ML20149E753
| ML20149E753 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/01/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20149E758 | List: |
| References | |
| NUDOCS 9408050192 | |
| Download: ML20149E753 (26) | |
Text
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Station Support D*partment
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PECO ENERGY
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9C$ ChestorbrocA Boulevard Wayne, PA 19087M91 August 1,1994 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Technical Specifications Change Request No. 9318-0 Response to Requests for Additional Information Gentlemen:
By letter dated January 14,1994, PECO Energy Company submitted a Limerick Generating Station (LGS), Unit 1 and Unit 2 Technical Specifications (TS) Change Request No. 93-18-0 that proposed to increase the allowable leak rate for the main steam isolation valves (MSIVs) and to delete the MSIV Leakage Control System (LCS). By letters dated May 6,1994, and May 23,1994, and during telephone conversations on June 9,1994, the NRC requested additional information, which is provided in Appendix 1. In addition to the NRC's requect for r.dditional information, changes to information presented in the January 14, 1994, submittal were identified by PECO during the development of the final design. These identified changes are included in this letter, and supenede the affected information contained in the January 14,1994 submittal.
Information supporting the response for additional information, and proposed changes supporting TS Change Request No. 93-18-0, are contained in Appendix 1 to this letter. Proposed TS replacement pages are contained in Appendix 2. This additional information is being submitted under affirmation, and the associated affidavit is enclosed. Appendix 3 contains a letter from General Electric dmpany to PECO dated May 27,1994 supporting the information provided.
[
If you have any questions, please do not hesitate to contact us.
Very truly yours, j
h.f? f & $
m G. A. Hunger, Jr.,
1 Director - Licensing t
Attachments Enclosure cc:
T. T. Martin, Administrator, Region I. USNRC (w/ attachments and enclosure)
N S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments and enclosure)
R. R. Janati, PA Bureau of Radiological Protection (w/ attachments and enclosure) i
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l COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER W. H. Smith, Ill, being first duly sworn, deposes and says: That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the enclosed additional information supporting Technical Specifications Change Request No. 93-18-0
" Increase the Allowable Leak Rate for the Main Steam isolation Valves and Delete the MSIV Leakage Control System," for Limerick Generating Station, Unit 1 and Unit 2, Facility Operating License Nos. NPF-39 and NPF-85, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
Vice Pre nt Subscribed and sw rn to befor me this day
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of L 4 41-1994.
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Notary Public h g h>95 My E
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i APPENDIX 1 i
LIMERICK GENERATING STATION j
UNIT 1 AND UNIT 2 Docket Nos.
50-352 50-353 License Nos.
NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 93-18-0
- Increase the Allowable Leak Rate for the Main Steam Isolation Valves and Delete the MSIV Leakage Control System" Additional Information - 9 Pages and Attachments
1 l
Page 1
.Qhan!ges Resulting from Final Deslan Work r
PECO Energy Company identified two changes during the development of the final design of Limerick Generating Station (LGS) modification (P-00017) which will implement the proposed Technical Specifications (TS) Change Request No. 93-18-0, affecting Units 1 and 2. The first change involves a change to the wording on pror osed TS page,3/4 6-3, provided in the change request letter from PECO to the NRC, dated January 14, I'.s94. Specifically, TS Section 3.6.1.2, ACTION c, was proposed as follows.
"The,eakage rate to less than or equal to 11.5 scf per hour for any one main steam line through the lsviation valves, and the total Main Steam line leakage to less than 200 scf per hour for all Main Steam lines, and" Upon further review of this statement, it has t,een determined that it is potentially confusing and could be incorrectly interpreted as meaning that once any MSIV is over 100 scf per hour leakage, all valves are required to be restored to less than 11.5 scf per hour. The following rewording is proposed, to avoid any mitinterpretations, and will supersede the above wording submitted with the January 14,1994 request.
"The leakage rate to.s 11.5 scf per hour for any main steam isolation valve that exceeds 100 scf per hour, and restore the combined maximum pathway leakage to.s 200 scf per hour, and" Therefore, the revised proposed TS pages, affecting Unit 1 and Unit 2, are being re-submitted and are contained in Appendix 2 of this letter.
A second change to the submittal is a clarification of the size of the opening for the MSIV Leakage Alternate Drain Pathway. The Safety Evaluation supporting the modification, and the original TS Change submittal, I
specified that the opening was 1.68 inches. In the final design phase of the modification, the maximum opening was determined to be 1.5 inches in diameter. As stated in the submittal, dated January 14,1994, the size of the opening has the potential to change the dose calculations for the modifications. To address this concern. General Electric Company has performed an analysis, and identified supporting information, that the identified change in the size opening has a minimal impact on the dose calculations performed.
PECO has accepted this conclusion for LGS and provided the letter from General Electric in Appendix 3.
Response to Reauests for AdditionalInformation RESPONSES TO QUESTIONS CONTAINED IN NRC LETTER DATED 5/6/94:
1.
What evaluation or calculation supports the conclusion that the Turbine Building at LGS will withstand an SSE?
Response
As identified in the PECO TS Change Request 93-18-0, dated 1/14/94 the LGS Updated Final Safety Analysk Report (UFSAR) section 3.7.2 8 describes the analysis performed for the Turbine Building as part of the original licensing of LGS This evaluation identifies the following information in support of the adequacy of the Turbine Building to withstand an SSE:
"In addition, the turbine enclosure was dynamically analyzed to ensure the capacity to withstand a SSE without collapsing on or impairing the integrity of the adjacent reactor and control structure."
Also in section 3.2 of the UFSAR table 3 21, note (28), the following is identified:
Page 2 "The main steam systems supporting structures (those portions of the Turbine Enclosure) are such that the main steam system and its supports can maintain their integrity."
2.
What explanation or calculation supports the conclusion that the main steam supports can maintain their integrity during an SSE?
Response
The design methodology and materials for the piping (pathways 208 and 214) for the MSIV Leakage Altemate Drain Pathway and their associated supports are identified in our response to question No.
G contained in this Appendix, proposed by the NRC in a letter to PECO dated 5/26/94. Piping and supports for Seismic category I and seismic category llA are seismically analyzed, and design margins are adequate to assure good seismic performance.
Seismic category 11 piping and supports originally not designed for SSE loading were evaluated for available margin, using the following described methodology.
Marain Assessment:
This assessment is to demonstrate that the Main Steam Drain Line design provides adequate margin, when subject to weight, operating mechanical and seismic loads, to provide a reasonable assurance that position retention of the line will be maintained. This, in conjunction with the supplemental field verification performed as described in Reference 1, has provided assurance that the supports will behave in a ductile manner, that the lines i
are free of known seismic hazards, and that the Limerick design, when modified, will perform in a manner similar to piping and supports which have observed good selsmic l
performance in past, strong-ground-motion earthquakes.
t The Conservative Deterministic Failure Margin (CDFM) methodology was utilized to demonstrate the margin inherent in the piping support design. This methodology !s described in detail in Reference 2 and utilizes a deterministic approach to margin assessment with the following basic steps:
The Earthquake Responso Spectrum is conservatively defined as 84% non-exceedance.
The Estimated Structural and Piping Response is median centered.
The Component Support Capacity is conservatively estimated.
This combination of conservatively defined, seismic demand, median centered responw to the seismic demand and conservative estimate of capacity is considered to result in a High i
Confidence of Low Probability of Failure (HCLPF) which provides the reasonable assurance of desired performance.
The piping support evaluations are performed using a median centered best estimate of the appropriate loadings as shown below:
l l
Page 3 Component Standard Expansion Support Designed by Anchors Loadino Combination Load Ratina OML+ DW+ Seismic TL x 0.739 References 2 & 3 Su" Where:
OML= Operating Mechanical Loads DW= Dead Weight Seismic-Earthquake inertial Loading TL-Support test load equal to or less than load under which support falls to perform its intended function Su-Material ultimate strength at temperature Su*-Material ultimate strength at test temperature.
Operating mechanical loads for the piping supports are thermal expansion loads. Piping systems designed utilizing rod supports typically impose little constraint on thermal expansion.
Seismic Demand:
The selsmic margin evaluation employs an earthquake response spectrum which is conservatively defined. This earthquake input motion definition is taken as NUREG-0098 i
(Reference 4) shape, as specified in NUREG 1407 (Reference 5), and is initially referenced to the plant design basis peak ground acceleration of 0.15g. Adjustments are then made to the Turbine Building design instructure response spectra to estimate the median centered response to the NUREG-0098 motions. These adjustments are based on scaling the Limerick Turbine Enclosure design spectra. The margin is then computed relative to the 0.15g Design Basis earthquake, and the HCLPF is then derived. The HCLPF calculations are performed in a manner consistent with margins computation performed for (IPEEE) severe accident vulnerabilities.
i HCLPFs for highly loaded supports are given in Table 1, which sSows that HCLPFs are greater than 0.4g, which is greater than the 0.i5g Design Basis Earthquake peak ground accoloration for the plant. Based on these HCLPFs, there is reasonable assurance that position retention of the line will be maintained.
Field walk down of the alternate leakage pathway had identified outtlers as summarized in Table 3. These outliers have been resolved as shown in Table 3.
REFERENCES:
1.
General Electric BWR Owners Group Report for increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems, GE NEDC-31858P Revision 2 September 1993.
2.
EPRI NP-6041, A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision 1) August 1991.
i
Page 4 3.
EPRI NP-5228, Selsmic Verification of Nuclear Plant Equipment Anchorage (Revision 1), June 1991.
4.
Newmark,N.M., W.J. Hall. Development of Criteria for Seismic Review of Selected Nuclear Power P! ants.NUREG/CR - 0098, May 1978.
5.
Nuclear Regulatory Commission. Procedure and Submittal Guidance for the Individual Plant Examination of External Events for Severe Accident Vulnerabilities.
NUREG 1407, April 1991.
3.
What explanation or calculation has been performed to support the conclusion that the block wall adjacent to the main steam transmitters will not fall during an SSE?
Response
?
The identified block wall was evaluated by utilizing a seismic margins methodology, which shows the block wall has a High Cont:.* ce of Low Probability of Failure (HCLPF) for earthquakes, greater than.3g, at ground level, which is higher than the.15g SSE. From this evaluation, it was concluded that the block wall adjacent to the main steam pressure transmitters will not fall during an SSE and compromise the pressure boundary of the MSIV Leakage Alternate Drain Pathway.
4.
How will the piping supports which were identified to be "out!!ers" be modified to resolve the identified concern?
Response
A complete list of
- outliers" is provided in Table 3, which also identifies the applicable requircd action.
RESPONSES TO QUESTIONS CONTAINED IN NRC LETTER DATED 5/26/94:
l 1.
Provide supplemental and updated piping earthquake performance database to those presented in NEDC-31585P, Rev. 2, including a more complete database for small bore piping.
Response
The supplemental and updated piping earthquake performance data was provided to the NRC by the BWROG under Plant Hatch Letter HL #4468 dated 1/6/94. The information supplied was provided by the BWROG MSIV Leakage Closure Committee, of which PECO Energy is a member, and is generic and applicable to Limerick.
2.
To ensure that the Limerick SSE design spectra are bounded by the experience database spectra, provide a plant-specific comparison of Limerick SSE Design Ground Response Spectra and the recorded ground motions at the selected earthquake database sites.
i
Response
Three graphs, which are provided as Attachment 1, provide the comparison between the Limerick Response Spectra and the experience database spectra. Graph 1 A provides a comparison of the Limerick horizontal ground response spectra to those experience data base spectra identified in NEDC-31585P Rev. 2. Graph 1B and 1C provide the comparison of the Limerick acceleration to
Page 5 those contained in the supplemental experience database provided in Plant Hatch Letter HL #4468 dated 1/6/94. As shown in the attachments, the Limerick SSE acceleration is well bounded by the experience database acceleration.
3.
Provide a plant specific comparison for design attributes of the main steam system piping utilized in the Limerick Altemate Leakage Pathway and those ir' the experience database, including pipe thickness, diameter-to-thickness ratio, and pipe span.
Response
The information requested is provided in Table 2 which can be compared to the data provided in NEDC-31585P Revision 2.
4.
Provide a plant specific comparison for design attributes of the Limerick main condenser and those in the experience database, including condenser size, weight, helght, footprint, and anchorage capacity.
Response
As stated in TS Change Request 93184, an evaluation of the LGS main condensor found that it is comparable to those in the seismic experience database contained in NEDC 31585P Rev. 2. The follow!ng information is provided to demonstrate the acceptability of the Limerick Maln Condenser Design:
1.
The Limerick condenser was constructed by Foster Wheeler and is a triple shell, triple pressure condenser built to the following design and construction codes:
- American Society of Testing and Materials (ASTM)
- Heat Exchanger Institute (HEI)
- American National Standards Institute (ANSI) 2.
The overall condenser surface area falls within the sizes of the condensers in the seismic experience database as demonstrated by Figure 2A of Attachment 2.
3.
The condenser's ability to resist seismic demand is demonstrated through Figures 28 and 2C, which show that the condensers' shear area / seismic demand exceeds those contained in the seismic database.
This information supports the conclusion, previously stated in TS Change Request 93-18-0, that the Limerick Main Condenser is seismically rugged and is comparable to those condensers which have shown to be capable of withstanding a Seismic Event.
5.
Provide the Licensee approved plant walk-down verification procedure for the Limerick Alternate Drain Pathway, i
Response
PECO Energy has completed the walk <fowns for both Limerick Unit 1 and Unit 2. The following is a summary of the activities which resulted in tqe completion of the walk-down evaluations and supports the conclusions presented in TS Change Request 93-18-0. The information provided is for the Limerick Unit 1 walk-down only, but is repnsentative of the activities performed for Limerick Unit 2.
5
PageS PECO Energy engineering procedure " MOD-CG-9"
- Guideline for Walk-downs," provides instructions for conducting walk-downs on plant systems, structures, and components. In accordance with this guideline, a walk-down plan was developed to identify the purpose, the intended use, the qualification of participants, the criteria to be evaluated, and the verification requirements. A copy of the walk-down Plan for Limerick Unit 1 is provided as Attachment 3.
The PECO Energy engineering strategy for the conduct of the selsmic verification was to contract with EOE Engineering to perform the necessary reviews of all piping within the boundaries of the MSIV Leakage Alternate Drain Pathway. To ensure a complete and thorough walk-down of the piping, PECO Energy engineering first identified the boundaries of the MSIV Leakage Attemate Drain Pathway and then assembled a complete set of Engineering Drawings to be referenced during the field walk-downs. The Engineering Drawings included all plant P&lD's, Piping Isometric Drawings, and Hanger Support Details, where available, which fell within the MSIV Leakage Alternate Drain Pathway Boundaries. A copy of this walk-down package was provided to EOE Engineering for review and reference.
As outlined in the " Walk-down Plan," general criteria was provided which established areas for consideration for the walk-down participants. These criterion were subjective, but provided focus to the major failure modes which have been identified in the EOE Seismic Experience Data Base.
Furthermore, EOE Engineers, who were the authors of k0C-31585P, Rev. 2, Experience Database Study, provided the key experience and knowledge to the walk-down team. This experience was not available within PECO Energy, and was essential to the conduct of a thorough and complete seismic evaluation. PECO Energy ensured the completeness of the walk-down by having the Lead i
Responsible Engineer for the Technical Specification Change Request and the Modification, lead the walk-down team and provide the required plant knowledge and interfaces.
i The walk 4own team also involved an Installation / Piping Design Engineer, and a Piping Designer to evaluate any outliers identified during the walk-down. These individuals who participated in the plant walk-down were tasked to develop a preliminary engineering solution to any "outtlers" identified during the walk-down and review the proposed changes with EOE Engineering to ensure proper and effective resolution of the " outliers".
The walk-down was performed over the course of three days at Limerick. The walk-down team was initially briefed, as required by the walk-down plan and given precise instructions as to their duties.
The EOE Engineers individually walked down the piping identified in the "MSIV Leakage Alternate Drain Pathway" scope. If a seismic " outlier" was identified a " Walk-down Data Sheet" was completed. A copy of the "Wa!k-down Data Sheet" form is provided as Attachment 4. When an
" outlier" was identified, a piping designer and engineer would review the noted discrepancy and develop an engineering solution to the identified problem. This solution was then reviewed with the EOE Engineers to ensure the problem was appropriately addressed. At the cor.ciudon of the walk-down, a review was performed to ensure all activities were completed and the full Scope of the "MSIV Leakage Alternate Drain Pathway" was walked down. Following the complebn of the physical walk-down, EOE Engineering provided a " Walk-down Report," which summarized the walk-down activities and identified the seismic " outliers". This " Walk-down Report" (provided to the NRC as Appendix 3 to TS Change Request 9318-0 dated 1/14/94) serves as the quality record for the walk down portion of the " seismic evaluation" performed.
6.
For the non-seismic category I portion of the main steam system piping, including the associated suppMs which are utilized as an alternate leakage pathway, provide a discussion of the materials imolved and the methodologies used for their original design and installation.
Page 7
Response
Two candidate drain paths to convey any MSIV leakage to the condenser are considered for Limerick Generating Station: Patt 208 and path 214.
Path 208:
Path 208 originates in the steam tunnel just downstream of the outboard MSIVs and terminates at the high pressure condenser. Lines within the steam tunnel are Seismic category I up to valve HV-C-2F020, and Seismic Category llA up to the Turbine building. Piping within the Turbine Building is i
Seismic Category 11.
Path 214:
Path 214 originates from the main steam lines in the turbine building just upstream of the Main Stop Valves (MSV) and terminates at the high pressure condenser. The path is Selsmic Category 11 downstream of the main steam lines and serves as the startup and operating drains to the condenser.
1.EISMIC CATEGORY llA:
DESIGN BASIS:
Piping Code: ANSI B31.1 1973 Code with Addenda thru winter 1974.
PIPING DESIGN DATA:
Design Temperature: 582* F Design Pressure: 1115 psia Pipe Size (NPS)
Thickness D/t l
4 0.337 13 3
0.438 8
2 0.343 7
1 0.250 5
1 0.179 7
Piping identified as seismic category llA was originally analyzed for seismic category I loading and constructed to the requirements of ANSI B31.1 code.
Design Loadin0s: Weight, Thermal and Seismic SSE.
Piping Material: Carbon Steel, Wolded Construction.
Support Types: Springs, Struts, Snubbers, Box types.
Seismic Design Basis: Response Spectrum Analysis using floor response.,pectra based on the design basis eadhquake(DBE) from FSAR (0.15 g Maxirnum Ground Motion)
Page 8 SEISMIC CATEGORY ll:
Piping identified as Seismic Category 11 is Non-Safety Related; not normally designed for seismic acceleration. Piping is designed and constructed as per ANSI B31.1 design code.
DESIGN BASIS:
Piping Code: ANSI B31.1 1973 Code with Addenda thru winter 1974.
PIPING DESIGN DATA:
Design Temperature: 582* F Design Pressure: 1115 psia.
Pipe Size (NPS)
Thickness D/t 4
0.337 13 2
0.343 7
1 0.250 5
Design Loading: Weight, Thermal.
Piping Material: Carbon Steel, Welded Construction.
Support Types: Springs, Rod Hanger, Cantilevered Bracket, and Stanch,on Design Basis: Computerized dead weight and Thermal Analysis.
Design parameters are summarized in Table 2 for the alternate leakage pathway.
7.
Provide a summary of the engineering analyses for a? the piping and component supports on the Limerick Alternate Leakage Pathway. This is necessary in order for the licensee to demonstrate that, despite the support failures observed in the database facilities, the supports in the above alternate pathway will maintain their structural integrity with acceptable safety factors, and will, in turn, ensure the pressure boundary integrity of the pathway during and eiter the design SSE loading.
Response
See PECO's response to question No. 2 contained in this Appendix proposed by the NRC in a letter to PECO dated 5/6/94.
8.
Discuss to what extent you commit to include the Alternate Leakage Path in the ASME code section XI inservice inspection program. Also discuss how repair and replacement of the piping will be performed, if needed.
Response
The MSIV Leakage Alternate Drain Pathway will be included in the LGS Augmented Repair and Replacement Program. However, the pathway will not be included in the LGS ASME Section XI, ISI Program.
l i
Page 9 9.
Address the Single Failure criterion with respect to the proposed alternate MSIV Leakage Drain Path system. A single failure to open of valve HV-0412F021 (single power supply) disables the entire alternate drain system. It is much more likely for this valve to fail to open following a LOCA than it is to lose the integrity of the main steam system and/or the alternate drain path. Given that a LOCA and failure of a Diesel to start is within your design basis, you should show that the consequences of a failure to open of the drain pathway isolation valve are acceptable.
Response
Two different pathways have been included in the boundary of the MSIV Leakage Alternate Drain Pathway which do not require the opening of any valves. These pathways are shown in blue, on the colored pathway print, provided as Attachment 5, (Line EBD-1(2)08 and EBD-1(2)14). They provide orifice flow pathways which ensure, even with the failure of valve HV-0411(2)F021, that there will be flow directed to the main condenser at the same elevation as that assumed in the radiological dose calculation. The radiological analysis was not performed assuming these openings are available. Although there is no fully evaluated backup to the primary pathway, there are two essentially passive backups that ensure sufficient flow to the main condenser and will act to reduce the radiological impact to within the limits of 10CFR100. Furthermore, there are motor operated valves (HV-1(2)04 and HV-1(2)01 A(B-D) in separato drain pathways, which are ag.t supplied with Class 1E power, therefore, they are not assumed in the dose calculation, but which will open on a turbine trip and provide a flow pathway of equal or greater cross sectional area than that assumed in the dose calculation.
Further considerations involve the fact that power to HV-041 1(2)F021 is supplied by the Limerick Diesel Generator Bus which is supplied by two independent offsite sources and the diesel generator.
i This provides a highly reliable source of power to the motor operated valve. Also, Limerick has proposed in TS Change Request 93-18-0 that the MSIV Leakage Alternate Drain Pathway be added to the LGS Technical Specifications. The new specifications will require that the HV-041 1(2)F021 be tested in accordance with the IST Program, which will require the valve to be tested on a quarterly basis. In addition, this valve will be added to the Generic Letter 89-10 Motor Operated Valve Program. The highly reliable power source in combination with the required testing for the HV-04b1(2)F021 provide a high degree of confidence that the subject valve will remain functional.
In addition, PECO Energy has evaluated the acceptability of the MSIV Leakage Alternate Dralq Pathway, and found that in comparison to the capability and design of the MSIV Leakage Control System (LCS), the MSIV Leakage Alternate Drain Pathway provides a significant erihancement to the overall safe operation of the plant. This is based on the fact that the MSIV LCS, although single failure proof by design, is a relatively complicated system with several critical restrictions. These include the inability to handle total MSIV Leakage greater than 100 scfh, and the need for several components in the system to operate correctly. NUREG 1169 identifies that generically the MSIV Alternate Drain Pathway, or as called in the document the *lsolated Main Steam System", is more effective than the MSIV Leakage Control System, since the Offsite Doses from the *lsolated Main Steam System
- as compared to the MSIV Leakage Control System are substantially less and that the *lsolated Main Steam System
- has a capability greater than that of the MSIV LCS. Furthermore, NUREG 1169 ldentifies that based on probability, the not availability with Operator Action of the
Isolated Main Steam System" is greater (i.e.,0.938), compared to that of the MSIV LCS (i.e.,0.802).
Based on the above discussion, PECO Energy has determined that the MSIV Leakage Alternate Drain Pathway provides the necessary level of protection which is required for this service.
s 4
7 Table la Seisnic Margin of a Rapresentative and Highly Loaded Bounding Support Design Operating DBE Component Anchorage 1
Support Dead Mech.
Seismic Total component Anchorage capacity /
Capacity /
HCLPF Designation Load Loads Load Loads Capacity Capacity Demand Demand i
j (Ib)
(1b)
(1b)
(1b)
(1b)
(Ib)
Note (1)
Note (2)
Note (3)
Note (6)
Note (4)
Note (7)
Note (5) i EBD-208-H22
-341
-293 272 (V) 909(V) 6300 T=5867 5.92 1.92 2.4g 1064 (H) 1064(H) 6300 V=31,260 EBD-208-H26
-306
-22 245 (V) 573 (V) 6300 T=5867 10.99 1.83 2.4g 1
V=31,260 EBD-214-El-H6
-389 12 623 (V) 1024 (V) 3955 T=4000 3.91 2.6 2.4g V=21,600 Note (1)
EBD-208-H22 is highly loaded support in Path 208 and EBD-214-El-H6 is highly loaded support in Path 214.These are cantilevered supports.
Note (2)
Seismic load is 1.0 times media-centered peak floor response spectra.
4 Note (3)
Total loads = Dead Load + Operating Mechanical Load + Seismic Load V = Vertical Load H = Lateral Load Note (4)
Anchorage capacity is based on bolt capacities shown in EPRI NP 5228 Rev. 1 Table 2.12 and the safety factors from 1
i EPRI NP-6041 Rev. 1 App. O.
i Note (5)
HCLPF = High Confidence of Low Probability of Failure.
Note (6)
Component Capacity is Equal to 5 x Catalog Load Rating x 0.7 Note (7)
Based on Pullout and Shear Interaction.
4 i
k TABLE.1.STU t
t
Table 2: Drain Pathway System Dasign Paraceters System Piping Temp.
Pres.
Non Sch D/t Supports Types Des.
Loading Analysis Seismic Designation Design
('F)
(psig)
Size (1)
Spacing Code Method De s.-
Basis Drain from ASMP.
582 1115 2" &
160 7 &
Linear R.
S.
outboard MSIV Sect.
3" 8
Sect.
strut MSS Thermal Elastic Analysi's to HV-C-F020 III III snubbers SP58 Hydro using box type SSE Drain from ANSI 582 1115 3"
160 8
ANSI Spring AISC D.W.
Linear R.
S.
HV-C-F020 to B31.1 B31.1 strut MSS Thermal Elastic Analysis Turbine Bldg 4"
80 13 snubbers SP58 Hydro using box type SSE Drain from ANSI 582 1115 4"
80 13 ANSI Rod AISC D. W.
Linear None HV-C-F020 to B31.1 B31.1 hangers MSS Thermal Elastic condenser in spring SP58 Hydro Turbine Bldg concrete anchorage bolted connection Structural Members Operating ANSI 582 1115 1" &
160 5&
ANSI Rod AISC D.
W.
Linear None drain from B31.1 2"
7 B31.1 hangers MSS Thermal Elastic main steam springs SP58 Hydro MSV to high concrete pressure anchorage condenser bolted connection Structural Members (1)
Diameter to Thickness TABLE-2.5TU
Table 3: Outlier Identification and Resolution outlier Type System Outlier (Potential Failure Resolution Required Description Description Mode)
Status Action A
P P
D V
4" EBD 208 Line in Potential for pipe I
Not acceptable as Modify support Turbine Bldg Drain falling off of its is EBD-208-H25 to from outboard MSIV dead weight supports provide bi-to condenser during an SSE lateral restraint. Add lateral stops for supports EBD-208-H23, 24, and 26 thru 28 2" EBD-214 in Beam clamp support I
Not acceptable as Remove the Turbine Bldg Drain Not documented is support from MSV to high pressure condenser Valve HV-204 Potential large I
Valve relocated and Relocate valve movement movement during an SSE concern addressed affecting EBD-214 drain pathway and condenser penetration Block wall adjacent Potential failure of I
Acceptable by None to the main steam wall during au SSE analysis pressure transmitter TABLE-2.$TU
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ATTACHMENT 3
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4.
PAGE 1 OF 3
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WALKDOWN PLAN.
1.0 LIMERICK GENERATING STATION U/l:
MODIFICATION P-00017 " ELIMINATION OF MAIN STEAM ISOLnT1UN c
VALVE'(MSIV) LEAKAGE CONTROL SYSTEM (LCS)"
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2.0 PURPOSE
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i There are two reasons for this walkdown. The first reason is to perfonn the necessary evaluations to demonstrate that the piping being credited for use in the "MSIV i
i Leakage Alte nate Drain Pathway" falls within the criteria specified in NEDC 31858P Revision 2. The second reason is to perform the necessary walkdowns to gather infonnation for the " final design" for Unit 1, and provide general design information for the " final design" for Unit 2, since this walkdown is not possible.
3.0 INTENDED USE:
The results of the seismic evaluation will be incorporated into a " Design Analysis" for Unit 1. This " Design Analysis" will demonstrate the adequacy of the MSIV Leakage Altemate Drain Pathway. The results of the modification walkdown will be used in the " final desien" for LGS Units 1 and 2.
4.0 QUALIFICATION
Each walkdown team member must be familiar with the modification and the stated purpose of the walkdown. Two members of the walkdown team, shall be knowledgeable of the requirements specified in NEDC-3185SP revision 2, and able to l
produce a walkdown report which will document any seismic outliers which may be l
identified in the walkdown. One member of the walkdown team will be familiar with installation issues.
t 5.0 PARTICIPATING ORGANIZATIONS:
EQE ENGINEERING Steven P. Harris NEDC-3185SP RVWR Thomas Roche NEDC 3185SP RVWR
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System Design (CB)
Andy Winter LRE Limerick Technical Bill Klinko LSR Limerjck Contract Mngmt Rob Krieder LIR UE&C Gerry Tuday Installation / Design Jack Kopko Piping Design Tom Powell Electrical Design
ATTACHMENT 3
,' e PAGE 2 OF 3 MODIFICATION P-00017 2
February 15,1994 WALKDOWN PLAN 6.0 ATTACII WALKDOWN DATA SHEETS FOR:
6.1 Discrepancies Identified during Seismic Walkdown. The following is a description of considerations to be given during this ponion of the walkdown:
Seismic Failure Modes:
In general the walkdown should identify seismic outliers which may result in seismic induced pressure boundary failure and inventory release of the main steam and drain
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piping. These outliers shall include suppon failure and falling of non-seismically I
designed plant features (11A), proximity impact, and differential seismic anchor motion on piping systems. Considerations for each of these classes of outliers is provided as follows:
Failure / Proximity Impact:
l Assurance that detrimental falling hazards and proximity interactions do not exist.
Components / Piping should at a minimum be 1 foot away from any potential seismic interaction which has the potential to cause damage during a seismic event. Also, critical piping shall not be in the pathway of any credible falling concem. Potential seismic interactions should be evaluated for piping components such as valve I
operators, vents, drains, instrumentation, and fragile appunenances. All outliers will be documented and evaluated.
Differential Seismic Anchor Motions:
Piping should be reviewed for seismic anchor movements imposed by the following three conditions:
Excessive Jnovement of terminal end equipment.
Differential movement between pipe suppons in adjacent uncoupled buildings.
Excessive movements imposed on small branch lines by flexible headers.
6.2 DiscrepanciesSssues identified during Design Walkdown. The following is a description of considerations which should be made during this ponion of the walkdown:
Piping Walkdown:
The piping walkdown will ensure that the piping being remuted will meet the " seismic criteria" outlined in NEDC-3185SP and the Safety Evaluation for License Change Request 93-18 revision 2. Any problems meeting this criteria shall be identified as a discrepancy. The " seismic criteria" shall at a minimum include the considerations provided in section 6.1 of this plan and the assumptions made in the seismic i
ATTACHMENT 3 PAGE 3 OF 3 MODIFICATION P-00017 3
February 15,1994 WALKDOWN PLAN calculation performed by EQE which are contained in the Safety Evaluation for LCR 93-18.
j For this portion of the walkdown a Piping Walkdown check list will be prepared by UE&C which will identify the applicable drawings to be reviewed and the criteria to be evaluated.
Electrical Walkdown:
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For this portion of the walkdown an Electrical Walkdown checklist will be prepared by UE&C which will identify the applicable drawings to be reviewed and the criteria to be evaluated.
7.0 VERIFICATION REQUIREMENTS:
The seismic walkdown will require independent verification. The services of EQE Engineering have been procured to provide this service which will be documented by a "Walkdown Report". The design walkdowms will not require independent verification, but will be reviewed by the modification team.
8.0 PREPARED BY:
OL Ob DATE: 2/15/94 Andy Winter (LRE Mod P-00017) mMawhodl7swlkptn l
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ATTACHMENT 4 WALKDOWN DATA SHEET MODIFICATION P-00017 1.0 GENERAL LIMERJCK GENERATING STATION U/1 DWG. NO./REV:
COMPONENT:
2.0 INSTRUCTIONS
2.1 Review Walkdown Checklist.
2.2 Provide a separate data sheet for each discrepency.
2.3 Sign and date each data sheet.
2.4 Have data verified by another member of the walkdown team, as required.
3.0 INFORMATION TO BE ENTERED FOR DISCREPENCY/ COMPONENT / DRAWING LISTED ABOVE:
l 3.1 COMPONENT NAME:
3.2 COMPONENT TYPE:
3.3 SPECIFIC ATTRIBUTE:
4.0 DISCREPANCIES IDENTIFIED:
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