ML18054B362

Project Plan:Ie Bulletin 79-14 Safety-Related Piping Reverification Program.

ML18054B362
Person / Time
Site:	Palisades
Issue date:	01/10/1990
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18054B361	List: ML18054B360 ML18054B362
References
IEB-79-14, PROC-900110, NUDOCS 9001180163
Download: ML18054B362 (7)

Text

OC0190-0002-NL02

• ENCLOSURE Consumers Power Company Palisades Plant Docket 50-255 PROJECT PLAN IE Bulletin 79-14

• SAFETY-RELATED PIPING REVERIFICATION PROGRAM January 10, 1990 6 Pages 1.0 2.0 3.0 4.0 *

• SAFETY-RELATED PIPING REVERIFICATION PROGRAM TABLE OF CONTENTS Topic INTRODUCTION

& SCOPE PROJECT DESCRIPTION SPECIFICATIONS

& PROCEDURES 3.1 PROJECT ADMINISTRATION 3.2 PIPING & SUPPORT ANALYTICAL SPECIFICATIONS 3.3 WALKDOWN PROCEDURE 3.4 RECONCILIATION PROCEDURE 3.5 OPERABILITY GUIDELINES

SUMMARY

OF CONTROLS ATTACHMENT 1 PROJECT MILESTONES OC0190-0002-NL02 1 1 3 3 3 3 4 4 4

• SAFETY-RELATED PIPING REVERIFICATION PROGRAM

1.0 INTRODUCTION

AND SCOPE During NRC inspections conducted at the Palisades Plant in August, September and October, 1989, NRC Region III inspectors identified a* number of significant concerns relative to *the adequacy of Consumers Power Company's (CPCo) response to. IE Bulletin 79-14 "Seismic Analysis for As-Built Safety-Related Piping Systems." CPCo has initiated a Safety-Related Piping Reverification Program to reverify the seismic design adequacy of safety-related piping and larger at the Palisades Plant. The program will involve (1) confirmation that piping isometric and pipe supp9rt drawings reflect the installed configuration and (2) assurance that the piping stress analysis and pipe support calculations*

reflect the installed configurations and are in conformance with the licensing basis (FSAR). A reconciliation process will be established to address those areas found to be different between the design and as-built conditions.

Those ditions found to be in nonconformance with the licensing basis will be brought into compliance in accordance with Consumers Power Company letter dated November 21, 1989. Attachment I displays the anticipated miles-.. tones for the project. 2.0 PROJECT DESCRIPTION 1 The Safety-Related Piping Reverification Program will involve (1) physical walkdowns, (2) piping stress analysis reconciliation and verification, and (3) pipe support calculation reconciliation and.verifications.

The program is divided into two phases. Phase I represents a sample of piping selected to assure that primary coolant system (PCS) inventory is maintained, that PCS inventory can be borated to shutdown concentrations, and that redundant mechanisms exist to remove decay heat. The following piping systems or portions of piping systems are covered in Phase I: Piping Number of Containment System Linear Feet Hangers/Supports Inside(I)/Outside ESS 947' 61 I AFW 309' 24 I AFW 737' 72 0 HPSI 206' 19 I HPSI 265' 25 0 LPSI 586' 51 I PCS (PORV) *693' **86 I I Subtotal 2741 231 0 Subtotal 1002 97 Total 3745 328 OC0190-0002-NL02 (0)

' ; * *

• 152' of new pipe installed during PORV modifications in 4th quarter, 1989 will not be reverified by walkdown during 79-14 reverification, but the_ analyses will be reverified.

• 2 ** 33 supports installed or modified during PORV modifications in 4th quarter, 1989 will not be reverified by walkdown during 79-14 cation, but the analyses will be reverified.

It is CPCO's intent to attempt inspection of all supports identified for Phase I. During the Spring, 1990 Maintenance Outage, radiation exposure limits will be established to define accessibility.

Those supports not inspected in the Spring will be walked down in the Steam Generator ment Outage later in 1990unless radiation doses or physical configurations prohibit.

Piping and support attributes covered by insulation will also be inspected by removing the insulation on a selective basis during the Spring Outage. The results of these inspections will determine the extent of insulation removal required for the remainder of lines in Phase I. Consumers Power will identify the scope of Phase II, which is the remainder of the and larger safety-related piping, based on the results of the Phase I reverifications.

Attachment I shows the current milestones for implementation of Phase I and the expected dates that Phase II scope will be determined.

The physical walkdown will be used to verify attributes such as: 1) piping geometry and dimensions

2) pipe support and component locations, orientation, and configuration

3) anchor bolt and baseplate conditions

4) welded attachments

5) gaps and clearances

6) general condition of piping, supports, attachments, fasteners, etc A description of the walkdown procedure is provided in*section 3 of this plan. Piping stress analysis verification will consist of model verification for piping as-built configuration as well as other critical design inputs such as: loading conditions; design and operating pressures, temperatures, and mechanical loads. Support calculation verification will involve evaluation of design parameters, conclusions, and reconciliation with the as-built support configuration and piping stress Procedures and specifications addressing the piping stress analysis and support calculation verification and reconciliation to the as-built configuration are described in Section 3 of this plan. Technical oversight of the safety-related piping reverification effort will be provided by a qualified individual(s) independent from the engineering organization(s) performing the effort. This oversight will include technical review of a sample of the piping stress analysis and pipe support calculation verification packages as well as overseeing the walkdown process. OC0190-0002-NL02 f *

• The documentation and records generated as a result of this project will be processed in accordance with existing Palisades document control procedures.

3.0 SPECIFICATIONS

& PROCEDURES 3 The safety-related piping reverification project will be controlled by the following specifications and procedures:

3.1 Project Administration This procedure provides an overview of the administrative and ment controls associated with the project. Some of the topics addressed are: 1) Scope of Project 2) Division of Responsibilities

3) Governing Documents

4) Discrepancy Identification and Reporting

5) Document Preparation

& Control 6) Resolution of Inaccessible Items 7) Independent Verification

8) Personnel Training & Qualification

9) Project Budgeting and Cost Control 10) Project Scheduling

& Status Reporting

11) Information Request Process 3.2 Piping and Support Analytical Specifications These documents specify the criteria to be used in the reverification analysis of the safety-related piping equal to or greater than and the associated support calculations.

The specifications were developed addressing analytical methodology as well as design ters and acceptance criteria.

3.3 Walkdown Procedure The Walkdown Procedure prescribes the technical requirements and instructions for gathering and documenting field data sufficient to evaluate the adequacy of the as-built conditions of the related piping systems. Some of the specific topics covered are: 1) Description of dimensional measurements to be made 2) How to record data 3) Walkdown checklist

4) Identification of the specific attributes to verify for supports, attachments, valves, etc 5) Listing of tools and instruments required OC0190-0002-NL02 f*. *

• 4 3.4 Reconciliation Procedure The Reconciliation Procedure prescribes the technical requirements and procedural guidance to ensure compatibility between design stress analysis and support calculations; the as-installed configuration, and the licensing basis. Evaluation of pipe supports, documentation of deviations, evaluation and basis for acceptance, preparation of reports and calculations are integral to the process. Some of the specific topics covered in this procedure are: 1) Initial screening to identify deviations between the design stress analysis, as-installed configuration and licensing basis. 2) Classification of deviations/acceptance criteria 3) Detailed review of differences between design stress analysis, as installed configuration and licensing basis 4) Detailed review of differences between existing suppo+t calcula-tions, as-installed configuration and licensing basis. 5) Re-analysis methodology

6) Operability evaluations

7) Data sheet and report preparation 3.5 Operability Guidelines This document establishes criteria (submitted December 1, 1989 and approved by the NRC) for determining justification for continued operation when encountering discrepancies in as-built safety-related piping and associated supports.

The criteria would permit operation for a interim period only. Modification will be made which returns the system to within FSAR allowables.

4.0

SUMMARY

OF CONTROLS Within the framework of the previously identified procedures, there are a number of controls-put in place to ensure a quality reverification program. The following is a listing of the major controls:

1) Independent verification of walkdowns, which will consist of independently re-performing certain walkdowns selected on a representative sample size. 2) Engineering review of field data packages 3) Independent Party engineering review of piping and support analytical reconciliation activities

4) Single point of contact for reporting of discrepancies and abnormalities to review for possible trends and feedback to engineering

5) Use of established plant programs and involvement of corrective action review board (CARB) and the plant review commitee. (PRC) 6) Development of Quality Plan by Bechtel Power Corporation for their involvement in this project to include: Technical Audit, Technical Review, and Schedule for Audits and Reviews -7) Involvement by the Palisades Quality Assurance and Quality Control organizations throughout the preparation, execution, and resolution phases of the project. OC0190-0002-NL02 j." *

• ATTACHMENT.

1 SAFETY-RELATED PIPING REVERIFICATION PROGRAM PROJECT MILESTONES ITEM FINALIZE PROJECT PROCEDURES BEGIN WALKDOWNS OUTSIDE CONTAINMENT CONTINUE WALKDOWNS INSIDE CONTAINMENT BEGIN PIPE STRESS AND SUPPORT CALCULATION VERIFICATIONS COMPLETE WALKDOWNS OUTSIDE CONTAINMENT COMPLETE REMAINING WALKDOWNS INSIDE CONTAINMENT EVALUATE PHASE I RESULTS AND IDENTIFY PHASE II SCOPE -OC0190-0002-NL02 DATE JANUARY, 1990 MARCH, 1990 CONCURRENT WITH SPRING OUTAGE APPROX 2 WEEKS AFTER STARTING WALKDOWNS JULY, 1990 CONCURRENT WITH S/G REPLACEMENT OUTAGE DECEMBER, 1990