ML17352A081

Discusses Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors USI A-46, Generic Ltr 87-02

ML17352A081
Person / Time
Site:	Turkey Point
Issue date:	06/23/1993
From:	Raghavan L Office of Nuclear Reactor Regulation
To:	Goldberg J FLORIDA POWER & LIGHT CO.
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, TAC-M68303, TAC-M68304, TAC-M69483, NUDOCS 9306300220
Download: ML17352A081 (10)

Text

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Docket Nos. 50-250, 5u-251 and 50-335 June 23, 1

Hr. J.

H. Goldberg President - Nuclear Division Florida Power and Light Company P. 0.

Box 14000 Juno

Beach, Florida 33408-0420

SUBJECT:

VERIFICATION OF SEISMIC ADEQUACY OF MECHANICAL AND ELECTRICAL EQUIPMENT IN OPERATING REACTORS-UNRESOLVED SAFETY ISSUE (USI) A-46, GENERIC LETTER (GL) 87-02 TURKEY POINT UNITS 3 AND 4, ST.LUCIE UNIT 1 (TAC NOs.

H68303, H68304 and H69483)

By letter dated September 8,

1992, you submitted responses to our March 18, 1992 request for additional information (RAI) relating to Unresolved Safety Issue (USI) A-46, as delineated in Generic Letter (GL) 87-02 for the St.

Lucie 1 and Turkey Point Units 3 and 4.

On the basis of our initial review of your submittal, we find that in certain cases your responses do not adequately address our March 18, 1992 RAI and in other cases we have identified the need for additional information or clarifications.

Attachment 1 identifies areas for which we require your additional response.

In addition, during the April 6, 1993 meeting with the staff, you agreed to reevaluate certain programmatic issues relating to shutdown duration, definition of safe-shutdown path and excluding relay evaluation from the scope of the USI A-46 program.

To enable us to continue with our review effort, we request your expeditious response to both these programmatic issues and those identified in Attachment 1.

This requirement affects fewer than ten respondents, and therefore, it is not subject to Office of Management and Budget review under P.L.96-511.

If you have any questions regarding this matter, please contact us at (301) 504-1471 or (301) 504-1483 (Original Signed By)

J. Norris, Sr. Project Manager Project Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc w/enclosure:

See next page Distribution See next page L. Raghavan, Project Manager Project Directorate II-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation OFC LA:PD II-2 NAME ETana 87<

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Florida Power and Light Company CC:

Jack Shreve, Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, Florida 32399-1400 Senior Resident Inspector St.

Lucie Plant U.S. Nuclear Regulatory Commission 7585 S.

Hwy AIA Jensen

Beach, Florida 34957 Mr. Joe Myers, Director Div. of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Harold F. Reis, Esq.

Newman 5 Holtzinger 1615 L Street, N.W.

Washington, DC 20036 John T. Butler, Esq.

Steel, Hector and Davis Miami, Florida 33131-2398 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. Thomas R,L. Kindred County Administrator St.

Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering, Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32399-0700 Regional Administrator, RII U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Mr. R.

E. Grazio Director, Nuclear Licensing Florida Power and Light Company P.O, Box 14000 Juno

Beach, Florida 33408-0420 Mr. J.

H. Goldberg President Nuclear Division Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 33408-0420 Mr. Thomas F. Plunkett, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102 Senior Resident Inspector Turkey Point Nuclear Generating Station U.S. Nuclear Regulatory Commission P.O.

Box 1448 Homestead, Florida 33090 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304

Memorandum Dated June 2

1 Distribution

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& Local PDRs PDII-2 RF S. Varga G. Lainas H. Berkow E.

Tana J. Norris L. Raghavan J.

Norberg OGC ACRS (10)

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ATTACHMENT 1 RE VEST FOR ADDITIONAL INFORMATION RAI REGARDING FLORIDA POWER AND LIGHT COMPANY'S RESOLUTION OF US I A-46 FOR ST.

LUCIE UNIT 1

AND TURKEY POINT UNITS 3 AND 4 Item No.

5 of the March 18, 1992 RAI requested a listing of the safe-shutdown path equipment and equipment categories, (including those inside containment, which are part of the safe-shutdown

path, but which have been excluded from the seismic adequacy verification program) and detailed technical justification for the exclusions unless they were in accordance with GL 87-02.

In response, you provided Piping and Instrument

Diagrams, along with associated equipment lists, which identify both the items included in the USI A-46 walkdowns and all items which were excluded (Enclosure A to your September 8,

1992 letter).

You stated that the exclusions consist of equipment which are either not within the lesser scope of FPL's program, passive items, or items excluded by the conditions set by GL 87-02.

Although you have identified passive equipment

items, you have not provided clear justification for excluded equipment (e.g.,

there were no valves included in the walkdowns).

Excluding an equipment item solely on the basis that the item is not within the lesser scope of FPL's program is not acceptable.

(Note:

We recognize that the Auxiliary Feedwater System was previously inspected as part of GL 81-14, and was, therefore, exempt from further review.)

Please provide specific technical justification for excluding individual pieces of equipment.

2.

Your equipment capacity vs.

demand evaluations were performed on a plant-specific basis using the Senior Seismic Review and Advisory Panel (SSRAP)

Bounding Spectrum instead of an equipment-specific basis.

In order to use the SSRAP Bounding Spectrum for representing an equipment item's seismic capacity, you must demonstrate, on an equipment-specific

basis, that each of the equipment items, for which a seismic capacity vs.

demand evaluation is required, is similar to an equipment category within the scope of the experience data base.

Provide criteria and procedures, or references for this demonstration.

The SSRAP Report, Revision 4, dated February 28, 1991, provides partial descriptions of the experience data base equipment categories and includes several caveats and exclusions for each equipment category.

Our review of the Seismic gualification Utility Group's Generic Implementation Procedure (GIP-2) for resolving USI A-46 has concluded that the equipment descriptions (and the caveats and exclusions) provided in the SSRAP report were not complete.

For acceptable descriptions of

equipment categories and specific caveats pertaining to each equipment category for using the experience data

base, refer to Appendix B of GIP-2 as corrected on February 14,

1992, and as supplemented by the staff's Supplementary Safety Evaluation Report No.

2 dated Hay 22, 1992.

3.

In response to the March 18, 1992 RAI, Item 9, you indicated that evaluation of the seismic adequacy of the above-ground vertical tanks is included in your USI A-46 implementation program in order to resolve USI A-40.

However, the adequacy of ring foundations for the steel tanks is not addressed in your USI A-46 program.

The provision for checking the adequacy of tank-foundations is a part of the resolution of USI A-40, as reflected in Section II.14.i of SRP 3.7.3 dated August 1989.

Please provide information relating to the adequacy of all of the applicable tank-foundations.

4.

In response to Item No.

11 of the Harch 18, 1992 RAI, you indicated that, with the exception of torque tightness testing, your equipment anchorage criteria would be in accordance with Volume 1 of EPRI NP-5228, Revision 1, dated June 1991.

Torque tightness checking is one of the most important attributes in ensuring the integrity of the bolted expansion anchorages.

You did not provide any justification for excluding torque tightness testing from your program.

Further, your Final Report references a preliminary version of EPRI NP-5228 dated May 1987 and it is also referenced in many of the Appendix C supporting calculations.

We have not endorsed the preliminary version of the EPRI report.

Please describe your methodology to ensure torque tightness checking of equipment anchorages.

Note that a random sample testing of the affected anchorages would be acceptable.

Please revise your Final Report to reflect compliance to the final version of EPRI NP-5228, Revision 1.

5.

Final Report Section 4.2.3 indicates a factor of safety (FS) of 3.0 for all expansion anchors.

This position is inconsistent with EPRI NP-5228, Revision 1, which, in some cases, specifies an FS greater than 3.0 for expansion

anchors, such as in cracked concrete.

Please justify the use of a single FS of 3.0 for all expansion anchors.

6.

With respect to the evaluation of equipment anchorages during the walkdowns, Final Report Section 4.2.3, page 19, states "When the anchorage was obviously rugged,

[Seismic Review Team]

SRT judgement was used to assess anchorage adequacy.

This judgement was performed in the context of the above criteria."

Please identify the specific criteria used to make such judgments and clarify whether the anchorage criteria is per EPRI NP-5228, Revision 1.

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Final Report, Appendix A, Walkdown Procedure, page 6 discusses two levels of ",screening-out" equipment anchorages during the walkdowns.

For the first screening, you state that the anchorage was evaluated to determine if it is in conformance with the design basis for the plant.

Your seismic design basis discussion (Final Report, Section 3.4 page 9) indicates that there were no specific commitments with regard to the seismic design of anchorages for mechanical and electrical equipment.

Please explain in detail how the first "screening-out" of equipment anchorage was performed (e.g.,

was the anchorage screening-out based on the criteria in NP-5228, Revision 17).

Discuss the SRT's use of judgment for the second level "screening-out" of equipment.

Identify and describe in detail the specific criteria used by the SRT to make these judgments.

Please justify the assumption of concrete compressive strength greater than or equal to 3500 psi used in the anchorage calculations.

Note that for concrete strengths below 3500 psi, EPRI NP-5228, Revision 1 requires application of a capacity reduction factor.

The equipment data sheets (EDS) completed by the SRT do not specifically address many of the anchorage concerns discussed in EPRI NP-5228, Revision 1.

The EDS do not specify checks for such items as anchor

spacing, free-edge

distance, gaps under bolted anchorage, effects of prying action, etc.

Please explain how the capacity reduction factors for closely-spaced

anchors, near-edge

anchors, cracked concrete, etc.,

which are described in EPRI NP-5228, Revision 1, were considered during the walkdowns and in the anchorage evaluations.

Final Report, Reference 13, requires comparison of applicable in-structure response spectra (IRS) with 1.5 times the bounding spectrum.

Please provide documentation of these comparisons for the critical equipment.

On the basis of the

IRS, (Section 4.2.3 Final Report) for assessment of anchorages, you propose to use 0.5g and 1.2g demands for equipment natural frequencies above 4.5 Hz, and below 4.5 Hz, respectively.

However, for equipment where IRS are not available, you propose to use a

horizontal acceleration of 0.3g per SSRAP.

Please provide justification for use of different demand values in assessing the anchorage capacity.

The adequacy of the above-ground vertical tanks has been assessed by considering all anchor bolts to be subjected to varying amounts of tension loads and the small area of the tank shell resisting the compression load.

Please provide an assessment of the buckling mode of failure of tank shells.

Also provide an assessment of shear stresses on anchor bolts and tank shells considering the vertical component of the postulated earthquake.

13.

Please demonstrate the adequacy of the safety-related electrical raceways (cable trays and conduits) and their supports, which is within the scope of the original GL 87-02.

Provide your plans for resolving this item of the Generic Letter.

14.

In response to Item 8 of the March 18, 1992 RAI relating to the development of IRS, you believe that providing this information is not within the scope of USI A-46.

However, we understand that you would be willing to discuss this information as divorced from the resolution of USI A-46.

To assure that proper procedures are used in verifying the adequacy of the equipment, we plan to discuss this issue during future audits of the St.

Lucie Unit 1 and Turkey Point Units 3 and 4 USI A-46 programs.

15.

Please revise the Final Report to delete references to ACI 349, Appendix B, relating to anchorage criteria as per your response to Item No.

12 of the March 18, 1992 RAI.