ML20070H506
| ML20070H506 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/22/1982 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20070H508 | List: |
| References | |
| TASK-AS, TASK-BN82-118 BN-82-118, NUDOCS 8212270041 | |
| Download: ML20070H506 (5) | |
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RHartfield DISTRIBUTION tiemo File RJacobs IE CDocret Fi_le Gray File JVan Vliet PPAS Docket No. 50-289 NRC PDR ECase RIngram MWilliams L PDR DEisenhut JStolz AE0D ORBil4 Rdg Glainas MJambour GMeyer MEMORANDUM FOR: Atomic Safety and Licensing Appeal Board for THI-l FROM:
Gus C. Lainas, Assistant Director for Operating Reactors, Division of Licensing
SUBJECT:
BOARD NOTIFICATION (BN-82 Il8) - THREE MILE ISLAND UNIT NO.1 (TMI-1) RESTART HEARING The NRC memorandum (enclosed) from F. J. Miraglia tc G. C. Lainas,
Subject:
TMI-1: Seismic Resistance of Auxiliary Feedwater Systems (AFWS) dated November 3,1982, is related to the TMI-l hearing issue of emergency feedwater reliability. The letter encloses a technical evaluation report (TER) from our consultant, Lawrence Livermore National Laboratory (LLL), responsible for the review of the seismic resistance of auxiliary feedwater systems for all pressurized water reactors (PWRs), identifying the LLL review results for TMI-1, that:
(1) the present AFW may substantially lack the capability to withstand a postulated safe shutdown earthquake, (2) the licensee did not conduct a complete walkdown of the AFWS, (3) the licensee has not volunteered commitments that appropriate actions would be taken for all the deficiencies identified, and (4) the licensee did not describe an alternate system for decay heat removal.
Although aspects of the EFS were extensively discussed in the TMI-l restart hearing, the issue of seismic capability of the emergency l
feedwater system was not explicit y considered during the Tf!I-l hearings.
The TMI related events considered for the emergency feedwater system reliability evaluation included only the small break loss of coolant accident and feedwater transients.
Seismic qualification was a future issue ~ to be considered separately by the Staff for all operating plants, the results of which review were to be issued at a later date, such as those in the enclosed memorandum.
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- PDR ADOCK 05000289 Gus C. Lainas, Assistant Director P
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11/3/82 Memo to Glainas A
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Docket No. 50-289 MEMORANDUM FOR: Atomic Safety and Licensing Appeal Board for TMI-l FROM:
Gus C. Lainas, Assistant Director for Operating Reactors, Division of Licensing
SUBJECT:
BOARD NOTIFICATION (BN ) - THREE MILE ISLAND
/
UNIT NO.1 (TMI-l) RESTART HEARING j
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The NRC memorandum (e'nclosed) from F. J. Miraglia tc G. C. Laina/
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Subject:
TMI-1: Seismi'c Resistance of Auxiliary Feedwater Systems (AFWS) s dated November 3,1982, is}related to the TMI-l hearing issu6 of emergency feedwater reliab lity. The letter encloses a technical evaluation report (TER) from'our consultant, Lawrence Lipermore National Laboratory (LLL), res'ponsible for the review of the seismic resistance of auxiliary feedwatdr systems for all pregsurized water reactors (PWRs), identifying the L1L review results for TMI-1, that:
(1) the present AFW may subs'tantially lack tfie capability to withstand a postulated safe shutdown' earthquake,f(,2) the licensee did not conduct a complete walkdown of the\\AFWS, (3) the licensee has not volunteered commitments that appropriate \\ action,s would be taken for all the deficiencies identified, and (4) the l'cef1see did not describe an alternate system for decay' heat removal.
The issue of seismic capability of the epergent feedwater system was not considered during the TMI-1 becaus low probability natural events such as earthquakes, were,hearingnexus to gents related to the not a TMI accident that were the ' ases ferjthe TMI-l res art evaluation. The u
TMI related events considered for tKe emergency fee water system relia-bility evaluation included the smal'l break loss of c lant accident and feedwater transients.
Seismic qualification was a fu re issue to be considere separately by the Staff for all operatin plants, the results of whi review were to be issued at a later dat, such as those in the enclos memorandum.
The Staff's position regarfing emergency feedwater sy tems re iability l
remains unchanged from that contained in the TMI-l hearing reco d.
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Glainas ACRS-16 JGray OR Rd9 RJacobs Ri:artfield JScinto-2 Docket No. 50-289 JVan Vliet OIE T1Cutchin JStol z PPAS EChristenbury RIngram f1Milliams AE0D G!! eyer MEMORANDUM FOR: Atomic Safety and Licensing Appeal Board for THI-l FR0f1:
'Gus C. Lainas, Assistant Director for Operating i Reactors, Division of Licensing
SUBJECT:
BOARD NOTIFICATION (BN ) - THREE MILE ISLAND
/-
UNIT NO. 1 (TMI-1) RESTART HEARING
/
./
J The NRC memorandum (enclosed) from F. J. Miraglia tc G. C. Laina
Subject:
TMI-1: Seismic' Resistance of Auxiliary Feedwater Systems (AFWS) dated November 3,1982, is related to the TMI-l hearing, issue of emergency feedwater reliability. The letter encloses,a technical evaluation report (TER) from our consultant, Lawrence Livanore National Laboratory (LLL), responsible for the review of the seismic resistance of auxiliary feedwater systems for all pressurized water reactors (PWRs), identifying the'LLL review results for TMI-1, that:
(1) the present AFW may substantially lack the capability to withstand a postulated safe shutdown earthquake, (2) the licensee did not conduct a complete walkdown of 'the AFWS, (3) the licensee has not provided commitments that appropriate actions would be taken for all the deficiencies identified, and (4) the licensee did not describe an alternate system for decay heat ~ removal The issue of seismic capability of the e'mergency feedwater system was not considered during the TMI-l hearings because low probability natural events such as earthquakes, were not a nexus to events related to the TMI accident that were the bases fcr the TMI,-1 restart evaluation. The TMI related events considered for the emergency feedwater system relia-bility evaluation included the small break loss of coolant accident and feedwater transients.
Seismic qualification was a future issue to be considered separately by the Staff for all operating plants, the resulthof which review were a later date, such as those in the\\ enclosed memorandum.
to be issued at The Staff's position regarding the seismic issue on Amergency feedwater l
systems remains unchanged from that contained in the TMI-1 hearing
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l record.
Gus C. Lainas, Assistant Director for Operating Reactors, DL 3d
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V GPU Nuclear Corporation 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 Kepford Harrisburg, Pennsylvania 17101 Judith H. Johnsrud Environmental Coalition on Nuclear Power Union of Ccncerned 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 10004 Mr. Ronald C. Haynes, Regional Administrator U. S. N. R. C., Region 1 631 Pi rk Avenue King of Prussia, Pennsylvania 19406 Mr. Henry D. Hukill, Vice President and Director - TMI-l ANGRY /TMI PIRC GPU Nuclear Corpora' tion 1037 Maclay Street P. O. Box 480 Harrisburg, Pennsylvania 17103 Middletown, Pennsylvania 17057 John Levin, Esq.
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Pennsylvania Public Utilities Commission Box 3265 Harrisburg, Pennsylvania 17120
v,w,esvur meswusww
- rs o Federal Em;rgency Management Agency 5
Mr. Thomas G;rusky ATTN:
Docket Clerk Bureau of Radiation Protection 1725 I Str :t, NW Department of Environmental Resources Washington', DC 20472 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Karin W. Carter, Esq.
505 Executive House P. O. Box 2357 a
sburg, Pennsy hania m 20 G ee w
'1 ar v ful Washington, 0; C.
20007 Dauphin County Office Emergency G. F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge Preparedness 1800 M Str'eet, N.W.
Court House, Room 7 Washington, D. C.
20036 Front & Market Streets Harrisburg, Pennsylvania 17101 Mr. E. G. Wallace Licensing Manager GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 William S. Jordan, III, Esq.
Ms. Lennie Prough Harmon & Weiss U. S. II, R. C. - TI11 Site 1725 I Street, FN, Suite 506 P. O. Box 311 Washington, DC 20006 Middletown, Pennsylvania 17057 Ms. Virginia Southard, Chairman CiUnns for a Safe Environment 264 Walton Street Lenoyne, Pennsylvania 17043 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division 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 Tl11-1 GPU Nuclear Corporation Regional Radiation Representative P. O. Box 480 Middletown, Pennsylvania 17057 EPA Recion III Curtis Building (Sixth Floor) 6th and Walnut Streets Philadelphia, Pennsylvania 19106 Governor's Office of State Planning Mr. Richard Conte Senior Resident Inspector (TMI-1) and' Development U.S.N.R.C.
ATTN: Coordinator, Pennsylvania P. O. bc 311 State Clearinghouse
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Middletown, Pennsylvania 17057 P. O. Box 1323 Harrisburg, Pennsylvania 17120 l
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'.Gus C. Lainas. Assistant Director,-
for Operating Reactors As we have done in other review actions for other plants, before we complete this review and prepare a safety evaluation report and resultant recommendation, we would like to be certain that our understanding of the AFW design is correct.
Therefore, the licensee should be asked to review and provide any comments on the TER and to provide any other information relevant to our reaching a position on what upgrade actions may be required and on a schedule appropriate for up-grading.
The licensee should be advised that at this time we do not agree with the consultant's conclusion regarding the adequacy of the seismic capability of the condenser hotwell supply lines (reference: Section 2, item (1) Piping, of the TER).
ke are continuing to review the approach of handling a post-ulated break of this piping with revised opersting procedures, since the CST low water level alarms, which would trigger the procedure, are not seismically qualified either.
The licensee should be specifically requested to address this matter in this review of the TER.
Please keep us informed on this matter.
h6-
.pa u Frank J. Miraglia, Assistant Director
~
for Safety Assessment Division of Licensing Enclosurc+
Technical Evaluation Report cc w/ enclosure:
D. Eisenhut J. Stolz
- 2. Ji n bs J. Van'll iet V. Panciera S. Lu, LLN L
Contact:
J. T. Bea rd x27465 e
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for Operating Reactors As we have done in other review actions for other plants, before we complete this review and prepare a safety evaluation report and resultant recommendation, we would like to be certain that our understanding of the AFW design is correct.
Therefore, the licensee should be asked to review and provide any comments on the TER and to provide any other information relevant to our reaching a position on what upgrade actions may be required and on a schedule appropriate for up-grading.
The licensee should be advised that at this time we do not agree with the consultant's conclusion regarding the adequacy of the seismic capability of the condenser hotwell supply lines (reference: Section 2, item (1) Piping, of the TER).
ke are continuing to review the approach of handling a post-ulated break of this piping with revised opersting procedures, since the CST low water level alarms, which would trigger the procedure, are not seismically qualified either.
The licensee should be specifically requested to address this matter in this review of the TER.
Please keep us informed on this matter.
h6-
.pa u Frank J. Miraglia, Assistant Director
~
for Safety Assessment Division of Licensing Enclosurc+
Technical Evaluation Report cc w/ enclosure:
D. Eisenhut J. Stolz
- 2. Ji n bs J. Van'll iet V. Panciera S. Lu, LLN L
Contact:
J. T. Bea rd x27465 e
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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 pre ~sent level of seismic capability of the initiation / control systems is less than OBE.
Structures - The turbine building is sgismic Class II and o
with some stiTrening it dould withstand OBE.
Some portions of the essential power supplies and initiation / control systems for the AFW are' routed through the turbine building.
l Since the licensee currently has no plans to modify /spgrade.
I 1
I the, turbine build,ing, we judge that the present level of seismic capability of the struct6res supporting or housing
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the AFW system components is less oc-than OBE.
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Based on our evhluation described above, those areas of t h e A F'.-l system judged not to possess an SSE seismic capability.
are icentified below.
c Pumps / Motors
,'o n e o
Piping Less than OBE.
o Valves / Actuators None o
Power Supplies None" o
Water Source (s)
None o
Ir.itiation/ Control Systems Less than OBE o
Structures Less than.OBE
~
- e :
Fresently less than OBE, and will be fully qualified when the licensee's proposed upgrade / modification is completed.
4.
6 TECHNICAL EVALUATION REPORT THREE MILE ISLAND NUCLEAR STATION, UNIT 1 SEISMIC OU ALIFICATION OF. AUXILIARY FEEDWATER S'. STEM 1.
INTRODUCTION 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 recently undertaken Multiplant Action Plan C-14 " Seismic Qualification of AFW Systems" [Ref. 13, which is She subject of this evaluation.
~
To implement the f.irst phase of Action Plan C-14, the NRC issued Generic Letter No. 81-14 " Seismic Qualification of AFW Systems" [Ref.
2], dated February 10, 1981, to all operating PWR licensees.
This letter req'uested each licensee (l) to conduct a walk-down of n_on-seismically qualified portions of the AFW system and identify defi-ciencies amenable t'o' simplh~ actions to improve seis'aic resistance, and (2) to provide design information regarding the seismic capabil'ity of the AFW system to faci'litate NRC backfit decisions.
ta: -
l The licensee of Three Mile Island Nuclear Station, Unit 1 responded i
with letters dated September 29 and December 8, 1981, and February 16, 1962 [Refs. 3, 4 & 5].
The licensee's response was found not,to be conplete and a Eecuest for Additional Information (RAI) was issued by the IRC, dated April 5, 1982 [Ref. 6].
The licensee provided sup-plemental responses in letters dated July 7, September 14, and Seo-tember 29, 1982 [Ref. 7, 8 and 9].
o.
This report provides a technical evaluation of the inforsation provided in the licensee's responses to the Generic Letter, and
~
includes a recc mendation regarding the need for additional analysis e:-d /cr up rading modifications of this plant's AFW system.
-9
- ' ' ^ - - -
- - - ^ - -
6 TECHNICAL EVALUATION REPORT THREE MILE ISLAND NUCLEAR STATION, UNIT 1 SEISMIC OU ALIFICATION OF. AUXILIARY FEEDWATER S'. STEM 1.
INTRODUCTION 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 recently undertaken Multiplant Action Plan C-14 " Seismic Qualification of AFW Systems" [Ref. 13, which is She subject of this evaluation.
~
To implement the f.irst phase of Action Plan C-14, the NRC issued Generic Letter No. 81-14 " Seismic Qualification of AFW Systems" [Ref.
2], dated February 10, 1981, to all operating PWR licensees.
This letter req'uested each licensee (l) to conduct a walk-down of n_on-seismically qualified portions of the AFW system and identify defi-ciencies amenable t'o' simplh~ actions to improve seis'aic resistance, and (2) to provide design information regarding the seismic capabil'ity of the AFW system to faci'litate NRC backfit decisions.
ta: -
l The licensee of Three Mile Island Nuclear Station, Unit 1 responded i
with letters dated September 29 and December 8, 1981, and February 16, 1962 [Refs. 3, 4 & 5].
The licensee's response was found not,to be conplete and a Eecuest for Additional Information (RAI) was issued by the IRC, dated April 5, 1982 [Ref. 6].
The licensee provided sup-plemental responses in letters dated July 7, September 14, and Seo-tember 29, 1982 [Ref. 7, 8 and 9].
o.
This report provides a technical evaluation of the inforsation provided in the licensee's responses to the Generic Letter, and
~
includes a recc mendation regarding the need for additional analysis e:-d /cr up rading modifications of this plant's AFW system.
-9
- ' ' ^ - - -
- - - ^ - -
~
In summary, our evaluation indicated that the licensee's AFW system does not possess an overall seismic capabili'ty.that can withstand an SSE.
~
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3 The primary water source 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, f.ailure 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 r
from' th.e nex t..( Cycle.Ro. 6) refueling.
Modifications recommended by the licensee include:
(a) Power supply modifications that have been mentioned under the power supplies evaluation.
(b)
Y3 ant operating procedures for AFW system would be changed to provide guidanc~e to'the bperator to isolate the CST from the AFW system by clcsing valves CO-V-lll A & B and CO-V-14 A & B frc= 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 is available from the reactor ouilding emergency cooling pumps and it is entirely. seismic Class I.
This water supply enters the AFW pump'ccmmon suction header between two sectionalizing valves EF-V-1 A & B.
Manual actions are required to access this. backup water supply.
Two series motor operated valves (EF-V 4 & 5) to the river water syster are normally kept' locked c1csed and the T.otcr control cen er breake.ds for'these valves are 1e:ked open.
If the backup supply of river water to the AFW system is needed, these locks will be removed and the breakers - -
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2.
EVALUATION Information-provided in licensee's responses included:
o Specification of the overall seismic capability of the AFW system.
o Identification of AFW system components that are currently non-seismically qualified for SSE.
o D'escripti,on of, procedure for switchover to a seismically qualified secondary water source.
o Discussion of levels of seismic capability of non-seismically qualified components.
Description of the AFW s'ystem boundary.
c o
Status of compliance with seismic related NRC Bulletins and Information Notices.
o Results of walk-down of non-seismically qualified areas.
o Additionallyt, schematic sketch of the AFW system.
o' '
Additionally, description of methodologies and acceptance criteria for seismically qualified components.
ec-s 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.
I (1)
Seisnic Capability of AFW System Except for thdse items identified in the following, the AFW system has been designed, constructed..and maintained to with-
~
stand an SSE utilizing methods and acceptance criteria consistent with that applicable to other safety-related systems in the plant.
.resently, those items identified by the li. cense'e as not being fully seisnically qualified are evaluated below:
o Pumos/Motorg - None
\\
2.
EVALUATION Information-provided in licensee's responses included:
o Specification of the overall seismic capability of the AFW system.
o Identification of AFW system components that are currently non-seismically qualified for SSE.
o D'escripti,on of, procedure for switchover to a seismically qualified secondary water source.
o Discussion of levels of seismic capability of non-seismically qualified components.
Description of the AFW s'ystem boundary.
c o
Status of compliance with seismic related NRC Bulletins and Information Notices.
o Results of walk-down of non-seismically qualified areas.
o Additionallyt, schematic sketch of the AFW system.
o' '
Additionally, description of methodologies and acceptance criteria for seismically qualified components.
ec-s 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.
I (1)
Seisnic Capability of AFW System Except for thdse items identified in the following, the AFW system has been designed, constructed..and maintained to with-
~
stand an SSE utilizing methods and acceptance criteria consistent with that applicable to other safety-related systems in the plant.
.resently, those items identified by the li. cense'e as not being fully seisnically qualified are evaluated below:
o Pumos/Motorg - None
- -y o
Y.
closed.
The switchover proceduro to use the backup water sources j
is still under review by the licensee.
Seismic qualification information for any alternate decay heat removal system was re' quested by the Gene'ric 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.
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 wit.h 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 fully con-form to the definitions of GL 81-14.
The AFW system was included within the scope of IE Bulletin
~
75LO2, 79-04, 79-07,.79-14, 80-11 and IE Information Notice 80-21.
s (2)
Walk-Down of Non Seismically Qualified Portion of AFW System Walk:-d cwn has been performed in conjunction with'IE Sulletins 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 completed on 7/31/81, (d) Conduit to MSV-6 has loose clamp which needs to be hightened, (e) Conduit to EFW S3 had no clamps to hold it to existing s, tee,1 and'needs clamp,for security, (f) Unistrut supporting conduit to EF-V SC is Icese at the base and needs to be tightened.
The licensee stated that items (d) to (f) have been or will be completed - -
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'o Piping - (a) The portion of the recirculation lines for the emergency feedwater pumps between the manual isolation valves (EFV-20 A & B'and EFV-22) and the conde!nsate storage tank (CST)
"B" were not seismically designed. "These' lines will be upgraded to seismic 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 b'etween 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 lice.nsee, not all connected branch lines from the AFW system are seismic Class I beyond the first valve and up to a point".of three orthogondl ristraints.
(d) The' instrument air supply line
~
~~
from valve IA-V27 to the AFW system is not seismically qual-e, -
iried.
The licensee presented.no justification for items (c) and- (d) and didsnot 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 less than OBE.
o 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.
c Pcwer SucDlies - Portions of the pcwer. supplies have been id e r. ti fi e d by the licensee as nor.-seismic Class I in a recent evaluation.
They include:
(a) Pcwer supplies for -
o
-a W
'o Piping - (a) The portion of the recirculation lines for the emergency feedwater pumps between the manual isolation valves (EFV-20 A & B'and EFV-22) and the conde!nsate storage tank (CST)
"B" were not seismically designed. "These' lines will be upgraded to seismic 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 b'etween 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 lice.nsee, not all connected branch lines from the AFW system are seismic Class I beyond the first valve and up to a point".of three orthogondl ristraints.
(d) The' instrument air supply line
~
~~
from valve IA-V27 to the AFW system is not seismically qual-e, -
iried.
The licensee presented.no justification for items (c) and- (d) and didsnot 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 less than OBE.
o 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.
c Pcwer SucDlies - Portions of the pcwer. supplies have been id e r. ti fi e d by the licensee as nor.-seismic Class I in a recent evaluation.
They include:
(a) Pcwer supplies for -
o
-a f.
prior to restart.
The walk-down, however, is not complete since it did'not cover all the non-seismically qualified items 1. den-tified under section (1).
(3)
AdditionalInformatiob The licensee provided schematic sketches of the AFW system including the water sources, heat sink, suction and discharge 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 I
the FSAR.
3.
CDNCLUSIONS ee-information con,tained in licensee's response's to the Generic The Letter 81-14 is complete.
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 beundary does not fully con-i~ c r.-
to the definiti:ns specified in the Generic Letter 81-14.
Based on submitted information, we conclude that presently the AFW system is not l'ikely to withstand an SSE.
Therefore, we re-commend the NRC consider requiring the licensee:
(a) to reanalyze and/or modify the non-seismically qualified portions of the AFW system, and (b) to complete the walk-down of the non-seismically qualified c:.;cr.er.ts of the AF% syrter within a reasonable time, under'NRC MU;-iplant Action Flan C-14.
~
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M UNITED STATES A
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NUCLEAR REGULATORY COMMISSION p7p y
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WASHifwGTON. D. C. 20555
&' 5Yi:.' ' l gm4 NQg8 %4thz ME!ORANDUM FOR:
Gus C. Lainas, Assistant Director for Operating Reactors Division of Licensing FROM:
Frank J. Miraglia, Assistant Director for Safety Assessment
' Division of Licensing
SUBJECT:
114REE MILE ISLAND UNIT 1: SEISMIC RESISTANCE OF AUXILIARY FEEDWATER SYSTEMS The NRC Multiplant Action C-14. " Seismic Qualification of Auxiliary Feedwater Sys.tems" ( AFW) was implemented by the issuance of General Letter No. 81-14 under 10 CFR-50.54(f).
This letter requested each PWR licensee to (1) con-duct a walkdown of any non-seismically qualified portion of the AFW and to identify deficiencies amenable to simple actions to improve seismic resistance, and (2) provide design information regarding the seismic resistance of the AFW Additionally, this letter requested that, if the review of the. AFW system.
indicated. a substantial lack of" seismic capability,_ the licensee should describe any alternate system for decay heat removal.
We are reviewing the licensee's responses to this generic letter including replies to our requests for additiona information.
For TMI-1, our review has progressed to the point of having)a final Technical Evaluation Report (TER) from our consultant, Lawrence Livermore National Laboratory.
A copy of this TER is enclosed.
The TER indicates that:
(1) the present AFW may sut:stantially lack the capability to withstand a postulated safe shutdown l
earthquake, (2) the licensee did not conduct a complete walkdown of the AFW l
system, (3) the licensee has not provided commitments that appropriate actions would be taken for all the deficiencies identified, and.(4) the license'e did not describe an alternate system for decay heat removal.
NRC generic correspondence of October 21, 1980 and February 10,1981 have stated clearly that our intent is to increase the seismic resistance of AFW systems'to the extent practical so as to provide reasonable assurance that they will be able to function following an earthquake of SSE magnitude.
./
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UNITED STATES A
pg$
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NUCLEAR REGULATORY COMMISSION p7p y
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WASHifwGTON. D. C. 20555
&' 5Yi:.' ' l gm4 NQg8 %4thz ME!ORANDUM FOR:
Gus C. Lainas, Assistant Director for Operating Reactors Division of Licensing FROM:
Frank J. Miraglia, Assistant Director for Safety Assessment
' Division of Licensing
SUBJECT:
114REE MILE ISLAND UNIT 1: SEISMIC RESISTANCE OF AUXILIARY FEEDWATER SYSTEMS The NRC Multiplant Action C-14. " Seismic Qualification of Auxiliary Feedwater Sys.tems" ( AFW) was implemented by the issuance of General Letter No. 81-14 under 10 CFR-50.54(f).
This letter requested each PWR licensee to (1) con-duct a walkdown of any non-seismically qualified portion of the AFW and to identify deficiencies amenable to simple actions to improve seismic resistance, and (2) provide design information regarding the seismic resistance of the AFW Additionally, this letter requested that, if the review of the. AFW system.
indicated. a substantial lack of" seismic capability,_ the licensee should describe any alternate system for decay heat removal.
We are reviewing the licensee's responses to this generic letter including replies to our requests for additiona information.
For TMI-1, our review has progressed to the point of having)a final Technical Evaluation Report (TER) from our consultant, Lawrence Livermore National Laboratory.
A copy of this TER is enclosed.
The TER indicates that:
(1) the present AFW may sut:stantially lack the capability to withstand a postulated safe shutdown l
earthquake, (2) the licensee did not conduct a complete walkdown of the AFW l
system, (3) the licensee has not provided commitments that appropriate actions would be taken for all the deficiencies identified, and.(4) the license'e did not describe an alternate system for decay heat removal.
NRC generic correspondence of October 21, 1980 and February 10,1981 have stated clearly that our intent is to increase the seismic resistance of AFW systems'to the extent practical so as to provide reasonable assurance that they will be able to function following an earthquake of SSE magnitude.
./
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,--m e
T auxiliary steam to EF turbino pump'and motor operators for condensate storage tanks A & B isolatien valves (CO-
' V-10 A & B) were no't designed to seismic req ~uirements; however, the licensee indicated that they are not part of the emergency power supply system and, therefore, are non-es'sential 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-vital power sources to Class 1E vital
' power sources.-
(c) Cable routing for the power supply to motor operated valves (COlV-14 A & B) between the hotwell and the AFW suction line will be upgraded to meet seismic Class T requirement.
Upgrading modifica tions to it' ems (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 present level of seismic capability of power supplies is less
~
than OBE,
'but it will--be ' equivalent to SSE upon completion of the
~~
planned modifications.
db-Water Source (s) - None Initiation / Control : Systems - Firstly, items identified by the o
licensee as non-seismically qualified but without plarned modifications include:
(a) Flow switches and control c-ir-cuitry of recirculation flow control valves (EF-V8 A, B
~
and C).
(b) Cable routing cf motor operators for main 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) Solenoid valves and limit switch which control the valves (MS-V113'A~& B) for p'roviding the
~
main steam to turbine.
(d) Cable r~ outing ef motor operators for main steam isolation valves MS-V1 A, B,.C,.& D.' Secondly, t h : s.e ncn-seismically qualified items with modifications scheduled to be completed by the first refueling af.ter re-start include:
(e) Ccnverter EP "-5A for 'ontrol valve c
e s
t-h e-M UNITED STATES A
pg$
~
- f'g..,7?g 4
NUCLEAR REGULATORY COMMISSION p7p y
g I
- g g
WASHifwGTON. D. C. 20555
&' 5Yi:.' ' l gm4 NQg8 %4thz ME!ORANDUM FOR:
Gus C. Lainas, Assistant Director for Operating Reactors Division of Licensing FROM:
Frank J. Miraglia, Assistant Director for Safety Assessment
' Division of Licensing
SUBJECT:
114REE MILE ISLAND UNIT 1: SEISMIC RESISTANCE OF AUXILIARY FEEDWATER SYSTEMS The NRC Multiplant Action C-14. " Seismic Qualification of Auxiliary Feedwater Sys.tems" ( AFW) was implemented by the issuance of General Letter No. 81-14 under 10 CFR-50.54(f).
This letter requested each PWR licensee to (1) con-duct a walkdown of any non-seismically qualified portion of the AFW and to identify deficiencies amenable to simple actions to improve seismic resistance, and (2) provide design information regarding the seismic resistance of the AFW Additionally, this letter requested that, if the review of the. AFW system.
indicated. a substantial lack of" seismic capability,_ the licensee should describe any alternate system for decay heat removal.
We are reviewing the licensee's responses to this generic letter including replies to our requests for additiona information.
For TMI-1, our review has progressed to the point of having)a final Technical Evaluation Report (TER) from our consultant, Lawrence Livermore National Laboratory.
A copy of this TER is enclosed.
The TER indicates that:
(1) the present AFW may sut:stantially lack the capability to withstand a postulated safe shutdown l
earthquake, (2) the licensee did not conduct a complete walkdown of the AFW l
system, (3) the licensee has not provided commitments that appropriate actions would be taken for all the deficiencies identified, and.(4) the license'e did not describe an alternate system for decay heat removal.
NRC generic correspondence of October 21, 1980 and February 10,1981 have stated clearly that our intent is to increase the seismic resistance of AFW systems'to the extent practical so as to provide reasonable assurance that they will be able to function following an earthquake of SSE magnitude.
./
0 0
^
jiiF y2 ////
,--m e
T auxiliary steam to EF turbino pump'and motor operators for condensate storage tanks A & B isolatien valves (CO-
' V-10 A & B) were no't designed to seismic req ~uirements; however, the licensee indicated that they are not part of the emergency power supply system and, therefore, are non-es'sential 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-vital power sources to Class 1E vital
' power sources.-
(c) Cable routing for the power supply to motor operated valves (COlV-14 A & B) between the hotwell and the AFW suction line will be upgraded to meet seismic Class T requirement.
Upgrading modifica tions to it' ems (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 present level of seismic capability of power supplies is less
~
than OBE,
'but it will--be ' equivalent to SSE upon completion of the
~~
planned modifications.
db-Water Source (s) - None Initiation / Control : Systems - Firstly, items identified by the o
licensee as non-seismically qualified but without plarned modifications include:
(a) Flow switches and control c-ir-cuitry of recirculation flow control valves (EF-V8 A, B
~
and C).
(b) Cable routing cf motor operators for main 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) Solenoid valves and limit switch which control the valves (MS-V113'A~& B) for p'roviding the
~
main steam to turbine.
(d) Cable r~ outing ef motor operators for main steam isolation valves MS-V1 A, B,.C,.& D.' Secondly, t h : s.e ncn-seismically qualified items with modifications scheduled to be completed by the first refueling af.ter re-start include:
(e) Ccnverter EP "-5A for 'ontrol valve c
e s
t-h e-
- )
i o
REFERENCES 1.
D.
G.
Eisenhut, U. S. Nue' ear Regulatory Commission, memorandum.
to H. R. Denton, "Multip ant' 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.
s 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
~
mor 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' Qual'ification' -
l ElectricaI,"'FebYuary 16', 1982.
6.
U. T-? Nuclear Regulatory-Commission, letter to Metpopolitan Edison
. Company, "Requ.est for, Additional Information on Seismic Qualifica-tion of the Auxiliary Feedwater Syste=, Three Mile Island Nuclear Station, Unit 1," April 5, 1982.
7.
H.
D.
Hukill, Metrcpolitan Edison Co pany, letter to J.
F. Stolz of U. S. Nuclear Regulatory Commission, July 7, 1982.
8.
H. D. Hukill, General Public Utilit'y Nuclear Corporation ~, letter to'J. F. Stolz of U. S. Nuclear Regulatory Commission, September 14, 1982.
a f
9.
H.
D. Hu%ill, General Public Utility Nuclear -Corporation, l e t.t e r to J.
F.
Stcle of U.
S. Nuclear Regulatory Ccm.ission, Septecber i
29, 1982.
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4
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