE 49-29656 EWS-312 NRCIE VI George A. Mulley, Jr., CIA 49-24451 EWS-461 Thomas E. Murley, R-I FTS-488-1299 R-I NRCR!
LEADOP James G. Partlow, IE 49 24614 EWS-360 NRCIE EILEEN H. Shannon Phillips, R-IV (817) 897-2201 R-IV NRCRIV LEAD 0P Thomas A. Rehm, EDO 49-27781 MNBB-6209 NRCRM EDO Ronald M. Scroggins, IRM 49-24750 MNBB-12109 R. Lee Spessard, IE 49-28833 EWS-350 NRCIE EILEEN Stuart A. Treby, ELD 49-28661 MN88-9604 WRCELD
! LEAD 0P Annette Vietta-Cook, NRR 49-28525 110 NRCDPLA ~SIMS Richard H. Vollmer, NRR 49-27726 P-428 NRCNRR MILLER Thomas F. Westerman. R-IV FTS-728-8145 R-!Y NRORIV LEAD 0P REVIEW GROUP MAILING' LIST 01/21/87
._ -_____-______