Text

Responds to RAI Re GL 87-02 Concerning Verification of Seismic Adequacy of Mechanical & Electrical Equipment in ors
	ML20134F449
Person / Time
Site:	Farley
Issue date:	10/28/1996
From:	Dennis Morey; SOUTHERN NUCLEAR OPERATING CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9611050297
	Download: ML20134F449 (49)
	v • d • e

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Southern Nuctsar Operating Company -

,p Post Office Box 1295 Birminghsm. Alabama 35201 -

Telephone (205) 868 5131

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o.v. 4ey Southem Nudear Operating Company Vice President Farley Project the Southern electhC System L

Docket Nos.:

50-348 10 CFR 50.4 50-364 i

l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 l

Joseph M. Farley Nuclear Plant Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors Unresolved Safety Issue (USI) A-46. Generic Letter 87-02 RAI Response Ladies and Gentlemen:

This letter is in response to the Request for Additional Information (RAI) dated August 29,1996, conceming our submittal dated May 18,1995, titled " Unresolved Safety Issue (USI) A-46, Generic

~ Letter E7-02 Response." The enclosure provides the Southem Nuclear Operating Company (SNC) l response to the RAI questions.

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In our May 18,1995 submittal we stated our intention to revise the licensing basis for both Units I and j

2 to allow application of earthquake experience data as an acceptable alternative for documenting the seismic adequacy of appropriate mechanical and electrical equipment. We strongly believe that since the original seismic licensing basis and design for both Units 1 and 2 is IEEE 344-1971, and the Units are basically identical, with only minor variations existing with regard to seismic design requirements, that if the GIP-2 methodology is acceptable for Unit I for new and replacement equipment then it also should be acceptable for Unit 2. However, we do recognize the NRC staff position that Unit 2 is not j

considered a USI A-46 plant. SNC will therefore not apply the GIP-2 methodology at this time to Unit l

2 for new and replacement equipment. SNC will continue to pursue NRC approval of application of the GIP methodology on an industry basis for plants in a similar position as FNP Unit 2. Upon resolution l

of open issues with the NRC, SNC will revise the FNP FSAR as appropriate.

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U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please advise.

Respectfully submitted,'

SOUTHERN NUCLEAR OPERATING COMPANY 6f4 7/ W Dave Morey

. MJA/ cit:A-46rai. doc

Enclosure:

A-46 Request for Additional Information cc:

Mr. S. D. Ebneter, Region II Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident Inspector i

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J ENCLOSURE Farley Nuclear Plant - Unit 1 USI A-46 Reauest for AdditionalInformation

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Enclosure Farley Nuclear Plant - Unit 1 USI A-46 Reauest for AdditionalInformation 1.

Question:

For the plant structures containing equipment in the USI A-46 scope:

Identify structures that have licensing-basis floor response spectra (5 percent a.

critical damping) for clevations lower than 40 feet above the effective grade, whose amplitude is greater than 1.5 times the GIP-2 Bounding Spectrum.

b.

Provide the response spectra designated according to height above the effective grade identified in item 1.a above and a comparison to 1.5 times the Bounding Spectrum.

With respect to the comparison of equipment seismic capacity to seismic c.

demand, indicate which method (Method A or Method B in Table 4-1 of GIP-2) was used to address the seismic adequacy of equipment installed on those floors identified in item 1.a above.

Response

This question is related to the use of 1.5 times the plant SSE ground response spectra as a realistic estimate of seismic demand under certain limited conditions as specified in the GIP. It is our understanding that the NRC Staff and representatives of the Seismic Qualification Utility Group (SQUG) arejointly secking generic resolution of this issue. It is Southern Nuclear Company's (SNC) position that the GIP has oeen approved by the NRC Staffin Supplemental Safety Evaluation Report No. 2 dated May 22,1992, (Reference 1) as an acceptable method of demonstrating the seismic adequacy of equipment within its scope. This new methodology differs from that contained in the existing plant licensing basis in substantial and fundamental respects. Accordingly, it is impossible to meaningfully compare isolated aspects of the two methodologies including their relative conservatisms. Any such comparison must be made at the program level to evaluate compliance with appropriate NRC regulations concerning seismic adequacy.

The following infonnation is provided with the understanding that a generic resolution to the application of method A of Table 4-1 of reference 2 is being pursued b y SQUG and the NRC staff.

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a. The following structures have licensing-basis SSE floor response spectra (5 percent critical damping) for elevations lower than 40 feet above the effective grade, where the amplitude is greater than 1.5 times the GIP-2 Bounding Spectrum:

Auxiliary Building (effective grade is EL.155')

Mass Point Elevation Direction 3

121' N-S 4

139' N-S and E-W 5

155' N-S and E-W 6

175' N-S and E-W 7

175' N-S and E-W Contaimnent Internal Structure (effective grade is EL.130')

Mass Poinj Elevation Direction 4

140' N-S 5

149' N-S 6

155' N-S and E-W Containment Shell (effective grade is EL.155')

i Mass Point Elevation Direction 12 193' N-S and E-W

b. Attachment I provides plots of the licensing-basis SSE floor response spectra identified in item "a" above compared to 1.5 times the Bounding Spectrum.

c. Method A of Table 4-1 of reference 2 was typically used to address the seismic adequacy of equipment installed at elevations identified in item "a" above for the auxiliary building and the containment internal structure following the guidance of references I and 2. No SSEL equipment is located on the containment shell at EL.193' Columns 10 and 11 of the Screening Evaluation Data Sheets found in Attachment G of reference 3, identify the capacity spectrum and demand spectrum respectively that were used to compare equipment i

seismic capacity to demand for each item of equipment on the SSEL.

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Enclosure 2.

Question:

In Table 1 of Appendix C and Table 2 of Appendix D, one of the relay evaluation status codes is " WALK," which indicates that equipment is seismically adequate based on walkdown using Seismic Capacity Bounding Spectra. Provide a list of relays resolved by this method and describe specific details of how each relay was evaluated to be seismically adequate.

Response

Items identified with a status code of" WALK" are actually breakers located in MCCs and switchgear. As stated in reference 4, breakers are not considered to be relays in the scope of A-46 because they have not shown a vulnerability to chatter. These breakers are included in the database for tracking purposes only. The status code indicates that the MCC or switchgear housing the breaker has been screened as part of the seismic capability walkdown. Relays, contactors, auxiliary contacts, and any other contact devices that control or effect the operation of these breakers have been evaluated for contact chatter per reference 4. The list of breakers identified with this status code is included as Attachment 2.

3.

Question:

In your relay evaluation report, you have identified.six relays as outliers. Were there any other

" bad actor" relays installed in the plant safe shutdown path and identified during the relay evaluation? Describe the resolution for seismic adequacy of these relays.

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Response

In addition to the relays identified in section 3 of reference 3, GE PVD relays were also identified in the safe shutdown path. Shake table testing meeting the requirements ofIEEE 344-75, demonstrated that these relays are acceptable for use at Farley Nuclear Plant (FNP),

4.

Question:

Provide information concerning equipment that does not meet the specific wording of a caveat and was not identified as an outlier. Provide the following information in a tabular form for each of these equipment:

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Enclosure a.

Equipment description

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Caveat Numberin the GIP-2 c.

Description ofdeviation from the GIP-2 caveat d.

Justification for resolution

Response

See Attachment 3.

5.

Question:

Appendix K contains few cases of outliers where potential bolt bending concerns were resolved by analysis. Provide the detailed analyses with sketches or drawings for the following three Cases:

LC Transformer in Diesel Generator Building (Equipment ID QlRilB503-A) a.

b.

MCC 1K in Service Water intake (EQ ID QlR17B504-A) 125-V-dC Service Water Building Battery No.1 (EQ 10 QSR42BS23A-A) c.

Response

The following describes the analyses performed to resolve outliers related to bolt bending for

' the three cases identified in question 5:

a. LC Transformer in Diesel Generator Buildine (Eauipment ID: OIRI IB503-Ak The largest gap for this transformer was found to be only 0.35". In the attached Figure 1, Sketch 5-A shows the gap condition. This outlier was resolved by referring to an enveloping evaluation made on an identical transformer (Q2RIIB504-A) where a gap of one inch was found. The seismic demand and gap size for Q2RIIB504-A enveloped that of QIRIIB503-A.

Evaluation of the bolt perfonn.tnce followed the procedure for anchors with excessive gaps given in reference 5. Using this procedure, the maximum allowable shear load associated with bolt bending is calculated assuming a) failure of the bolt at the concrete surface and b) failure of the embedded portion of the bolt. Of course, it should be noted that the maximum applied axial load (demand) on the bolt is explicitly considered in the calculation of the allowable shear load. The lesser allowable shear load is then compared to the maximum shear loading or E-4

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Enclosure i

j demand on the bolt to verify that the allowable shear load is greater than the actual shear loading. Next, the shear-tension interaction on the bolt is checked per reference 2 using the maximum applied shear and axial loads, i.e., the maximum demand, and the allowables Va &

Pa as defined in the GIP. 'Ihese evaluations showed the anchorage for the transformer to be acceptable.

b. MCC IK in Service Water Intake (Eauipment ID: OIR17B504-A):

i Sketch 5-B of Figure I shows the base channel of the MCC at the corner that is shimmed due to the sloping floor surface. Ifit is conservatively assumed that the ends of the channel legs that are in contact with the shims and the floor surface offer no resistance to shear loads or lateral deflection at the base, then the shear loads would produce bendmg in the anchor bolts. Using this conservative assumption, the worst gap identified is approximately two inches, which includes the height of the base channel plus the gap height. Evaluation of the bolt performance followed the procedure for anchors with excessive gaps given in reference 5. A discussion of

' these evaluation procedures is provided in response Sa above. These evaluations showed the anchorage for the MCC to be acceptable.

c.125-V-de Senice Water Buildine Batterv No.1 (Eauioment ID: OSR42B523A-A):

Sketch 5-C of Figure I shows the largest gap found for this battery rack which is only about 0.4". This battery rack is a low height, two tier battery rack with 16 - 1/2" diameter Phillips Red Head anchors approximately 5-1/2long. The maximum shear load on a bolt is only about j

50 lb. and the maximum tensile load is less than 10 lb. due to the low aspect ratio of these

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racks. "he extremely low resulting bending moment, and very low stresses / loads in the bolts, j

was the basis for determining that the anchorage is adequate.

The evaluations described above, as well as EPRI Report TR-103960 (reference 5), are available for review at the SNC offices in Birmingham, AL.-

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Question

l Referring to Section 4.2.2, provide a detailed discussion of the methodology and assumptions used for the generation of the new in-structure response spectra (IRS) for equipment loc red in the diesel generator building and the service water intake structure and the new ground response spectra (GRS) at elevation 155 feet. Indicate if the new methodology and the assumptions adopted comply fully with those of the FNP Unit 1 FSAR.

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Response

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He development of the new IRS for the diesel generator building (DGB) and service water intake structure (SWIS) follows the guidance given in the current Standard Review Plan l

(NUREG-0800, Rev. 2, 9/89) using the Farley SSE spectral shape and horizontal peak ground acceleration (pga) of 0.lg.

i New In-Structure Response Spectra Generation Per Standard Review Plan (SRPh 1

The substructure approach of performing soil-structure interaction (SSI) analysis of structures j

was applied to the DGB and SWIS at FNP. His approach separates the SSI problem into a series of simpler problems, solves each independently, and superposes the results. The elements 1

of the substructure approach are:

Specifying the free field ground motion and defining the soil profile.

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l Calculating the foundation impedances and wave scattering functions.

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Modeling the structure. The stmetural models were based on the Farley original building i

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Performing the SSI analysis, i.e., combining the previous steps to calculate the response of e

j the coupled soil-structure system.

l This substructure procedure is implemented in the CLASSI family of computer programs, and is identified in the SRP as an acceptable method. Here are however, specific recommendations in the SRP for performing SSI analysis, the key aspects of which are summarized in the l

following paragraphs. In addition to the SRP, guidance on major aspects of SSI analysis in l

ASCE 4-86 were followed.

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The substructure procedure is linear elastic. Nonlinear soil material behavior can be considered i

in an equivalent linear fashion. He soil model does include the layering characteristics of the i

site as well as the " primary nonlir earities" associated with the seismic induced strain. Low i

strain soil properties as a function of depth were derived from detailed site investigation reports i

as defined in the FSAR, and degraded soil properties compatible with the seismic induced strain level were computed using the computer program SHAKE. Uncertainty in the determination of soil properties are bounded by varying the low strain shear moduli within the range of 0.5 times to 2.0 times the best estimate values.

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Enclosure Per the SRP, the control point should be specified either on the free surface at grade or, in the case of poor top soil, on an imaginary outcrop of a competent layer. In the original FSAR analysis of caisson supported structures at Farley, the SSE was applied at the lower bearmg end of the caisson. For the current analysis, the control point was specified on a hypothetical outcrop, the Compact Overburden layer that exists at 24.5 feet below grade at the main plant area. At the outlying service water intake area, the soil profile differs from the main plant area.

There, the control point was specified on an imaginary outcrop of the Lisbon formation 85 feet below grade. The frequency content of the control motion was defined by the Farley SSE.

For embedded structures, the SRP recognizes the wave scattering phenomenon, but limits reduction in foundation input motion to 60% of the control motion at grade. Also, increased foundation rocking due to wave scattering effects should be included. He full effects of radiation damping in the soil may be utilized provided soil layering effects and frequency dependency of the foundation impedances are incorporated in the andy:is. If side soil is accounted for in the impedance calculation, the potential for redcaxi lateral support should be considered. ASCE 4-86 suggests debonding the top 20 feet of soil, or half the embednent, whichever is less. This consideration was applied to the embedded SWIS foundation.

To bound the uncertainty in determining soil properties, three sets of high strain soil properties consistent with the SSE excitation level were developed. These three soil profiles were then used to develop SSI parameters. Three analyses were then performed using the lower bound, best estimate, and upper bound SSI parameters. Structural properties remained unchanged for all three analyses. The IRS from the three analyses were then enveloped and peak broadened by 10% to yield the "conser ative design" SRP spectra.

Site Response and Development of New Ground Resnonse Spectra at Elevation 155' Feet:

i The substructure approach to SSI is a linear elastic method. However, the force-deformation, as well as hysteretic damping characteristics of soil, is a function of strain level, i.e., shear modulus decreases, and damping increases with strain. The nonlinear soil behavior was treated in an equivalent linear manner by the use of soil properties compatible with the effective seismic induced strain in the soil. The computation ofstrain compatible properties was performed in an iterative linear fashion u;ing the computer program SHAKE. He methodu.gy in SHAKE models the soil as a horizontally layered linear viscoelastic medium. By further assuming vertically incident shear, the problem reduces to a one-dimensional case.

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s-Enclosure herefore, a soil column may be used to represent a given site for the purpose of performing one <limensional wave propagation analysis. De input to SHAKE comprise:

Low strain soil properties.

The soil shear modulus versus stram, and damping versus strain relationship. For the cohesionless soil type reported in the FSAR for this site, the mean degradation curves for sand are applicable.

He horizontal component of ground motion. The ground motion is the horizontal artificial time history matched to the Farley SSE.

Specification of control point location.

SHAKE performs iterative linear analyses to converge on strain compatible soil properties.

The use of strain compatible properties accounts for the primary nonlinearities in the soil under seismic induced strain. These properties are used later in calculating foundation impedances.

In addition to defining the strain compatible soil properties, the SHAKE analysis also yields motion at various depths of the soil profile, including motion on top of the soil column. De motions at the plant grade of elevation 155 from the SHAKE analysis were used to derme the ground response spectra for the surface mounted tanks located in the plant yard for the IPEEE evaluation.

In the SRP approach, the uncertainty in determining soil properties is bounded by considering three sets oflow strain soil properties. The lower bound property set is obtained by factoring the best estimate low strain shear moduli by 0.5. He upper bound shear moduli are taken at twice the best estimate values. Each of these property sets is iterated upon using SHAKE to derive the corresponding high strain values.

. The subsurface conditions within the main plant area where the DGB is located, and the outlying service water intake area, are sufficiently different to warrant separate treatment.

Methodolony for New IRS and GRS for Tanks in Plant Yard Comoared to Farlev FSAR:

i The development of the new IRS for the DGB and SWIS follows the guidance given in the current Standard Review Plan (NUREG-0800, Rev. 2,9/89) using the Farley SSE spectral j

shape and horizontal peak ground acceleration (pga) of 0.lg.

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- Enclosure As stated in reference 3, these new IRS are judged to be " conservative design" IRS due to the fact that the SSI analyses, and the calculation of the new IRS, were performed following the latest revision of the SRP; however, for additional conservatism in the A-46 and IPEEE -

evaluations they were treated as " realistic, median-centered" IRS. The Farley FSAR discussion of the development of the original IRS describes analysis techniques commonly used in the early to mid '70's. He original SSI analyses are based on the theory of a rigid base resting on an elastic half-space using a single soil shear wave velocity. Using this SSI analysis approach, the FSAR limited soil damping to 7 percent. The SSE for these analyses was always placed at the foundation level of the building even though the FSAR does not define the motion at those locations but at the ground surface which is plant grade.

New ground response spectra as descrilxxi above for the surface mounted tanks in the plant yard was developed specifically to meet SNC commitments as a result of the FNP IPEEE response to NRC GL 88-20 Supplement 4 as documented in SNC letter to the NRC dated September 14,1992.

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Question:

Referring to Section 4.2.4.4, provide an example of the calculation for determining the seismic capacity of key cable and conduit raceways. Was the weight of cable insulating materials (e.g.,

thermo-lag material) included in the raceway seismic demand determination? If yes, discuss the manner in which the weight was accounted for in the evaluation, and if not, explain the basis for the weight exclusion.

Response

The seismic capacity of the cable and conduit raceways evaluated in the SQUG limited analytical review (LAR) was determined by following section 8.3 of reference 2. A generic cable tray weight of 50 lbift. was used for the evaluations that enveloped the worst case loading determined by adding the weight of the cables as taken from the FNP raceway loading report, the weight of the tray and cover, and the weight of any fire wrap material. Conduit weights were taken from section 8.3.9 of reference 2 plus the weight of any fire wrap material.

The LAR evaluations are available for review at the SNC offices in Birmingham, AL.

8.

Question:

With respect to Appendices I and J of the summary report, please provide the engineering calculations that support the resolution of the two outliers identified with Drawing Nos. D-172203 and D-177920 listed in Appendix I and the three outliers listed in Appendix J, which are associated with Drawing Nos. D-177930, D-177920, and D-207921.

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Response

Limited Analytical Review (LAR) selection number FNPCS8 (the LAR selection number is a unique number assigned to each LAR sample) from drawing D-172203 in the diesel generator building, is a cantilevered support suspended from the ceiling. De support is anchored with four 3/4" diameter cast-in-place J-bolts. He support was analyzed per section 8.3 of reference

2. The evaluation revealed that the anchorage capacity did not meet the GlP criteria when using the generic cable tray weight of 50 lb./ft. for the lateral load check herefore, the analysis was performed again using a lower generic weight that enveloped the actual cable tray weights for this support. The lower generic weight was possible because the trays in the diesel generator building are relatively light with no fire wrap material. He revised analysis was successful in demonstrating the adequacy of the support for A-46. No additional LAR samples were selected since FNPCS8 was still the enveloping support for the diesel generator building.

LAR selection number FNPCSIO from drawing D-177920 at elevation 155' in the auxiliary building, consists of a main tube steel column suspended from the ceiling and braced laterally by horizontal members that are connected to adjacent supports. The top of the main column is welded to a steel beam that is welded to embedded steel plates in the ceiling..ne evaluation revealed that the welds to the embedded plates were over stressed due to the dead load noment.

This condition was resolved by installing additional support members to provide adequate lateral and vertical bracing to reduce the moment at the embedded plate weld. Following this modification the support meets the GIP criteria.

The outlier listed in Appendix J of reference 3 for drawing D-177930 is LAR selection number FNPCSIS located at elevation 139' in the auxiliary building. This support consists of a single tube steel arm cantilevered from the wall supporting 4 conduits. The support is anchored with two 3/8" diameter expansion anchors. De evaluation revealed that the anchor bolts did not meet the GIP criteria due to dead load moment. His outlier was resolved by evaluating the adjacent supports for the additional load assuming failure of FNPCSIS. The adjacent supports, as well as the conduit spans, were found to be acceptable for the additional load. His support was a unique case and was not used as an enveloping case for other supports.

The outlier listed in Appendix J ( ' rference 3 for drawing D-177920 is the same as LAR selection number FNPCS10 which.s described above.

The outlier listed in Appendix J of reference 3 for drawing D-207921 is LAR selection number FNPCSI1 located at elevation 155' in the auxiliary building. This selection is an embedded steel plate in the ceiling with two supports attached to it. He 8" x 3/4" x 4*-0" plate is anchored to the ceiling with eight 3/4" diameter Nelson studs.

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4 Enclosure The Q-Decking was cut out around the plate prior to pouring the concrete slab to allow the plate to be installed flush with the ceiling rather than spanning the ribs of the Q-Decking.

FNPCS 1 I was chosen as an enveloping case for other embedded plates in the plant. The evaluation demonstrated that the embedded plate meets the GIP criteria. The cable and conduit raceway evaluations were performed as described in the response to RAI question 7. De evaluations described above are available for review at the SNC offices in Birmingham, AL.

9.

Question:

Review of Appendix K shows several repeating types of outlier descriptions including: potential interaction from overhead light, adjacent panels and walls or hoist chain; inadequate anchorage and load path or bolt bending concern; and unconnected bays and panels or gaps under panels.

Provide representative examples ofengineering documentation that support the resolution of the above mentioned outlier categories.

Response

All of the equipment outliers listed in Appendix K, with the exception of the potential bolt bending concerns which were resolved analytically, were resolved by a plant modification.

Rese modifications were performed using the FNP design change process or a maintenance work order which is used to restore a component to its original design configuration. The following sumniary describes each outlier resolution in more detail. The evaluations described below are available for review at the SNC offices in Birmingham, AL.

Potential interaction from overhead lieht: Fluorescent light fixtures throughout the plant were identified by the seismic review teams (SRTs) for their potential to fall during an earthquake. This outlier was resolved by restraining the fixture with tie wire to prevent

falling,

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Panels not bolted together: A number of panels containing essential relays were noted as e

being vulnerable to potential impact from adjacent panels. This outlier was resolved by bolting the adjacent panels together to prevent impact.

Other cotential interaction concerns: Other potential interaction concems were identified with nearby items such as the diesel generator building hoist crane, platforms, ladders, etc. These items were all restrained or secured to prevent impact to the SSEL equipment.

Inadeauate anchorane and/or load oath: All equipment determined to have inadequate anchorage and/or load path was modified to increase the anchorage capacity of the equipment.

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Potential bolt bending concern: Several equipment items had a gap of greater than 1/4" j-under the base. This condition violates the GIP caveat which limits the gap to less than i:

1/4" for bolted anchorages. An analysis of the anchor bolts showed that the bolt bending was less than allowed following the procedures in reference 5. Therefore, the bolts are i

adequate for A-46.

hl Gan under panel: Two equipment items were identified with the outlier description " gap l

under panel". Rese are actually the same as the " potential bolt bending concerns" j

described above. Dese were also evaluated and shown to be acceptable for bolt.

bending. Because such a large portion of the panel base was not in contact with the floor, grout was added under the panel to provide even distribution of the panel load on the floor, i

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Question:

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4 With respect to Appendix G, some heat exchangers and tanks (e.g., condensate storage tank l

I (QlP1ITOOl) and regenerative heat exchanger (QlE21H0943) with "NA" designations under l

Columns 10,11,12, and 13] arejudged as "OK" under Column 16. Discuss the rationale for i

their acceptance and provide pertinent documentation.

Response.

The regenerative heat exchanger (Q1E21H002) was evaluated under the equipment class

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"other" because its d:: sign did not fit the " tanks and heat exchanger" equipment class. The heat exchanger consists of three horizontal shells. The 9 5/8" OD x 13'- 4 3/8"long shells are bolted to the wall and connected to each other by 3" OD piping. The Seismic Review Team (SRT) used a combination of engineeringjudgment and calculations to screen out the heat exchanger. The Screening Evaluation Work Sheet (SEWS) for the "other" equipment class only asks the following 4 questions; 1) Seismic capacity vs. demand,2) Anchorage,3)

Interaction effects, and 4) Is equipment seismically adequate? Dese questions were all i

answered affirmatively on the SEWS. Other items such as " capacity spectrum", " demand spectrum, and " caveats" are not included on the SEWS and are therefore "NA". Column 12,

'" capacity > demand", could have been designated "Y"; however, it was designated "NA" because it is not supported with the same questions such as " capacity spectrum", " demand spectrum", and "<40'" that are typical for most of the equipment classes.

He condensate storage tank (QlP1IT001) was evaluated under the " tanks and heat exchanger" equipment class. He SEWS for this class do not include questions for items such as capacity spectrum, demand spectrum, and caveats and are therefore "NA" He tank evaluation was based on section 7 of reference 2.

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Enclosure Based on these calculations and the seismic capability walkdown, it was determined that the tank shell capacity exceeds demand and that all other aspects of the tank, anchorage, attached piping, and the foundation are adequate for A-46.

11.

Question:

Referring to Appendix G, provide a copy of the engineering calculations justifying the acceptability of refueling water storage tank (QIF16T0501).

Response

ne refueling water storage tank (QIF16T0501) is a 500,000 gallon flat-bottom vertical water storage tank located at plant grade, elevation 154.5 feet. The tank is 46 feet in diameter and 41 fxt in height with a dome roof. He tank is anchored to a four foot thick mat foundation at grade. The original seismic analysis used the Farley OBE and SSE ground response spectra with the horizontal pga of 0.05 g and 0.10 g respectively as the seismic design input motion.

For the A-46 and IPEEE evaluation of this tank, a new ground motion at plant grade was calculated. This motion was calculated based on the Farley SSE ground motion being defined at a hypothetical outcrop of the Compact Overburden layer that exists at 24.5 feet below grade.

The compact oventurden has a low strain shear wave velocity of 2520 fps. A plot of the new ground response spectra at plant grade, elevation 154.5, is provided in Appendix F of reference

3. The development of this new ground response spectra is discussed as part of the response to question 6. As previously stated in the response to question 6, new ground response spectra for the surface mounted tanks in the plant yard was developed specifically to meet SNC commitments as a result of the FNP IPEEE response to NRC GL 88-20 Supplement 4 as documented in SNC letter to the NRC dated September 14,1992.

The GIP guidelines on vertical tanks (section 7 of reference 2) was initially used to evaluate the refueling water storage tank with the new GRS. This evaluation was successful except for a slight exceedance ofless than 5 % when comparing overturning moment capacity to the overturning moment. Tank shell capacity was the limiting condition. The GlP evaluation is considered conservative, e.g., maximum peak spectral acceleration was used by assuming the tank's impulsive mode frequency coincides with the peak spectral acceleration of the new GRS.

To provide further assurance of the seismic adequacy of this tank, the refueling water storage tank was also evaluated using the seismic margin methodology following Appendix H, ". lat-Bottom Vertical Fluid Storage Tanks, of reference 6. The seismic capacity was found to exceed the seismic demand of the new ground spectra by a margin of 1.5. Therefore, the resulting high-confidence-of-low-probability-of-failure (HCLPF) value when the Farley SSE GRS is specified at the hypothetical outcrop of the Compact Overburden is 0.15 g.

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- Enclosure De margin of 1.5 is also considered sufficiently high to satisfy not only screening out the I

refueling water storage tank for IPEEE but also for resolution of USI A-46. The tank j -

evaluation described above is available for review at the SNC offices i 2 Birmingham, AL.

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Question:

Referring to Appendix G, discuss the basis for acceptmg fuel Storage Tank IB (QlY52T502) i with "NA" designations under Columns 10 through 14.

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Response

1 rl' The fuel storage tank IB (QlYS2T502) is a 40,000 gallon buried tank. The SRT performed a review of the tank drawings along with an existing FNP seismic evaluation report in order to screen out the tank. Since this is a buried tank, items such as capacity spectrum, demand j

spectrum, caveats, and anchorage are "NA" a

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Question:

1 4

j Page 27 of Appendix G lists several senice water intake louvers with "NA" designations under Columns 10, i1, and 13. Discuss the method used for determining the seismic capacity of these louvers and the basis for their acceptance as designated in Column 16, i

4 j

Response

)

The senice water intake louvers consist of Honeywell D640A Moduflow dampers with

' Honeywell M445 spring return Modutrol motors. The louvers are mounted in the IWAC duct.

l The duct is well supported at the location of the louvers to support the additional weight of the -

i louvers on the duct and prevent distortion of the duct and louver. The louver frame is blocked i

into the ductwork plenum area which will prevent any significant movement. Here is also sufficient clearance provided to enable the louvers to operate during a seismic event. Dese details were judged by the SRT to provide sufficient stability and support for the operation of.

the louvers.

i 14 Question:

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Provide a copy of References 8 and 10 listed on Page R-1.

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9 Enclosure

Response

Reference 8 contains the soil-structure interaction analysis of the diesel generator building and the service water intake structure, and the development of the ground response spectra at elevation 155 feet for the IPEEE evaluation of surface supported tanks in the plant yard. A detailed discussion of the methodology and assumptions used is prosided in the response to question 6. These analyses are available for review at the SNC omces in Birmingham Reference 10 is the computer code "SIIAKE." He methodology and assumptions associated with the SHAKE computer program are also discussed as part of the response to question 6.

EQE International, who performed these analyses, can provide additional information about this computer program if required.

15.

Question:

Referring to the third party audit work reported in Appendix L, provide a copy of each of the four files identified in Mr. John W. Reed's letter to Mr. Keith D. Wooten, dated January 20, 1994.

Response

He four files described in Mr. Reed's letter are sununarized below. These evaluations are available for review at the SNC oflices in Birmingham, AL.

Motor operated valve QIEl IMOV8888B-B is located on elevation 121' in the auxiliary building. The valve size is 10" diameter with a Limitorque SB4-150 motor operator. The SRT screened out the valve based on their walkdown and a stress analysis performed by Westinghonse. The stress analysis ensured that the valve was adequate for a 3 g horizontal seismic load applied at the center of gravity of the valve operator.

Diesel generator panel 1B CT JB (QlR43G510-B) is located on elevation 155' in the diesel generator building. The panel is 151/2" x 42" x 30" high and is anchored to the concrete floor by four 3/8" diameter expansion anchors. The SRT screened out the panel based on their walkdown and analysis of the base anchorage.

The diesel generator 1B local control panel (QlH21E527-B) is located on elevation 155' in the diesel generator building. The panel is 35" x 161" x 90" high and is anchored to the concrete floor by 5/8" diameter cast-in-place J-bolts. An analysis of the panel anchorage demonstrated that it did not meet the GIP criteria. Additional anchorage was installed to increase the capacity E-15

i i

1 Enclosure j

a to an acceptable level. The SRT also identified an overhead light fixture that could potentially j

1 i

impact the panel during a seismic event. De light fixture was restrained to prevent it from falling. All other aspects of the panel were found to be acceptable by the SRT during the l

'walkdown.

i

{

The 600V load center IR/2R (Q1R16B508-A) is located on elevation 155' in the diesel l

generator building. The load center is 60" x 84" x 91" high. He as-found anchorage consisted j

of minimal welds on only one side of the load center. An analysis of the panel anchorage demonstrated that it did not meet the GIP criteria. Additional anchorage was installeho l

increase the capacity to an acceptable level. The SRT also identified an overhead light fixture that could potentially impact the load center during a seismic event. De light fixture was 4

restrained to prevent it from falling. All other aspects of the load center were found to be 1

. acceptable by the SRT during the walkdown.

l 4

i 4

References:

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1. " Supplement Safety Evaluation' Report No. 2 on Seismic Qualification Utility Group's j

]

Generic Implementation Procedure, Revision 2, Corrected February 14,1992 for _

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Implementation of GL 87-02 (USI A-46), Verification of Seismic Adequacy of Equipment in

(

Older Operating Nuclear Plants," NRC, May 22,1992.

1 l

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2. " Generic Implementation Procedure for Seismic Verification ofNuclear Plant Equipment,"

Revision 2, Seismic Qualification Utility Group, February 14,1992.

?

3. " Unresolved Safety Issue A-46 Summary Report, Joseph M. Farley Nuclear Plant, Unit 1,"

Southern Nuclear Operating Company submitted to NRC on May 18,1995.

i

4. " Procedure for Evaluating Nuclear Power Plant Relay Seismic Functionality," Final Report.

1 EPRI NP-7148-SL, Electric Power Research Institute, Palo Alto, CA, December 1990.

5. " Recommended Approaches for Resolving Anchorage Outliers," EPRI TR-10M60, Electric y

Power Research Institute, Palo Alto, CA, June 1994.

6. "A Methodology for Assessment of Nuclear Power Plant Seismic Margin, (Revision 1)",

EPRI NP-6041 SL, Electric Power Research Institute, Palo Alto, CA, August 1991.

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ATTACHMENT 2

r ATTACHMENT 2 FARLEY A-46 RAI RESPONSE-QUESTION 2 Unit 1 Essential Relays With Resolution Method = " WALK" SSEL REFERENCE RELAY RELAY RELAY RESOLUTION COMPONENT DRAWING ID NO.

VENDOR MODEL NO.

METHOD PANEL ID NO. Q1C11E004A AB QlCl)E004A-AD D-177198/2 52/RTA WESTINGHOUSE DS416 WALK Q1CllE004A-AB D-177198/2 52/R113 WESTINGIIOUSE DS416 WALK PANEL ID NO. QlC11E0048-AB QlCllE004B-AB D-177198/2 52/BYB WESTINGilOUSE DS416 WALK QlCllE0048-AB D 177198/2 52/BYA WESTINGliOUSE DS416 WALK PANEL ID NO. QlR15A006-A QlPl7P001C-A D-177183 52 DF04 AC MA-350 WALK QlE21P002A-A D-177180/1 52 DF06 AC MA-350 WALK Q1Rl5A006-A D-177155 52 DF01 AC MA-350 WALK QiR15A006-A D-177161 52 DF15 AC MA-350 WALK Q1R15A505-A C-177144 52 DF02 AC MA-350 WALK QlR15A503-A D-177145 52 DFl3 AC MA-350 WALK QlRI1B004-A C-177159 52 DF03 AC MA-350 WALK QlEliP001 A-A D-177193 52 DF09 AC MA-350 WALK QSR43A501-A D-177143 52 DF08 AC MA-350 WALK PANEL ID NO. QlR15A007-B Q1El1P001B-B D-177193 52 DG09 AC MA-350 WALK Q1E21P002C-B D-177180/2 52 DG06 AC MA-350 WALK QlP!7P001A-B D-177184 52 DG04 AC MA-350 WALK QlR15A506-B C-177144 52 DG02 AC MA-350 WALK QlRilB005-B C-177159 52 DG03 AC MA-350 WALK Q1R15A007-B D-177168 52 DG01 AC MA-350 WALK Q1R15A504-B D-177167 52 DGl3 AC MA-350 WALK QlR43A502-B D-177142 52 DG08 AC MA-350 WALK QlR15A007-B D-177169 52 DGl5 AC MA-350 WALK PANEL ID NO. QlR15A503-A QlR11B503-A C-172762 52 DI108 AC MA-350 WALK QSR43A503-A D-172761 52 Dil07 AC MA-350 WALK QlR15A503-A C-172795 52 DIl01 AC MA-350 WALK PANEL ID NO. Q1R15A504-B Q1R15A544-B D-172763 52 DJ06 AC MA-350 WALK QlR15A504-B D-172869 52 DJO2 AC MA-350 WALK QlR15A504-B D-172764 52 DJ01 AC MA-350 WALK Q1R15A504-B D-172764 52 DJ07 AC MA-350 WALK PANEL ID NO. Q1R15A505-A QlP16P001B-A D-172748 52 DK04 AC MA-350 WALK QlRllB504-A C-172765 52 DK02 AC MA-350 WALK Q1P16P001A-A D-172747 52 DK03 AC MA-350 WALK PANEL ID NO. QlR15A506-B QlP16P001D-B D-172751 52 DLO3 AC MA-350 WALK QlP16P001E-B D-172752 52 DLO4 AC MA-350 WALK QlR1IB505-B C-172766 52 DLO2 AC MA-350 WALK

" " " ^ " "

Page!

O b

t k

e ATTACIIMENT 2 1

FARLEY A-46 RAI RESPONSE-QUESTION 2 Unit 1 Essential Relays With Resolution Method = " WALK" a

SSEL REFERENCE RELAY RELAY RELAY RESOLUTION j

COMPONENT DRAWING ID NO.

VENDOR MODEL NO.

METHOD PA.NEL ID NO. Q1R16B006-A QlR42E001 A-A.

C-177077 52 ED04 WESTINGiiOUSE DS2%

WALK QlR16B006-A D-177064 52 ED08 WESTINGIlOUSE DS416 WALK Q1R16B006-A D-177074 52 ED02 WESTINGlIOUSE DS416 WALK Q1R17B001-A D-177089/1 52 ED10 WESTINGIIOUSE DS206 WALK QlR17B509-A D-177089/2 52 EDl3 WESTINGilOUSE DS206 WALK QlR17B008-A D-177089/1 52 EDl4 WESTINGilOUSE DS206 WALK QSR17B006-A D 177089/1 52 ED05 WES11NGHOUSE DS206 WALK PANEL ID NO. QlR16B007-B l

QlR42E0018-B C-177077 52 EE05 WESTINGilOUSE DS206 WALK QlR16B007-B D-177070 52 EE07 WESTINGHOUSE DS416 WALK QlR17B002-B D-177089/1 52 EE10 WESTINGHOUSE DS206 WALK j

QlR16B007-B D-177074 52 EE02 WESTINGIIOUSE DS416 WALK QlR17B009-B D-177089/1 52 EEIS WESTINGHOUSE DS206 WALK QlR17B510-B D-177089/1 52 eel 4 WESTINGIIOUSE DS206 WALK QSR17B007-B D-177089/1 52 EElI WESTINGHOUSE DS206 WALK PANEL ID NO. QIR16B506-A QlR17B504-A D-172826/2 52 EK03 WESTINGIIOUSE DS206 WALK QlR16B506-A D-172826/2 52 EK05 WESTINGHOUSE DS206 WALK QlR16B506-A D-172825/2 52 EK02 WESTINGHOUSE DS206 WALK PANEL ID NO. Q1R16B507-B QlR17B505-B D-172826/2 52 EID9 WESTINGHOUSE DS2%

WALK QlR16B507-B D-172826/2 52 ELOS WESTINGiiOUSE DS206 WALK QlR16B507-B D-172825/2 52 ELO2 WESTINGiiOUSE DS206 WALK PANEL ID NO. Q1R16B508-A QlR17B507-A C-172832 52 ER03 WESTINGilOUSE DS206 WALK j

QlR16B508-A D-172831/2 52 ER02 WESTINGHOUSE DS206 WALK PANEL ID NO. Q1R16B509-B QlR16B509-B D-172831/1 52 ES02 WESTINGIIOUSE DS206 WALK QlR17B508-B C-172832 52 ES03 WESTINGIIOUSE DS206 WALK PANEL ID NO. Q1R17B001-A QlP18C002A-A D-177793 52 ITE lE3 WALK PANEL ID NO. Q1R17B002-B QlP18C002B-B D-177793 52 ITE IE3 WALK PANEL ID NO. QSR17B006-A QSV49K001A-A D-177270/3 52 ITE JE3 WALK PANEL ID NO. QSR17B007-B QSV49K001B-B D-177270/3 52 ffE lE3 WALK i

Page 2 FIRELAYAPR l

O a

i l

1 1

4 ATTACHMENT 3 i

. +

i ATTACllMENT 3

^'

FARLEY A-46 RAI RESPONSE - QUESTION 4 Equipment Meeting the Intent of a Caveat Without Meeting the Specific Wording ID #f

> EquipmentJ Caveat #g

Description'off

? Justification forf s

1 Description 1

!Cavestl l Resolution?

i N1P18PCV2885A Pressure Control 4

Valve mounted on 1" dia. pipe 3/4" pipe but valve is very light i

Valve or larger andjudged adequate by SRT N1P18PCV2885B Pressure Control 4

Valve mounted on 1" dia. pipe 3/4" pipe but valve is very light Valve or larger andjudged adequate by SRT N1P18PCV2885C Pressure Control 4

Valve mounted on 1" dia. pipe 3/4" pipe but valve is very light Valve or larger andjudged adequate by SRT Q1ElIFCV0602A-A RilR pump mini flow 6

Actuator & yoke not braced Pipe well supported adjacent to valve independently from pipe valve. Pipe & valve support are attached to the same wall; therefore, the valve & pipe will i

move together.

QlF16T0501 Refueling water NA Shell capacity vs. demand The tank was evaluated using the storage tank Seismic Margin Assessment methodology as described in EPRI NP-6041. The resulting high-confidence-low-probability-of-failure (IICLPF) of 0.15 g pga provides a margin of 1.5 over the SSE pga of 0.10 g. Therefore, the intent of the caveat is met.

QllIlINGCCM2523A-A ICCMS processor 2

No computers of programmable Microprocessor in panelis l

mbinet train B controllers seismically qualified.

Q1HIINGCCM2523B-B ICCMS processor 2

No computers of programmable Microprocessor in panelis cabinet train B controllers seismically qualified.

Q1HIINGR25041-AB Radiation monitor 3

No strip chart recorders SRTjudged strip chart recorders panel adequately restrained.

Q1P15HV3103-A Pressurizer liquid 7

Actuator & yoke not braced Pipe and valve are supported sample line isolation independently from pipe independently; however, they 1

CMT.ATS tX1C

E ATTACIIMENT 3

~

., i FARLEY A-46 RAI RESPONSE - QUESTION 4 Equipment Meeting the Intent of a Caveat Without Meeting the Specific Wording

ID # 1 E

7 quipmentt 1Cavent #.

. Description of.9 (Justification for:3 L Description 4

- Caveat ::

Resolatio~ is n

valve will move together since they are both supported from the same point.

Valve support will prevent 4

Valve mounted on 1" dia. pipe imposing excess stress on the or larger piping.

Q1P15IIV3105-B RIIR heat exchanger 7

Actuator & yoke not braced Pipe and valve are supported A sample valve independently from pipe independently; however, they will move together since they are both supported from the same point.

Valve support will prevent 4

Valve mounted on 1"dia. pipe imposing excess stress on the or larger piping.

QlP1511V3106-B RIIR heat exchanger 7

Actuator & yoke not braced Pipe and valve are supported B sample valve independently from pipe independently; however, they will move together since they are both supported from the same point.

Valve support will prevent 4

Valve mounted on 1" dia. pipe imposing excess stress on the or larger piping.

Q1P1511V3332-B Pressurizer sample 4

Valve mounted on 1" dia. pipe Valve support will prevent valve orlarger imposing excess stress on the piping.

l 7

Actuator & yoke not braced Pipe and valve are supported independently from pipe independently; however, they will move together since they are i

2 CAVEATSDOC

.+

. o.

ATTACllMENT 3 3

FARLEY A-46 RAI RESPONSE - QUESTION 4 Equipment Meeting the Intent of a Caveat Without Meeting the Specific Wording LID #;

? Equipmente l Caveat #;

? Description'ofs

? Justification for Description 5 sCaveat2

?Resolutioni both supported from the same point.

QlP1511V3333-B RCS hot leg sample 7

Actuator & yoke not braced Pipe and valve are supported line is 'ation valve independently from pipe independently; however, they will move together since they are both supported from the same point.

Valve support will prevent 4

Valve mounted on 1"dia. pipe imposing excess stress on the or larger piping.

Q1P1511V3765-A RCS sample valve 7

Actuator & yoke not braced Pipe and valve are supported independently from pipe independently; however, they will move together since they are both supported from the same point.

Valve support will prevent 4

Valve mounted on 1" dia. pipe imposing excess stress on the or larger piping.

Q1P16FV3009A-B CCW heat exchanger 7

Actuator & yoke not braced Tubing to valve components service water independently from pipe have adequate flexibility, SRT discharge judges that no damaging differential movement will occur.

Q1P16FV3009C-A CCW heat exchanger 7

Actuator & yoke not braced Tubing to valve components service water independently from pipe have adequate flexibility, SRT discharge valve judges that no damaging differential movement will occur.

QlP16P001A-A Service water pump 2

Casing and impeller shaft not Lateral seismic restraint located 1A cantilevered more than 20 ft, 38 ft. Below pump. This will 3

CAVEATS DOC

.o

\\

ATTACHMENT 3 FARLEY A-46 RAI RESPONSE-QUESTION 4 Equipment Meeting the Intent of a Caveat Without Meeting the Specific Wording ID #3 y

!! Equipuneet; iCavest #;

iDescription oft 3 JustiGestion for y,

L a

? En-@di iCavesti FResolutioni -

independently from pipe proximity; therefore, differential displacement between pipe and valve will not occur.

QIP19HV2228-B Pressurizer PORV 4

Valve mounted on 1" dia. pipe Lateral support on operator will back-up air supply orlarger prevent the valve from imposing valve excess stress in the 3/4" pipe.

Valve and pipe supports attached 7

Actuator & yoke not braced t( the floor in close proximity; independently from pipe therefore, differential displacement between pipe and valve will not occur.

Q1R36A511B 4,16KV switchgear Anchorage For bolted anchorages, gap Dolt bending stress OK per SRT IL surge arrestor caveat 6 under base less than 1/4" calculation; therefore, the intent of the caveat is met.

f 5

CAVEAT 5 DOC

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..

ML20134F449

Contents

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ML20134F449

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Enclosure:

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

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