ML20216E681
| ML20216E681 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/03/1997 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216E687 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9709110047 | |
| Download: ML20216E681 (47) | |
Text
I Station Support Department
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PECO NUCLEAR nco e, c-,
965 Crmtertwook Doulevard A Unit of PECO Energy wayne. m 19m7.se91
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September 03,1997 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR 56 U. S. Nuclear Regulatory Commission Attn. Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3, Request fcr Additional Information Regarding Generic Letter 87-02 on the Resolution of Unresolved Safety issue (USI) A-46
References:
- 1) Letter from G. J. Beck (PECO Energy) to USNRC Document Control Desk dated September 18,1992 (GL 87-02, Supp.1, 120 Day Response)
- 2) Letter from G. A. Hunger, Jr._(PECO Energy) to USNRC Document Control Desk dated January 24,1994 (Supplemental Response to Generic Letter 87-02, Supp.1)
- Document Control Desk dated May 7,1996 (Summary Report L
for Resolution of USI A-46)
Dear Sir:
The subject request for additional iaformation (RAI) regarding Generic Letter (GL) 87-02, on the resolution of USl A 46 at Peach Bottom Atomic Power Station dated June 5,1997, requested that PECO Energy Company (PECO Energy), respond within 90 days of the date of the letter with additional information regarding PECO
/
Energy's Peach Bottom Atomic Power Station Summary Report for Resolution USI A-46 (ref. 5).
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September 03,1997 Page 2 in responst to NRC Generic Letter 87-02, the SQUG (A-46) program was
- developed to verify the seismic adequacy of equipment of older plants. The SQUG (A 46) Program was performed using the ' Generic implementation Program (GIP) for Seismic Verification of Nuclear Plant Equipment" Rev. 2. The SQUG (A-
- 46) program is outside the scope of commitments made in the UFSAR and Technical Specifications which form the basis of the operating license of the plant.
It is critical to note that the information provided as enclosures to this response (including calculations, tables, figures, prints, etc.) is dynamic by nature and, while this provides an accurate description of the present, PECO Energy will continue to revise design documentation in accordance with the approved revision processes and the applicable regulatory requirements, without modification of this response, information (e.g., program documents, correspondence, etc.) referred to in this response is contained in docketed correspondence or is available for your review.
This letter p,ovides the requested additional information. In Attachment 1 to this letter, the NRC request is restated, followed by the PECO Energy response.
if you have any questions, please do not hesitate to contact us.
Very truly yours, G. A. Hunger, Jr.,
Director - Licensing Enclosed: Affidavit, Attachment 1 with enclosures cc: H. J. Miller, Administrator, Region I, USNRC
.W. L. Schmidt, USNRC Senior Redent inspector, PBAPS W
COMMONWEALT'H OF PENNSYLVANIA :
- ss.
COUNTY OF CHESTER .:
J. B._ Cotton, being first duly swom, deposes and says:
That he is Vice President of PECO Energy; the Applicant herein; that he has read the attached response to the NRC Request for Additional Information regarding Generic Letter 87-02 for Peach Bottom Atomic Power Station, Units 2 and 3, Facility Operating License Nos. DPR-44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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fW Vice President Subscribed and sworn to before me this 3 day -
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Attachment 1 6 :[
t 89.131 Where references are cited in this document without association with another document, (e.g., Reference 1) they are listed at the back of this document.
Reauest #1
' The conservatism of the seismic margin methodology in the EPRI NP-6041 procedure is not certain at this time, when compared to the GIP 2 guidelines. Its application is, therefore, not endorsed by the NRC for the analysis of safety.
related system and components, including the resolution of USI A 46 mechanical, electrical, and structural component outilers. You are requested to
. re-evaluate your USI A 46 program if the above methodology has ever been used, end ensure that all the outilers identified in the Peach Bottom Units 2 & 3 A-46 program are resolved by using the plant licensing basis methodology or other.
approaches acceptable to the staff.
Response: .
The USl A-46 program for Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3 did not utilize the_ seismic margin methodology of the EPRI NP-6041 procedure to screen out any components on the USI A-46 Safe Shutdown Equipment List (SSEL). ,
L Elements of the seismic margin methodology were used, however, to resolve outilers, as discussed below. ,
Section 5.3 of the GIP-2 discusses several generic methods for resolving outtlers identified during the USl A-46 program. It also states that details for
. outlier resolution are beyond the scope of the GIP-2 procedure, in addition, section 5.3 states that "It is permissible to resolve outliers by performing additional evaluations and applying engineering judgment to address those
- ' areas which do not meet the screening guidelines contained in the GlP. Strict
.- adherenco to the screening guidelines in the GIP is not absolutely required".
P Enclosure 1.1 to this response lists the PBAPS USl A-46 mechanical and electrical components (excluding relays) identified as outliers where the EPRI NP-6041 methodology was used for resolution. The list of relays can be found in Attachment F to the. Relay Evaluation report, in the section titled " Resolved Outlier Relays." The affected relay contacts are those identified on the included Outiler Seismic Verification Sheets with " Capacity vs. Demand
- as the outlier -
issue.
s Page 1 of 26
Attachm:nt 1 All other outliers were resolved using licensing basis methodology or generic methods outlined in the GIP-2.
The outiler resolutions that utilized the EPRI NP-6041 methodology for the PBAPS Units 2 and 3 can be categonzed as follows:
+ Capacity Vs. Demand Outlier Resolution
- Relay Capacity Vs. Demand Outlier Resolution Capacity Vs. Demand Outlier Resolution For those components identified as outliers due to demand exceeding capacity, the PBAPS USl A-46 program scaled down the " Realistic, median-centered" in-structure IPEEE respcase spectra that were developed for the various structures. The IPEEE spectra for the PBAPS structures were developed using NUREG/CR 0098 median spectral shape anchored to an 84% non-exceedance probability (NEP) 0.3g peak ground acceleration (PGA). The GlP-2 states that "If in-structure response spectra have been developed for the IPEEE, based on the realistic, median-centered methods described in section 4.2.4 using a median spectra shape ground response spectrum (GRS), then the IPEEE in-structure response spectra may be used to generate realistic, median-centered, in-structure response spectra (ISRS) for use in the USl A-46 program by scaling down the IPEEE spectra an appropriate amount".
For the majority of outliers, the methodology of section 4.2.4 of the GIP-2 was used for scating down the IPEEE spectra. For components located in Diesel Generator bldg. elevation 127', Reactor bldg. elevation 195', and Emergency Cooling Tower elevations 153' and 192', however, a modified approach of the methodology given in section 4.2.4 of the GIP-2 was used. The ratio at the peaks of the GRS to the IPEEE review level GRS was used to scale the IPEEE spectra. The technical basis for this approach is based on the correlation of the results of the scaling as compared to the recently developed ISRS for the Radwaste/ Turbine building which demonstrates that the modified approach produces similar results for the PBAPS site. Therefore, it is PECO Energy's conclusion that the PBAPS USI A-46 program capacity vs. demand outliers were resolved in accordance with the GlP-2 recommended guidelines and thus are acceptable for the outlier resolution of the USI A-46 pregram.
Page 2 of 26
Attschment 1 Relav Capacity Vs, Demand Outlier Resolution To resolve relay capacity vs. demand outliers, the PBAPS USl A-46 program scaled down the " Realistic, median-centered" in-structure IPEEE response spectra for the relays host cabinet located in the Reactor building at floor elevation 135'. The scaled down IPEEE spectra (i.e., " realistic median-centered" A-46 in-structure spectra) were developed in VECTRA calculation 0067-00084- '
C-014. The seismic demand for the relays was calculated in accordance with the requirements of section 6.4.2 of the GIP 2 (i.e., demand = IRS *FS*AF; where: IRS = realistic, median-centered (RRS) A-46 spectra, FS = 1.5 for RRS, and AF = the applicable in-cabinet amplification factors from table 6-2 of GlP-2).
As concluded in the above response, the relay outlier resolutions were performed in accordance with the GIP 2 guidelines and thus are acceptable for the outlier resolution of the PBAPS USI A-46 program.
if Additional relay outliers were resolved for host cabinets located in the RadwasterTurbine building at floor elevation 100' The in structure spectra that were used to resolve the relay outliers were developed in VECTRA calculation 0067-00084-C-020," Clipped A-46 Spectra for Radwaste/ Turbine Building". The spectra were dsveloped by clipping the in-structure Radwaste/ Turbine building -
USl A-46 spectra that were generated in VECTRA calculation 0067-00084-C-005A,"Radwaste/ Turbine Building A-46 Spectra." The clipping of the spectra was in accordance with Appendix Q of EPRI NP-6041. Enclosure 1.2 shows the 5% damped A-46 horizontal spectra for the Radwaste/ Turbine building elevation 150' and the corresponding clipped spectra.
A comparison of the unclipped A-46 and clipped A-46 spectra for the Radwaste/ Turbine building shows that the E-W direction peak acceleration reduced from 0.61g to 0.5g and the N-S direction peak acceleration reduced from 0.68g to 0.56g as a result of the clipping performed in accordance with Appendix Q of EPRI NP-6041.
The reduction in the peak seismic demand spectra when combined with the generic amplification factors (AF) and the additional GIP-2 conservatism factor (FS) of 1.5 discussed above produce a demand spectra for the subject relay outliers that is conservative. Therefore, the relay capacity vs. demand outlier resolution that utilized clipping of the " realistic, median-centered" A-46 in-structure response spectra is acceptable for the outlier resolution of the PBAPS USl A-46 program.
Page 3 of 26
Att: chm:nt i Reauest #2 Adequacy of Seismic Demand Determination (Ground Spectia and ,
In Structure /FloorResponse Spectra)
Referring to the in structure response spectra provided in your 120-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 response spectra (5% critical damping) for elevations within 40-feet above the effective grade, which are hlcherin amplitude than 1.5 times the Selsmic Qualification Users Group (SQUG) Bounding Spectrum.
Response
The structures exhibiting the above-stated criteria are the following:
Emergency Cooling Tower (ECT) Elevation 153'-0 Diesel Generator Building (DGB) Elevations 127'-0,151'? s 31'-0 Circulating Water Pump Structure (CWPS) Elevation 116'-u The Radwaste Building also exhibits this criteria tvith respect to the 120-day response in-structure response spectra. However, this question is no longer applicab!e to this building because realistic, median-centered in-structure response spectra were rigorously developed for it subsequent to the 120 day response, The procedure to develop these response spectra was accepted in a safety evaluation report that was transmitted to PECO Energy in Reference 3.
These spectra were then used to define seismic demand for a capacity / demand review in accordance with Method B in Table 4-1 of GIP-2,
- b. With respect to the comparison of equipment seismic capacity and seismic .
demand, Indicate which method in Table 41 of GIP-2 was used to evaluate the seismic adequacy for equipment Installed on the corresponding floors in the structure (s) Identitled in item (a) above. If you have elected to use Method A in Table 4-1 of the GIP-2, provide a technicaljustification 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 earthquaks (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 plant foundation level. The SQUG Bounding Spectrum is defined at the free field ground surface. For plants located at deep soft or rock sites, there may not be a significant difference between the ground motion amplitudes at the foundation level and those at the free field Page 4 of 26
AttCchment 1 ground surface. However, for sites where a structure is founded on -
shallow soll, the amplification of the ground motion from the foundation level to the group surface may be significant.
Response
For alllisted elevations in the ECT, DGB, and CWPS Method A was used.
PECO Energy believes this is an appropriate use of Method A, based on guidance in the GIP and further clarification provided by SQUG in Reference 4.
This information is consistent with the IN-STRUCTURE RESPONSE SPECTRA section of the PECO Energy 120 day response. The discussion provided below repeats pertinent aspects of that reference and includes related information specific to PBAPS.
Method A of GIP Table 4-1 provides a methodology to evaluate the seismic adequacy of equipment by comparing equipment capacity based on earthquake experience ground response spectra at database sites with the plant's SSE ground response spectrum (GRS). The composite earthqt.ake experience ground response spectrum from the database sites (reference spectrum) is reduced by a factor of 111.5 to account for possible additional amplification of mntion in nuclear plants compared to database plants and is referred to as the
" Bounding Spectrum' in the GIP.
The seismic capacity of equipment defined by the Bounding Spectrum is compared to the seismic demand at the effective grade using the plant licensing basis SSE GRS. The GIP method conservatively limits use of this approach to equipment which has natural frequencies above about 8 Hz and is located lower than about 40 feet above the effective grade of the building. These restrictions prohibit the use of GIP Method A for those equipment natural frequencies and for those higher elevations in buildings where equipment amplified responses are typically higher.
Additional details justifying the use of GIP Method A may be found in the report "Use of Seismic Experience in Nuclear Power Plants," prepared by the Senior Selsmic Review and Advisory Panel (SSRAP), February 28,1991. This report, included as Reference 5 in GIP-2, summarizes SSRAP's judgment on this subject by stating on Pages 102 and 103 that:
. . . the use of very conservative floor response spectra should be avoided when assessing the seismic ruggedness of floor-mounted equipment. . . . Only for cases of equipment mounted more than 40 feet above grade or equipment with as-anchored-frequencies less than about 8 Hz is it necessary to use floor spectra.
Page 5 of 26 i
l Att:chment i PECO Energy also recognizes that there is a continuing dialogue between SQUG and the USNRC regarding definition of the location of the SSE ground -
motion response spectrum. PECO Energy agrees with the SQUG positiori that, from a licensing perspective,.the statement that "the SSE ground motion response spectrum . . . is defined at the plant foundation level" is not accurate.
For PBAPS, the location of the SSE ground response spectrum is not defined in the licensing basis documents. During the design of plants such as PBAPS, however, it was common industry practice to " apply" the SSE GRS of the site to the base of building models to conform to the existing state-of-the-art soil structure interaction analysis techniques of that time frame. This is a simplified bounding assumption in which the SSE GRS is conservatively applied at the base of each building analyzed at a site, regardless of the depth of the building embedment. For example, a review by SQUG of analyses performed at several SQUG plants shows that the SSE GRS defined at the ground surface (or not defined)wat applied to the base of the models of reactor buildings (typically embedded about 50 feet) and also to the base of the models of diesel generator buildings (typically embedded less than about 15 feet). In the original design cf PBAPS, this practice resulted in applying the SSE GRS to seismic models of buildings at elevations ranging from 76'-10' to 135'-0". SQUG and PECO Energy do not believe it is correct to state that the SSE ground motion response spectrum is " defined' at the plant foundation level simply because the analytical methods used to generate in-structure response spectra conservatively applied the input motion at the base of the building models.
Therefore, PECO Energy considers the PBAPS SSE GRS to be defined at the free field ground surface and to be representative 'of the ground motion at each building's effective grade in accordance with the guidance in the GIP. For the Emergency Cooling Tower and the Circulating Water Pump Structure this is the same as the top of the foundation. For the Diesel Generator Building the effective grade is twenty-two feet above the foundation,
- c. For the structure (s) Identified in Item (a) above, provide the in-structure response spectra designated according to the height above the effective 7 grade. If the in-structure response spectra identified in the 120-day response to Supplement No.1 to Generic Letter 87-02 was not used, provide the response spectra that were actually used to verify the seismic adequacy of equipment within the structures identified in item (a) above.
Also, provide a comparison of these spectra to 1.5 times the Bounding Spectrum.
Be_soonse:
The requested in-structure response spectra are provided in Enclosure 2.1 Also shown on these figures is the 1.5 times the Bounding Spectrum (B.S.).
Each plot of response spectra is the original 2% structural damping OBE curve Page 6 of 26
Att chment 1 that has been conservatively multiplied by 2.4 to convert it to an SSE curve wiihout benefit of higher structural damping allowable for SSE building analysis, L as described in Sections 3.5.1 and 3.5.2 of the summary report. On these plots the in structure spectra are labeled "SSE ISRS," and the amplified bounding spectrum is labeled "1.5X B.S."
The response spectrum that was used to define seismic demand for the locations listed in item (a) above is the SSE ground response spectrum at 5%
damping. For application of Method A, this spectrum was compared directly to the SQUG Bounding Spectrurn. The SSE ground response spectrum is shown on Figure 3.5-2 of the PBAPS USI A-46 summary report. This spectrum is completely enveloped by the SQUG Bounding Spectrum, i
4 Page 7 of 26
Attachment 1 Reauest #3 For those components listedin Table 4.21 of the Seismic Evaluation Report, which are inaccessible during the walkdowns, the proposed methods of evaluation are based on general area walkdown, similarity to Unit 3 components, .
similarity to other components on the SSEL list, and drawings revicw. You are requested to provide responses to the following comments .
- a. The generalpurpose of the equipment screening and walkdowns is to
, ensure the adequacy of the original seismic design; particularly, general Installation, welded and embedded connections, and anchorages, as weII as interaction concerns. Explain how these objectives could be accompIlshed based on similarity to other components.
Resoonse:
NOTE: Before responding to this request the following correction to Table 4.2-1 is presented (corrections are highlighted)
Oriainal Submittal Class Component Description Method of Evaluation RWCU Inlet Inboard SRT looked at robot video 8A M02-12-015 Isolation Valve RWCU Inlet Outboard 8A M02-12-018 Isolation Valve General area walkdown and drawing review
, Corrected Table Class Component Description Method of Evaluation RWCU Inlet inboard General area walkdown>
8A M02-12-015 - Isolation Valve an'd drawing review; -
RWCU Inlet Outboard .SRT looked at robot video;
' ~
-8A Wl03-1'2'-0185 Isolation Valve camera -
The Seismic Review Team (SRT) made every effort to walk down all components listed on the PBAPS USl A-46 program. However, the components listed on Table 4.2-1 of the seismic evaluation report as inaccessible could not Page 8 of 26
Attachment 1 l be walked down by the SRT due to being physically inaccessible, having outage l maintenance work performed, or being located in high radiation areas where access was not allowed by health physics (HP). The 21 inaccessible
- components listed on Table 4.2-1 can be grouped as follows: :
+ In-line components such as relief valves, isolation motor-operated valves, solenoid-operated valves and ventilation dampers (total of 13 components: VRV2-2-8096C, VRV2-2-8096D, RV2-02-71 C, RV2-0?-71 D, MO2-12-015, MO3-12-018, SV-81308, P020223-1, P020223-2, PP0223-3, P020223-4, P030223-1, P030223-3);
. Buried Diesel Generator oil storage tanks (total of 4 components: 0AT38, OBT38, OCT38, ODT38); and
- Tornado missile protected Diesel Generator supplement supply fans (total of 4 components: 0AV091, OBV091, OCV091, ODV091).
The discussion that follows will provide the explanation and guidelines the SRT used to conclude that these inaccessible components screened-out in accordance with the GIP-2 criteria.
in-Line Components The in-line inaccessible components are inherently rugged components as long as the Piping /HVAC systems are adequately support 3d and the GIP-2 caveats are met, including interaction concerns. In the majority of cases the SRT walked down the general area in which the components were located to check for any interaction concerns with nearby or overhead plant systems. The SRT concluded that interaction concerns were not an issue with the subject components since the systems that could cause interaction concerns were well supported, and in addition, other similar components that were walked down on the corresponding areas of PBAPS Unit 2 or Unit 3 were interaction free. In general in-line components do not require an anchorage evaluation and thus SitT inspection of general installation, welds and embedded connections is not required.
The SRT, in addition to the general walkdown of the area, reviewed the applicable component drawings to screen-out the GIP-2 caveats. The SRT walked down approximately 350 similar components between both units of PBAPS and determined that the plant design drawings were in good agreement with the as found condition of the plant SSEL components. Based on the above discussed information, the SRT concluded that the 13 in-line mechanical inaccessible components met the GIP-2 requirements and thus screened-out.
Page 9 of 26
Attachment 1
\-
Buried Diesel Generator (DlG) Oil Storace Tanks l The four DIG tanks are buried in the ground surrounded with backfill soil and thus the SRT could not physically inspect them. Entry into the access pit
- requires special authorization since it is a " confined space". The SRT performed a general walkdown of the area above the tanks and did not identify any overhead systems or equipment that may impact the tanks or their connections.
l Therefore, the SRT concluded that the buried tanks are free of any interaction concerns. The SRT reviewed the design basis tank drawings to determine the structural anchorage details. Each tank is supported by a continuous concrete saddle and is anchored to the concrete mat with 8 straps. Each strap is 1/2" thick by 4' wide and each end of the strap is welded to a clip ongle 4*x4'x1/2*x5" long; the angles are anchored to the concrete mat with 1 1/2" diameter cast-in-place J-bolts that have a 4-foot embedment. The concrete base mat and access pits are reinforced concrete structures with standard structural concrete details.
The hatch covers are adequately attached to the reinforced concrete box structures. Based on the detailed review of the design basis documentation and the general area walkdown the SRT concluded that the DIG oil storage tanks met the GIP-2 requirements and thus ccreened-out.
Tornado Missile Protected DIG Suoolement Sucolv Fans The four DIG vent supplement supply fans are located on the lower roof of the DIG building and are enclosed by Tornado Missile Barriers. Access to visually inspect the fans is not possible without removal of the missile barriers which are welded to embedments around the opening. The SRT performed a general walkdown of the area and did not identify any overhead systems or equipment that may impact the fans or their connections. Therefore, the SRT concluded that the fans are free of any interaction concerns. The SRT reviewed the design basis fan drawings to determine the structural anchorage details. The fans are anchored with four 1/2" diameter Redhead anchors, A conservative anchorage analysis was performed using a conservative fan weight of 2000 lbs, a bolt circle of 42 inches (actual fan diameter is greater), minimum bolt embedment and an edge distance of 21/2". The minimum safety margin of the anchorage evaluation is 3.48. Even if a 50% reduction to the anchor bolt capacity is taken to account for the fact that a tightness check was not performed on the expansion anchors, the anchor capacity will still be larger than the demand (i.e.,
SF = 0.50
- 3.48 = 1.74 > 1.0). Based on the detailed review of the design basis documentation, the anchorage evaluation and the general area walkdown the SRT concluded that the DIG vent supplement supply fans met the GIP-2 requirements and thus screened-out, it should be noted, with respect to the anchorage verification of the buried D/G oil storage tanks and D/G vent supplement supply fans discussed above, the Page 10 of 26 4
l l
AttCchmont 1 .
1 GIP-2 recognizes that it may not be possible to visually inspect all bolts. Section 4.1.4 of GIP-2 states the following: "All required anchorages of safe shutdown equipment will be inspected unless otherwise justified by the licensee, based on other anchorage evaluation results, radiation dose concerns, or other factors' The SRT attempted to visually inspect and verify all of the safe shutdown equipmmt anchorage but for reasons explained above was unable to do so, it is the SRT's judgment that the GlP-2 allows for the equipment anchorage to be evaluated based on design basis documentation review and sound engineering judgment based on the entire PBAPS USI A-46 program anchorage evaluation.
Therefore, the conclusions reached by the SRT with respect to inaccessible safe shutdown components meet the GIP-2 requirements.
- b. Explain what is meant by "similar to Unit 3 components," and how the
" Unit 3 Components" can be used for similarity comparison in walkdowns, if they are Inaccessible as well.
Response
It shculd be noted that the PBAPS Units 2 and 3 are almost identical plants.
Therefore, systems and components have the same layout or are mirror image to the other Unit. Minor differences between the two PBAPS Units were evaluated by the SRT using engineering judgment and determined to be inconsequential.
The term *Similar to Unit 3 components' as is applied to the PBAPS USl A-46 inaccessible components means the following:
- The component is of the same GIP-2 equipment class, but it may not be the specific counterpart in the other Unit.
. The Unit 2 component is located in the same area as the similar component on Unit 3. For example, if the component that was inaccessible on Unit 2 is an MOV, it is the same pipe size as the Unit 3, the MOV orientation is the same, the piping configuration and supports are similar, spatial configuration is the same, and interaction concems were judged to be the same as Unit 3.
- Based on the design basis documentation review, the SRT determined that the component is the same size and the caveats are the same for both Units. In addition, the anchorage for the two components is the same (i.e., same bolt sb:e and type but spacing of anchors may not be identical).
Page 11 of 26
l Attachm:nt i In screening out the inaccessible components listed on Table 4.2-1, by making ,
reference to a Unit 3 component, the SRT made sure that the Unit 3 component )
was accessible and thus was walked down, was the same class and located on j the same system and the component met the GIP 2 criteria. The discussion to RAI question 3a shows that eight (8) components (i.e., D/G oil tanks and D/G I
supplement supply fans) are located in common structures for both Units, six (6) ventilation dampers are in the pumphouse and only seven (7) in line !
components were compared to the other Unit.
- c. Provide a completion schedule for the evaluation of these inaccessible components, and the status of the msolution of the outilers, should they be identified by the proposed methods.
Response
1 The discussions in the responses to Parts a and b of this request provide the technical basis for considering the evaluation of these components to be complete.
As stated in the submittal report, these components were inaccessible during the walkdowns because they are located in contaminated areas, moderate to high radiation areas, or areas which are difficult to gain physical access to for inspection purposes. According to Appendix F of the GIP, equipment in very -
high radiation areas or otherwise inaccessible locations may be excepted from walkdowns. With the exception of one compor ,ent, SV-81308, PECO Energy believes that tne equipment listed in Table 4.2-1 of the Seismic Evaluation Report falls within this guidance and does not require scheduling of additional walkdowns. SV-8130B is located in the Unit 2 South Isolation Valve Room which is now accessible during power operations and this component will be walked down as discussed below.
For additional clarity regarding the reasons these components were inaccessible, the following discussion is provided.
Unit 2 Drywell Comoonents VRV2-2-80960 VRV2-2-8096D RV2-02-71C RV2-02-71D MO2-12-015 These components were not walked down because they were either disassembled at the time of the drywell walkdown or not accessible because of restricted acccas due to other outage maintenance or ALARA concerns (such as Page 12 of 26
Attachment i temporary shielding blocking access). PECO Energy does not believe that another entry to the drywell is warranted.
Unit 3 Cleanuo System Isolation Valve Room MO-3-12-018 This component was not walked down due to ALARA concerns. This room is a locked, high radiation area. PECO Energy does not believe that entry into this room is warranted.
Unit 2 South Isolation Valve Room SV-8130B At the time of the planned entry into this room, during a refueling outage, the valve was not located. Confirmation of its location was obtained after reactor rsperation had resumed. As stated previously, this room is now accessible during power operation and, therefore, PECO Energy does believe that another entry into this room is appropriate. PECO Energy will complete the walkdown of the component and will resolve any corresponding outlier issues by December 31,2000, l.ower Roof of Diesel Generator Buildina OAV091 OBV091 OCV091 ODV091 These components were not walked down because they are located behind tornado missile shields that are welded closed.
Preventive Maintenance on these fans is performed from below the roof slab, inside the_ diesel room, utilizing scaffold. This access would not provide the required inspection opportunity because the anchorage of the fan would still not be accessible. Removal of the missile barrier is e labor-intensive activity, and the recurring task work order that formerly cut the welds to provide access to the fans was deactivated in 1993. PECO Energy does not believe that arranging a complete inspection is warranted.
Page 13 of 26
Attachment 1 Pumchouse P020223-1 P020223-2 P020223-3 P020223-4 P030223-1 P030223-3 These components were not fully walked down because the damper is located at the ceiling above a plenum and is not visible (P020223-1, P020223-2) and the operators are inside the ductwork with some disassembly required for access (all componenta).
Due to the limited amount of additional data that visual inspection would provide, however, PECO Energy does not believe that arranging for a complete inspection is warranted.
Yard Area Outside Diesel Building OAT 38 OBT38 OCT38 ODT38 These components were not walked down because they are buried and no access is possible. The access pit for each tank is a confined space and a special permit is required for entry.
There is a recurring task to drain, clean, inspect and repair the tank that is performed on 8 year intervals. This task provides access to the interior of the tank and would not allow inspection of external details. Entry to the access pit is included in this task, but this would only allow inspection of the tank manway cover and an instrument line for oil level indication.
Because inspection of the pit will not add significant value to the tank evaluation, and access to the outside of the tank is not possible, PECO Energy believes that further inspection activity is not warranted.
Page 14 of 26
- = _
Attachmont 1 l I
Reavest #4 As discussed in the attached relay evaluation report, the relay outilers have been resolved using the special exception containedin Section 4.2 of the GIP. You are requested to provide, for staff review, a representative sample of resolutions which employed such special exception, as contained in Vectra Calculation two.
0067M84-C-021, "Selsmic Evaluation of PBAPS Relay," Revision 1, March 12, 1996.
Response
The introductory paragraph of Section 5.0, Outlier Resolution, of the relay evaluation report that refers to "special exception" was intended to introduce the discussions in the next two pcragraphs that describe scaling of IPEEE in-structure response spectra and clipping in structure response spectra using an approach consistent with Appendix 0 of EPRI NP-6041 SL These methods were used only for outlier resolution.
Note also that Vectra Calculation No. 0067-00084-C-021 is only a tabulation of final resolution of relay outliers for which demand exceeded capacity at original screening. The calculation that develops the clipped A-46 median-cer..ared spectra is Vectra Calculation No. 0067-00084-C-020(This calculation hos been entered into the PECO Energy document control system as PS-0920.). A complete copy of this calculation is contained in Enclosure 4.1.
The scaling of IPEEE spectra was performed in accordance with the process described on Pages 4-19 and 4-20 of the GIP and is documented in Vectra Calculation No. 0067-00084-C-014. The use of scaled IPEEE spectra is further discussed in the responses to Request #1, above, and to Request #9, below.
Page 15 of 28
Attachment 1 4
Reauest #5 The reference submittal states that all outiler resolutions, either by analysis, physical modifications, or administrative actions will be completed by December 31,2000. You are requested to provide thejustification for assuring operability of the affected systems and components while a number of safety related
- components in the safe shutdown path have bun Identified as outilers; thus rendering their selsmIc adequacy questionable and their conformance to the licensing basis uncertain.
Resoonse:
When identifying an outlier, the Seismic Review Team (SRT) always considered whether or not the component conformed to the existing plant licensing basis.
Where a deviation from the current licensing basis was identified a non-conformance report (NCR) or other appropriate document was initiated to address the condition. The instances that this action was necessary were very few. For example, an NCR was initiated for a loose anchor bolt at the E4 Diesel Generator Day Tank, and a few Equipment Trouble Tags were initiated for minor cable tray and HVAC support issues The NCR and the trouble tags were evaluated for operability and processed to completion in a_ _ ordance with existing plant procedures, it is the judgment of the SRT that the other identified outliers conform to the plant's licensing basis and are operable. For a limited number of these outliers that exhibit less rugged seismic features (e.g., large, unanchored, oil-filled transformers and low-ruggedness relays) a specific evaluation was performed to confirm this judgment.
The committed date, December 31,2000, to resolve outliers is based on replacing relays during scheduled 4kV bus outages occurring over two outages for each unit. Of the totallist of equipment and relay outliers, approximately hcif have already been resolved through analysis. Those outliers requiring plant work are proceeding to resolution as the modifications are designed and planned into the station's work schedule.
In sur.1 mary, PECO Energy has confirmed conformance to the current licensing basis, is making appropriate progress iri resolving the outliers and has assured operability of the SSEL systems untiline committed resolution of the outliers.
Page 16 of 26
_ . - _ - . .- - . ---- . = _ . . - - -
Attachmont 1 Reauest #Q In Attachment B. " Third Party Audit Report and Resume," to the Seismic Evaluation Report, it is stated that a third party performed a walkthrough audit at the plant.-
^
- a. Clarify the scope and the extent of the walkthrough activity. Since no specific walkdown findings are obvious from the audit report, you are requested to clarify whether the cudit has Indeed included an Independent plant walkdown for all the relevant A-46 equipment or has it merely served to echo the walkdown results already generated by the Seismic Review Team (SRT). The SRT walkdown results are summarized in Table 4.2-4 of the attached Selsmic !! valuation Report. If an Independent plant walkdown was not performed, provide the documentation to indicate that this third party audit has compiled with the walkdown requirements of GIP-2.
Resoonse:
The walkthrough_ audit was a series of overview walkdowns that were conducted to provide the data necessary to complete the independent evaluation as
. required by the GIP and described below.
The third party auditor performed two walkthroughs of Peach Bottom. The Third Party Audit walkthrough was performed in advance of reviewing Screening Evaluation Work Sheets SEWS that were developed by the Seismic Review Teams (SRT). The walkthroughs were conducted on items and areas of the plants selected by the third party auditor. Consequently, the auditor could draw conc!usions independent of the work being performed by the SRT. The first walkthrough ' focusing on Unit 3) was performed on July 15,1993. A sample of each of the eqaipment classes was reviewed in the walkthrough. The first walkthrough was documented by the third party auditor by photographs (approximate!y 100 photos) and a photo log which was used by the third party auditor throughout the project for the review of project reports. The second walkthrough (both Units 2 and 3 with a focus on Unit 2) was performed on November 11,1994. Again a sample of each of the equipment classes was reviewed in the walkthrough. The second walkthrough was also documented by the third party auditor by photographs (approximately 50 photos) and a photo log. Following each Third Party Audit walkthrough a post walkthrough meeting was held with members of the SRT to review the observations of the auditor.
The Third Party Audit walkthrough was performed on a sampling basis (in
- accordance with the intent of GIP Section 2.2.7). In Section 2.2.7 the GlP states that the Third Party Audit "... will provide an assessment of the walkdown and
- analysis by audit and sampling. This is intended to be a one- or two- day overview to determine if gross errors have been made." It is not the intent of the Page 17 of 26
.- ~ - ,
AttachmInt 1 9
GIP that the Third Party Audit should provide "an independent plant walkdown for all the relevant A-46 equipment" as stated in the RAl.
- b. In Section 2.2 of Attachment B, it is stated that the third party has reviewed at least one of each equipment classes on the SSEL. ExplsIn how such a limited scope of review can lead to a general conclusion that Peach Bottom Units 2 & 3 are, "In general, well designed for seismic loads and that equipment installation appears to be quite rugged." Also provide the documents which support such review findings by the third party.
! Response: ,
The Third Party Audit was performed on a sampling basis in accordance with the GlP (see response to item a, above). While the audit focused on certain items of equipment, the auditor walked through much of both plants and observed the type of construction and installation of many items of equipment. The conclusion is based on the results of the two walkthroughs as described in item c below.
We believe that the general conclusion is well supported by the results of the walkdown by the SRTs.
The following documents related to the plant walkthroughs are provided:
- 1. Photo log from July 15,1993 walkthrough by the third party auditor. (Enclosure 6.1)
- 2. Photo log from November 10,1994 walkthrough by the third party auditor (handwritten) (Enclosure 6.2) n 3. Letter 040-93-016-L from Programmatic Solutions to PECO, dated August 16, 1993. (Enclosure 6.3)
- 4. Meeting Minutes dated November 11,1994. (Enclosure 6.4) 5, Letter 040-95-009-L from Programmatic Solutions to PECO, dated August 11, 1995. (Enclosure 6.5)
- 6. Letter 0067-00064-234 from Vectra Technologies to PECO, dated February 24, 1996. (Enclosure 6.6)
- c. Explain the apparent confilct between the conclusion drawn in item (b) above, regarding equipment ruggedness, and the multiple evidences of component outilers listed in Table 4-2.4 of the Seismic Evaluation Report.
Response
i An outlier is not a conclusion that the equipment is not seismically rugged. A
- large number of outliers merely means that the standard screening guidance provided in the GIP is not met for many items. Only once the outliers have been evaluated using the methods described in the GIP can it be determined whether -
or not the equipment seismic capacity meets the seismic demands.
Page 18 of 26
- c L AttCchment 1
?
Consequently, it should not be concluded that there is a conflict between the- ,
- conclusion drawn in item (b) and the multiple evidences of component outliers- 1 Rather, it is necessary to compare the final results of outlier evaluation relative -
' to the conclusion drawn in item (b). This comparison can be performed by . t
- reviewing the Outiler Seismic Verification Sheet (OSVS) forms in Attachment D of the report. A summary comparison from the OSVS is provided in Enclosure 6.7c This table shows that 138 outliers were resolved without modification (i.e.,
the outliers did not indicate inadequate seismic capability). The other categories
< of outlier (i.e., those that require modification or maintenance) include a total of ,
131 outliers. Tha third party auditor walkdowns identified at least one case of outlier represented by 8 of the general categories (these are marked "yes" in the third column of the table and include!,100 outilers) in the table. The sample from the Third Party Audit then provided indication that these types of outlier
- required further consideration. Five of the categories (these are marked "no" in the third column of the table and includes 31 outliers) requiring modification or-maintenance were not identified by the Third Par +y Audit.
The general conclusions of the Third Party Audit are, therefore, in agreement with the specific conclusions of the Seismic Evaluation Report.- The small number of outliers that were not identified in the Third Party Audit are consistent .
with the expectaticos and limitations of an overview audit. In accordance with the guidance of the GIP, the Third Party Audit determined that no gross errors
- had been made.
t 4
Page 19 of 26
Att: chm:nt 1 '
Reauest #7 A Seismic Adequacy of Cable and Condult Raceways a.- You stated in Reference 1 that you performed an evaluation of the cable .
and conduit raceways in accordance with the GIP-2 guideline. However, during the recent review of anotherplant's Implementation of the GIP-2 Guideline, the staff found that the procedure for ductile cable tray systems might not be sufficiently conservative. The GIP 2 guideline stated that the ductile cable iray systems do not require an evaluation forlateralloads.
The staff does not fully endorse this position and is currently pursuing a
- resolution of the cable tray system ductilityissue with SQUG (Reference 2). A generic resolution, when estabilshed, should apply to the Peach Bottom plant cable trays as weII. At that time, you should revise the evaluation of the Peach Bottom cable tray systems accordingly.
For the interior of the cable spreading room, provide drawings of the cable tray systemc and structures including drawings of the floor and/or ceiling at the elevations where the cable trays are attached. Also provide the corresponding floor response spectra, including a discussion of how the flexibility of the floor was accounted forin constructing the spectra, and the finalresults of the cable tray system evaluations in terms of deflections and associated stresses of the support systems. Provide the welght of the cable trays and Its contents, such as fire retardants, which were consideredin the evaluations. In addition, provide the validation i documents of any computer codes or any analysis methodology which are used to produce the results discussed above.
Response
PECO Energy is cognizant of the continuing dialogue between SQUG and the NRC regarding the GIP cable tray evaluation method, including the recent
- correspondence from SQUG to the NRC oa June 11,1997 (Reference 5).
PECO Energy will continue to work with SQUG on this issue and will make revisions as appropriate.
- The request for detailed drawings for the interior of the cable spreading room was discussed with NRC staff in a telecon of July 14,1997, During that conversation, PECO Energy described what information is available.
Consequently, it was agreed that the initial response to this request would be satisfied by providing the following:
< - Floor drawings: S-68, Turbine Building Plan at Elevation 150*-0 (C.S. Room) (Enclosure 7.1)
S-71, Turbine Building Plan at Elevation 165'-0 (Control Room /above C.S. Room) (Enclosure 7.1) ,
Page 20 of 26
- ~. .-- -- - .- .
Attachment 1
- Layout drawings: E-1141 (3 sheets), Tray Layout, Sections
& Details, Turbine Building Area 3 Elevation
] 150'-0 (Enclosure 7.1)
E-1154 (9 sheets), Conduit Layout, Cable Spreading Room, Turbine Building Area 3, Elevation 150'-0" (Enclosure 7.1)
- Floor Response Spectra:
The floor response spectra provided here are the median centered spectra that were discussed in the response to Request #2. They are provided in Enclosure 7.2. These are horizontal floor responso spectra, and flexibility of the floor is not pertinent to their development.
Elevation Direction 150'-0 E-W, N-S 165'-0 E-W, N-S
- Limited Analytical Review (LAR):
Calculation PS-0912, SQUG/IPEEE-Limited Analytical Review of Raceways (Enclosure 7.3)
Calculation PS-0939, SQUG/USl A-46, PBAPS Fan Room USl A-46 Outlier Evaluation (Enclosure 7.4)
The LARs contain the final results of the cable tray evaluations, performed in accordance with the GlP. The weights that were used in the reviews can be found in the enclosed calculations. Also, please note that theso calculations do not utilize any computer codes.
The basis for selecting the worst case cable tray / conduit configurations was the judgment of the SRT that performed the plant walkdowns. The data gathered during these walkdowns has been documented in accordance with the GIP on Plant Area Summary Sheets; these were included in the summary report in Attachment E.
' The two calculations that provide the LAR are further discussed in the response to part (b) of this request.
Page 21 of 26
Attochment 1 4
- b. You discussed the cable tray systems evaluation in Section 3.6.3. Provide a sample calculation (including the methodology used) wh!ch involves the worst case configurations of cable tray and conduit raceways, from a safety margin point of view. Provide the validation documents related to the evaluation. Also, provide a copy of Reference 5.3.3, "Bechtel Cable Tray and Conduit Raceway Selsmic Test Program, Volume I and II, September,1978," and explain how this reference was used in your evaluation. Discuss how the cable and conduit raceway evaluations discussed in Section 3.6.3 differ from those la Section 4.4.
Response
During the above-noted telecon of July 14,1997, the contents of Sections 3.6.3 and 4.4 of the PBAPS summary report were also discussed. In brief, Section 3.6.3 is a summary of the historical design bases for cable tray systems and includes Reference 5.3.3 as a resource document. Section 4.4 is the summary of the implementation of the GIP cable tray evaluation method. With this clarification, the NRC staff indicated tha1 historical design information was not required, and the response should consist of data pertaining to implementation of GIP methodology, principally the LAR.
As stated above, the implementation of the GIP cable tray evaluation method is discussed in Section 4.4 of the summary report. Key elements of this method are plant walkdowns and the LAR. Prior to performing the walkdowns, the SRT reviewed existing design documents, layout drawings and standard details, to become familiar with the original design basis. The emphasis of the walkdowns was on GIP guidelines and ensuring the as-found configuration matched the design documents.
Walkdown results ere documented on Plant Area Summary Sheets. From the data gathered during the walkdowns, worst-case samples of the raceway support systems were selected for the LAR.
The LAR was performed in two phases. The original set of samples is contained in Calculation PS-0912. The configurations that are reviewed in this calculation, although labeled for a specific plant area, represent similar configurations throughout the plant (including the cable spreading room). The second set of samples is contained in Calculation PS-0939. These configurations were reviewed to resolve cable tray outliers in the fan room (Elevation 165'-0",
Radwaste Building) which are described on an OSVS sheet contained in Section D of the summary report. Note also that the LAR contains copies of applicable standard details as appropriate.
Page 22 of 26
Attachmont 1 i Reautst #8. Deviations from the GIP 2 Guideline in the summary report you stated that you are committed to implement the GIP.
2, including the clarifications, Interpretation, and exceptions in SSER 2, and to communicate to the NRC statt any significant or programmatic deviations from the GIP guidance. You further stated that the submittal confirms that no significant orprogrammatic deviations from the GIP guideline were made.
i Provide the worst-case items (from the safety point of view) which deviate from the GIP-2 puideline but were categorized as not significant. In addition, you are also requested to provide the definition of " safety significant," which were used by the walkdown personnel tc categorize the deviations as either being significant or non significant, and provide aJustification that such a definition is adequate.
Resoonse:
As stated in the submittal letter, "no significant or programmatic deviations from the GIP guidance were made." Table 4.2-2 of the submittal report provides a summary of " Equipment Meeting Intent But Not Letter of Caveat Summary."
The instances where the SRT exercised judgment to conclude that an observed condition is insignificant and meets the intent of the GIP are all minor, it is PECO Energy's opinion that none of these are consequential to the conclusiores of the Seismic Evaluation Report and ranking does not have technical value.
They are all insignificant.
A review of the Screening Evaluation Work Sheets (SEWS) has been performed. The following list is presented as being representative of these items.
- Floor-mounted transfoTner utilizes stiffeners adjacent to anchor bolts to resist shear load in direction of weak-axis bending for bottom support channel. Weak axis bending not consequential.
Pilot-operated safety-relief valve combines features of safety valve and solenoid valve. -Possesses overall very rugged construction and meets intent of 3g static load caveat.
. Damper integrally mounted with duct systems judged to have support
" structure and anchorage acceptable without formal anchor analysis.
Page 23 of 26
,.7_...__..._
,e -i L Att"chment 1 - ;
f., <
j
-* L Transformer mounted at base'of battery chaiger through sloded holes in; L the mounting brackets? Judged acceptable because attaching bolts and: :
nuts also utilize lock washers, indicating higher strength bolts and well
- torquod connection. - Additionally, ample clearance to cabinet sheet metal j
! exists.
In all cases where these kinds of judgments were exercised by the SRT, the -
1l
=
affected SEWS have been so annotated.
I- - None of these items are considered safety-significant, because in the judgment of the SRT, the outlier resolution activity that would have been required by a - y negative response to the applicable screening element would have clearly I
- resulted in a conclusion that the noted condition was acceptable. Negative:
responses and formal outiler resolution activities were utilized for screening elements for which the conclusion was either not obvious or was clearly not ;
=
within the screening guidelines of the GIP, i ,
i-l -
I 4
Page 24 of-26 4
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- .- - .. = .. . . _ . - . . - - - - . - . - - . - -
Att:chment 1 Reauest#9 OutilerResolution in Section 4.6, titled " Description of Outilers,"you provided a discussion on in-structure response spectra. It is not clear why this was done. Clarify whether these spectra are different from those submitted in your 120-day response to -
Suppisment No.1 to Generic Letter 87-02. If they are, provide a detailed Justification for changing the spectra and explain how these spectra are used for -
equipment quellfhation (including the names of structures, elevations, and
- equipment, etc.). Also, provide the validation documents of the methodology used for constructing the spectra. CIsrlfy whether these spectra are different from those discussedin Section 3.7.2.
Resoonse:
Section 3.7.2 describes in detail the spectra that was used as input in the USl A-46 effort for determining the seismic demand. The in-structure response spectra is the same input used in the seismic analysis and design for PBAPS as described in Appendix C of the UFSAR and submitted in the 120 day response
. to Supplement No.1 to Generic Letter 87-02. However, new in-structure response spectra ( ISRS ) were developed for the Radwaste/ Turbine building. A PECO Energy Letter ( ref. 5.1.8 of Seismic Evaluation Report ) provided the response to an earlior request from the USNRC to describe the methodology used by PECO Energy for developing realistic, median-centered ISRS for the 4
Radwaste/ Turbine building. The USNRC issued a Safety Evaluation Report
( SER ) (ref. 5.1.9 of Seismic Evaluation Report ) documenting the review of the procedure used and concluded that it was acceptable for use in the USI A-46 Program.
I The spectra described in sections 3.7.1 and 3.7.2 were used in determining if the capacity versus demand caveat was met for a component.
The purpose of section 4.6 of the Seismic Evaluation Report was to summarize
.the methods used for resolution ( or proposed resolution ) of outliers only.
The in-structure response spectra method described in section 4.6 of the Seismic Evaluation Report was used for evaluating outliers only, specifically where the capacity versus demand caveat was not met as part of the screening criteria.
Specifics where the ISRS method described in section 4.6 for outlier evaluations was utilized is discussed further as part of the PECO Energy response to RAI
- number 1.
Page 25 of 26
.- . _ _ . , .=. - - - . . - - .. _-.--. - .- - - _ - - . - . - -
Attachment 1
- References 1, Letter from G. A. Hunger, Jr., PECO Energy, to NRC Document Control Cask, ;
- Summary Report for Resolution of Unresolved Safety issue (USI) A-46," dated l May 7,1996. ;
i
- 2. Letter to D. Dorman, NRC, from N. P. Smith, Seismic Qualification Utility Group, !
'SQUG Generic Response to the Staff RAI,' dated August 19,1996.
l
- 3. Letter from Joseph W. Shea NRC, to George A. Hunger, Jr., PECO Energy, "Use of Median-Centered In Structure Response Spectra for Resolution of Unresolved Safety issue A-46 and Generic Letter 87-02, Supplement 1...'.
- 4. Letter to John F. Stolz, U.S. Nuclear Regulatory Commission from Neil P. Smith, Chairman Seismic Qualification Utility Group, dated June 30,1997,
Subject:
Generic issue included in NRC's Requests for Additional Information on Use of
- GlP Method A.
- 5. Letter to John F. Sto!I, U.S. Nuclear Regulatory Commission from Neil P. Smith, Chairman Seismic Qualification Utl*y Group, dated June 11,1997,
Subject:
SQUG Response to NRC RAI on Lateral Load Ductility Evaluation of Cable Tray Supports.
4 i
Page 26 of 26
. . . _ ~ . . _ _ . _ _ . . . _ . - . . - . , .._ _ , _ . _ .
t 1
ENCLOSURE 1.1 !
Mechanical and Electrical Components ,
Outilers Resolved with EPRI NP 6041 Methodology (2 pages) 9 b
r ,p e -. -s x- 4,-<-mer -y--*, . .-w. . ~ - v - -v-.- - ,--
MECHANICAL AND ELECTRICAL COMPONENTS OUTLIERS RESOLVED WITH EPRI NP 6041 METHODOLOGY Equip. Equipment Equipment Reference Class ID. Location Elevation Calculation Number Comments 1 20B36 Reactor Bldg. U2 165' 0067 00084 C 014 Dem. Exceeds Cap.
4 20X30 Reactor Bldg. U2 165' 0067 00084 C 014 Dem. Exceeds Cap.
4 20X31 Reactor Bldg. U2 165' 0067 00084 C 014 Dem. Exceeds Cap.
4 20X32 Reactor Bldg. U2 165' 0067 00084 C 014 Dem. Exceeds Cap.
4 20X33 Reactor Bldg U2 165' 0067 00084 C 014 Dem. Exceeds Cap.
7 A02 03 32A Reactor Bldg. U2 135' 0067 00084 C 014 Dem. Exceeds Cap.
7 A02 03 328 Reactor Bldg. U2 135' 0067 00064 C 014 Dem. Exceeds Cap.
7 A02 03 35A Reactor Bldg. U2 135' 0067 00084 C 014 Dem. Exceeds Cap.
~
7 A02 03 358 Reactor Bldg U2 135' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV2 02 071 A Drywell U2 154'9" 0067 00084 C 014 Dem. Exceeds Cap.
7 RV2 02 0718 Drywell U2 154' 9" 0067 00024 C 014 Dem. Exceeds Cap.
7 RV2 02 071C Drywell U2 154'9" 0067 00084 C 014 Dem Exceeds Cap 7 RV2 02 071D Drywell U2 154'9" 0067 00084 C 014 Dem. Exceeds cap 7 RV2 02 071E Drywell U2 154' 9" 0007 00084 C 014 Dem. Exceeds Cap 7 RV2 02 071F Drywell U2 154' 9" 0067 00084 C 014 Dem Exceeds Cap 7 RV2 02 071G Drywell U2 154'9" 0067 00084 C 014 Dem. Exceeds Cap.
7 RV2-02 071H Drywell U2 154' 9" 0067 00084 C 014 Dem. Exceeds Cap.
7 RV2 02 071J Drywell U2 154'9" 0067 00084 C 014 Dem. Exceeds Cap.
7 RV2-02 071K Drywell U2 154' 9" 0067 00084 C 014 Dem. Exceeds Cap 7 RV2 02 071L Drywell U2 154' 9" 0067 00084 C 014 Dem. Exceeds Cap 9 OAK 032 ECT 195' 0067 00084 C-016 Dem. Exceeds Cap 9 OBK032 ECT 195' 0067 00084 C 016 Dem. Exceeds Cap.
9 OCK032 ECT 195' 0067 00084 C 016 Dem. Exceeds Cap.
18 2AC65 Reactor Bldg. U2 165' 0067 00084 C 014 Dem Exceeds Cap 18 2BC65 Reactor Bldg. U2 165' 0067 00084 C 014 Dem. Exceeds Cap 18 PT 2508B Reactor Bldg. U2 195' 0067 00084 C-014 Dem. Exceeds Cap J
MECHANICAL AND ELECTRICAL COMPONENTS OUTLIERS RESOLVED WITH EPRI NP 6041 METHODOLOGY Equip. Equipment Equipment Reference Class ID. Location Elevation Calculatinn Number Comments 4 30X31 Reactor Sidg U3 165' 0067 00084 C 014 Dem. Exceeds Cap.
4 30X33 Reactor Bldg. U3 165' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV3 02 071 A Drywell U3 154' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV3 02 071B Drywell U3 154' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV3 02 071C Drywell U3 154' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV3 02 071D Drywell U3 154' 0067 00084 C 014 Dem. Exceeds Cap 7 RV3 02 071E Drywell U3 154' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV3 02 071F Drywell U3 154' 0067 00084 C 014 Dem Exceeds Cap.
7 RV3 02 071G Drywell U3 154' 0067 00084 C 014 Dem. Exceeds Cap.
7 RV3 02 071H Drywell U3 154' 00S7 00084 C 014 Dem. Exceeds Cap 7 RV3 02 071J Drywell U3 154' 0067 00084 C 014 Dem Exceeds Cap.
7 RV3 02 071K Drywell U3 154' 0007 00084 C 014 Dem. Exceeds Cap 7 RV3 02 071L Drywell U3 154' 0067 00084 C 014 Dem Exceeds Cap 7 A03 03 32A Reactor Bldg U3 135' 0067 00084 C 014 Dem Exceeds Cap.
7 A03 03 328 Reactor Bldg. U3 135' 0067 00084 C 014 Dem. Exceeds Cap.
7 A03-03 35A Reactor Bldg. U3 135' 0067 00084 C 014 Dem. Exceeds Cap.
7 A03 03 358 Reactor Bldg. U3 135' 0067 00084 C 014 Dem. Exceeds Cap.
8A M0312-018 Reactor Bldg. U3 165' 0067 00084 C 014 Dem. Exceeds Cap.
18 3AC65 Reactor Bldg. U3 165' 0067 00084 C 014 Dem. Exceeds Cap.
~
18 PT 3508B Reactor Bldg. U3 195' 0067 00084 C 014 Dem. Exceeds Cap.
4 OAX26 ECT 153' 0067 00084 C 014 Dem. Exceeds Cap.
4 OBX26 ECT 153' 0067 00084 C 014 Dem. Exceeds Cap 4 OCX26 ECT 153' 0067 00084 C 014 Dem. Exceeds Cap 20 OAC097 Diesel Gen Bldg 127' 0067 00084 C-014 Dem. Exceeds Cap.
20 OAG13 Diesel Gen. Bldg. 127' 0067 00084 C p14 Dem. Exceeds Cap.
20 OBC 097 Diesel Gen. Bldg. 127' 0067 00084 C 014 Dem. Exceeds Cap.
~
20 OBG13 Diesel Gen. Bldg. 12T 0067 00084 C 014 Dem. Exceeds Cap.
20 OCC097 Diesel Gen Bldg 12T 0067 00084-C 014 Dem. Exceeds Cap.
20 OCG13 Diesel gen. Bido 12T 0067 00084 C 014 Dem. Exceeds Cap.
20 ODC097 Diesel Gtn Bldg. 12T 0067 00084 C 014 Dem Exceeds Cap 20 ODG13 Diesel Gen. Bldg. 12T 0067 00084 C 014 Dem. Exceeds Cap.
S \ RED 0812A 97
I i
I 5
ENCLOSURE 1.2 Horirontal Response Spectra for i
.j .
- Radwaste/ Turbine Building, Elevation 150'. 0" f
(4 Pages) i W
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