ML20212K281

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Forwards Util 860213 & 0319 Ltrs Contending That Plant Erroneously Identified by NRC as Being within Scope of USI A-46, Seismic Qualification of Equipment in Operating Plants. Response Requested
ML20212K281
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 02/25/1987
From: Coleman H
TENNESSEE VALLEY AUTHORITY
To: Anderson N
NRC
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8703090261
Download: ML20212K281 (5)


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S01 86020 g y 3//7 Memorandum TENNESSEE VALLEYT6THORITY R (In w &

~l To R. L. Gridley, Manager of Licensing, ONP, LP SN 157B-C y

1 FROM H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant

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DATE

February 13, 1986 8U8#E E SEQUOYAHNUCLEARPLANT(SQN)-STATUSOFTHEEQUIPMENTSEISMIb QUALIFICATION PROGRAM

Reference:

J. W. Hufham's memorandum to Those listed dated November 6, 1985, " Seismic Qualification on Equipment at TVA Nuclear Plants - Resolution of Unresolved Safety issue (USI A-46)" (L44 851106 800)

SQN has been erroneously 3 eDiifitd M )a being included within the scope of their(Unreso' Tired Safety Issue A-4,

Seismic Qualification of Equipment in OperatEg~ Plants?~The seismic qualification of safety-related electrical and mechanical equipment has been thoroughly audited by NRC's seismic audit team; further evaluation under A-46 is not warranted.

A detailed discussion of this situation is provided by the attachment.

It is recommended that this attachment be forwarded to NRC to provide the basis for appropriately deleting the SQN facility from the list of A-46 plants.

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H. L. Ab'orcrombie l

CRB:WSW:RWM:SFH Attachment l

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RIMS, MR 4N 72A-C H. B. Rankin. ONP, DSC-E, Sequoyah This was prepared principally by R. W. Headors and F. H. Coleman.

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SEQUOYAH NUCLEAR PLANT f'

UNRESOLVED SAFETY; ISSUE A-46 The. status of activities related to the resolution of USI A-46, " Seismic Qualification of Equipment in Operating Plants," is outlined in a j

_ memorandum from H. R. Denton (NRC/NRR) to V. Stello (CRGR), reference 1.

1 This memorandum included a listing of nuclear plants which fall within the scope of A-46, i.e., those plants which have not been audited against the current seismic qualification criteria of IEEE 344-1975. TVA's Browns Ferry Nuclear Plant (BFN) is appropriately included in the list; also included, however, is the Sequoyah Nuclear Plant (SQN).

It is TVA's i

position that the inclusion of SQN is not appropriate.

The seismic qualification of the safety-related electrical and mechanical equipment at SQN has been thoroughly evaluated against current criteria as

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reflected in IEEE 344-1975 and Regulatory Guide 1.100. TVA's efforts to demonstrate that the equipment qualification complied with current criteria i1!l began with a presentation to NRC's seismic audit team headed by Dr. S. Hou i

(DSS /MEB) in 1976. With NRC concurrence, the presentation was generic in f;

nature and addressed two primary areas of concern.

1.

TVA's efforts on implementing new seismic qualification requirements of 4

IEEE 344-1975 standard.

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TVA's ef forts on verifying seismic adequacy for equipment tested under l1 the guidance of IEEE 344-1971 standard.

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.7-This initial effort to resolve the seismic qualification concern is documented in the audit team's trip report, reference 2.

Reference 2 also included a listing-of specific seismic qualification data for use by the NRC seismic audit team to verify TVA's position that the SQN equipment was adequately qualified against the IEEE 344-1975 criteria. The requested additional data was provided to NRC for technical review in February 1977, reference 3.

It was assumed that this additional data served to resolve the seismic concern until April 1979, when TVA received an NRC request via telecon f rom Dr. P. Y. Chen for still more information related to the data package submitted in February 1977. The requested additional data was transmitted in June 1979, reference 4.

This additional data was presented in such a way. as to further demonstrate that the SQN equipment seismic qualification program was consistent with the procedures of IEEE 344-1975.

Receiving no further comments or questions from the seismic audit team, it was of course concluded that NRC concurred with TVA's position regarding the adequacy of the seismic qualification program. This conclusion of adequacy is reflected in Supplement 1 of the SER (reference 5),

section 3.10, " seismic Oualification of Seismic catemory I Instrumentation and Electrical Eauipment." Here it is concluded that this equipment, e

originally qualified in accordance with IEEE 344-197], was evaluated against current criteria and was found to be accep Eble, thus satisfying the applicable requirements of General Design Criterion 2.

035343.03

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.2-3 TVA is, of course, fully committed to the resolution of the-seismic

. qualification concern at BFN through the program resulting from the A-46 effort.

It is felt, however, that this concern has been fully resolved to the satisfaction of NRC's seismic audit team for the SQN equipment and that no further effort in this regard is warranted. It is therefore requested that SQN be deleted from the list of A-46 facilities.

References:

1.

Harold R. Denton's memorandum to Victor Stello dated June 7,1985 (B41 851216 002).

2.

S. A. Varga's letter to Godwin Williams, Jr., dated November 16, 1976 (LES 761122 022).

3.

J. E. Gilleland's letter to S. A. Varga dated February 7,1977 (DES 770209 016).

4.

J. E. Gilleland's letter to S. A. Varga dated June 22, 1979 I

(A27 790621 011).

5.

NRC's NUREG-00ll, Supplement 1, Safety Evaluation Report related to operation of Sequoyah Nuclear Plant Units 1 and 2.

1 035343.03

-L44 860319'802 SN 157B Lookout Place March 19, 1986 e

Director of Nuclear Reactor Regulation Attention:

Mr. S. J. Youngolood, Project Director PWR Project Directorate No. 4 Division of Pressurized Water Reactors (PHRs) Licensing A U.S. Nuclear Regulatory Commission Hashington, D.C. 20555

Dear Mr. Youngblood:

In the Matter of the

)

Docket Nos. 50-327 Tennessee Valley Authority

)

50-328 As a result of recent telephone discussions with memoers of your staff, enclosed is a discussion regarding seismic qualification of equipment at Sequoyah Nuclear Plant (SQN).

The seismic qualification of safety-related electrical and mechanical equipment at SQN has been thoroughly evaluated by NRC's Seismic Qualification Review Team.

The enclosed discussion provides the factual information and documentation necessary to show that SQN should be removed from the list of plants "to be reviewed" under the scope of Unresolved Safety Issue (USI) A 46.

The results of the referenced NRC evaluations show.

that further evaluation under the scope of USI A-46 is not warranted.

It is therefore requested that SQN be deleted from the list of facilities "to be reviewed" under USI A-46 resolution.

Please inform me when SQN has been removed from the list.

If you have any questions regarding this subject, please call Joa Ziegler of my staff at FTS 858-8077.

Very truly yours, 1

l TENNESSEE '/ ALLEY AUTHCRITY R. Gridley Manager of Licensing j) i Enclosure cc:

See page 2 I

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' Director cf 'luclear Reactor Regulation Marcn 13. 1986 cc (Enclosure):

Mr. R. J. Clark Browns Ferry Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesca, Maryland 20814 Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stable Senior Project Manager PWR Project Directorate No. 4 Olvision of PWR Licensing-A U.S. Nuclear Regulatory Commission Washington. 0.C.

20555 8

Integrated Safety Assessment Program Directorate Olvision of PWR Licensing-B U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Or. T. Y. Chang Hall Stop 144 Engineering Issues Branch Olvision of Safety Review and Oversite U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Or. Jal Rajan Mall Stop P-712 Engineering Branch Olvision of PWR Licensing-B U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814

Ofrector of Nuclear Reacter Regulation Maren 19, 1986

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JAO:0EM:JDZ:KEH Enclosure cc (Enclosure):

RIMS, MR AN 72A-C H. L. Abercromole, ONP, Sequoyan H. C. Bibb, Browns Ferry H. C. Orotleff, H12 A12 C-K K. M. Jenison, Sequoyah-NRC R. B. Kelly, LP 4N 45A-C Browns Ferry Resident Inspectors-NRC H. S. Sanger, Jr., Ell B33 C-K F. A. Szczeoanski, BR IN 768-C K. H. Whitt, E3 A8 C-K bc (Enclosure):

R. E. Atsuo, LP SN 1378-C B. C. Morris, Browns Ferry D. L. Lambert, LP SN IISB-C R. H. Shell, LP SN 1558-C J. H. Sullivan, ONP, Seauoyan D. L. Williams, Jr., H10 885 C-K 0606h

ENCLOSURE

?

The status of activities related to the resolution of USI A 46, " Seismic

(

Qualification of Ecutoment in Operating Plants," is out!!nea in a July 7, 1985 NRC memorandum frcm H. R. Denten to V. Stello, CRGR (reference 1).

That memorandum ano also the enclosure to NRC's " Regulatory Analysis for Proposed Resolution of USI A 46...." included a listin'g cf nuct-ar olants wnich fall witnin the scope of A-46 resolution, i.e.,

those plants antch nave not been audited against the current seismic qualification criteria of IEEE 344-1975.

Our Browns Ferry Nuclear Plant (BFN) is accropriately included in the list; also included, however, is our Sequoyah Nuclear Plant (SONr. While TVA believes that resolution of USI A 46 is the accrocriate mecnanism to evaluate seismic adequacy of equipment in older plants, the inclusion of SQN is not appropriate.

The seismic qualification of safety-related electrical and mechanical eauipment at SON has been thoroughly evaluated against current criteria as reflected in IEEE 344-1975 and Regulatory Guide 1.100.

TVA's efforts to demonstrate that SON eautpment is seismically quallfled to meet current criteria began with a presentation to NRC's seismic audit team neaded by Dr. S. Hou (DS$/MEB) in 1976.

With NRC concurrence, the oresentation was generic in nature and acdressed two primary areas of concern.

TVA's efforts on implementing new seismic qualification requirements of IEEE 344-1975 standard.

TVA's efforts on verifying seismic adequacy for equipment tested under the guidance of IEEE 344-1971 standard.

This initial effort to resolve the seismic qualification concern is documented in the audit team's trip report, reference 2.

Reference 2 also included a listing of specific seismic qualification data for use by the NRC seismic aucit team to verify that the SON eautpment was adequately quallfled against the IEEE 34a-1975 criteria.

The requested additional data was proviced for NRC's Selsmic Qualification Review Team (SORT) for technical review in February 1977 (reference 3).

It was assumed by TVA that this additional cata terved to resolve seismic qualification concerns until April 1979, when TVA received an NRC request by way of telecon from Dr. P. Y. Chen for more information related to the data package submitted in February 1977.

The requested additional data das transmitted in June 1979 (reference 4).

This additional data was presented in sucn a way as to further demonstrate that the SON equipment telsmic qualificaticn program was consistent with the orocecures of IEEE 344-1975.

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-t-Receiving no further comments or cuestions from the SCRT, i yas concluded t

that NRC concurred with TVA's position regarding the 3decuacy'of SON's seismic qualification program.

This conclusion of aaeauacy is reflected in Supplement I of the SON safety evaulation recort (reference 5), section 3.10,

" Seismic Qualification of Seismic Category I Instrumentation and Electrical Equ i cme n t. Here it is concluced that the 504 equioment, artginally qualifiec in accordance with IEEE 344-1971, was evaluated against current criteria (i.e.. IEEE 344-1975) and was found to ce acceotable, thus satisfying the applicable recuirements'of General Cesign Criterien 2.

TVA agrees that using earthauake experience ~ data is the most reasonaole and cost-effective alternative for verifying selsmic adecuacy of equipment at SFN through the program resulting from the A-46 effort.

However, seismic qualification has been fully resolved to the satisfaction of NRC's SQRT for SQN equipment and no further effort in this regard is warranted.

References:

1.

Memorandum from Harold R. Denton, NRC, to Victcr Stello, NRC, dated June 7, 1985.

2.

Letter from S. A. Varga, NRC, to Godwin Hilliams, Jr.. TVA, cated November 16, 1976.

3.

Letter from J. E. Gilleland, TVA, to S. A. Varga, NRC, dated February 7, 1977.

4.

Letter from J. E. Gilleland, TVA, to S. A. Varga, NRC, dated June 22, 1979.

5.

NRC's NUREG-00ll, Supplement 1. Safety Evaluation Report related to operation of SeQuoyah Nuclear Plant units I and 2.

J0Z:KEH 3/19/86 0606h

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