ML20032C138

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Denies 810723 Request for Exclusion from Criteria Developed Upon Completion of Unresolved Safety Issue A-46.Meeting W/Util Would Be Beneficial to Discuss Proposed re-evaluation of Capability to Withstand Seismic Events
ML20032C138
Person / Time
Site: Haddam Neck, Millstone  File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 10/20/1981
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Counsil W
CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO.
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8111090067
Download: ML20032C138 (4)


Text

{{#Wiki_filter:~ 3 e Docket Hos. 50-213/245/336 OCT 2 01981 f L ' o~ 9 < < i d. / P s-Mr. W. G. Counsil, Vice President kbf.!Y (h j Nuclear Engineering and Operations -d Connecticut Yankee Atoraic Power Corpany E O C T - 0 3 1 " ~ S Northeast Nuclear Energy Company '[ 'l " "g'd "80^'" $/ Post Office Box 270 Hartford, Connecticut 06101 j b Cear Mr. Counsil: By letter dated July 23, 1981 you inforced NRC Chairman Nunzio J. Palladino of your intention to initiate a comprehensive reevaluation at the component level of the capabilities of Haddan Neck Plant, Millstone Unit No. I and 11111 stone Unit No. 2 to withstand credible seisnic events. You further stated in the letter to the Chairman that Northeast Nuclear Energy Company (NNECO) and Connecticut Yankee Atomic Power Company (CYAPCO) have concluded that an independert review of the seismic resistance capability for these plants is appropriate and announced your intention to develop a method of assuring that all electrical and nechanical equipment inportant to safety is appropriately qualified and to confirn that each plant can be brought to a safe shutdown Condition if subjected to a seismic event. YoJ noted that the NRC was enbarking on a program under Task A-46 of the Unresolved Safety Issues to deveiop an explicit set of guidelines for judging the adequacy of the seisnic qualification of mechanical and electrical equipment at all operating plants. You requested, based upon your initiation of a prograri to be defined by a later submittal, to be excluded from any progran initiated by the NRC as a result of its resolution of Task A-46. Your letter to D. G. Eisenhut, dated Septerber 15, 1981, submitted the description of the program that you plan to initiate and complete in approxi-nately one year. If you believe that the results of the program which you have described could produce an enhancerent of the capability of your plants to withstand the adverse effects of a seig..ic event, we encourage your initiative in this effort. However, we cannot, rior to the development of our guidelines, judge the acceptability of the criteria which forn the basis of your progran or grant exclusion, as you have requested, from the criteria that evolve during and upon the completion of Task A-46. l g sun a PDR oney .l. nne ronu m oo n secu cm OFFICIAL RECORD COPY wo mmw 1

fir. W. G. Counsil As we proceed with resolution of USI A-46, it would be beneficial to the staff to meet with you to discuss your progran and your basis for acceptability of seismic qualification. We would also share with you any insights we have developed. Sincerely. Origini signed by IL R. Denton j Harold R. Denton, Director Office of Nuclear Reactor Regulation DISTRIBUTION NRC PDR aA ;egcant{g(.- Docket u;/tMONLk Loca1 PDR eq/ ORB Reading n[ Lac?M)LNGtatg>0mgJy p DCrutchfield a HSmith WPaulson JShea OELD KKniel Rosztoczy Johnston Schroeder Glainas TMurley RVollmer DEisenhut ECase HDenton RMattson SHanauer PPAS BSnyder SCavanaugh (ED0-10896) SECY-81-2096 Ref: ED010744 / / DIR DE DI) /

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- ~. 3 81-2096 -f ~ 'Lo'99 ng D.te ~ No. i i NRC SECRETARi AT ' TO: O com-6 ion.,- o.t. XXU Ee.e. oirjoper. cen. couniei k O cons.ti.on soiic ior Public Aff. irs O secret.ry l-Q I Inspector & Aud6 tor I O poiicy Evenueiion - W. G. Counsil i incom;,, From: Northeast Utilities i To: cc: A Palladino 9/15/ 81 ..i To: Eisenhut _ o.. l-sub.ct: Haddam Neck Plant--seismic aualification of i i machanical anrf electric paidnment j i O P,.p.,. piy for n.tur. of: O ca.irm.n O c1. ,t O E DO, GC, CL. SO L, PA, S ECY, l A, PE i O si or. e omite.a i i j O R. turn ori in.i of incomin.itn r pons. { t For direct reply

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g e J September 15, 1981 Docket Nos. 50-213 50-245 50-336 B10308 i Mr. Darrell G. Eisenhut, Director i Division of Licensing -Ofi' ice of Nuclear Reactor Regulation U. G. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

(1) W. G..Counsil letter to N. J. Palladino,. dated July 23, 1981. Gentlemen: Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1 and 2 Seismic Qualification of Mechanical and Electrical ~ Equipment By Reference (1) Connecticut Yankee Atomic Power Company sCYAPCO) and Northeast Nuclear Energy Company (NNECO) identified the initiation of a seismic reevaluation program fo: the Haddam Neck Plant, and Millstone Unit Nos. I and 2. This design-specific reevaluation is intended to assure that all electrical and mechanical equipment important to safety is appropriately qualified and to confirm that each plant can be brought to a safe shutdown condition if subjected to a seismic event. This I concept was developed in light oft i o The recognition'that the ultimate responsibility for assuring safe o nuclear plant operation resides with the licensees. i. l o The need to utilize engineering resources officiently. Recent experiences and difficulties-on the issue of envirorraental l o qualification of electrical equipment. l o The Staff's plan to promulgate interim and final requirements on-seismic qualification. i me of L 8.L$92&#&f'7 e

i, - In view of tiis course of action, Reference (1) requested that we be excluded from any iterative process with the NRC Staff on seismic qualification which may be authorized by the Commission. As of this writing, we have not received any response from the Staff in this regard. We request a response on this point at your earliest con-venience, as it is an integral part of the program identified in i Reference (1). In any event, in fulfillment of the Reference (1) commitment to provide program details, CYADCO and NNECO hereby provide, Mechanical and Electrical Equipment Seismic Qualification Program. s Included within the scope of review for this program are all electrical } and mechanical components required to assure that the plants can be brought to a safe shutdown condition if subjected to a seirmic event. The specific listing of components being evaluated in this program is being finalized and will be made available to the Staf f if required. The program description in Enclosure 1 has been segregated into eight major parts: o Introduction o Background o Definitions o Program Description. o Modeling, Analytical, and Testing Techniques. o Load Combinations and Acceptance criteria. o Equipment Damping. o References. Regarding the Program Description, we invite your attention to the use of the Delphi evaluation method as an important verification tool. The Program contemplates that first, 5 - 10 percent of the equipment re-quired for safe shutdown will be evaluated and analyzed in detail. An additional number of corponents will be evaluated by means of the Delphi method. This method consists of en evaluation of the seismic resistance capability of additional equipment, by independent expert consultants, based upon a detailed physical inspection. The individual ratings are then processed statistically to arrive at. a consensus estimate of the seismic capability. We believr. this method constitutes an efficient and effective way of evaluating and verifying the design adequacy of that equipment not included in the detailed evaluation sample. The apprcp-riateness of this method is supported by the principles identified in the Attachment to Reference (1). t

^ . Although not explicitly addressed in Enclosure 1, the program will maximize the use of data available from other ongoing seismic related activities at our three operating facilities. These includes o SEP related structural analyses, o Cable tray and conduit raceway evaluation program. Electrical equipment qualification program, o Piping reanalyses associated with the SEP and I&E Bulletin 79-14. o o Generation of plant-specific floor response spectra. We currently estimate that the total duration of this program will be a period of approximately one year from the date of this letter. The plant walkdowns, in-situ inspection, and testing of selected components is scheduled to be completed during the calendar year 1981. We intend to provide the Staff periodic status reports as appropriate, with due consideration given to feedback received from the Staff and the availability of interim results of this program. We trust you find this information sufficient to reach a favorable decision regarding the acceptability of this program in lieu of participation in any URC Staf f iterative process. Very truly yours, CotmECTICUT YANKEE ATOMIC POWER COMPANY NORT!! EAST !MCLEAR ENERGY COMPANY f[/M[$L W. G. Counsil Senior Vice President cc: See Attached List l l l i f I l l l t l l e I I L

L . The lionorable Nunzio J. Palladino cc: Chairman, Naclear Regulatory Commission Commissioner John F. Ahearno Commissioner Peter A. Bradford Commissioner Victor Gilinsky Comissioner Thomas M. Roberts [ Mr. J. Carson Mark t Chairman, Advisory Committee on Reactor Safeguards William J. Dircks, Executive Director for Operations Mr. Harold R. Denton Mr. Victor Stello, Jr. Mr. Richard H. Vollmer Mr. Dennis M. Crutchfield Mr. Robert A. Clark Mr. Zoltan R. Rosztoczy Mr. William T. Russell --4

= _.. } Docket Nos. 50-213 50-245 50-336

s 1

l ENCI4SURE 1 MECllANICAL AND ELECTRICAL EQUIPMENT SEISMIC QUALIFICATION PROGRAM 4 }. ^ i 1 IIADDAM NECK PLANT j MILLSTONE NUCLEAR POWER STATION, UNIT NOC. 1 AND 2 l-4 l SEPTEMBER, 1981 I , _.. _, _ _. -,. ~ ~.,...

1. INTRODUCTION 1 The purpose of this program description is to define the procedures by-i which the Haddam Neck Plant and Millstone Nuclear Power Station, Units No. 1 and 2 Seismic Category I mechanical and electrical equipment, necessary for safe shutdown of the reactor, shall be seismically evaluated. The evaluation shall determine if the necessary safety function and structural integrity can be assured during and following a Safe Shutdown Earthquake seismic event. Furthermore, this program shall define the basis by which equipment shall be selected for-review to determine a seismic design adequacy. 2. BACKGROUND The Haddam Neck Plant and Millstone Nuclear Power' Station Seism"c Category I mechanical and electrical equipment was designed and constructed to be capable of a safe shutdown of the reactor in the event of a zero period ground acceleration as defined in the applicable FDSA, FSAR's and current technical specifications. The design basis earthquakes used in the original. designs were essentially characterized by the mean centered Housner type ground response spectra. Various methods of treating additional amplification through the building structures were employed 1 at the Haddam Neck and Millstone Nuclear Power Plants. -The load combinations, damping values and behavior acceptance criteria used in the design are also defined in the applicable design documents. s - t The state-of-the-art af seismic analysis and design has' changed signifi-cantly during the design, construction, and_ operation of these three l. plants. Some of these changes applicable to one or all of these plants include: i o Use of mean plus one sigma ground spectra rather than mean spectra-o rigorous use of floor response spectra as design input o horizontal earthquake motion defined as-two'orthogonal components rather than a resultant o changes in damping values considered in design o ' changes in methods used to qualify electricai equipment by test Because of the numerous changes which have taken place in the seismic qualification requirements for mechanical and electrical equipment since the Cor,nacticut Yankee and the operating Millstone units were designed and built, this qualification program has been developed to reevaluate the seismic design adequacy of the mechanical and electrical equipment in light of current requirements. 4 ..e t

  • 3.

DEFINITIONS In order to assist in the understanding of the scope of effort covered by this qualification program the following nomenclature is defined. 1. Mechanical Equipment - Equipment such as pressure vessels, tanks, heat exchangers, coolers, chillers, pumps, valves, ducts and their supports which are used to process fluids identified as Seismic Category I which are required to shutdown and maintain the nuclear power plant in a safe shutdown condition. 2. Elect-ical Equipment - Equipment such as raotors, switchgear, motor conti ol centers, relays, control panels, battery racks, M-G sets and transformers and their supports which are used to power, instru-ment or control Seismic Category I equipment which are required to shutdown and maintain the nuclear power plant in a safe shutdown condition. Electrical equipment contain assemblies of devices formed into a structural entity. For structural evaluation purposes electrical equipment are groupcd into 3 basic categories: (a) Panel doards - Box shaped structures which generally have elec-trical devices mounted on the front face for display purposes. Often the structure is large enough to permit personnel entry to service the back of the display panel. Because of their size latera! restraint is usually provided by lineal structural frame elements.to a self-standing back structure or existing building wall. (b) Cabinets - Enclosed self-standing box shaped structures made up either of lineal framing members covered with metal plate or metal plate membranes joined by tack welded, bolted or sheet metal screws. Contained electrical devices usually sit on shelves supported by the cabinet frame or plate. (c) Racks - Vertical cantilevered pianner structural frames supporting attached electrical devices. 3. Components - Identificable electrical items such as resistors or capacitors, used to construct devices. Normally, seismic qualifi-cation is not at the component level. 4. Devices - Assemblies of electrical components designed to perform a specific function. Normally the smallest assembly of components which has received seismic qualification. 5. Active Devices - Required to move or otherwise change state in order to perform its safety function during or following a seismic event. 6. Passive Devices - Required only to maintain structural or leak tight integrity in order to perform its rafety function during or following a seismic event. For electrical components, electrical characteris-tics must also be maintained.

, 4. PROGRAM DESCRIPTION 4.1 General Seismic Reevaluation of Equipment All seismic Category I equipment oc devices required for safe shutdown shall be identified and an individual Equipment or Device Survey Form as shown in Attachment A prepared. The equipment will be surveyed using the Check List and Procedure shown in Attachment B. As a result of this survey and an ir, situ inspection, an Evaluation of Equipment Seismic Resistance Work Sheet shall be prepared for each item of equipment by a team of individual consultants having expertise in determining the design resista g of mechanical and electrical equipment by means of the Delphi Method. A sample of the work sheet-intended for this use is provided as Attachment C. A total sample size of the criti. cal equipment identified for a detailed reevaluation shall be approximately 5-10 percent of the Category I equipment identified as required for safe shutdown. A seismic analysis or test of the critical equipment selected for detail review shall be performed and the resultant seismic design capacity determined. These detailed analyses and tests shall be used not only to validate the seismic design capacity of the particular equipment analyzed or tested but also to demonstrate the applicability of the Delphi Method for seismic qualification of the Seismic Category I equipment not reevalu-ated in detail. 4.2 Selection of Equipment for Detailed Reevaluation Selected critical mechanical and electrical equipment using rigorous analytical or test methods shall be evaluated in detail to determine current seismic design adequacy. The types of critical mechanical and electrical equipment and distribu-tion systems to be evaluated are summarized as follows: i (a) Tanks and Vessels l (b) Heat Exchangers l (c) Pumps (d) Motor Operated Valves I (e) Electrical Panel Boards l (f) Electrical Equipment Racks l (g) Electrical Cabinets (h) HVAC Equipment I (i) HVAC Ducts [ Evaluation of equipment shall include consideration of active as well as passive modes of failure as applicable. The criteria for selection of critical equipment to be evaluated are as follows: l l

. (a) Critical equipment required for safe shutdown shall be iden-tified based on functional importance. (b) Based on a walk-through and insitu inspection, particular items of; equipment shall be' selected from the critical list which are considered to exhibit a high sensitivity to seismic loading. 5. MODELING, ANALYTICAL AND TESTIAG TECHNIQUES 5.1 Modeling and Analytical' Techniques { I In general the same analytical models and techniques developed _for the original seismic design and analysis shall be used in the evaluation of seismic capabilities. Deviations from such models and techniques shall be identified and used only when the original analysis is clearly inappro-priate. These deviations s }lgebasedonthecurrentstate-of-the-art ,3 concerning seismic analysis All component analysis shall use elastic systems analysis to proportion loading to the component, attached systems, and supports. 5.2 Testing Efforts shall be made to secure seismic qualification test results from .) manufacturers for devices and equipment where such data currently exists. The seismic input to such devices installed in equipment shall be deter-mined by either analytical or insitu low impedance vibratory test methods. 6. LOAD COMB: NATIONS AND ACCEPTANCE CRITERIA 6.1 LoadCombintpons The equipment seismic review shall be conducted for the following load combination: U = 1.0D + 1.0L + E, where: 0= Limiting load on the equipment, device or component D= Dead load L= Operating live load during normal operation plus any live load occurring as a direct result of earthquake loading. Live loads shall include thermal effects in those cases where thermal effects include loads which are considered as primary (i.e. vessel nozzles and component supports) E = S fe Shutdown Earthquake load s

. l l f 6.2 Acceptance Criteria for passive devices (structural and leak tight integrity only) total stresses resulting from the loading, U, shall be limited as defined in the FSAR except as follows: (a) Current ASME/ACI Code or Standard Review Plan limits may be used provided material selection and fabrication requirements are comparable to current code requirements. Actual measured or sampled material properties may be used (b) rather than specified minimum yield or crushing strength. For active devices (must operate or change state), total stresses resulting from the loading 0, shall be limited to normal code allowable plus 20 percent, but in no case shall exceed 0.8 times yield or the onset of non-linear behavior. Devices qualified by test, to seismic inputs equal to or exceeding the safe shutdown level of earthquake excitation, may be used in lieu of analysis to qualify components. 6.3 Seismic Input The seismic input to the reetaluation of equipment shall be based on site specific floor response spectra currently under development for the Haddam Neck and Millstone facilities. 7. EQUIPMENT DAMPING Thedampingvaluesusedinthisseismicreviewshallbegggedonthe with modi-damping values given in Table 1 of Regulatory Guide 1,61 fications to equipment damping as shown in Table 1 of this program The modification of damping values used in these criteria description. are based on the recommendations and data contained in References 5, 6, 7, and 8.

.. 8. REFERENCES (1) Cor3 tis, R. B., et. al. "Delphi Method: Theory.and Design Application,"- Vol. St6 Journal Structural Division of American Society of Civil Engineers, June 1981. (2) Boiler and Pressure Vessel Code Section III, Appendix N - Dynamic Analysis Methods, American Society of Mechanical Engineers, 1980. (3) StandardReviewPlan,Section3.7.2,"SeismicAnalysis",U.S. Nuclear .? Regulatory Commission, June-1975. l (4) Regulatory Guide 1.61, " Damping Values for Seismic Design of Nuclear. Power Plants," U.S.- Atomic Energy Commission, October 1973. (5) Lawrence Livermore Laboratory, Seismic Review of Dresden' Nuclear. Power Station - Unit 2 for Systematic Evaluation Program, NUREG/CR-0891, April 1980. (6) Bohm, G. J., " Damping for Dynamic Analysis of Reactor Coolant Systems," Presented at the National Topic Meeting, Water Reactor Safety of the American Nuclear Society, Salt Lake City, 26-28 March 1973. (7) Morrone, A., " Damping Values of Nuclear Power Plant Comporents," Report WCAP-7921 Westinghouse Nuclear Energy Systems, Nov. 1972. h (8) Stevenson, J. D., " Structural Damping Values us a Function of Dynamic i Response Stress and Deformation Levels", Nuclear Engineering'and Design, Ve'. 60, 1980. j 1 i f f i l l [ l t. I -,... -,., _,... -,,.,,,......., _, -,. -.. ~..., _. _... ~,..., _ _ _. ~ _ _ _, _. _. _ _ _,. ~, -. _ ~ _ _ -.., _...,.

. TABLE 1 Damping Values - Percent Critical to be Used jg)the Seismic Margins Review for Passive Components' Structure or Component Percent Critical Damping 4.0( ) Large diameter piping systems Pipe diameter 12 in. Small diameter piping systems 3.0(l) Pipe diameter 12 in. 4.0(3) Welded Steel Structures 7.0( ) Bolted 5 teel Structures Welded Steel Components (2) 4.0 Bolted Steel Components ( ) 7.0 7.0(3) Reinforced Concrete Structures 5.0(3) Prestressed Concrete Structures (1) ThegvquesarebasedontestperformedbyWestinghouseElectric Co. (2) Thesedampingvaluesareconsistentwithdampingvaiuesdefinedfg) welded and bolted structures and by review of existing test data (3) R.G. 1.61 OBE damping levels shall be used as structural damping in generation of floor response spectra where total calculated stresses in the structure for the SME do not exceed 1/2 yield. (4) Damping values used in evaluation of active components shall be reduced in the same proportion of OBE to SSE damping values as defined in Table 1 of R.G. 1.61. i ~

_9_ ATTACHMENT A EQUIPMENT OR DEVICE SURVEY FORM I.D. No. Item

Description:

L'ocation: 1) General Description, Photograph, or Sketch of Supports: I 2) Check List: A) Base Plate:

1) Base Plate Dims:
2) Bolt Holes:

a) Number b) Spacing c) Size d) Edge Distance B) Specify means of attachment of equipment to structure:

1) Bolted:

a) Poured in Place Bolts: i b) Expansion Anchor Bolts: c) Welded Bolts:

3) Other:

C) Description of Additional Attachments (bracing, gussetts, etc.)

1) Number:
2) Location:

= A -s: ~ " 1.D. No. I

3) Dimension:
4) Size:

D) Gen 3ral Condition - Visual Inspection: 3 % s 1) Welds (AWS Dl.1 para. 8.15.1) , (, ,a a) Cracks: .i -(\\ i,_ b) Fusion: ,i , s c) Craters: d) Profiles: s e) Fillet Size: 2) Bolts: 4 a) Fit: b) Relative Size (Bolt to Hole): t i rv s c) Material: 4 1 N E) General Equipment Dims: g 3 4 x w ) y r ) e 't N-e, 3 p 9. s ^ s. .\\ '\\ F) Estimated Weight. T Estimated Location of C.G.: sN s. G) Is component supported or restrained by block wall Yest No H) General Comments: t g g n l ji E_ ,f -l l \\e

, e f- -e ~~ L 3-jm.. _.. ~ s..,, 4 .{. -11a w 1, n - a, s ,7 9 F s $ '" g ATTACHMENT B s] j 1 + 7 f ( CHECX.l.IST AND PROCEDURE FOR INVESTIGATION OF

  • EQUE 5NT TO EVALUATE SEISMIC DESIGN ADEQUACY

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4 The survey con ist,s of the following activitie.i
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~ e 1. An "as built" description of't le means' of ' attachment of each of the equipment listed to,the floor or other support system. 5/

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2. vQdentify for each equipmentj listid'the following: Numberhndlegathn'ofholesdiP ^ awbase dircensions and / \\) into the plate .electricaleqd:pmentbaseasweli.hdorpunched a / J k l / .Y' thickness. .; I t ' ' } Specify the'(aeans by which the electdcal equipment is attached e i b., to support structure. h. 6 i, (1), Anchor f alts eMedded in coMete support structure I ? 5(Poured'in Ple.e) T' f } I /R' ( 3 (2) hnchor bditb'Im,oetded in concrete suppor,t structure +. (Expansion Ar' chop ,y-T u gc (S)s Ancpo,r bolts. welded to embedded or other. steel structure y _v_ t. my

s (ki)\\ Dimhnsi>f anil thickness of embedment steel if available

-g,,4,4 g4 _ [3 _ g -(5)~ Plu'g%lt.faping existing holes) to embedded or other ~ steel sgruptpre s e h 4 't i or T -{ .(6) Tack. v ish.o embedded or other steel structure

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,\\ , [) Fillet welds to embedded or other steel structure d' 3, a, ) t . '/' ((, (8) Otheb j l [ .?x' !\\ q, t Descripfion'pf tha at.tachments to include numbek, location, if ( y' dimension and pize of,the attachment. 4' 1 7 4,' ir / d. General condition of tlie attachment.

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3' (1) Visual inspection of the welb\\irf accordance with the requirement of' AWS Dl.1, Pare. 8.K.1 Visual Inspection i U m "1, (2) Viyaal inspection of bS'iks/gf identify fit, size of holes ei refative,to bolt size and tightness of nut and identifica- -e P j ', tion of bolt material if possible n s t u i el 1 Give overall dimension of electrical equipment. t ' }t 1 r (' f5 } Give est.imate of equipment weight and iocation of C.G. .t A* s' # * / ,f - i. t ,b 6

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. g,. g1 ; s -A ? y ..9ei.. . [ 91 , 1% L. ~ c } 4.: f. p y"Q ,1 4 WORK SHEET EVALUATION OF EQUIPMENT SEISMIC ~ RESISTANCE j Device Title j. System Title ___ I.D. No. Equipment Title t Horizontal resultant and vertical component

1.. Comments-on degrde;of restraint, r,igfidity acceleration levels input to equipment that it of supports, stiffriess. mass, etc.

3 M is adjudged capable of surviving to the first failure mode with probabili'.ies noted. 2. -Estimateof.fdominantorfundamental-frequencies. u, + 31 Descriptinn of. expected first failure node. .v-l

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g Level 4. Commer.ts on the condition of' the. item and ' I{ Probchility, its support as to the degree of corrosion,

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Perc q Horizontal Vertical bolt' tightness, etc. 90 5. Comments on damaging effects of surrounding 50 10 components. 6. Recommended modifications, tests, analyses, etc. 6.1 As a' function of acceleration level. 6.2 Independent of acceleration level. _. _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.}}