ML18067A579
| ML18067A579 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/19/1997 |
| From: | Robert Schaaf NRC (Affiliation Not Assigned) |
| To: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, TAC-M69468, NUDOCS 9706230321 | |
| Download: ML18067A579 (8) | |
Text
"' Mr. Thomas C. Sardine.
Licensing Manager Palisades Plant 47780 Blue Star Memorial Highway Covert, Ml 49043 June 19, 1997 *
SUBJECT:
PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED SAFETY ISSUE A-46 (TAC NO. M69468)
Dear Mr. Sardine:
In your letter of May 23, 1995, you provided the Palisades plant-specific summary report on the resolution of unresolved safety issue (USI) A-46 in accordance with Consumers Power Company's (CPCo) commitment to Generic Letter (GL) 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46." The NRC staff reviewed the summary report and determined that additional information was necessary to complete our review of your A-46 response and issued a request for additional information (RAI) on May 31, 1996.
The staff has reviewed your September 27, 1996, response to the RAI and has determined that additional information is required in order to complete our review. You are requested to respond to the enclosed questions within 90 days from the date of this letter. If you have any questions regarding this request, you may contact me at (301) 415-1312.
9706230321 6~836~55
~DR ADOCK PDR Docket No. 50-255 Sincerely, ORIGINAL SIGNED BY Robert G. Schaaf, Project Manager Project Directorate 111-1 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/encl:
See next page DISTRIBUTION:
See attached page DOCUMENT NAME: G:\\WPDOCS\\PALISADE\\PAL69468.RAI To receive a copy of this document, indicate in the box C =Copy w/o attachment/enclosur E =Copy with attachment/enclosure N
= No copy
' lb ~
OFFICE PM:PD31 LA:PD31 NAME RSchaaf :d CJamerson DATE (o / tf /97 b I 5 /97
\\
Mr. Thomas C. Bordine Consumers Power Company cc:
Mr. Thomas J. Palmisano Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish Vice President & Secretary Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michig~n 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Palisades Plant
- U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant
.27782 Blue Star Memorial Highway Covert, Michigan 49043 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 Gerald Chernoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street,~- W.
Washington DC 20037 Michigan Department of Attorney General Special Litigation Division 630 Law Building P.O. Box 30212 Lansing, Michigan 48909 April 1997
' REQUEST FOR ADDITIONAL INFORMATION FOR THE PALISADES PLANT DATED: June 19, 1997 DISTRIBUTION:
Docket File (50-255)
PUBLIC PD# 3-1 *Reading J. Roe J. Hannon L. Marsh C. Jamerson R. Schaaf A. Lee OGC ACRS B. Burgess, Riii
REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO GENERLC LETTER 87-02 PALISADES NUCLEAR PLANT
- 1.
Regarding the use of 1.5 times the plant safe-shutdown earthquake (SSE) ground response spectra as a realistic estimate of seismic demand, the staff considers that your September 27, 1996, response did not adequately address the staff's information request. During an August 28, 1996, NRC meeting with the Seismic Qualification Utility Group (SOUG), the staff elaborated on its concern and the primary focus of the request for additional information (RAI) question. As a result of considerable discussion on the subject, the staff agreed to clarify the question. The following represents the *revised question which is being forwarded to affected USI A-46 licensees for response:
Referring to the in-structure resoonse spectra provided in your 120-day-response to the NRC's request in Supplement No. 1 to Generic Letter fGLJ 87-02. dated May 22. 1992. the following information is requested: *
(a)
Identify structure(s) which have in-structure response spectra (5%
critical damping) for elevations within 40 feet above the effective grade, which are higher in amplitude than 1.5 times the SOUG Bounding Spectrum.
(b)
With respect to the comparison of equipment seismic capacity and seismic demand, indicate which method in Table 4-1 of GIP~2 was used to evaluate the seismic adequacy for equipment installed on the corresponding floors in the structure(s) identified in Item (a) above. If you have elected to use method A in Table 4-1 of GIP-2, provide a technical justification for not using the in-structure response spectra provided in your 120-day response. It appears that some A-46 licensees are making an incorrect comparison between their plants' SSE ground motion response spectrum and the SOUG Bounding Spectrum.
The SSE ground motion response spectrum for most nuclear power plants is defined at the plant foundation level. The SOUG Bounding Spectrum is defined at the free field ground surface. For plants founded
. on deep soil or rock, there may not be a significant difference between the ground motion amplitudes at the foundation level and those at the ground surface. However, for sites where a structure is founded on.
shallow soil, the amplification of the ground motion from* the foundation level to the ground surface may be significant.
ENCLOSURE
- (c)
For the structure(s) identified in Item (a) above, provide the in-structure response spectra designated according to the height above
- the effective grade. If the in-structure response spectra identified in the 120-day response to Supplement No. 1 to Generic Letter 87-02 was not used, provide the response spectra that were actually used to verify the seismic adequacy of equipment within the structures identified in
- Item (a) above. Also, provide a comparison of these spectra to 1.5 times the Bounding Spectrum.
- 2.
As noted in the peer review letter provided with your September 27, 1996, submittal, the peer reviewers did not perform walkdowns of inaccessible areas due to radiological concerns, including the containment and a few areas in the auxiliary building which are radiologically controlled. Discuss your walkdown approaches for equipment items listed in the SSEL [safe-shutdown equipment list] that are located in the inaccessible areas, and the basis of concluding that they are adequately installed and hence seismically adequate.
- 3.
As indicated in the peer review letter, a number of observations were made by the peer reviewers for the consideration of the A-46 seismic review team. The staff has reviewed the list of observations identified in the letter and found that no documentation regarding resolution of the following items has been provided:
(a)
The local shear stress effect (tearing) of the steel skid underneath the steam turbine-driven auxiliary feedwater pump (P-SB);
(b)
Lack of spacers between fire pump batteries (ED-36 & -37 A/B C/D) and lack of restraint for the wooden battery cover; (c)
Potential for impact due to proximity of the Instrument AC Bus Transfer Switch Panel (EY-50) to ED-16; (d)
Potential interaction hazard for the SIRW [safety injection and refueling water] tank due to collapse of a vent stack adjacent to the containment; and (e)
"Seismic housekeeping" items due to lack of restraint of carts, anchorage of tables and similar components, as identified throughout the control room.
You are requested to describe any corrective measures taken to address each of the above peer reviewers' observations and confirm their completion to the NRC staff.
- 4.
Your September 27, 1996, response to Question 6, regarding outlier resolution, is not acceptable to the staff. You are requested to elaborate on your decision to defer the resolution of identified outliers and your evaluation in support of the conclusion that the licensing basis for the plant will not be affected by your decision. Specifically, you are requested to provide the justification for assuring operability of the affected systems and components while a number of safety-related components in the safe shutdown path have been identified as outliers, thus rendering their seismic adequacy questionable and their conformance to the licensing basis uncertain.
- 5.
Your September 27, 1996, response to Question 3, regarding the proposed use of the seismic margin methodology in the EPRI [Electric Power Research Institute) NP-6041 procedure, is not acceptable to the staff. The methodology has not been approved by the staff and its conservatism is uncertain at this point. It is, therefore, not endorsed by_ the staff for the analysis of safety-related systems and components, including the resolution of mechanical, electrical, and structural component outliers in the A-46 program. You are requested to reevaluate your program and ensure that all the identified outliers will be resolved using the plant licensing basis methodologies or other approaches acceptable to the staff.
- 6.
Your September 27, 1996, response to Question 8, as to why the maximum acceleration represented by the floor response spectra (FRS) at higher elevations is less than that at lower elevations, is that the FRS at higher elevations peak in the first mode (1.94 Hz) and that at lower elevations they peak in the second mode (5.52 Hz). We find this explanation unacceptable. In the modal analysis as performed, the response of the structure at a point is a combination of different modes of vibration through the use. of participation factors. It appears that there is a need for further clarification on how FRS were generated. Provide a detailed description of how the FRS as shown in Appendix B of the Palisades A-46 summary report were generated. The information provided should include the actual response spectra generated in addition to the smoothed spectra.
- 7.
In your September 27, 1996, response to Question 9, you provided evaluations of the adequacy of the anchors for two 480-volt motor control centers (EB-01 and EB-26) and one charging pump (P-55C). For EB-01, there are three anchors with two different anchor types and for EB-26 there are ten anchors of the same anchor type. Both EB-01 and EB-26 are located in the auxiliary building at floor elevation 607. Even t~ough there is no response spectrum established for this elevation, it can be interpolated from the response spectra at floor elevations 601 and 61 0 as provided in Appendix B. An explanation.
should be* provided for the following:
(a)
For the screening evaluation of EB-01 both the capacity based on 1.5 times the Bounding Spectrum and the demand based on Design Floor Response Spectrum are shown. For the screening evaluation of EB-26 the capacity based on 1.0 times the Test Response Spectrum and the
-. l
- spectra on which the demand is based are not provided. Provide the missing information. Also indicate how the capacity based on spectra is used in establishing the safety factors as shown in the table on sheet 10 of 13 for EB-01 and on sheet 11 of 11 for EB-26 of Enclosure 3.
(b)
The spectral values for both EB-01 and EB-26 are 1.64g for east-west (E-W) and north-south (N-S) and 0.20g for vertical. However, in calculating the safety factors as shown on sheet 10 of 13 for EB-01 and sheet 11 of 11 for EB-26, different values, 0.656g in the horizontal direction and 0.080g in the vertical direction are used. Provide an explanation for these differences.
(c)
In the combinations of spectral accelerations, why are there no combinations involving 1.64g in both N-S and E-W?
(d)
For P-55C, which is located in the auxiliary building at elevation 590, the spectral values shown on sheet 3 of 13 are different from those shown on sheet 1 3 of 13. Explain the apparent discrepancies. Are the procedures similar to those used for EB-01 and EB-26 in calculating the factor of safety?
- 8.
From your limited analytical review (LAR) data sheet No. LAR 005 for a cable tray computation it appears that you analyzed a highly indeterminate structure as a determinate structure. The results of your analysis may not represent the actual behavior of the structure unless the joints of the members and the supports are free to rotate. Provide the details about the joints and supports to justify such an assumption; otherwise the subject raceway should be analyzed as an indeterminate structure.
- 9.
On sheet 1 of 6 of the screening evaluation work sheet for tank T-73, in the computation of estimated weight, the weight of water is calculated on the basis of a tank radius of 4.0625 feet instead of (4. 75 -.6875/ 12 = 4.692).
Provide an explanation for this discrepancy.
- 10.
In Section 5.0, "Conclusion" of "Seismic Analysis of SIRW T-58 Tank, Calculation No. C-019," you stated that the outlier will be resolved if the concrete pad reinforcement is verified. Confirm if this has been done. If not, what is your plan for resolution of this open item?
- 11.
On sheet 2 of 3 for analysis of tanks T-53A and T-538, it appears that the frame which supports the tanks is statically unstable for the horizontal seismic force unless horizontal members are added at the top and bottom. Confirm that these members actually exist and are simply not shown in the figure; otherwise a modification of the frame should be considered or additional justification regarding the seismic stability of these tanks should be provided.
- *12.
_In the evaluation of anchorages for tanks T-53A and T-538, and heat exchangers E-60A&B, the results show the anchorages are not adequate and remain as outliers. However, the outliers were disposed of without further detailed analysis. Such a procedure of outlier resolution is unacceptable. A detailed analysis to resolve each outlier is requested.
- 13.
You claimed that the joint details as shown on sheet 1 of 4 of LAR data sheet No. LAR 012 for a cable tray are such that the joints are free to rotate. With the angles forming the joints, the staff has reservations with this claim. Please provide a justification for this claim.