ML20212J247
| ML20212J247 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1999 |
| From: | Adensam E NRC (Affiliation Not Assigned) |
| To: | Smith N SEISMIC QUALIFICATION UTILITY GROUP |
| References | |
| NUDOCS 9906290050 | |
| Download: ML20212J247 (8) | |
Text
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Mr. N:il P. Smith, Chairman Seismic Qualification Utility Group c/o MPR Associates, Inc.
320 King Street Alexandria, Virginia 22314
SUBJECT:
REVIEW OF SEISMIC QUALIFICATION UTILITY GROUP'S REPORT ON THE USE OF THE GENERIC IMPLEMENTATION PROCEDURE FOR NEW AND i
REPLACEMENT EQUIPMENT AND PARTS
Dear Mr. Smith:
l By letter dated July 15,1998, the Seismic Qualification Utility Group (SQUG) submitted a report l
entitled, "Use of the Generic Implementation Procedure for New and Replacement Equipment and Parts, Revision 1, July 15,1998," for review by the U.S. Nuclear Regulato.ry Commission j
(NRC). The report is intendtsd to provide guidance to SQUG member utilities regarding seismic qualification of new and replacement equipment and parts (NARE). SQUG supplemented this
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l report on August 18,1998, with a revision to page 4 of the NARE guidelines to include four restrictions on the use of Method A.
The purpose of this letter is to inform you that the NRC staff has completed its review of the report and its supplement and to provide the enclosed comments for SQUG consideration (Enclosure 1). Enclosure 2 is the staff's understanding of the text agreed upon between SQUG l
and the NRC for page 4 of the NARE guidelines.
l By this letter, the NRC is also informing SQUG of recent management changes affecting SQUG activities. I have been assigned as the Lead Project Director and Ronald W. Hernan has been assigned as the Lead Project Manager for all SQUG activities. Eugene V. Imbro,301-415-3288, is the Lead Technical Branch Chief. Mr. Hernan can be reached at 301-415-2010, and I can be reached at 301-415-1353.
I l
Sincerely, l
ORIGINAL SIGNED BY:
Elinor G. Adensam, Director Project Directorate i Division of licensing Project Management Office of Nuclear Reactor Regulation
Enclosures:
As stated 9(/-//F cc w/encls.: Mr. R. Kassawara Mr. James Fisicaro, Duke Energy Co.
EPRI Program Manager jjfisica@ duke-energy.com 3412 Hillview Avenue gJ.
l P.O. Box 10412 Palo Alto, CA 94304
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Enclosures:
As stated Distribution:
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NAME RHernan BClayto nsam DATE' 6/23/99 0 g00@6/23/99 6/g/99
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UNITED STATES
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S NUCLEAR REGULATORY COMMISSION E
I WASHINGTON. D.C. 3066H001
%, y g June 23,1999 i
Mr. Neil P. Smith, Chairman Seismic Qualification Utility Group c/o MPR Associates, Inc.
320 King Street Alexandria, Virginia 22314
SUBJECT:
REVIEW OF SElSMIC QUALIFICATION UTILITY GROUP'S REPORT ON THE USE OF THE GENERIC IMPLEMENTATION PROCEDURE FOR NEW AND REPLACEMENT EQUIPMENT AND PARTS
Dear Mr. Smith:
By letter dated July 15,1998, the Seismic Qualification Utility Group (SQUG) submitted a report entitled,"Use of the Generic implementation Procedure for New and Replacement Equipment and Parts, Revision 1, July 15,1998," for review by the U.S. Nuclear Regulatory Commission (NRC). The report is intended to provide guidance to SOUG member utilities regarding seismic qualification of new and replacement equipment and parts (NARE). SQUG supplemented this report on August 18,1998, with a revision to page 4 of the NARE guidelines to include four restrictions on the use of Method A.
The purpose of this letter is to inform you that the NRC staff has completed its review of the report and its supplement and to provide the enclosed comments for SQUG consideration (Enclosure 1).- Enclosure 2 is the staff's understanding of the text agreed upon between SOUG and the NRC for page 4 of the NARE guidelines.
By this letter, the NRC is also informing SOUG of recent management changes affecting SOUG activities. l have been assigned as the Lead Project Director and Ronald W. Hernan has been assigned as the Lead Project Manager for all SOUG activities. Eugene V. Imbro,301-415-3288, is the Lead Technical Branch Chief.- Mr. Hernan can be reached at 301-415-2010, and I can be reached at 301-415-1353.
Sincerely, Elinor G. Adensam, Director Project Directorate i Division of licensing Project Management Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/encis.: Mr. R. Kassawara Mr. James Fisicaro, Duke Energy Co.
EPRI Program Manager jjfisica@ duke-energy.com 3412 HilMew Avenue P.O. Box 10412 Palo Alto, CA 94304 e ww e w
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NRC COMMENTS ON THE SEISMIC QUALIFICATION UTILITY GROU.P DOCUMENT USE OF GENERIC IMPLEMENTATION PROCEDURE, REVISION 2 FOR NEW AND REPLACEMENT EQUIPMENT AND PARTS, REVISION 1, JULY 15,1998 FOR USl A-46 PLANTS By a letter dated July 15,1998, from Neil P. Smith, Seismic Qualification Utility Group (SQUG),
to Robert A. Capra, NRC, Revision 1 of the report, "Use of Generic Implementation Procedure (GIP) for New and Replacement Equipment and Parts (NARE)" was transmitted. The report is intended to provide guidance to SQUG membe utilities regarding the subject of concem. By i
letter dated August 18,1998, SQUG supplemented its transmittal with a revised page 4 of the NARE guidelines. Our comments are as follows:
1.
Section 3. Aoolicable Sections of GIP (a) in Section 4, on page 4 of the NARE guidelines dated July 15,1998, Revision 1, the report provides guidance regarding the use of GIP-2 for determining seismic' demand. The discussion does not focus on the limitation stated in GlP-2, regarding the use of Method A for comparison of equipment seismic capacity vs.
demand.
By letter dated August 18,1998, SQUG supplemented its submittal with clarifications on the use of Method A for NARE. In that letter, SQUG revised page 4 of the NARE Guidelines to include only four restrictions on the use of Method A. Although the staff agrees with these four restrictions (three of which are already in GlP-2), the staff does not agree that the four restrictions provide a sufficient envelope to assure appropriate implementation of the limitation that the amplification factor of the free-field ground motion at the location of the new/ replacement equipment is about 1.5 or less.
Although the staff may find certain plant-specific situations where (with justification) an amplification factor greater than 1.5 may be acceptable for closing the USl A-46 review, the staff continues to disagree with SQUG regarding its treatment of this limitation in the NARE Guidelines. Absent a staff acceptance in a plant-specific A-46 SER on the use of Method A at a defined plant location, licensees are expected to justify the use of Method A for NARE at locations where the amplification factor between the free-field ground response spectra and the instructure response spectra is more than about 1.5 (see also NRC letter of September 21,1998).
Based on the discussions between the staff and SQUG, a proposed text for revision to the SQUG NARE Guidelines was faxed to the staff. An edited version of the proposed text that would be acceptable to the staff is provided in (b)
The text at the bottom of the revised page 4 attached to SQUG's August 18,1998, letter, does not flow to page 5 of the NARE guidelines in SQUG's July 15,1998, letter, Revision 1.
2 (c)
On page 5 of Attachment 1 to the July 15,1998, letter, SQUG reiterates the statement in GlP-2. Part 1. Section 2.M, Paragraph 4 conceming the safety function of equipment (es., relays). We find this c dement as quoted, not to be valid for application to NARE. Essential relays are defined in GIP-2 as those relays required for safe shutdown only. For NARE, this definition and the provisions of GIP-2 are not applicable in general, since Class IE (e.g., relays) equipment may be required to psrform certain safety functions other thsn the safe shutdown of the plant (e.g., those required for mitigation of an accident).
Consequently, the seismb adequacy of this Class IE equipment has to be 1
ensured. Licensees may apply the GIP-2 provisions, where applicable, to demonstrate the seismic adequacy for other safety related relays.
2.
Section 5 - Identification of Desian Dif'erences (a)
'Mth regard to the fourth sentence of Paragraph "a" and the last sentence of paragraphs "b" and "c," we support the design attributes listed in Table 1 of the NARE guidelines. However, each design attribute should be addressed based on documented tests, analysis, engineering judgement, or combinations thereof.
In perforrning design evaluations, the basis for attributes not addressed should be provided. Where engineering judgement is relied upon, the basis for the judgement should be documented.
(b)
With regard to the use of seismic experience database, our understanding of the difference between Paragrapha "a" and "c" is that in "a," equipment is made by a different vendor and in "c " equipment is made by the same vendor. if our
' understanding is consistent with yours, we seggest that you modify ths text to clarify the difference between equipment addressed in paragraphs "a" and "c."
3.
Section 6. Evaluation of Desian Differences on Seismic Capacity of Candidate (Eauioment).
(a)
In paragraph "a" the database content information described in the SQUG "20 classes" report and the SQUG Electronic Database of Earthquake F perience are subjected to comments described in., Comment No.J below.
(b)
In item 6.a.(2), the phrase "a significant number of equipment items" is not clear.
Future guidance regarding sample size will have to be established in accordance with staff-endorsed Industry Standards on the use of earthquake experience-based approach for seismic qualification of equipment, which are currently under development by ASME-QME & IEEE-344. The ASMEllEEE proposed guidance is intended for Alj classes of equipment, existing and new, not just for new classes. For NARE, it is necessary to have a strong basis for the experience data through the control of equipment sample size. The staff projects that for equipment with potentially significant des',gn differences, the licensee may use a A,
3 future ASME-QME standard that is endorsed by the staff or re'ly on esismic qualification using conventional analysis or testing methods.
(c)
We suggest that the last portion of item 6.b. would be clearer as follows: "...or combinations thereof to ensure the seismic capacity of the subject equipment is equal or greater than the experiet a database generic capacity." (original sentence: "...or combinations thereof to determine whether the seismic capacity l
of the subject equipment is below the experience database generic capacity").
4.
Tanks and Heat Exchanoers At the bottom of page 4 of the July 15,1998, document, SQUG proposed a modification of Section 7 of the document 'dse of Generic Implementation Procedure (GIP) for New i
and Replacement Equipment and Parts (NARE)," dated June 8,1998. The new Section 7 would state, "This section on tanks and heat exchangers is considered applicable to tanks and heat exchangers which are installed at the plant as well as for new installations."
Note that, in its SSER No. 2 on SQUG GlP-2 dated May 22,1992, the staff stated that the criteria for evaluating tanks and heat exchangers were not acceptable for new installations. However, we propose the following instead.
Section 7 of GIP-2 is acceptable for replacement of existing tanks and heat exchangers, as well as, for the design and construction of new tanks and heat exchangers, except for new flat-bottom vertical tanks. For new flat-bottom vertical tanks the following attributes, in addition to appropriate GIP-2 criteria, are necessary to make them acceptable:
(a)
The cast-in-place anchor-bolts and associated hardware (chairs, transfer plates, etc.) in Subsection 7.3.3 will be designed and installed in accordance with embedment depth, edge distance, anticipated concrete cracking, and corrosion allowance specified in GIP-2. The maximum strain in the anchor-bolts will not exceet '. hat corresponding to the yield strength of the bolt material.
(b)
In Step 16, op 0.6 [ min.(a,,,o )) [ psi]
g (c)
In Subsection 7.3.7, the tank foundation (ring-type or otherwise) will be designed to resist uplift and the overtuming moment.
5.
Earthauake Ground Motion to the document "Use of Generic implementation Procedure (GlP) for New and Replacement Equipment and Parts (NARE), Revision 1,"is a table entitled
" Earthquakes and Database Facilities Which May Bo Used to Establish Representation in and Caveats for GIP Ear +'1 quake Experience Equipment Classes." This table contains a list of 10 earthquakes,48 industrial facilities, and estimates of peak ground acceleration at the industrial facilities from one or more of the earthquakes.
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4 Although peak ground acceleration has been used in the past to characterize earthquake strong ground motion, this single parameter does not have a good correlation with earthquake damage. A much better correlation of ground motion damage potentialis the ground response spectrum which demonstrates the maximum amplitude of the ground motion as a function of the natural frequency. It is the NRC position that the appropriate characterization of the ground motion at a facility, to be used to verify the adequacy of equipment similar to that in nuclear power plants, is the response spectra developed from the ground rnotion recorded at or near a facility.
The ground motion from an earthquake at a particular site is a function of earthquake magnitude and type of faulting, the distance of the site to the fault, and the geology along' the propagation path and immediately under the site. If the ground motion estimate for a facility is not based on the response spectra of recordings made at the site, then the following information is necessary to properly evaluate the estimate.
a.
The name, location (latitude and longitude), and foundation geology (i.e., rock, deep soil, shallow soll) of the facility.
b.
The name, date, time, epicenter, magnitude of the earthquake and distance of the facility to the earthquake rupture.
c.
The 5 percent of critical damping response spectra of the ground motion estimated at the facility from the earthquake, d'
The method used to estimate the ground motion at the facility.
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e.
If the ground motion is based on actual ground motion recordings, the location (latitude and longitude) and foundation geology of the reccrding station and its distance from the facility and its distance to the closest part of the fault rupture. If the estimation is based on a method other than an actual recording of the earthquake ground motion or if the recording station is not co-located with the facility, the detailed method used to estimate the ground motion and any ground motion attenuation equations which may have been used to obtain the estimate.
Of the database sites in the table entitled " Earthquakes and Database Facilities Which May Be Used to Establish Representation in and Caveats for GlP Earthquake Experience Equipment Classes," only a limited number of sites have been reviewed and evaluated for use to verify the seismic adequacy of equipment in nuclear power plants.
The following sites were found acceptable as part of the staff review of GlP-2 [Those marked with (1)] and the staff review of the topical report NEDC-31858P, Revision 2
[Tnose marked with (2)].
San Femando, California 1971 earthquake Sylmar Converter Station (1)
Rinaldi Receiving Station (1)
Valley Steam Plant (1)
Burbank Power Plant (1)
Grayson Power Plant (near Glendale City Hall) (2)
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Point Mugu, Califomia 1973 earthquake Ormond Beach Power Plant (2)
Ferndale, Califomia 1975 earthquake Humboldt Bay Power Plant (2)
Imperial Valley, Califomia 1979 earthquake El Centro Steam Plant (1)
Coatinga, Califomia 1983 earthquake Main Oil Pumping Plant (1)
Union Oil Butane Plant (1)
Shell Water Treatment Plant (1)
Coatinga Water Treatment Plant (1)
Chile 1985 earthquake Bata Shoe Factory (1)
San Isidro Substation (1)
Liolleo Water Pumping Plant (1)
Vicuna Hospital (1)
Concon Petroleum Refinery (1)
Las Ventanas Power Plant (2)
In addition to the above ecrthquake-facility pairs the NRC staff has reviewed and accepted the following earthquake-facility pairs for the verification of the seismic capacity of equipment:
Loma Prieta, California 1989 earthquake Moss Landing Power Plant (2)
Petrolia, Califomia 1992 earthquake Humboldt Bay Power Plant (2)
PALCO Cogeneration Plant (2)
Petrolia, Califomia 1992 earthquake aftershock Humboldt Bhy Power Plant (2)
Landers, California 1992 earthquake Coo! water Power Plant (2)
Whittier Narrows, Califomia 1987 earthquake Commerce Refuse to Energy Plant (2)
Other earthquake and database facilities in the NARE Guidelines are not acceptable at this time.
For the NRC to eccept additional earthquake-facility ground motion estimates for the verification of the seismic adequacy of equipment in nuc!aar power plants, the quality and the level of detail in the ground motion information would have to be equivalent to that relied upon for the acceptance of the earthquake-facility pairs in the above list.
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EDITED TEXT ON USE OF METHOD A FOR NARE BACKGROUND 1
By letter dated August 18,1998, SOUG supplemented its submittal with clarifications on the use of Method A for NARE. In that letter, SOUG revised page 4 of the NARE guidelines to include four restrictions on the use of Method A. Additional proposed text was faxed to the staff on March 29,1999.
EDITED TEXT Additional plant-specific evaluation is required to justify use of Method A for those applications where available instructure response spectra indicate that the building amplification above the ground motion may be significantly in excess of about 1.5. Specifically, the conservatisms inherent in the instructure response spectra need to be evaluated on a structure-specific basis using a combination of qualitative and quantitative approaches to confirm that an amplification factor of free field ground motion at the location of the new/replacernent equipment will be within about 1.5. The following factors should be considered, as applicable:
Location of input motion to building Ground response spectra shapes Soll-structure interaction Ground motion incoherence Frequency (structural modeling)
Structural damping Time history simulation Non-linear behavior (e.g., soil property profile variation, concrete cracking)
Other published data on the conservatisms in calculational models compared to measured and/or modern best-estimate response spectra.
Accordingly, the use of Methc d A for NARE application shall be consistent with staff acceptance of Method A for specific buildings and elevations in the plant specific SER on closure of USl A-46. For use of Method A in buildings and at elevations not reviewed and accepted by the staff in the A-46 SER, the plant owner would be expected to follow the restrictions given on revised page 4 of the NARE guidelines and to perform the additional plant-specific evaluations outlined above or to develop realistic median-centered instructure response spectra to justify that the amplification factor between the free-field response spectra and the applicable instructure response spectra will be within about 1.5. (For use in buildings and at elevations at and below those reviewed and accepted by the NRC as part of the A-46 reviews, no further action would be required.) The plant-specific evaluation, where required, should be documented and available for staff review on a case-by-case basis.
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