ML20080S749
| ML20080S749 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/27/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-4-018, 2NRC-4-18, NUDOCS 8402290238 | |
| Download: ML20080S749 (30) | |
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- h. 8-s 2NRC-4-018 (412) 787 - 5141 Telecopy --
Nuclear Construction Division February 27,:1984 Robinson Plaza, Building 2, Suite 210 Pittsburgh, PA 15206 United States Nuclear Regulatory Commission l~
. Washington, DC 20555 ATTENTION: Mr. George W. Knighton, Chie f Licensing Branch 3 Of fice of Nuclear Reactor Regulation
SUBJECT:
Esaver Valley Power Station - Unit 2 Docket No. 50-412 NRC - Structural Desiga Audit Gentlemen:
In an NRC letter dated September 15 , 19 83, we rece ived the
" Requests for Additional Infonnation" from the Structural and Geot echnical Engineering Branch. Draft res pons es to these que s t ions were provided to the NRC on December 14 , 1983, as: reque s ted . The NRC Structural Des ign Audit, which included a review of these responses and which was criginally scheduled for the week of December 12, 1983, occurred on January 31 through February 3,1984, at the of fices of Stone & Webster Engineeri .g Corporation in Boston, MA. The audi t age nd a , s ich was rece ived fr om the NRC via telecopy on January 11, 1984, is cont ained in Attachment 1. The Notes of Conference from the audit are contained in Attachment 2. During the course of the audit the NRC reviewers , Mr. D. Jeng and M r . K . C. Leu, developed twenty-eight (28) items requiring cd dit ional act ion by DLC. Due to the nature of the act ion items, further review by SWEC and DI4 was needed to
.better define the scope of the work involved. At the audit exif- meeting, DLC committed to provide on February 27, 1984, a response or a schedule for providing a response to each .of the actiun items.
M tachment 3 to this le t ter cont ains the act ion items developed during .:he ' audit including the as sociated res pons e or schedule fo r providing a response. In Attachment 3, DLC has provided written responses to Action Items 2, 3, 17, ~ 18, 25, 26 and 27. Res po ns es to the remaining action items will' be provided by either April 27, 19 84 (It ems 1, 6, 13, 14, 15, 16, 21, 22, and 28) or June 15, 1984 (It ems 4, 5, 7, 8, 9, 10, 11, 12, 19, 20, 23, and 24) .
At t achment 4 cons is t s of our res po ns es to the NRC Structural Engineering Sect ion's review comment s on BVPS-2 St andard Review Plan di f fe rences . These comments were transmit t ed to DLC in your letter dated l September . 22, 1983. In this let ter, we were reques t ed to cor.s ider these l' comment s in res pond ing to the Structural and Ge ot echnical Engineering i
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Mr. George W. Knighten, Chief Page 2
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Brac.ch's " Req ue s t s for Additional In fo rma t ion." At the audit, the NRC reviewe rs requested that DLC provide fo rmal res pons es to each of the identified SRP dif ferences cont ained in the September 22, 1983, letter. As
- indicated in Attachment 4, most of these dif fe rences are directly related to an act ion item developed during the audi t , and the res pons e to these items will be addressed in the appropriate act ion it em . r es po ns e . The remaining responses are provided in Attachment 4, with the exceptian of the res pons es fo r SRP Sect ions 3.3.1.11.3, and 3.7.3.11.7, d ich will be submitted on April 27, 1984.
During the audit, a cons ide rable amount of discussion took place conce rning the rev iewe rs ' pos it ion of comparing the BVPS-2 des ign basis with the present SRP guidelines . BVPS-2, which received its Cons truct ion Permit on May 3, 1974, is in excess of 90% complete with respect to the atructural design. This design was performed in accordance with the design bases descrioed in the BVPS-2 PSAR *ich was docketed on October 20, 1972, and approved by the NRC with the issuance of the Cons truct ion Permit. DLC feels the structural design of BVPS-2 meets the applicable requirement s of 10CFR50, Appendix A.
It is es timated that 15,000 man-hours will be expe nded in res pond-ing to the Structural Design Audit act ion items and the SRP dif ferences .
DLC will make every ef fort possible to improve on the schedule fo r res pond-ing to these act ion items. If you should have any que s t ions , ple ase cont act Mr. J . D . O' Ne il at ( 412) 7 87-5141.
DUQUESNE LIGHT COMPANY By /T
- E. W . Woolever Vice President ETE/wjs Attachments cc: Mr. G. Walton, NRC Resident Inspector (w/ attachments) .
Ms. L. Lazo, Project Manager (w/ attachments)
SUBSCRIBED AND SW RN TO BEFORE ME THIS J7 DAY OF _ ([uqw , 1984. l m'bt. A.)
Not ary Public ANITA ELAINE REITER, NOTARY PUBLIC l
ROSINSON TGYiNSH:P, /,LLEGHENY COUNTY '
MY COMM;SS ON EXPlRES CCTOBER 20,1986 1
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United Statea , Nuclear Regulatory Commission
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- Mr. George W. Knighton, Chief -
-Page 3 COMMONWEALTE OF PENNSYLVANIA )
.) SS:
. COUNTY OF ALLEGHENI )
On this J/ __ day of (A/ /// , before me,
) f a Notary Public in and for said Commonwe alt h and County, pe rso nally appeared E. J. Woolever, who being duly sworn, deposed and said that (1) he
- is Vice President of Duquesne Light, (2) he is duly authorized to execute j
~ and file the _ foregoing Submi tt al on behalf of said Company, and (3) the s tat eme nt s set forth in the Submittal are true and correct 'to the best of his knowledge.
tG 1 Not ary Public ANITA ELAINE REtTER, NOTARY PUBLIC ROBINSON TO// tis!UP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOSER 20,1986 7'
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6,i...sa :5:54 *.:: = Iu_:P3 rc. c-s cal 7-e ATTACHMENT 1 Beaver Valley 2 Generating Station Agenda of NRC Structural Audit
- January 23, 1984 to January 27, 1984 Tuesday 8:30 am 1. Introduction NRC Staff 1/24/84 . Purpose and procedures of audit, -
expected end products of audit.
9:00 am 2. Overview of plant, design Applicant
- a. construction status
- b. design status
- c. highlights of special design criteria, features and problems '
9:30 a'a 3. Review of Seismic Analysis Applicant
- a. Seismic analysis criteria and procedures
, b. Soil-structure interaction _
1:00 pm 4. Containment (Detail Presentation) Applicant
- a. seismic analysis
- b. ultimate capacity analysis
. c. liner plate analysis (including d.
buckling,':as applicable)
\ Review of containment design calculations and drawings 3:30 pm 5. Response to staff questions and resolution Applicant of deviation from SRP provisions 4:30 pm. 6. Stamary of Action Items W2dnesday 8:30 am 1. Containment (continued) 1/25/84 Review of Containment Design Calculations 9:30 am 2. Interior Structures Applicant
- a. Design Summary
- b. Interior Structural Analysis and modeling j c. Seismic design
- d. Load continations l e.. Review of Design Calculations and Drawings 1:00 pm 3. Other Category I Structures Applicant
- a. Brief design sumary
. b. Design highlights /special problems
- c. Seismic design including SSI analysis as. applicable
- d. Review of design calculation and drawings
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3:30 pm 4. Response to staff questions and .
resolution of deviation from SRP provisions ,
4:30 pm 3. Sumary of Acting Items Thursday 8:30 am 1. Primary intake structure (BV 1 & 2) 1/26/84 (Seismic design and analysis)
- 2. Wind and Tornado design missile protection and design of missile barrier, 1:00 pm 3. Tanks, seismic Design criteria and analysis method
- 4. Cable tray supports, conduits, cable tunnel and pipe trench. .
2:30 pm 5. Other technical topics 3:30 pm 6. Sumary of action items
( Friday 8:30 am 1. Response to staff questions and resolution of 1/27/84 deviation from SRP provision, if needed.
10:00 am 2. Exit Meeting ,
- a. Finalization of action items
. b. Schedules
- c. Sumary 9
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- ATTACHMENT 2 NOTES OF CONFERENCE NRC STRUCTURAL DESIGN AL'DIT BEAVER VALLEY POWER STATION - UNIT N0. 2 DUQUESNE LIGHT COMPANY Held in the Offices of
Participants:
Stone & Webster Engineering Corporation Boston, Massachusetts See Attachment A January 31 - February 3, 1984 PL7 POSE The NRC S t r'uci. ural Design Audit is a regularly scheduled part of the operating license review process. Topics for the audit included the NRC structural branch questions (220 series) and their comments on Standard Review Plan (SRP) differences provided in the NRC letter dated September 22, 1983.
DISCUSSION D. Jeng explained his audit method of developing with the applicant a list of action items. Resolution of the action items would be discussed at Friday's exit meeting. J. O'Neil presented the BVPS-2 construction status, and P. Talbot presented the design status. The engineering confirmation program was discussed. The NRC's agenda for the audit was followed intermittently for the next 3 days as described below.
G. Tilton gave a review of the seismic analysis. Standard Review Plan Sections 3.7.1 and 3.7.2 were compared in detail to the BVPS-2 design, and Action Items I through 6 were developed. Mr. Tilton discussed the soil-structure interaction, and Action Item 7 was developed. Mr. Tilton also led a presentation on the containment, including seismic analysis and liner plate analyses. Action Items 8 through 10 were developed.
Discussion of interior structures began Wednesday, triggering Action Items 13 and 28. Other Category I structures were then discussed.
Wind and tornado design missile protection was reviewed on Thursday, prompting Action Items 18 and 21. Cable tray supiorts, conduits, and cable tunnels were also discussed, resulting in Action Items 19, 20, and 24.
Engineering Mechanics engineers then discussed tanks and buried piping, prompting Action Items 22 and 23. The auditors then reviewed the intake structure. Discussion with Power engineers on the spent fuel racks continued until Friday and resulted in Action Items 25 and 26. Action Item 27 developed from discussion of the polar containment crane.
The 220-series questions and draft responses were also discussed intermittently throughout the audit. Resolution of each question, including development of action items, follows:
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e 220.2 - Draft response was approved 220.3 - Action Item 21 220.4 - Action Item 1 220.5 - Action Item 7 220.6 - Action Item 7 220.7 - Action Item 7 220.8 - Action Item 4 220.9 - Draft response was approved 220.10 - Action Item 24 220.11 - Action Item 17 220.12 - Draft response was approved 220.13 - Action Item 25 .
220.14 - Action Item 25 220.15 - Action Item 17 The final major item discussed at the audit was the NRC Stru'ctural Engineering Section's comments on SRP differences dated September 22, 1983.
D. Jeng indicated that the NRC expects written responses to these items, and E. Eilmann stated that DLC would provide responses or schedules for responses on February 27, 1984. Discussion and concomitant Action Items proceeded as follows:
P.1, SRP Section:
3.3.1.II.3 - Discussion held; response to be provided 3.7.1.II.la - Action Item 1 3.7.1.II.2 - Action Item 11 3.7.2.II.6 - Action Item 4 P.2, SRP Section:
3.7.2.II.5 - Action Item 12 3.7.2.II.4 - Action Item 7 3.7.3.II.7 - Telephone conversation among NRC, DLC, and Westing-house was held. Response to this item will explain Westinghouse scope.
P.3, SRP Section:
3.7.3.II.2h - Discussion held; response to be provided 3.7.3.II.21 - Action Item 20 3.8.1.II.2 - Action Item 8 3.8.1.II.2 (2nd Item) - Action Item 16 3.8.1.II.4j - Action Item 9 3.8.2 - Action Item 14 P.4, SRP Section:
3.8.1.II.2 (Actually 3.8.3.II.2) - Action Item 15 3.8.4.II.2 - Action Item 16 3.8.4.II.2, 3.8.5.11.2 - Action Item 15 3.8.4.II.3 - Action Item 17 3.8.4.II.8 - No discussion; closed 3.8.3.II.4d - It was agreed that the response to this item will indicate that the requested in fo rma ti on was pre-sented and discussed at the Structural Design Audit.
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.; l l5 P.S. SRP Section 3.8.3.II.2 - G. Tilton explained that BVPS-2 has no structures to which this SRP section applies 3.8.3.II.2 (2nd ItemF - Action Item 16 3.G.4.II.4f - Actica Item 26 3.8.5.II.2 - Action Item 16 3.8.5.II.4f - Action Item-4 At Friday's exit meeting,-action items developed at the audit were presented in final form and are included as Attachment B. Mr. Eilmann stated that DLC will respond - to the action items and the September 22 SRP comments in a letter to the NRC on February 27, 1984. Schedules for responses will be provided for all items not answered.
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ATTACHMENT A ,
NRC STRUCTURAL AUDIT ATTENDANCE LIST JANUARY 31, 1984 NAME COMPANY D. Jeng NRC
- L. Lazo NRC
- h. C Leu NRC P. A..Cadena DLC E. T. Eilmann DLC W. Hwang DLC
- E.'F. Kurtz DLC J. D. O'Neil DLC W. F. Reimer DLC
- G. J. Ashworth SWEC
- K. M. Bendiksen SWEC
- W. H. Bohlke SkIC
- J. Busa SkIC ~
- G. Bushnell SWEC
- J. P. Camobreco SWEC
- P. G. Campbell SWEC
- T. Chang SWEC
- J. A. Curtin SWEC
- G. East SWEC
- J. J. Elder SWEC
- R. F. Hankinson SWEC
- D. D. Hunt .SWEC
- R. A. Loranger SWEC .
- P. RaySircar SWEC
- N. P. Sacco SWEC
- P. Sekerak SWEC
- M. Che.ridan SWEC
- Part Time
( t. '.A ATTACHMENT B NRC STRUCTURAL DESIGN AUDIT ACTION ITEMS Action -Items which reference the SRP are required to be consistent with the
. Standard Review Plan (SRP) applicable to BVPS-2.
- 1. Th'e applicant intends to demonstrate that the site-specific response spectra approved by the Geosciences Branch will be comparable to that shown . on FSAR Figure 3.7B-1 and any significant differences will be addrersed ' nd justified.
a The applicant will also address the deviations of the vertical spectra from those given in Regulatory
-Guide 1.60.as it is applicable to the BVPS site.
- 2. Show how cracking of a typical panel of a containment interior structure will affect the dynamic modeling and response, and show that it would not affect the outcome of the design.
- 3. Provide information to justify and provide curves showing the +25 to
-20 percent peak spreading for the cases where no soil properties
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variation was implemented for the intake structure and auxiliary
. building.
- 4. For each of the following three structures, assess the impact using three-component seismic input vs using the current two-component com-bination on the structure design adequacy. In case of signific :.
discrepancies, try to demonstrate that the design margins using as-built material strength and accounting for other conservatisms used in the design were adequate to justify these discrepancies.
Consider only these key floors of the.following three buildings:
For the containment -
the crane support, apex, reactor support, operating floor, and basement.
For the auxiliary building and the fuel building -
the roof, basement, and an operating floor.
If the three-component piping support point spectra are fpund to be not comparable to those used in the original piping analysis (subject to NRC review 2nd acceptance), develop the floor re:ponse spectra ac-counting for three-component earthquake input for the following piping systems:
A. Primary Loop Cooling System i-B. Main Feedwater Line Piping System C. Component Cooling Water Piping System These spectra should be used by the pipirig analysts to demonstrate that
- .he above systems were adequately designed for the three-component 1
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earthquake effects. For any deviations from the applicable ASE Section III criteria, please provide a justification considering the as-built material strength and conservatisms.
- 5. For each of the three key structures identified in Item 4, consider the base mat shear forces due to earthquakes and ' assess the impact of including additional accidental torsional effects, and show that the structural elements are adequate for these effects.
- 6. Assess the safety facters against sliding and overturning of both the containment and auxiliary building structures by accounting for the three component earthquak.e input.
- 7. Perform soil-structure interaction analyses for the two key structures (containment and intake structure) to show: that the intent of SRP 3.7.2.II'.4 is met. Where discrepancies from- the SRP are identified, provide a justification by accounting for as-built strength of materials and design conservatisms. Also, compute for the intake structure applicable safety factors against sliding and overturning based on the revised analyses and show conformance to the criteria of SRP Section 3.8.5.
- 8. The applicant did not use the ASE Section III Division 2 code provisions (ACI 359) pertaining to load combinations, design allowables, materials, quality control and special construction techniques for the BVPS-2 design. Instead, the applicant used the applicable provisions contained in the ACI 318-71 code. The applicant is requested to demonstrate that the requirements of the ASE III Division 2 code are met or identify and justify the deviations.
- 9. Perform an ultimate capacity analysis for the cratainment.
- 19. Identify the -differences 'oetween ASE III Division 2 and specific criteria used in design of BVPS-2 liner and justify any deviations therefrom.
il. Perform a random and limited review of actual design calculations to ensure that the stress and strain levels of key structural elements are consistent with Position C.3 of Regulatory Guide 1.61.
- 12. BVPS-2 design response spectra are developed based on the response only in the direction of input motion. Coupling between orthogonal directions of response is not considered. Also, BVPS-2 uses a two-directional input-motion criterion without consideration of the statistical independency among different input time histories.
The applicant should provide support documents to demonstrate that the Category I structures are reascnably symmetric as was claimed in Amendment 1; therefore, coupling in structural response between mutually orthogonal axes of structures is indeed insignificant. 3 Moreover, the statistical independency of the input motions used in the analysis should be considered in order to comply with the current SRP Section 3.7.2 provisions.
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- 13. Provide technical justification for using a dynamic amplification factor of 1 for the analysis of pressurization effect on steam generator cubicles. Also, address the basis for not accounting for the cracking effect of the concrete elements during pressurization.
- 14. The applicant is requested to provide comparisons to demonstrate that the current SRP structural acceptance criteria (3.8.2) for design limits and loading combinations are complied with. Deviations identified by the comparison should be justified.
- 15. The applicant should identify and justify the deviations of its internal- structural design from the applicable requirements of the ACI-349 as amended by Regulatory Guide 1.142.
- 16. The applicant took - some exceptions to the provisions of Regulatory Guides 1.10, 1.55, 1.69, 1.94, 1.115, 1.142, 1.143. Deviations from these Regulatory Guides should be identified and justified by the applicant.
- 17. Demonstrate .that the load factors indicated in SRP Section 3.8.4, Equations II.3.C(ii)(a)(4) and (5) are complied with, or state that the intent of those equations have been met.
- 18. The applicant will state that no steel structure missile barriers were used in the plant. The applicant will also state that the criteria used for the missile barrier design covering the overall structural response is addressed in the SWECO No. 7703 report dated 1977, a copy of which is enclosed for staff review and acceptance.
- 19. With respect to Category I duct banks, describe the design criteria and analysis procedures used to demonstrate the adequacy, and also indicate if the applicable criteria of SRP Section 3.8.4 were met. For any deviations from the criteria identified, please provide a justification considering the as-built material strengths and conservatisms, as appropriate.
- 20. Describe the key types of cable tray (and conduit) configurations used at BVPS-2. For each of the configurations identified, evaluate if the criteria provided in SRP Sectier. 3.8.4 were fully met in the design and analysis of the trays (and conduit). For any deviations from the criteria identified, please provide a justification considering the as-built material strength and conservatisms, as appropriate. The selection of key types of cable trays should consider the various layers of decking as well as the variability in supports and anchoring effects.
- 21. With respect to the issuc af the rate of pressure drop for tornado definition, please provide a quantitative technical justification demonstrating that the intent of Regulatory Guide 1.76 is fully met.
Also, address the adequacy of using a single degree of freedom modeling in assessing the structural response of a plate subject to the above indicated pressure drop loading.
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- 22. Evaluate the (11) Category I tanks with respect to the criteria of SRP l -Section 3.8.4 in order to demonstrate their design adequacy. The
( evaluation should consider the following parameters:
I f 1. Use realistic modeling of the tanks, accounting for the f flexibility of the tanks.
- 2. Consider any surrounding soil embedment as -well as pipe anchoring load effects.
- 3. Consider both sloshing and overturning effects.
- 4. Evaluate the adequacy of the tanks against buckling failure.
. 5. Ensure' that foundations, anchoring bolts, and other . con-nections to the tanks are adequately designed.
For any deviations from the above SRP Section 3.8.4 criteria, use as-built material strength, applicable test results, and design con-servatisms to justify the deviations.
- 23. If the three-component piping support point spectra are found to be not comparable to those used in the original piping analysis (subject to NRC review and acceptance), demonstrate that the key safety-related systems, equipment, and piping have met the three-component earthquake consideration criterion given in SRP Section 3.7.3. The evaluation should include the following key items within various Category I structures:
- 1. Containment - reactor vessel support, one steam generator, pressurizer, one hot-leg piping system, and primary coolant pump
- 2. Auxiliary building - component cooling water pump, baric acid transfer pump
- 3. Control building - main control board
- 4. Fuel building - fuel pool cooling pump
- 5. Intake structure - service water pump For any identified deviations from the above SRP Section 3.7.3 criterion, use as-built material strength and design conservatisms to justify the deviations.
- 24. Perform a sinplified stick model dynamic analysis of the cable tunnel accounting for the overburden and embedment effects. Demonstrate that the provisions of SRP Section 3.8.4 are met. For any deviations from the 59J criteria identified, provide a justification considering the as-built material strength and conservatisms. Also, account for any significant relative ground motions upon the tunnel seismic responses.
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- 25. The applicant will arrange a meeting with the NRC to discuss the con-tent of the response to Question 220.14. The applicant will also present the design of the fuel pool at this meeting.
- 26. Provide. documentation which demonstrates that the provisions of Appendix D to SRP Section 3.8.4 are met in fuel rack design. Justify any deviationc. Use of design conservatisms applicable to the design to support the deviations will be acceptable, as appropriate.
- 27. Provide a justification for not combining the earthquake load with the main suspended crane load and other applicable loads in the design of the polar crane.
- 28. Provide a simplified justification to demonstrate that T applicable g to the cubicles in ~ the containment need not be included in the design.
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Attachment 3
- 1. The applicant intends to demonstrate that the site-specific response spectra approved by the NRC's Geosciences Branch will be comparable to that shown on FSAR Figure 3.7B-1 and any significant differences will be addressed and justified. The applicant will also address the deviations of the vertical spectra from those given in Regulatory Guide 1.60 as it is applicable to the BVPS site.
Response
This ites will be addressed in the responses to the NRC Geosciences Branch questions 230.2, 230.3,. and 230.6 to be submitted by April 27, 1984.
- 2. Show how cracking of a typical panel of an interior structure will affect the dynamic modeling and response, and show that it would not affect the outcome of the design.
Response
The si.ructural model used in the seismic analysis realistically predicts the responses of the containment's interior structure. The widening of the peaks of the ami lified response spectra accounts for variations of structural' properties (cracking of minor portions of the structure),
dampings, soil properties, and soil-structure interactions.
The criterion used on BVPS-2 for peak widening is more conservative than the acceptance criteria of SRP 3.7.2 (Section II.9). The criterion of SRP 3.7.2 states that if no special study is performed to determine the amount of peak widening, then 115 percent is acceptable. BVPS-2
- widening criteria of +25 percent and -20 percent is clearly more con-servative.
Therefore, we do not believe further analysis to be necessary.
- 3. Provide information to justify and provide curves showing the +25 to
-20 percent peak spreading for the cases where no soil properties variation was implemented for the intake structure and auxiliary building.
Response
The acceptance criterion, of SRP 3.7.2, for peak spreading of floor re-sponse spectra states: " Consideration should be given in the analysis to the effects on floor response spectra (e.g., peak width and period coordinates) of expected variations of structural properties, dampings, soil properties, and soil-structure interactions. Any reasonable method for determining the amount of peak widening associated with the structural frequency can be used, but in no case should the amount of peak widening be less than 110 percent. If no special study is per-formed for this purpose, the peak width should be increased by a minimum of 115 percent to be acceptable."
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t The peak spreading criterion used for BVPS-2, (+25 percent and -20 per-cent) is more conservative than the acceptance criteria of SRP 3.7.2.
Therefore, we do not believe that further justification is required.
- 4. For. each of the following three structures, assess the impact using three-component seismic input vs using the current two-component com-bination on the structure design adequacy. In case of significant discrepancies, try -to demonstrate that tw design margins using as-built material strength and accounting for other conservatisms used in the design were adequate to justify these discrepancies.
Only consider these key floors of the following three buildings:
For'the containment - the crane support, apex, reactor support, operating floor, and basement, For the auxiliary building and the fuel building - the roof, basement, and an operating floor.
If the three-component piping support point spectra are found to be not comparable to those used in the original piping analysis (subject co NRC review and acceptance), develop the floor response spectra ac-counting for three-component earthquake input for the following piping systems:
A. Primary Loop Cooling System B. Main Feedwater Line Piping System C. Component Cooling Water Piping System These spectra should be used by the piping analysts to demonstrate that the above systems were adequately designed for the three-component earthquake effects. . For any deviations from the applicable ASME III criteria, please provide a justification considering the as-built material strength and conservatisms.
Response
Items 4, 12, and 23 will be addressed in one response which will be submitted by June 15,-1984.
- 5. For each of the three key structures' identified in Item 4, consider the base mat shear forces due to earthquakes and assess the impact of in-cluding additional accidental torsional effects, and show that the structural elements are adequate for these effects.
Response
A response will be submitt.ed by June 15, 1984.
- 6. Assess the safety factors against sliding and overturning of both the containment and auxiliary building structures by accounting for the three component earthquake input.
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Response
A response will be submitted by April 27, 1984.
- 7. Perform soil-structure interactwn analyses for the two key structures (containment and intake structure) to show that the intent of SRP 3.7.2.II.4 is set. Where discrepancies from the SRP are identified, provide a justification by accounting for as-built strength of materials and design conservatisms. Also, compute for the intake structure applicable safety factors against sliding and overturning based on the revised analyses and show conformance to the criteria of -
SRP Section 3.8.5.
Response
A response will be submitted by June 15, 1984.
- 8. The applicant did not use the ASME Section III Division 2 code provisions (ACI 359) pertaining to load combinations, design allow-ables, materials, quality control and special construction techniques for the BVPS-2 design. Instead, the applicant used the applicable provisions contained in the ACI 318-71 code. The applicant is re-quested to demonstrate that the requirements of the ASME III Division 2 code are met or identify and justify the deviations.
Response
A response will be submitted by June 15, 1984.
- 9. Perform an ultimate c,apacity analysis for the containment.
Response
A simplified ultimate pressure capacity analysis of the containment will be performed. The results of this analysis will be submitted by June 15, 1984.
- 10. Identify the differences between ASME III Division 2 and specific criteria used in design of BVPS-2 liner and justify any deviations therefrom.
Response
A response will be sub itted by June 15, 1984.
- 11. Perform a random and limited review of actual design calculations to ensure that the stress and strain levels of key structural elements are consistent with Position C.3 of Regulatory Guide 1.61.
Response
A response will be submitted by June 15, 1984.
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- 12. BVPS-2 design response spectra are developed based on the response only in the direction of input motion. Coupling between orthogonal directions of response is not considered. Also, BVPS-2 uses a two-directional input-motion criterion without consideration of the statistical'independency among different input time histories.
The applicant should provide support documents to demonstrate that the Category I structures are reasonably symmetric as was claimed in Amendment 1, therefore, coupling in structural response between mutually orthogonal axes of structures is indeed insignificant.
Moreover, the statistical independency of the input motions used in the analysis should be considered in order to comply with the current SRP Section 3.7.2 provisions.
Response
A response will be provided by June 15, 1984, in conjunction with Items 4 and 23.
- 13. Provide technical justification for using a dynamic amplification factor of one for the analysis of pressurization effect on steam generator cubicles. Also, address the basis for not accounting for the cracking effect of the concrete elements during pressurization.
Response
A response will 'ue submitted by April 27, 1984.
- 14. The applicant is requested to provide comparisons to demonstrate that the current SRP structural acceptance criteria (3.8.2) for design limits and loading combinations are complied with. Deviations identified by the comparison should be justified.
Fesponse:
A response will be submitted by April 27, 1984
- 15. The applicant. should identify and justify the deviations of its in-tern 11 structural design from the applicable requirements of the ACI-349 as. amended by Regulatory Guide 1.142.
Response
A comparison will be made to summarize the significant deviations of the containment's internal structures design criteria from the ap-plicable requirements of the ACI-349 as amended by Regulatory Guide 1.142.
A response will be submitted by April 27, 1984.
- 16. The applicant took some exceptions to the provisions of Regulato.y Guides 1.10, 1.55, 1.69, 1.94, 1.115, 1.143. Deviations from these ,
Regulatory Guices should be identified and justified by the applicant. /
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I Response:
A response will be submitted by April 27, 1984.
- 17. Demonstrate that the load factors indicated in SRP Section 3.8.4, Equations II.3.C (ii) (a) (4) and (5) are complied with or state that the intent of those equations have been met.
Response
These two equations govern only when considering the effects of high-energy pipe breaks, (Yr, Yj, and Ym). ,
. The BVPS-2 design cr,iteria will be revised to agree with the allowable limits for required section strengths, given in SRP 3.8.4 for Equations II.3.C (ii).(a) (4', and (5).
Specifically, the strength limits for equations 3.8-15 and 3.8-16 of FSAR Section 3.8.3.3 will be changed from 1.8 and 2.0, to 1.6 and 1.7, respectively. Additionally, a note will be added allowing the plastic modulus of steel to be used for shapes meeting the AISC criteria for compact sections.
- 18. The applicant will state that no steel structure missile barriers were s used in the plant. The applicant will also state that the criteria used for the missile barrier design covering the overall structural response is addressed in the SWECO No. 7703 report dated 1977, a copy of which is enclosed for staff review and acceptance.
Response
The applicant is in accordance with the acceptance criteria of SRP 3.5.3 as it . applies to the design of concrete and steel missile barriers.
Steel barriers, where used, are evaluated using either the Stanford Research or s Ballistics Research ' Formulas for local response (i.e.,
penetration). 'Overall responses are evaluated using methods consistent with the criterion of SRP 3.5.3 for steel barriers.
Concrete barriers are evaluesed for local and overall responses utilizing the procedures p re.sented in Stone & Webster Engineering Corporation Topical Report SWECO 7703, which was previously sub-mitted to Mr. J. F. Stolz of the NRC on September 23, 1977. A copy of this report will be submitted under separate cover for your convenience.
The thickness of concrete barriers conform to the minimum acceptable barrier thickness requirements specified in Table 1 of SRP 3.5.3.
Maximum allowable ductility ratios for steel 'and concrete barriers are in compliance with Appendix A of SRP 3.5.3. , ,
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w - _ _ _ - _ _ _ _ - _ _ - _ _ _ - _ _ _ _ _.
TE I
- 19. With respect to Category I duct banks, describe the design criteria and analysis procedures used to demonstrate the adequacy, and also indicate if the applicable criteria of SRP Section 3.8.4 were met. For any deviations from the criteria identified, please provide a justification considering the as-built material strengths and conservatisms, as appropriate.
Response
A summary of the design criteria and analysis procedures for seismic
,3 Category I duct banks will be submitted by June 15, 1984.
- 20. Describe the key types of cable tray (and conduit) configurations used at BVPS-2. For:each of the configur. cions identified, evaluate if the
, criteria provided in SRP Section 3.8.4 were fully met in the design and analysis of the trays (and conduit). For any deviations from the criteria identified, please provide a justification considering the as-built material strength and conservatisms, as appropriate. The selection of key types of cable trays should consider the various layers of decking as well as the variability in supports and anchoring
- effects.
Response
A summary of the design criteria and analysis procedures, as well as a description of key types of cable tray and conduit support con-figurations will be submitted by June 15, 1984.
- 21. - With ' respect to the issue of the rate of pressure drop for tornado definition, please provide a quantitative technical justification demonstrating that the intent of Regulatory Guide 1.76 is fully met.
Also, address the adequacy of using a single degree of freedom modeling s
in assessing the structural response of a plate subject to the above indicated-pressure drop loading.
l',
Response
' ' As part of the audit, the auditors reviewed the technical documentation which justifies that the pressure drop loading considered in the design of Category I structures at BVPS-2 meets the criteria of Regulatory Guide 1.76.
A summary of the analysis and its results will be submitted by April 27, 1984.
- 22. Evaluate the (11) Category I tanks with respect to the criteria of SRP
.Section 3.8.4 in order to demonstrate their design adequacy. The
'" f evaluation should consider the following parameters:
- 1. Use realistic modeling of the tanks, accounting for the flexibility of the tanks.
- m
- 2. Consider ' any surrounding soil embedment as well as pipe anchoring load effects.
I 6
- 3. Consider both sloshing and overturning effects.
- 4. Evaluate the adequacy of the tanks against buckling failure. '
5 Ensure that foundations, anchoring bolts, and other con-nections to the tanks are adequately designed.
For any deviations from the above SRP Section 3.8.4 criteria, use as-built material strength, applicable test reshlts, and design con-servatisms to justify the deviations.
Response: ,
t A response-will be submitted by April 27, 1984.
- 23. If the thiee-component piping support point spectra are found to be not comparable to those used in the original piping analysis (subject to NRC review and acceptance), demonstrate that the key _ safety-related systems, equipment, and piping have met the three-component earthquake consideration criterion given in SRP Section 3.7.3. The evaluation should incl *:da the following key items within various Category I structures:
- 1. , Cortainment - reactor vessel srpport, one steam generator, pressurizer, one hot-leg piping system, and primary coalant Pump
- 2. Auxiliary building - component cooling water pump, boric acid transfer pump
- 3. Control building - main control board s
- 4. Fuel building - fue:1 pool cooling pump
- 5. Intake structure - service water pump For any identified deviations from the above SRP Section 3.7.3 criterion, use as-built materia'. strength and design conservatisms to justify the deviations.
Rysponse:
. A response will be submitted by June 15, 1984, in conjunction with Items 4 and 12.
- 24. Perform a simplified stick model dynamic analysis of the cable tunnel accounting for the overburden and embedment ef fects. Demonstrate that the provisions of SRP Sec. tion 3.8.4 are met. For any deviations from the SRP criteria identified i.' provide a justification considering the as-built material strength and conservatisms. Also, account for any significant relative ground . motions upon the tunnel seismic responses.
, sponse:
A rerponse will be submitted by June 15, 1984.
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- 25. The applicant will arrange a meeting with the NRC to discuss the con-tent of the response to Question 220.14. The applicant will also 4 present the design of the fuel pool at this meeting.
Response
A meeting will be arranged with the NRC to discuss this item, following final verification of the structural calculations for the fuel pool.
Structural calculations will be finalized after receipt of the final fuel rack loads from the vendor.
The meeting will be scheduled for the later part of June 1984.
- 26. Provide documentation which demonstrates thr.t the provisions of Appendix D to SRP Section 3.8.4 are met in fuel rach design. Justify any deviations. Use of design conservatisms applicable to the de.ign to support the deviations will be acceptable, as appropriate.
Response
The EUPS-2 spent fuel rack design cocforms to the criteria of SRP 3.8.4 Appendix D; the following table gives ,an item-by-item comparit.:n of the criteria.
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Applicable to BVPS-2 Appendix D Requirement Specification Compliance
- 1. Item 1 cl Appendix D describes Appendix D infarmation will be information to be provided in provided in the FSAR.
the ?9AR.
2a. Construction materials for the All materials for the spent fuel spent fuel racks shall conform racks conform to the P-8 metals to ASME III, Section NF. Selec- group of ASME IX. ASME IX references all SA materials per ASME.II.
tion of materials shall be to This minimize cotrosion and be com- is an identical requirement.
patible with the fuel pcol enviroweent. -
- b. Design, fabrication, aad instal- Design of the spent fuel racks ctmplies with lation of spent fuel' racks cay ASME III, Section NF criteria.
be performed based on ASME III, Section NF.
l 3a. Appendir. provides several means BVPS.-2 complies with this of developing dynamic input data, requirement.
I b. Saismic excitation along three seismic excitations are applied orthogonal directions should be in three orthogonal directions imposed simultaneously. simultaneously.
- c. Peak response in each direction Worst case stresses are combined by should be combined by SRSS in SRSS in accordance with R.G. 1.92.
accordance with R.G. 1.92.
- d. Kinetic energy of the fuel Fuel bundle impact loadings shall assembly shall be considered for be considered and the fuel shall effects on fuel rack walls. No not be adversely affected.
fuel damage shall occur.'
4a. Identification of a change in The BVPS-2 racks are not a medti: -
temperature distribution due to cation to the rack structure and
- the proposed modification. Indi- therefore this requirement is not cation of the thermal load due directly applicable.
to the effect of max temperature distribution through pool walls and base slab.
- b. The effects of temperature These thermal gradients are considered.
gradients across the rack struc-ture due to differential heating effects between a full and empty cell should be considered.
- c. Maximum uplift forces during Maximum uplift forces are considered.
fuel handling should be con-sidered.
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g, Appendix D Requirement Specification Complianc'e
- d. The spent fuel racks -hould be The racks are analyzed for a fuel evaluated for the effects of a drop from the maximum height onto dropped fuel assembly from the top of the rack and for a drop maximum height. through a cell to the bottom of the fuel rack.
- e. Specific loads and load combina- The spent fuel racks are analyzed tions should be in accordance for the loads and load combinations with SRP 3.8.4, II.3. specified in ERP 3.8.4, II.3.
Sa. Design and analysis procedures Design and analysis procedures meet should be in accordance with the requirements of SRP 3.8.4, II.4, SRP 3.8.4, II.4. however, the design code for the racks is ASME III, NF as required by i Appendix D.
- b. Appendix D requires a flexibility BVPS-2-rack design does not utilize analysis of pool walls when the lateral restraints.
rack design incorporates lateral restraints at hi.her t elevations.
6a. The fuel rack structural The fuel rack structural acceptance acceptance criteria shall be criteria,is per Table I, as modified in accordance with Table I.~ by R.G. 1.124 (in accordance with Note 3 of Table I).
- b. When buckling loads are consid- Buckling allowables are in accordance ered, they should be in accord- with Appendix XVII of ASME III.
ance with Appendix XVII of ASME III.
- c. Requires that sliding and tilt- All dynamic deflections of the fuel ing motion be contained within racks are considered and tipping is suitable geometric constraints, constrained to 1/3 of the the maximum over-tipping angle. No impact with
- fuel pool walls is acceptable.
- 7. Requires that connections between There are no connections between the rack and the fuel pool liner be racks and the liner.
made by welding and all welding be qualified in accordance with the applicable code.
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- 27. Provide a justification for not combining the earthquake load with the main suspended crane and other applicable loads in the design of the polar crane.
Response
The polar crane design and seismic requirements are described in the BVPS-2 " Control of Heavy Loads" report submitted to the NRC in 2DLC-4556 dated April 2, 1982.
The following is based on the report:
The BVPS-2 Polar Crane was designed to the followin's basic se 'smic requirementis:
A. The crane bridge and trolley are provided with suitable restraints so they do not leave their rails during an earthquake.
B. No part of the crane will become detached and fall during an earthquake.
The design analysis used by the crane manufseturer (Harnischfeger Corporation) was computational in nature and was based on the matrix displacement method (direct stiffness cethod). The first step in the method is to approximace the actual configuration as a structural framework which is defined by a stable system of uniform (constant cross-section), weightless beam segments, and joints at which loads are applied an weights are lumped. With this model information along with the structural loading (static loads and dynamic loading in the form of a shock spectra input),
the computer performs the computation to provide the following 4
information as output.
- 1. Displacements, shear and axial forces, and moments of members for static loadings.
- 2. Reactions and equilibrium checks at each joint for static loadings.
- 3. Frequencies and mode shapes.
- 4. Displaccments, shear and axial forces, and moments of members for each of first ten forced modes of vibration.
The Dynamic Analysis for seismic events was divided into two cases:
A. For a 1/2 Safe Shutdown Earthquske (1/2 SSE), the horizoutal and vertical seismic loadings are added directly considering a single horizontal directica earthquake to act concurrently with a vertical direction earthquake. The stress levels due to these combined 11
5.
loading conditions do not exceed 75 percent of minimum yield strength in accordance with the ASTM specification for the material or maximum stress levels permitted under all applicable codes.
B. For a Safe Shutdown Earthquake (SSE), the horizontal and vertical earthquake loads are added directly con-sidering a single horizontal direction earthquake to act concurrently with the vertical direction earthquake.
The maximum stress levels due to these combined loading conditions do not exceed the smaller of: ,
- 1. Minimum yield strength. .
- 2. Seventy percent of the ultimate tensile strength of the material in accordance with the ' ASTM or equivalent specification for the material.
These design criteria for the two earthquake events .ce provided to assure the polar crane maintains its integrity through the worst possible design basis earthquake. There were actually five separate design cases used in analyzing stresses that would be present in the crane bridge. These are:
Case I - The design analysis considered the sum of the following:
(all cases usiat ASTM A-36 steel)
Dead Load - This is the weight of all effective parts of the bridge structure, machinery parts, and the fixed equipment supported by the structure.
Live Load - Weizht of two trolleys and 334 ton load.
Impact Allowance - an additional load equal to 15 percent of the rated capacity.
Wind Load at '5 3 mph.
Case II - This case considered the following loads:
Dead Load Live Load = 2 Trolleys 1/2 Safe Snutdown Earthquake (Vertical and horizontal with trolleys at centerline, 1/4 point, and end of span.)
Case III - Same as Case II, except with fall Safe Shutdown Earthquake.
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Case IV - This case of crane analysis included the Dead Load plus a Test Load of 125 percent of a 334 ton weight and the weight of the trolleys.
Case V - The crane analysis here included the Dead Load plus a Live Load of two trolleys only at the end of the crane span with a wind at 90 mph.
The seiswic analysis for the main hoist trolleys included the following design combination (all cases using ASTM A-36 steel):
Case I - This design case of crane analysis included a Dead Load and 167 ton Live Load.
Case II - This case includes the Dead Load weight plus a 1/2 Safe Shutdown Earthquake with not lifted load.
Case III - This analysis of the trolleys includes a Dead Load plus a Safe Shutdown Earthquake with not lifted load.
Case IV - This case consists of a Dead Load a Live Load o'f 125 percent of the 167 ton design load.
The polar crane is only operated when BVPS-2 is in the cold shutdown or refueling mode. The polar crane is made up of two main hoists and auxiliary hois c.. The main hoists are used priaarily during plant outages for refueling or maintenance purpose. The auxiliary hoist is used for various maintenance lifts and lifts during the refueling procedure to remove tools and equipisent. The polar crane will perform only a limited number of lifts throughout the design life of the plant.
The maximum critical load to be lif ted during plant generating life (reactor head or lower internals) is only 40 percent of the brid;e design rated load of 334 tons.
FSAR Figures 9.1-13 through 9.1-21 illustrate the safe load paths and safe shutdown equipment for the area serviced by the polar crane. The safe load paths identified will be used -as the load handling paths and any deviation from ope';ating proceaures will require an approved procedual change. There is an extremely .J ow. probability of a seismic event occurring coincident with the polar crsne lifting a heavy load over a safety-telated component outside of the sale load paths.
The BVPS-2 polar. crane was designed purchased, and delivered between 1973 and 1977 prior to issue of NUREG 0554 and 0612.
The BVPS-2 " Control of Heavy Loads" report has been reviewed by NRC and evaluation comments are included in NRC letter from Mr. George W. Knighton to hr. E. J. Woolever dated January 1, 1984.
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- 28. Provide a simplified justification to demonstrste that TA applicable to the cubicles in the containment need not be included in the design.
I Kt.sponse:
A simplified justification will be submitted by April 27, 1964, to demonstrate that T A c ntribution to the design of the cubicles is small and as such need not be included.
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e
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Attachment 4 The folloning responses are provided in consideration of the Scructural Engineering Section's woents on I;VPS-2 Standard Review Plan differences contained in the NRC letter dated September 22, 1964 (Attachment 3).
P.1, SRP Section:
3.3.1.II.3
Response
The applicant will submit an assessment of the signicant dif-ferences between the BVPS-2 criteria and . the ANSI A58.1' code, with regard to wind loads, by April 27, 1984.
3.7.1.II.la - Action Item 1 3.7.1.II.2 - Action Item 11 3.7.2.II.6 - Action Item 4 P.2, SRP Section:
o 3.7.2.II.5 - Action Item 12 3.7.2.1I.4 - Action Item 7 3.7.3.II.7 - The method of combining closely spaced modes for items within SWEC's scope is in accordance with Regulatory Guide 1.92.
Westinghouse method is used only for items supplied and qualified by Westinghouse. Further information will be provided by April 27, 1984.
P.3, SRP Section:
3.7.3.II.2h -
Response
The intent of the guidance providad in SRP 3.7.3 Section II.2.h is to ensure that Categorf I systems are not . damaged by the failure of a non-Category I system. This assurance can be provided by isolation or remote location as described in the SRP. Where neither isolation nor remote location is practical, assurance is provided by designing the non-Category I system for structural integrity under all loading conditions.
The Winter 1972 Addenda of ASME III, Appendix F, subsection F-1220 (a) states "The faulted condition design procedurer contained in F-1300 are provided for limiting the consequences of the specified event. They are intended (see.NA-1130) to assure that violation of the pressure retaining boundary will not occur in components or supports which are in compliance with these procedures." Therefore, meeting the faulted allowable pipe stress limit- will ensure piping structural integrity. Also, since the safe operability oc 1
.- _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ _ l
n reoperability of a non-Category I system (either during or fol-lowing the postulated event) is not required, and since the stresses from the SSE inertia load case always envelop those from OBE inertia, the upset primary pipe stress evaluation (Equation 9) including the effects of OBE inertia, need not be performed.
Therefore, only the seismic events associated with the faulted plant condition are analyzed. The pipe supports on these non-Category I systems are designed t.o withstand all normal, upset, emergency, and faulted loads in accordance with the respective code allowables.
3.7.3.II.21 - Action Item 20 3.8.1.II.2 - Action Item 8
'3.8.1.II.2 (2nd Item) - Action Item 16
'3.8.1.II.4j - Action Item 9 3.8.2 - Action Item 14 P.4, SRP Section:
3.8.1.II.2 (Actually 3.8.3.II.2) - Action Item 15 3.8.4.II.2 - Action Item 16 3.8.4.II.2, 3.8.5.II.2 - Action Item 15 3.8.4.II.3 - Action Item 17 .
3.8.4.II.8 - No discussion; closed 3.8.3.II.4d
Response
The structural Design Audit Guidelines provided by the NRC in G. W. Knighton's letter to E. J. Woolever dated November 2,1983,.
were throughly reviewed along with the associated reports and calculations at the NRC itructural Design Audit. The submittal of the " Notes of Conference" satisfies the requirements of this ites.
P.5, SRP Section .
3.8.3.II.2 Respon.se: -
This item was discussed in the audit; the auditors concurred that the ASME Boiler and Pressure Vessel Code was not applicable to the steel and concrete internal structures of the BVPS-2 containment.
Structural steel design for steel members inside the containment are governed by the AISC code.
3.8.3.11.2 (2nd Item) - Action Item 16 3.8.4.II.4f - Action Item 26 3.8.5.II.2 - Action Item 16 3.8.5.II.4f - Action Item 4 2
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