ML20028B794
| ML20028B794 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/16/1982 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8212060147 | |
| Download: ML20028B794 (13) | |
Text
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s November 16, 1982 DISTRIBUTION G Olb CDocket File 7 RJacobs NRC PDR JVan Vliet L PDR RIngram ORB #4 Rdg Gray File +4 DEisenhut JTBeard Docket No. 50-289 OELD JWermiel AE0D ASLAB LHarmon-2 EBlackwood ACR5-10 H0rnstein Mr. Henry D. Hukill TBarnhart-4 Vice President LSchneider GPU Nuclear Corporation OGC P. O. Box 480 OPA Middletown, Pennsylvania 17057 DBrinkman RDiggs
Dear Mr. Hukill:
Our contractor has reviewed the seismic qualification of the auxiliary feedwater (AFW) system (also known as the emergency feedwater system) at Three Mile Island, Unit 1 (TMI-1) and prepared the enclosed Technical Evaluation Report (TER). The review was based on infor-mation you provided in the submittals referenced in the TER. The TER indicates that: (1) the present AFW system might substantially lack the capability to withstand a postulated safe shutdown earthquake (SSE), (2) your walkdown of the AFW system was not a complete walkdown, and (3) you have not described an alternate system for decay heat removal. Additionally, the TER indicates that there are identified deficiencies for which you have not committed to perform appropriate modifications. While our February 10, 1981 letter did not explicitly request AFW system modifications, it did explicitly express our intent to increase the seismic resistance, where necessary, to ultimately provide reasonable assurance that the system will function after the occurrence of earthquakes up to and including the SSE.
As we have done iin other review actions for other plants, we are forwarding this TER to provide you an opportunity for review and comment, and an opportunity to submit any other relevant information before we complete our review and prepare a Safety Evaluation documenting our position on what upgrade actions may be required. Please be advised that we do not, at this time, agree with our contractor's conclusion regarding the adequacy of the seismic capability of the condenser hotwell supply lines (reference: Section 2, item (1) Piping, of the TER). We are continuing to review the approach of handling a postulated break of this piping with revised operating procedures, since the CST low water level alarms, which would trigger the procedure, are not seismically qualified either.
8212060147 821116 PDR ADOCK 05000289 P
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omy OFFICIAL RECORD COP'r usoeomewasseo NRC FORM 318 (10-80) haCM 024o
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- Q Mr. Henry D. Hukill ble request that you specifically address this matter in your review of the TER. Our schedule is such that we will be able to consider all coments and additional infomation that we have received by no later than Decenber 20, 1982.
Please contact your Project Manager if you have questions on this issue.
Sincerely, "uMGIliAL SIG;Ep 3r J015 F. STOLAss-John F. Stolz, Chief Operating Reactors Brai.ch #4 Division of Licensing
Enclosure:
TER cc w/ enclosure:
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GPU Nuclear Corporatioa 50-289, TMI-l Mr. R. J. Toole Jordan D. Cunningham, Esq.
Manager, TMI-l Fox, Farr and Cunningham GPU Nuclear Corporation 2320 North 2nd Street P. O. Box 480 Harrisburg, Pennsylvania 17110 Middletown, Pennsylvania 17057 Ms. Louise Bradford TMIA Board of Directors 1011 Green Street P.A.N.E.
Harrisburg, Pennsylvania 17102 P. O. Box 268 Middletown, Pennsylvania 17057 Ms. Marjorie M. Aamodt R. D. #5 Coatesville, Pennsylvania 19320
- Docketing and Service Section Earl B. Hoffman U. S. Nuclear Regulatory Commission Dauphin County Commissioner Washington, D. C.
20555 Dauphin County Courthouse Front and Market Streets Chauncey Kenford Harrisburg, Pennsylvania 17101 Judith H. Johnsrud Environmental Coalition on Nuclear Power Union of Concerned Scientists 433 Orlando Avenue c/o - Harmon & Weiss State College, Pennsylvania 16801 1725 I Street, N. W.
Suite 506 Washington, D. C.
20006 Mr. Steven C. Sholly Union of Concerned Scientists 1346 Connecticut Avenue, N. W.
J. B. Lieberman, Esq.
Dupont Circle Building, Suite 1101 Berlock, Israel & Lieberman Washington, D. C.
20036 26 Broadway New York, New York T0004 11r. Ronald C. Haynes, Regional Administrator U. S. N. R. C., Region I G31 Park Avenue King of Prussia, Pennsylvania 19406 ANGRY /TMI PIRC 1037 Maclay Street Harrisburg, Pennsylvania 17103 John Levin, Esq.
Pennsylvania Public Utilities Commission Box 3265 Harrisburg, Pennsylvania 17120
T wu nuclea'r L,trporau en General C unsel Federal Emergency Managem;nt Agency Mr. Thomas Gerusky ATTN: Docket Clerk Bureau of Radiation Protection 1725 I Street, NW Department of Environmental Resources
- Washington, DC 20472 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Karin W. Carter, Esq.
505 Executive House i
'P. O. Box 2357 Judge Gary L: Itilhollin Harrisburg, Pennsylvania 17120 4412 Greenwich Parkway, fAl Washington, D. C.
20007 Dauphin County Office Emergency G. F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge Preparedness l
1800 M Street, N.W.
Court House, Room 7 -
Washington, D. C.
20036 Front & Market Streets j
Harrisburg, Pennsylvania 17101 Mr. E. G. Wallace l
Licensing Manager GPU Nuclear Corporation l
100 Interpace Parkway Parsippany, New Jersey 07054 l
William S. Jordan, III, Esq.
Ms. Lennie Prough Harmon a Weiss U. S. fl. R. C. - Till Site 1725 I Street HY, Suite 506 P. O. Box 311 Washington, DC 20006 Middletown, Pennsylvania 17057 Ms. Virginia Southard, Chairman Citizens for a Safe Environment 264 Walton Street 3
Mr. Robert B. Borsum Lemoyne, Pennsylvania 17043 Babcock & Wilcox Nuclear Power Generation Division l
Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. David D. Maxwell, Chairman Board of Supervisors Londonderry Township RFD#1 - Geyers Church Road Middletown, Pennsylvania 17057 Mr. C. W. Smyth Supervisor of Licensing TitI-1 GPU Nuclear Corporation P. O. Box 480 Regional Radiation Representative Middletown, Pennsylvania 17057 EPA Reaion III Curtis Building (Sixth Floor) 6th and Walnut Streets Philadelphia, Pennsylvania 19106 Governor's Office of State Planning Mr. Richard Conte and Development Senior Resident Inspector (TMI-1)
ATTN: Coordinator, Pennsylvania U.S.N.R.C.
State Clearinghouse P. O. Box 311 P. O. Box 1323 Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120
Revised Oc'tobor 29, 19d2 4
TECHNICAL EVI.LUATION REPORT THREE MILE ISLAND NUCLEAR STATION, UNIT 1 SEISMIC OUALIFICATION OF AUXILIARY FEEDWATER SYSTEM 1.
I!;TRODUCTION Since the accident at Three Mile Island, considerable attention has been focused on the capability of nuclear power plants to reliably remove decay heat.
The NRC has rece,ntly undertaken Multiplant Action Plan C-14 " Seismic Qualification of AFW Systems" [Ref. 13, which is the subject of this evaluation.
To implement the first phase of Action Plan C-14, the NRC issued Generic Letter No. 81-14 " Seismic Qualification of AFW Systems" [Ref.
23, dated February 10, 1981, to all operating PWR licensees.
This letter requested each licensee (1) to conduct a walk-down of non-seismically qualified portions of the AFW system and identify defi-ciencies amen'able tb simplb' actions to improve seismic resistance, and (2) to provide design information regarding the seismic capability of the AFW system to facilitate NRC backfit decisions.
The licendee of Three Mile Island Nuclear Station, Unit I responded with letters dated, September 29 and December 8, 1981, and February 16, 1982 [Refs. 3, 4 & 53.
The licensee's response was found net to be ecmplete and a Request for Additional Information (RAI) was issued by the NRC, dated April 5, 1982 [Ref. 63.
The licensee provided sup-in letters dated July 7, September 14, and Seo-plemental responses tember. 29, 1982 [Ref. 7, 8 and 93 This report provides a technical evaluation of the information provided in the licensee's responses to the Generic Letter, and includes a recer.endation regarding the need for additional analysis and/er u;gr; ding.cdifications of this plant's AFW syster.
1
2.
EVALUATION Information provided in licensee's responses included:
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o Specification of the overall seismic capability of the AFW system.
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Identification of AFW system components that are currently o
non-seismically qualified for SSE.
Descripti,on of, procedure for switchover to a seismically o
qualified secondary water source.
Discussion of levels of seismic capability of non-seismically o
qualified components.
Description of the AFW s'ystem boundary.
o o
Status of compliance with seismic related NRC Bulletine and Information Notices.
o Results of walk-down of non-seismically qualified areas.
o Addit.ionally, schematic sketch of the AFW system.
o Additionally, description of methodologies and acceptance criteria for seismically qualified components.
We have reviewed'the licensee's responses, and a point-by-point evaluation of licensee's responses against Generic Letter's requirements is provided below.
(1)
Seismic Carability of AFW System Except for those items identified in the following, the AFW system has been designed, constructed and maintained to with-stand an SSE utilizing methods and acceptance criteria c,onsistent with that applicable to other safety-related systems in'the plant.
Presently, those itens identified by the licensee as not'being full; s ei s r i c a ll:, qualified are evsluated below:
c Funts /:'Otcrs - I:one o
Piping - (a) The portion of the recirculation lines for th.e emergency feedwater pumps between the manual is~olation valves (EFV-20 A & B and EFV-22) and the condensate storage tank (CST)
"B" were not seismically designed.
These lines will be upgraded to sdismic Class I at the next refueling outage.
(b) The condenser hotwell supply lines are non-seismic Class I.
However, we believe that according to the licensee's statement a postulated break of these lines does not cause a safety concern because the plant operating procedures will be revised to assure the closure of isola-tion valves between the hotwell.and the AFW suction line (Co-V-14 A & B) and, hence, the condenser hotwell supply lines will be' isolated when the water level of the condensate storage tank reaches the technical specification limit.
(c) Based on the sketch submitted by the licensee, not all connected branch lines from the AFW system are seismic Cla.ss I beyond the first valve and up to a point of three orthogonal restraints.
(d) The ' ins tr'.' ment air supply line
from valve IA-V27 to the AFW system is not seismically qual-iried.
The licensee presented no justification for items i
i (c) and- (d) and'did not indicate any plans to re-evaluate and/or modify the system in these areas.
Based on the given information, we judge that the present level of seismic capability of the AFW system piping is le s than OBE.
c Valves / Actuators - All valves were designed such that the OBE stresses would be below yield and SSE stresses would be within ultimate strength.
The valve functional opera-bility during and after an SSE has been assured based on
(
calculations.
Based on the given information, we judge that the valves / actuators presently'have a seismic capacity ecuivalent to the SSE level.
l l
o F:wer Eurrlies - Pcrtions of the pcwer supplies have been l
l
_ den:ifie: :y the licc ns c-e a s r.or.-sei ric Class I in a r:ccnt evaluation.
They ir.cicce:
(a) Tcwer supplies for.
1 auxiliary steam to EF turbine pump and motor operators for condensate storage tanks A & B isolation valves (CO-V-10 A & B) were not designed to seismic requirements; however, the licensee indicated that they are not part of the emergency power supply system and, therefore, are non-essential items.
(b) The power supply from the motor op-erated valves (CO-V-lll A & B) in the cross tie between the condensate storage tanks (CST) A and B will be changed from the existing non-vita,1 power sources to Class 1E vital power sources.-
(c) Cable routing for the power supply to motor operated valves (CO-V-14 A & B) between the hotwell and the AFW suction line will be upgraded to meet seismic Class I requirement.
Upgrading modifications to items (b) and (c) have been proposed by the licensee, and are planned to be implemented before the startup from the next (Cycle No. 6) refueling.
We conclude that the pre,sent level of seismic capability of power supplies is less than OBE,
~
but it will b'e equivalent to SSE upon completion of the planned modifications.
o Water Source (s) - None o
Initiation /Conbrol Systems - Firstly, items identified by the licensee as non-seismically qualified but without planned.
modifications include:
(a) Flow switches and control cir-cuitry of recirculation flow control valves (EF-V8 A, B i
and C).
(b) Cable routing of motor operators for main I
steam supply isolation valves to the turbine driven pump (MS-V2 A & B) and for the main steam bypass to the condensate valves (MS-V8 A & B).
(c) S'ol'enoid valves and limit switch which control the valves (MS-V113 A & B) for 'roviding the p
main steam to turbine.
(d) Cable routing of motor-operators for main steam isolation valves MS-V1 A, B,C, & D.
- Secondly, th::e n:n-:cismically qualified iter.: With modificatiens scr :- :_ed to be c:r;1e ed 5-the 'irc: re fueling a f ter re-start in;1ude:
(e) C.:ncerter E?-Y-EA for centrol valve 1
U-
EF-V30A.
(f ) Low level alarm for condensate storage tanks A & B.
Finally, those non-seismically qualified items which we believe to be non-essential include:
(g ) Cable routing of motor operators of main steam to EF ' turbine pump valves MS-V10 A & B. '(h ) Local starter for MS-V10 A & B motor operators.
(i) Limit switch on EF turbine pump steam-supply regulating valve.
Since the licensee has not indicated any plans for removing deficiencies identified in items (a) to (d), we conclude that the present level of seismic capability of the initiation / control systems is less than OBE.
Structures - The turbine building is seismic Class II and o
-with some sti'ffening it could withstand OBE.
Some portions of the essential power supplies and initiation / control systems for the AFW are routed through the turbine building.
Since the licensee currently has no plans to modify / upgrade t'he turbine buil-ding, we judge that the present level of seismic capability of the structures supporting or housing the AFW system components is less than OBE.
Based on o:r evaluation described above, those areas of the AFW system judged not to possess an SSE seise.ic capability are identified below.
l o
Pumps / Motors None o
Piping Less than OBE o
Valves / Actuators None o
Power Supplies None' o
Water Source (s)
None o
Initiation / Control Systems Less than OBE o
Structures Less than OBE Ucte:
Presently less than OBE, anc will.be fully cualifiec when the licer.see's prcposed upgrade /nodification is completed.
5
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In summary, our evaluation indicated that the licensee's AFW system does not possess an overall seismic capability that can withstand an SSE.
The primary water sou$ce is the condensate storage tank.
~
This tank and the suction piping to the AFW pumps are seismic Class I.
However, in two cases, there is only a single isolation valve (CO-V-14) between the seismic Class I water supply piping and the non-seismic Class I piping to the'-condenser hotwell.
In either case, failure of that valve to isolate the condensate storage tank from the non-seismic Class I piping could result in that particular condensate storage ' tank draining to the con-denser hotwell or' turbine building.
The licensee had therefore conducted an evaluation of the condensate system and identified some necessary modifications and changes of operating procedures, as discussed earlier, that will be implemented prior to startup from the next.(Cycle No. 6) refueling.
Modifications: recommended by the licensee include:
(a) Power supply modifications that have been mentioned under the power supplies evaluation.
(b)
Plant operating procedures for AFW system would be changed to provide guidance to the operator to isolate the CST from the AFW system by closing valves CO-V-111 A & B and CO-V-14 A & B-from the control room whenever the CST reaches the' technical specification limit following AFW system initiation.
Additionally, the licensee stated that a secondary water supply of river water i
is available from the reactor building emergency cooling pumps and it is entirely seismic Class.I.-
This water supply. enters the AFW pump common suction header between two sectionalizing valves EF-V-1 A & B.
Manual actions are required to ace,ess this backup water supply.
Two series motor operated valves (EF-V 4 & 5) to the river water syster are nornally kept' locked clcsed ar.d the motcr control center treaker's for these valves are locked open.
If the backup supply of river.-ater t.c the AFW system is needed, these locks will be removed and the breakers 6-t I
e cicsed.
The switchover procedure to use the backup water sources is still under review by t.he licensee.
Seismic qualification information for any alter'nate decay heat removal system was re' quested by the Generic Letter 81-14 if substantial lack of seismic qualification of the AFW ' system is indicated.
We did not find that the licensee's AFW system has an SSE capability, and the licensee's responses did not provide information on any alternate decay heat removal system.
i Regarding the AFW system boundary, the schematic sketches provided by the licensee show that there are branch lines with-out a second isolstion valve.' Moreover, for those branch lines with a second valve, it is not clear whether the second valve is normally closed or capable of automatic closure.
We there-fore conclude that the AFW system boundary does not fullf con-form t'o the defini.tions of GL 81-14.
The AFW system was included within the scope of IE Bulletin 79-02, 79-04, 79-07,.79-14, 80-11 and IE Information Notice 80-21.
(2)
Walk-Down of Non Seismically Qualified Portion of AFW System i
l l
Walk-desen has been performed in conjunction with IE Bulletins 79-02 and 79-14.
The licensee identified six deficiencies which have been corrected:
(a) Support EF 8, repair completed on 4/7/81, (b) Support EF-72, repair completed on 7/27/81, (c)
Support EF-125, repair ecmpleted on 7/31/81, (d) Conduit to I:SV-6 has loose clamp which needs to be tiEhtened, (e) Conduit to EFW c2 had no clamps to hold it to existing steel and'needs clin; for recurity, (f) Unistrut suppcrting condu'it tc EF-V 5C 1e iccse at the case and needs to be tichtened.
The licencee stated that items (d) to (f) have been or will be completec e,.--,e
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prior to restart.
The welk-down, however, is not complete since it did not cover all the non-seismically qualified items iden -
tified under secti,on (1).
~
(3)
Additional Information The licensee provided schematic sketches of the AFW system including the water sources, heat sink, suction and dischar6e piping, major mechanical equipment, and structures supporting
'and housing the AFW system items..
Additionally, licensee's responses provided a description of the methodologies, loading ~ combinations and acceptance criteria that were used in the design of the seismically qualified portions of the AFW system, by referring to the appropriate sections of the'FSAR.
r 3
CONCLUSIONS The information con,tained in licensee's responses to the Generic Letter 81-14 is domplete.
The licensee conducted a partial walk-down of the non-seismically qualified areas of the AFW system.
Also, -
the valve arrangement in the AFW system boundary does not fully con-
' form to the definitions specified in the Generic Letter 81-14.
Based on submitted information, we conclude that presently the AFW system is not likely to withstand an SSE.
Therefore, we re-commend the NRC consider requiring the licensee:
(a) to reanalyze and/or modify the non-seismically quali"i-ed portions of the,AFW system, and (b) to complete the walk-down of the non-seismically qualified ccmper.ents of the AFW system withir. a resscnable time, under !;RC J' ; *: t i - I s r. : Action ?lan C-14.
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REFERENCES e
1.
D. C. Eisenhut, U. S. Nuclear Regulatory Commission, memorandum to H. R.'Denton, "Multiplant-Action Plan C-14; Seismic Qualification of Auxiliary Feedwater Systems," February 20, 1981.
2.
U. S. Nuclear Regulatory Commission, Generic Letter No. 81-14 to all operating pressurized water reactor licensees, " Seismic Qua-lirication of Auxiliary Feedwater Systems," February 10, 1981.
3 H. D. Hukill, Metropolitan Edison Company, letter to D. G. Eisenhut of U. S. Nuclea'r Regulatory Commission, September 29, 1981.
4.
H. D. Hukill, Metropolitan Edispn Company, letter to D. G. Eisenhut of U. S. Nuclear Regulatory Commission, December 8, 1981.
5.
H. D. Hukill, Metropolitan Edison Company, letter to D. G. Eisenhut of U. S. Nuclear Regulatory Commission, "EFW Seismic Qualification -
Electrical," Feb'ruary 16, 1982.
6.
U. S. Nuclear Regulatory Commission, letter to Metropolitan Edison
~
Company, "Requ.est for. Additional Information on Seismic Qualifica-tion of the Auxiliary Feedwater System, Three Mile Island Nuclear Station, Unit 1," April 5, 1982.
7:
H. :. Hukill, ::etropolitan Edison Ccmpany, letter to J. F. Stol:
of U. S. Nuclear Regulatory Commission, July 7, 1982.
8.
H. D. Hukill, General Public Utility Nuclear Corporation, letter to-J. F. Stolz of U. S. Nuclear Regulatory Commission, September 14, 1982.
9.
'2
- . M u;:1 ; 1.
Ge..eral.;u'lic Utility ':uclear.Cor.:Oratien, letter F.
Et::: cf U.
S.
- acisar Ecqui:::ry C:rmicrien, Se, rte.ter
- 29. 1952.
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