ML20125D481

Summary of 921110 & 19 Meetings W/Numarc in Rockville,Md Re Issues Involving Insps,Tests,Analyses & Acceptance Criteria Required by 10CFR52.List of Attendees & Viewgraphs Used for Presentation Encl

ML20125D481
Person / Time
Issue date:	12/02/1992
From:	Boyce T Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9212150220
Download: ML20125D481 (44)

Text

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%...../ December 2. 1992 APPilCANT: Nuclear Management and Resources Council (NUMARC)

PROJECT: 10 CFR P4rt 52 Irplementation

SUMMARY

Of MEETINGS WITH NUMARC TO DISCUSS ISSUES RELATING TO THE IMPLEMENTATION Of 10 CFR PART 52 Public meetings were held between the N-lear Regulatory Commission (NRC) and NUMARC staff 5 Rockville, Maryland, on ,,ovember 10 and 19, 1992. The purpose of these meetings was to discuss issues related to the inspections, tr.ts, analyses, and acceptance criteria (ITAAC) required by 10 CFR Part 52.

Enclosure 1 contains lists of the attendees at the meetings.

Enclosure 2 contains the viewgraphs presented at the meeting on November 10.

NUMARC opened the meeting by presenting a short summary of the lessons learned from the recent NUMARC/ industry review of the ITAAC for the lead reactor design. NUMARC identified generic ITAAC as an area for further discussion with the staff, and provided a list of the proposed generic ITAAC. NUMARC stated that its position was that generic ITAAC were not Tier 1 material. The staff indicated that they did not require generic ITAAC, but that the issues in the generic ITAAC could be addressed in the system ITAAC. The staff r.etlined an approach to address welding and equipment qualification in the )'

stem ITAAC, and agreed to meet with NUMARC on November 19 to furthe t' discuss

c issues.

1. . staff stated its concerns regarding facility nonconformances with Tier 2 information. A utility could adopt the position that since the ITAAC were "necessary and surricient" for fuel loading, a nonconformance was irrelevant.

If the situation " ranted, the NRC could cite the utility for a violation of the requirements of 10 CFR Part 50, Appendix B for quality assurance. The staff noted that this could mean that the burden to ensure appropriate addressal of the noncunformance would now be on the NRC vice the utility. The staff stated that it was considering a

• bridge" concept that would require the utility to certify that the detailed design was in conformance with the design

' *tification rule. The staff indicated that this would be discussed further

..i a Commission paper under preparation regarding the format and content of a combined license.

E;:losure 3 contains the information discussed at the meeting on November 19.

NUMARC opened the meeting by expressing its concerns over the implementation of generic ITAAC for environmental qualification and welding. The staff then presented the information in the enclosure to be used as the basis for the development of a method to incorporate the generic concerns from the generic ITMC and apply them to each of the system ITAAr. The staff stated that much '

of the material presented could be incorporated as supporting material into the Tier 2 standard safety analysis report (SSAR). The Tier 2 material would include specific code addenda, edition and code cases for welding and non-proprietary description of equipment qualification testing and analysis 100073 L + /,jd.:5:(

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o December 2, 1992 methods. The functional system drawings would identify ASME boundaries for welding and environmental qualification boundaries. Each system ITAAC would include t. verification of equipment qualification and weld:ng as part of the system walkdown. This approach would also ensure that the quality of the hardware was incorporated into the ITAAC rather than a generic process. The staff would review conformance to Tier 2 methods for welding and equipment qualification as part of its " sign as you go" inspection activities.

The staff stated that the design features for severe accidents that have been incc.rporated into the designs under review must be considered in the Tier 1 mat eri al . These features include thoce described in SECY-90-016,

" Evolutionary Light Water Reactor (LWR) Certification Issues and Thoir _

Relationship to Current Regulatory Requirements," and follow-on Commission papers describing the design-specific resolutions of these issues. A representative from GE Nuclear Energy (GE) stated that GE intended to do this for the advanced boiling water reactor.

(Original signed by)

Thomas H. Boyce, Project Manager &

Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page _

DISTRIBUTION w/ enclosure 1:

Central file PDST R/F TBoyce JNWilson PDR JPartlow, 12G18 EJordan, MNBB3701 ACRS (10)

PShea RHasselberg TWambach plSTRIBUTION w/o enclosures:

TMurley/FMiraglia DCrutchfield Wiravers RPierson RBorchardt SDembek CPoslusry MMalsch, OGC WRussell , 12G18 MFleishman, 16B15 KConnaughton, 16G15 GMizuno, 15B18 RNease, 16G15 EMcKenna, 16G15 JJohnson, 16G15 RMeyer, 16G15 MZobler, 15B18 JMoore, 15B18 TCollins, 16G15 GGrant, 17G21 BBorderick, 15B18 JGray, 16G15 MFinkelstein, 15B18 JLyons, 801 AThadani, 8E2 JRichardson, 7026 JScarborough, 16G1 RTripathi, 17G21 y EDoolittle,16G15 TCollins,16G15 MRubin,8EA KCyr, 16G15 ZRoszroczy, RES TDiPalo, RES GBagchi, 7H1 0FC: LA:PDST:ADAR '

PM:PDST: SC: I NAME: JNWj sp PShead2)e a - TBoyce:1 DATE: 12/R / 12/7-/92 12/pf924i 0FFICIAL RECORD COPY: NUMMTG.THB t/

1 l

cc: Mr. Robert Mitchell Mr. Joseph Quirk General Electric Company GE Nuclear Energy 175 Curtner Avenue General Electric Company San Jose, California 95125 175 Curtner Avenue, Mail Code 782 San Jose, California 95125 Mr. L. Gifford, Program Manager Regulatory Programs Mr. Steve Goldberg GE Nuclear Energy Budget Examiner 12300 Twinbrook Parkway 725 17th Street, N.W.

Suite 315 Room 8002 Rockville, Maryland 20852 Washington, D.C. 20503 Director, Criteria & Standards Div. Mr. Raymond Ng Office of Radiation Programs 1776 Eye Street, N.W.

V. S. Environmental Protection Agency Suite 300 401 M Street, S.W. Washington, D.C. 20006 Washington, D.C. 20460 Joseph R. Egan, Esquire Mr. Daniel F. Giessing Shaw, Pittman, Potts & Trowbridge U. S. Department of Energy 2300 N Street, N.W.

NE-42 Washington, D.C. 20037-1128 Washington, D.C. 20585 Mr. Nicholas J. Li;.arulo Marcus A. Rowden, Esq. Nuclear Safety & Regulatory Analysis fried, Frank, Harris, Shriver Nuclear & Advanced Technology Div.

& Jacobsen Westinghouse Electric Corporation 1001 Pennsylvania Avenue, N.W. P.O. Box 355 Suite 800 Pittsburgh, Pennsylvania 15230 Washington, D.C. 20004 Jay M. Gutierrez, Esq. Mr. John C. Butler Newman & Holtzinger, P.C. Advanced Plant Safety & Licensing 1615 L Street, N.W. Westinghouse Electric Corporation Suite 1000 Energy Systems Business Unit Washington, D.C. 20036 Box 355 Pittsburgh, Pennsylvania 15230 Mr. C. B. Brinkman, Acting Director Nuclear Systems Licensing Mr. M. D. Beaumont Combustion Engine ring, Inc. Nuclear & Advanced Technology Div.

1000 Prospect Hill Road Westinghouse Electric Corporation Windsor, Connecticut 06095-0500 One Metrose Metro 11921 Rockville Pike, Suite 350 Mr. C. B. Brinkman, Manager Rockville, Maryland 20852 Washington Nuclear Operations Combustion Engineering, Inc. Mr. S. M. Modro 12300 Twinbrook Parkway, Suite 330 EG&G Idaho Inc.

Rockville, Maryland 20852 P.O. Box 1625 Idaho Falls, Idaho 83415 Mr. Stan Ritterbusch Nuclear Licensing Combustion Engineering, Inc.

1000 Prospect Hill Road Post Office Box 500 Windsor, Connecticut 06095-0500 ,

MEETING WITH NUMARC NOVEMBER 10, 1992 lEMI AFFILIATION Je' y 14. Ison NRC/ADAR D' h !rutchfield NRC/ADAR Me ^ d. Malsch NRC/0GC William Russell NRC/NRR/ADT Tom Murley NRC/NRR Bill Borchardt NRC/ADAR Mort Fleishman NRC/0CMKR William Travers NRC/ADAR Bob Pierson NRC/ADAR ,

K. A. Connaughton NRC/0CM/JC Geary S. Mizuno NRC/0GC Tom Boyce NRC/ADAR Rebecca Nease NRC/0CM Eileen McKenna NRC/0CM/CD James W. Johnsoi NRC/0CM/IS Steve Dembek NRC/ADAR Ralph Meyer NRC/0CM/KR Marian Zobler NRC/0GC Janice Moore NRC/0GC Tim Collins NRC/0CH/FR Geoff Grant NRC/0EDO Bernard M. Cordenick NRC/0GC Michael Finkelstein NRC/0GC Jack Scarborough NRC/0CM/KR Chet Poslusny NRC/ADAR J. E. Lyons NRC/NRR J. Gray NRC/0CM/JC Dave Rehn Duke Power W. C. Counsil TV Electric Marc Rowden Fried, Frank /GE Adrian Heymer NUMARC Ray Ng NUMARC Steve Frantz Newman a Holtzinger Joe Egan Shaw Pittman (ABB)

A. J. James GE NE Robert W. Bishop NUMARC Charles Thompson DOE /NE-43 John Chambers GE Nuclear Energy Bart Cowan Eckert Seamans (Westinghouse)

Diane Antolovich Westinghouse Denny Popp Westinghouse Bill Ramsey Southern Company Jack Wheeler DOE Norman Fletcher DOE /ALWR Armand Langmo Bechtel Power Corp.

Russ Bell NUMARC John Rec ABB-CE Charles Brinkman ABB-CE Enclosure 1

MEETING WITH NUMARC NOVEMBER 19, 1992

[iAE AFFILIATION Jerry Wilson NRC/ADAR Jim Richardson NRC/DE Ashok Thadani NRC/DSSA Tom Hurley HRC/NRR W. T. Russell NRC/NRR/ADT Dennis Crutchfield NRC/ADAR Bob Pierson NRC/ADAR Beth Doolittle NRC/DCM/FR Tim Collins tRC/0CM/FR Martin G. Malsch NRC/0GC Mark Rubin NRC/NRR/ADT Tom Boyce NRC/ADAR Jim Lyons NRC/DSSA Bill Borchardt NRC/ADAR Rebecca Nease NRC/0CM Karen Cyr NRC/0CM William Travers NRC/ADAR Zoltan Roszroczy NRC/RES Goutam Bagchi NRC/ECGB Raji Tripathi NRC/0ED0 Vince San Angelo Bechtel Power Charles Brinkman ABB-CE Joseph Egan Shaw Pittman Charles Thompson DOE Robert W. Bishop NUMARC Adrian Heymer NUMARC Marc Rowden Fried, Frank Bill Rasin NUMARC Steve Frantz Newman & Holtzinger A. J. James GE Nuclear Energy Russ Bell NUMARC Dan Giessing DOE Regis Matzie ABB-CE

i NRC/NUMARC MEETING ON GENERIC ITAAC AND OTHER PART 52 ISSUES NOVEMBER 10,1992 ROCKVILLE, MD Enclosure 2

3 LNCLOSURE A NRC STAFF /NUMARC MEETING PART 52 ISSUES ..

NRC llEADQUARTERS, WlitTE FLINT, MARY 1AND 10:00 a.m. Introduction 10:05 a.m. Summary of Industry ITAAC Review, September 8 - October 2, 1992 10:15 a.m. Industry Action Plan for resolving generic ITAAC issues 11:00 a.m. Discussion on generic issues described in SRM on SECY 92 287, dated September 30,1992 11:10 a.m. Other Part 52 Issues

- Tier 2 " Prime" and change process

- Design Control Document

- Bridging Document Proprietary Information 11:50 a.m. Action Items 12:00 p.m. Adjournment

AREAS OF PROPOSED GENERIC ITAAC ,

• Welding

• Seismic including anchorage

• Seismic "2 over 1"

• EQ

• Set Point Methodology l

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NUMARC 1

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OTHER AREAS FOR GENERIC ITAAC BEING SUGGESTED BY NRC

• Conduit and cable trays including separation

• Rebar patterns and spacing

• Concrete criteria

• Anchor bolt criteria NUMARC 2

INDUSTRY POSITION GENERIC ITAAC

• Generic issues are not Tier 1. material NUMARC 3

PART 52 CONCEPTS

• Design Certification and COL implemented using two tier approach -- SRM on SECY-90-377 e Part 52 references Part 50 and its appendices

-- SECY-92-134 implies construction activities are inspected via SAYGO process for ITAAC and the traditional construction QA/QC processes

• Pre-Operational finding, i.e., fuel load authorization Compliance with ITAAC acceptance criteria No single deviation /non-compliance with such acceptance criterion permitted

• ITAAC relate to hardware verification not processes NUMARC I

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PART 52 CONCEPTS, CONTINUED u

e Tier 1 requirements Significant hardware design features Verification of proper implementation of design in constructed facility is via ITAAC

-- Failure to meet acceptance criteria in ITAAC could preclude fuel load authorization NUMARC-5

PART 52 CONCEPTS, CONTINUED I

e Tier 2 requirements SSAR as modified to reflect FSER Verification via Part 50, Appendix B, QAP ,

and NRC audit / inspection program i 4 l

l NUMARC 6

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GENERIC ISSUES VERIFIED BY QA/SAYGO PROGRAMS e SSAR/FSAR describes design and verification programs e Records Management implementation

• NRC staff inspection modules

• NRC sign-off on inspection modules at predetermined steps e Licensee takes corrective / preventive actions for any deficiencies NUMARC 7

t 4

SUMMARY

OF INDUSTRY REVIEW OF ITAAC SAN JOSE, CA SEPTEMBER 8 - OCTOBER 2,1992 l

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SCOPE AND GENERAL DETAILS -

• Review undertaken by discipline 1 Plant mechanical systems I & C, Software, Control Room design .

b Electrical power distribution Structural and buildings

• Approximately 8 - 12 reviewers per session l

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NUMARC 1

SCOPE AND GENERAL DETAILS

• Concentrated on ABWR submittal - Lead ALWR design Approximately 70% ABWR System ITAAC reviewed

• 5 ABB System 80 + systems reviewed

• 2 passive plant systems, AP600 design, discussed

• Initial aim to review ITAAC Group identified the need to review Tier 1 design descriptions NUMARC 2 i

REVIEW TEAM COMPOSITION

• 7 Utilities e 2 A/Es

• INPO, DOE, EPRI, NUMARC

• ABB Combustion Engineering, Westinghouse

• GE Nuclear Energy start-up engineers

• Legal Counsel l

.NUMARC 3

f s

I GENERAL CONCLUSIONS .

1

• ITAAC/ Tier 1 (design description) is a legal / licensing document rather than a technical document - Legal counsel / review an ,

important element

• ITAAC developed from Tier 1 design description

• Tier 1 design description developed from SSAR

• SSAR based on the detailed design NUMARC 4

--,,w- r g- 2~~

GENERAL CONCLUSIONS CONTINUED e ITAAC entries should not introduce new inspections, tests or analyses that are different from existing tests, inspections and analyses

• ITAAC requirements are a small part of the overall licensing commitment and the owner's iiispection and test program

• Where feasible, ITAAC inspections, tests or analyses should utilize existing pre-operational test programs NUMARC 5

9 GENERAL CONCLUSIONS, CONTINUED e in determining Tier 1 scope, following questions asked:

What are the important and salient aspects of the design that have a safety significance? 3 What is the effect of freezing the design for sixty years -- any knowledge of intentions to change regulations, methodologies or active R & D projects?

• More emphasis on testing and as-built inspections than in preliminary submittals

• Language in the ITAAC/ Tier 1 design .

description is critical

• General introduction / preamble for Tier 1/ITAAC document to include clarifying language to assist in understanding Tier 1/ITAAC document l

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• Need a set of general definitions NUMARc 6

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GENERAL CONCLUSIONS, CONTINUED e One test / inspection in the field can satisfy more than one ITAAC entry in an individual system or a number of systems e Benefits of developing boiler plate language for a number of system ITAAC entries --

minor revisions to take into account system nuances often required

• Figures and diagrams are useful, encouraged but not a requirement -- beneficial in understanding Tier 1 design description

• If drawings are utilized,.over prescriptive symbols should be avoided -- keep symbols general

• Not every Tier 1 design description entry needs or demands an ITAAC entry

• Operator actions should not be included or accounted for in ITAAC -- ITAAC relate to the Certified Design NUMARC 7

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GENERAL CONCLUSIONS, CONTINUED e Scope and content of systems Safety related systems -- correct level of detail -- wording has changed to make more specific and objective Non-Safety related systems -- reduced content but more emphasis on detail and specificity and objective acceptance criteria .

Wording has changed but the thrust and content is very similar to preliminary submittal Language is more specific, objective and measurable e Conscientious and detailed review of Tier 1 design descriptions is essential NUMARC 8

.. - -. -. . -- -- - - - - . - _- _- -= _- - --.

GENERAL CONCLUSIONS, CONTINUED e Avoid direct references to code and standards ,

in Tier 1 with the exception of ASME Section lli e Important to have a Writers' Guide / Style Guide and Part 52/ITAAC orientation Writers' guide / style guide should include a preferred list of phrases /words in addition to a list of phrases /words to be avoided Orientation is critical for. authors of ITAAC AND the complete project group --

designers, reviewers, supervisors and managers Feedback to complete project team is important NUMARU 9

4 GENERAL RECOMMENDATIONS

• Internal review group essential - potential <

customer review beneficial

• Further industry discussion warranted Seismic & Structural issues Environmental Qualification Set Point Methodoiogy Impact of Tier 1 on operations post fuel load

• "One on One" GE/NRC staff interactions --

with managerial support as required --

essential to assure timely resolution of ITAAC issues Build on the rapport achieved during the ,

individual NRC/ Review Group interactions in San Jose NUMXRC 10

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g +y , e- , , - v

REVIEW GROUP OPEN ISSUES 1

• Generic ITAAC associated with QA/QC and i construction / design / procurement process and interf ace issues Action plan to resolve this issue being discussed within the industry -- part of November 10 management meeting

• Industry uncertainty over the scope of NRC staff suggestion to modify Tier 2

• Scope of Tier 1/ITAAC and regulatory -

envelope for passive designs

• Regulatory significance and impact of Tier 1 design descriptions on operations - (post fuel load)

L 1

l NUMARC 11 1

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DEFINITION OF EQUIPMENT QUALIFICATION Hechanical and electrical equipment that is used to perform a necessary safety <

function must be demonstrated to be capable of maintaining functional

- operability under all service conditions, including LOCA, postulated to occur during its installed life for the time it is required to operate.

Documentation relating to equipment qualification issues will be completed for all equipment items important to safety in accordance with the requirements of GDC 1, 2, and 4 of Appendix A and Criterion 111, XI, and XVil of Appendix B to 10 CFR 50, and 10 CFR 50.49. This documentation will be in the form of the equipment qualification list and the device specific qualification _ files, and .

will include the specified environmental conditions, qualification methods (e.g., tests, or tests and analyses), and documentation of qualification results. The installed condition of mechanical and electrical equipment important to safety will be conipatible with conditions for which it was ,

qualified.

SYSTEM AND BUILDING ITAAC The functional diagrams provided in the ITAAC for each system should identify the portions of the system required to be environmentally qualified that are inside containment, or in other areas, that are defined as a harsh environment and the portions that are in a mild environment. Also, the building drawings in Tier 1 should identify the areas that are defined as harsh and mild environments.

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l Enclosure 3 m _ _ _f _ . . . , _ _ . _

@ WR E0VIPMENT OVAllFICATION 3.10 Seismic and Dynamic Qualification of Mechanical and Electrical Eauipment In SSAR Sections S.9.2.2 and 3.10, GE provides information on the seismic and dynamic qualification of safety-related mechanical and electrical equipment.

Section 3.9.3.2, also contains information relative to pump and valve opera-bility assurance. This information includes

• rationale used to determine if tests, analyses, or combinations of both will be performed

• criteria used to define the seismic and other relevant dynamic load input motions the proposed demonstration of the adequacy of the qualification program GE will use the seismic qualification methodology in Section 4.4 of NEDE-24326-1 (proprietary) for both mechanical and electrical equipment. This program conforms to Institute of Electrical and Electronics Engineers (IEEE) 323 as modified and endorsed by RG 1.89. The program also meets the criteria in IEEE 344 as modified by RG 1.100. In SSAR Tables 1.8-20 and ,

1.8-21, GE agrees to use RG 1.100, Revision 2, June 1988, and IEEE 344, 1987.

It shou'd be noted that Section 9 of IEEE 344, 1987 recognized the use of

" experience data" as a method for seismic qualification of equipment. As used in IEEE 344, experience data includes both seismic experience and previous qualifications. The staff has not accepted the use of seismic experience on either evolutionary or passive plants. In accordance with RG 1.100, Revi-sion 2, the method of qualification will be reviewed by the staff on a case-by-case basis. The staff reviewed NEDE-24326-1 (proprietary) and approved the qualification methodology therein in an SER sent to GE on October 23, 1983.

-In response to the staff's request for information in Question 271.2, GE stated that the methodology in NEDE-24326-1 (proprietary) also conforms to the above commitments in Tables 1.8-20 and 1.8-21. This commitment is acceptable.

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lhe methodology in NEDE-24326-1 (proprietary), supplemented by the information in SSAR Sections 3.9.2.2 and 3.9.3.2, provides test and/or analysic criteria used to demonstrate the operability of active pumps and valves (i.e., those ASME Class 1, 2, or 3 components which must perform a mechanical mation to shut down the plant or mitigate the consequences of a postulated event). The criteria described are consistent with the guideline in SRP 3.10. In addi-tion, consistent with staff positions on recently licensed plants, SSAR Sec-tions 3.9.3.2.1.1, 3.9.3.2.3.1.4, and 3.9.3.2.5.1.2 provide commitments that operability is further assured by limiting the stresses to the material elastic limit when the component is subjected to (1) the combination of normal operating loads, (2) SSE and other reactor bui' ding vibration loads, and (3) dynamic sy 'am loads (LOCA). Specifically, the average membrane stress resulting fro: 7 wove faulted condition (Service Level D) loads is limited to 75 percent vi una material yield stress, and the maximum membrane plus bending stress is lhited to 110 percent of the yield stress. Imptementation of such criteria will provide assurance that valve bodies or pump t.ases will not distort to the extent that operubility of the mmponent is impaired.

NEDE-24326-1 (proprietary) provides qualification methodology only cnd con-tains no plant-specific information. Therefore, each COL applicant referenc-ing this document must ensure that specific environmental parameters along with seist'.c and dynamic input response spectra are properly defined and enveloped in the methodology for its specific plant and implemented in f.h equipment qualification program, in SSAR Sections 3.9.3.2 and 3.10, GiL commits the COL applicant to provide documentation of the results of both the pump and valve operability and the seismic and dynamic qualification programs. In addition, in accordance with the supporting Tier 2 material discussed below, the COL applicant shall develop and maintain files on the ABWR tests and analy;es that were performed to (1) ensure that the criteria in the SSAR were properly implemented, (2) ensure that adequate qualification was demonstrated for all equipment and their supports, and (3) verify that all applicable loads were properly defined and accounted for in the testing and analyses performed. in SSAR Section 3.10.5, GE commits that aoplicants referencing the ABWR design will maintain in a permanent file equipment -

qualification records includi" reports described in SSAR Sections 3.10.2.1.4 and 3.10.2.2.3. In addition, these records will be readily available for audit. Since this issue involves plant-specific information, the staff concludes that it does not meet the requirements of 10 CFR 52.47(a)(1)(vil),

and therefore cannot be categorized as.an interface. Thir is COL Action Item 3.10-1.

The staff concludes that GE has defined appropriate seismic and dynamic caali-fication of mechanical and electrical equipment and pump and valve operability programs. These programs meet applicable portions of GDC 1, 2, 4,14, and 30, Appendices A and B to 10 CFR Part 50, 10 CFR Part 52.47, and Appendix A tJ 10 CFR Part 100 and are acceptable.

3.10.1 Supporting Tier 2 Material The criteria listed below provides a more detailed basis to support the staff's conclusion in Section 3.10 above. G.E. should revise the SSAR Section 3.10 to include all of the following criteria including the pertinent portions of NEDE-24326-1 (proprietary) as indicated below with references to applicable SSAR sections which contain commitments to each ites. A COL applicant pro-

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P posing to use criteria other than those discussed below for equipment' seismic-qualification, shall submit them to the NRC staff as a part of its COL application for review t,nd approval prior to its use.

1. Tests and analyses are required to confirm the operability of all mechanical and electrical equipment during and after an earthquake of magnitude up to and including the SSE, and for all static and dynamic-loads from normal, transient and accident conditions. Prior to SSE qualification, it should be demonstrated that the equipment _-can with-stand the % SSE excitation without loss of structural integrity.

Analyses alone, without testing, are acceptable as a basis for qualification only if the necessary functional operability of the equipment is assured by its structural integrity alone. When complete testing is impractical, a combination of tests and analyses is acceptable.

Equipment that has been previously qualified by means of tests and analyses equivalent to those described here are acceptable provided that proper documentation of such tests and analyses is submitted.

Commitments to most of the above criteria can be found in the SSAR, Subsections 3.9.2.2 and 3.9.3.2 and in NEDE-24326-1 (proprietary),

Sections 4.4.2.5.1, 4.4.3.3 and 4.4.4.

2. Equipment should be tested in the operational condition. Operability should be verified during and/or after the testing, as applicable to.the equipment being tested. Loadings simulating those of plant normal nperation, such as thermal and flow-induced loading, if'any, should be concurrently superimposed upon the seismic and other pertinent dynamic loading to the extent practicable. Particular attention should be paid, in operability qualification of mechanical equipment subjected to flow-induced loading, to incorporate degraded flow conditions such as those that might be encountered by the presence of debris, impurities, and contaminants in the fluid system. An example of this may be the opera-bility of the containment sump pump recirculating water full of debris.

Commitments to most of the above criteria can be-found in the SSAR, Subsections 3.9.2.2 and 3.9.7. 2 and .in NEDE-24326-1 (proprietary),

Sections 4.4.2.5, 4.4.2.5.1 ud 4.4.2.5.2.

3. The characteristics of the required seismic and dynamic input motions should oe specified by response spectrum or time history methods. These characteristics, derived from the structures or systems seismic and dynamic analyses, should be representative of the input motions at the equipment mounting locations.

Commitments to the above criteria-can be found;in the-SSAR, Subsection J.7.3.1 and in NEDE-24326, Section 4.4.4.1.4.6.2.

4. For seismic and dynamic loads, the actual test input motion-should be characterized in the same manner-as the required input motion, and the conservatism in amplitude and frequency content should be demonstrated (i.e., the test response spectrum should closely resemble and envelope the required response spectrum over the critical frequency range).

-0 Commitments to the above criteria can be found in the SSAR, Subsection 3.9.2.2.1 and NEDE-24326-1 (proprietary), Section 4.4.2.5.3(b).

5. Since seismic and the dynamic load excitation generally have a broad frequency content, multi-frequency vibration input motion should be used. However, single frequency input motion, such as sine beats, is acceptable provided the characteristics of the required input motion indicate that the motion is dominated by one frequency (e.g., by structural filtering effects), or the anticipated response of the equipment is adequately represented by one mode, or in the case of structural integrity assurance, the input has sufficient intensity and duration to produce suffhiently high levels of stress for such assurance. Components that have been previously tested to IEEE Std. 244-1971 should be reevaluated to justify the appropriateness of the input motion used, and requalified if necessary.

Commitments to the above criteria can be found in the SSAR, Subsection 3'

3.9.3.2.3.1.4 and in NEDE-24326-1 (proprietary), Sections 4.4.2.5.3 and 4.4.2.S 6.

6. For the seismic and dynamic portion of the loads the test input motion should be applied to one vertical axis and one principal horizontal axis (or two orthogonal horizontal axes) simultaneously unless it can be demonstrated that the equipment response in the vertical direction is not sensitive to the vibratory motion in the horizontal direction, and vice versa. The time phasing of the inputs in the vertical and horizontal directions must be such that a purely rectilinear resultant input is avoided. An acceptable alternative is to test with vertical and horizontal inputs in-phase, and then repeat the test with inputs 180 degrees out-of-phase. In addition, the test must be repeated with the equipment rotated 90 degrees horizontally.

Components that have been previously tested to IEEE Std. 344-1971 should "

be requalified using biaxial test input motions unless justification for using a single axis test input motion is provided.

Commitments to the above criteria can be found in the SSAR, Subsaction 3.9.3.2.3.1.4 and NEDE-24326-1 (proprietary), Section 4.4.2.5.4.

7. Dynamic coupling b 9n the equipment and related systems, if any, such as connected ,. ing and other mechanical components, should be considered.

8. The fixture design should simulate the actual service mounting and should not cause any extraneous dynamic coupling to the test item. A commitment to this criteria can be found in the SSAR, Subsection 3.9.2.2.1.

9. For pumps and valves, the loads imposed by the attached piping should be properly taken into account. In order to assure operability under com-bined loadings, the stresses resulting from the applied test loads should envelope the specified service stress limit for which the component's operability is intended. As discussed in Section 3.10

l above, the SSAR, Subsections 3.9.3.2.1.1, 3.9.3.2.3.1.4 and l 3.9.3.2.5.1.2 contain criteria which addresses this issue. 1

10. If the dynaniic testing of a pump or valve assembly proves to be imprac-ticable, static testing of the assembly is acceptable provided that the ,

end loadings are conservatively applied and are equal to.or greater than '

postulated event loads, all dynamic amplification effects are accounted for, the component is in the operating mode during and after the ,

application of loads, and an adequate analysis is made to show the '

validity of the static application of loads,

11. The in situ application of vibratory devices to simulate the seismic and dynamic vibratory motions on a complex active device is acceptable to confirm the operability of the device when it is shown that a meaningful test can be made in this way.

12. The test program may be tested upon selectively testing-a representative number of components according to type, load level, size, etc., on a prototype basis.

13. Selection of damping values for equipment to be qualified should be made in accordance with Regulatory Guide 1.61 and IEEE Std. 344-1987.- Higher damping values may be used if justified by documented test data with proper identification of the source and mechanism. Confirmatory Issue 3.9.2.3-2 addresses this issue.

14. When complete testing is not practicable, the features listed below-should be incorporated into a test and analysis operability assurance-program for pumps and valves. Similar programs can be developed for other types of equipment,

a. Simple and passive elements, such as valve and pump bodies and their related piping and supports may be analyzed to confirm structural integrity under postulated event loadings. However, complex active devices such as pump motors, valve operator and gate or disk assem-

! blies, and other electrical, mechanical, pneumatic, or hydraulic

[- appurtenances which are vital to the pump or valve operation should-be tested for operability.

l b. The following analyses are acceptable provided they are correlated to classical problems, elementary laboratory-tests, or in situ l tests:

l l i. An analysis is performed to determine the vibratory input to the valve or pump.

! 11. An analysis is performed to determine the system natural frequencies and the movement-of the pump or valve during the dynamic events.

iii. An analysis is performed to determine the pressure differential and the impact energy on a valve disc dering a LOCA, and to-l verify the design adequacy of the disc.

I l'

b '

iv. An analysis is performed to determine the forcing functions of.-

the axial and radial loads imposed on-a pump rotor due to a LOCA, such that combined LOCA and vibratory effects on the shaft and rotor assembly can be evaluated.

v. An analysis is performed to determine the speed of the pump shaft as a result of postulated events and to compare it with the design critical speed.

vi. An analysis is performed to verify the' design adequacy of.the wall thickness of valve and pump pressure-retaining bodies.

vii. An analysis is performed to determine the natural frequencies or a pump shaft and rotor assembly to ascertain whether they are within the frequency range of the vibratory excitations.

If the minimum natural frequency of the assembly is beyond the excitation frequencies, a static deflection analysis of the shaft is accaptable to account for dynamic effects. If the assembly natural frequencies are close to the excitation fre-quencies, an acceptable dynamic analysis must be performed.to determine the structural response of the assembly to the excitation frequencies.

viii. When analyses are used for qualification, the. combination of multimodal and multidirectional responses should be made in accordance with Regulatory Guide 1.92.

15. GDC 1 of Appendix A and paragraph XVII of Appendix B to 10 CFR 50 estab-lish requirements for records concerning the qualification of equipment.

In order to satisfy these requirements, complete and auditable records must be available and maintained by the applicant, for the life of the plant, at a central location. Their files should describe the qualifica-tion acthod used for all equipment in sufficient detail to document the degree of compliance with the criteria of this SRP section. These records should'be updated and maintained current as equipment is-replaced, further tested, or otherwise further qualified.

The equipment qualification file should contain a list of all systems equipment and the equipment support structures, as defined-in paragraph 2 of subsection I. The equipment list should identify which equipment is NSSS supplied and which equipment is B0P supplied. The equipment quali-fication file should also include qualification summary data sheets for each piece of equipment, i.e., each mechanical and electrical component of each system, which summarize the component's qualification. These data sheets should include the following information:

a. Identification of equipment, including vendor,-model number and location within each building. Valves that are part of the reactor coolant pressure boundary should be so identified,

b. Physical description, including dimensions, weight and field mounting condition. Identification of whether the equipment is pipe, floor, or wall supported.

I

c. A description of the equipment's function within the system. l

d. Identification of all design (functional) specifications and .

qualification reports, and their locations. Functional.specifica- 1 tions for active valve assemblies should confirm to the Regulatory i Position of Regulatory Guide 1.148.

e. Description of the rc aired loads and their intensities for which the equipment must be qualified.

f. If qualification by test, identification of the test methods and procedures, important test parameters and a summary of the test ,

results,

g. If qualification by analysis, identification of the analysis methods and assumptions and comparisons between the calculated and allowable stresses and deflections for critical elements.

h. The natural frequency (or frequencies) of the equipment.

i. Identification of whether the equ pment may be affected by vibration fatigue cycle effects and a descr;ption of the methods and criteria used to qualify the equipment fo- such loading conditions.

J. Indicate whether the equipment has met the qualification requirements.

k. Availability for inspection, i.e., identify whether the equipment is already installed.

1. A compilation of the required response spectra (or time' history) and corresponding damping for each seismic and dynamic load specified for the equipment together with all other loads t.onsidered in the qualification and the method of combining all loads.

3.10.2 Methods and Procedures of Analysis or Testing of Supports of Electrical Equipment and Instrumentation SSAR Section 3.10.3 describes the procedures and criteria for the seismic qualification and design of th? NSSS electrical equipment supports; seismic Category I supports for battery racks, instrument racks, control consoles, cabinets, and panels; seismic Category I alectrical raceway (cable trays and conduit) supports; seismic Category I local instrument supports; and seismic Category I instrument tubing supports. This section of the report covers only the staff's evaluation of the procedures and criteria for the design of the seismic Category I electrical raceway supports.

SSAR Section 3.10.3.2.2 describes the procedures'and criteria for the. design-of the seismic Category I electrical raceway supports. GE used the response spectrum method to analyze the composite ' system of the_ electrical raceways and l supports to calculate the seismic loads and the reactor building vibration l (RBV) loads resulting from an SRV discharge or LOCA inside the containment.

The input to the dynamic analysis is the seismic and RBV floor response spectra (FRS) generated for the supporting floor. In case the. supports _are l

I

l Weldina and Weld Acceolance Criteria The requirements listed below are considered by the staff to be essential in controlling welding activities. Any change will require the COL applicant to submit the changes to the NRC staff for review and approval prior to use.

ASME Code Weldina Welding activities shall be performed in accordance with the requirements of Section 111 of the ASME Code. The required nondestructive examination and acceptance criteria is stated in Table 1. Component supports shall be fabricated in accordance with the requirements of Subsection NF of Section III of the ASME Code except that the visual weld acceptance criteria shall be the Nuclear Construction issue Group (NCIG) standard NCIG-01, " Visual Weld Acceptance Criteria for Structural Welding of Nuclear Power Plants," Revision -

2.

Weldina of non-ASME pressure retainina Piping Welding activities involving non-ASME pressure retaining piping shall be accomplished in accordance with written procedures and shall meet the requirements of the ANSI B31.1, Code. The weld acceptance criteria shall be as defined for the applicable nondestructive examination method described in ANSI B31.1 Code Weldina of Structural and Buildina Steel Welding activities shall be accomplished in accordance with written procedures and shall meet the requirements of the American Institute of Steel Construction (AISC) Manual of Steel Construction. The visual acceptance criteria shall be as defined in NCIG-01, Revision 2.

Weldinq of Electrical Cable Tray and Conduit Supports Welding activities shall be accomplished in accordance with the American Welding Society (AWS) Structural Welding Code, D1.1 The weld visual acceptance criteria shall be as defined in NCIG-01, Revision 2.

Weldina of Heatina Ventilatina and Air Conditionina Supports Welding activities shall be accomplished in accordance with the American Welding Society (AWS) Structural Welding Code, D1.1 The weld visual acceptance criteria shall be as defined in NCIG-01, Revision 2.

Weldina of Refuel Cavity and Spent Fuel Pool liners Welding activities shall be accomplished in accordance witn the American Welding Society (AWS) Structural Welding Code, D1.1 The welded seams of the liner plates shall be spot radiographed, liquid penetrant and vacuum box examined after fabrication to ensure that the liner do not leak. The acceptance criteria for these examination shall meet the acceptance criteria stated in subsection NE-5200 of Section 111 of the ASME Code.

attached to a wall or to two different locations, the input is the upper bound FRS envelope obtained by superimposing the FRS of both floors or locations.

In addition,-in many cases GE combined several FRS by superposition to I

generate an upper. bound FRS envelope as the input to facilitate the design.

According to SSAR Section 3.8.4.2.4, the design of seismic Category I electri-cal raceway supports uses codes, standards, and specifications applicable to '

the building structures to which they are attached. These codes include AISC Steel Construction Manual and AISI SG-673. The supports are designed and located to withstand the dynamic loads in three directions by means of verti-cal, transverse, and longitudinal support and bracing systems. The design considers the dead loads, live loads, and seismic loads plus other RBV dynamic -

loads. According to SSAR Section 3.10.3.2.2, the supports, including those for the non-seismic Category I cable trays and conduits, are designed to meet seismic Category I requirements. These design criteria and procedures meet the guidelines of SRP Section 3.8.4 and are acceptable. However, GE did not provide the design procedures and criteria for the seismic Category I cable ~

trays and conduit. This is Open Item 3.10.3-1.

GE is required to resolve the open item above for the staff to conclude that the procedures and criteria for the design of seismic Category I raceway supports are acceptable.

, ,n, - , _ . . . -

i TABLE I Welding Activities and Weld Examination Requirements for ASME Code,Section III Welds Class 1 Components (1)(2)(3).

_ Component Weld Type NDE'Reouirements Vessel Category A (Longitudinal) RT nius MT or PT Vessel, Pipe, Category B RT plus.MT or PT Pump, Valve (Circumferential)

Pipe, Pump, Butt weld RT plus MT or.PT Valve Fillet and socket welds MT or PT Category C and 51milar RT plus MT or PT. RT must be Vessels (6) welds multiple exposure Partial penetration and MT or PT on all accessible surfaces fillet welds Category 0 Vessels (6) a) Butt welds, all RT plus MT or PT

& Branched b) Corner welded nozzles RT plus MT or PT Connections .c) Corner welded branch and RT plus MT or PT piping connection exceed-ing 4" nominal diameter d) Corner welds branch and MT or PT piping 4" and less e) Weld buildup deposits at UT plus a, b, c above if connected to openings nozzle or pipe f) Partial penetration MT or PT progressive and final surface g) Oblique full penetration RT-or UT plus MT or PT. In addition, branch and piping UT of weld, fusion zone, and parent connections metal beneath attachment surf ace.

General Fillet, partial penetration, MT or PT socket welds

. Ger eral Structural attachment welds MT or PT Special welds 1) Specially designed seals- MT or PT

2) Weld metal cladding- PT

3) Hard surfacing PT a) Valves 4" or less None PT

4) Tube-tube sheet weldt

5) Brazed joints VT 1

Class 2 Components (1)(2)(4)

-Component Weld Type NDE Requirements Vessel Category A (Longitudinal)-

RT .

a) Either of the members exceeds 3/16 inch MT, PT, or RT b)-Each member 3/16 inch or less Pipe, Pump, Longitudinal RT Valve Vessel. Category B (Circumferential)

RT a) Either of the members exceeds 3/16 in. MT. PT, or RT b) Each member 3/16" or less Pipe, Pump and Circumferential RT Valve a) Butt welds b) Fillet and partial penetration MT or PT Vessel (6) and Category C similar joints a) Corner joints, either of the RT in other members exceeds 3/16" of components thickness b) Each member 3/16" or less MT, PT, or RT c) Partial penetration and fillet MT or PT welds Vessel (6) and- Category D similar welds a) Full penetration joints when RT in other either members exceed 3/16" of components thickness b) Full penetration corner MT or PT

.jointsLwhen either member exceeds 3/16" c) Both members 3/16" or less MT or PT d) Partial penetration and MT or PT fillet weld joints RT Brar ch Con. a) Nominal size exceed 4" and Nozzles in b) Nominal size 4" or smaller - MT or PT (external and pipe, valve, accessib'le internal surfaces) pump

Class 2 Components (Cont'd)(1)(2)(4)

Component Weld Type NDE Requirements Vessels + Cat. A -RT designed to Cat. B RT NC-3200 Cat. C, Butt weld RT Cat. C, Full penetration corner UT or RT Cat. C, Partial penetration corner MT or PT both sides and fillet welds Cat. D, Full penetration (6) RT Cat. D. Partial penetration MT or PT both sides Fillet, Partial Penetration, socket, MT or PT and structural attachment welds Special Welds a) specially designed seals MT or PT b) weld metal cladding MT or PT c) hard surfacing PT d) hard surf acing for valves with None inlet connection 4" nominal pipe size or less e) tube-tube sheet welds PT f) Brazed joints VT-Storage Tanks a) side joints RT (Atmospheric) b) roof and roof-to-sidewall VT c) bottom joints vacuum box testing of-at least 3 psi-d) bottom to sidewall vacuum box + MT or PT e) Nozzle to tank side MT or PT f) Nozzle to roof VT g) Joints in nozzles- RT h) others Similar welds in vessels Storage Tanks a) sidewall RT (0-15 psi) b) roof RT .

c) roof-to-sidewall RT. if not possible, MT or PT d) bottom & bottom-to-side vacuum box method + MT or PT e) nozzle tank M1.or PT f) joints to nozzles RT.

g) others same as similar vessel joiots

• :. _ 3 _ - ,

Class 3 Components (1)(2)(5)-

Component Weld Type 'NDE Requirements Vessels Category A (Longitudinal) 1.- a) Thickness exceeding the limits RT of Table ND. 5211.2-1 b) Welds based on joint effi- RT .

ciency permitted by ND.3351.1 c) butt welds in nozzles attached RT to vessels in a or b above

2. Welds not included in 1 above Spot RT 'each 50 ft of weld.

additional RT to cover each-welders work. .

3. Nonferrous vessels exceeding 3/8 RT inch Pump, Valve, Pipe -

pipes greater than 2 in. size RT, MT, or PT pumps & valves greater than 2 in, according to-the product-form-Vessel Category B (Circumferential)

1. a)- Thickness exceeds Table RT ND.5211.2 for Ferrous metals b) thickness exceeds 2/8 in for RT nonferrous metals c) joint efficiency according to RT ND.3352.l(a) d) attachments to vessels and RT exceeds nominal pipe size 10" or thickness 1 1/8 in.

2. welds not involved in 1 above _ RT'6.in. long sections'+ the intersections of Cat; A welds pipe, pump and Greater, than' 2" nominal pipe size RT~, PT, or MT

' valve Vessel Category C:

1. 'a) Thickness exceeds Table - RT N3-5211.2 or ND-5211.3 b) Attachments exceed 10 inch RT-NPS or 1 1/8 inch wall thickness

2. Welds not involved in 1 or 2 Spot RT_to-cover each above welders work-Pipe. Pump, Valves Greater than 2" nominal' pipe size RT, PT. or MT

-.7 -.

Class 3 Components (Cont'd)(1)(2)(5)

Vessel Category D:

1. Fuli penetration butt welds RT designed for joint efficiency per ND.3352.1(a)

2. In nozzles or communicating RT s chambers attached to vessels or heads requiring full RT

3. Welds not covered ~by 1 and 2 Spot RT to cover each' above welders work Pipe, Pump and Greater than'2" nominal pipe size RT, PT, or MT Valve Special Welds a) weld metal cladding PT b) hard surfacing PT (i) hard surfacing for valves none with inlet connection 4" nominal pipe size or less c) tube-tube sheet welds -PT d) Brazed joints VT Storage Tanks a) sidewall joints Same as Category A or B

.(Atmospheric) vessel joints b) roof and roof-to-sidewall VT c) bottom joints vacuum box testing of at least 3 psi, or PT or MT plus VT during. pressure test -

d) bottom to sidewall Same-as bottom joints e) Nozzle to tank side MT or PT. .

f) Nozzle-to-roof VT g) Joints in nozzles ex. roof nozzles MT or PT h) others Similar welds in vessels Storage Tanks a) sidewall Same-as Category A or B (0-15 psi) vessel joints -

b) roof Same as Category A vessel-joints c) roof-to-sidewall Same as above if possible,

.r MT or PT o

d) bottom & bottom-to-side Vacuum box testing at least' 3 psi, or PT pr MT plus VT during-pressure test e) nozzle to tank MT or_PT

-f) joints in nozzles MT or PT1 g) others same as similar vessel joints l

l l

=

d

.**e Containment Vessel (1)(2)(6)

Component Weld Type NDE Requirements Containment Category A, Butt Welds (Long'l) ' RT Containment Category B, Butt Welds (Circ.) RT Containment Category C, Butt weld RT .,

Containment Category C, Nonbutt Welds UT or MT or PT Containment Category D, Butt Welds RT Containment Category D, Nonbutt Welds UT or MT or PT Containment Structural attachment welds a) Butt Welds RT b) Nonbutt Welds UT or MT or PT Spe:ial welds Weld Metal Cladding PT Components Supports (1)(2)(7)

Component Weld Type NDE Requirements Class 1 Primary Member, Full Supports Penetration Butt Welds RT All other welds MT or PT Secondary Member Welds VT Class 2 and MC Primary Member, Full Supports Penetration Butt Welds RT Partial Penetration or fillet MT or PT welds throat greater than 1"'

All other Welds VT i Secondary Member Welds VT Class 3 Primary Member, Groove or MT or PT Supports throat greater than 1" All other welds VT-Secondary Member. Weld \ff l

L Special- Welds Transmitting Loads in the UT base metal beneath the weld Requirements, Through Thickness Direction in All Classes Members Greater than 1" S

NOTES: ,

1) -The required confirmation that facility welding activities are in-compliance with the certified design commitmsnts will include the-following third party verifications:

a. Facility welding specifications and procedures meet the applicable ASME Code requirements

b. Facility welding activities 4re performed in accordance with the applicable ASME Code requirements

c. Welding activities related records are prepared, evaluated and maintained in accordance with the ASME Code requirements

d. Welding processes used to weld dissimilar base metal and welding filler metal combinations are compatible for the intended _ applications

e. The facility has established procedures for qualifications of welders and welding operators in accordance with the applicable ASME Code requirements

f. Approved procedures are available and used for preheating and post heating of welds, and those procedures meet the applicable requirements of the ASME Code

g. Completed welds are examined in accordance with the applicable examination method required by the ASME Code

2) Radiographic film will be reviewed and accepted by the COL applicant's nondestructive examination (NDE), Level III examiner prior to final acceptance

3) The NDE requirements for Class I components will be as stated in subarticle NB-5300 of Section III of the ASME Code

4) The NDE requirements for Class 2 components will be as stated in subarticle NC-5300-of Section III of the ASME Code

5) The NDE requirements for Class 3 components will be as stated in

! subarticle ND-5300 of Section III of the ASME Code

6) The NDE requirements for_ containment vessels will be as stated in subarticle NE-5300 of Section III of the ASME Code

7) The NDE requirements for component supports will be as stated in subarticle NF-5300 of Section III of the ASME Code

8) For corner joints UT may be used instead of RT. For Type 2 full L penetration corner weld joints, if RT is used, the fusion zone, and parent l-metal beneath the attachment surface shall be UT examined after welding.

! LEGEND:

L L RT - Radiographic Examination; UT - Ultrasonic Examination; MT - Magnetic

!~ Particle Examination; LP - Liquid Penetrant Examination; VT - Visual Examination i

l 3 l

'- a

.. g g .-

Fig. NB-3351-1 Welded joint locations typical of categories A, B, C, and D

j Fig..NB-3352-1 typical butt joints  !

l - L - i