ML18102A967

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Forwards RAI Re Seismic Qualification of Mechanical & Electrical Equipment in Operating Plants
ML18102A967
Person / Time
Site: Salem  
Issue date: 04/04/1997
From: Olshan L
NRC (Affiliation Not Assigned)
To: Eliason L
Public Service Enterprise Group
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR TAC-M69479, TAC-M69480, NUDOCS 9704160217
Download: ML18102A967 (6)


Text

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~r. Leon R. Eliason Chief Nuclear Officer & President-Nuclear Business Unit Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038 April 4, 1997

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC QUALIFICATION OF MECHANICAL AND ELECTRICAL EQUIPMENT IN OPERATING PLANTS, SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 (TAC NOS. M69479 AND M69480)

Dear Mr. Eliason:

The NRC has revised your response of August 19, 1996, to our request for additional information (RAI) of June 14, 1996, pertaining to the resolution of USI A-46.

The review has identified certain findings for which additional information is needed in order to complete the review of your A-46 submittal.

Please respond within 30 days of receipt of this letter.

Docket Nos. 50-272/311

Enclosure:

RAI cc w/encl:

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PDR Sincerely, Isl Leonard N. Olshan, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

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UNITED STATES

  • NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 4, 1997 Mr. Leon R. Eliason Chief Nuclear Officer & President-Nuclear Business Unit Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC QUALIFICATION OF MECHANICAL AND ELECTRICAL EQUIPMENT IN OPERATING PLANTS, SALEM NUCLEAR GENERATING STATION, UNITS I AND 2 (TAC NOS. M69479 AND M69480)

Dear Mr. Eliason:

The NRC has revised your response of August IQ, 1996, to our request for additional information (RA!) of June 14, 1996, pertaining to the resolution of USI A-46.

The review has identified certain findings for which additional information is needed in order to complete the review of your A-46 submittal~

Please respond within 30 days of receipt of this letter.

Docket Nos. 50-272/311

Enclosure:

RAI cc w/encl:

See next page Leonard N; Olshan, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation I

  • ~.

Mr. Leon R. Eliason ~

  • Public Service Electr1c & Gas
  • Company

'cc:

Mark J. Wetterhahn, Esquire Winston & Strawn 1400 L Street NW Washington, DC 20005-3502 Richard Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place

  • Newark, NJ 07101 Mr. D. F. Garchow General Manager - Salem Operations Salem Generating Station P.0. Box 236 Hancocks Bridge, NJ 08038 Mr. Louis Storz Sr. Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038 Mr. Charles S. Marschall, Senior

. Resident Inspector Salem Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 Maryland Office of People's Counsel 6 St. Paul Street, 21st Floor Suite 2102 Baltimore, Maryland 21202 Ms. R. A. Kankus Joint Owner Affairs PECO Energy Company 965 Chesterbrook Blvd., 63C-5 Wayne, PA 19087 Mr. Elbert Simpson Salem Nucle~enerating Station, Units 1 a.72 Richard Hartung Electric Service Evaluation Board of Regulatory Commissioners 2 Gateway Center, Tenth Floor Newark, NJ 07102 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Lower Alloways Creek Township c/o Mary 0. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Mr. David R. Powell, Manager Licensing and Regulation Nuclear Business Unit P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. David Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17120 P. M. Goetz MGR. Joint Generation Atlantic Energy 6801 Black Horse Pike Egg Harbor Twp., NJ 08234-4130 Carl D. Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box 231 Wilmington, DE 19899 Public Service Commission of Maryland Engineering Division Chief Engineer 6 St~ Paul Centre Baltimore, MD 21202-6806 Senior Vice President - Nuclear Engineering Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038

l.

SECOND REQUEST FOR ADDITIONAL INFORMATION SALEM NUCLEAR GENERATING STATION. UNITS l AND 2 USI A-46 Adequacy of Seismic Demand Determination (Ground Spectra and In-Structure/Floor Response Spectra)

The licensee's response to Question 5 of the staff's request for additional information (RAI) dated May 30, 1996, concerning the use of ground response spectra for estimating seismic demand did not provide the requested information. This issue was discussed in a meeting held between SQUG representatives and the staff on August 20, 1996.

As a result of considerable discussions on the subject, the staff agreed to clarify the question.

The following is the revised RAI on this issue.

Referring to the in-structure response spectra provided in your 120-day-response to the NRC's request in Supp7ement No. 1 to Generic letter (GLJ 87-02. dated Hay 22. 1992. the fo77owing 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 SQUG 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 the 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 plant's safe shutdown earthquake (SSE) ground motion response spectrum and the SQUG Bounding Spectrum.

The SSE ground motion response spectrum for most nuclear power plants is defined at the plant foundation level..

The SQUG Bounding Spectrum is defined

. at the free field ground surface. For plants located at deep soil or rock sites, 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.

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 GL 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.

ENCLOSURE

2 The licensee is requested to address this question on a plant-specific basis.

2.

Soil Structure Interaction If the soil structure interaction (SSI) analysis performed for the A-46 program and discussed in Reference l differs from the SSI analysis discussed in the Salem Final Safety Analysis Report, then provide the input data used to perform the SSI for the containment building in Reference l including name of the code used, results of the calculations performed such as maximum stresses at boundary elements of the foundation as well as the stresses at the containment building.

3.

Seismic Adequacy of Tanks and Heat Exchangers The licensee stated that the large flat bottom storage tanks on the Safe Shutdown Equipment List (SSEL) did not meet the screening guidelines of the Generic Implementation Procedure, Revision 2, as corrected on February 14, 1994 (GIP-2} and were identified as outliers. The licensee further stated that detailed evaluations were performed in accordance with Appendix H of the EPRI NP-6041.

The EPRI NP 6041 Appendix H methodology is known to yield less conservative results than those of GIP-2 methodology.

Therefore, the staff does not accept the Appendix H methodology unless the licensee provides an adequate justification. When a justification for use of Appendix H is not possible, the licensee should submit an alternate resolution for the outlier tanks or perform the necessary physical modifications to meet the acceptance criteria. When an alternative analytical resolution is proposed, the licensee is requested to document a validation of the methodology and identify a way of predicting credible test data with sufficient margin.

The licensee is also requested to identify the method chosen for evaluation of the tank, and provide a sample of the evaluation including tank anchorage evaluation.

4.

Seismic Adequacy of Cable and Conduit Raceways In accordance with the GIP-2 guideline, the licensee performed a walkdown of the plant raceways and also performed a limited analytical review on 23 selected cable tray systems.

However, during the recent review of another plant's implementation of the GIP-2 Guideline, the staff found that the procedure for ductile cable tray systems might not be sufficiently conservative. The GIP-2 guideline stated that the ductile cable tray systems do not require an evaluation for lateral loads. The staff does not fully endorse this position and is currently pursuing a resolution of the cable tray system ductility issue with SQUG (Reference 4). A generic resolution, when established, should apply to the Salem plant cable trays as well, and the licensee should be expected to revise its evaluation of the Salem cable tray systems accordingly.

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- 5.

Deviation from the GIP-2 Guidance In Reference I the licensee stated that it is convnitted to implement the GIP-2, including clarifications, interpretation, and exceptions in SSER-2, and to convnunicate to the NRC staff any significant or programmatic deviations from the GIP guidance.

The licensee further stated that the submittal confirms that no significant or progranvnatic deviations from the GIP-2 guidance were made.

In response to the staff RAI (Reference 2), the licensee provided a typical list of the items that deviated from the GIP-2 guideline (Reference 3). They are all minor in nature. However, they are characterized as representative. The licensee should provide the worst case items (from a safety point of view) which deviate from the GIP-2 guideline but were categorized as not being significant. In addition, the licensee is requested to clarify the definition of "safety significant" that the walkdown crew used to classify the deviation as significant or non-significant and provide a justification for why such a definition is adequate.

6.

REFERENCES I. Licensee Submittal to NRC Document Control Desk "Generic Letter 87-02 and Supplement 1, USI A-46 Walkdown Summary Report, Salem Generating St~tion Unit Nos. 1 and 2," May 22, 1995.

2.

Letter from NRC to Public Service Electric and Gas Company "Request

- for Additional Information on the Resolution of Unresolved Safety Issue A-46, Salem Generating Station Unit Nos. 1 and 2, 11 June 14, 1996.

3. Letter from D. R. Powell of Public Service Electric and Gas Company to NRC Document Control Desk "Response to Request for Additional Iriformation, 11 August 19, 1996.
4. Letter to D. H. Dorman of NRC from N. P. Smith of Seismic Qualification Utility Group "SQUG Generic Response td the Staff RAI," August 19, 1996.