ML20215D857
| ML20215D857 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/26/1986 |
| From: | Mcnutt G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215D785 | List: |
| References | |
| 226.0-(B), 226.0-(B)-R01, 226.0-(B)-R1, NUDOCS 8612170067 | |
| Download: ML20215D857 (25) | |
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p . TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
SPECIAL PROGRAM f7 REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 1 Q. - .
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TITLE: SEISMIC INTERACTION DESIGN Design of Lighting Fixture Supports PAGE 1 0F 22 REASON FOR REVISION:
Incorporated TVA line organization coments.
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ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- a 1' TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
< SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 22
- 1. CHARACTERIZATION OF ISSUE (S):
Concern: -
Issue:
WI-85-100-023 Lighting fixtures are not properly
" Lighting fixtures at WBNP are designed to prevent them from not properly restrained and becoming:
caged to prevent them from o Free missiles becoming missiles or swinging o Swinging missiles missiles during seismic events. which might damage Category I CI has no further information. equipment during a seismic event.
Anonymous concern via letter."
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by INP0 and Gilbert / Commonwealth Date See below Documentation Identifiers:
1.O}
V a. INPO Finding DC.3-2 in 1985 against WBN resulted in SCR WBN CEB 8537 and the subsequent SCR SQN CEB 8514 (12/24/85).
'b. Gilbert / Commonwealth (G/C) Report No. 2614 dated March 3, 1986, " Final Report - Technical Review of Sequoyah Nuclear Plant Modifications," Technical Issue No. 11.
NOTE: The Gilbert / Commonwealth Technical Issue specifically addresses the swinging seismic interaction of a Category I(L) two inch 0.D. pipe and a Category I valve. This Gilbert / Commonwealth Technical Issue will be resolved by closure of TVA generated SCR SQN MEB 8610 which will assess thehorizontalmovement(swinging)ofseismicCategoryI(L) supported items (including lighting fixtures) and their effect on adjacent seismic Category I items.
Category I(L) items are defined in FSAR Section 3.2.1 as follows:
01160 - 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: ~226.0(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 22 "Those components which are important to reactor operation but not essential to safe shutdown and isolation of the reactor and whose failure could not result in a release of substantial amounts of radioactivity, but are in close proximity to Category I components, have been seismically qualified to retain limited structural integrity during a SSE, if they have potential for compromising structures or components necessary to mitigate the [e]ffects of a design basis accident such as a LOCA or steam /feedwater line break."
- 3. DOCLDENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEE NT:
Lighting fixtures at WBN
- 4. INTERVIEW FILES REVIEWED:
The interview files for concern WI-85-100-023 were reviewed on 10/08/86 as indicated by RFI SQN #622 (10/08/86). The file
(~] r contains only the K-Form and Generic Applicability information.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA 7
< 'See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, t.ND OTHER DISCU55 ION 5 RELATtU TO ELEMENT.
See Appendix A.
01160 - 11/24/86
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 226,0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 22
- 8. EVALUATION PROCESS:
- a. Evaluated program to assure that lighting fixtures do not become seismic interaction items.
- b. Reviewed attachments to the two NRC letters from Youngblood to White (02/18/86) and (06/23/86) for possible additional relevant information.
- c. Obtained and reviewed design drawings for light fixtures.
- d. Reviewed selected calculations of light fixture restraints.
- e. Reviewed SQN program and results to date in resolving SCR SQN MEB 8610 and Gilbert /Comonwealth Technical Issue # 11,
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
(3 Chronology:
Time period cited in concern: Start of construction to present Light fixture vertical support addressed by TVA in design criteria
' SQ N-DC-V-13. l l : 03/23/73 >
Light fixture horizontal movement addressed by TVA in design guide DG-C.l.6.3: 07/25/78 Concern identified to TVA management: Prior to 06/08/84
- 'K-form provided: 12/07/85 INPO WBN Audit Finding 0C.3-2 regarding vertical and horizontal issues on generic rod hung items: Sometime in 1985 Resultant SCR SQN CEB 8514 addressing vertical issue: 12/24/85 G/C Report No. 2614 addressing horizontal issue: 03/03/86 Resultant SCR SQN MEB 8610: 03/03/86 01160 - 11/24/86
7 TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (8)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 22 ,
Discussion:
Light Fixture Support Criteria NRC General Design Criterion 4 requires that Category I structures, systems, and components be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. SQN commitment to comply with this criterion is contained in FSAR Section 3.2, (App. A, 6.a).
Position C-2 of Regulatory Guide 1.29, " Seismic Design Classification," (App. A, 6.b) states that those portions of structures, systems, or components that are non-Category I, i.e.,
I(L), but whose failure could reduce the functioning of a Category I item to an unacceptable safety level should be designed and constructed so that the Safe Shutdown Earthquake (SSE) would not cause such failure. SQN commitment to comply with this regulatory guide is contained in FSAR Section 3.2.1, (App. A, 6.a).
The design of SQN electrical system is based, in part, on Standard
' IEEE-308-1971 (App. A, 6.g) as stated in FSAR Section 8.1.5 (App. A, 6.a). This standard establishes and defines Class lE as the classification of electrical equipment required to achieve safe
~s hutdown. Based on evaluation team discussions with TVA personnel (IOM #357 and #371) (App. A, 7.m and n) SQN was originally designed with three lighting systems:
o Normal Lighting - This system is powered from non-Class lE power sources.
'~u SLandby Lighting - This system is normally powered from non-Class lE power sources and transfers to the on-site Class IE diesels upon failure of non-Class IE sources.
o Emergency Lighting - This system is powered from the on-site Class lE vital battery boards and is activated by failure of the of f-site sources and operates until transfer from the normal to standby system is completed when the diesels are fully functional. This 125 Vdc system is designed for 2-hour operation.
01160 - 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 6 0F 22 The structural support of these three systems is described in SQN-DC-V-13.ll (App. A, 6.c) and shown on drawing series 47A057 (App.A,5.u).
NCR SQN MEB 8304, R2 (App. A, 5.v) indicates that TVA committed to the NRC on 10/23/79 to provide a fixed self-contained second emergency lighting system consisting of fluorescent or sealed beam units with an individual 8-hour minimum battery power supply in areas that must be manned for safe cold shutdown and for access and egress routes to and from all fire areas.
This commitment was made in response to NRC review of FSAR for 10CFR Part 50, Appendix R requirements. The structural support for this system is not included in SQN-DC-V-13.ll (App. A, 6.c), but is shown on drawing 47N1410-1, R18 (App. A, 5.u).
TVA design criteria for seismic support of original design lighting fixtures in Category I structures are contained in Civil Design Guide DG-C1.6.3 (App. A, 6.d), which states that a literature survey of damage due to earthquakes finds lighting fixtures highly
% susceptible to failure. This is particularly true for dlv pendant-mounted fluorescent and incandescent fixtures. The
& criteria conclude that, with certain stated exceptions, the incorporation of an auxiliary support cable as an integral part of the light fixture is the most effective approach for ensuring an appropriate degree of seismic vertical restraint. This support is a 1/16-inch flexible corrosion-resistant cable (MIL-C-5424).
Additional requirements are imposed for the first emergency lighting system to maintain the electrical power supply to the fixture during or after a seismic event. This is accomplished by a three-way lateral cable support system which keeps the fixture in a
< ' plumb position.
Design Guide DG-C-1.6.3 (App. A, 6.d) further states that:
"In the event of a lighting fixture failure due to seismic conditions, motion of the fixture in any direction will be limited to the length of free cable. Care must be taken to eliminate or otherwise protect any safety-related equipment within the range of motion afforded by the cable from impact by the fixture."
0116D - 11/24/86
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i TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 7 0F 22 The evaluation team has reviewed these criteria in light of general engineering industry experience and determined that they are adequate.
< The SQN design criteria, which predate the civil design guide, for support of original lighting fixtures in Category I structures are contained in SQN-DC-V-13.11 (App. A 6.c), which forms the design commitment for SQN. The two sets of design criteria are very similar. With the exceptions noted later, after review of the 47A057 (App. A, 5.u) series lighting fixtures support drawing, the evaluation team determined that SQN-DC-V-13.11 (App. A, 6.c) criteria are adequate based on general engineering industry experience.
Criteria Application The implementation of the SQN design criteria is contained in the notes and details shown on the 47A057 (App. A, 5.u) series lighting fixture support drawing which is invoked by lighting plan and
/Q detail drawings such as 45N1410-1, 55N416-1, and 55N416.2 (App. A, QM/ 5.u). Individual lighting fixtures in nuclear industry facilities are typically light weight, generally 50 pounds or less and rarely exceeding 100 pounds. These weights are confirmed by SQN-DC-V-13.11 (App. A, 6.c) Section 4.0, which indicates weights
'in the 20 to 35 pound range.
Smaller and lighter fixtures have one auxiliary cable support at the fixture stem while larger and heavier fixtures generally have more than one stem with auxiliary cable supports at each stem. The minimum breaking strength of the cable is specified to be 480 pounds. The cable is generally attached to a single expansion
' anchor either 1/4- or 3/8-inch in diameter. Specification G-32 (App. A, 5.t) indicates allowable tension working loads of 500 and 700 pounds and shear working loads of 300 and 500 pounds. Thus the evaluation team concludes that the light fixtures are properly designed with adequate vertical support to withstand a seismic event. The evaluation team has reviewed this drawing series and concludes that it is technically adequate, subject to one observation which is similar to that for SQN-DC-V-13.ll (App.A,6.c). This observation is that Figure 5.0-1 of the design criteria SQN-DC-V-13.ll (App. A, 6.c) and the principal detail for emergency lighting fixtures on 47A057-21, R3 (App. A, 5.u) correctly illustrate application of Section 5.0 criteria .
0116D - 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 22 However, the details in Figure 4.7-1 for the emergency light and the alternate detail shown on 47A057-21 (App. A, 5.u) and the emergency light detail shown on 47A057-6, R5 do not agree with the text of Section 5.0 and with Figure 5.0-1.
The evaluation team reviewed drawings 47N1410-1, R18, 55N416-1, R18, and 55N416-2, R19 (App. A, 5.u) and noted that they refer to a battery pack enfergency light system that differs from the types described in either the SQN design criteria or drawing 47A057, as discussed earlier. This battery pack emergency lighting system is not required to withstand a SSE, as indicated by general note 5 of drawing 47N1410-1, but must be restrained from becoming a hazard to Category I systems during or following a SSE. These restraint details are shown as detail A of drawing 47N1410-1 and the evaluation team deems them to be adequate for the purpose.
Seismic Interaction Program The discussion below is not specifically about the support of
' ""' *'"' " " " """ ' ' '"' ""~"' '*""' '
TVA's seismic interaction program and the subsequent addressing of C%f e lighting fixtures as a component of that program.
In early 1986, Gilbert / Commonwealth (G/C) conducted a technical
' review of the SQN main and auxiliary feedwater systems modifications between issue of operating license and June 1985.
G/C Report 2614 (03/03/86) (App. A, 5.a) describes the approach, methodology, results, and conclusions of the technical review.
Technical Issue No. 11 of that report is titled " Seismic Interactions" and describes a condition where a 2-inch 0.D.
Category I(L) primary makeup water supply piping system was located
' near tubing supplying air to the auxiliary feedwater bypass valve 2-LCV-3-148A. This piping is not seismically restrained to prevent lateral displacement and the striking of the air supply line. G/C found no documentation to demonstrate that this interaction vould not impair the auxiliary feedwater system safety functions.
G/C also found that INP0 Finding DC.3-2 (1985) (App. A, 5.z) for WBN identified a proximity issue regarding displacement of Category I(L) piping systems as a potentially generic concern. This INPO finding and the resultant SCR SQN CEB 8514 (App. A, 5.v) address the position retention (falldown) but not the displacement (swinging) of a Category I(L) system. The TVA action plan to resolve G/C Issue No. Il resulted in the generation of SCR SQN MEB 8610 ( App. A, 5.v) .
01160 - 11/24/86
- ?*- TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER:'1 PAGE 9 0F 22 C,p[
During 02/12-03/14/86, the NRC staff conducted a special inspection
, -to examine design control practices for SQN. The main focus of this inspection was on the findings of the G/C technical review and additional items. The inspection results are contained in NRC I&E Inspection Reports 50-327/86-27 and 50-328/86-27 transmitted by NRC letter _from Taylor to White (04/22/86) (App A, 5.b). The NRC concluded that the G/C review was thorough and appropriate in technical depth within the selected review scope and that the technical and generic issues identified appear to be valid.
G/C Technical Issue No. 11 indicated that a proximity issue was identified with regard to the displacement of Category I(L) piping as a potentially generic concern by INP0 Finding DC.3-2 in 1985 for WBN (App. A, 5.z). This finding resulted in SCR SQN CEB 8514 (12/24/85 and 02/28/86) (App. A, 5.v). The INP0 finding states:
"An engineering evaluation has not been performed to justify the design criteria of seismically supported nonsafety (IL) [I(L)]
systems. The present design criteria for IL y [I(L)] rod hangers is not adhered to consistently. Some IL [I(L)] support designs do not consider all seismic loadings."
The INP0 finding contained the following as supporting f acts:
o Undocumented development of vertical load criteria for piping support rod hangers o Inconsistent factors of safety not meeting design criteria for piping supports
'o Undocumented development of flexibility criteria for HVAC duct rod hangers o The potential for rod hanger supported pipe displacing and impacting other nearby components / systems is not addressed o Rigid supports are interspersed with rod hangers in HVAC I(L) duct systems. Distribution of horizontal loads in a seismic event is not modeled consistently with actual structural behavior I
n, 01160 - 11/24/86
. 1 I TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 10 0F 22 Further Relevant Document Review 1
The evaluation team reviewed the attachments to NRC letters from Youngblood to White (02/18/86 and 06/23/86) (App. A, 5.c and d) for issues or information, relevant to this report, that are not included in the concern statement itself. No such issue or information was found in the February 1986 letter; however, on pages 131-133 of the attachment to the June 1986 letter, it became apparent to the evaluation team that the term " caged" used in the I concern relates to prevention of the light bulbs or tubes from falling out of the fixtures as a result of a seismic event. This associated issue does not appear to have been subjected to a documented review by TVA. However, the evaluation team's generic conclusion is that because light bulbs and tubes have brittle glass and light mass (usually one pound or less), they do not generally present a significant safety hazard that might ccmpromise the function of adjacent Category I equipment, which is of greater ruggedness and mass. According to criteria developed by the evaluation team for other nuclear power plant facilities, the item being struck will not generally be adversely affected if the size s% or mass of the striking item is less than or equal to that of the item being struck.
k(2})
Exceptions for this conclusion might be found in areas such as over the main control room semi-horizontal panels where plant operators or panel switches or buttons might be impacted. During the evaluation team walkdown during the week of 06/24/86 for evaluation of Element Report 224.5(B), it was noted that there was a grate or grid for diffusing light between the tubes or bulbs and the control panels which will mitigate any falling tubes or bulbs. Thus the evaluation team considers this associated issue to be of no safety significance.
TVA Evaluation of SCR SON MEB 8610 Inspection criteria for rod hung Category I(L) items are established in TVA memo from Handy to SQN Files (04/22/86)
(App. A, 5.k). This memo, which has been checked, reviewed, and approved by TVA, establishes a maximum horizontal displacement of
+ 6 inches for such pipes, conduits, HVAC ducts, and cable trays and a maximum horizontal displacement of + 10 inches or + 30 degrees swing angle, whichever is less, for pendant-mounted light fixtures.
01160 - 11/24/86
TVA ' EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1
[ifhh PAGE 11 0F 22
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Evaluation team discussion with TVA personnel (IOM #326, App. A, 7.k) indicated that there are no calculations or other documentation for these criteria which are based on informal studies of ground motion displacements at rock-based sites within the TVA service territory plus consideration of building movements during an SSE. TVA personnel committed to providing such documentation in IOM #326-(10/01/86, App. A, 7.k).
On the basis of evaluation team discussions with TVA personnel as documented in IOM #326 (App. A, 7.k), new Engineering Change Notices will address seismic interaction concerns as a part of the seismic review process. These new evaluations will be similar to, and compatible with, those completed under SCR SQN MEB 861C (App.A,5.v). This seismic review process will be in r.ecordance with CEB-DI-121.03, R1 (App. A, 6.f), ' Seismic Design, Review and Control." The CEB seismic evaluation for seismic interaction will include the following elements:
o Ensure equipment and systems will not have unacceptable impact from existing rod hung Category I(L) items A.
o Ensure that new roo hung Category I(L) items will not impact
(% J) existing Category I fragile items in an unacceptable manner These two elements are currently expected to be based on design
' consultation and walkdown information and evaluation. As these elements are currently based on verbal instruction, TVA personnel understand that there is a need to formally document this instruction by revision of CEB-DI-121.03.
A walkdown of the auxiliary building was conducted (March 8 and 9, 1986 and documented by TVA memo from Estes to Brown, 06/05/86,
' p. A, 5.n) to identify possit!e interactions between Category
'Ap(L)
I supported components and safety-related components which could result in degrading a safety system.
This TVA walkdown of the auxiliary building identified 204 possible interactions of which 98 were reviewed by CEB. The remainder were justified by EEB and MEG. Approximately 20 interactions involved lighting fixtures or stems. TVA concluded that 10 interactions -
none involving lighting - required field work. TVA determined that one of these ten interactions (one pipe potentially interacting with two separate air line solenoid valves) was due to seismic interaction considerations and that the remainder were due to other considerations.
0116D - 11/24/86 I
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 12 0F 22 q
A second walkdown of the control building, diesel generator building, additional diesel generator building, ERCW pumping station and the annulus areas of both Units 1 and 2 reactor buildings was conducted on 04/26-27/86, as documented by TVA memo from Estes to Brown (06/11/86) (App. A, 5.0), for similar purposes and with similar methodology as the first walkdown.
This TVA walkdown identified 90 possible interactions of which 49 were reviewed by CEB. The remainder were justified by EEB and MEB. There were two interactions involving lighting fixtures and/or stems. TVA concluded that two interactions - none involving lighting - required field work for reasons other than seismic interactions.
The first walkdown was surveyed by the TVA Quality Surveillance Group (on 04/18-22/86 and documented by TVA memo from Andrews to Wilson, 05/14/86) (App. A, 5.1), to assess the adequacy of the walkdown procedures and walkdowns performed by DNE in the auxiliary building. The weaknesses listed by this memo appear to the evaluation team to have been satisfactorily resolved based on review of the walkdown package.
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' U' S Technical Instruction TI-98, R0 (04/25/86) (App. A, 5.s) and a similar predecessor document were used to perform the walkdowns.
This instruction was reviewed and approved by PORC as documented by
'Unreviewed Safety Question Determination (USQD) for TI-98, R0 (04/25/86) (App. A, 5.s) in response to directions in TVA memo from Andrews to Abercrombie (04/18/86) (App. A, 5.j) that walkdowns or surveys of safety-related matters must be performed by PORC-reviewed instructions pending an approval programmatic instruction. The evaluation team reviewed TI-98 and concluded that it was adequate for its stated scope.
During review of the walkdown instruction and resultant documentation the evaluation team noted that portions of the auxiliary building and the contair.72nt vessel portion of the reactor buildings were excluded from the scope of the walkdowns.
l TVA's Action Plan to resolve G/C technical Issue No. 11 (02/24/86)
- (App. A, 5.a) committed to list, walkdown, and evaluate all Seismic I(L) systems for SQN. This committment was confirmed in IOM #416
! (11/19/86) ( App. A, 7.p).
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Oll6D - 11/24/86
. , ~. .
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 13 0F 22 The evaluation team notes the lack of a document describing the complete program for controlling this seismic interaction activity. The technical instruction will effectively implement the walkdown activities of this program. The TVA memo frcm Handy to SQN files (04/22/86) (App. A, 5.k) contains adequate threshold criteria for subsequent evaluations when its basis is adequately documented. The division of responsibilities between disciplines is defined in CEB-DI 121.03, R1, (App. A, 6.f). Such a program might include thresholds of fragility / ductility / flexibility to provide additional criteria for interaction resolution. The walkdowns and evaluations performed to date and those that are required to complete this effort will resolve near-term issues and j furnish an adequate baseline for future evaluations as additional plant modifications are made. Recognition of this future need is alluded to in item c. of block Se in SCR SQN MEB 8610 (App. A, 5.v), which states:
i
" Corrective action will be readdressed to the
' post-modification walkdown phase' rather than to the ' design phase,' and will be included in the acceptance criteria of a.b the post-modification walkdown."
ih9' TVA personnel committed to revise CEB-DI-12.1.03 to provide a complete program in IOM #416 (11/19/86) (App. A, 7.p).
~ The walkdown results are indicated on a marked set of plant drawings and a computerized listing attached to the two TVA memos I from Estes to Brown. The documentation of the EEB and MEB 2 evaluations appears to be principally the interaction resolution contained in the computerized listings (App. A, 5.n and o) while j that for the CEB is calculation CEB CAS 214, R1 (App. A, 5.w).
I i
' The evaluation team reviewed both the computerized listings of potential seismic interactions and the calculations and noted the following:
I o Many interactions are resolved by the notation that the
! nonrod-hung item is nondivisional, nontrained, etc. This is I
acceptable since neither item in the interaction is clearly required for safe plant operation or shutdown.
01160-- 11/24/86
- . TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 14 0F 22 o The evaluation team reviewed a copy of the CEB calculation (CEB-CAS-214) for lighting fixtures and other items included within the scope of SCR SQN MEB 8610 (App. A, 5.v). The calculation was reviewed for its assumptions, collection of data, logic, analysis, and conclusions. This calculation is based on photographs of the interaction, the interaction description in the computerized listing, the design cr,iteria in the TVA memo from Handy to SQN files (04/22/86)
(App. A, 5.k), and other data gathered during the walkdowns.
! The evaluation team considers the calculation to be generally adequate; however, additional written justification is needed in some areas to permit another engineer who did not participate in the original walkdowns to arrive at the same conclusions. During the discussions with TVA personnel (App.
A, 7.p) it became apparent that enhanced understanding may be obtained by viewing the original color photographs. During these discussions TVA personnel committed to have a supervisor re-review calculation CEB-CAS-214 in light of the above and any necessary changes to the calculations will be made at the time of additional walkdown evaluations.
The evaluation team considers the TVA action plan response to G/C Issue No. 11 and t.orrective action / action required to prevent recurrence portions of SCR SQN PEB 8610 generally adequate in concept. However, some deficiencies and discrepancies exist in TVA
' evaluations and design documents regarding prevention of lighting fixtures from becoming swinging missiles (seismic interaction) and the application of the lighting design criteria. TVA personnel committed to correct these deficiencies and discrepancies, as described in the findings below, in IOM #399 (11/14/86)
( App. A, 7.o) and IGM #416 (11/19/86) ( App. A, 7.p).
j Findings:
- a. The TVA design of light fixtures provides for adequate vertical support to withstand a seismic event and prevent their becoming free missiles that might damage Category I
. equipment. The TVA design of light fixtures, per se, does
- not, in general, provide adequate horizontal support during l and after a seismic event to prevent their becoming swinging i missiles that might damage adjacent Category I equipment.
l However, this design oversight has been documented on SCR SQN
! MEB 8610 (App. A, 5.v) and is being addressed.
m
+
Oll6D - 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM
, _ REVISION NUMBER: 1 PAGE 15 0F 22
- b. The evaluation team noted that there is no document which describes the complete program for controlling the seismic interaction design activity. Technical Instruction TI-98, R0 (App. A, 5.s) will effectively implement the walkdown activities of this program when amended to address all plant areas. The TVA memo from Handy to SQN files (04/22/86)
(App. A, 5.k) provides adequate threshold criteria for subsequent evaluations. The division of responsibilities l
. between disciplines is defined in CEB-DI 121.03, Rl, (App. A, 6.f). In addition, the CEB seismic review process for future reviews is to be in accordance with a future revision of CEB-DI-121.03, R1 (App. A, 7.o) and includes an evaluation for adverse impact of rod hung items as indicated by IOM #326 (10/01/86) ( App. A, 7.k). However, this evaluation is currently in the form of verbal instructions which TVA personnel have committed to properly document.
- c. Plant walkdowns and subsequent technical evaluations by TVA to resolve SCR SQN ME8 8610 (App. A, 5.v) excluded portions
- of the auxiliary building and the containment vessel portion (3)
(/
of the reactor building which were contaminated or required dress-out. Evaluations of these areas are necessary to determine the need for any potential hardware fixes. TVA personnel committed to perform a walkdown and evaluation of these areas in IOM #416 (11/19/86) (App. A, 7.p).
- d. The technical basis for the inspection criteria established in TVA memo from Handy to SQN Files (04/22/86) has not been documented. TVA personnel committed to providing such documentation in IOM #326 (10/01/86) (App. A, 7.k).
, e. The evaluation team considers calculation CEB-CAS-214, R1 generally adequate; however, additional written justification is needed in some areas to permit another engineer who did not participate in the original walkdowns to arrive at the same conclusions. TVA personnel committed to re-review the calculation based on the above and make any necessary changes (App. A, 7.p) .
- f. Figure 5.0-1 of the design criteria SQN-DC-V-13.ll (App. A, 5.r) correctly illustrates the criteria application of Section 5.0; however, the details in Figure 4.7-1 for the emergency light do not agree with the text of Section 5.0.
, h.
($ 3 01160'- 11/24/86
~
e f- i<
ig TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
< SPECIAL PROGRAM
._ REVISION NUMBER: 1 6
{-
l PAGE 16 0F 22 r g. The principal detail for emergency lighting fixtures on 47A057-21, R3 ( App. A, 5.u) correctly illustrates the E application of design criteria SQN-DC-V-13.ll, Section 5.0 (App. A, 5.r). 'However, the alternate detail shown on 47A057-21 and the emergency light detail shown on 47A057-6, R5 do not agree with the text of Section 5.0.
Conclusions:
}! The evaluation team concludes the issue of light fixtures not being i properly designed to prevent them from becoming free missiles is not a valid issue since TVA has provided a design that is adequate to keep the light within an arc radius of the length of the cable
( support. However, the evaluation team concludes that the issue of light fixtures not being properly designed to prevent them from becoming swinging missiles is a valid issue which has been recognized as indicated by TVA in its action plan response to G/C Issue No.11 and the generation of SCR SQN MEB 8610. The evaluation team considers the TVA action plan response to G/C Issue (o)
'v' No. 11 and corrective action / action required to prevent recurrence portions of SCR SQN ME8 8610 generally adequate in concept.
However, some deficiencies and discrepancies exist in TVA evaluations and design documents regarding prevention of lighting fixtures from becoming swinging missiles (seismic interaction) and the application of the lighting design criteria. TVA personnel
, committed to correct these deficiencies and discrepancies, as described in the findings above, in IOM #399 (11/14/86)
( App. A, 7.o) and IOM #416 (11/19/86) (App. A, 7.p). l g.
.w I
0116D~- 11/24/86 jL
m.
-TVA EMPLOYEE CONCERNS ~ REPORT NUMBER: 226.0(8)
SPECIAL PROGRAM
_ REVISION NUMBER: 1 PAGE 17 0F 22 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Gilbert / Commonwealth's " Final Report Technical Review of SNP Modifications for TVA," G/C Report No. 2614, Technical Issue Data Sheet No. 11(03/03/86)
- b. Letter from J. M. Taylor, NRC, Director of Office of Inspection and Enforcement to S. A. White, TVA,' Manager of Nuclear Power.
Subject:
"NRC Reports 50-327/86-27 and 50-328/86-27," [L44 860506 542], (04/22/86)
- c. Letter from B. J. Youngblood, NRC, Director PWR Project Directorate #4, NRR to S. A. White, TVA, Manager of Nuclear Power,
Subject:
" Concerns Regarding TVA Nuclear Program,"
[L44 860226 001], (02/18/86)
- d. Letter from 8. J. Youngblood, NRC, Director PWR Project Directorate #4, NRR to S. A. White, TVA, Manager of Nuclear Power,
Subject:
" Transcript of Interview ...," [none],
s (06/23/86)
Rankin, Manager Design Services.
Subject:
" Routing of Safety Related Conduits, Cable Trays, Piping and Instrument Lines in Nonseismic Designated Areas in Category I Structures," [825 851205 004], (12/05/85)
P. Vineyard, Project Manager.
Subject:
, Rev. 0," [S01 860102 805], (01/03/86)
Rankin, Manager Design Services.
Subject:
"SCR SQN NE8 8516 R0," [825 860107 011], (01/07/86)
N. Johnson, Civil Lead Engineer.
Subject:
"SCR 8610 Walkdown Civil Involvement," [B25 860408 002], (04/08/86)
Subject:
"Walkdowns conducted by DNE," [S08 860502 814], (05/14/86)
t L. Abercrombie, Site Director.
Subject:
" Conduct of Plant AM Walkdowns and Surveys," [S08 860418 811], (04/18/86)
Oll6D~- 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL' PROGRAM REVISION NUMBER: 1 PAGE 18 0F 22 APPENDIX A (cont'd) k.- TVA SQN memo from K. D. Handy, Mechanical Engineer to SQN Files.
Subject:
"SCR SQN NEB 8515 - Rod Hung Categor; I(L)
System Interaction Limits with Safety Related Targets -
Quality Design Information," [825 860422 008], (04/22/86)
Subject:
"SNP-SCR 8610
- Walkdown Civil Involvement," [825 860516 02?], (05/16/86)
Subject:
"SNP - Seismic Dead Load Supports Used for Class lE Electrical Conduit Installation," [B25 860603 013], (06/03/86)
Subject:
" Report of Results of March 8-9, 1986 Walkdown of the Auxiliary Building g for Interactions," [B25 860606 003], (06/05/86) p N:u o TVA SQN computerized "Walkdown Report for Seismic Safety Interfaces SQEP Mechanical Section No.1" for the Auxiliary Building attached to [B25 860606 003],
(04/17/86)
Subject:
" Report of Results of April 26-27, 1986 Walkdown of the U1 and U2 Annulus, Control and Diesel Generator Buildings, and the ERCW Intake Pumping Station," [625 860610 001], (06/11/86) a o TVA SQN computerized *Walkdown Report for Identifying Interactions in the Control and Diesel Generating Buildings, ERCW Pump Station and U1 and U2 Annulus,"
attached to [825 860610 001], (04/26-27/86)
Subject:
"Sequoyah Nuclear Plant - Design Input Memorandum for Location and Design of fiping and Supplemental Steel in Category I Structures - Design Criteria, SQN-DC-V-24.1," preliminary (10/03/86)
Subject:
" Auxiliary Building Pipin g Interaction Walkdown," [825 861014 015], (10/14/86) g 01160'- 11/24/86
t
[^~ TVA El#LOYEE' CONCERNS-SPECIAL PROGRAM REPORT NUMBER: 226.0(B)
' ~
REVISION NtMBER:.1 4
M
_ fii; _ ..PAGE 19 0F 22 - . .
APPENDIX A (cont'd)
~
- r. TVA Design Criteria / Guides:
~
- o. .TVA Design Criteria SQN-DC-V-13.11, R1,." Support of Lighting Fixtures in Category I Structures," (03/23/73) o TVA General Design Information, DG-C1.6.3, " Seismic Support of Lighting Fixtures-in Category I Structures,"
(06/05/81)
- s. TVA Procedures:
.o TVA SQN Technical Instruction TI-98 R0, "Walkdown Procedure for Identifying Interactions in the Control and Diesel Generating Buildings, ERCW Pump Station and U1 and U2 Annulus," (04/25/86) o TVA SQN USQD for TI-98 R0, (04/25/86)
- t. TVA Specification:
o TVA General Construction Specification No. G-32, Rev. 11, " Bolt Anchors Set in Hardened Concrete,"
[842 851216 500] (01/31/86)
- u. TVA Drawings:
o 47A057, R10, " Mechanical Seismic Supports - Lighting Fixtures"
, o 45N1410-1, R18, " Lighting - Plans and Details -
Elev. 653.0" o 55N416-1, R18, " Lighting - Floor Elev. 732.0 - Plans and Details" o 55N416-2, R19, " Lighting - Floor Elev. 732.0 - Plans and Details"
o NCR SQN MEB 8304, R2, [844 860404 007] (04/04/86) o SCR SQN CEB 8514, R0, [841851231021] and gyyn [841 860228 017], (12/24/85) and (02/28/86) o SCR SQN ME8 8610, R1, [844 860611047] (06/11/86) 0116D'- 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
SPECIAL PROGRAM REVISION _NIMBER: 1 ._
PAGE 20 0F 22 APPENDIX A (cont'd)
- w. TVA Calculation:
o CEB CAS 214, R1 " Evaluation of Walkdown Report for Seismic Safety Interferences," [B41 860516 004]
(05/16/86)
- y. TVA SQN work request nos. 107622, 107623 and 107627 dated 05/20/86, 03/09/86, and 03/09/86 respectively [ Interactions TPW/734/003; HVG/734/003; HVG/734/004]
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREAT 3 a. St? FSAR Update through Amendment 03 3 3.1 "Conformance with NRC General Design Criteria"
/ 3.2 " Classification of Structures, Systems and Components" 3.0 " Electric Power"
- b. NRC Regulatory Guide 1.29 R1, " Seismic Design Classification," (8/73)
- c. TVA Design Criteria SQN-DC-V-13.ll, R1, " Support of Lighting Fixtures in Category I Structures," (03/23/73) l d. TVA General Design Information, DG-C1.6.3, " Seismic Support
, of Lighting Fixtures in Category I Structures," (06/05/81)
- e. TVA Policy Memorandum PM86-04(DNE) from W. C. Drotleff, l Director of Nuclear Engineering to Those Listed.
Subject:
l " Engineering Judgment," [B20 860424 001], (04/25/86) l l f. TVA Design Interface Document CEB-DI 121.03, R1, " Seismic Design, Review, and Control," (05/16/86)
- g. IEEE Standard Criteria for Class lE Power Systems for Nuclear
- Power Generating Stations, IEE Std 308-1971 l
0116D'- 11/24/86 l
-e
~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 21 0F 22 APPENDIX A (cont'd) 7.- LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEENT.
- c. RFISQN#592(09/26/86)
- d. RFISQN#596(09/26/86)
- g. RFISQN#662(10/27/86)
(_./ i. TVA Transmittal #005, Item 30, (03/21/86)
- j. TVA Transmittal #116 (09/22/86)
- k. Telephone call from J. W. Benkert, Bechtel, to N. A. Liakonis and J. K. Rochelle, TVA, IOM #326 (10/01/86)
- 1. Telephone call from J. A. Utley, TVA, to J. W. Benkert, Bechtel, IOM #318 (10/20/86)
, m. Telephone call from J. W. Benkert, Bechtel, to P. N. Nesbitt and C. Sudduth, TVA, IOM #357 (10/31/86)
- n. Telephone call from J. W. Benkert, Bechtel, to C. Sudduth, TVA, IOM #371 (11/06/86)
- o. Telephone call from N. A. Liakonis, J. K. Rochelle, and W. H. Brown, TVA, to J. W. Benkert, Bechtel, IOM #399 (11/14/86)
- p. Telephone call from N. A. Liakonis and J. K. Rochelle, TVA, to J. W. Benkert, Bechtel, IOM #416 (11/19/86) k o
01160'- 11/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 226.0 (B)
SPECIAL PROGRAM REVISION NUMER: 1
,s F- PAGE 22 0F 22 CATD LIST j' The'following CATO forms are included as'part of this report:
226.00 SQN 03
~
a -
u l
i l
01160'- 11/24/86
ECTG C.3 Attachreent A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document ICATD)
INITIATION
- 1. Insuediate Corrective Action Required: 0 Yes
- 2. Stop liort. Reconenended: O Yes % No
- 3. X No CATD No. 2.7 6.0 0 - S at4- O 1 a. INITIATION DATE \\b rlB 6
- 5. RESPONSIBLE ORGANIZATION: TVA.-bME '
- 6. PROBLEM DESCRIPTION: O NQR v'L a o e-e_ % .7 - \ e-9 vvA h .:: % w. C <-L-\ e.%QRL% sG. N -sect v - is .ss cLoe s .cs oN-o_ c <-ei wL4% + be. A-ex4 oS Se.e_4 o % s. o e .%. '
4W s a. ~ o_ e_ v.L4 e, to . A W e. - w a_N e. cA.ca.N. N [
sb o ww o% w\Aost-6.Rs a. ~ c L W e. e% e. c e_m
\L ckN cA.e.4 e * \ do w o4 ' a. s .- e e. w '.4% -N-b =_ 4414 o S.'* S e c. 4 t. o % so o 4- S an't oc. -v - va sN.
// /
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O ATTACHMENT 5
- 7. PREPARED BY: NAME h W MU
- 8. DATE: wbri e 6 CONCURRENCE: CEG-Hp41 h m , AWh/d- '
DATE: Il-7Aiv4 i
- 9. APPROVAL: ECTG PROGRAM'MGR. O DATE:
RRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
i l
i i
i O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H:
__ DATE:
SRP: DATE:
ECTG PROGRAM MGR: _ DATE:
VERIFICATION AND CLOSEOUT 13.
Approved implemented.
corrective actions have been yerified as satisfactorily Caj SIGNA!URE IITLE DA E
.;r
- ECTG C.3 .
=-
Attachment A
. Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracking Document (CATD)
INITIATION
! 1. Inunediate Corrective Action Required: M Tes O No
- 2. Stop Work. Reconunended: 0 Yes % No
- 3. CATD No. 2.? G. OO -SGLN - O 2. 4 INITIATION DATE \k7 ME4 l
- 5. RESPONSIBLE ORGANIZATION: T V A -- bNE '
- 6. PROBLEM DESCRIPTION: XQR O NQR T- V A c_a \cv\a.4% o w
, C.E % C A5 7 \'t. R,\ s e, e. d.s ee.- ee.v Lau 4 o t-
- m. A.a a % c.m oe'w r W=w -V e_ b ;- \ h sk r,tc. w os, i wa c.J. .\t^4-=. o-e=<. e.mts%s -4 ." 4.a.se.es% t
- a. A. eok.4 o\ +k.s s o.t.3, d A + a .-a. V ,o ~
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- 4. . c. TvA m e. - o 4. .- . % W a.. d.w V s,ca,M .%.,No.s tow \"t %\%T ,,\ '
O ATTACHMENTS
- 7. PREPARRD Bt: NAME A W W /(U DATE: w\s.w\se l g 8. CONCURRENCE: CEG-H14b h .2 R N tW DATE: I(-24-80.
- 9. APPROVAL: ECTG PROGRAM MGR. O DATE:
CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
i a
l l
l O ATTACHMENTS t
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
SRP: DATE: ,
ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEQUT
- 13. Approved corrective actions have been verified as satisfactorily implemented.
l l
l SIGNATURE TITLE DAIE
I 1 4. , ,
, l ECTG C.3 Attachment A Page 1 of 1
~', Revision 2 - A g_ _ ,
ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Inusediate Corrective Action Required: k Yes O No
- 2. Stop Work Reconumended: 0 Yes X No
- 3. CATD No ,'2. L 6. 0o- 544- o 3 4 INITIATION DATE \\ l'2.M %
- 5. RESPONSIBLE ORGANIZATION: T Ni A - O M E. '
- 6. PROBLEN DESCRIPTION: KQR O NQR v st A e_v mA w =_-h-\ oAs e4
%C R % GLM f% e.1h a c. A o e_ x e_b cla_J o a n.s .4 %e_
o wv*A's a. s b *Ask' wa n w d., A \.at e-e_ ce_-k o e-
% W A ct m % w s* .Q.e_ *-N.A.a_ e_esm4af w a 4 o.-e ss.u .e?' ve__s sa\ n o .--\ ' . w .
o\ O ATTACHMENTS i 7. PREPARED BY: NAME R AA C L+ fMA) DATE: \\\ r wlh
- 8. CONCURRENCE: CEG-HgAd & TLMc W DATE: 1L32t_-lisb
!4 9. APPROVAL: ECTG PROGRAM MGR. O DATE:
CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
I i
l 9
O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
SRP: DATE:
ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEOUT hl
- 13. Approved corrective actions have been verifled as satisfactorily implemented.
SIGNATURE TITLE DATE
- - _,