SVP-97-232, Forwards Response to 970819 RAI Re Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating Plants

Forwards Response to 970819 RAI Re Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating Plants

ML20217K554
Person / Time
Site:	Quad Cities
Issue date:	10/24/1997
From:	Pearce L COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR SVP-97-232, NUDOCS 9710280309
Download: ML20217K554 (30)

Text

g Gimmonw cahh I'diwn Gimp.iny Qu.ed Gtits Generating Station

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22710 2%th Astnue North nirdin a, 11.(.1212-9740 '

Tel 309M i-22 41 l

i SVP-97-232 October 24,1997 U. S. Nuclear Regulatory Conunission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Request For AdditionalInformation (RAl)- Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating Plants Docket Numbers 50-254 and 50-265

Reference:

A. R. hf. Pulsifer letter to I. Johnson dated August 19,1997, " Request for Additional Information - Quad Cities, Units 1 and 2 (TAC NOS h169476 and h169477)"

B. C. P. Patel letter to D. L. Farrar dated June 6,1993, " Evaluation of Dresden Nuclear Pour Station, Units 2 and 3 and Quad Cities Station, Units I and 2, Procedure for Developing in-Structure Response Spectra for Resolution of USI A-46 (TAC NOS. h169442, h169443, M69476 and h169477)

C. E. S. Kraft letter dated June 28,1996, ESK-96-128, " Summary Report for Resolution of Unresolved Safety issue (USI) A-46 Generic Letter 87-02, NRC Docket Nos. 50-254 and 50-265" D. J. G. Partlow letter dated hiay 22,1992, " Supplement No. I to Generic Letter (GL) 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 (SSER No. 2) on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14,1992 (GIP-2)"

The Attachment to this letter provides Comed's response to the referenced Request for Additional Information (RAI).

9710280309 971024 PDR ADOCK 05000254 ' [')p('

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~ [2 'M 11111 1.11 1.1 1 1 11!.! 11 A tinicom Company

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• USNRC SVP-97-232 2- October 24,1997 if you have any questions concerning this letter, please contact Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, extension 3609.

Respectfully, g,

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- --- /PBrt-L. W. Pearce Site Vice President-Quad Cities Station i

Attachment A, Comed Response to NRC Request for Additionallnformation I

cc: A. B. Beach, Re .onal Administrator, Region III R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident Inspector, Quad Cities W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)

M. E. Wagner, Licensing, Comed SVP Letter File

t c ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 1 of 15) 1, in Table 8.2 ofthe Seismic Evaluation Report attached to the referenced letter, which lists the Quad Cities A-46 equipment outhers and the status of their resolut!on, the Consermtive Deterministic Failure Afargin (CDimf) method ofElectric power Research Institute (EPRI) NP-604), " Seismic Afargin Report,"is utill:ed to resolve the outliersfor cable and conduit raceway systems. The methodology has not been approved by the staf for the analysis ofsafety-related systems and components, including the resolution of mechanical, electrical and structural component outliers in the Unresolved Safetyissue (USI) A-46 program. You are requested to re-evaluate yourprogram and ensure that all the identifed outliers will be resolved using the plant licensing basis methodologies or other approaches acceptable to the staf The capacity estimates given in Table 8.2 were calculated for unresolved cable tray system ,

outlicts only. They were calculated in accordance with the Generic implementation Procedure (GlP) methodology as approved by the USNRC (Reference D), not using the conservative deterministic failare margin (CDFM) methodology, High Confidence Low Probability of Failure (HCLPF) values were not used for the resolution of outliers and were provided for staffinformation.

Only methodologies acceptable to the staff and in accordance with the GlP have been and will be used for outlier resolution.

2 The referenced submittal states that all outlier resolutions, either by analysis, physical modifcations, or replacements, will be completedfor each respective unit by the end of the second refueling outagefor that unit aRer the receipt of the staff's Safety Evaluation Report. You are requested to elaborate on your decision to defer the resolution of identifed outliers andyour evaluation in support ofthe conclusion that the licensing basisfor the plant will not be afected by>vur decision. Spectfically, Svu are requested to provide thejustifcationfor assuring operability ofthe afected systems and components while a number ofsafety-related components in the safe shutdown path have been identifed as outliers; thus rendering their seismic adequacy questionable and their conformance to the licensing basis uncertain.

The response to this questions is broken into three parts.

In response to "You are requested to elaborate on your decision to defer the resolution of identified outliert, " we provide the following:

In the summary report submittal (Reference C), Quad Cities committed to " resolve all of the outliers for each respective Unit by the end of the second refueling outage for that Unit after receipt of the Safety Evaluation Report [SER]." This commitment was made based on SQUG guidance that two refueling outages was an acceptable time span and in anticipation that the SER was forthcoming.

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t-ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 -

(Page 2 of 15)

It was not Quad Citics' intention that the summary report submittal convey we were deferring outlier resolution. Following the submittal, Quad Cities promptly began engineering activities towards resolution of the outliers. The present status of the $1 equipment outliers is as follows:

e 27% of the outliers are resoked (Closed).

e 12% of the outliers are partially (over 50%) closed.

. 25% of the outliers am scheduled to be Closed in 1998. ,

e 36% of the outliers require additional analysis to be completed in 1998 with resulting modifications, as required, thereafter.

With respect to relay outliers, the plan is to initiate additional analyses, circuit evaluations and industry data research in 1998 with resulting modifications, as required, thereafter.

This summary shows that Quad Cities is actively pursuing outlier resolution.

In response to " ..andyour evaluation in support ofthe conchtston that the licensing basisfor the plant will not be a@cted byyour decision. " we provide the following:

With regard to assuring operability of systems and components, Quad Cities has followed guidance provided in the Generic Implementation Procedure (GIP). Section 2.2.5 of the -

GIP describes in detail the guidelines used by Quad Cities in implementing its responsibility to reporting under the USl A-46 program.

GlP Section 2.2.5 states: " failure ofequipment to meet GIP Initial screening or outlier resolution guidelines does not, ofitself give rise to a needfor the licensee to consider a JC0 or reporting under applicable reporting requirements unless the plant has modifed its commitmems to adopt the USl A-46 (GIP) methodology as its licensing basisfor vershing the seismic ade quacy ofelectrical and mechanical equipment, as setforth in Paragraph 2.3.3 below. Ifa determination is made that equipmentfailing to meet the GIP initial screening or outlier resolution guidelines does not meet the existing plant licensing or design bases.

inchtding specipc plant commitments and requirements. the licensee must consider reportability and operability implications pursuant to Technical specifications and 10 C.FR 50. 72, 50. 73 and 30.9, among others as appropriate, including the needfor JCO. Non-safety grade equipment selected for use in A 46 is not exemptfront reporting requirements.

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ATTACHMEN f A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97.232 (Page 3 of 15)

There is no independent requirement to notify the Staffwhen an outlier or equipment deficient against A-46 criteria, ahich is not a deficiency against the plant's licensing or design basis, will not be modified to conform to the A-46 guidelines. However, licensees willreport unresolved A-46 outliers or equipment deficient against A 46 criteria to the NRC Stafin theirfinal summary reports. These reports willinclude an explanation ofthe safety implications ofnot modifying the outliers or equipment deficient against 4 46 criteria. The Stafwilljustify any requirement to modify these outliers under 10 C.F.R. 50.109 as stated in Section 2.3.) below."

The GIP methodology screens out equipment which passes a ret of conservative, generic, seismic adequacy criteria, Equipment which does not pass this sercen is identified as an outlier and either is resolved by one of the resolution methods described in the GIP (Part II, section 5.3) or is left as an unresolved outlier. As discussed above, reportability and operability determinations under 10 C.F.R. 50.72 and 50.73 are not part of the GlP methodology and are not considered unless the unresolved outlier is also a condition outside the plant's design basis.

In response to "...you are requested to provide thejustificationfor assuring operability ofthe affected systems and components.., " we provide the following:

Quad Cities has reviewed all outliers against its seismic design basis in accordance with GIP methodologies. Problem identification Forms (PIFs) were generated for outliers which were identified by the Seismic Review Team as possible operability issues. He operability of components and systems was reviewed utilizing Quad Cities Procedure QCAP 0230-07, " Operability Determination". We have determined that the equipment meets its design basis and that the GIP outliers are not reportable in accordance with 50.72,50.73 or 50.9,

3. In the Relay Evaluation Report, Section 3. 7.3, it is stated that, "Ofthe 1249 contacts enluated using the Seismic Capacity Screening process, 654 ofthe contacts passed "

The number ofthe contacts that didnotpass uould, therefore, be 595 instead of$62, as stated. You are requested to clanfy this discrepancy, After the initial screening, 5 additional ielays were found to be not vulnerable (NV) and 28 instruments were found to not have contacts and, therefore, could not chatter. Therefore, the 1249 contacts should have been 1216 contacts.

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ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 4 of 15)

4. In Appendix C to the Seismic Emluation Report, "Qnaa Cities Nuclear Station Walkdown Personnel Resumes," and Appendix A tu the Relay Evaluation Report,

" Resumes ofIndividuals Performing Relay Review," certapcates were not provided to demonstrate that those who participatedin the seismic walkdown inspections and relay review have completed all the necessary seismic quah) cation utilitygroup (SQUG) training courses. You are requested to provide appropriate documentation to demonstrate that these individuals are quah)ed to participate in the USI A-46 Implementation Program.

L Attached are the certifications for Karl Adlon, Steve Anagnostis, Charles Beck, Jerry Bednarczyk, Walter Djordjevic, Scott Eckhart, Harry Johnson, Robert Kennedy, Bruce Lory, John Stevenson, George Thomas and hiike Warpchoski S. In Section 4,1,1 ofthe Seismic Emluation Report, it appears that in some cases, the seismic demandfor equipment located within 40-feet above the efectre grade has been defined by the Housner ground response spectrum (GRS) instead ofthe amphped in-structure response spectra (IRS). Providejustificationfor using this approach at the Quad Cities site (shallow soillayer on competent rock), where the amplyicdIRSis shoun to be higher than the GRS (Figure B-5 in the Appendix B of the Seismic .

Emluation Report).

The Quad Cities Updated Final Safety Analysis Report (UFSAR), Section 3.7.2.1.1.1 states "Since the buildings [ Reactor-Turbine Building] are founded directly on rock, they are assumed to act with the ground motion at the foundation level" The UFSAR Appendix 2A details work performed during original construction to " establish the capability of the bedrock for supporting the Quad-Cities Power Plant." Also, Section 3.2 of the Summary Report states "The buildings are founded en bedrock so any soil structure interaction effects were considered negligible". Quad Cities is not a " shallow soil layer" as suggested in Question 5 of the USNRC's RAl.

In accordance with hiethod A of the GIP, the use of a ground response spectrum for comparison to the GlP bounding spectrum is an acceptable means of capacity screening within 40' of grade. Comed (Letter dated January 15,1993) submitted the ground spectrum as well as amplified in-st: teture response spectra to the USNRC for review, in its Reference B letter, the USNRC responded that the floor spectra wece acceptable for use as " conservative, design" spectra. No restrictions were noted in that letter with regard to the use of GIP hiethod A vs. hiethod B for purposes of capacity screening. Therefore, these spectra were used for capacity screening at Quad Cities.

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-COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 5 of 15)

6. In Section 4.1.1 end Appendix B of the 3eismic Evaluation Report, it appears that at Quad Cities, the IRS atjeors within 40-feel above the epctive grade are above the Bounding Spectrum (BS), and in some cases, above 1.5xBS at a number offrequencies (e.g., Reactor Building elemtion 623.00, Figure B-4). Provide additionalinformation regarding the procedures used in assessing the seismic adequacy ofequipment and their anchorages in such cases.

I j- It is acceptable and in accordance with the GIP to use Method A capacity screening l (ground spectrum vs. bounding spectrum) for equipmcnt located within 40' of grade (as are the equipment found on Elevation 623') if the estimated fundamental frequency of that equipment is not less than 811z. Quad Cities is utilizing Method A for the majority of equipment assessments for equipment located on Elevation 623' For equipment located on Elevation 623' and for which the fundamental frequency may be below 8 liz, such as with motor control centers (MCCs), Method B (in-stmeture response spectrum vs.

reference spectrum) is used for capacity screening. Sir.ce the in-structure spectrun:

exceeds the reference spectrum, the MCCs hre been declared outliers.

7. GIP-2 (Section 4.4) recommends that expansion anchors not be usedfor anchoring vibratory equipment, such as pumps andair compressors. Ifused GIP-2 recommends ..

large margin between the pullout loads and the pullout capacities. The screening vertBcation data sheets (SVDS) in Appendix D to the Seismic Evaluation Report do not provide any information regarding the type of anchors usedfor the listed equipment.

Provide information about the seismic adequacy ofvibratory equipment secured by expansion anchors.

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ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 6 of 15)

The Safe Shutdown Equipment List (SSEL) pumps and compressors are listed below. Of these, only the control room HVAC compressor (1/2-9400-102) skid is mounted with concrete expansion anchors with a calculated safety factor of 9.53.

Equip. No. Equip. Name CEAs?

1/2-9400-102 CR llVAC Compressor Skid Yes 1-4609A/B DG Air Compressor Skid No 1/2-4609A/B DG Air Compressor Skid No 2-4609A/B DG Air Compressor Skid No 1-1001-65A l A RHRSW Pump No 1-1001-65C IC RHRSW Pump No

! l-3903 DG Cooling Pump No l l-5203 DG Fuel Transfer Pump No l l-5208 DG Fuel priming Pump No l-5209 DG Engine Driven Fuel Pump No l-6650 DG Scavenging Oil Pump No 1-6651 DG Main Lube Oil Pump No 1-6666A DG Engine Driven Cooling Pmp No l l-6666B DG Engine Driven Cooling Pmp No 1/2-3903 DG Cooling Pump No 1/2-5203 DG Fuel Transfer Pump No 1/2-5208 DG Fuel priming Pump No 1/2-5209 DG Engine Driven Fuel Pump No 1/2-6650 DG Scavenging Oil Pump No

!!2-6651 DG Main Lube Oil Pump No 1/2-6666A DG Engine Driven Cooling Pmp No '

1/2-6666B DG Engine Driven Cooling Pmp No 2-1001-65A 1 A RHRSW Pump No 2-1001-65C IC RHRSW Pump No 2-3903 DG Cooling Pump No-2-5203 DG Fuel Transfer Pump No 2-5208 DG Fuel priming Pump No 2-5209 DG Engine Driven Fuel Pump No 2-6650 DG Scavenging Oil Pump No 2-6651 DG Main Lube Oil Pump No 2-6666A DG Engine Driven Cooling Pmp No 2-6666B DG Engine Driven Cooling Pmp No 1-1002A l A RHR Pump No 1-1002C IC RHR Pump No

' 2-1002A 2A RHR Pump No 2-1002C 2C RHR Pump No e

a c- ATTACHMENT A COMED RESFONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY-ISSUE A-46 SVP-97-232 (Page 7 of 15)

8. Section 6 of the Seismic Emluation Report provides a summary descriling the methodologyfor enluating large, flat-bottom, vertical tanks. Hou ever, Table 6.1 does not contain information about such tanks. Ident@ the large, flat-bottom, vertical tanks that are not listedin Table 6.1, andprovide thefollowing relatedinformation:

a. Sketches showing tank dimensions, anchor chair.;, anchorages (including embedment), andfoundation.

, b. A detailedcalesdation ofa representative tank which

[ demonstrates the seismic adequacy ofthe tank utilizing the GIP-2 procedure.

There are no large, flat-bottom, vertical tanks on the Quad Cities Safe Shutdown Equipment List since none were required to achieve safe shutdown and maintain it for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The discussion of the evaluation oflarge, flat bottom tanks was erroneously included in the Quad Cities Seismic Evaluation Report.

9. Section 7.3 ofthe Seismic Evaluation Report indicated that 8 out of11 limited analytical reviews (lARs) performed required outlier evaluations. In light ofthe result, provide a justi)cationfor not expanding the reviews to a larger sample si:e.

All vital areas of the Reactor Building and Turbine Building, as well as the Aux. Electric Equipment and Cable Spreading Rooms were walked down by the Seismic Review Team (SRT). Eleven LARs were chosen to be representative and bounding - i.e., worst ease

. examples. Of the eight outliers, three had been previously analytically resolved.

Based on the walkdowns, the supports can be classified in three general types: ,

e wall-mounted hangers -

e rod trapeze suspended hangers e floor-mounted hangers The wall-mounted hangers represented by LARs 005,006 & 009 pass the screening assessment in accordance with the rules of Section 8 of the GIP.

The rod trapeze, suspended hanger is the most common raceway hanger at Quad Cities.

Five of the eleven LARs (LARs 001,003,007,010, & 011) chosen address this hanger type. Only LAR 011 remains unresolved and this is due specifically to the situation of short hangers interspersed among longer hangers. As stated in Table 8.2 (A-46 Equipment Outliers), " additional walkdowns to identify this specific hanger type may be required in the Reactor and Turbine buildings",

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ATl'ACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 8 of 15)

The fmal conunon hanger type at Quad Cities is the floor-mounted hanger. This hanger type is not ubiquitous at Quad Cities; rather, each design is unique and specifically located in one room or area of the plant. In other words, these unique designs occur at one location in the plant and nowhere else within Quad Cities.

LAR 002 is a very short run in the cable spreading room comprised of only 5 supports, e

LAR 004 is an intermittent hanger type (interspersed between other hanger types) in the cable tunnel.

LAR 008 is unique to a specific location on elevation 639' of the Turbine building, e

LAR 012 is a unique support post design found only in the vicinity of the hydraulic L control units.

l l Whereas these supports may represent outliers, expansion of the sample would not lead to L

other outliers or additional lessons learned since these examples comprise all of the types of floor mounted hangers at Quad Cities.

In conclusion, LARs were selected for worst case examples for each type of cable tray

[ hanger. Resolutions will be applied to hangers that fit that outlier hanger type, as needed.

! Therefore, there is no need to expand the reviews to a larger sample size.

l I

10. In reference to Table 7.3 in the Seismic Evaluation Report, L4R 001 involved a rod hung trape:e supporting 3-tier cable trays. Provide detailed calculations showing how the outlierfor L4R 001 support was resolved, including thejustspcationfor the use ofthe rodfatigue test data and the generic acceptability curvefrom SEP Project 8050.

With respect to LAR 001, this system is one in which short hangers are interspersed among longer hangers. The GIP screening methodology is not suitable for such systems.

Using the redundancy / consequence approach in Section 8.4.8 (Outlier Analysis) of the GIP, the short hangers are allowed to fail and the entire load must then be carried by the remaining longer hangers. In this state, it is shown that the ductility factor for the remaining longer hangers is less than unity; thus, there is no rod fatigue concern.

While the Systematic Evaluation Program (SEP) rod fatigue data is quoted within the calculation, the curve is comparable to Figure 8-4 in EPRI Report NP-7152 D. Our calculation results are within the criteria limits of the SEP curve. The EPRI Report NP-7152 D curve duplicates the results of the SEP Project cun'e.

The calculation requested is in the process of being transferred to the site Once the process for transfer is complete we will forward the calculation. This is expected to be completed by December 1,1997, l

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ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A_46 SVP-97-232 (Page 9 of 15) 1L in reference to Table 7.3 i'n the Seismic Emluation Report, a number ofoutlier resolutionsfor the raceway hangers were performed based on Ihe high-confidence-low-probabilin-of-failure (HCil'19 and the CL)lM methodologies, u hich, in view ofitem ),

are not acceptable to the staf Provide an alternate methodfor resolution ofthese raceway outliers, andprovide a schedulefor imnlementing the resolution.

The capacity estimates given in Table 7.3 were calculated for unresolved cable tray system outliers only They were calculated in accordance with the Generic implementation Procedure (GIP) methodology as approved by the USNRC (Reference D), not using the conservative determirktic failure margin (CDFM) methodology. HCLPF values were not i used for the resoluion ofoutliers and were provided for staffinformation.

Only methodologies acceptable to the rafiand in accordance with the GlP have been and will be used for outlier resolution, incluing cable tray outliers.

I

12. Tables 8.1 and 8.2 in the Seismic Emluation Report show a number ofpieces of equipment that do not meet the seismic demand. The SRThas recommended methodsfor resching these outliers, Provide a table showing how these outliers were actually resolved The following table provides the current outlier resolution status.

ID EQUIPMENT A-46 OUTLIER FINDING RESOLUTION / COMMENT A01 Hydraulic Control- 1) Equipment type outlier 1) Outlier resolved in original A-46 Unit 2) Red gas bottles at South bank restrained report.

UIHCU by only one chain. An orange gas bottle 2) Gas bottle lower chain replaced. Re-and an unrestrained green trash can are located trash can. Walked down on 12-impact hazards. 13-96. Issue resolved.

A02 Hydraulic Control Equipment type outlier. Outlier resolved in original A 46 report.

Unit U2 HCU A03 Nitrogen Bottle Nitrogen bottle is restrained only by top WR960116774 expected completion in N/A (1). N/A (2) chain. 1998.

A04 Exhaust Silencer Silencer saddle not positively supponed. 1) Calculation has been prepared and is 1-6667 in review.

1/2 6667

2) One saddle to be welded to base plate.

2-6667

t -ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 10 of 15)

ID EQUIPMENT A-46 OUTLIER FINDING RESOLUTION / COMMENT A05 Fans and Dampers Scismic demand exceeds capacity. Realistic, median centered floor spectra 1;l/2;2-5727 to be developed. in 1998.

MCC 28 3 MCC 291 250VDC MCC 1 A; IB; 2A; 2B Transformers MCC 28-1 A 1 TR MCC 291 1 TR cWCR 12 TR; 19 TR; 28 TR; 29 TR A06 Unit 2 250 VDC Right tear anchor bolt missing. WR960118673 expected completion in Battery Charger 1998.

A07 MCC and Panel 1) Seismic demand execeds capacity. 1) Realistic, median centered floor MCC 181 A 2) Unit has missing or loose sheet metal spectra to be developed. in 1998.

MCC 191 1 screws which attach to the base chanacl. 2) 18 I A: WR960117196 completed l-MCC 191 1 PNL 20-97 MCC 281 A 19-1 1 & PNL: WR960117208 expected completion in 1998.

28 I A: WR960l!7250 completed I 20-97 A08 MCC 1) Seismic demand exceeds capacity. 1) Realistic, median centered floor MCC 18-3 2) MCC is not bolted to adjacent spectra to be developed. in 1998.

distribution panel (3/16" gap). 2) WR970000974 expected completion in

3) Missing several corner sheet metal 1998, screws uhich attach to the base channel. 3) WR960117201 completed 1-20 97 A09 Motor Control Center I) Scismic demand exceeds capacity. 1) Realistic, median centered floor MCC 19-1 2) The welding includes both 19 1 and 19- spectra to be developed. in 1998.

6 and is not well distributed. Welds 2) MCC weld to embed to be upgraded.

should be upgraded on the left end unit 3) WR960117198 completed 120-97 and the 2 right end units (next to 19-6).

3) Missing some sheet metal screws.

A10 Motor Control Center 1) Seismic demand exceeds capacity. 1) Realistic, median centered floor MCC 19-4 2) The welding for 19-4 is not well _ spectra to be developed. in 1998.

distributed. Welds should be upgraded on 2) MCC wcld to embed to be upgraded.

left end of 19-4 (next to 19-1 1).

Ai1 Panel 1) Seismic demand exceeds capacity. 1) Realistic, median centered floor 2201 32 2) 1/4" gapped anchorage on one side of spectra to be developed. in 1998.

panel. 2) WR970017123 expected completion in 1998.

A12 Panel Seismic demand exceeds capacity. Realistic, median centered floor spectra 2202-32 to be developed. in 1998.

A13 Damper Damper on small duct line which may Damper connection to damper ta be 2-9472-32 disconnect. upgraded.

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ATTACHMENT A COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SVP-97-232 (Page 11 of 15)

ID EQUIPMENT A-46 OUTLIER FINDING RESOLUTION / COMMENT A14 MCCs 1) Seismic demand exceeds capacity, 1) Realistic, median centered floor MCC 18 I A 1 2) MCC or panel is not bolted to adjacent spectra to be developed. in 1998.

MCC 281 A 1 Panel. 2) PNL2 to 28-1 A: WR970000976 MCC 181 A 1 PNL expected completion in 1998.

MCC 28-1B 28-1-1 TO 281B: WR970000975 PNL #1 expected completion in 1998.

! PNL #2 - 18-1 1 TO 18-1B: MCCs were opened, are bolted together and is resolved.

A15 MCC and Panel 1) Seismic demand exceeds capacity. 1) Realistic, median centered floor MCC 29-1 1 2) MCC or Panel is not bolted to adjacent spectra to be developed. in 1998.

MCC 291 1 PNL Panel (there is only a 3/8" gap). 2) WR970000977 expected completion in MCC 29-4 1998.

A16 MCC I) Seismic demand exceeds capacity. 1) Realistic, median centered floor MCC 181B 2) MCC 18-1B is right next to (touching) spectra to be developed. in 1998.

MCC 181 A l but not bolted together. 2) 181 1 TO 18-1B: MCCs were opened,

3) Unit has deficient welds and welds are bolted together and is resobed should be added. 3) MCC ucid to embed to be upgraded.

4) Missing sheet metal screws. 4) WR960117202 comDieted 120-97 Al7 Bus Panel is 1/2" away from block wall on rear Resobed. Calculation QDC-8300-S.

125 VDC BUS l A and it is an interaction hazard. 0441 shows that equipment will not 125 VDC BUS 1 A-l contact wall.

A18 125 VDC Bes 1B 1) Anchorage demand exceeds capacity 1) Weight and demand calculation to be 125 VDC Bus IB 1 based on conservative weight estimate. completed in 1998.

2) There are lights above the units with 2) WR960117357 completed 1-7-97.

open hooks and it is an interaction issue.

A19 MCC I) Weld to embedded angle distributed 1) MCC weld to embed to be upgraded.

250VDC MCC 2 - fairly even but unsymmetric. 2) WR960117358 completed 17-97.

2) Lights above units with open hooks.

A20 Panel Nearby cable tray support is an impact Cable tray support will be attached to the 2202-70B hazard. panel.

A21 Panel Adjacent gas bottle with single loose chain , h960116774 expected completion in 2212-32 is an impact hazard. < )98.

A22 Panel 912-8

' Resolved. Deleted since safe shutdown system not on SSEL A23 MCC + Batt. Chargers Overhead fluorescent light above hung Resol ed.

MCC 18-2 with an open S-hook U-1: WR960117356 comnieted 1-7-97.

1-8300-1 A U-2: WR950117358 comnieted 1-7 97.

1 8350 2 8300-1 2 8300-1 A -

2-8350 1 8300-1 r

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COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND %

UNRESOINED SAFETY ISSUE A-46' SVP-97-232 (Page 12 of 15)

YD EQUIPMENT A-46 OUTLIER FINDING RESOLUTION / COMMENT A24 Cooler Cooling water line lacks flexibility and Detailed analysis of coolers and supports 15746A, B since cooler is rod lumg so water line may to be completed in 1998.

2 5746A, B be in danger of breaking due to l

l 5747 displacement potential of rods.

2 5747 l 5748A B 2 5748A, B T25 Cooler Bolt type is not covered by the GIP Cinch Outlier is resolved in original A-46 1-5745A Anchor. Bolt type and size are usumed to report.

15745C be the same as the ones used in Dresden 2 5745A - which are 1/2" Cinch Anchor.

2 5745C 1 5749 1/2-5749 '

2 5749 A26 Switchgear Overhead trolley hoist is an impact Trolle3 movement to be restrained in SWGR 28 hazard. 1998.

SWGR 18 SWGR 19 A27 Switchgear Overhead trolley hoist is an impact hazard Trolicy movement to be restrained in SWGR 29 and needs to be parked. 1998.

A28 Switchgear 1) Could not open units to determine if the 1) Breakers need to be racked out and SWGR 131 units are plug welded at the base. removed for inspection. Will perform i

SWGR 141 2) Verify if end two units of SWGR 141 inspection in 1998 or assume that welds SWGR 231 are tied to other 10 units, are not present. ,

SWGR 241 3) Spare breaker stored near SWGR 241 2) Resolved. Drawing 4E 10541, Sect.

is an impact hazard. A-A shows the cubicle-to-cubicle bolting of the added cubicles.

3) QCOP 6500-04 revised to include designated storage .xations. Issue resolved.

A29 Switchgear. 1) Could not open units to determine if the 1) Breakers need to be racked out and SWGR 13 units are plug welded at the base. removed for inspection. Will perform SWGR 14 2) A light with open S-hooks abos e the inspection in 1998 or assume that welds SWGR 23 switchgear is an impact hazard. are not present.

SWGR 24 3) Spare breaker stored near SWGR 24 is 2) Completed:

an impact hazard. U-1: WR960117356 completed 1-7 97.

U-2: WR960117359 completed 17 97.

3) QCOP 6500-04 resised to inelude designated storage locations. - Issue resolved.

A30 Panel 90139 Anchor at corner of panel is loose. WR960057190 completed 1-14-97.

A31 Panel 902-48 Panel has one gapped anchor (loose WR960057185 completed 5-6-97.

washer).

e . _

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l o

ATTACHMENT A COMED RESPONSE TO NRC REOUEST EQR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 ann.2 UNRESOINED SAFETY ISSUE A-46 SVP-97-232 (Page 13 of15)

ID EQUIPMENT A46 OUTLIE R FINDING RESOLUTION / COMMENT A32 2202 70B to 902 39 Panelis not bolted to adjacent panel WR97(KKX1978. WR97tKKK)979, 90132 to 90146 WR97(KKK)981 and WR960118685 90133 to 90147 to exlected completion in 1998.

901 48 N246 to 902 38 A33 Panel I Cabinet is too close to a conduit snugly WR960ll771

• spected completion in 2252 10 against the wall which thus poses an 1998.

impact hazard.

A34 Panel Tool Bot (on whccis) located next to Tool box moved. Scismic flousekeeping 2251 12 Pancis and the Exciter Impact flazard. Procedure to be completed in 1998.

2251 98 A35 Panel Adjacent ductwork supported on rod Duct to be attached to panel. ,

902 33 hangers is 1/4" away (gap) frota top of cabinet and poses an interaction harard.

A36 Panel Panel internal PC card racks for w hich PC boards in 902 27 hate nylon 901 27,902 27 cards falling out of very flexible internal "retaincts" and ,therefore, will not tack is a concern. disc. anect during scismic event. Unit I will be inspected in 1998.

A37 Panel 1) Panel is not bolted to adjacent panel 1) WR970(KN)981 expected completion in 901 33 901-47, thus it is an impact hazard. 1998.

2) Ad,iacent ductwork supponed on rod 2) Duct to be attached to panel.

hangers is 1/4" away (gap)from top of cabinu and poses an interaction hazard.

A38 Battery Rack Some Styrofoam spacers on the fiont or Resob ed.

125 VDC BA'IT I ends of the rack are short and can fall WR960073145 ERSIRktqd 8 29 96.

250 VDC BATT 1 loose (that is, through) and a few already WR960073139 comnlewd 8 22 96.

125 VDC BA'IT 2 have even though there has been no carthquake.

A39 Battery Rack 1) Some Styrofoam spacers on the fiont or 1) WP960073139 completed 8 22 96.

250 VDC DATT 2 ends of the rack are short and can fall 2) Nuclear Logis'ics Inc. is reviewing loose (that is, through) and a few already aged battery report for applicability.

have even though there has been no Response espected in 1998, carthquake.

2) Battery is 10 years old.

A40 Valve Valve is located in RWCU toom which is Outlier is resolved in original A46 1 0220-45 inaccessible therefore Caveats 7 9 and the report.

2 0220-45 resiew for scismic interaction cannot tw resolved. Valve is located on a 3/4" line which lies outside of the GIP database thus Cavents 4 and 5 cannot be resolved.

e

. ATTACllMENT A

COMED RESPONSE TO NRC REOUEST FOR ADDITIONAL,

! INFORMATION OUAD CITIES. UNITS I AND 2

! UNRESOINED SAFETY ISSUE A-46 SVP-97-232 l (Page 14 of 15) l l ID EQUIPMENT A-46 OUTLIER FINDING RESOLUllON/ COMMENT

! A4i Rack Rack mounted (cnclosed in pancl) lo be replaced with Mercold Snap Action PE 1 Mercold switch which is designated as (Orange liigh) mechanical soitch or

" bad actor". equivalent.

A42 Pressure Switch Missing one of the 4 screws attaching it to DCp 9600383 to replacc switch.

1464142A ,

the support.

A43 RHR lirat Exchangers Support steel was identified as marginal Comed evahrated and made 1 +2 1003 A+ B based on design basis resiew and A-46 modifications to (upgraded) the supports.

(SQUG) assessments. Remh ed.

A44 Cable Spreading Unit 1/2 Cable Spreading Room. The Outlict ruohed in original A 46 report.

lloom support is a 3-tier, rod hung trapea LAR 001 supporting 3 trays. The support has two different types of ceiling anchorages. The embedded strut vctsion loads execed allowables for the vertical capacity check.

A45 Cable Spreading Unit 1/2 Cable Spreading Room. The Additional walkdowns, enal)ses and Room support is an unbraced floor mounted evaluations will be performed and .'.e LAR 002 Unistrut frame with 6 tiers. The loads in design of support upgrades, as required, the bolted post connections to the floor will be completed in 1998.

baseplates exceed allowables for the lateral load check.

A46 Unit 1&2 Cable Cable Tunnels. The support is an eight Additional walkdowns, anal > ses and Tunnels tier, floor to ceiling, unbraced frame evaluations will be performed and the LAR 004 supporting four tra3s. The wcided floor de:ign of suppori upgrades, as required, anchorage is not ductile. The stress in the uill be completed in 1998.

welds exceeds allowables for the lateral load check.

A47 Turbine Building Turbine Building, El. 639. The support is This outlict is resobed by outlier Units 1/2 a 2 tier, rod hung trapen supporting 2 analysis. See original A-46 Report.

LAR 007 trays. The support loads in the welded sicci anchorage exceed the allowables for the vertical capacity check. The rod fatigue check was also not met.

A48 Turbmc Building Turbine Building, El. 639. The support is Additional walkdo.vns, arialyses and Units 1/2 an unbraced, floor mounted, Unistrut evaluations will be performed and the LAR 008 frame with 2 ticra supporting 2 trays and design of support upgrades, at squired, 2,3" conduit. The left post welded floor will be completed in 1998, anchorage is not ductile. The stress in the wcids exceeds allowables for the lateral load check.

ATTACliMENT A i

C_QMED RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION OUAD CITIES. UNITS 1 AND 2 UNRESOINED SAFETY ISSUE A-46 SVP-97 232

.(Page 15 of 15)

ID EQUIPMENT A 46 OUTLIER FINDING RESOLUTION / COMMENT I 1

A49 Turbine Building So. Turbine Buildmg. El. 619. The support is This outtler is rewhed by outlict i End a 4 tier, tod hung trapete supporting 4 analpis, Sec original A 46 Report LAR010 trays. The support has three different types of ceiling anchorages, the loads for  !

two of which, the embedded strul and shell

! anchor versions, exceed allowables for the

^

vertical capacity cho:lc A50 Reactor Building Reactor Building Units 1/2, El. $95. The Additional walLdowns, analyses and Units 1/2 support is a 2 bay,3 tier, tod hung trapeze evaluations will be perfonned and the i LAR011 supporting 6 trays. The support has two design of support upgrades, as required.

different types of ceiling anchorages. The will be completed in 1998. ,

embedded strut version loads execed

] allowables for the vertical capacity check and the rod fatigue evaluation criteria due

, to short hanger rods interspersed among

longer rod hangers. This general problem

of mixed long and short hangers exists in

, the Turbine building, also. ,

A51 Reactor Building HCU cable duct support in the Reactor Additional walkdowns, analpes and Units 1/2 Building Units 1/2, El. 395. The support evaluations will be performed and the LAR012 consists of a 3" pipe column,91/2 ft tall design of support upgrades, as required.

supporting a 8"x24" cable duct containing will be completed in 1998.

the equivalent of fifteen (15) 3" conduit.

The anchorage loads exceed the allowables for the lateralload check.

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