ML20148E999
| ML20148E999 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/28/1997 |
| From: | Langenbach J GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20148F000 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR 6710-97-2203, GL-87-02, GL-87-2, NUDOCS 9706040053 | |
| Download: ML20148E999 (33) | |
Text
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l GPU Nuclear, Inc.
(
Route 441 Scuth NUCLEAR Post Office Box 480 Middletown, PA 17057-0480 Tel 717444-7621 6710-97-2203 May 28,1997 U; S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
Three Mile Island Nuclear Station Unit 1 (TMI-1),
Operating License No. DPR-50 Docket No. 50-289 Response to the NRC's Request For Additional Information On The Resolution of Unresolved Safety Issue A-46 at Three Mile Island Nuclear Station, Unit No.1.
By letter dated May 17,1995, GPU Nuclear submitted a plant-specific summary report documenting the results of the seismic walkdown evaluation performed at TMI to address Unresolved Safety Issue (USI) A-46 (Generic Letter 87-02). Following their review of the summary report, the NRC staff, on February 24,1997, issued a request for additional information (RAI) in order to complete their assessment.
Enclosed is our response to the NRC RAI. Please note that we are still in the process oflocating the documentation for the outlier resolution of the raceway TB-355-1 (See our response to Question 20(a) in the enclosure). If we fail to locate the documentation, it will be reconstituted following our reevaluation of the raceway. The documentation will be submitted as soon as it becomes available.
If you have any questions regarding our response, please contact Mr. Yosh Nagai at (201) 316-7974 ofour Licensing staff.
Sincerely, I
9706040053 970528
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PDR ADOCK 05000289 t
P PDR O,3 d v * -
ames W. Lange ach
/ pip Vice President and Director, TMI Enclosure c: Administrator, Region I TMI NRC Project Manager TMI NRC Resident Inspector 1
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ENCLOSURE REOUEST FOR ADDITIONAL INFORMATION Resolution ofUSI A-46 (Generic Letter 87-02)
Three Mile Island Unit I
REFERENCE:
Letter from T, Broughton (GPUN) to NRC, dated May 17,1995, "Three Mile USI A-46 Seismic Evaluation Report, (EQE Report No. 42105-R-002, dated May 11, 1995)"
1.
On Page 10, the reporta mentions that the SSEL,(Safe Shutdown Equipment List) contains 679 components of which 658 components were evaluated during the walk down to verify their seismic adequacy. Provide information to show how the remaining 21 components were verified for seismic adequacy.
"Unless otherwise noted, "the report" means the " Reference" described above.
Response
The 21 components are designated by an 'R' in the SORT field of the Safe Shutdown Equipment List (SSEL) for relay review (Appendix D of Report). These components do not need to operate and which, upon loss of power, will fail in the desired position or state. Section 3.1.2.6 of the GIP defines this equipment as passive for the purposes of defining the SSEL. In GIP section 3.1.2.7, the relays that control these passive components must be evaluated for relay chatter since chatter could cause the equipment to operate in an undesirable manner. However these components are i
not required to have a SQUG type evaluation per the GIP, only the relays that control these components need be evaluated. The seismic evaluation of 19 of these relays, classified as essential i
relays, can be found in GPUN Calculation C-1101-900-5320-025. After submittal of the Report,
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further evaluation of the control circuits of the remaining two components, WDG-V-0047 &
WDL-V-0257, resulted in all the relays in these circuits being screened as non-vulnerable or chatter acceptable. None of the relays were essential. In addition, the host or housing for the relays associated with the equipment with essential relays are also verified to be seismically adequate. (See SVDS in appendix H and also refer to response to RAI question # 11) 2.
On Page 13 of the report,it is stated that as a deviation from the GIP, the TMI Seismic Capability Engineers (SCEs) did not sign the Screening Verification Data Sheets (SVDS) but signed a cover sheet with a statement that "they agree with the data in the SVDS package that they prepared." But, the SVDS included in Appendix II does not have a signature on any page. Submit the missing signed cover sheet (s) that would show the SCEs agreement on SVDS.
Responsg The requested cover sheet has been misplaced. The attached (Attachment I) new cover sheet has been generated and signed by the Seismic Capability Engineers (SCEs) involved in the walkdowns.
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3.
Item 9 on Page 21 of the report did not include in the SSEL those equipment items which (if failed during and after an SSE), were postulated to fail in the desired position. However, a malfunction of the control devices of such equipment can fail l
the equipment in an undesirable state. Therefore, show with examples that the l
control devices of such equipment were included in the SSEL.
l Essponse Refer to the response provided for Question No.1. The 21 components identified are not verified
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for seismic but the control devices, which are classified as essential relays, are verified for the SSE l
at the mounting location. The host components and anchorage for the host components are also i
verified for seismic. The following two examples demonstrate the verification of the control l
desices and host equipment.
l Line #
Component Control Device Location Verification l
Document l
App. A&D App. A&D App.F App.A Host & Control Device l844 MU-V-0010 CLK RLY 714UPDA XCC cabinet SQ-T1-XCC El 338 of CB C-1101-900-5320-025 2187 RC-GRP-0009CLK RLY SU14-13 ES Cab SA SQ-T1-5 A j
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EL 338 of CB C-1101-900-5320-025 CLK RLY SU14-13 ES Cab 5B SQ-TI-5B EL 338 ofCB C-1101-900-5320-025 l
CLK RLY SU14-13 ES Cab 5C SQ-TI-5C EL 338 of CB C-1101-900-5320-025 CLK RLY 4U9-1 ES Cab 5D SQ-TI-5D EL 338 of CB C-1101-900-5320-025 j
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4.
In reference to Item 4, Section 2.1.1.2, Page 22 of the report, the structural integrity i
l of equipment was not considered as a failure mode (e.g., rupture of a valve). Since l
this assumption was TMI plant-specific, provide a list of all cases where the I
structural integrity was not considered as a failure mode, and explain how the equipment functionality was verified for those cases so that the impact of this assumption can be evaluated.
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Response
This asamption is consistent with the GlP method in Section 3 for selecting equipment in the safc shutdown path, and used only for identification of the SSEL components. It was not used for equipment seismic verification which was performed in accordance with the GIP caveats. This assumption is taken from the GIP Section 3.2-6 second paragraph which states:
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An equipment failure is defined as the failure of the active functional capability of
. the equipment, not its structural integrity. For example, for a motor operated valve, t'
failure of the valve to open or close with the motor operator is a failure of the valve to perform its active function. It is not necessary to consider rupture or leakage of fluid for the valve as a failure mode.
This applies to all active valves on the SSEL. The valves are verified in accordance with the caveats specified in the GIP. This statement would have been more appropriately placed in Section 2.1.1.1," Generic Criteria and Assumptions" 5.
Item 5 on Page 23 indicates that " inherently rugged" equipment types include
" pressure and temperature gauges, flow elements and other items defined in the GIP." However, the GIP (Section 3.3.5) does not include the temperature gauges and flow elements, nor does it list any items other than the valves already included in the TMI report. List all equipment types that were considered " inherently rugged," and for those items which were not listed in the GIP, provide information to snow the seismic adequacy of equipment including their mountings.
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Response
This statement in the report refers to items which are shown on the piping and instrument diagrams, are part of the pressure boundary of a piping system, but are not required to perform an active function for safe shutdown; for example, pipe mounted pressure gauges and temperature gauges. In-line flow elements are another example. Therefore they should not be included on the.
j SSEL.
j 6.
Regarding operator action, very high reliance has been placed on operators' ability j
for recovery of many seismically vulnerable items within a short period of time.
Examples are spread throughout the report, of which the following are a few:
i Page 25, Section 2.2.1, Second Paragraph
" Breakers to the control rods can be tripped from the control room or locally (underline added) at the switchgear."
Page 39, Last Sentence "The control room operators can manually align NSCCW cooling..."
Page 41
" Doors will be opened and diesel radiator fans will be used...within 25 minutes ofloss of ventilation."
Page 67, Fourth Bullet
" Resetting seal-in relays."
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i Any one or a few of these operations may easily be performed; but, it is questionable whether all of the cited operator actions can be performed reliably within the short available period of time given the potential for absence of electricallight and egress that could have been created after an SSE-type earthquake as a result of falling or failure of non-seismic components on seismic components. Provide information to show that the assumed recovery of all malfunctions / damages within the needed period can be accomplished in the plant condition after ari SSE-type earthquake (see also Item Nos. 9 and 10).
Response
GPUN chose to use their existing symptomatic operating procedures to respond to a seismic event. This is the option that the SQUG group and the GIP recommend. In addition, the SQUG group and the GIP do not require any special training for the safe shutdown path.
Operations participated in the development of the SSEL and agreed that the operator actions specified were acceptable and within the existing symptomatic procedures. All but two, loss of instrument air and station blackout, of the specified operator actions were part of existing procedures and revisions have been issued to incorporate these operator actions. Operators are trained on the use of these symptomatic procedures and they have demonstrated that they provide acceptable procedure for safe shutdown during abnormal condition. The equipment relied on for shutdown in response to an abnormal event is the same as required by the symptomatic operating procedures and operations is trained to continue to the next level of equipment until the plant reaches hot shutdown. The additional time spent selecting the next level of equipment is part of the normal response to an abnormal event and will not.mpact the safe shutdown of the plant.
3 Section 2.4.6, " Simulator Run", addresses the loss of the emergency diesels with the assumptions that communications (two way radios) was lost, annunciation on the panels failed and access and egress to and from the diesel building was hampered by equipment collapse. A review of the results of the simulator mn showed that all critical annunciator alarms were addressed during the exercise. During the simulator run operations initially worked to get the plant under control.
Then the balance of the shutdown process was followed.
Earthquake experience has shown that typical industrial grade equipment and strrtures are inherently rugged and not susceptible to damage at A-46 plant SSE levels.
Based on the results of the simulator run operations can establish and maintain hot shutdown safely in a timely manner using the existm3 symptomatic procedures.
7.-
Regarding the normal make-up flow path, the report on Page 26 states that "since make-up pump MU-P-1B is selected for normal plant operation, the make-up pump MU-P-1B and valve MU-V-16B are selected as the primary path for long-term reactivity control function." Then it states,"the normal plant make-up path is through the normally closed make-up valve MU-V-217..." and further continues, "the normal make-up flow path is designated as the optional path..." Clearly state
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which one of the two is the normal make-up flow path (i.e., through MU-V-16B or MU-V-217) and whether the normal make-up flow path is primary or optional.
. Verify and confirm with explanation that this clarification will not aher equipment selection on the SSEL.
Response
J The normal makeup flow path is MU-P-1B through MU-V17 and MU-V217.
Since the valves (MU-V17 and MU-V217) in the normal makeup path will not be available upon a loss of offsite power, the primary path for long-term reactivity control was chosen to be M'U-P-1B and MU-V16B. MU-P-1 A and C with valves MU-V16A and C are backup flow paths. The normal plant makeup alignment is designated as the optional path.
l This does not alter the original equipment selection on the SSEL.
8.
Regarding the 4160-volt system, the report on Page 35 states that only buses ID and
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IE are Class IE implying that the other buses were probably not verified for seismic
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l adequacy. If so, provide information to show how potential electrical and structural 1
interaction among these adjacent class IE and r.on-class IE buses during a seismic event were considered (e.g., falling or failure of non-seismic components on seismic components causing structural damage, electrical short, etc.).
Response
The ID and IE 4160 volt class IE buses are located in two separate rooms in the Control Building at elevation 338' - 6". The other 4160 volt busses which 'are not required for A-46 are not located in these areas but at elevation 322' - 0" in the turbine building. The other equipment in the rooms, including that in the overhead and miscellaneous wall mounted equipment was reviewed for interaction during the walkdown of the ID and IE 4160 volt busses as required by the GIP. The seismic verification of the other equipment in these rooms assures that neither stmetural damage or electrical short will happen due to falling or failure of non-seismic equipment.
9.
In Section 2.2.5.7 on Page 40 and Section 2.2.5.11 on Page 42 of the report,it was assumed that portable components would be available for use following an SSE.
Provide information to demonstrate that the portable components (i) will not be damaged during the SSE in their respective locations and (ii) would be available j
within the required duration (e.g., four hours in one case) in the aftermath of a major earthquake (see also item No. 6).
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B3nponse l
Portable ventilation equipment, including fans and flexible ducting, is stored in various locations in i
the plant, including an operations equipment storage area in the Turbine Building at grade and the fire equipment storage locker adjacent to and south of the Turbine Building. The storage locker is j
the primary, reliable source of portable ventilation equipment. The fans available for ventilation j
l-are industrial duty equipment of rugged construction. The locker is a skid mounted pre-l engineered steel building located approximately 200 feet form the Control Building entrance door l
and at the same floor elevation. Access is through the Turbine Building. The ability to establish a l
portable ventilation system as described in the plant procedure 1203-34 would be relatively unaffected by the effects of a seismic event.
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The same equipment source is available for manual action to provide portable ventilation to j
l maintain acceptable temperatures in the intake screen and pumphouse in the event of failure of the i
normal ventilation system. Access from the storage area to the pumphouse is by vehicle on site i
roadways. Under normal conditions the equipment could, by conservative estimates, be in-place in l
. under 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if necessary. It is unlikely that the seismic event would significantly affect the time needed to accomplish the same actions.
In each of the manual actions described, the potential is very low for barriers such as damaged equipment or stmetures which could inhibit the operators' ability to establish the portable i
ventilation systems within the required time. Earthquake experience has shown that typical l
industrial grade equipment and structures are inherently rugged and not susceptible to damage at A-46 plant SSE levels.
l 10.
In Section 2.4 on Page 52, the report states that the operator "will eventually be directed to the use of equipment and instruments on the SSEL even though the operator may have first tried to shut down using equipment not included in the l
SSEL." This may delay the operator action further if ultimately the A-46 shutdown l
path is to be followed. Provide information to demonstrate that this delay in operator action will not compromise safety and was considered toward on time recovery from potential malfunctions, especially, in light of RAI Item.No. 6.
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Response
The referenced quote from our report is a paraphrase of a statement in the GIP on page 3-45 which states "will eventually be directed to the use of the safe shutdown equipment and instmments even though the operator may have first tried to shut down using equipment not included in the USI A-46 SSEL" As stated above in Item #6 operations can establish and maintain hot shutdown safely and in a timely manner using the existing SSEL equipment and the symptomatic procedures. Use of symptomatic procedures in response to an A-46 event is the same response as any other transient and adds no additional delays.
i 11.
For cabinets and panels containing relays, the report in Section 3.5.1 on Page 65 states that "a relay evaluation of these cabinets and panels is not required." It is not 7
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l clear what is meant by "a relay evaluation" of a cabinet. Have the safety-significant l
relays been evaluated? Have the cabinets containing these relays been evaluated?
L If both of these answers are affirmative, clarify what "is not required" then. If any of the answers are negative, provide information to show how the seismic adequacy i
of relays including the housing cabinets was verified.
Response (Refer to response for Ouestion 1) 1 The panels and cabinets described in section 3.5.1 of the report do not perform any i
l function other than to house relays associated with various components on the SSEL. All relays housed in these cabinets which are associated with any items of equipment on the SSEL have i
been identified as essential relays and evaluated to ensure that they have a capacity which exceeds L
the demand placed on the relay. In addition, a screening verification and walkdown in accordance with the procedures prescribed in the GIP was performed for all such cabinets and panels. The purpose of the walkdown was to verify the seismic adequacy of all relays housed in these cabinets and panels which are associated with the equipment on the SSEL. The walkdown considered all the caveats and criteria described in the GIP and any outliers identified during the walkdown have l
been resolved. Therefore, the relays housed in these cabinets and panels which are associated l
with equipment on the SSEL have been shown to perform their intended function.
The intent of the state. ment that a relay review is not required for these cabinets and panels is to clarify that the cabinet itselfis not a part of the SSEL. Therefore, it is not necessary to determine if relay chatter or malfunction would impact any components located j
within the cabinet that are not associated with equipment on the SSEL. The walkdowns and relay reviews which have been conducted verify the seismic adequacy of all SSEL equipment which has associated relays located inside the subject cabinets.
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12.
The report on Page 74, second paragraph states that " anchor bolt tightness checks were performed in accordance with the GIP where tightness checks were determined to be required." This implies that the GIP criteria were used to perform L
the bolt tightness check and prior to that another set of criteria was used to determine whether such a check is required. Specify the criteria that were used to l
determine whether an anchor bolt tightness check is required and who made the i
determination.
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Response
l The intent of the statement in the report is to convey that all tightness checks were performed l
in accortlance with the criteria contained in the GIP. In addition, the criteria contained in the l
GIP were used to determine if a tightness check was required. In all cases except those described below, a tightness check was performed for all anchors associated with the SSEL equipment as specified by the GIP:
- 1) Anchor bolts loaded in tension due to dead weight were not inspected per the guidelines of Section 4.4.1 of the GIP.
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- 2) In some cases, the reduced inspection guidelines contained in GIP sections 4.4.1 and Appendix C, C.2.10 were used as a basis for eliminating the need to perform a tightness check
- 3) In two cases, anchors were determined to be inaccessible due to being buried in a poured in place concrete pad.
- 4) In some cases, the intent of the inspection requirement contained in the GIP was met by a review of documentation instead of by a physical tightness check. The intent of the tightness check is to ensure that the anchor is installed properly. In all cases where documentation was relied upon, the equipment had been installed after plant procedures and quality assurance requirements equivalent to those in use for plant modifications today had been instituted.
l These procedures and inspection requirements were put into place after the NRC issued IE i
Bulletins 79-02 and 79-14 and are sufficient to ensure that the anchonge is installed adequately. Additionally, in all cases where documentation was relied upon, the SCE's l
performed a visual inspection of the anchorage to detennine if any conditions existed which could adversely affect the capacity of the anchors. The decision regarding whether or not to perform an anchorage tightness check was made by the SCE's responsib!c for evaluating the
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item of equipment with input from Plant Operations.
See the response to question 19 b for a list of equipment which falls in categories (3) and (4).
13.
Regarding analysis of outliers for 43 mechanical and electrical components on Page 74, fourth paragraph, the report mention: that as of the report issue date,10 calculations (were) still in progress. Confirm that all calculations have been completed and the outliers (43) are all resolved and found acceptable.
Response
Outliers on a total of forty-three (43) components were identified for resolution by analysis in the USI A-46 report. A review of records confinned that the resolution has been completed and the outliers on the forty-three (43) components have been resolved by analysis. There are no outstanding calculations. The table below is a summary of the components and the analysis documents resolving the outliers.
EAnalysis Doc Line-Component ID L
- Comments EQE 42105-C-002 2371 TG-CV-0001 l
2373 TG-CV-0002 l
2375 TG-CV-0003 2377 TG-CV-0004 j
2379 TG-SV-0001 2381 TG-SV-0002 1
2383 TG-SV-0003 2385 TG-SV-0004 9
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C1101-220-5320-047 2240 RC-V-0002 l
C1101-220-5320-048 i
Cl 101-155-5320-006 1005 1 A BATTERY
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1020 IB BATTERY Cl 101-900-5320-025 1007 1 A DG CNPL i
l 1008 1 A-480V-ES I
l C1101-900-5320-025 1009 1 A-480V-ESF l
1010 1 A-480V-ESV l
1012 1 A-480-RWD
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1013 1 A-480V-SHES 1023 IB-480V-ES I
l 1024 IB-480V-ESF
{
l 1025 IB-480V-ESV l
1026 IB-480V-RWD l
1027 IB-480V-SHES l
1032 1C-480C-ESV l
1034 1D-4160V-ES l
1036 lE-4160V-ES l
1063 4A 1064 4B i
1065 4C 1066 4D 1067 SA 1068 5B 1069 5C 1070 5D 1749 INVERTER 1 A 1750 INVERTER IB 1751 INVERTER IC 1752 INVERTER ID i
1753 INVERTER lE 1754 LWDS 2177 PNL-RSTSP-B 2366 T-1176 2430 XCL I
l 2431 XCLA l
l 14.
Regarding the Third Party Review, the report on Page 82, Section 4.6 states that "the balance of Dr. Stevenson's comments were... satisfactorily resolved by further analysis." Did Dr. Stevenson concur with the resolution of his comments? Provide a more-descriptive response to Dr. Stevenson's observations in Appendix L so that
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an independent evaluation can be made.
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Resp _p_nz The resolution of Dr. Stevenson's comments was made by an in-house peer review. Dr.
Stevenson was not apprised of the results. Potential approaches to resolve the comments were discussed with Dr. Stevenson during his review of the SQUG walkdown results.
A summary of the peer review is provided below with item numbers referring to the numbers in Dr. Stevenson's May 26,1994 letter (Appendix L):
(1)
GPUN Calculation No. Cl 101-168-5320-001 " River Water Pumps Structural Problems Horizontal Restraints; Rev. O, was reviewed.
(2)
Control Room ceiling will be modified under Budget Activity, BA-412552 do. ring the 12R outage.
(3)
Metal Clad wall in the control building is adequate for seismic loads. (Refer to Calculation # C-1101-155-5320-006 and EQE memo dated June 1994).
(4)
No resolution required.
(5)
GPUN Seismic Qualification Package SQ-TI-WDL-C-0003A, Rev. O, resolved this item.
(6)
Comments were resolved by GPUN Seismic Qualification Package SQ-TI-RC-RV-0002, Rev. 0; GPUN Calculation Nos. Cl101-220-5320-047, " Frequency of Pressurize and ITS support", Rev. 0; GPUN Calculations Cl 101-220-3320-048,
" Pressurizer Accelerations due to SQUG Response Spectra", Rev. 0; and GPUN Verification No. VI101-220-036, Verify Calculations Cl101-220-5320-047 and C1101-220-5320-048.
(7)
No resolution required.
(8)
No resoluf a required.
(9)
No resolution required.
(10)
No resolution required.
Dr. Stevenson's generic concerns:
To ensure that the frequency calculations adequately considered anchorage flexibility and that Dr. Stevenson's other comments were not applicable all SQ packages were reviewed by the SCE's in the week following the receipt of Dr. Stevenson's comments. All packages that were impacted were corrected.
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15.
Regarding the small, wall-mounted boxes identified on Page 82 (Item 5) clarify whether these are needed for safe shutdown. If so, justify why they were not included in the safe shutdown list.
Resoonse The small wall mounted boxes referred to in SSEL General Note # 5 in Appendix B, are wall mounted pull boxes, splice boxes and terminal boxes. These boxes do not contain any SSEL equipment and were reviewed for seismic adequacy during the conduit and cable tray walkdown.
The boxes that were reviewed during the conduit and cable tray walkdown were determined to be and are seismically adequate and required no further action.
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16.
For the SSEL items that werejudged to be strong enough to not require a seismic verification (e.g., manual valves), confirm that there was a site inspection performed (on all of them) to verify their availability.
E e
This question is asked in light of the missing hand wheel for a valve (e.g., Page B4 of the report, Item 3).
Resoonse The GIP Section 3.3.5 classifies manual valves as rugged and as such need not be walked down.
Prior to the equipment walkdown, a system walkdown was performed to identify seismic vulnerabilities and help determine the list of safe shutdown equipment. The system walkdown performed before the actual equipment walkdown included the system as a whole. Items such as missing handwheels or lack of anchorage would have been identified during the system walkdown if they existed.
The intent of the referenced note, "No handwheel available for manual action", was to identify that these valves on the SSEL do not have a handwheels for manual operation, not that the handwheel was missing. This note was applied to fluid operated valves and relief valves that l
normally do not have handwheels and do not require handwheels for operation.
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17.
The integer designation of functional class provided on Page B8 in Appendix B of the report, does not seem to be consistent with the decimal designation on the tables (Column 17)in Appendices C and D. Provide clarification or missing information.
Response
Section 2.3 of the Report describes the information in each field of the SSEL. Refer to Entry 17, "SSEL Function", on page 51 for the description of the number after the decimal point.
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18.
In Appendix F, Page 9 the report mentions that for relay EllC-LV (Contact VCS 840), the manufacturer /model number was not available. Provide the missing 4
i information or show how the relay was evaluated without the model number.
Essponse The EHC cabinet and the relays contained therein, including relay EHC-LV, was removed during J
the 11 R outage. The digital control system that was installed in its place contains no essential i
relays and therefore does not require a relay evaluation. A revision to the relay review will be prepared to incorporate these changes.
t 19.
The following questions pertain to Appendix J on meeting the intent of caveats:
a)
It is not clear from the description provided in the report as to what the i
deviations were in definitive terms (e.g., size, distance, configurations, loading, stresses, etc.) that did not meet the words of the caveats, and what justifications were used in definitive or quanthative terms that met the intent of the caveats. In order to establish an understanding of the pervasiveness (roughly about three hundred caveats for which wordings were not met) and i
the severity of this issue,it is requested that adequate data he provided for the following sample equipment items identified in Appendix J to the report (called "Line Number" in the report) that will enable a complete understanding of the deviations and justification for their acceptance: Line Numbers: 1114,1192,1281,1525,1680,1756,1838,1970,2013,2089,2121, 2129,2332,2452,2496.
Response
Examination of the verification packages (SQ packages) for the equipment corresponding to the requested Line Numbers found adequate documentation to suggest that the intent of the caveats is satisfied even though the exact wording of the caveats is not met. A summary of the review is presented below for the equipment requested. The summary lists the caveat for which the 'words i
of the caveats' is not met, a brief description of the deviation and the justification that shows how the intent of the caveat is satisfied.
I i14: (CC) This benchboard contained a computer terminal (Caveat 2, Evaluate Computers and Programmable Controllers) and strip chart recorders (Caveat 3, Evaluate Strip Chart Recorders Separately). These were seen to be well supported, thus not a seismic interaction hazard to other instruments in the panel, and they were not active components needed for safe shutdown. This was considered to meet the intent of the caveats which say they should be evaluated separately.
I192: (DF-P-0001 A) Anchorage Caveat 2, Type of Anchorage Covered by GIP. This item is a pump whose motor is anchored with expansion anchors. GlP Section 4.4.1, Check 2 states that expansion anchors should not be used to secure pumps. If they are they should have a large margin between the pullout load and pullout capadty. Since this is a small pump and the attached 13
=
piping is well supported, it was judged that the anchorage loads were minimal and the caveat intent was met.
1281: (EF-V-0001 A) This valve has a cast iron body (Caveat 2, Valve Body Not of Cast Iron) and cast iron yoke (Caveat 3, Valve Yoke Not of Cast Iron). Caveat 2 states, "..the intent of this caveat is satisfied if seismic stresses in the valve body due to piping loads are low.. " The valve has studs (tie rods) across the flanges which carry the piping bending and tension loads across the i
valve body, so the stresses in the body are minimal, satisfying the intent of the caveat. Caveat 3 l
j states, "If the yoke stress is low [from 3g static analysis], then the intent of the caveat is met."
SQ-T1-NR-V-0010A-SEWS shows the yoke stress is low.
1525: (IA-V-1542) Caveat 1, Earthquake Experience Equipment Class. This small valve does not have a yoke; hence, it does not exactly meet the description given in the GIP for a spring-opposed, diaphragm-operated pneumatic valve. However, since the bell housing was mounted directly on the valve body (no yoke) it was judged that this met the intent of the caveat. Caveat 2, Valve Body Not of Cast Iron. The valve has a cast iron boc!y, but since stresses in the body are minimal (tubing and operator all rigidly supported) the intent is met. Caveat 4, Mounted on 1-inch Diameter Pipe Line or Greater. The valve is mounted en n 3/4-inch line. The caveat description states, "There is no concern if the valve, the operator, and the line are well-supported and anchored to the same stmeture." This was the case; therefore, the intent of the caveat was met.
Caveat 7, Actuator and Yoke Not Independently Braced. While the piping was not braced to the j
same structure "immediately" adjacent to the operator, the distance was small (23 inches) enough that it wasjudged to meet the intent of the caveat that the piping not impose large forces on the 4
actuator.
1680: (IC-P-0001 A) Caveat 2, Cantilever Impeller Shafl Less Than 20 Feet Long. The pump does not have a radial bearing at the bottom of the casing to support the impeller shaft. The concern is j
that a long shaft, up to 20 feet, would be very flexible and have excessive deflection. Since this pump has a very short shaft, the deflection would be minimal and the intent of having a radial bearing is met.
1756: (MS-V-0001 A) Caveat 6, Actuator and Yoke Not Independently Braced. The pipe supports are not "immediately" adjacent to operator support. A calculation showed the yoke stress to be low, so the intent of the caveat was met.
I838: (MU-V-0003-PB) Anchorage Caveat 2, Type of Anchorage Covered by GIP. This instmment is mounted on grating. The anchorage is by threaded studs which pass through the grating and are secured by a backing plate and nut instead of a bolt head. Many instruments on racks are secured to the rack by studs. Therefore, while threaded studs are not listed in the anchorage types in GIP-2 Section 4.4.1, Check 2, it was judged that they met the intent of being covered by the GIP.
1970: (NR-P-0001B) Caveat 2, Cantilever Impeller Shaft Less Than 20 Feet Long. The shafl length on this pump exceeds 20 feet. The caveat states that if the shaft length exceeds 20 feet, an
" evaluation should address the concerns of excessive shaft and casing stresses and deflection of 14
the impeller drive shaft" A calculation was done which addressed these concerns; therefore, the intent of the caveat was met.
2013: (NR-V-0025B) Caveat 7, Actuator and Yoke Not Independently Braced. While the piping was not braced to the same structure "immediately" adjacent to the operator, the distance was l
small enough that it was judged to meet the intent of the caveat that the piping not impose large forces on the actuator.
2089: (NS-V-0015) Interaction Caveat 1, Proximity. The valve operator is very close to a structural member. However, the seismic capability engineersjudged that the deflections of both the operator and the structural member would be too small for impact to occur; therefore, the i
intent of the caveat, avoiding damaging impact, was met.
2121: (NS-V-0046A) Caveat 4, Mounted on i-Inch Diameter Pipe or Greater. This is a small relief valve on a 1/2-inch diameter stub off a 6-inch diameter pipe. The valve does not have a heavy operator, which is the concern of the caveat. Therefore, the intent of the caveat, preventing an overstressed condition in the adjacent piping, is met.
2129: (NS-V-0051B) Caveat 4, Mounted on 1-Inch Diameter Pipe or Greater. This is a small reliefvalve on a 1/2-inch diameter stub ofra 1-1/2-inch diameter pipe. The valve does not have a heavy operator, which is the concern of the caveat. Therefore, the intent of the caveat, preventing an overstressed condition in the adjacent piping, is met.
2332: (NS-V-0052C) Interaction Caveat 1, Proximity. The cabinet touches a lightweight sheet metal wall. The wall's vibration will cause light impact loads against the cabinet. The cabinet does not contain relays, so light impacts will not be damaging. Therefore, the intent of the caveat, avoiding damaging impact, was met.
2452: (MS-HY-0005B) Anchorage Caveat 2, Type of Anchorage Covered by GIP. This instrument is mounted with Liebig expansicn anchors. While expansion anchors are covered by the GIP, Liebig is not on the list of expansion anchors in GIP-2 Section C.2.2. However, the plant has test data to determine the capacity and these bolts are accepted for use in new design.
Therefore, the intent of the caveat, that the bolt capacity can be determined with confidence, is met.
2496: (BS-PT-0285) Caveat 6, Sufricient Slack and Flexibility of Attached Lines. This instmment l
has a flex conduit with no slack. Both ends of the conduit are rigidly supported to the same structure, so the intent of the caveat, " preventing a line breach due to differential seismic displacement of the equipment and the line's nearest support,"is met. Caveat 7, Adequate Anchorage and Anchorage Caveat 4, Adequacy of Anchorage Installation Evaluated. There is l
surface spalling around the shell of the expansion anchors holding the instrumeat to the concrete wall, and the shell protrudes 1/2-inch from the face of the concrete. The inetiument is lightweight and a tug test was used to confirm that anchorage had suflicient capacity in spite of the spalling, thus satisfying the intent of the caveat.
15 l
r 8
i b)
. The GIP caveats require verification of anchor bolt tightness check in applicable and selected cases, not withstanding the presence or absence of a QA program at the site.. Explain why the caveats on anchor bolt tightness j
4 f
were judged to have met the GIP forTMl just because there is a QA 1
program at TMI (Page J15, Justification Code 11) even though no site 1
verification of anchor bolt tightness was made for certain items.
' Response
[
The anchor bolt tightness checks were performed for all anchored equipment where required j
by the GIP.except for the 10 items of equipment described below. The anchors for the first two items of equipment were not inspected because the anchorage is encased by a poured in place concrete pad. The GIP states that it is not the intent of the procedure to require
' disassembly of stmetures to perform the tightness check. The remaining eight items of 1
. equipment wem installed after original plant construction and in accordance with plant installation and inspection pmcedures equivalent to those used today to install anchors for plant 4
modifications. These procedures were instituted by GPUN after the issuance of NRC IE Bulletins 79-02 and 79-14. Since these pmcedures require an independent torque check after installation of the anchor, the intent of the GIP tightness check is met. In addition, these anchors were not inspected because Plant Operations determined that the items of equipment are sensitive and could affect pint operation if disturbed. In cases where the existing
. documentation was used to meet the intent of the GIP tightness check, the SCE's still
].
performed a visual inspection of the anchorage to ensure that conditions do not exist which could adversely impact the adequacy of the anchors. The GIP tightness check was not performed for the following 10 items:
4 i
Line No.
Component No.
Reason for no Tightness Check 2176 PNL-RSTSP-A The anchor bolts for this panel is inaccessible for i
inspection since they are covered by a poured in place concrete pad.
2177 PNL-RSTSP-B Reason same as PNL-RSTSP-A L
-2174 PNL-RSP-A At the time of the walkdown there were operational
[
cancerns about the ruggedness of this component.
Operations felt that this is a sensitive component that r
could not be subjected to a SQUG type inspection and recommended that the SCE's consider an alternative to torque testing each anchor bolt.
2175 PNL-RSP-B Reason same as PNL-RSP-A 1460 HSPS-CAB-Al Reason same as PNL-RSP-A
~ 1461 HSPS-CAB-A2
. Reason same as PNL-RSP-A e -
1462 HSPS-CAB-A3 Reason same as PNL-RSP-A 1463 HSPS-CAB-A4 Reason same as PNL-RSP-A 1153 CRD-CB-0010 Reason same as PNL-RSP-A 1154 CRD-CB 0011 Reason same as PNL-RSP,-A 16 j
l
After I&E Bulletin 79-02, TMI adopted QA procedures for installation of expansion anchors which included independent verification of proper anchor bolt installation by torque testing.
Certain floor mounted electrical equipment on the SSEL had expansion anchors installed per these procedures. When the seismic capability engineers could verify from plant documentation that the torque testing had been performed, and visual inspection indicated the anchorage was still in good condition, then the intent of the caveat, verification of proper installation, was judged to have been met.
c)
From the information provided in the report,it appears that in some cases the TMI equipment conditions do not meet the caveats although additional data, such as analysis and testing data, modifications of equipment, or other means can very well demonstrate adequacy of the particular equipment item.
l Ilowever, according to GIP-2,in such a case, an item should be considered an " outlier" for not satisfying the caveats. Provide justification as to why equipment items requiring additional analysis or data, or modifications were not listed as outliers. For example, potential candidates are the description i
codes 6,19 and 22, and justification codes 3,18 and 26 for equipment iteins j
in Appendix J.
Response
Description Code 6 as written, " Anchor bolt tightness check will be completed after resolution of anchor bolt outliers." Does not clearly reflect the condition. This code is applied to Line Item 2388, an instrument rnk. The anchorage for this rack was determined byjudgment to be insuflicient. An outlier was written, and new anchorage was installed per the Operational Quality Plan. Description 6 will be revised to clearly reflect the condition.
Description Code 19, " Cover is not latched." This refers to an instrument on a control panel whose cover was not properly secured. The situation was corrected on the spot by installing a retaining screw in the cover. Under the TMI plant-specific A-46 walkdown work plan, minor items such as loose screws would be corrected on the spot (COTS) and not written up as outliers since the seismic capability engineers would wi ness the correction. These items were tracked on t
COTS forms. Anything which would require a work order was written up as an outlier. Even though these items were corrected on the spot, work orders were not generated and the items were not identified as outliers, all such minor maintenance items were identified in the appropriate SEWS package as well as on the COTS form. The condition was verified to be resolved before the seismic capability engineer signed the SEWS package.
1 Description Code 22, " Item supported on vibration isolators." This refers to the following three j
items: Line Numbers 1384,1680 and 1681.1384 is a control cabinet. Line Item 1384 has been removed fiom the plant. Line Numbers 1680 and 1681 are pumps. Their description code should have been 21 rather than 22 (see discussion of 1680 under Question 19a.)
17 l
d i
l Justification Code 3, " Plant has data to determine capacity." This refers to items anchored with
[
Liebig expansion anchors. The plam has design capacities for these anchors based on test data, as t
explained above under Question 19a, Line Item 2452. This is the only case where plant specific data outside the GIP was used in meeting the intent of a caveat.
Justification Code 18, " Justified by analysis." This refers to Line Items 1084,1384,1969,1970, 1971,1975,1977,2161,2162,2273 and 2274.1084 is an air handler which is suspended on rod hangers with spring type vibration isolators. The attached ductwork has lateral supports close to the air handler which limit movement of the air handler. The analysis showed that the intent of the 3
caveat, preventing failure of a vibration isolator from lateral loading, is met because the lateral loading can be accommodated by the lateral supports on the ductwork.1384 is discussed above I
under Description Code 22.1969,1970,1971,2273 and 2274 are vertical pumps with cantilever lengths exceeding 20 feet. The discussion of 1970 under Question 19a applies to all of these.1975 and 1977 are control panels on a common base. The base was missing one anchor bolt. The anchorage calculation showed the anchorage was adequate without the missing bolt. The seismic 1
capability engineers felt the acceptability of not having a bolt at that location should be noted on the SEWS by saying the intent of the caveat was met. 2161 and 2162 are valves with cast iron bodies. The analysis showed the stresses in the body were low, thus meeting the intent of Caveat 2 as per the GIP.
Justification Code 26, " Latch will be installed under COTS Program." This is explained under Description Code 19 above.
i In summary, the use of additional data or modification referred to by the question was only used to verify that the intent of a caveat, as explained in the GIP, was met. This is in accordance with 4
the GIP-2 and the SQUG walkdown training. Any cases where the caveat was not met were classified as outliers, even if additional data or modification was used in the resolution.
d)
Explain how the description code 21 (i.e.," Pump has radial bearing") applies to I&C devices (e.g., Line Numbers 2255 and 2256).
)
Response
j The application of Description Code 21 to line numbers 2255 and 2256 is an error. The code i
should have said, " Temperature sensors are longer and proportionately heavier than those i
represented in the database." The Report will be revised to reflect this error.
)
a l
20.
The following questions pertain to the outliers discussed in Appendix K:
4 4
a)
The brief discussion of the description and resolution of outliers included in Appendix K does not provide adequate information in characterizing the i
deficiencies and for evaluating acceptability of the proposed / implemented i
modifications. This observation is applicable to over 400 caveats listed in Appendix K. As described in the GIP,it is expected that the deficiencies and modifications have been thoroughly documented to allow an independent i
18 4
5
review. To illustrate thoroughness of such documentation, submit complete information that led to the resolution of the outliers for the following I
equipment items (called "Line Numbers"). Any deficiencies including field information (e.g., configuration, size, design, etc.) and analysis / testing data should also be included. Line Numbers: 1001,1010,1032,1943,1945,1051, 1060,1098,1114,1324, and 1383, and Raceways CB-338-1, CB-338-6 and TB 355-1.
Response
For the line items requested, the list below cross-references the documents that contain the resolution to the outliers for each component. Following this list is a summary of the caveats on which outliers were written and the resolutions to the outhers.
i JTEM LINE #
COMPONENT IDENTIFICATION GPUN CALC. NUMBER 1001 ES cabinet l A SQ-Tl -1 A 1010 1 A-480V-ESV SQ-T1-1 A-480V-ESV 1032 1C-480V-ESV SQ-TI-lC-480V-ESV 1043 1L-480V-RP SQ-T1-lL-480V-RP 1045 1N-480V-TRCH SQ-TI-lN-480V-TRCH j
1051 1 S-480V-ES SQ-TI-1S-480V-ES 1060 ESAS Actuation Cab. 3A SQ-TI-3A 1098 Battery Charger IB SQ-T1-1B-Battery 1114 (cc) CR Console Center SQ-TI-CC 1324 EG-LS-0244B SQ-T1-EG-LS-0244B i
1383 EG-Y-001B-GR SQ-T1-EG-Y-0001B-GR l
Ract.ays CB-388-1 EQE Calc 42058-C-005 Raceway CB-388-6 EQE Calc 42105-C-001 Raceway TB-355-1 To be submitted at a later date i
19
1.
ES Cabinet 1 A j
Caveat #
. Outlier Desc.,
Resolution 5
Cabinets IB&lB/S not Modification per B/A 412552B, bolted bolted together these cabinets together 9,A9,A10 Grout pad not anchored Modification per B/A 412552B, l
to base slab installed new anchors in the load path 10 Relays not evaluated Refer to Appendix F of report for relay evaluation and cale C1101-900-5320-025 l
12 Same as caveat # 5 Same as caveat # 5 L
I 2.
l A-480V-ESV 1
11 Relays have not been Refer to Appendix F of Relay Repoit evaluated and cale Cl101-900-5320-025 I2 Interaction-air monitor at Outlier analytically resolved, see each end ofMCC is calculations in Appendix C of SQ unanchored can fall and package
{
impact MCC
]
3.
IC-480V-ESV Caveat #
Outlier Desc, Resolution l
5,15 Top hat not bolted to Modified per B/A 412552B cabinet-10,A10 No anchors on east side Modified per B/A 412552B 11 Relays have not been Refer to Appendix F of Relay Report evaluated and calc Cl101-900-5320-025 12,12 Interaction with existing Acceptable per G/C Calc #DC-5390- 3/4"
%" conduit.
207.1-SE A2 Plug welds on west side Modified per B/A 412552B 20
i 4.
IL-480V-RP 3
Relays have not been Refer to Appendix F of Relay Report evaluated and calc C1101-900-5320-025 11 Transformer coils are not Modified per FCR-C-100727 positively anchored to cabinet base 5.
IN-480V-TRCII F
3,G2 Westinghouse breakers Accepted "as is" per memo 5810 DB-50
& DB25 does not 0145 have side to side restraint I
4,G2 Transformer compartment Modified per B/A 412552B j
not bolted to switchgear q
10,G2 compartment 10,G2 Inadequate anchorage of Modified per B/A 412552B & B/A 2
A10,G6 angle to grout pad. No FCR-C-100727 anchors on transformer 11 G7 & G8 Relays have not been Refer ~to Appendix F of Relay Repon G2 evaluated and cale C1101-900-5320-025 6.
1 S-480V-ES Caveat #
Outlier Desc.
Resolution 3
Bieaker lacks side to side Installed per doc. CCR-94-104 restraint i
11 Relays have not been Refer to Appendix F of Relay Repon evaluated and calc Cl101-900-5320-025 I4 Possible interactit n with See GPUN Calc. (1101-155-5320-metal wall east of switchgear 006 wall will not fall 3(Trasns)
Transformer not anchored FCR-C-100727 to cabinet frame 21
7.
3A 5, I2 Cab 3 B/S and 3 B/3 A not Modified per B/A 412552B bolted together 9,A9,A10 Pad supporting panelis not Modified per B/A 412552B tied down to floor with ties or rebars 10 Relays have not been Refer to Appendix F of Relay Report evaluated and cale Cl101-900-5320-025 I
8.
Battery Charger B 4, 7, 9 A8, Questionable welds in load Anchorage and load path are j
A9 path and questionable adequate per GC Calc. DC-5390-anchorage.
2071-SE 6
Middle door missing on Screw added per housekeeping screw l
11 IB-DC panel south of Anchorage is adequate as 4
chargers has questionable documented in sews for IB-DC anchorage.
14 Overhead light bulb could Light bulbs were shown to not be strike AC or DC switches a concern - see attach I for batt l A sews 9.
CC-Control Room Console Center Caveat #
Outlier Desc.
Resolution 11 Meter RC-lP-D has one Screw added per housekeeping of two mounting screws not engaged Il Various unsecured items Controlled per safe housekeeping near console may impact controls on benchboard.
Items include 2 chairs on wheels, clipboards and lunch boxes 22
I4 Ceiling panels may Ceiling to be modified in 12R via potentially collapse onto B/A 412552 equipment 10.
EG-LS-0244B 9
Mercury switch Evaluation in memo 5543-93-208 concluded that chattering or malfunction of this switch will not effect the safe operations of the emergency diesel generator 11.
EG-Y-0001 B-GR Outlier 1 It is unknown ifitem is in Resolution contained in GPUN EPRI database calculation C-1101-741-5320-004 Outlier 2 Base detailincludes ceramic Resolution contained in GPUN isolators which have calculation C-1101-741-5320-004 unknown capacity 12.
Raceway CB-338-1 IR Rigid bolt connection All supports in the catwalk are supports US-5 justified as adequate in EQE US-9 calculation 42058-C-005 US-I l 13.
Raceway CB-388-6 Caveat #
Outlier Desc.
Resolution AR Support fail the vertical EQE Calc. 42105-C-001, support load check (3xDC)in passes the Lateral Load check Section 8.3.2 of the GIP for ID0% fill assuming 100% cable fill (actualis less)
V
4 A.
-m+-
--e-.a a
a eAa-*
E+4k
--4 a
= - -
4<~
- ,Me=
~
-, - *Aa-
--M.7 a6
-5=
i5k'kW m
l L
14.
Raceway TB-355-1 Caveat #
Outlier Desc.
Resolution l
OC Tray 324 anchored to block. To be submitted at a later date wall. Wall or anchorage capacity not known j
b)
For Line Number 1007, the outlier resolution code (No. 3) refers to the relay l
report. However, the relay list included in Appendix D does not include Line Number 1007 (Page 1). Provide the missing information or explain how the essential relays in Line Number 1007 were evaluated.
Response
SSEL Line Number 1007 is listed as seismic review only ("S") in the SORT field of the SSEL.
The relay review ("R") of this item was not included in this field ard should have been. Both a complete relay review and seismic review were performed. The mi:, sing "R" caused the item to be left off the Relay Review SSEL. The SSEL will be updated to correct this error.
l c)
For Line Numbers 2371 through 2385, no resolution approach was identified.
Explain how these outlier items were or will be resolved.
i
Response
Line Numbers 2371 through 2385 are the turbine control valves and the turbine stop valves.
These outlier valves have been resolved satisfactorily by analysis. (See EQE Inc. Calculation
- 42105-C-002) j d)
For several outlier relays, the outlier code (R3) specified: "To be resolved or l
replaced during 12R." For relays that are not being replaced, the resolution code does not provide useful information (i.e., the resolution is to resolve).
Explain what actions are being taken to resolve those outlier relays.
Response
At the time of the issuance of the GPUN Seismic Evaluation Report a number of relays had not yet been resolved. Since then Calculation C-1101-900-5320-025 entitled "SQUG/USI A-46 Seismic Evaluation of Relays for TMI Unit 1" was prepared and resolved the relays in question.
i l
The methodology used for the evaluation is consistent with the approach contained in Section 6 of i
the GIP, EPRI NP-7147-SL " Seismic Ruggedness of Relays", EPRI NP-7148-SL " Procedure for Evaluating Nuclear Power Plant Seismic Functionality" and EPRI NP-5223-SL " Generic Seismic Ruggedness of Power Plant Equipment" 3
a d
i 24
e)
For Line Number 2177, the observation is that the relay was upside down, and for resolution, the report refers to the relay report which does not seem i
to include any further information on the subject. Provide the missing information or explain how the outlier was resolved.
Response
The relay referenced as being mounted upside down is an ITE/Gould model J10 with GPUN Tag
- 69x4AL. The visualinspection indicated the relay was mounted upside down since the nameplate was upside down. Since the vendor mounting requirements allow the mounting of the relay in this position the resolution was to accept the relay as mounted.
21.
The report mentions that data outside the GIP were used to evaluate the GIP items (e.g., Page JIS, Jtem 3) and items outside the GIP (i.e., Equipment Class O).
Describe these data and how they were used for seismic verification of TMI equipment.
Respong The only instance where data outside the GIP were used to evaluate GIP items as seismically I
adequate (i.e., not outliers) was for equipment anchored with Liebig expansion anchors. This is discussed under Question 19.
l Equipment denoted on the SSEL as Equipment Class 0 and evaluated as seismically adequate (i.e., not outliers) were:
BW-H-0001,2 BWST Tank Heating Elements EHC-LV,MTSV,MTV Turbine Electrohydraulic Control and Trip Valves IA-T-0002A,B Compressed Air Bottles IA-T-0003A,B Compressed Air Bottles IA-T-0004A,B Compressed Air Bottles IA-T-0005A,B Compressed Air Bottles IA-T-0006A,B Compressed Air Bottles IA-T-0007A,B Compressed AirBottles IA-T-0008A,B Compressed Air Bottles MU-F-0002A,B Letdown Filters MU-F-0003 RCP Seal Return Filter MU-F-0004A RCP SealInjection Filter H-9R,SJ-3,H-8R,2-35, 1-52,1-53 Sound Powered Phone Jacks These items werejudged to be seismically rugged by the seismic capability engineers on the basis of their past experience and knowledge of the earthquake experience data. The anchorages of the items were separately determined to be adequate. (See SEWS Packages for evaluations) 25
22.
Section 4.3 2 of the report states that the safety related vertical tanks are as follows:
3 large flattoottom vertical tanks,8 vertical tanks with legs, and 4 vertical tanks on steel base skirts. Provide screening evaluation work sheets (SEWS-Form similar to those on pg.G.21-1 of GIP-2) for these 15 tanks, and a detailed analysis of the condensate storage tank (CST, I A) to illustrate how the outlier evaluation was performed for the vertical tanks.
11esponse The requested SEWS forms and analysis are attached (Attachment II).
23.
Section 4.3.3 relating to the review of cable and conduit raceways, states (middle of page 79 of 84)," anchorage is judged acceptable for the 'other' seismic performance concerns." Provide a summary description of how the raceway support anchorages were sampled and judged acceptable. Provide typical work sheets (similar to Table 8-1,8-2,8-3 of GIP-2) for the raceway runs in containment building, diesel j
generator building and auxiliary building (one run in each of the buildings).
J
Response
The cable and conduit raceway walkdown was conducted by plant area as per the GIP guidelines.
Within each plant area,100% of the anchorage of supports was inspected. For areas where access restrictions prevented close visual inspection, such as in the overhead of the catwalk area, each support and anchorage was looked at from the floor to verify that the plant as-built support drawings were valid. The suppon drawings were then used as the basis for the support evaluation.
(The only exception to this was above the control room where ceilib3 puels had to be removed.
In this area, a random inspection was performed by removing ceiling tiles and viewing from the ceiling level. The suppons in this area are in good condition and are lightly loaded.) For each plant area, GIP-2 Exhibit 8-1 was filled out, and any supports judged not acceptable for inclusion rule, other seismic performance concern or seismic interaction, as per the guidance in GIP-2 Chapter 8, were documented on Outlier Seismic Verification Sheets.
The requested work sheets are attached (Attachment III).
24.
The fire barriers attached to the essential raceway systems contribute appreciably to the vertical and horizontal loadings on the raceways, their supports, and anchorages under seismic events. Provide information related to the inclusion of the fire barrier weight in the seismic calculations of the raceway systems. This information may be provided on the relevant work sheets requested in question 23.
26
1
Response
l The raceways at TMI were inspected and a worst case sample of supports was selected for an l
analytical review. The guidelines contained in the GIP were used to select the sample of supports.
None of the worst case supports are installed on trays or conduits which have fire barrier material attached to them. The likely reason for this is that all supports for raceways which are protected by fire barriers were analyzed in detail for seismic loads using conventional analytical techniques.
A large number of these supports were upgraded during the fire protection installation to provide extra capacity to support the fire barrier weight. Therefore, these supports are not judged to be among the worst case sample of supports.
I 25.
Provide information related to the method of resolving comments from the third party inspection, specifically, the concerns related to item (5) in Appendix L regarding Waste Evaporator Cooler, and Dr. Stevenson's " Summary Remark" regarding the determination of response frequencies of components.
A.
Method for Resolution for all Third Pany Comments l
The specific affected component qualification is revisited to verify if the comment is legitimate. Ifit is legitimate, its affect on the SQUG verification package is assessed and corrective action taken. All other SQUG packages having similar l
equipment and/or configuration are then revisited to verify if the comment has any impact on any additional evaluations. SQUG packages that were impacted have been corrected.
l B.
Resolution to Comments on Item (51 WDL-C-0003 A All comments made by third party are accepted and incorporated in the anchorage calculation for this component.
5(a)
Based on reexamination of the tank suppon stmeture, the SCEsjudged that the frame of the top tank may not be rigid in the vertical direction while the frame of the bottom tank is rigid. For conservatism it s 'as assumed that the frame is not rigid in the vertical direction and the peak l
acceleration coefficient for the floor response spectmm is used in the calculation. The overturning moment for the N-S seismic was adjusted and the anchor bolt demand recalculated.
I 5(b)
Page 1 of the anchorage calculation was revised to add an anchorage plan.
I e
27
J 5(c)
The bolt embedment was obtained from plant drawings E-422-006 and S-423-018 and field observation of the bolt projection above the concrete surface. The embedment is determined to be 19" From Table C.3-1 of the GIP the minimum embedment for 3/4" diameter cast in place bolt is 71/2"
< 19" The corresponding pullout capacity is 15.03' From configuration I
and field conditions there are no required adjustments to this pullout capacity. This evaluation is contained in the anchorage calculation as resolution to this comment.
26.
Referring to the in-structure response spectra provided in your 120-day-response to the NRC's reauest in Supplement No. I to Generic Letter (GL) 87-02, dated i
May 22,1992, the followine information is reauested:
a)
Identify structure (s) which have in-structure response spectra (5% critical damping) for elevations within 40-feet above the effective grade, which are j
higher in amplitude than 1.5 times the SQUG Bounding Spectrum.
1 Responst 1
The spectra used in the resolution of USI A-46 are enveloped by the SQUG j
reference spectrum (i.e.,1.5 times the SQUG bounding spectrum) at all elevations i
within 40 feet of grade. However, at some locations in the Intermediate Building i
and in the Turbine Building the in-structure response spectra exceed the reference I
spectrum at some frequencies.
As stated in the 120 day response to Generic Letter 87-02, Supplement 1, GPUN has developed new in-structure response spectra for use in resolving USI A-46.
The procedures and methodologies used to develop these spectra are co isistent with the guidance provided in the NRC's Standard. Review Plan. The original ground response spectra specified in the TMI FS AR is used as input to the analysis. Based on the methodology used to generate in-stmeture response spectra and the input used in the analysis, the newly generated spectra comply with the requirements for conservative in-structure response spectra as defined in Section 4.2.4 of the GIP. The methodology used to develop these spectra was submitted to the NRC in response to Generic Letter 87-02, Supplement 1. In their safety evaluation attached to their letter from Ron Hernan received by GPUN on 9/28/94, the NRC concluded that the seismic input utilized and the procedures used in the development are acceptable. Additionally, the NRC concluded that the spectra can be classified as " conservative design" in-structure response spectra for resolution of USI A-46.
The new in-stmeture response spectra for the Reactor Building, Auxiliary / Fuel / Control Building, Intermediate Building and Turbine Building were issued on July 8,1993, the spectra for the Intake Screenhouse and Pumphouse 28
i were issued on July 29,1993 and the spectra for the Emergency Diesel Generator 1
Building were issued in May 1995.
b)
With respect to th'e comparison of equipment seismic capacity and seismic
' demand, indicate which method in Table 4-1 of GIP-2 was used to evaluate the seismic adequacy for equipment installed on the corresponding Hoors in the structure (s) identified in Item (a) above. If you have elected to use method A in Table 4-1 of the GIP-2, provide a technicaljustification for not using the in-structure response spectra provided in you 120-day-response. It appears that some A-46 licensees are making an incorrect comparison between their plant's safe shutdown earthquake (SSE). The SSE ground motion response spectrum for most nuclear power plants is defined at the plant foundation level. The SQUG Bounding Spectrum is defined at the free field ground surface. For plants located at deep soil or rock sites, there may not be a significant difference between the ground motion amplitudes at the foundation level and those at the ground surface, flowever, for sites where a structure is founded on shallow soil, the amplification of the ground motion l
from the foundation les el to the ground surface may be significant.
l Respong When comparing equipment seismic capacity to demand, GPUN used Method A from Table 4-1 in GIP-2 in some cases and Method B in other cases. Both methods are considered acceptable in the GIP Revision 2 and in the associated NRC SSER on Revision 2 of the GIP. GIP Revision 2 states that the capacity can j
be compared to a demand which is defined in terms of either a ground response i
spectrum or an in-structure response spectra. The GIP funher states that the ground response spectra used for making comparisons per Method A should be the free field SSE ground response spectra. The SSE ground response spectra described in the TMI FSAR is defined at grade in the free field. Therefore, GPUN
)
appropriately applied Method A as described in the GIP Revision 2 to perform this j
comparison; i
However, GPUN is aware that a question has risen regarding the use ofMethod A at sites with a shallow soil layer overlying rock or other competent material. Since TMI is a shallow soil site and since the spectra described in our 120 day response
.L exceed the reference sp.ectmm at some locations, GPUN is reviewing cases where Method A from Table 4-1 was used to compare capacity to demand. If the use of Method A is determined to be inappropriate, the equipment will be reevaluated
)
using Method B.
i 29 1
c)
For the structure (s) identified in item (a) above, provide the in-structure
]
response spectra designated according to the height above the effective i
grade. If the in-structure response spectra identified in the 120-day-response to Supplement No. I to GL 87-02 was not used, provide the response spectra that were actually used to verify the seismic adequacy of equipment within the structures identified in Item (a) above. Also, provide a comparison of j
these spectra to 1.5 times the Bounding Spectrum.
Response
j The instructure response spectra at the locations where the spectra is not enveloped by the SQUG Reference Spectrum (1.5 times the SQUG Bounding Spectrum) are attached (Attachment IV). The plots include a comparison to 1.5 times the SQUG Bounding Spectmm.
1 i
i i
l 30
ATTACHMENT I RESPONSE TO OUESTION 2 COVER SHEET WITH SCE SIGNATURES s
Response to:
NRC RAI dated February 24,1997 Unresolved Safety issue A-46 -- TMl-1 l
Screening Verification Data Sheets Cover Sheet The signatures of the Seismic Capability Engineers (SCE) below represent the review and accepted of the attached Screening Verification Data Sheets (SVDS) data for the items that the SCEs perfonned walkdowns.
R9/L u?
Ah h bs l.L, D. Augditme P. D. Baugjyinan J. P. Conosente R. W. Cushing
&h.
=$
M Gotthard S. M. Lazorchak T. II. Noble S. C. Ramdeen See. Note.l.
O R. A. S@elis E. Y. Tang J. L. White Note 1: Mr. E. Y. Tang is no longer employed by GPUN. As an SCE he walked down less than 10 items. The second SCE on those walkdowns has reviewed the attached SVDS data and accepted the results of Mr. Tang's walkdowns.
i ATTACHMENT 11 i
RESPONSE TO OUESTION 22 SEWS FOR 15 VERTICAL TANKS I
Response to; NRC RAI dated February 24,1997 Unresolved Safety issue A TMl-1