ML20135A660

Forwards Request for Addl Info Re Resolution of Unresolved Safety Issue A-46

ML20135A660
Person / Time
Site:	Three Mile Island
Issue date:	02/24/1997
From:	Buckley B NRC (Affiliation Not Assigned)
To:	James Knubel GENERAL PUBLIC UTILITIES CORP.
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, TAC-M69486, NUDOCS 9702270324
Download: ML20135A660 (10)

Text

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February 24, 1997 s

Mr. James Knubel, Vice President and Director - TMI-l GPU Nuclear Corporation P.O. Box 480 Middletown, PA 17057

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED SAFETY ISSUE (USI) A-46 (GENERIC LEETER 87-02) AT THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 1 (TAC NO. M69486)

Dear Mr. Knubel:

By letter dated May 17, 1995, GPU Nuclear Corporation (G W1), submitted a plant-specific summary report documenting the results of the seismic walkdown evaluation performed to address USI A-46 at TMI-1. We have reviewed the summary report and determined that <Mitional information is necessary in order to continue our review of your A ittals. Enclosed is the request for additional information.

Sincerely, (Original Signed By) l Bart C. Buckley, Senior Project Manager '

Project Directorate I-3 Division of Reactor Projects - I/II ,

Office of Nuclear Reactor Regulation 1 Docket No. 50-289

Enclosure:

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g,,, # February 24, 1997 Mr. James Knubel, Vice President and Director - TMi-1 GPU Nuclear Corporation P.O. Box 480 Middletown, PA 17057 ,

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED ,

SAFETY ISSUE (USI) A-46 (GENERIC LEETER 87-02) AT THREE MILE ISLAND  ;

NUCLEAR STATION, UNIT NO. 1 (TAC NO. M69486)

Dear Mr. Knubel:

By letter dated May 17, 1995, GPU Nuclear Corporation (GPUN), submitted a plant-specific summary report documenting the results of the seismic walkdown evaluation performed to address USI A-46 at TMI-1. We have reviewed the summary report and determined that additional information is necessary in order to continue our review of your A-46 submittals. Enclosed is the request for additional information.

Sincerely, a uc 3 Bart C. Buckley, Senior Project Manager Project Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/ enclosure: See next page 1

7 Three Mile Island Nuclear Station, Unit No. I cc:

Michael Ross Robert B. Borsum Director, O&M, TMI B&W Nuclear Technologies GPU Nuclear Corporation Suite 525 P.O. Box 480 1700 Rockville Pike Middletown, PA 17057 Rockville, MD 20852 John C. Fornicola William Dornsife, Acting Director Director, Planning and Bureau of Radiation Protection Regulatory Affairs Pennsylvania Department of GPU Nuclear Corporation Environmental Resources 100 Interpace Parkway P.O. Box 2063 Parsippany, NJ 07054 Harrisburg, PA 17120 Jack S. Wetmore Dr. Judith Johnsrud Manager, TMI Regulatory Affairs National Energy Committee GPU Nuclear Corporation Sierra Club P.O. Box 480 433 Orlando Avenue Middletown, PA 17057 State College, PA 16803 Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

Washington, DC 20037 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Michele G. Evans Senior Resident Inspector (TMI-1)

U.S. Nuclear Regulatory Commission P.O. Box 311 Middletown, PA 17057 Regional' Administrator, Region I U.S. Nuclear Regulatory Comission 475 Allendale Road King of Prussia, PA 19406

l REQUEST FOR ADDITIONAL INFORMATION l Resolution of USI A-46 (Generic Letter 87-02) l Three Mile Island Unit 1  ;

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REFERENCE:

Letter from T. Broughton (GPUN) to NRC, dated May 17, 1995, "Three 1 Mile USI A-46 Seismic Evaluation Report, (EQE Report No. 42105-R- I 002, dated May 11,1995)."

! 1. On Page 10, the report

• ment' ions that the SSEL [ Safe Shutdown Equipment i List) contains 679 components of which 658 components were evaluated i

during the walk down to verify their seismic adequacy. Provide

!- information to show how the remaining 21 components were ver,1fied for seismic adequacy.

! 2. On Page 13 of the report, it is stated that as a deviation from the GIP, the TMI Seismic Capability Engineers (SCEs) did not sign the Screening Verification Data Sheets (SVDS) but signed a cover sheet with a statement that "they agree with the data in the SVDS package that they prepared." But, the SVDS included in Appendix H does not have a signature on any page. Submit the missing signed cover sheet (s) that would show the SCEs agreement on SVDS.

3. Item 9 on Page 21 of the report did not include in the SSEL those equipment items which (if failed during and after an SSE), were postulated to fail in the desired position. However, a malfunction of the control devices of such equipment can fail the equipment in an undesirable state. Therefore, show with examples that the control devices of such equipment were included in the SSEL.

4. In reference to Item 4, Section 2.1.1.2, Page 22 of the report, the structural integrity of equipment was not considered as a failure mode (e.g., rupture of a valve). Since this assumption was TMl plant-specific, provide a list of all cases where the structural integrity was-not considered as a failure mode, and explain how the equipment functionality was verified for those cases so that the impact of this assumption can be avaluated.

5. Item 5 on Page 23 indicates that " inherently rugged" equipment types include " pressure and temperature gauges, flow elements and other items defined in the GIP." However, the GIP (Section 3.3.5) does not include the temperature gauges and flow elements, nor does it list any items other than the valves already included in the TMI report. List all equipment types that were considered " inherently rugged," and for those items which were not listed in the GIP, provide information to show the seismic adequacy of equipment including their mountings.

• Unless otherwise noted, "the report" means the " Reference" described above.

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6. Regarding operator action, very high reliance has ben placed on operators' ability for recovery of many seismically vulnerable items

within a short Meriod of time. Examples are spread throughout the

report, of whici the following are a few:

• Page 25, Section 2.2.1, Second Paragraph

" Breakers to the control rods can be tripmi from the control room

, or locally [ underline .added) at the switc gear."

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• Page 39, Last Sentence l "The control room operators can manually align NSCCW cooling..."

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• Page 41 l " Doors will be opened and diesel radiator fans will be used ...

i within 25 minutes of loss of ventilation."

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• Page 67, Fourth Bullet j " Resetting seal-in relays."

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{ Any one or a few of these operations may easily be performed; but, it is 4

questionable whether all of the cited operator actions can be performed reliably within the short available period of time given the potential for absence of electrical light and egress that could have been created after an SSE-type earthquake as a result of falling or failure of non-seismic components on seismic components. Provide infomation to show that the assumed recovery of All malfunctions / damages within the needed period can be accomplished in the plant condition after an SSE-type earthquake (see also Item Nos. 9 and 10).

7. Regarding the normal make-up flow path, the report on Page 26 states that "since make-up pump W-P-1B is selected for normal plant operation, the make-up pump W-P-1B and valve M-V-16B are selected as the primary path for long-term reactivity control function." Then it states, "the normal plant make-up path is through the normally closed make-up valve W-V-217 ..." and further continues, "the normal make-up flow path is designated as the optional path ..." Clearly state which one of the two is the normal make-up flow path (i.e., through E-V-168 or M -V-217) and whether the normal make-up flow path is primary or optional. Verify and confire with explanation that this clarification will not alter equipment selection on the SSEL.

8. Regarding the 4160-volt system, the report on Page 35 states that only buses ID and IE are Class IE implying that the other buses were probably not verified for seismic adequacy. If so, provide information to show how potential electrical and structural interaction among these adjacent class IE and non-class IE buses during a seismic event were considered (e.g., falling or failure of non-seismic components on seismic components causing structural damage, electrical short, etc.).

9. In Section 2.2.5.7 on Page 40 and Section 2.2.5.11 on Page 42 of the report, it was assumed that portable components would be available for use following an SSE. Provide infomation to demonstrate that the 2

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l portable components (1) will not be damaged during the SSE in their j respective locations and (11) would be available within the required .

i duration (e.g., four hours in one case) in the aftermath of a major j earthquake (see also Item No. 6).

! 10. In Section 2.4 on Page 52, the report states that the operator "will

eventually be directed to the use of equipment and instruments on the l SSEL even though the operator may have first tried to shut down using

equipment not 'neluded in the SSEL." This may delay the operator action

further if ultimately the A-46 shutdown path is to be followed. Provide

! infomation to demonstrate that this delay in operator action will not

! compromise safety and was considered toward on time recovery from potential malfunctions, especially, in light of RAI Item No 6.

! 11. For cabinets and panels containing relays, the report in Section 3.5.1 i on Page 65 states that "a relay evaluation of these cabinets and panels j is not required." It is not clear what is meant by "a relay evaluation" 1 of a cabinet. Have the safety-significant relays been evaluated? Have

!_ the cabinets containing these relays been evaluated? If both of these

! answers are affirmative, clarify what "is not required" then. If any of l the answers are negative, provide information to show how the seismic i adequacy of relays including the housing cabinets was verified.

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! 12. The report on Page 74, second paragraph states that " anchor bolt tightness checks were performed in accordance with the GIP where

! tightness checks were determined to be required." This implies that the  !

! GIP criteria were used to perform the bolt tightness check and prior to ,

! that another set of criteria was used to detemine whether such a check i l is required. Specify the criteria that were used to detemine whether i an anchor bolt tightness check is required and who made the  ;

I determination. '

l 13. Regarding analysis of outliers for 43 mechanical and electrical  ;

! components on Page 74, fourth paragraph, the report mentions that as of l l thereportissuedate,10 calculations [weregstillinprogress.

f Confim that all calculations have been coup eted and the outliers (43) are all resolved and found acceptable.

14. Regarding the Third Party Review, the report on Page 82, Section 4.6 states that "the balance of Dr. Stevenson's comments were ...

satisfactorily resolved by further analysis." Did Dr. Stevenson concur with the resolution of his comments? Provide a more-descriptive response to Dr. Stevenson's observations in Appendix L so that an independent evaluation can be made.

15. Regarding the small, wall-mounted boxes identified on Page 82 (Item 5) clarify whether these are needed for safe shutdown. If so, justify why they were not included in the safe shutdown list.

16. For the SSEi. items that were judged to be strong enough to not require a seismic verification (e.g., manual valves), confirm that there was a site inspection perfomed (on all of them) to verify their availability.

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This question is asked in light of the missing hand wheel for a valve 4 (e.g., Page 84 of the report, Item 3). l i  !

i 17. The integer designation of functional class provided on Page 88 in j Appendix 8 of the report, does not seem to be consistent with the

decimal designation on the tables (Column 17) in Appendices C and D.  !

! Provide clarification or missing infomation.

! 18. In Appendix F, Page 9 the report mentions that for relay EHC-LV (Contact

! VCS 840), the manufacturer /model number was not available. Prov4de the

! missing information or show how the relay was evaluated without the i model number.

! 19. The following questions pertain to Appendix J on meeting the intent of

caveats:

i j a) It is not clear from the description provided in the report as to i what the deviations were in definitive terms (e.g., size, i distance, configurations, loading, stresses, etc.) that did not

meet the words of the caveats, and what justifications were used

[ in definitive or quantitative terms that met the intent of the

! caveats. In order to establish an understanding of the

! pervasiveness (roughly about three hundred caveats for which j wordings were not met) and the severity of this issue, it is l requested that adequate data be provided for the following sample

! equipment items identified in Appendix J to the report (called

"Line Number" in the report) that will enable a complete l understanding of the deviations and justification for their

acceptance

Line Numbers: 1114, 1192, 1281, 1525, 1680, 1756,

1838, 1970, 2013, 2089, 2121, 2129, 2332, 2452, 2496.

i b) The GIP caveats require verification of anchor bolt tightness j check in applicable and selected cases, not withstanding the i presence or absence of a QA p"ogram at the site. Explain why the F caveats on anchor bolt tightness were judged to have met the GIP

! for TM1 just because there is a QA program at TMI (Page J15, i Justification Code 11) even though no site verification of anchor bolt tightness was made for certain items.

j l c) From the infomation provided in the report, it appears that in

! some cases the TMI equipment conditions do not meet the caveats l although additional data, such as analysis and testing data,

! modifications of equipment, or other means can very well

! demonstrate adequacy of the particular equipment item. However, l according to GIP-2, in such a case, an item should be considered l an " outlier" for not satisfying the caveats; Provide justification as to why equipment items requiring additional

analysis or data, or modifications were not listed as outliers.

l For example, potential candidates are the description codes 6,19 i and 22, and justification codes 3, 18 and 26 for equipment items j in Appendix J.

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!5 d) Explain how the description code 21 (i.e., " Pump has radial

) bearing") applies to I&C devices (e.g., Line Numbers 2255 and j 2256).

20. The following questions pertain to the outliers discussed in Appendix K:

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l~ a) The brief discussion of the description and resolution of outliers l

included in Appendix K does not provide adequate information in  !

! characterizing the deficiencies and for evaluating acceptability '

l of the proposed / implemented modifications. This observation is

applicable to over 400 caveats listed in Appendix K. As described  !

! in the GIP, it is expected that the deficiencies and modifications 1

) have been thorwugMy documented to allow an independent review.  ;

To illustrate theroughness of such documentation, submit complete  !

information that led to the resolution of the outliers for the following equipment items (called "Line Numbers"). Any l deficiencies including field ~information (e.g., configuration, size, design, etc.) and analysis / testing data should also be ,

included. Line Numbers: 1001, 1010, 1032, 1043, 1045, 1051, 1060, j 1098, 1114, 1324, and 1383, and Raceways CB-338-1, CB-338-6 and TB '

355-1.

b) For Line Number 1007, the outlier resolution code (No. 3) refers to the relay report. However, the relay list included in Appendix D does not include Line Number 1007 (Page 1). Provide the missing ,

information or explain how the essential relays in Line Number 1 1007 were evaluated. 4 c) For Line Numbers 2371 through 2385, no resolution approach was ,

identified. Explain how these outlier items were or will be I resolved.

d) For several outlier relays, the outlier code (R3) specified: "To  ;

be resolved or replaced during 12R." For relays that are not '

being replaced, the resolution code does not provide useful i information (i.e., the resolution is to resolve). Explain what actions are being taken to resolve those outlier relays.

e) For Line Number 2177, the observation is that the relay was upside down, and for resolution, the report refers to the relay report which does not seem to include any further information on the subject. Provide the missing information or explain how the outlier was resolved.

21. The report mentions that data outside the GIP were used to evaluate the GIP items (e.g., Page J15, Item 3).and items outside the GIP (i.e.,

Equipment Class 0). Describe these data and how they were used for seismic verification of TMI equipment.

22. Section 4.3.2 of the report states that the safety related vertical tanks are as follows: 3 large flat-bottom vertical tanks, 8 vertical tanks with legs, and'4 vertical tanks on steel base skirts. Provide 5

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screening evaluation work sheets (SEWS-Form similar to those on pg.G.21-1 of GIP-2) for these 15 tanks, and a detailed analysis of the condensate storage tank (CST, IA) to illustrate how the outlier

! evaluation was performed for the vertical tanks.

l 23. Section 4.3.3 relating to the review of cable and conduit raceways, l states (middle of page 79 of 84), " anchorage is judged acceptable for the 'other' seismic performance concerns." Provide a summary

description of how the raceway support anchorages were sampled and i judged acceptable. Provide typical work sheets (similar to Tables 8-1, j 8-2, 8-3 of GIP-2) for the raceway runs in containment building, diesel

! generator building and auxiliary building (one run in each of the a

buildings).

J i 24. The fire barriers attached to the essential raceway systems contribute j appreciably to the vertical and horizontal loadings on the raceways, j their supports, and anchorages under seismic events. Provide i information related to the inclusion of the fire barrier weight in the

seismic calculations of the raceway systems. This information may be

provided on the relevant work sheets requested in question 23.

i l 25. Provide information related to the method of resolving comments from the j third party inspection, specifically, the concerns related to item (5) 4 in Appendix L regarding Waste Evaporator Cooler, and Dr. Stevenson's i

" Summary Remark" regarding the determination of response frequencies of .

j- components. I i

! 26. Referrina to the in-structure resnonse snectra nrovided in voor ,

120-dav-resnonse to the NRC's reauest in Sunnlement No. 1 to i l Generic Letter (GL) 87-02. dated Nav 22. 1992. the followina information l i is reauested:

i j a. Identify structure (s) which have in-structure response spectra (5% j l critical damping) for elevations within 40-feet above the  !

. effective grade, which are higher in amplitude than 1.5 times the j j SQUG Bounding Spectrum. i j b. With respect to the comparison of equipment seismic capacity and  ;

j seismic demand, indicate which method in Table 4-1 of GIP-2 was

! used to evaluate the seismic adequacy for equipment installed on

the corresponding floors in the structure (s) identified in Item l (a) above. If you have elected to use method A in Table 4-1 of i the GIP-2, provide a technical justification for not using the in- <

structure response spectra provided in your 120-day-response. It

! appears that some A-46 licensees are making an incorrect comparison between their. plant's safe shutdown-earthquake (SSE)

! ground motion response spectrum and the SQUG Bounding Spectrum.

l The SSE ground motion response spectrum for most nuclear power i plants is defined at the plant foundation level. The SQUG

Bounding Spectrum is defined at the free field ground surface.

i For plants located at deep soil or rock sites, there may not be a i significant difference between the ground motion amplitudes at the

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foundation level and those at the ground surface. However, for i

sites where a structure is founded on shallow soil, the amplification of the ground motion from the foundation level to the ground surface may be significant.

, c. For the structure (s) identified in Item (a) above, provide the in-structure response spectra designated according to the height .

i above the effective grade. if the in-structure response spectra

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i identified in the 120-day-response to Supplement No. I to GL 87-02 was not used, provide the response spectra that were actually used to verify the seismic adequacy of equipment within the structures 4

identified in Item (a) above. Also, provide a comparison of these spectra to 1.5 times the Bounding Spectrum.

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