ML19312A244

Responds to IE Circular 78-08 & IE Bulletin 79-01.Confirms Acceptable Seismic & Environ Qualification Program for Facility

ML19312A244
Person / Time
Site:	Zimmer
Issue date:	10/08/1979
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7911020017
Download: ML19312A244 (2)

Text

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THE CINCINNATI GAS & ELECTRIC COMPANY auf CIN CIN N AT8, OHIO 4 5201

$IfSE%,"" October 8, 1979 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. James G. Keppler Director RE: WM. H. ZIMMER NUCLEAR POWER STATION -

UNIT 1 - DOCKET NO. 50-358, SEISMIC & ENVIRONMENTAL QUALIFICATION IE CIRCULAR 78-08, IE BULLETIN 79-01,

• JAMES G. KEPPLER LETTER OF JUNE 11, 1979 W.O. 57300, JOB E-5590, IE CIRCULAR &

BULLETIN FILE Gentlemen:

The above referenced documents requested that objective evidence of the Environmental Qualification of all instruments and electrical equipment required to perform safety functions during or following postulated accidents be made available for NRC audit.

Environmental Qualifications were identified by your June 11, 1979 letter to include seismic, radiation, temperature, coisture and pressure.

After several conference phone calls with General Electric ,-

and/or your staff, we believe an acceptable Environmental Qualification '

Program is being implemented on the Zimmer Project. This letter is "

intended to confirm that program. '

v,;f' Since we had already implemented a seismic qualification program in co-operation with the NRR Seismic Qualification Review Team (SQRT) prior to receipt of the Region III request, we believe i i it would be desirable to continue handling seismic separately under this existing SQRT program. Ta date, we have presented to the NRR -

SQRT reviewers information we believe adecuately documents the h ghalification of all Balance of Plant (BOP) Category 1 equipment 'l for seismic loads. In addition, we have presented the NRR SQRT M.}

reviewers the results of a partial seismic review of NSSS Category h(,d 1 equipment NSSS Category along with schedules 1 seismic for completion of the remaining review. Copies of the NRR SQRT letter , 'c:

dated February 23, 1979, outlining their requirements for seismic ' ,:;"

qualification and our April 26, 1979, response letter identifying plans for implementation are attached for your review. c 1256 105 v oj,ggo O k ,

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\N To: U.S. Nuclear Regulatory Commission October 8, 1979 Re: Wm. H. Zimmer duclear Power Station - Page #2 W.O. 57300, Job E-5590 The NRR's SQRT review is under the direction of Mr. Robert Bosnak, Mechanical Engineering Branch Chief, Room P924C, Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland 20014, Phone 301-492-7456. We believe the NRR SQRT seismic requirements adequately address the Region III scismic concerns and that the NRR SQRT approval of our seismic qualification program results can be accepted by Region III as evidence of acceptable seismic qualification.

A separate program has been initiated to review the other environmental qualifications (i.e. , temperature, radiation , pressure ,

humidity) of all Category 1 components. Under that program, we are reviewing 100% of both BOP and NSSS items to assure that equipment is qualified to meet predicted site conditions of temperature, humidity, pressure and radiation. We are preparing a summary of the equipment being reviewed which will be available for NRC audit.

This summary will include: component identification, function, environmental parameters, and qualification reference report number.

This program is being aggressively followed and progress reports will be made available if desired.

We believe the above program for environmental qualification meets your requirements. My staff will continue to work with both your Region III people and the NRR SQRT reviewer to expedite program completion.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By E. A. BORGMANN Senior Vice President HCB: dew cc: R, Bosnak J. D. Flynn W. D. Waymire H. C. Brinkmann W. W. Schwiers

, J. R. Schott l S. G. Salay R. J. Pruski W. E. Smith General File

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JtJN 111979 Docket No. 50-358 -

Cincinnati Gas and Electric '

- Company ATTN: Mr. Earl A. Borgmann Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnati, OH 45201 Gentlemen:

This refers to the inspection conducted by Messrs. J. Hughes, T. E. Vandel, H. S. Phillips and K. R. Naidu of this office on April 25-27, 1979, of activities at the Wm. H. Zimmer Nuclear Power Station authorized by NRC Construction Permit No. CPPR-88 and to the discussion of our. findings with Messrs. B. K. Culver, W. M. Schwiers and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

'During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appendix A.

This notice is sent to you pursuant to the provisions of Section 2.201 af the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office within thirty days of your receipt of this notice a written statement or explanation in reply, including for each item of non-compliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.

Based on our conversation of April 27, 1979 we are requesting that you have available at the site for our inspector's review objective evidence of the Environmental Qualification of all Instrument -

Electrical Equipment that is required to perform safety functions dttring or following postulated accident conditions. This environmental qualification should include such parameters as seismic, radiation, temperature and moisture. A partial listing of components was given to W. W. Schwiers on April 27, 1979. In order to expedite our review, this information should be available for our review by August 1, 1979.

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Cincinnati Gas and JUN 111979 Electric Company In accordance with Section 2.790 of the NRC's " Rules of Practice,"

Part 2, Title lo, Code of Federal Regulations, a copy of this  :

'T Ictter,theenclosures,andyourresponsetothisletterwillbej placed in the NRC's Public Document Room, except as follows. If the enclosures contain information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. .The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.

We will gladly discuss any questions you have concerning this inspection.

Sinccrely, g~ 60. 'p'

<'/ James G. Keppler /

Director

Enclosures:

1. Appendix A, Notice of Violation

2. IE Inspection Report No. 50-358/79-09 and No. 50-358/79-12 cc w/ enc 1:

J. R. Schott, Plant Superintendent Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Harold W. Kohn, Power Siting Commission Citizens Against a Radioactive

Environment

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NUCLEAR REGULATORY COMMisslON WASHINGTON, D. C. 20555

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,o February 23, 1979 Docket No. SS358 T@ Mr. Earl A. Borgmann Vice President - Engineering The Cincinnati Gas and Electric Company P. O. Box 960 Cincinnati, Ohio 45201

Subject:

REEVALUATION OF EQUIPMENT QUALIFICATION FOR SEISMI DYNAMIC LOADS - WM. H. ZIMMER NUCLEAR POWER STATION The loadspurpose of this applicable letter to your is to discuss two issues related to vibratory facility. "

1.

In 1975, the Regulatory Requirements Review Committee characterized Regulatory Guide 1.100 as Category 2 - further staff consideration required in order to determine the need for backfitting. The Guide concerns the seismic qualification of electrical equipment. Further staff consideration of this issue resulted in the position published in Standard Review Plan (SRP) 3.9.2 and 3.10 in November 1975, regarding the staff requirements for implementation on mechanical W! and electrical equipment and their supports, which were approved by the Director, Office of Nuclear Reactor Regulation.

The Guide provides guidelines to account for the effects of an input

'which has both multifrequency and multiaxis characteristics for seismic Category I equipment and supports.

Plants which are currently being reviewed for an operating license had construction permit reviews using single frequency, single axis methods. prior to 1975, and During a seismic event multiaxis vibration.it is likely that such equipment could be exposed to multif

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Pursuant to General Design Criterion 2, seismic Category I equipment from accidents and severe natural phenomena.and supports are t is concerned, the staff has interpreted General Design Criterion 2 Insofar a to require the combination of seismic effects and, in the Mark II and A Mark III containments designed by General Electric,:the vibratory loads attributed by General Electric to feedback of hydrodynamic loads from the pressure suppression pool of these designs.

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- A meeting was held in Bethesda, Maryland, on April 4,1978 among the NRC staff, the General Electric Company, and those utilities having boiling water reactor plants under construction and identified as having equipment qualified via single frequency, si.ngle axis methods. Those present at the meeting were advised that:

'S 1. During the review process necessary to issue an operating license, we s will reevaluate _the ade_quacy ,of.j;he .origj.nal si.ngle frequency, single

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axis _tei[l.n.g_or_analysjs_ met _ hods in view cf the multifrequency, multi-axis concerns.

2. The objective of the reevaluation is to find whether the original seismic qualification of the equipment was adequate. Additional justiffcation of the validity of the original qualification, or in some cases requali-fication, inay be necessary. In assessing the volidity of the original qualification or requalification, the criteria to be used by the staff to determine acceptability will be IEEE 344-1975, Regulatory Guides 1.100 and.l.92, and Standard Review Plan Sections 3.9.2 and 3.10. Other criteria may be used if justified by an applicant and approved by the staff. ^

3. In the reevaluation phase of the program we will select certain items from a plant-specific listing of seismic Category I items, paying particular attention to systems required for safe shutdown following a seismic event.

During the reevaluation phase, a plant specific review will be conducted by yM our Seismic Qualification Review Team (SQRT). In its review, the team will reevaluate the original qualification adequacy of selected seismic Category I items of equipment for which single frequency, single axis methods were used.

The team will determine those items which are acceptable and those which require requalification.

The second issue concerning equipment design and qualification for combined vibratory loads was not discussed in the April 4 meeting, but has been the subject of generic discussions between the General Electric Company and the staff and discussions on individual plant dockets. We require that seismic

. Category I equipment and supports be designed and qualified to withstand

. effects of hydrodynamic vibratory loads associated with either safety relief

valve discharge or LOCA blowdown into the pressure suppression containment in addition to the effects of dynamic loads arising from earthquakes The .

response of each item of seismic Category I equipment that is affected by these loads will depend on its location in the plant and the input trans-mitted to it from the suppredsion pool via the intermediate structural members. L3 A 3 i ?. 3 b )

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, The magnitude and frequency content of the hydrodynamic loads is being defined as part of the Mark II Containment Program. There has been a continuing discussion with the Mark 11 owners as to what constitutes an accepts.sle method for the combination of seismic and hydrodynamic vibratory responses of seismic Category I equipment and supports. The staff has previously 0:cepted the use of square-root-sum-of-squares (SRSS)

Y] methods for combination of responses due to LOCA and safe shutdow, earthquake

~4' . ' (SSE) loads on the reactor coolant pressure boundary and its supports (see NUREG-0484). Our review is continuing and we are concentrating on the proposed Kennedy-Newmark criteria for the combination of safety relief valve (SRV) and operating basis earthquake (0BE) loads, and for general use in combining responses due to vibratory loads on other seismic Category I equipment. The eventual outcome is expected to establish our position and criteria for general acceptance of response combinations using SRSS methods.

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To decide whether seismic Category I equipment meets the requirements of General Design Criterion 2, the SQRT team will review the combined required response spectra (RRS) or the combined dynamic response, examine the equipment configuration-and mounting, and then determine whether the test or analysis which has been conducted demonstrates compliance with the RRS if the equipment ^

was qualified by test, or acceptable analytical criteria if qualified by analysis.

As we indicated in our meeting on April 4,1918 with applicants and General Electric, we strongly believe that the reevaluation phase of the program, and any requalification which results from the reevaluation, be done generically to the extent possible as the most efficient utilization of the resources of NRC and BWR owners in meeting licensing schedules. We are

• t9 sending a similar letter to two other applicants with ongoing operating license reviews'- the Shoreham facility of Long Island Lighting Company and the LaSalle facility of Commonwealth Edison Company. We believe that a generic program for these facilities, at least for NSSS-supplied equipment, is preferable to individual case reviews. We will urge consideration of a generic approach also by other affected applicants with Mark II and Mark III designs. He believe that a generic program should at least include the elements contained in Enclosure 1 to this letter.

Satisfactory completion of the reevaluation phase of the program for a majority of the seismic Category I equipment and supports and initiation f of the requalification phase of the program will be required prior te any

- staff recommendation concerning the granting of an operating license, w'th

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appropriate license conditions required concerning a_n_ acceptable completion

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, schedule of the requalification program. Fin addition, some confTrmatory in situ testing to characterize the ability of equipment and supports to accomodate hydrodynamic loads may also be a licensing prerequisite.

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. 4 We request a reply concerning your plans and schedule for completion of the submission detailed in the enclosure for those items not already provided in your :pplication, and whether a generic program will be initiated with the other uffected applicants.

gg Sincerely,

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Roger S. oyd, Director p Division of Project Management Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc:

See next page-

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i-Mr. Earl A. Borgmann I

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cc: Troy B. Conner, Jr. , Esq. David B. Fankhauser, PhD Conner, Moore & Corber 3569 Nine Mile Road 1747 Pennsylvania Avenue, N. W. Cincinnati, Ohio 45230 Washington, D. C. 20006

• Mr. William J. Moran Cincinnati City Solicitor General Counsel Room 214, City Hall The Cincinnati Gas and Electric Cincinnati, Ohio 45202 Company P. O. Box 960 Mr. Stephen Schumacher Cincinnati, Ohio 45201 Miami Valley Power Project P. 0.. Box 252 fir. Willl e G. Porter, Jr. Dayton, Ohio 45401 Porter, Stanley, Arthur and Platt Ms. Augusta Prince, Chairperson 37 West. Broad Street 601 Stanley Avenue Columbus, Ohio 43215 Cincinnati, Ohio 45226 Mr. Peter H. Forster, Vice President Charles Bechhoefer, Esq. , Chairman Energy Resources Atomic Safety & Licensing Baord The Dayton Power and Light Panel Company V. S. Nuclear Regulatory Comission P. O. Box 1247 Washington, D. C. 20555 Dayton, Ohio 45401 Mr. G. G. Sherwood, Manager J. Robert Newlin, Counsel Safety and Licensing d The Dayton Power and Light General Electric Company Company 175 Curtner Avenue P. O. Box 1247 San Jose, California 95125 Dayton, Ohio 45401 Mr. James D. Flynn '

Manager, Licensing Environmental Affairs The Cincinnati Gas and *

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Electric Company

, P. O. Box 960 Cincinnati, Ohio 45201 Mr. J. P. Fenstermaker Senior Vice President-0perations Columbus and Southern Ohio Electric Company

• n 215 North Front Street Columbus, Ohio 43215 .

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         ;-                                                                                            c ENCLOSURE 1                         3 REQUEST FOR ADDITIONAL INFORMATION (a) For your plant identify those items of nuclear steam supply system e,y                             and balance-of-plant equipment requiring reevaluation and specify why
  ?                            reevaluation is necessary (i.e. because the original qualification used the single frequency, single axis methodology, because equipment is affected by hydrodynamic loads, or because both of the above conditions were present) for each item of equipment.

(b) Develop the combined required response spectra, or the combined dynamic response as appropriate, for all items of equipment identified in (a) for each plant. The combined required response spectra, or ^ combined dynamic response, is to include all applicable vibratory (seismic and hydrodynamic) loads. (c) Develop the proposed methods and criteria to be used to determine gg the acceptability of the original equipment qualification te meet the required response spectra of (b). The presentation of the proposed methods and criteria and final acceptance by the staff should be scheduled to be completed early in 1979. (d) Using the final methods and criteria developed in (c), provide the results of the review of the original equipment qualification

                    '.        (reevaluation phase) with identification by plant of (1) equipment which has failed to meet the required response spectra and will
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require requalification, and (2) equipment which is acceptable, together with the necessary information to justify the adequacy of the original qualification. ] (e) Indicate the availability of equipment identified in (d)(2) by plant or other location for staff inspection and review. (f) Develop procedures and schedule plan for the requalification phase for items identified in (d)(1). (g) Develop a' confirmatory in-situ test program to characterize the ability of equipment to accommodate hydrodynamic loading. e t O d 1256 115

o . 1. THE CINCINNATI GAS & ELECTRIC COMPANY

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WMZ Docket No. 50-358 april 26, 19"9 PAY -179 Mr. Harold Denton, Director ~--~~ Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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RE: WM. H. ZIMMER NUCLEAR POWER STATION UNIT 1 - RE-EVALUATION OF EQUIPMEN" 3 QUALIFICATION FOR SEISMIC AND HYDRODYNid+ :0 LOADS ,.m._,,, 1

Dear Mr. Denton:

UmEm i , This is in response to Roger Boyd's February 23, 1979 letter which requested a reply concerning our plans and schedule for re-qualification of equipment for seismic and hydrodynamic loads. Please be advised that much of the work on the Zimmer project has already been completed. All the Category 1 balance of plant (BOP) equipment has been re-evaluated and, with some additional testing of selected items, has been found to be qualified for both seismic and hydrodynamic loads in accord with 1975 IEEE-344 criteria. The results of this re-evaluation have been reviewed in some detail with the NRC's SQRT team and found acceptable. General Electric (GE) has completed a re-evaluation of all Category 1 Nuclear Steam Supply System (NSSS) equipment and, with some additional testing, has found the equipment to be qualified for both seismic and hydredynamic loads. A meeting has been scheduled to review the details with the NRC's SQRT team in San Jose on May 15, 16, and 17, 1979. Although the GE re-evaluation was performed to the

             ; original criteria, work is aggressively under way to upgrade athat re-evaluation to meet 1975 IEEE-344 criteria. Since the
           ~NSSS equipment is similar to the SOP equipment and to equipment of other NSSS vendors which has been qualified to 1975 criteria, we believe this NSSS equipment also to be qualified.
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r% CG&E has commi;ted to perform in-situ testing during start-up of the Zimmer Plant to further demonstrate equipment qualification. B

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e , ,,a .. d To: Mr. Harold Denton, Director April 26, 1979 Re: Wm. H. Zimmer Nuclear Power Station - Pa e #2 Unit 1 - Re-evaluation of Equipment ' Qualification for Seismic and Hydrodynamic Loads Although the dynamic load definitions and load combinations used in the evaluation of all three MK II Lead Plants were similar, plant unique considerations resulted in different numerical values for the calculated loads imposed at each plant. Therefore, it will not be possible to perform a completely generic qualification pro-gram. CG&E is working with GE and the other two utilities in an effort to develop common programs where practical. In,a detailed Lead Plant Meeting with the SQRT team on April 10, 1979, CG&E committed to work with the NRC to resolve remaining SQRT questions. Toward that end the following action plan was agreed upon:

1. The utilities will demonstrate that Category ^

l BOP equipment meets 1975 IEEE-344 criteria. (This has already been completed for the Zimmer Project.)

2. The utilities will demonstrate that Category 1 NSSS equipment meets the original criteria.

(This will be done during the May meeting in San Jose.)

3. A Lead Plant common list of NSSS Category 1 equipment with specific equipment identified as " safe shut-down" items for each of the three plants will be' developed. (This list is being prepared now and will be submitted to the NRC prior to the May meeting.)

4. Those items of GE equipment which meet the 1975 criteria by reference to BOP or other work will be identified. (This list is being prepared f

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now and will be available in a 2 to 3 month time frame.)

5. A schedule with milestones, for re-assessment of the balance of GE NSSS items will be provided.

(This is being prepared now and is scheduled for #' completion by June.) The above outlines the approach being followed in the Zimmer re-evaluation as requested by your February 23, 1979 letter. 1956 \\1

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To: Mr. Harold Denton, Director April 26, 1979 Re: Wm. H. Zimmer Nuclear Power Station - P,'ege #3 Unit 1 - Re-evaluation of Equipment '

          -          Qualification for Seismic and Hydrodynamic Loads In summary, all the Zimmer Category 1 equipment has already been evaluated and found qualified for both seismic and hydrodynamic loads to original criteria and a very substantial amount of equipment has been re-evaluated and found qualified to the 1975 criteria. This furnishes a good basis for confidence in the qualifications of Zimmer Category 1 equipment.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY

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By E. A. BORGMANN f'- - - Senior Vice President EAB: daw cc: Charles Bechhoefer Glenn O. Bright Frank F. Hooper Troy B. Conner, Jr. James P. Fenstermaker Peter H. Forster William J. Moran J. Robert Newlin William G. Porter, Jr. James D. Flynn Thomas A. Luebbers Leah S. Kosik John D. Woliver

                                                                        } } }()         }}8 fState of Ohio         )
              , County of Hamilton)ss J

Sworn to and subscribed before me this 270

• day of April, 1979.

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