View source for NPL-97-0450, Forwards 30-day Response to 970516 RAI Re GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. Three Oversize Drawings Encl

{{Adams
| number = ML20217G196
| issue date = 07/31/1997
| title = Forwards 30-day Response to 970516 RAI Re GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. Three Oversize Drawings Encl
| author name = Johnson D
| author affiliation = WISCONSIN ELECTRIC POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000266, 05000301
| license number = 
| contact person = 
| document report number = GL-87-02, GL-87-2, NPL-97-0450, NPL-97-450, NUDOCS 9708070118
| package number = ML20217G200
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 46
}}

=Text=
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Wisconsin Electnc POMR COMPANY twi t%cn 90%, ryy,,                                                                             M IV> MI WD Nuctwv kd , two 99,,, wi g,4pai NPL 97 0450 10 CFit 50.4 July 31.1997 Document Contial Desk US NUCl.l! Alt f(110UI A10l(Y COMMISSION Mail Station I'l 137 Washington, DC 20$$$
1.adies/ Gen'lemen:
q       1]RCKl!TS 50 266 AND 50 301 i!Qil'DNSE TO RiiOUEST FOR ADIE110NAldNFORM ATION DENIMC11ilTl!R 87-02.VERillCAllCFJOL9i]SjlC ADEOUACY OLA1ECllAMLCAl, ANRELECIRICAl> liQLilPMl!NT IN OPl!RATINO RI? ACTORS l'Q1N1111MCimilCLEA1(l'l, ANT.1,LNIIS 1 AND 2
)
Your lettes dated May 16,1997, requested additional information related to Generic 1.etter 87 02. You requested this infonnation within 30 days of our receipt of that letter. Our {{letter dated|date=July 7, 1997|text=letter dated July 7,1997}}, replied to the somponent cooling water system issues in response to your request for additional information. As discussed with our NRR l'roject Manager, Ms.1.inda Gundnun,it was acceptable to postpone our response to the remaining issues until July 31,1997. This extension has provided us with the opportunity to incorporate knowledge gained from recent industry conferences on the subject.
Our response to the remaining items contained in your request for additional information is pMvided in Attachment A to this letter.
q If you require additional information, please contact us.
Sincerely,
     , KYWML.                            kcm Douglas F. Johnson                                                                          o5 ' ,
o.o     Manager, rg       llegulatory Services & l.icensing h       Attachment withlinclosures NRC ltesident inspector (with attachment, w/o enclosures 1 g5" cc:        NRC Regional Administrator (with attachment, w/o enclosures)                          l lllll('l]'
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Attachment A to NPL 97 0450 WISCONSIN Fl.ECTRIC RESPONSE TO Rl!OUEST FOR ADDITIONAL. INFORhiATION POINT IlEACll NUCLEAR Pl ANT. UNITS I AND 2 UNRESolNED SAFETY ISSUE A 46 SUMh1ARY REPORT. DATED MAY 16.1997
: 1. AdrJn!pey of Seismic Demand Detennination (Ground Spectra and in Structure / Floor Resoonse SPIIIIU1 LLutstion la, identify structure (s) that have in structure response spectra ($ percent of critical damping)for elevations within 40-feet above the effective grade, which are higher in amplitude than 1,5 times the Seismic Qualification Utility Group (SQUG) llounding Spectrum.
Rsironse lam The effective grade for all structures at Point lleach Nuclear Plant (PUNP) is established at 8'.
The following table lists those structures for which the 5% damped horizontal ISRS, for
                   - elevations within 40' above the effective grade, are higher in amplitude than 1.5 times the Generic implementation Prceedure, Revision 2 (GlP4)(reference 1) llounding Spectrmn.
Table 1 1 Elevations w het e 5% damped PilNP Structures                       horiiontal ISRS > 1.5 x ilounding Spectrum Control lluilding                                          26' 44' Pipeway #1                                                 6.5' 15' 23' Pipeway #2                                                 26' (Pipeways # 2 & 3 are similar in                           36' construction, use the same building                        47' model and have the same ISRS)
Pipeway #3                                                 26' (Pipeways # 2 & 3 are similar in                           36' construction, use the same building                        47' model and have the same ISRS)
                                                                                                                      )

Attachment A to NPL 97-0450 Page 2 of 22 WISCONSIN El.ECTRLC kBSPONSE TO IEOUEST FOR ADDITION AL INFORM ATION POINT ilEACll NUCI EAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 Question Ib.
H'ith 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 adequacyfor equipment Installed on the correspondingfloors in the structure (s) Identified in item (a) above. ifyou have elected to use method A In Table 41 of the GIP-2, provide a technical)ustificationjbr not using the In-structure response spectra provided in your 120-day response.
Ennonse Ib.
The following table provides the number of equipment items on the USl A-46 Seismic Safe Shutdown Equipment List (SSEL) located at each of the buildings & elevations identified in "la" above.
Table 12 Elevations w herc     # of items w herc      # of items u here PilNP          5% damped              Capacity vs.          Capacity vs.
Structures     horisontal ISRS >    Demand check used         Demand check 1.5 x Ilounding     Method A in Table       used Method 11 in Spectrum             41 of GIP 2        Table 41 of GIP-2 Control                 26'                     O                     52 Iluilding 44'                    0                     15 Pipeway #1             6.5'                    2                      0 IS'                    0                      0 23'                    0                      0 Pipeway #2              26'                    0                       1 36'                    0                      0 47'                     0                     0 Pipeway #3              26'                     0                      2 36'                     0                      0 47'                     0                      0 Of the 72 items located at these building / elevations,2 components, ISI 866A and ISI 866B were evaluated for seismic capacity vs. demand using Method A of Table 4-1 of GlP-2.

Attachment A to NPL 97 0450 Page 3 of 22                                                                                                      i WISCONSIN Ell!CTRIC                                              !
RESPONSI! TO REOUEST FOR ADDITIONAL INFORhtATION                                     i POINT !!HACll NUCLEAR PLANT. UNITS 1 AND 2 UNRESOINIID SAFETY ISSUE A 46 SUhihiARY REPORT DATED MAY 16.1997                                  f I
hiethod A of Table 41 was used because ISI 866A and ISI 86611(the Equipment Class 8,             !
hiotor Operated Valves being evaluated) meet the caveats for applying this capacity vs. demand comparison. For PilNP, the llousner Ground Response Spectrum (ORS), anchored at 0.12g is defined at the free field ground surface. The PilNP $% damped flousner ORS Safe Shutdown Earthquake (SSE)is bounded by the OlP Dounding Spectrum as shown in linclosure 1, and the          "
valves are located on the 8' elevation which is < 40' above effective grade. Thercibre, it is directly applienble for comparison with the flounding Spectrum (Refe ence 9, page 100).           j Section 11.4.2 of the OlP 2 presena % methods that are both technically acceptable methods for     "
verifying that a component has sufficient seismic capacity to withstand the SSE. In fact, SSRAP encouraged the use of the llounding Spectrum vs. GRS comparison over the Reference Spectrum       ;
vs. ISRS comparison in order to avoid having to use ISRS which may be very conservatively determine (Reference 9, page 102).
Both Section 11,4.2.3 of GlP-2 and Appendix A of the SSRAP Report (page 105) discuss              ,
applying the llounding Spectrmu vs. free field ground response spectra with judgment, paying panicular attention to situations which could cause the amplification factor from the GRS to the ISRS to be greater than that of typical nuclear plant structures. In the case of ISt 866A and     !
1S16611, the piping system both upstream and downstream of the valves is very well supported.
These sections of pipe were estimated to be relatively stilt. It was thejudgment of the Seismic Capability Engineers that no out-of the-ordinary condition existed and that the US vs. GRS comparison was acceptable.
l i
i

Attachment A to NPL 97 0450 Page 4 of 22 WISCONSIN ELECTRIC BESPONSE TO REQUEST FOR ADDITIONAL INFORMATION POINT DEACil NUCI liar PLAN 7. UNITS 1 AND 2 i
UNlliSOLY[iD SAFETY ISSUE A 46 SUMM ARY REPORT. DATED M AY 16.1997 Gyestion ic, For the structures identitled it item (a) above, provide the in structure response spectra designated according to the helpht about effective grade. If the in structure response spectra Identijled in the 120-day-response to Supplentent No. I to GL 87-02 seus not used, provide the response spectra that svere actually used to ver# the seismic adequacy of equipment seithin the structures identified in item (a) above. Also, provide a comparison of these spectra to 1.$ times the flounding Spectrum.
Enponse le, Appendix 11 of the Point Beach Nuclear Plant (PUNP) Seismic Evaluation Report (References 6 and 7) provides the complete listing of the structures at PUNP and the corresponding 5%
damped, hori7ontal in structure response spectra (ISRS) for each elevation in a structure's building model. These are the same ISRS provided to the NRC in Wisconsin Electric's 120-day response to Supplement 1 of Generic Letter (GL) 87 02 (Reference 4) and used for the USl A.
46 Seismic Verification Project.
Enclosure i provides the plot of the 5% damped horizontal liousner Ground Response Spectra (GRS) plotted in comparison to the GlP Bounding Spectrum and the plots of the 5% damped horizontal ISRS for all of the structures at PDNP for those elevations within 40 feet of effective grade plotted in comparison to the GlP Reference Spectrum (1.5 x Hounding Spectrum).

    . ._- _ . - .                    . . _ =         .       . . .      - -          - = _ _ . -             - __    _
Attachment A to NPL 97 04$0 l' age 5 of 22 WISCONSIN 1:1.ITCIR[C RiiSPONSl! TO f(I! OUI!ST FOlt ADQlTION AL INI'Ol{M ATION POINT llEACil NUCllAILPL ANT. UNITS 1 AND 2 MBRESOLVEDJAFl!TY ISSUE A 46 SUhjM Al(Y 1(EPOl(L IMDJD M AY 16JS92                                           l l
: 2.       Sshulig_Mygacy of TadsJudUrnLEAdwutrD                                                                         i i
WlullWLbl l'on stated that the Rll'STl refueling water storage tank l,1(2)T-13, dhi not rneet the Section 7 evaluation rules of the GIP 2 (page 8 5, Ref I) (teferring to page 8 5 of the WE Scismic Evaluation iteport (reference 8) and are hientijled as outilers. l'oufurther stated that a detailed evaluation was performed in accordance with ilppendir 11 ofICPRI NP-6041. Since the liPRI NP 6041 <typendte 11 methodology is known toylehlless conservative results than those based on GlP-2 methodology, the staff did not accept the <lppendit ll methodology without a technicalJustljicationfor its acceptance.
                            )'our September 30,1996, response dhi not provide a technical)nstificationfor the tan A 's evaluation methodology (use ofitppendir 11 to EPRI NP 6041). The staff therefore requests thatyou identify allthe items whme acceptance were based on methodologies that differfrom the GIP 2 Guidelines andprorble afmrificationfor the acceptability ofeach item. If hen computer codes were used in arriving at certain conclusions, valldation docunwnts should be prorbled e.speciallyfor those codes where non linear analyses were performed. The validation should be beyond quality an urance / quality control arguments. It should include, as a minknum, a numerical error bound and a comparhan with physical data, in addition, analysis of a soll structure interactionfor the tank evaluation should aho be ruthlated, documented and submittedfor NRC review when it differsfrom the one used in constructing thefloor response spectra in your 120-day submittal or differsfrom the 1%tR flinal safety analysh report l when the subject was not dhcuued in your 120-day response.
Rup2 mas _2n The itefueling Water Storage Tank (ItWST) analysis was provided to the NI(C stalTas Enclosure 4 to Wisconsin Electric's response to the NitC's initial request for additional information (iteference 3) Enclosure 4 consisted of 5 documents listed as iteferences 10 through 14.
During a follow on evaluation of the seismic capacity of the itWST, Wisconsin Electric has detennined that the seismic capacity of the tank as calculated in lieferences 10 through 14 does not provide sufficient design margin for final resolution to the USl A-46 outlier. As a result. WE has decided to upgrade the scismic capacity of the tank with a structural modification, l
l 1 ,                   .            .                      .        -                             -     .          ..

Attachment A to NPL 97 0450 Page 6 of 22 WISCONSIN El.ECTRIC L'ESPONSE TO REOUEST FOR ADDITIONAL INF0Ehf ATION POINT DEACH NUCl. EAR Pl. ANT. UNITS 1 AND 2 UNRESOINED SAFETY ISSUE A-46 SUhihf ARY REPORT. DATED Nf AY 16.1907 Ouestion 2b on page 4/23 ofEnclosure 4 (#ef. 2) (referring to page 4/23 of the Point Beach Refueling Water Storage Tank Seismic Capacity Final Report, Reference 11), a Ilst offallure modes is provided, including item 4 "Globalshell bucAling due to overturning moments " flowever, a calculation was notprovidedfor this mode. Provide such a calculation and discuss why                                           '
buckling is not a governing mode offailure. Also provide validation documentation as discussed above.
Enponse 2b                                                                                                                   l The calculation for the global shcIl buckling due to overturning moments is incorporated into the                            l EPRI 6041 Appendix 11 procedure. The adjusted allowable base moment of 16.037 kip f1 and                                    .
the CDFM Peak Ground Acceleration (POA) capacity of 0.127g provided in Section 8 of the Point Deach RWST Seismic Capacity Final Report (reference 11) is based upon the global shell                                :
buckling failure mode as the governing failure mode. This RWST capacity is calculated in.                                    !
Stevenson & Associates calculation 91C2696 C003. Revision 0 Reference 12) transm!'ted as                                    :
part of Enclosure 4 to Wisconsin Electric's response to the initial request for additional information (Reference 3).
i t
The EPRI NP 6041 Appendix 11 procedure considers buckling in determination of the allowable tank shell compressive stress. The allowable compressive stress is then used as input into the equations for allowable base moment. These steps are very similar to the steps in the GlP 2 method for allowable base moment determination.
r I.
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f-
          . Attachment-A to NPL 97-0450 Page 7 of 22 WlSCONSIN ELECTRIC
: RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR PLANT. UNITS I AND 2 -
UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997-
: 3.      Seismic Adeauncy of Cable and{onduit Raceways i
Question 3 During our review of the GIP-2 Guidelines, the stafffound that the procedurefor ductile cable tray systems neededfurther evaluation. The guideline s aced that the ductile cable tray system is not required to be evaluatedfor a lateralload. The staffis currentlypursuing the resolution ofthis issue with SQUG.: A generic resolution, when established, should apply to the Point Beach plant cable trays as well, andym, should revise the evaluation of the Point Beach cable tray systems accordingly.
J For the interior of the cable spreading room, provide drawings ofcable trays, structural
(                   drawings ofthepoor and/or the ceiling ut the elevation where the cable trays are attached,      '
                   -poor response spectra (discuss how thepexibility of thepoor was taken into consideration) andfinal results ofcohle tray evaluation in terms ofdefection due to the system stress level. l
''                  Provide stiffness (naturalfrequencies) of the cable tray systems and supportingfloor andfor     ;
ceiling including weight of the cable tray andits contents such aspre retardant. Provide the
{
margins to the design limits and/orfailure. In addition, provide validation documents of any computer codes used to produce the results discussed above.
B_esponse 3 Section 7 of the Wisconsin Electric Seismic Evaluation Report, Revision 1 (References 6 & 7) provides the results of the Cable Tray and Conduit Raceway Review. The cable spreading room
                  ' (CSR) was designated as a separate walkdown area for the review. The results of the walkdown are recorded on the cable spreading room plant area summary sheet (PASS) provided in f                Enclosure 2.
Four Limited Analytical Review (LAR) cable tray supports were selected in the CSR, LAR 3,4, 5, and 10. The PASS form provides the plan view sketches of these four LARs. The LAR analysis is contained in Stevenson & Associates (S&A) calculation 91C2696 C-018 (Reference 16) and was submitted as Enclosure 5 to Reference 3. The analysis for the CSR LARs is contained on the following pages:
4 LAR#                   Pace #'s 3                 A18 to A24 4~-               A25 to A31 5                TA32 to A37 10                 A89 to A95 The cable tray supports in the CSR are mounted to the underside of the Control Building, 44' elevation floor slab. Bechtel Drawings C-181, C-183 and C-184 provided in Enclosure 3 are
                  . the associated structural drawings.
                                                                                          .a                      a

Attachment A to NPL 97 0450 Page 8 of 22 WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 The horizontal in-structure response spectra for the Control Building,44' elevation,5% damping is provided as one of the ISRS in Enclosure 1. It is plotted on the same graph with the Control Building 26' elevation. 5% damping and is plotted in comparison to the GIP-2 Refdcence Spectrum.
The analysis of the cable tray supports follows the methodology provided in Section 11.8 of the GlP 2. As a result, the cable tray deDections, and the stiffness of the cable tray systems and the supporting ceiling have not been determined. The cable tray supports that are identified as outliers will be upgraded using the analysis methodology and to the acceptance criteria provided in Section 11.8 of the GIP 2. Therefore, the deDection and stiffness parameters will not be determined for these cable tray systems.
The margins to the acceptance criteria for the LAR analyses are provide in _Section 7.5.1, Summary of Results, of the Wisconsin Electric Seismic Evaluation Report, Revision 1 (References 6 & 7). Table 7-2, Critical Interaction Values, provides the resultant critical interaction value(CIV) for each LAR analysis. A CIV > 1 indicates that the cable tray support has exceeded the allowable load limits.

t Attachment A to NPL 97-0450 Page 9 of 22 WISCONSIN ELECTRLC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR PI ANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997
: 4. Lisensee Event Report Question.f The Licensee Event Report 97-008-00 (Reference 3) discussed existence of non-seistnic duct work located above safety-related equipment in the containtnent. This situation existedfor some time and it is apparent that the walAdown crewfor the A-46 programfailed to identify the deficiency. Demonstrate that this is not an indication of a general weakness in the USI A-46 walAdown program.
Response 4 When reviewing the event discussed in LER 97-008 00 (reference 17) and examining its implications on any weakness in the USl A-46 walkdown program, it is important to distinguish between the plant equipment involved in the LER and the equipment in the scope of the USl A-46 seismic verification project. LER 97-008 00 identifies the following safety-related equipment as the being possible targets for impact form the non-seismic ductwork:
* SG channelhead vent piping
* Valve RH-790 and RHR piping
* Letdown piping and valves
* RTD bypass
* Various instruments and sensing lines
* SG blowdown and sample piping
* Various secondary instruments The USl A-46 seismic verification project only involves that set of equipment identified as being required to place the plant in a safe hot-shutdown condition following a safe shutdown earthquake event. For PBNP, this set of equipment was selected to be consistent with the safety-related (SR) scoping of the equipment, meaning that very few, if any, non-SR components are included on the PBNP Safe Shutdown Equipment List (SSEL). The PBNP SSEL is only a sub-set of the larger set of equipment that is scoped SR. Not all SR equipment is on the SSEL, and therefore, not all SR equipment was walked down by a qualified Seismic Review Team (SRT) made up of two Seismic Capability Engineers (SCE).
In addition, the USl A-46 seismic verification project was not required to walkdown piping or instrument sensing lines even if the sensing line was associated with an instrument on the SSEL.
From the list of equipment that was identified in the LER, the only component that is on the PBNP SSEL is IRH-700. The SRT that walked down 1RH-700 did not identify a spatial interaction concern for this valve. The two licensee engineers that conducted the walkdown of the Unit i SG cubicles discussed in LER 97-008-00 are qualified SCEs. Their walkdown was l
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l l
Attachment A to NPL 97-0450 Page 10 of 22 WlSCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCl, EAR Pl ANT. UNITS 1 AND 2 UNRESOINED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 consistent with that of the original SRT. Both groups concluded that the IRH-700 valve would not be affected.
The walkdowns for the USl A 46 seismic verification project were conducted in a controlled and methodical manner. Each piece of equipment on the SSEL was walked down two separate times, both times by a qualified SRT. The first preliminary walkdown was performed to gather field information on the equipment and to fill out a draft screening evaluation worksheet (SEWS) form. The second final walkdown was performed with the final version of the SEWS in hand by a different SRT. Both times, the SRT was checking compliance with the caveats, including the spatial interaction caveats.
Of the 99 equipment outliers identified in Section 9 of the Wisconsin Electric Seismic Evaluation Report, Revision 1 (References 6 &7),35 of them are associated with a spatial interaction hazard. This is indicative that the qualified SRTs where sensitive to identifying interaction hazard concerns.

_ Attachment A to NPL 97-0450 PageiIof22 WlSCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 UNRESOLVED S AFETY ISSUE A-46 SUMM ARY REPORT. DATED M AY 16.1997-
: 5.      Deviations from GlP 2
        - Ouestion 5 in Reference 4 (Reference 5 to this submittal} you stated thatyou are committed to implement the GIP-2 Including claripcations, interpretations, and expectations in SSER-2, and to communicate to the NRC staff any signipcant or programmatic deviationsfrom GIP-2 guidance. l'oufurther stated that the submittal conprms that no significant or programmatic deviationsform the GIP-2 guidance were made.
Provide the worst-case items (from the safety point of view) that deviatefrom the GIP-2 guidelines but were categorized as not being signuficant, in addition, we request thatyou provide a depnition of"Signipcant deviations" that the walkdown crew used to classify the deviation as signtpcant or insignipcant andprovide ajustopcationfor why such a depnition is adequate.
Resnonse 5 Section 5 of the Wisconsin Electric Seismic Evaluation Report, Revision 1 (References 6 & 7) provides the a listing of equipment for which the Seismic Review Team (SRT) deviated from the GlP 2 caveats, in these cases, the SRT used engineeringjudgment based on their Seismic Capability Engineer (SCE) training and their seismic design experience to meet the intent of the screening evaluation worksheet (SEWS) caveats rather than the exact wording of the caveat.
Meeting the intent of the equipment caveats is permitted under the walkdown guidance provided in Section 11.4.1 of the GIP-2. If the SRT could notjustified meeting the mtent of a particular caveat, the equipment was declared an outlier.
The SRTs did not have pre-determined definitions of"significant" deviations versus
          '" insignificant" deviations. Following the thought process as stated above,"significant" deviations would be declared outliers, and " insignificant" deviations were ones where the meeting the intent of the caveats wasjustified.

             - _            _ _ __~ _ _ _ _ _ _ _ _.-._ _ _._ _ __ _._....- _ . _ -
i h                A'ttachment A to NPL 97 0450L
                 ~ Page 12 of 22                                                                                                       *
                                                                                    -WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORM ATION POINT HEACil NUCLEAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997
: 6.           Relavs Mounted on Vibratine Eauipment t
t Question Your response dated September 30,1996, to our RAI (item 11) on " Relays Mounted on
: Vibrating Equipment" states thatyou agree with the SQUGposition on this issue in the SQUG letter to the NRC, dated A ugust 19,1996. flowever, as indicated in the NRC letter to the SQUG, dated December 5,1996, the SQUG's generic response to the NRC question is not L                             acceptable. First , the specyle issue in question is not regarding relays mounted gn diesel generators and air compressors. The issue is the inappropriateness of using the " rule-of-the-box" concept and the)udgment based on the normal operation of the dieselgenerators of air compressors tajust[fy the seismic adequacy ofdevices, such as relays , mounted in the -
Instrumentation and control cabinets anchored on the common skid ofthe dieselgenerator or
(                             air compressor.
i-                             The concept of the " rule-of-the-box" applies to components in a system that has already been successfully subjected to a vibratory environment comparable with or greater than the y                          . required motion (e.g., SSE). Thenfore, the " rule-of-the-box" concept can also be applicable
                          ' for accepta:tce of the relays mounted on vibratory equipment (or in a cabinet supported on the
'                             common skid) provided it is demonstrated that the vibratory motion of the equipment for the              .
skhl) is at least equal to the required seismic motion at that location, and that the relays performed all their intendedfunctions during the periods of vibration.
                            . With regard to relays mounted on dieselgenerators and air compressors, thefollowing specific questions should be addressed:
l
: a.              Does the mechanical vibration envelop the required input motion (e.g., SSE)from all -
p                                             aspects (e.g., amplitude, frequency, direction, etc.)?.
F
                                            . Do these vibratory equipment-mounted reksys perform all their operational safety b.
                                           -functions (e.g., change ofstate) while the supporting equipment is vibrating (i.e.,
during startup an normal operation) so that the relays can be considered quahfied to that level? =
: c.              For any of these vibratory equipment items, could an SSE occur when the equipment is vibrating? Ifso, then the earthquake load will be an increment to the normal operational vibratory load, and the relay may need to be reviewedfor the increased motion.
                            ' The vibratory motion of the skid is expected to be less severe than the vibratory equipment itselfprovided the skid is rigidly mounted on a heasyfoundation. Therefore, all of the above
                            ; questions will also applyfor relays contained in skid-mounted cabinets with a particular 4
   . - _ - -            n             ,_ _. - - , .                           __ ,_       ,.   . _ _ ,  ,,- . _ _ _ _ _ , -  _ _ _  _.

Attachment A to NPL 97 0450 Page 13 of 22 WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACll NUCLEAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFFTY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 emphasis on the vibration level verification, with the understanding that it is the vibration of the skid and tyy of the vibrating equipment, that will be compared with the required input motion (i.e., item a. above). In addition, the cabinet that houses the relays may also change the vibration level and characteristics at the relay locations.
Regarding " bad actor" relays, they are so described mainly because of their low seismic capacities, or inexplicable performance characteristics. Therefore, " bad actor" relays mounted on vibratory equipment may be expected to have demonstrated their performance under certain conditions. But, in general, these relays also should be verifiedfollowing the approachfor other vibratory equipment-nmunted relays discussed above.
In conclusion, the staff's original RAI has been clarified and divided into three questions e described above. Any USI A-16 plant licensees who have inappropriately used the " rule-c{-
the-box" concept or exercised thejudgment, based on normal operation of the vibratory equipment, tojustih the seismic adequacy ofcomponent/ device mounted on a vibratory equipment or mounted in a cabinet that is anchored to the common skid of the vibratory equipment, should demonstrate the seismic adequacy of the component / device by calculation and/or test data.
The above revised RAls have been sent to the SQUG. In response to these RAls, the SQUG did not provide specsfic responses to the above RAls in its letter to NRC dated April 18, I997.
Therefore, the staffdoes not accept the SQUG response as a resolution to this issue l'on are requested te provide specsfic resolutions to the above RAls.

===Response===
Wisconsin Electric intends to re evaluate the seismic adequacy of those contact devices that were originally considered to be seismic adequate based on being mounted on vibrating equipment.
WE agrees with the staff s concern that the vibratory excitation caused by the operation of the vibrating equipment may be outside the frequency range of concern for the seismic event.
The types of equipment initially screened as seismically adequate based on the rule-of-the-box application consist of relays, circuit breakers, contactors, mechanically actuated switches and manually actuated switches. The initially screening of these components was broad in scope simply because the only criteria we tried to meet was being mounted on the vibrating equipment and not being " bad-actor" relay.
As a result, the re-evaluation will need to more clearly define what each contact device in the equipment control is (e.g. whether it is a relay, circuit breaker, switch, etc...) and then determine if functional screening for chatter acceptability is appropriate or if the seismic capacity versus seismic demand screening is appropriate.

- Attechment A to NPL 97-0450 -
Page 14 of 22 W1SCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCl. EAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 WE intends to provide an update to the Relay Evaluation Report (References 18 & 19) once this evaluation is completed.

         - Attachment A to NPL 97 0450-
         ~ Page 15 of 22 WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCI EAR PLANT. UNITS 1 AND 2
                    . UNRESOLVED SAFETY ISSUE A 46 SUMM ARY REPORT. DATED MAY 16.1997
;          7.         Human Factors Aspects of A-46 Ouestion 7a.
In response to question 23 on page A32 of 42 of the licensee's submittal (Reference 3), the                  :
licensee did not specylcally address how the multi-disciplinary team evaluated that sufficient time was available to ensure operators could accomplish the required actions associated with a safe shutdown. Please describe how the team determined that sufficient time was available t accompIlsh these activities?
T Resnonse 7a.                                                                                                 -
As part of the Safe Shutdown Equipment List (SSEL) equipment selection process, those '
accidents and transients previously analyzed for in the PBNP Final Safety Analysis Report (FSAR), were reviewed. Those that were considered credible as a result of the PBNP safe shutdown earthquake (SSE) event were identified (References 6 & 7, Section 2). The equipment required to mitigate the consequences of these accidents and transients are included on the SSEL.
The response procedures are grouped in categories of Emergency Operating Procedures (EOPs),
Critical Safety Procedures (CSPs), Emergency Contingency Actions (ECAs) and Abnormal
..                    Operating Procedures (AOPs). The procedures are written to direct the actions required to support the PBNP design basis accident and transient analysis identified during the FSAR review, The actions taken are based on plant symptoms and indications and are not associated with what initiated the accident or transient. The SSEL equipment selection process also 4                     reviewed the applicable procedures to ensure that the equipment selection is consistent with the set of equipment used by the operations personnel in the response to the postulated accidents and transients. However, the equipment is not specifically identified for the operators ss being on the SSEL. The operators can rely on this equipment, without specifically knowing the equipment is on the SSEL, because the equipment has been verified to be seismically adequate.
The procedures are reviewed during a valid e on process and any changes are reviewed against the PBNP licensing basis and design basis under 10CFR 50.59. The operating crews continually conduct both classroom and simulator training on the procedures. The auxiliary operator training includes practical factors and job performance measures for training on local equipment operation. The multi-disciplinary team evaluated that sufficient time was available for the operators to accomplish the required actions based the training that demonstrates that operators successfully complete existing procedures. They also based their evaluation on the existence of the procedure validation process which ensures that the procedures are adequate to respond to the
]
PBNP design basis accident and tmnsient events.
   -.--l,     -
                ,-ne,          , vN ,- e       e               --
on,                        - ~        -, , .,--N, , , -

Attachment A to NPL 97 0450 LPage 16 of 22 WISCONSIN ELECTRIC-                                              ;
                                     - RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 4                       . UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997                                    .
Question 7b.
<                        Regarding question 24, the staff agrees that the USI A-46 scenario is not espected to cause harsh environment conditions. As discussed in a letterfrom the staff to the SQUG dated December 3,1996,following ajoint meeting of representatives of the NRC and SQUG on                 ,
A ugust 28,1996, the staffprovided the SQUG with additional clarification of the types of concerns that should be considered including (1) the potentialfor diminished lighting due to a loss-of offsite pow #r, (2) other barriers such as damaged equipment or structures which could inhibit operators ability to access plant equipment (e.g., Ingress / egress paths to SSEL equipment), and (3) the potentialfor requiring operators to enter hazardous (e.g., high temperature humidity, steam, flooding, or eleJrical hazards) or unfamiliar areas to manually       ,
reset or realign equipment.
Flow were these potentially hazardous environmental conditions and edditional concerns factoredinto the analysis?
Resnonse 7b
   .                     As stated in Response 7a above, the Point Beach Nuclear Plant (PBB'P) Safe Shutdown Equipment List (SSEL) equipment selection process also reviewed the applicable procedures to
-                        ensure that the equipment selection is consistent with the set of equipment used by the operat:ons personnel in the response to the postulated accidents and transients.
The mqjority of the equipment in that equipment set is operated from the control room. In addition, the required system parameter indications are available in the control room so operators can verify proper system and equipment operation from the control room.
                       ' As part of this response, the Operating Procedure Review in Section 2.4 of the Seismic Evaluation Report (references 6 & 7) and the response to Question 24 to Wisconsin Electric's initial RAI response (reference 3) were re evaluated. The initial procedures review for the USl A 46 Seismic Verification Project postulated that the operators would be directed to the Emergency Contingency Actions (ECAs)- 0.0, ECA 0.1 and ECA-0.2 as a result of a loss of all AC power. liowever, AC safeguards power is considered available because the emergency diesel generators are on the SSEL. Therefore, it is more accurate to postulate that the operators would not transition to the ECAs and remain in the EOPs. As a result, Wisconsin Electric will
                      ; be preparing a revision to Section 2 of the Seismic Evaluation Report (References 6 & 7) for
: accuracy and clarification.
Operator Access to Eauinment
                      . The equipment which may require local operator action is located within the envelop of the safety related (SR) structures at PBNP with one exception, the air-operated atmospheric steam dump valves. The equipment that is located within the SR structures is considered to be
;                     : accessible, the accessibility of the atmospheric steam dump valves is discussed below.

  - Attachment A to NPl. 97 0450 Page 17 of 22 WISCONSIN El ECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORM ATION POINT BEACH NUCl. EAR PLANT. UNITS 1 AND 2 UNRESOINED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 4
The air-operated atmospheric steam dump valves are located at the 85' elevation in the Unit I and Unit 2 facade structures on a seismic platform attached to the exterior of containment. The atmospheric steam dump valves are used to control SG pressure and therefore reactor coolant system pressure and temperature. In order to operate these valves from the control room, an instrument air supply to the valves is required. The present instrument air system is non seismic and can not be relied upon to function during and following the SSE event. As a result,if these valves are required to be operated, the PAD auxiliary operator must locally open these valves manually. The Unit I and Unit 2 facade structures are directly adjacent to the Primary Auxiliary Building (PAB). An analysis of the facade structures and the PAB super-structure has been done. Theiefore, the PAD auxiliary operator's access to the atmospheric steam dump valves is maintained.
Emergency 1.ighting A technical evaluation of the emergency lighting capability at PBNP has been done as part of the Fire Protection Program (reference 20). This evaluation is applicab'e to the USI A-46 Seismic Verification Project. The set of equipment required for the 10 CFR 50 Appendix R, worst case fire safe shutdown scenario and the set of equipment required for tb USI A-46 Seismic Verification SSE scenario are similar. The local operator action foi the Appendix R worst case fire scenario considers the need to evacuate the control room and or erate the safe shutdown equipment from the local control stations. For the USI A-46 SSE sc:nario the operators remain in the control room. As a result, the local operator action required fcr the Appendix R scenario is considered to be more extensive than for the SSE scenario.
Emergency lighting is provided in areas of the plant which contain equipment identified as requinng local operator action for the Appendix R scenario. The lighting units are seismically qualified and seismically mounted. Therefore, this emergency lighting is considered adequate for the USl A 46 SSE scenario.
P

  -       -.               ~ . . -            -     - -      - -       - . . - - . _ - . - -.                  - - - -
Attachment A to NPL 97 0450                                                                                           >
Page 18 of 22 WISCONSIN ELECTRIC                                                 a RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACli NUCLEAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
RFPORT. DATED MAY 16.1997
: 8.       Component Cooline Water System issues Undate Ouesdon Please provide an updated status on the component cooling water system issues at Point Beach                 ,
as described in your {{letter dated|date=November 20, 1995|text=November 20,1995, letter}}.
           - Response An updated status on the Component Cooling Water System issues has been provided to the NRC staff under a separate letter (reference 21) submitted to the NRC on July 7,1997,
: 9.       Outstandine Outlier Status Undate l            Ouestion Please provide a status ofoutstanding outliers that remain to be completed and the current schedule dates ofcompletion.
Resnonse The USl A-46 outliers are identified in Section 9 of the Seismic Evaluation Report (References 6 &
7).
~
Eauipment Class I throuch 21 For Equipment Classes I through 21,99 outliers were initiallyidentified. Of those 99 outliers,57 outliers have been resolved either by a modification upgrade or by analysis. Forty two (42) outliers remain to be resolved.
Eauinment Class 22 -
For the Equipment Class 22 Cable and Conduit Raceway review,3 of the 10 Limited Analytical Review (LAR) cable tray supports were identified as outliers. In addition to these, there were two
.            (2) outliers associated with cables hanging out of their respective cable trays in Unit 1 and Unit 2 containment and one (1) outlier associated with a loose base clip angle on a cable tray support in Unit I containment. The outlier resolution for these is in progress.
Outlier Resolution Schedule                                                                                  ,
The initial outlier resolution schedule presented in Section 9 of the Seismic Evaluation Report (references 6 & 7) proposed to have the outliers resolution completed by February of 1998, following the second refueling outage for the PBNP Unit 2. The outlier resolutio.n schedule has been delayed due to an extended Unit 2 Steam Generator Replacement Outage. At this point the follow-on Unit I and Unit 2 outage dates have not been established. The revised proposed completion date for the outlier resolution is after the next available outage for each unit. This is estimated to be in mid 1999.

Attachment A to NPL 97 0450 Page 19 of 22 WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 UNRESOINED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 There are two exceptions this proposed schedule:
: 1) The upgrade of IT-13 and 2T-13 Refueling Water Storage Tanks
: 2) The evaluation and any required upgrade of contact devices associated with the G-01 and G-02 emergexy diesel generator control circuits.
These two projects are in the preliminary evaluation stages to determine the scope of work.      ,
T e
aw~      -,

l t
i Attachment A to NPL 97-0450 Page 20 of 22 WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEAC11 NUCLEAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED M AY 16.1997

==References:==
: 1. Seismic Qualification Utility Group, " Generic Implementation Procedure (GlP), for Seismic Verification of Nuclear Plant Equipment", Revision 2, Corrected,2/14/92.
: 2. Letter from NRC to Wisconsin Ele.nic Power Company," Supplemental Request for Additional Information on Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A 46," dated May 16,1997.
: 3. Letter from Wisconsin Electric Power Company to NRC Document Control Desk,
        " Response to Request for Additional Information Regarding the Report on the Verilication of Seismic Adequacy of Mechanical and Electrical Equipment on Operating Reactors,"
dated September 30,1996.
: 4. WE Response to GL 87-02, Supplement 1 on SQUG Resolution of USl A-46 Point Beach Nuclear Plant, Units 1 and 2, Letter No. VPNPD 92 313, NRC-91-111 Bob Link (WE) to USNRC, dated September 21,1992
: 5. Letter from Wisconsin Electric Power Company to NRC Document Control Desk,
        " Generic Letter 87-02 Summary Report for Resolution of Unresolved Safety issue A-46, Point Beach Nuclear Plant, Units I and 2," dated June 30,1995.
: 6. WE Point Be2h Nuclear Plant Units 1 and 2,"USNRC Generic Letter 87-02, USl A-46 Resciution, Seismic Evaluation Report," Rev. O, Jtme 1995.
: 7. WE Point Beach Nuclear Plant Units I and 2,"USNRC Generic Letter 87-02, USl A-46 Resolution, Seismic Evaluation Report," Rev.1, January 1996.
: 8. Letter from NRC to Wisconsin Electric Power Company," Request for Additional Information Regarding the Report on the Veritication of Seismic Adequacy of Mechanical and Electrical Equipment on Operating Reactors," dated May 23,1996
  ~9. Senior Seismic Review and Advisory Panel (SSRAP) Report, Use oLSeismic Experience al Test Data to Show Ruccedness of Eauipment in Nuclear Power Plants, Revision 4.0, February 28,1991.
: 10. IT-13 Refueling Water Storage Tank (RWST) Screening Evaluation Worksheet (SEWS)
: 11. Stevenson & Associates Report 91C2696-DR-004," Point Beach Refueling Water Storage Tank Seismic Capacity Final Report," June 30,1995.
: 12. Stevenson & Associates Calculation 91C2696-C-003," Point Beach RWST Seismic Capacity," 6/23/95.

Attachment A to NPL 97-0450 Page 21 of 22 WISCONSIN El ECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEACll NUCl EAR Pl. ANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 

==SUMMARY==
REPORT. DATED MAY 16.1997 Refer ences:
: 13. Stevenson & Associates Calculation 91C2696-C-004,"RWST Bolt Chair and Tank Shell Nonlinear Analysis,"6/23/95.
: 14. Robert P. Kennedy letter to Mr. John O'Sullivan (Stevenson & Associates)," Point Beach RWST Seismic Analysis," March 22,1994.
: 15. EPRI NF 6041-SL, Revision 1."A methodology for Assessment of Nuclear Power Plant Seismic Margin," August 1991.
: 16. Stevenson & Associates Calculation 91C2696-C-018,"USl A-46 Limited Analytical Review, Cable Tray and Conduit Supports," 6/29Di
: 17. Licensee Event Report 97 008-00, Wisconsin Electric Power Company "Non-Scismic Duct Work Located Above Safety-Related Equipment in Containment, Point Beach Nuclear Plant, Units I and 2," dated March 3,1997.
: 18. WE Point Beach Nuclear Plant Units I and 2,"USNRC Generic Letter 87-02, US! A-46 Resolution, Relay Evaluation Report," Rev. O, June 1995.
: 19. WE Point Beach Nuclear Plant Units 1 and 2,"USNRC Generic Letter 87-02, USI A 46 Resolution, Relay Evaluation Report," Rev.1, January 1996.
: 20. Wiscorsin Electric, Fire Protection Evaluation Report, July 1996, Technical Evaluation 9.2, " Technical Evaluation of Emergency Lighting Capability at Point Beach Nuclear Plant."
: 21. Wisconsin Electric letter, NPL 97-0401 to the U.S. Nuclear Regulatory Commission,
        " Component Cooling Water System issues Update, Point Beach Nuclear Plant, Units 1 and 2," July 7,1997.

Attachment A to NPL 97 0450 Page 22 of 22 WISCONSIN ELECTRIC RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION POINT BEAC11 NUCLEAR PLANT. UNITS 1 AND 2 UNRESOLVED SAFETY ISSUE A-46 SUMM ARY REPORT. DATED MAY 16. l(197

==Enclosures:==
: 1. a. Plot of the 5% damped horizontal Housner Ground Response Spectra (GRS) plotted in comparison to the GIP Bounding Spectrum and;
: b. Plots of the 5% damped horizontal ISRS for all of the structures at PBNP for those elevations within 40 feet of effective grade plotted in comparison to the GIP Reference Spectrum (1.5 x Bounding Spectrum).
: 2. Wisconsin Electric Point Beach Nuclear Plant Cable Spreading Room Plant Area Summary Sheet, SPREADINGRM (Rev. 0) PASS.
: 3. a. Bechtel Drawing C-181, Concrete - Turbine Building - Class 1 Structure Plans at El.
26'-0" & El. 44'-0".
: b. Bechtel Drawing C-183, Concrete - Turbine Building - Class 1 Structure, Elevations and Details
: c. Bechtel Drawing C-184, Concrete - Turbine Building - Class 1 Structure, Reinforcement - Plans & Sections.

Wisennain Electric Power Comnany
        - Resnonne To Reonest for Additional Informatinn. Point Scach Nuclear Plant. Units 1 and 2.
        - Unresolved Safety Issue A 46 Summary Reoort. dated May 16.-1997 Attachment A - Enclosure 1
          - a. Plot of the 5% damped horizontal llousner Ground Response Spectra (GRS) plotted in comparison to the GIP Bounding Spectrum and; b-  Plots of the 5% damped horizontal ISRS for all of the structures at PBNP for those elevations within 40 feet ofelrective grade plotted in comparison to the GIP Reference Spectrum (1.5 x Bounding Spectrum),
a G-,
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                                  - - * - -Containment St.v:ture 45* Elevation Page 1

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                    *SQUG GIP Reference Spectrum                   + Control Buiidrng 26' Elevation - - * - -Control Building 44' Elevate Page 1

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                                 - - Pipeway #1 - 15' Elevation                            - -A - Pipewrf#1 - 23* Elevation Page 1

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                     - -x- - Ppeways 2 & 3 - 36' Elevaten - - * - -Ppeways 2 & 3 -47 Elevadon                                                                                                                      4 Page 1

PBNP - Pipeway 4 in-Structure Response Spectrum - 5% Damping 2.0000
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                                       '          I     I II 0.1000                                            1.0000                                                        to 0000                                                       100 0000 Frequency (Hz)
                            "'#""SQUG GIP Reference Spectrum                 :    Pipeway 4 - 15' E:evatson                   - -A - Pipeway 4 - 26' Elevation Page 1

                     . ._      .             .-. .___.. _._          .. ~..    . . .    .     . . - _ .            _   _. . , _ _ _
s 4
Wisconsin Electric Power Company Response To Reauett for Additional Information. Point Beach Nuclear Plant. Units 1 and 21 4
Unresolved Safety Issue A-46 Summary Report. dated May 16.1997-1 l
1 4                                                                                                                                       b
                                                                                                                                         }
Attachment A - Enclosure 2
            . Wisconsin Electric Point Beach Nuclear Plant Cable Spreading Room Plant Area Summary Sheet, SPREADINGRM (Rev. 0) PASS s
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Wisc;n:In Electric Power Company P Int Beach Nu:l:ar Pl:nt                             GIP rov 2. Corrected 2/14/92
%                 OUTLIER SEISMIC VERIFICATION SHEET (OSVS)                                        Sheet 1 of 2 ID : SPREADINGRM (Rev. 0)                           l Class   : 22. Cable   Tray and   Conduit Raceways Desenption : ELECTRICAL RACEWAYS CABLE SPREADINO ROOM Building : CB                               l Floor El. : 26.00                        l Room, Row / Col:
: 1. OUTLIER ISSULDEFINITION - Cable and Conduit Raceway _a
: a. Identify all the screening guidelines which are not met. (Check more than one if several guidelines could not be satisfied.)
inclusion Rules                                                                                     i Other Seismic Performance Concerns Limited Analytical Review                                                                                        X Other
          ' b. - Describe all the reasons for the outlier (i.e., if all the listed outlier issues were resolved, then the signatories would consider this item of equipment to be verified for seismic adequacy).
According to S&A's LAR Cable Tray and Conduit Supports Report. 91C2696-C-018, both LARs 3 & 4 do not meet the requirements of section 8.0 of the GIP, therefore they are outliers.
: 2. PROPOSED METHOD OF OUTLIER RESOLUTION lOptional)
: a. Defined proposed method (s) for resolving outlier,
: b. Provide information needed to implement proposed method (s) for resolving outlier (e.g., estimate of fundamental frequency).-
: 3. SEISMIC OPERABILITY EVALUATION:
C
                                                                                                                               ,      --r --n -

re Wisc:nsin Electric P:wer C:mpany . P: Int B:a:h Nuclear Plant                                                    GIP Rsv 2, Correct:d 2/14/92
 **           OUTLIER SEISMIC VERIFICATION SHEET (OSVS)                                                                  Sheet 2 of 2 10 : SPREADINGRM (Rev. 0)                                                  l Class    : 22. Cable  Tray        and Conduit Raceways Description : ELECT RICAL RACEWAYS . CADLE SPREADINO ROOM Bui%ng : CB -                                                       l Floor El. : 26.00                           l Room Row / Col:
AJERTJElCAllQtt The information on this OSVS is, to the best of our knowledge and belief, correct and accurate, and resolution of
    - the outiier issues listed on the previous page will satisfy the requirements for this item of equipment to be venfied for seismic adequacy:
Approved by:                                                                         1 Date:
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_ _ _ _ _ - _ _ _ _ _ - _ _                                  _ _ _ _ .                                       i

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Wisc:n;In Electric Pcwor Ctmpany - Print Bo=h Nullear Plant                                        GIP Rev 2 Corrected,2/14/92 J' s               CABLE AND CONDUlT RACEWAY REVIEW                                                         Sheet 1 of 10 PLANT AREA 

==SUMMARY==
SHEET ID : SPREADINGRM (Rey, 0)                                         Cquipment Description : ELECTRICAL RACEWAYS - CABLE SPREADING ROOM Building : CB                                                     Floor El. ; 26.0000               l Room, Row / Col:
Check List inclusion Rule Review                                                                                                                    Acceptance
: 1. Cable Tray Span                                                                                                                         Yes
: 2. Conduit Span -                                                                                                                          Yes
: 3. Tie Downs                                                                                                                               Yes
: 4. Channel Nuts                                                                                                                            Yes
: 5. Rigid Boots                                                                                                                             N/A
                                                                              ~
: 6. Beam Clamps                                                                                                                             N/A
: 7. Cast Iron Inserts                                                                                                                       N/A Other Seismic Performance Concem Review                                                                                                  Acceptance
: 1. Anchorage                                                                                                                               Yes
: 2. Welded Connections                                                                                                                      Yes
: 3. Concrete Condition                                                                                                                      Yes b      4. Corrosion                                                                                                                               Yes
: 5. Sagging Raceways                                                                                                                        Yes
: 6. Broken or Missing Components and Sharp Edges                                                                                            Yes
: 7. Restraint of Cables                                                                                                                     Yes
: 8. Cable Fill / Ties                                                                                                                       Yes
: 9. Aging of Plastic Ties                                                                                                                   Yes
: 10. System Hardspots                                                                                                                        Yes
: 11. Short Rods                                                                                                                              N/A Seismic Interaction Review                                                                                                               Acceptance
: 1. Proximate Features                                                                                                                      Yes
: 2. Falling Hazards                                                                                                                         Yes
: 3. Differential Displacement                                                                                                               Yes
: 4. Isolated Outliers                                                                                                                       Yes LimitedAnalylicalRevlem LAR No.                 Document Name 003                     Five Tier Unbraced Cantilever Hanger 004                     Seven Tier Braced Cantilever Hanger 005                     Three Tier Trapeze Hanger 010                     Four Tier Cantilever Trapeze Hanger G_QMMENTS The SRTs are T. C. Muehlfeld and W. Djordjevic - 10/22/93.
General: Trays have 4" side rail with 3.75'' fill height. Trays are solid bottom, btA .nostly ladder type with bottom covered with sheet metal. Trays are covered with tray cover for the most part. Tray risers (covered vertical tray) tre found throughout. Hanger spacings vary from 5' to 8', Splice plates appear riveted with 6 rivets (3 per end)in total. Trays are attached to cross-members by channel nut hardware. Hanger assembly is specified to be all Unistrut Corp. hardware.

_        _ - - - - . -                          _ - . - ~ .         . - . . - - - . - - ~ - .       --~
rs.                                                                                                                                   ,
Wisc:n;In Electr6c Power Company .P Int Beach Nuclear Plant                              GIP Rev 2, Corrected,2/14/92
*e                   CABLE AND CONDUlT RACEWAY REVIEW                                              Sheet 2 of 10 PLANT AREA 

==SUMMARY==
SHEET                                                                                 :
T6TSPR8iADINGRM (Rev, 0)                        Equipment Desenpton : ELECTRICAL RACEWAYS CABLE SPREADING ROOM                              r Butiding : CB                                 Floor El. : 26.0000                         l Room, Row / Col:
This room is the most densely populated room in the plant with relatively full trays. Tray configurattion are mostly cantilever strut hangers with some trapeze strut hangers. Cable tray runs of 4,5,6 and 7 tiers are found throughout the room. All members are P1001 (double channel) construction. Anchorages are directly to cmbedded strut, to runners (stringers) bolted to embeddad strut, or to concrete expansion anchors (CEA).
Conduits are supported alongsido trays, on posts, or mounted directly to the ceiling or wall.
LAR 3 is a 5 tier 24" wide tray run supported on an unbraced cantilever strut. The strut is anchored (bolted) to a 30" runner whose ends are bolted to embedded strut. It supports trays designated by 1AJ14,15 and CC05,04 cmoog others and is located above Bus 2004. It is shown in the attached sketch and in the attached photo figures                i i to 4.
LAR 3 is an OUTLIER because it does not meet the requirements of Section 8.0 of the GIP. See S&A's LAR -
Cable Tray and Conduit Supports Report 91C2696 C 018.                                                                           ,
f; ' 4 is a 7 tier braced cantilever strut 24" wide tray hanger. It is similar in general configuration to LAR 3 except thm it is longer, holds more tiers, and has a P1000 brace to provide lateral support. Hanger spacing is 5'. It is shown in the attached sketch and in the attached photo figures 5 to 7.
LAR 4 is an OUTL'ER because it does not meet the requirements of Section 8.0 of the GlP. See S&A's LAR -
Cable Tray and Conduit Supports Report. 91C2696-C-018.                                                                          ,
LAR 5 is adjacen; to LAR 4 and is a 3 tier strut trapeze hanger with 13 trays (9" to 24" widths) per tier level.
Hanger spacing are 3.75' and it is anchored to the concrete ceiling by bolting to Unistrut emberis at two places. It is shown in the attached sketch and in the attached photo figures 8 to 11.
LAR 10 is west of LAR 3 & LAR 4 and is a 4 tier cantilevered trapeze type hanger. There are 4 tray tiers (1 tray per tier) cantilever off and braced to an i tier (with 1 tray) trapeze hanger. The hanger spacing is 6' and it is enchor to the concrete ceiling by botting to Unistrut embeds at two places. It is shown in the attached sketch and in the attached photo figures 12 to 14.
    - Evaluated by:                                                           ,
Date:
n                                                                   ewe

==Attachment:==
Pictures

==Attachment:==
LAR 003 Five Tier Unbraced Cantilever Hanger

==Attachment:==
LAR 004 Seven Tier Braced Cantilever Hanger

==Attachment:==
LAR 005 - Three Tier Trapeze Hanger

==Attachment:==
LAR 010 - Four Tier Centilever Trapeze Hanger deE
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Wisconsin Electric Power Company . Point Beach Nucisar Plant                              GIP Rev 2. Corrected,2/14/92
    ''                                                                                                         Sheet 3 of 10 CABLE AND CONDUlf RACEWAY REVIEW PLANT AREA 

==SUMMARY==
SHEET ID : SPREADINGPM (Rev. 0)                               Equipment Desenption : ELECTRICAL RACEWAYS CABLE                               l SPREADING ROOM Building : CB                                           Floor El. : 26.0000             l Room, Row / Col:
PJC.IDRES i
                                                                                                                       .        'S                       j i
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Fig. 3: LA c. 003                                                    Fig. 4: LAR 003 i
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 ...                                                                                                                               N Wisconsin Electric Power Company . Point Deach Nuclear Plant            GIP Rev 2, Corrected,2/14/02
'.-              CABLE AND CONDUlT RACEWAY REVIEW                               Sheet 4 of 10 PLANT AREA 

==SUMMARY==
SHEET 10 : SPREADINGRM (Rev. 0)              Eauipment Desenption : ELECTRICAL RACEWAYS CABLE SPREADING ROOM Building : CB                          Floor El. : 26.0000          l Room, Row / Col:
x                                     .        z.         ..
                                                                                                     ~
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Im Fig. 5: LAR 004                                             Fig. 6: LAR 004 Fig. 7: LAR 004                                             Fig. 8: LAR 005 I

Wisconsin Electric Power Company . Point Beach Nuclear Plant                                  GIP Rev 2, Corrected,2/14/92 l  's
* CADLE AND CONDUlT RACEWAY REVIEW                                                   Sheet 5 of 10 PLANT AREA 

==SUMMARY==
SHEET 10 : SPREADINGRM (Rev. 0)                                  Equipment Destnption : ELECTRICAL RACEWAYS - CABLE SPREADING ROOM l       Duilding : CB                                              Floor El : 26.0000               l Room, Row / Col:
l
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Fig.10: LAR 005 Fig. 9: LAR 005 l
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Fig 11: LAR 005                                                           Fig.12: LAR 010 l
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Wisconsin Electric Power Company . Point Beach Nuclear Plant                    GIP Rev 2. Corrected 2/14/92
  ***                                                                                        Sheet 6 of 10 CADLE AND CONDUlT RACEWAY REVIEW
;                           PLANT AREA SUMlDRY SHEET l          10 : SPREADINGRM (Rev. 0)                       #Tguipment Desenption : ELECTRICAL RACEWAYS CABLE j                                                           ;                      SPREADING ROOM                                          ;
;                                                                                          l Room, Row / Col:
Building : CU                                 l Floor El. ; 26 0000 N,                            .
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I Fig 13: LAR 010                                                  Fig.14: LAR 010 1
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Wloconsin Electric Power Company P int 8::ch Nuclear Pl:nt                                                                GIP Rev 2, Corrected,2/14/92
  ''s'               CABLE AND CONDUli RACEWAY REVIEW                                                                                Sheet 7 of 10 PLANT AREA 

==SUMMARY==
SHEET ID : SPREADINGRM (Rev. 0)                                      Equipment Desenption : ELECTRICAL RACEWAYS CABLE SPREADING ROOM Butiding : CB                                                  Floor El. : 26.0000                                        l Room. Row / Col:
LAfL003 Five Tier UnbfAGeLCantilever Hanget tM 003 -
* PASSID- $PRf)D NORW d
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* B'.4LDiNC. CB d
o'           9'                         21'       _                            ELfVAllON: 26'
                      *         .             ,                     O                  l                      0 n                                 I i           .
2
                                                                                          ..                    1J 1l7           \        I                   -7 24*: 5' Deep Cable troy
.                                         (Typ>co.. oil tiers)                                       P1000 24*
2(                                                                 Hanger ;003?ed cbove 2004 Dus.
Covere: :r:ys are 4*-s' deep.
R03.02                {-                                                Edi reig-: is 3.75*.
4 L                                    Han;er 5:scing is 5' - 8'.
                                                                                         ~
{.                                                Ceaera! Cos!gurction is Contaever 17                                                                r                                    P1001 :s:ed onto runners (stringe's).
(typ )                                                                                                 sponte; :etween embedded strut.
CD5.04                ['             2.92.9 2.                          Tr ys := d to hordental member
                             "                                                                                    6'          by sprt; cuts.
k'                                                 Post sa: orts vert; col riser troys
                                                                                               -                              (R$$ca: R$7) on e:ther s;de. Troys CD05.04 c                                                 C''   24'8Id"P. *;th a 6' tr;butary i     .
17                           length,  Add full tr'butory
                                                                                                                                                   .       weignt for both ver. col troys to this post.
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Support opprox. 8 - 7 Coeduits -
eit9 2' tributary length (ie 16' of 7 conduit for locd) ili
                                  . _ . _ .                      _-                 _.           . _ _ _ .       .     ~ _ _ .._ ..                    .__ _._ _ . ~

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Wisc:nsin Electric Power Company . P: Int Beach Nucle:r Plant                                                      GlP R V 2, Corr:cted,2/14/92
 *e'               CACLE AND CONDUlT RACEWAY REVIEW                                                                         Sheet 8 of 10 PLANT AREA 

==SUMMARY==
SHEET 10 : SPREADINGRM (Rev. 0)                             Equipment Desenption : ELECTRICAL RACEWAYS . CABLE SPREADING ROOM Building : CB -                                       Floor El. : 26.0000                                          l Room, Row / Col :
LAR 004 Seyenller Braced _CanilleYetHanget
                                                                                                                                   'A 004 e
4                4
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* 37                                                  PA% 1D. $PP(AD C RW
                                     *'s              e kI                        2 '.        _l                               %)GNC. CB
                             ,                       a                                   -
n                                ELUAT.ON: 26' s       .               O                                      U L                        11                                        !           ' _    i 1/7               I                    ikT 2r Y oet, tee troi (fyp40t, 08 tars)                                 Pl000 24' 26'        -
4 - 1.25*
XLOS h              Cono.it
                                 ~_:                                   anrq 4.
i 17                                           j                                             LM l4 coas'sts of 7 tr$ a:th 24' (typ )                                  ,
e,de tecys sad is c:cted beteten DtC5            t
                                                                    '                        2                       ''se's R11 & Ril-I
                                 "     I                                               1                             f at cre:s ge*e'ot conf 4g,,ro. ion
{                                                   es comieve' P1001 Runcers (str.rgen) soon 6 teeen 0x06          h                                                    ord tie 0; rec 'y to embedt ed st'wts Troys ottcued to Montot ,1 reember l                                                                             by sprmg sts it has c '1000 icte'o1
                                                                                   . .                               Br:Ce to p*ov>de laterol uppyt.
i 0.06            {     aCC n i                                      All memoers are P1001, euect as ro:t1 I                                                        i j                                            HQ9;er $;;C PQ i s $'.
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                                                                             .+Y g                        1.25' 12Y T              luc 2              i k"                    !              (fee'gency fl000 LQPts l                     ~l                       (s!. mate - ICl
                                                                                   /
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* l Wisconsin Electric Power Company . Point Beach Nuclear Plant                             GIP NOV 2. Correct:d,2/14/92             i 3 e'              CABLE AND CONDUlT RACEWAY REVIEW                                              Sheet 9 of 10 PLANT AREA 

==SUMMARY==
SHEET                                                                                         !
iD : SPREADINGRM (Rev, 0)                      Equipment Desenption : ELECTRICAL RACEWAYS CABLE SPREADING ROOM Building : CB                                  Floor El. : 26.0000                       l Room. Row / Col:
LAli.00L:lhteelletltapeteEansat totes ano<, ix-u trwrmer.                                                                                     TAR 005 M membo's o', P1001, enept es notes-                                                                          PAS $ 0: $PM04 N C fetary toeps = 3 7$'                                                                                        BADWC:
fLEVA!CN; C,B6' P3370 teres Montsetsi Erroesces $trut:                     4                   ,
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.ar Wisc:nsin Electric Power Company . P: int Beach Nuclear Plant                               GIP ROV 2, Correct:d,2/14/92 S*                        CACLE AND CONDUlT RACEWAY REVIEW                                               Sheet 10 of 10 PLANT AREA 

==SUMMARY==
SHEET ID: SPREADINGRMt Rev. 0)                                 Equipment Desenption : ELECTRICAL RACEWAYS . CABLE SPREADING ROOM Building : CB                                            Floor El. : 26.0000                l Room Row / Col:
LMullA four_Iler Cantilever Trapage Han9tt LAR 010 PA$$ ID. SPPEADNORM
                                                       .                                                                                            BUILD;N0; CB 4,                                                                                                                ELEVAtt0N: 26'
: ':      ,o      ,
[p33go Embed - O
                                            .d"                                                                                                                  .f f                                                                                    7     I 30"                                          g                   YM02.03 - 24' trcy j                                               i
(                                                                      ,e y IET11.10 - 24' trey h.
J ._                                                                                                                      _ S' _
6'                                             k'                             4' 020E02.03 - 24' troy h.
                        ,e i'      j Dv03.04 - 24' trey      f g
: 4.                                                         Hosger is the next west jy                                                                                               suppod to LARs 3 & 4 20A08,09 - 24' tray h.                             PIDOO All members cre P1001 ex:ect cs note 3.
6                                                                                                Henger Spo:ing is 6'.
P1001 Brackets ili

Wiscort=8n Electric Power Company Resoonse To Recuest for Addit}onal Information. Point Beach Nuclear Phnt. Units 1 and '
L!ntesolved Safely.hsne A 46 Summary Report. dated May 16.1997                                                ,
J 1
Attachment A - Enclosure 3
.              a. Bechtel Drawing C 181, Concrete - Turbine Building - Class 1 Structure Plans at El. 26*-0"
                     & El. 44' 0".
: b. Bechtel Drawing C 183, Concrete Turbine Building - Class 1 Stnicture, Elevations and Details
: c. Dechtel Drawing C 184, Concrete - Turbine Building Class 1 Structure, Reinforcement -
Plans & Sections.
a f
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