ML20195F771
| ML20195F771 | |
| Person / Time | |
|---|---|
| Issue date: | 08/21/1986 |
| From: | Speis T Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20153G441 | List: |
| References | |
| REF-GTECI-A-40, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8608280006 | |
| Download: ML20195F771 (2) | |
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ENCLOSURE
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NUCLEAR REGULATORY COMMISSION w AtmwC10N, D. C. 2065$
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MEMORANDUM FOR: Thomas M. Nuvak. Acting Director. Division of PWR Licensing A Frank J. Miraglia. Director, Division of PWR Licensing B Robert M. Bernero, Director. Division of BWR Licensing FROM:
Themis P. Spets. Director Division of Sat'ety Review and Oversight
SUBJECT:
PROPOSED POSITION ON USE OF USI A 46 SE!$ HIC EXPERIENCE DATA WASE In a cooperative effort with the NRC. the 3eismic Qualification Utilities Group (SCUG), and EPRI have collected actual carthquake experience data and seismic test experience data. This data base provides the basis for the resolution of USl A 46. "hismic Qualification of Ecufpment in Operating Plants." The l
esperience data has been organized in a manner such that the seismic adequacy of clssses of equtpment can be verified (subject to certain caveats and exclusions) by coeparison with the data base up to prescribed seismic motion bounds. The use of this data base has significant advantages over conventional seismic qualification proevduras. The US1 A-46 resolution is scheduled to be completed and a generic letter requiring implementation issued by October 1936.
DSR0 has received several inquiries from utilities with operating plants undergoing re review or under OL review about the potential use of the seismic l
experience data base for their plants.
Several utilities have particular interest in the data collected on cable trays end conduits.
If cable tray and coHuit seismic capability could be established by comparison with the data be,e, millions of dollars could be savvo on detailed structural analysis.
~9 date, the utilities have been answered by informing them that.1) licensing questions should be handled through the licensing divisions, and 2) the selsmic data balv has not yet been appro'ved for use in implementing A 46.
In particular.
the cable tray and conduit data report has not been reviewed and approved by i
the statf, r"
f The purpose of this Ivtter is to recomend 4 position to be taken by the Itcanning divisions with regard to the use of the A 46 seiseic experience data base. 05RO believes that the data base, when completed and approved, is a viable and ufficient eachanism for demonstrating the seismic adequacy of rechanical aid electrical equipment and cable trays and conduits, including their supports, and should be considvred an acceptable,a_1 ternate _Mthod for the, lltenline proitsL_he W5Fosed' plant wiQ not be subject to A.46 implementation even if the I
Dau_1.reme n} s. ln t chEge to IEEE Standard 344, a section is aoded
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l on the use of seismic experience data for seismic qualification of electrical equipment. The current plans for the generic incorporation of the seismic experience data base as an acceptable alternative in SRP 3.10 is expected to be through the endorsement of the upcoming revisions to IEEE Sta ard 344 in Aegulatory Guide 1.100.
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- 2' There is currently a lot of interest in the cable tray and conduit dato base.
The cable tray and conduit experiences and test data reviewed to date show cable trays and conduits have significant seismic capability even when seismic loads were not considered in the design and when grossly overloaded. A variety of support designs are represented. This data base when completed and reviewed, with necessary caveats and exclusions, is expected to be appropriate for use on a cast. by case basis for all plants under ruview or re-reetew whether subject to A-46 requirements or not.
g I.f plants subject to the A-46 implementation have current seismic qualification problems or have made connite.ents due before the scheduled. implementation of USI A-46, cons m t 'n should be given to deferring those ccenitinents until A-46 is implen..
DSR0 has arranged a presentation on the A 46 data base and implementation pro;edures On September 16 for NRR management, thcluding the Licensing Division Directors. Assistafit Directors and Engineering Branch Chiefs.
In acdition, DSR0 will keep the licensing divisions infonned of the status of the experience data basw. and will assist the engineering branches as necessary in answering "uestions from utilities on data base implementation.
The contacts for this issue are Newton Anderson (x24305) and T. Y. Chang (x29779).
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Themis P. Spets, Director-l Division of Safety Review and Dyersight cc:
G. Lainas C. E. Rossi l
D. Crutenfield R. 3allard L. Marsh G. Bagchi P. Y. Chen J. Chen J. Richardson B. Sheron K. Kniel W. Minners
- 2. Roszteczy f Thomas, 00U3 y R. 5 ha f f s tall, ry.C N. Smith, SQUG R. Vollrer H. Denton
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00CKE TEC, USNRC / C.ULES !. CROCf GURE5 [E t j Q n r ;.w ~ e IEEE POWER ENGINEERING SOCIETY 87 NOV -9 A9 :19_, NUCLEAR POWER ENGINEERING COMMITTEE 6 /% g lye s, es.-R % 9' 'C g M p: 5......,7 C 5......, v.. c 6...... St. 4.,4i C..,4,..t., J. T. B AVE R H. 5. P.,t., L. D. Test J. E. T h.... G. A. T ec ka. leg e. lac. .. e k.e g v.a P.b'ic P... 5.s p lySyve-Ge e,.I Elect,c C.-o.ay D 6 e P.-e Co-o.ar P.O. B.: 85608 P.O. O.s 968 M.S. 981C 17$ Cv tne, Aven e M C 862 M.C.B.833389 u Sue D.es., C A 92138 R.ckl.ad.
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1 (2151422 3734.,377C October 29, 1987 $U BCOMMIT T E E.C H AIR M E N h_* ~~-4' % Sc. i. A 4 .a. e,..... J. T, s... 7 Rules and Procedures Branch, b,' k,*I[""'.." c e-e.a, Division of Rules and Records, c.u 5. vola Office of Administration and Reso4rce Management. 8 U.S. Nuclear Regulatory' Commission [y',g,',T20 $. F.ac.i.le L A 70775 Washington, DC 20555 504 6356044Ec.2812
Subject:
Proposed Revision 2 to Regulatory Guide 1.100: sc.: c,........, 5..... t r. c & T v. Seismic Qualification of Electric and Mechanical D. C. L.,6,. N0.el.'Y[n$$'rg,7 4dpmen M Nuclear Nwer Mass, '~* CI$ N4.Isll E Request for Co=ments, letter by G. A. Arlotto, 2 August 14, 1987. 5:.4. A.,1..y c.... N '..N'uis.,i s...c e cc. IEEE/ PES /NPEC acknowledges the NRC endorsement of IEEE-344-1987 P.C, B. 2 7: E..- N. 3 2 and in particular the use of experience data. Guidance on the Z'!','l3,yl'I42M use of experience data for seismic qualification has been incorporatM in this revision of the document. We are pleased
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that NRC believes the use of operating experience is consistent g, a.iu s... Eje e. C..s. with the proposed resolution of Unresolved Safety Issue (LSI) p,'$'s.*. 5' [ A-46 (NUREG-1030, "Seismic Qualification of Equipment in ~ S."it. +. 'A 1523; Operating Nuclear Power Plants " February 1987). 412. 374 4211 50 6. 5..'.e r..E.1c ed $1 c.-iPrepared by E ".G M n a Nbw
- %g G. D. Shipway K. M. Skreiner (215i 8414t:2 Chairman, W.G. 2.5 Vice Chaircan W.G. 2.5 l
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mo e... ..e P.usbv.8, P A 15235 J. T. Bauer (412. 25c 26 2 Chairman sc.e, c..ra y A s ..c. Nuclear Power Engineering Committee. IEEE J. D. L *.a' o a... c.--.... 9k iac. P.O.s. 14;a R e.d a. P A 15503 cc NPEC SC-1 (215. 3!71200 E s,. 2':73 File Lotter ) SC.9. E c..e o R.C.
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01,100 C PDR Sc.le. Av. oe c.-c.ei THE INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS INC% ud n/M l l
03O }} kb. f 6 Aks ~; DOCKETED USNRC l FULES t. P,jl3,7E0.URES BR II y WISCONSIN CtflC posta coupar r b (414)277 2345 231 W VICHIGAN.P O box 2046. MILWAUKEE.W153201 ge m ha I,1979 E*"87Ef*' 5g FM M f s' O 8 I November 9, 1987 Rules & Procedures Branch Division of Rules and Records Office of Administration and Resources Managemirnt US NUCLEAR REGULATORY CO!O!ISSION Uushington, DC 20555 Gentlemen: COMMEN'rS ON PROPOSED REVISION 2 TO REGULATL,.'Y GUIDE 1.100, SEISMIC QUALIFICATION OF ELECTRICAL AND MECHA.'ICAL EQUIPMENT FOR NUCLEAR POWER PLANTS In response to your letter of August 14, 1987, which forwarded proposed Revision 2 of the subject regulatory guide, the following comments are offered: 1. The sub]ect regulatory guide requires case by case approval for qualification of equipment, using earthquake experience. This is in conflict with NRC Generic Lotter 87-02, which permits generic qualification of equipment based on data obtained from earthquak<. sites, using a methodology developed by the Seismic Qualifiestion Utility Group (SQUG). The regulatory guide should endorse the SQUG methodology being reviewed by the NRC Staff. 2, The proposed Regulatory Guide 1.100 applies IEEE-344-1987 to pipe supports, snubbers, restraints and hangers. This proposed qualification method is inappropriate for these devices ar.d is not consistent with NUREG-0800, Standard Review Plan, Sections 3.9.2, 3.9.3, 3.9.4 and 3.10. The ASME, ANSI and AISC codes have been demonstrated by experience to adequately address these components. For example, a hydraulic snubber's lockup velocity, bleed velocity and displacement prior to lockup are important for it to perform its design function during an earthquake. These variables are not addressed by the proposed regulatory guide. The regulatory guide should be revised to remove mechanical equipment from the scope. 071109 01,100 pyg WildG->bll/Y
.o NRC, Rules a Records Div. November 9, 1987 i Page 2 3. IEEE-344-1997 requires justification of similarity of each equipment item to be seismically qualified by experience. SQUG experience in resolution of Unres;olved Safety Issue A-46 indicates that a broad and diverse data base applicable to generic types of equipment is the preferred approach. The t regulatory guids should explicitly endorse the SOUG methodology l now being revit2wed by the NRC Staff for twenty classes of i equipment. 1 We will be pleased to discuss these comments wit.) you. I Very truly yours, + i I C. W. Fay [ i Vice President j Nuclear Power r 5 .i i i 9 E I r i ? I I i j l I t i I 1 l J l i b, 1 i t I j
0S07 Seismic Qualificati3n Utility Group g c{ d, g#/et DOCKETED Ug 1sa street ww seite soo ih k //ff2 J 4 f CM ,/ / sehensten, c.c. sonos jo prR 3 o 9' 8 o '87 NDY -9 A9 3 9 " I ' ' 8 " ' T H November 3, 1987 C h eltm a n Rules and Procedures Brar c5 Division of Rules and Records Of fice Adninistration and Resource Management US Nuclear Regulatory Commission Washington, D.C. 20555 Subj ect : USNRC Regulatory Guide 1.100, Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants Gentlemen: Tnis is in response to your letter of August 14, 1987 which forwarded Revision 2 of the subject regulatory guide for industry comment. As requested, our cortnents are directed primarily to the use of earthquake experience data f or seismic qualification of equipment. As you may be aware, the Seismic Qualification Utility Group (50VG), a group of 38 utilities representing over 60 operating nuclear plants, has act vely pursued tne documentation and use of earthquake experience as a practical and cost ef fective means of verifying the seismic ruggedness of equipment since 1982. As a result of this effort, and with the assistance of the USNRC and the Senior Seismic Review and Advisory Panel, methodology an0 acceptance criteria for the use of earthquake experience data have been developed and accepted as the preferred method for resolution of Unresolved Safety Issue A-46. The methodology and acceptance criteria are '.n accordance with NRC Generic Letter 87-02 and its attachments, and are presented in the SQUG Generic implementation Pro:edure (GIP). The Generic Implementation Procedure is under review and trial use and will be the subject of an NRC Safety Evaluation Report, it is with this background that we have reviewed your proposed Regulatory Guide 1.100, Revision 2. Our position with regard to seismic qualification of equipment is that the proper use of earthquake exper ience data to verify seismic ruggedness of equipment covered by the data base is cost effective and fully equivalent (in nany cases superior) to the classical seismic qualification methods defined in detail in IEEE 344-1987.
- Further, while the experience data approach has been added as an acceptable qualification methcd in the IEEE 344-1987 standard, its coverage is brief and necessarily general, and will be difficult to apply.
These l limitations are acknowledged in the Foreword of IEEE 344-1987. k 1.100 C PDR R n a nam
. = g USHRC November 3, 1987 ~ Therefore, we question the advisability of using IEEE 344-1987 as the interim basis for use of earthquake experience data for equipment qualification. Instead, consideration should be given to referencing the SQUG Generic Implementation Procedure, as the interim guidance for use of experience data for equipment qualification. The use of the 50VG Generic Implementation Procedure as the guidance for use of seismic experience data would also resolve the f ollowing problem areas in the proposed regulatory guide: 1. Mechanical Equipment - As presently written, Regulatory Guide 1.100 adds nechanical equipment to the scope of IEEE 344-1987, a document written by electrical engineers for electrical equi pment. We do not believe this is appropriate. Alternatively, the Generic Implementation Procedure properly covers both electrical and mechanical equipment. 2. Similarity - The similarity issue, as described in IEEE 344-1987, is complex and appears to incorporate an approach similar to that used in environmental qualification. The SOUG experience indicates that an approach which addresses similarity on a component by component basis is not the best approach. Instead, it indicates that similarity is best addressed by a diverse data base as is done in the Generic Implementation Procedure. Tne Generic Implementation Procedure provides more practical and more definitive guidance in this area than does the proposed IEEE 344-1987 In addition to the above, we note that Regulatory Guide 1.100 is intended to apply to piping and equipment supports, restraints and nangers. We do not believe the methods of IEEE 344-1987 are appropriate for these static, structural devices. We consider these are best covered by current rules in the applicable ASME, ANSI and AISC Codes. We tnerefore reconnend deleting equipment and piping supports f rom the scope of 9eg Guide 1.100. We will be pleased to discuss these comments in more detail at your convenience. Si nce rely, Neil P. Smith Chai nnan Seismic Qualification Utility Group .}}