ML20197K077

Forwards RAI Re Licensee 960930 Submittal of Specific Summary Rept in Response to USI A-46 Program at Pilgrim Nuclear Power Station

ML20197K077
Person / Time
Site:	Pilgrim
Issue date:	12/16/1997
From:	Wang A NRC (Affiliation Not Assigned)
To:	Oliver L BOSTON EDISON CO.
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR TAC-M69471, NUDOCS 9801050200
Download: ML20197K077 (8)

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D9cember- 16,.1997 Mr. Leon 'J. Olivier Vice President Nuclear Operations.

and Station Director +

Boston Edison. Company rim Nuclear Power Station Pilg#1 Rocky. Hill Road RFD Plymouth, MA 02360 SudJECT: REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF

. UNRESOLVED SAFETY ISSUE (l'SI) A-46. .'ILGRIM NUCLEAR POWER STATION (TAC NO. M6 A71)

Dear Mr. Olivier:

By letter dated September 30. 1996. Bostr Edison Company forwarded the plant-specific- sumary report.in response to the USI A-46 program at the Pilgrim Nuclear Power Station.. The Nuclear Regulatory Commission (NRC) has reviewed '

the summary report and determined that additional information is needed to-complete the review of the licensee's-implementation of the USI A-46 program.

Attached:is the staff's-Request for Additional Information (RAI). We request tnat you respond within 90 daysa Questions regarding this' request should'be.sent to my attention at the above address::or, you can contact me at (301) 415-1445i Sincerely.

AkErl Y."SarigNr"ojIcEManager Project Directorate.1-3 3@

Division of Reactor Projects - I/II \

Office of Nuclear Reactor Regulation g Docket No. 50-293 1

Enclosure:

Request for Additional nformation QQ g g cc w/ encl.: - See next page DISTRIBUTION:

cDocketdile T. Clark J. Zwolinski ACRS PUBLIC"~ A. Wang R. Eaton R. Cooper RI PDI-3 R/F= OGC D. Dorman C. Wu B;'Boger

. DOCUMENT NAME: G:\ PILGRIM \A46.RAI -

- To receive a copy.of this document, indicate in the box: "C" - Copy without attachment / enclosure "E' - Copy with attachmen,t/gnclosure "N" No copy lDFFICE - LA PDI 3 g yn l E PM:PDI-3 l (A)U $ 183/ l- l l l NAME TLClark OAC/ AWeng 9f?) * - RBEntohl ' _

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PDR- ADOcK 05000293 P PDR ,

Mr. Leon J. Olivier Boston Edison Company Pilgrim Nuclear Power Station cc:

Mr. Ron Ledgett Mr. Jeffery Keene Executive Vice President Licensing Division Manager 800 Boyleston Street Boston Edison Company Boston. MA 02199 600 Rocky Hill Road Plymouth. MA 02360-5599 Resident Inspector U. S. Nuclear Regulatory Commission Ms. Nancy Desmond Pilgrim Nuclear Power Station Manager Reg. Af fairs Dept.

Post Office Box 867 Pilgrim Nuclear Power Station Plymouth. MA 02360 RFD #1 Rocky Hill Road Plymouth, MA 02360 Chairman. Board of Selectmen 11 Lincoln Street Mr. David F. Tarantino Plymouth. MA 02360 Nuclear Information Manager Pilgrim Nuclear Power Station Chairman. Duxbury Board of Selectmen RFD #1. Rocky Hill Road Town Hall Plymouth, MA 02360 878 Tremont Street Duxbury. MA 02332 Ms. Kathleen M. O'Toole Secretary of Public Safety Office of the Commissioner Executive Office of Public Safety Massachusetts De artment of One Ashburton Place Environmental Protection BP ,on. MA 02108 One Winter Street Boston, MA 02108 Mr. Peter LaPorte. Director Attn: James Muckerheide $

Office of the Attorney General Massachusetts Emergency Management One Ashburton Place Agency 20th Floor 400 Worcester Road Boston MA 02108 P.O. Box 1496 Framingham. MA 01701-0317 Mr. Robert M. Hallisey Director Radiation Control Program Chairman, Citizens Urging Massachusetts Department of Responsible Energy Public Health P.O. Box 2621 305 So # Street Duxbury MA 02331 Boston, nA 02130 Citizen at Risk

-Regional Administrator Region I P.O. Box 3803 U. S. Nuclear Regulatory Commission Plymouth. MA 02361 475 Allendale Road King of Prussia. PA 19406 W.S. Stowe, Esquire Boston Edison Company Ms. Jane Fleming 800 Boyleston St. 36th Flcor 8 Oceanwood Drive- Boston. MA 02199 Duxbury. MA 0233 cc: (cont.)

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RE00EST FOR ADDITIONAL INFORMATION (RAI)

PILGRIM NUCLEAR POWER STATION. UNIT 1 UNRESOLVED SAFETY ISSUE (USI) A-46

1. In your letter dated September 30, 1996. you stated that Boston Edison Company committed to implement Generic Implementation Procedure. Revision 2 (GIP-2). You also stated that no 3rogrammatic or significant deviations from the GIP were taken w111e performing the walkdown and seismic adequacy evaluations at Pilgrim Station for resolution of USI A-46.- List a sample of worst case deviations that are considered-to be insignificant for Pilgrim and provide the bases for cateprizing them as such. Also, submit the definition of " safety significant" that the-walkdown crew used and provide a justification of why the definition is adequate.

2. Referring to the in-structure response spectra provided in your 12C-day response to the NRC's request in Supplement No. 1 to Generic Letter (GL)- 87-02, dated May 22. 1992, the following information is requested:

a. Identify structure (s) which have in-structure res)onse spectra (5% .

critical damping) for elevations within 40 feet a)ove the effective grave, which are higher in amplitude than 1.5 times the Seismic Qualification Utility Group's (SOUG) Bounding Spectrum.

b. With respect to the 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 floors 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 technical justification for not using the in-structure response spectra provided in your 120-day response. It appears that some A-46 licensees are making an incorrect comparison between their plant's safe shutdown earthquake (SSE) ground motion response spectrum and the SQUG Bounding Spectrum. The SSE ground-motion response. spectrum for most nuclear power plants is defined at the )lant foundation level. The 50VG Bounding Spectrum is defined at tie 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 le;el and those at the ground surface. However, for sites where a structure is founded on shallow soil.- the amplification of the ground motion from the

! foundation level to the ground surface may be significant.

c. For the structure (s) identified in Item (a) above, provide the

'in-structure response spectra designated according to the height above the effective. 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 Enclosure d

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-to verify the' seismic adequacy of equipment within the structures ,

identified in Item (a) above. - Also, provide a comparison of these spectra toL1.5 times the. Bounding Spectrum.

3. .On~Page 4-1 of Section 4 of Enclosure B, you stated that "the SSEL i contains a total of 1008 items, cod of this total, 22 items are

' inherently rugged' or are part of the NSSS and do not require further  :

evaluation per GIP." List all equipment types that were considered

" inherently rugged"; provide information to demonstrate their seismic adequacy including their mountings.

4. In Section 4.1.3 of Enclosure B,. you stated that " engineering judgement is an important element in the evaluation of equipment anchorage. As a general rule, all significant sized equipment was rigorously analyzed to determine anchor bolt forces. Small equipment (usually 50 lbs. or less),

was accepted based on judgement if a comparison of an estimated anchor bolt force and the size and strength of the as found anchorages indicated

.that sufficient anchorage strength existed." Discuss the criterion used

, to determine that equipment is considered as "significantly sized" and for which a rigorous analysis was performed to demonstrate its seismic adequacy. Also, provide a sample calculation to demonstrate the seismic 4 adequacy of small equipment anchorage.

5. Ir Section 4.3, you indicated that all Seismic Capability Engineers (SCE) have been 500G trained and certified and their resumes are provided in Appendix C. However, no SOUG training qualification was mentioned in any one of the resumes in Appendix C. Provide the evidence or certification of the 50VG training qualification for all SCEs involved in the A-46 program at Pilgrim, o 6. In Table 5-1 of Enclosure B regarding the comments for meeting the intent

. of the caveats, bounding spectra have been identified. It is unclear how individual equiment in the table did not meet the caveats described in Appendix B of tie GIP-2. but was considered to meet the intent of the caveats. Provide a detailed description of how the equipment did not meet the GIP caveats, for each item in Table 5-1. As an example, provide the basis for judging that equipment items VAC205A-1 and VAC205D-1 have met the intent of caveats with respect to their seismic adequacy.

7. In reference to Table 5-1, fe Motor Operated Valves (MOVs) M03800, H03801 M03805..M03806, M03808, M03813. M04083 and M04084, the valve

.o actuator sup Provide an example of a calculation, port brackets including the are made of maximum cast iron.

calculated stress and the allowable stress limits to demonstrate the seismic adequacy of these MOVs.

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8. In reference to Table 6-1, " Tanks and Heat Exchangers Evaluation Results," it is not clear how you resolved a total of 14 outliers by

" components -speci fi c . eval uati on . " Provide the methodology. *he analysis 1 and/or modification in detail regarding the resolution of outliers for heat exchangers E122A&B, E206A&B. E207A&B, E209A&B and E216A&B. and Tanks T126A&B and T151A&B.

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9. Section 6.2 of Enclosure C of the reference letter states that 110 relays out of a total of 622 essential relays are classified as " outlier relays." All outlier relays at Pilgrim Station are listed in Attachment 2 of-the Enclosure. The safety implications arising from malfunction of outlier relays are provided in Attachment 3. The licensee indicated that at the time of the June 13. 1996 submittal to the NRC. there were no

" Unresolved" outlier relays.

Regarding the resolution of outlier relays. very high reliance has been placed on operators' ability for recovery of many seismically vulnerable items within a short period of time. For instance. the following examples are cited.

• For 4160V Breakers A504 and A604

... operator action would be required to manually reset the lockout relay.

For 4160V Breaker A509 and A609.

... operator action to restart the Diesel Gmerator is available should relays fail."

• For 480V Breakers B601. B602, 102. 202, 310. 410 in Drywell Cooling Fans VAC205A-1. VAC205B-1. . etc..

" . operator action to restart the drywell cooling fans may be required should these relays fail.

Any one or a few of these operations may easily be performed, however, it is questionable whether all of the cited operator actions can be performed reliably within the short period of time available given the potential for absence of electrical light and egress that could have been created after an SSE-type earthquake as a result of 9111ng or failure of non-seismic components on seismic comporents. Provide information to show that the assumed recovery of all malfunctions / damages within the needed period can be accomplished in the plant condition after an SSE-type earthquake.

10. The NRC staff has concerns about the way the USI A-46 cable trays and conduit raceways issue is being disposed of by some USI A-46 licensees.

The staff issued RAls to several licensees on this issue. SOUG responded instead of the licensees because SOUG considered the P.Als to be generic in nature. The staff issued a subsequent RAI to SOUG as a follow-up to their response, liowever, the staff found that the correspondence with SOUG did not achieve the intended results in that it did not address the identified technical concerns of the staff. Therefore, we are requesting your response to the items stated below.

The GIP procedure recommended performing what is called "a limited analytic evaluation" for selected cable and conduit raceway supports.

.The )rocedure further recommended that when a certain cable tray system can )e judged to be dactile and the vertical load ca)acity of the anchorage c.an be established by a load check using t1ree times the dead weight, no further evaluation is needed to demonstrate lateral resistance 1

4 to vibration from earthquakes. The staff has concerns with the manner in which these simplified GIP criteria were implemented at your plant.

The GIP procedure eliminates horizontal force evaluations by invoking ductility. However, some so-called non-ductile cable tray support systems would eventually become ductile by inelastic deformation.

buckling or failure of the non-ductile caole tray supports and members.

This procedure is a basic de)arture from conventional methods of engineering evaluation and tie GIP dces not provide an adequate basis for dealing with those cable trays that are iritially judged to be non-ductile but are eventually called ductile by pcstulating failure of the lateral supports. If this procedure was followed for eliminating cable trays from further assessment at your plant. then all the cable trays could conceivably be screened out from the A-46 evaluation. We request that you provide the following information to enable our assessment and safety evaluation of cable trays at your plant.

a. Define ductility in engineering terms as used at Pilgrim for the USI A-46 evaluation. Clarify how this definition is consistently dpplied to actual system configurations at Pilgrim station for the purpose of analytical evaluation.

b. Provide the total number of raceways that were selected for worst-case analytical calculations and were classified as ductile in your A-46 evaluation and fce which you did not perform a horizontal load evaluation. Indicate the approximate percentage of such raceways bs compared with the population selected for analytical review.

Discuss how the ductility concept is used in your walkdown procedures.

c. Describe the ty)ical configurations of your ductile raceways (dimension, mem)er size, supports, etc.)

d. Justify the position that ductile raceways need not to be evaluated for a horizontal load. When a reference is 3rovided, state the page number and paragraph. The reference should ae self-contained, and not refer to another reference

e. In the evaluation of the cable trays and raceways. if the ductility of the attachments is assumed in one horizontal direction, does it necessarily follow that the same system is ductile in the perpe%icular direction? If yes, provide the basis of this conclusion. If it is not ductile in the serpendicular direction.

how was the seismic adequacy of the attac1ments evaluated?

f. Discuss any raceways and cable trays including supports in your plant that are outside of the experience data. Explain what criteria are used for establishing their safety adequacy and specify your plan for resolution of outliers that did not meet the acceptance criteria. Provide examples of the configurations of such raceways and cable trays including supports. Also, indicate the percentage of cable trays and raceways udtside the experience data

5 in relation to the population of raceways and cable trays examined during the walkdowns of the safe shut down path. Discuss how they will be evaluated and disposed.

g. Submit the evaluation and analysis results for four of the representative sample raceways (one single non-ductile one single ductile, one multiple non-ductile, and one multiple ductile raceway), including the configurations (dimension, member size. -

supports. etc.).

11. In Enclosure B of your letter. the screening verificatio esults by equipment class. incluoing the total number of screening items, the number of outlier items and the number of acceptable items, are provided in Table 4-1. A total of 183 outliers including one conci;4t and cable tray outlier were encountered. All outliers divided into 67 groups are provided in Section 8.2. The status of outliers and their safety implications are also provided. For all open outlier items, the proposed resolutica are provided in Section 9. You are requested to elaborate on your deciuon to defer the implementation of certain identified outliers and your evaluation in support of the conclusion that the design basis for the affected components / systems will not be affected by your decision.

12. Indicate whether you used the SMA methodology described in the re) ort EPRI NP-6041 for the resolution of the outlier tanks and heat exclargers.

If you used the SMA methodology for the tank evaluations, you dre aware that this methodology is known to yield .nalytical results which are not as conservative as those obtained by M owing the GIP-2 guidelines.

Therefore, it is generally not acceptao.e for the A-46 program. Desciibe the extent to which the method was used in your A-46 program. For each deviation from the GIP-2 guideP nes, in situations where the margin ethodology is utilized identify the nature and the extent of the deviation, and provide a technical Justification for its acceptance.

13. Indicate whether you found any anchor type (e.g., '.ead cinch anchor) that is not covered by the GIP-2 during the walkdown. If yes, how did you resolve the issue?

14. If Thermal-Leg panels are attached to a cable tray system, discuss how the changes in weight have been incorporated in the GIP evaluation of these systems and their supports.

15. You provided two different in-structure response s)ectra (liS) in References 15.1 and 15.2 respectively, provided Jelow. Indicate which i IRF has been used for your A-46 program. If the IRS in Reference 15.2 l has never been usec' for resolutions of the A-46 issues, please state so.

15.1. Letter from Boston Edison Company (BECo) to NRC. "120-Day l Response to Supplement 1 of Generic Letter 87-02 for PNPS." dated i September 21. 1992. i 15.2. Letter from E. Boulette (BECo) to NRC. " Additional Response to GL 87-02. Supplement 1." dated February 9. 1994.

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