ML20216H424
| ML20216H424 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/09/1997 |
| From: | Eaton R NRC (Affiliation Not Assigned) |
| To: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR TAC-M69467, NUDOCS 9709160242 | |
| Download: ML20216H424 (6) | |
Text
t-t September 9. 1997 Mr. Michael'B.'Roche Vice President and Director GPU Nuclear Corporation Oyster Creek Nuclear Generating Station Post Office' Box 388-
. Forked River. New Jersey 08731
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED SAFETY ISSUE, A-46. AT OYSTER CREEK NUCLEAR GENERATING STATION (TAC.NO. M69467)
Dear Mr. Roche:
As a result of the U.S.. Nuclear Regulatory Commission's (NRC's) staff review of the subject issue. it was determiled that additional information is necessary to complete the review.
Enclosed is the list of items subject to this request.
If you have questions regarding this request please contact me on (301) 415-304).
Sincerely.
l Original signed by Bart C. Buckley for Ronald B. Eaton Senior Project Manager Project Directorate
-2 Division of Reactor Projects I/II Office of 5!uclear Reactor Regulation Docket No:'50 219
Enclosure:
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M. Roche Oyster Crcek Nuclear GPU Nuclear Corporation Generating Station cc:-
Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, DC 20037 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 BWR Licensing Manage-GPU Nuclear Corporation 1 Upper Pond Road Parsippany, NJ 07054 Mayor La:ey Township 818 West Lacey Road Forked River, NJ 08731 Licensing Nanager Oyster Creek Nuclear Generating Station Mail Stop: Site Emergency Bldg.
P.O. Box 388 Forked River, NJ 08731 Resident Inspector c/o. U.S.- Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 I
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REQUEST FOR ADDITIONAL INFORMATION i
RESOLUTION OF USI A-46 (GENERIC LETTER 87-02)
OYSTER CREEK NUCLEAR GENERATING STATION
REFERENCE:
Letter from H. B. Roche-(GPUN) to NRC, dated March 29, 1996, "USI A-46 Seismic Evaluation R3 port (EQE Report No. 42112-R-001, dated March 29,1996)."
1.
On page 10, the report mentions that the SSEL [ Safe-Shutdown Equipment List] contains 512 components of which 390 components were evaluated during the walkdown to verify their seismic adequacy.
Pro' fide information to show how the remaining 122 components were verified for seismic adequacy.
2.
Item 9 on page 20 of the report did not include in the SSEL those equi) ment items that (if failed during and after an SSE [ Safe shutdown eart1 quake?) were postulated to fail in the desired position. However, a malfunct on of the control devices of such equipment can fail the equipment in an undesirable state. Therefore, show with examples that the control devices of such equipment were included in the SSEL.
3.
In reference to Item 4, Section 2.1.1.2, page 21 of the report, the structural integrity of equipment was not considered as a failure mode (e.g., rupture of a valve). Since this assumption was Oyster Creek plant-specific, provide a list of all cases where the structural integrity was not considered as a failure mode and explain how the equipment functionality was verified for those cases so that the impact of this assumption can be evaluated.
4.
Item 5 on page 22 indicates that " inherently rugged" equipment types include " pressure and temperature gauges, flow elements and other items defined in the GIP [ generic implementation procedure]." However, the GIP (Section 3.3.5) does not include the temperature gauges and flow clements, nor does it list any items other than the valves already included in the Oyster Creek report.
List all equipment types that were considered " inherently rugged," and for those items that were not listed in the GIP, provide information to show the seismic adequacy of equipment, including their mountings.
5.
In Section 2.3.1 on page 33, the report states that the operator "Will eventually be directed to the use of equipment and instruments on the SSEL even though the operator may have first tried to shut down using equipment not included in the SSEL." This may delay the operator's action further if ultimately the A-46 shutdown path is to be~followed.
Provide information to demonstrate that this delay in operator action will not compromise safety and was considered toward on time recovery from potential malfunctions, especially in light of this request for additional information (RAI) Item No. 7.
6.
For cabinets and panels containing relays, the report in Section 3.5.1 on page 48 states that "a relay evaluation of these cabinets and panels is not required." It is not clear what is meant by "a relay evaluation" of a cabinet. Have the safety-significant relays been evaluated? Have the cabinets containing these relays been evaluated?
If both of these ENCLOSURE
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2 answers are affirmative, clarify what "is not required" then.- If any of the answers are negative.-provide-information to show how the seismic-adequacy.of relays including the hcusing cabinets was verified.
'7 Regarding operator action, very high reliance has been placed on operators' ability for recovery of-many seismically vulnerable items l
within a short period of time. Section 3.7 on pages 49 and 50 stated that 53 relays are identified as requiring operator action to restart or reenergize the component after the SSE.
- Any one or a few of these operations may easily be performed. It is questionable whether all of the cited operator actions can be performed reliably within the short available period of time given the potential for absence of electrical light and egress-that could have been created after an SSE-type earthquake as a result of falling or failure of-nonseismic components on seismic components. Provide information to show that the assumed recovery of all malfunctions / damages within the needed period can be accomplished in the plant condition after an SSE-type earthquake, f
8.-
The report on page 58 states that " anchor bolt tightness checks were
- performed in accordance with the GIP where tightness checks were determined to be required." This im)1ies that the GIP criteria were used to perform the bolt tightness cieck and prior to that another set of criteria was used to: determine whether such a check is required.
Specify the criteria that were used to determine whether an' anchor bolt i
tightness check was required.
g.
Regarding the Third Party Review, the report on page 66, Section 4.6, states that "Dr. Stevenson's comments were... satisfactorily resolved by further analysis " Did Dr. Stevenson concur with the resolution of his comments? Provide a mare descriptive response to Dr. Stevenson's observations in Appendix M so that an independent evaluation can be made.
l 10.
The brief discussion of the Description Code and the Resolution Code as included on page K6 in Appendix K does not provide adequate information in characterizing the deviations and for evaluating acceptability of the licensee's justification that led to the conclusion of meeting the intent of caveats. This observation is applicable to many of the-caveats listed in Appendix K.
In order to understand and evaluate the
- acceptability of the licensee's evaluation, it is requested that a thorough documentation of the deviation and-justification of the caveat
- be provided for the following sample equipment items (called System Numbers"): System Numbers 225, 241, 642, 732, 822. ~It,hould be noted that Appendix B of the GIP describes the specific concerns related to each caveat. For the above sample equipment items, the licensee should m
address in detail all-of the concerns as discussed in the GIP, 7
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3 11.
The following questions pertain to the outliers discussed in Appendix L:
a) The brief discussion of the description and resolution of outliers
. included in Appendix L does not provide adequate information in characterizing the identified deficiencies and for evaluating acceptability of the proposed / implemented modifications.
This observation is applicable to more than 300 caveats listed in Appendix K.
As described in the GIP, it is expected that the deficiencies and modifications have been thoroughly documented to allow an independent review. To illustrate thoroughness of such documentation, submit complete information that led to the resolution of the outliers for the following equipment items identified by System Numbers / Mark Numbers. Any deficiencies including field information (e.g., configuration, size, design, etc.) and analysis / testing data should also be included. Equipment items:
System Number 212/ Mark Number P-20-002 B, System Number 215/ Mark Number V-16-0001, System Number 41 1/ Mark Number V-1-0008, System Number 411/ Mark Number V-1-0176, System Number 611/ Mark Number PNLl6R, System Number 642/PNL ER8B.
b) For Core Spray System Pump NZ01-B, System Number 212/ Mark Number P-20-001 B, the Description Code identified:
" Seismic capacity of adjacent or overhead item is unknown, potential interaction hazard,"
and the Resolution Code specified:
Perform seismic testing of relay, Replace if relay fails acceptance criteria."
It is not clear as to how the proposed resolution will resolve the identified deficiency.
Provide further details that show how this outlier was resolved.
c) For several outlier relays that were identified as inadequate or of unknown seismic capacity, the outlier code (20) specified:
" Modify circuit or replace relay." For relays that are not being replaced, the resolution code does not provide useful information (i.e., how the modification of circuit will resolve the issue). Explain what actions are being taken to resolve those outlier relays.
12.
Appendix N of the licensee's report provides the schedule for completing all modifications required to resolve outliers. However, it is noted that the equipment items listed in Appendix N does not include all the outliers reported in Appendix L of the same report.
Provide the missing information or explain the discrepancy between the two lists.
13.
Section 4.1:
Provide graphical comparisons of an amplified bounding response spectrum with the in-structure response spectra at the following locations:
93 Reactor Building:' ' Elevations 23 ft. 6 in., 51 ft. 3 in., 75 ft. O in.;
Drywall: Elevations 46 ft. 2 in., 75 ft. 3 in.; Turbine Building: 46 ft.
6 in.; Diesel Generator Building: 18 ft. 4 in., 23 ft. O in.; Intake Structure: 6 ft. O in.
4 14.
Section 4.1:
It appears that in some cases, the seismic demand for equipment located within 40 ft. above the effective grade has been defined by the site-specific ground response spectrum (GRS) instead of the amplified in-structure response spectra (IRS).
For example, in line numbers 488 and 487 of the screening verification data sheets (SVDS),
the same type of equipment (i.e., HDR vent valves in the Reactor Building) at the same elevation-seem to have been screened by the two different approaches.
Provide justification for not using Method B of Table 4.1 of GIP-2 in a consistent manner for screening the equipment at various elevations.
15.
Section 4.3.1: GIP-2 (Section 4.4) recomends that expansion anchors should not be used for anchoring vibratory equipment, such as pumps and air compressors.
If used, the GIP-2 recomends a large margin between the pullout loads and the pullout capacities.
The SVDS in Appendix D do not provide any information regarding the type of anchors used for the listed equipment. Provide information about the seismic adequacy of vibratory equipment secured by expansion anchors.
16.
Section 4.3.2 and Appendix L:
The summary states that the four large heat exchangers and one large flat-bottom vertical tank are outliers.
Provide the following information about the four heat exchangers and the tank describing how the outliers were resolved:
a.
Sketches showing the tank (heat exchangers) dimensions, anchor chairs, anchorages (including embedment), saddle restraints, and foundation.
b.
A detailed calculation of the tank that demonstrates the seismic adequacy of the tank utilizing the GIP-2 procedure.
17.
Section 4.3.3: The limited analytical reviews indicated that 7 out of 20 reviews of the raceway supports required outlier evaluations.
The refined evaluations of these outliers demonstrated seismic adequacy.
Provide the detailed seismic evaluation work sheets for these seven supports with the original and the refined calculations.
18.
Our reviews and audits of a few A-46 plants indicate irregularities in the use of Section 8 of GIP-2 for raceway supports. Please provide the following information in that context:
a.
Elaborate on the basis for assuming " ductile" support system for the raceway support configurations not documented by the experience database; for,eyample, two nonuniform columns of cable trays supported by three supports (anchorages). Also, see Figure 8-5 of GIP-2, where the analysis of the complete configuration would be required for lateral seismic load as opposed to the analysis of individual " ductile" supports.
Provide the method utilized to i
resolve the issue of questionable " ductile" support systems.
t b.
Provide procedures that will be utilized for the future addition of cables in the raceway trays, when partial-fill assumption is used in the limited analytical reviews of the raceway supports.
.-