ML20147D742
| ML20147D742 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/02/1988 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8803040129 | |
| Download: ML20147D742 (14) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 105B Lookout Place MAR 21988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos.
50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - INTEGRAT8ID DESIGN INSPECTION (IDI) - NRC INSPECTION REPORT 50-327/87 t.8 AND 50-328/87-48 provides T/A's revised response to IDI item D3.6-1.
provides a list of couaitments being made by TVA in this submittal. It is our understanding that the revised response provided herein completes TVA's actions on this' item for unit 2 restart.
If you have any questlans, pleaso telephone D. L. Williams at (615) 632 1170.
Very truly yours, TENNESSEE VALLEY AUTHORITY M. J. RYy, Deputy rector Nuclear Licensing and Regulatory Affairs Enclosures cc:
See page 2 8803040129 880302 I
PDR ADOCK 05000327 O
DCD g g An Equal Opportunity Employer
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- U.S. Nuclear Regulatory Commission hdfdk 2]hhh-Enclosures
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.Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects 'Jivision U.S. Nuclear Regulatory-Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. C. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Piko Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 m
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,s ENCLOSURE 1 SEQUOYAH NUCLEAR PLANT REVISED RESPONSE TO IDI ITEM D3.6-1 ITEM NO:
D3.6-1 TITLE: Design Review for ERCW Equipment, Review of Vendor Component Qualification Documentation
SUMMARY
OF ITEM:
Some vendor seismic component qualification reports appear to violate quality assurance provisions of the contract in that no evidence of a design review could be found. The preparer and checker were not identified in the qualification report.
In section 3.4 of the integrated design inspection (IDI) report issued November 6, 1987, the NRC identified an apparent "major" programmatic deficiency in TVA's review of vendor seismic qualification reports and equipment seismic qualification.
Nine examples were cited where mechanical, electrical, or I&C components were not qualified in accordance with the requirements specified in the TVA procurement documents.
. C.'.ASSIFICATION: Programmatic Concern REVISED RESPONSE:*
In TVA's specification to the vendors, the vendor was required to submit design calculations which were to be independently reviewed and cortified to ensure compliance with TVA requirements.
If adequate independent review could not be furnished by the manufacturer, TVA could perform the independent review.
In some cases the vendors chose to have TVA perform the independent review and submitted the componcnt qualification reports for review and approval. The fact that the vendor submittals reviewed by the NRC did not ident lfy a checker does not imply that the calculations were not checked by the vendor for crithmetic errors before submittal.
In the specific seismic reports identified by those IDI items, TVA performed an independant review.
This was documented by correspendence (attachment 1) with original vendor submittels.
Since 1906, TVA has had a seismic qualification program in place consistent with the maturing technology in the nuclear industry.
In the earliest efforts for Brownu Ferry equipment, TVA contracted with its NSSS supplier, CE to provide technical requirements for the seismic qualification of TVA
- Revision to December 29, 1987 response.
' procured safety equipment and to evaluate their vendor-supplied qualification reports for compliance.
By the early 1970s, TVA had formed a core of specialists with backgrounds related to the technical aspects of seismic qualification tests and analyses.
This growing base of TVA technical expertise resulted in the development of seismic qualification criteria consistent with industry standards and URC requirements. TVA then established procedures to ensure that the criteria were appropriately incorporated, implemented, reviewed, and approved.
Seismic qualification requirements have been included in TVA procurement contracts from the late 1960s to the present. For Sequoyah components and equipment, TVA provided vendors with direction and design information for performing seismic qualification which was consistent with IEEE Standard 344-1971.
In TVA's specifications to the vendors, each vendor was required to submit design calculations which were independently reviewed and certified to ensure compliance with all contract requirements.
If adequate independent review could not be furnished by the vendor, TVA could perform the independent review.
TVA inspectors reviewed contractor fabrication processes and witnessed tests. TVA also hired component qualification engineers experienced in stress analysis, dynamic analysis, and testing to re;iew vendor seismic qualification of equipment and_to provide direction and design input to the specifications.
In addition, NSSS suppliers of safety-related components were audited by experienced component qualification engineers to ensure compilance with technical and QA requirements. Vendor solstrie. qualification documents were reviewed by established interface review (squodeheck) procedures. The procurement branch routed documentation to the appropriate engineering organization for review. The review comments woro attached to the squadcheck and routed back to the responsible procurement branch, procedures were formalized for seismic design, review, and control by issuance of Engineering procedure (EP) 3.02 in 1977.
Ep 3.02 was replaced in 1985 with discipline interface agreement CEB-DI-121.03 titled, "Sol 1mic Design, Review, and Control." programmatically, the seismic evaluation of vendor-generated seismic analysis and/or test of components was conducted by the component qualification engineers of the Civil Engineering Branch to ensure compliance with applicable design criteria and the FSAR.
This review met the intent of an ASME Owner's review by present standards.
In addition, the depth of review included a technical assessment to satisfy tho TVA reviewer of the component's
. design adequacy.
The TVA review process also included a review by the section supervisor before final approval of the vendor submittal.
An arithmetic check was not typically performed unless the magnitude of numbers presented appeared to be "out of the ball park."
Minor corrections were made directly on the vendor document submitted for review and the document approved with such corrections noted. Major errors were returned to the vendor for correction and then submitted for further TVA review.
l There have been two Seismic Qualification Review Team (SQRT) audits performed by the NRC to evaluate TVA's seismic qualffication of components. An SQRT audit was conducted in 1976 at SQN and in 1982 at WBN.
A safety evaluation report issued February 1980 concluded that TVA's seismic qualification program was in compliance with IEEE Standard 344-1971. The concern of justifying the original testing and analyses in light of IEEE Standard 344-1975 as l
supplemented by Regulatory Guide 1.100 was.also resolved with recommendations to TVA f rom the NRC that the seismic margin program be expanded.
In a TVA/NRC meeting on April 1, 1981, NRC requested TVA to submit a seismic margin program plan and a list of components to be investigated for SQN units 1 and 2 in accordance with an approved seismic margin review program. The results of the review program have shown that all safety-related mechanical, electrical, and I&C components possess sufficient margin to envelop the higher level 84th percentile critoria. No programmatic concern was indicated by thesu SQRT audits in the component qualification area.
l Based on this background and to previde further support for this position. TVA agreed to document an additional third-party review of the procurement documente and correspondtng seismic qualification reports for a sample of 40 Category I components before sequoyah unit 2 restart.
This review, performed by Impell, has been completed and the results are provided in reference 1.
It was concluded that, for the 33 components procured directly by TVA, a TVA review process was in place, no restart safety concerns exist, and no hardware modifications are required.
I The remaining 7 components were supplied by TVA's NSSS supplier, Westinghouse. Reference 2 addresses the TVA/ Westinghouse interface and the manner in which the interface criteria were established.
A Westinghouse WCAp 7700 topical report titled, "Seismic Analysis of Nuclear power plant Auxiliary
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Equipment," which was used as "a basis for certification of Westinghouse Plant Apparatus Auxiliary Equipment," established that the equipment studied can sustain equivalent static G loads greater than those specified in the Westinghouse E-Specs. TVA has reviewed WCAP 7700 for methodology and applicability, and has-determined that the analyses meet TVA's FSAR requirements. Westinghouse has also written a certificate of Compliance (attachment 2) which certifies that all equipment supplied by Westinghouse is in conformance with the FSAR. Therefore TVA has concluded that the Westinghouse equipment is seismically qualified.
To provide additional assurance, TVA will require that Westinghouse provide evidence that they have audited their vendor seismic qualification reports in typical cases where a vendor has provided a certificate of compliance to Westinghouse.
This evidence will be obtained within 90 days after restart of unit 2.
There were three issues identified in the third-party review by Impell which require further action after restart:
1.
Documentation Retrieval Program. TVA commits to developing a formal retrieval program for vendor seismic qualification documentation within 90 days after restart of unit 2.
2.
Technical Issue on Valve Extended Structure Flexibility. TVA cornles to reviewing this technical issue and developing any necessary corrective action within 90 days after restart cf unit 2, 3.
Technical Issue on Valve Orientation. TVA commits to reviewing this technical issue and developing any necessary corrective action within 90 days after restaet of unit 2.
For istuos 2 and 3, concurrence of the corrective action taken by TVA will be obtained from the reviewing organization (Impell).
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REFERENCES:
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Review of Seismic Equipruent Qualification Documentation, Impell
. Corporation Technical Report 03-0060-1145 Revision ~0, dated February 5, 1988 (B41 880205 003).
,1 2.
TVA/ Westinghouse Interface. Seismic and Nozzle Load Criteria and.
i Application, dated February 4, 1988 (B41 880204 005).
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ATTACHMENT 1 Yl List of; contract Letters For:
1.
TVA contract 71C33-92691 2.
TVA Contract 72C33-92730 3.
TVA Contract 72C35-92775 4.
TVA contract 73C35-83571-2 1.. TV) Contract 71C33-92691 a.
Letter from Industrial Process Engineers dated 1/31/72, to TVA, D. B.
Weaver, Chief, MEB (Reference TVA Contract 71C33-92691) b.
Letter from TVA, D. B. Weaver, Chief, MEB, dated 3/23/72, to Indur. trial Process Engineers, Mr. C. B. Houar c.
Letter from Industriel Process Engineers dated 4/25/82, to TVA, D. B.
Weaver..Chlef, MEB,(Reference TVA Contract 71C33-92691) d.
Letter from TVA. D. B. Weaver, Chief, MEB, dated 5/12/72, to a
Industrial Process. Engineers, Mr. G. V. Houar e.
Tk% remo dated S/15/72, to B. S. Montgomery from C. E. Civins i
2.
TVA Contract 72C33-92130.
- r Letter from H. K.' Porter Company, Inc., dated 6/2/72 to TVA, Chief-a.
Mechanical Enginear
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Letter from H, K. Tyrter Company, Inc., dated 6/14/72 to IVA, Chief Hochanical Enginene q},.
c.
L2tter from H. K. Porter Company, Inc., dated 6/30/12 to TVA, Chief A
Mechanical Engincor i,
d.
Letter from H. E. Porter Company, Inc., dated 7/17/72 to TVA, Chief Mechanical Engineer a
e.
Letter from H. K. Porter Company, Inc., dated 8/1/72 to TVA, Chief M0chanical Enginear f.
Letter from TVA, D.
B. Weaver, Chief, MES, dated 8/14/72 to H. K.
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Porter Company, Mr. R. E. Schremp
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Letter from TVA, D. 3. Weaver, Chief, MEB, dated 9/6/72 to H. 1.
Porter Company, Mr. R. E. Schremp h.
Letter from H. K. Porter Company, Inc., dated 7/11/72 to TVA, D. B.
Weaver, Chief-MES 1.
Letter from H. K. Porter Company, Inc., dated 9/28/72 to TVA, D. D.
Wwaver, Chief 4MEB
- j. Letter f rom TVA, D. ' 3. < k%sver, Chief, MEB, dated 10/18/72 to H. K.
Porter Company, Mr. R. E. Schreep k.
Letter from H. K. Porter Company, Inc., dated 10/25/72 to TVA, D. B.
Weaver, Chief-MEB 1.
Letter from TVA, D B. Weaver, Chief, MED, dated 11))t/72 to n. K.
c Porter Company, He.. R. E. Schremp n
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ATTACHMENT 1 (Continued) y.
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Letter f rom H. n Torter Company Inc., dated 12/18/72 to TVA, D. B.
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'EM Weaver, Chief-HdB I
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Letter fror. TVA. s D. B. Weavor, Chief, MEB dated 2/5/83 to H. K. Porter Compary', he. R. i. Schremp.
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TVA mes dat+d J,9/73 to J. A. Hudson from J. I. Givens (Bel 870330 I
004).
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TVA memo).ateC 11/8/72 to R.'.NE.
Lyon from J. I. Givens (B41 870330 p.
' 004).
3* (N TVAmanh'dled 10/10/72 to R. E. Lyon from J. I. Givens (B41 8:'0330 z.,
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TVA memo dated 9/15/72 to R. E. Lyon from J. I. Givens (Bel 870330
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L k,a. Tet;ter dated 4.'91/71 from R. G. Products, Inc., to TVA, R. E. Lyon, i
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b.^ Letter datei 6/5/77 from R. G. Products, Inc., to TVA, S. C. Wyatt, Expeditbg Sorv'.ses.
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L+.ti.ee dated d.21/72 fr.r.o.IVA, D. B. Weaver, Chief. MEB to R. G.
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Preduct1,Inc.', N., ' H. Finid.c.
Letter dated 8/1/72 from R. G. Products, Inc., to TVA, R. E. Lyon, 1
Chief-MEB.
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Letter dated 10/6/72 f rom TVA, D. B. Weaver, Chief, MEB, to R. G.
lj ;t3 frem TVA D. B. Wever, Chief-MEB to R. G.
Products, Inc., S. W. Klose.
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TVA memo dated 12/1/71 from J. I. Givens to R. E. Lyon (Bel 870330 004).
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TVA mero data: 9/25'72 feom J. I. Givens to R. E. Lyon (Bel 870330 004).
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TVA Contrach 73C35. P3571-2 2
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- 1. TVA memo dated 2/27/73'from J. T. Givens to
- A. Madson (Bel 870330 sj,-
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l N y b. I' TVA memo date64 /17/ 73 f rom J. I. Givens to J. A. Madson (B41 870330 11 004).
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ATTACHMENT 1 (Continued) c.
TVA memo dated 4/27/73 from J. I. Civens to J. A. Madson (B41870330 004).
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Letter usted 5/9/73 from TVA, D. B. Weaver, Chief-MEB to American Foundry and Furnace Company, R. K. Maxwell.
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TVA memo dated 7/16/73 from J. C. Key to J. A. Hudson (541 870330 004).
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M,r. J. 8. Hosmer SequoyahProjectEngineer TVA 88-544 Tennessee Valley Authority February 16, 1988..
Sequoyah Nuclear Power Plant. DSC-A P.O. Box 2000 Soddy Daisy. TN 37379 Tennessee Valley Authority sequoyah Nuclear Power Plants Seismic Qualification of W Supolied Auxiliary Ecutoment Dear Mr. Hosmer i
This letter addresses seismic qualification of equipment supplied by Westinghouse for the Sequoyah Nuclear Plant.
It discusses the manner in' which Westinghouse satisfied the Sequoyah FSAR requirements and addresses the role of WCAP-7700 Rev.1, '$stsmic Analysis of Nuclear Power Plant Auxiliary Equipment' in the qualification of that equipment.
WCAP-7700, Westinghouse (WestinghouseProprietaryClass2)isanin-house...
doctment prepared for the purpose of providing 'a"basis for ' ?
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s certifying seismic qualification of Westinghouse suppl.iede C14st-2 'and 3' - --
- ce,7;r Category 1 auxiliary equipment.
It presents the seismic' analyses result '
of a fairly complete package of the tanks and heat exchangers and s'me o(f the typical safeguard related pumps and valves that Westinghouse had e
on contract at the time this WCAP was prepared (1971).
This report describe the analysis method u.s the mathematical modeling of the equipment, and sed. All analyses used an umbrella seismic response curve to represent the earthquake motion and acceleration.
The curve had a maximum value of 3g which is higher than most existing plants at the elevations where the majority of the auxiliary mechanical equipment is located.
The peak of the curve extends from 20 cps all the way down to the equipments' lower fundamental frequencies.
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The findings based on models studied heat exchange,rs, and most valves have, fundamental frequ show that horizontal tanks t
than 33 cps and can be considered considered flexibles based on the umbrella studied can sustain equivalent static g loads gre,ater than those t
i specified in the equipment specifications.
It also found that most with stralgit piping runs attachet, the stresses a punps have natural frecuencies above 33 cps and for valves pipe and that it is the pipe designers' responsibility to support the valves so that the piping is not overstressed. properly design n1 supports for large components, such as tank Another enough r'gidity in the system.
I Sequoyah Nuclear Plantseismic qualification of Cateqory I systems the Seismic Systern Analy(sis)sub-section SNP
's described in the and Components Supplied by Westin1 house"3.7.2.1, plant's FS In
' Category 1 Systems procedure used for modeling.important step in the seismic a
, it is stated that ?an Th. system is represented by lumped masses and a set of springs idealialns the stiffness properties of the system'.
This is the ap'proach used in WCAp-7700.
static Loads' a simplified static analysis method i wherein an equ,ivalent statti: load js determined by using the the floor spectrum only when it has been demonstrated that the
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of freedos system or if the component or equipment
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of the component is made,, the peak acceleratio It i
i floor spectrum is increased by a factor of 1.5, and that the I
equivalent static loads in this case are determinsd from the increased acceleration level.
the stupitfled, analyses is provided where specific uses are This corresponds to the brief discussion in WCAP 7700 of early (pre-1971 design of) equipment, in the past, was performe designs in which it is stated that the seismic-resistant load' ng statically applied and that such an analysis tends to under estimate the coupling effects of the members in the component, he it is not necessarily conservative and cannot be used without justification as stated in the Westinghouse seismic Design Manual WCAP-7345(Proprietary Therefore from WCAP-7700, it can be concluded that a system).
of using the equivalent static load method of design.was i a
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-n-plant's floor resin the SNP FSAR Section 3.7.3.8 is a discussion of the vertical results.ponse spectra and the combination of horizontal and vertical results that yields the highest stresses is taken as limiting case for the design of components and systems.
3.7.3.10 is a discussion of response peak shifting to take into In Sectidn consideration variations that may have an effect where peaks occur.
These techniques are similar to those discussed above Witch desc the analytical methods used in WCAP 7700 in which an umbrella c was used.
Finally. FSAR Section 3.7.5.1 defines the procedures im Westinghouse in supplying seismic Category 1 equipment.plemented by of this section, and based on the discussions above, it is obvious Frors review 1
that the findings of the studies reported in WCAP-7700 were facto into the preparation of equipment specifications for Sequoyah auxiliary equipment to assure their seismic design adequacy.
seismic requirements imposed on Thus, the and satisfied by, the e meet the seismic qualification r,equirements of the FSAR. qui; cent vendors conformance with the FSAR. Westinghouse certifies that all equip Tnerefore.
1 Very truly yours.
WESTINGHOUSE ELECTRIC CORPORATION fd d:
T. /. l.ordi, Manager TVA sequoyah Project cct D. W. Wilson K. 3. Seidle A. B. Poole J. Kincaid l
W. R. Manglante i
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ENCLOSURE 2 SEQUOYAH NUCLEAR PLANT LIST OF COMMITMENTS 1.
TVA will require that Westinghouse previde evidence that they have audited their vendor seismic qualification reports in cases wheta a vendor provided a certificate of compliance to Westinghouse. This evidence will be obtained within 90 days after restart of unit 2.
2.
TVA commits to developing a formal retrieval program for vendor seismic qualification documentation within 90 days after restart of unit 2.
3.
TVA commits to reviewing the technical issue (raised by Impell Corporation) on valve extended structure flexibility and developing any necessary corrective action (including concurrence by Impell) within 90 days after restart of unit 2.
4.
TVA commits to reviewing the technical' issue (raised by Impell Corporation) on valve orientation and developing any necessary corrective action (including concurrence by Impell) within 90 days after restart of unit 2.
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