ML20133G164

Forwards RAI Re NRC Review of Util plant-specific Summary Rept in Response to USI A-46 Program at Plant

ML20133G164
Person / Time
Site:	Beaver Valley
Issue date:	01/10/1997
From:	Brinkman D NRC (Affiliation Not Assigned)
To:	Cross J DUQUESNE LIGHT CO.
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR TAC-M69428, NUDOCS 9701150194
Download: ML20133G164 (7)

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-January 10, 1997 l Mr! J. E. Cross t

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SUBJECT:

fREQUESTFORADDITIONALINFORMATION(RAI)-BEAVERVALLEYPOWER .

..f * , , ' STATION,* UNIT NO.1, UNRESOLVED SAFETY ISSUE A-46 (TAC NO. M69428) '

Dear,

.Mr.

Cross:

By: letter dated January 31, 1996, Duquesne Light Company (DLC) submitted the plant-specific summary report in response to the Unresolved Safety. Issue (USI)

A-46 program at Beaver Valley Power Station, Unit No. 1 (BVPS-1). The.NRC staff..has reviewed the summary report and -has. determined that additional information is required to complete its review of DLC's USI A-46 program. The additional information we require to complete our review of DLC's USI A-46 program for BVPS-1 is described in the enclosed RAI. Please provide DLC's response to this RAI within 120 days of receipt of this -letter to enable us to complete our review in a timely manner.

Please contact me at (301) 415-1409 if you have any questions regarding this issue.

Sincerely,

/S/

Donald S. Brinkman, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-334

Enclosure:

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..... January 10, 1997 Mr. J. E. Cross President - Generation Group i Duquesne Light Company

. Post Office Box 4 Shippingport, PA 15077 i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) - BEAVER VALLEY POWER a STATION, UNIT NO. 1, UNRESOLVED SAFETY ISSUE A-46 (TAC NO. M69428)

Dear Mr. Cross:

By letter dated January 31, 1996, Duquesne Light Company (DLC) submitted the plant-specific summary report in response to the Unresolved Safety Issue (USI)

A-46 program at Beaver Valley Power Station, Unit No.1 (BVPS-1). The NRC staff has reviewed the summary report and has determined that additional information is required to complete its review of DLC's USI A-46 program. The additional information we require to complete our review of DLC's USI A-46 program for BVPS-1 is described in the enclosed RAI. Please provide DLC's response to this RAI within 120 days of receipt of this letter to enable us to complete our review in a timely manner.

Please contact me at (301) 415-1409 if you have any questions regarding this issue.

Sincerely,

.h .

Donald S. Brinkman, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-334

Enclosure:

RAI cc w/ enc 1: See next page

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l J. E. Cross Beaver Valley Power Station Duquesne Light Company Units 1 & 2 cc:

Jay E. Silberg, Esquire Bureau of Radiation Protection 1 Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of 2300 N Street, NW. Environmental Resources Washington, DC 20037 ATTN: R. Barkanic Post Office Box 2063 R. K. Brosi, Manager Harrisburg, PA 17120 Nuclear Safety Department (BV-A)

Duquesne Light Company _ i Beaver Valley Power Station Mayor of the Borrough of PO Box 4 Shippingport Shippingport, PA 15077 Post Office Box 3 Shippingport, PA 15077 ,

Commissioner Roy M. Smith 1 West Virginia Department of Labor Regional Administrator, Region I Building 3, Room 319 U.S. Nuclear Regulatory Commission Capitol Complex 475 Allendale Road Charleston, WVA 25305 King of Prussia, PA 19406 John D. Borrows Resident Inspector Director, Utilities Department U.S. Nuclear Regulatory Commission !

Public Utilities Commission Post Office Box 298 180 East Broad Street Shippingport, PA 15077 Columbus, OH 43266-0573 Director, Pennsylvania Emergency Duquesne Light Company Management Agency Beaver Valley Power Station Post Office Box 3321 PO Box 4 Harrisburg, PA 17105-3321 Shippingport, PA 15077 ATTN: S. C. Jain, Vice President i Ohio EPA-DERR Nuclear Services (BV-A)

ATTN: Zack A. Clayton Post Office Box 1049 Columbus, OH 43266-0149 l Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 ,

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Reauest For Additional Information Reaardina Unresolved Safety Issue A-46 '

j Beaver Valley Power Station. Unit No. 1 j Docket No. 50-334 i

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Reference:

Letter (and attachments) from Duquesne Light Company to USNRC,

] " Summary Report for Resolution of USI A-46," January 31, 1996 i 1. On page 20 of your submittal, you state that "The length of all Hilti

! Kwik-bolts.is known by virtue of controlled procurement." Indicate whether the demand force in an anchor was compared against the bolt i

strength specified in Generic Implementation Procedure, Revision 2, (GIP-2) Table C.2-1, or the bolt strength corresponding to the actual bolt length from the Hilti catalog. If the Hilti Catalog allowable bolt loads were used, provide the basis for not using the GIP-2 allowable j '

l bolt loads.

I 2. You stated that thirty-one (31) tanks and heat exchangers were reviewed I and twenty-seven (27) were outliers, and most of the outliers were

! caused by anchorage problems. However, you did not state whether you -

i had reviewed the adequacy of the tanks and heat exchangers themselves

assuming the anchorage was properly designed and installed. Provide i information regarding the adequacy of the tanks and heat exchangers

~i themselves in accordance with the criteria delineated in Chapter 7 of GIP-2.

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3. Based.on the information provided by DLC, it is unclear as to how some l equipment were determined to meet the intent of the stated caveat. The i following questions pertain to Table 5.2 on meeting the intent of l caveats as described in Appendix B of GIP-2.

4 l a. For equipment FE-CDL-1A, FE-CDL-1B, PCC-FE-1A, and PCC-FE-18, you

stated that the anchorage calculation is not yet complete but that

the anchorage was adequate. State your basis for this conclusion.

b. Transmitters FT-CH-124, FT-CH-127, and FT-CH-130 were mounted to j block walls with expansion anchors. You stated that you performed j analyses for these anchors and found them acceptable. Provide the criteria that you used for expansion anchors embedded in block walls and submit anchorage calculations for these three transmitters.

c. For BAT-BKR-1, -2, -3, -4 and BAT-CHG-1, -2, -3, -4 provide a calculation for each type of equipment to demonstrate the seismic

adequacy of these cabinets.

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d. For valves FCV-RC-455C1, C2, D1, and D2, discuss how these valves are equivalent in ruggedness to the check valves with regard to design adequacy during a seismic event.

e. For flow indicators FI-CH-122A,124,127,130, and 150, FI-FW-100A/B/C, level recorders FR-MS-478, 488, and 498, LI-FW-474, 475, 476, 484, 485, and 486, discuss in detail how these components were qualified by the " rule of the box."

f. For flow indicator FI-CH-122, provide the basis for concluding that the collapse of a lighting fixture located above this equipment will not adversely affect its function.

g. For motor-operated valves MOV-106A and 114A, provide the basis for concludingithat the failure of the 1-inch steel pipe above the valves will not damage the valves.

h. Discuss how the solenoid-operated valves SOV-MS-101A, B, and C were qualified by the " rule of box" with panels PNL-MS-101A, B and C respectively.

i. For solenoid-operated valves S0V-RC-455C1, C2, D1 and 02, the clearance from the valve housing is approximately 1/16-inch to the adjacent PCV-RC-455C valve actuator. Provide additional informati:m to demonstrate that the S0Vs and the valve actuator would not respond out of phase and impact each other during an earthquake, as-described in the Bounding Spectrum Caveat 3 of Appendix B to GIP-2.

j. Provide an analysis or a calculation to demonstrate the seismic adequacy of the cast-iron valve yokes for valves TV-MS-111A, B, and C.

k. For control room air intake vent damper VS-D-40-1F, provide the basis for the statement that poor weld quality is judged to be structurally adequate.

4. In Table 5-3, it appears that the brief discussion and resolution of the outliers do not provide adequate information in characterizing the deficiencies and for evaluating acceptability of the proposed or implemented modifications. This observation is applicable to over 200 caveats -listed in Table 5.3. It is expected that, as GIP-2 specifies, the deficiencies and modifications have been thoroughly documented to allow an independent review. Provide documentation regarding the resolution of the outliers for equipment BAT-1, FCV-RC-455C1, FR-MS-478, HCV-CH-389, INV-VITBUS-1, PCV-RC-456, PNL-AMSAC, PNL-PR-HTR-A, RK-VS-E567, TRANS-1-8-N1, TV-CH-200A, VS-AD-9, VS-AFD-5, VS-D-4-8A, VS-F-57A, and WR-P-1A.

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5. Section 5.3.1.5 of the reference report states that the BVPS-1 air supply system is not seismically qualified for functionality. The resolution provided in Table 5.3.1.5 shows that there are seven air-operated valves (i.e., FCV-CH-122, FCV-FW-103A and B, HCV-MS-104, PCV-MS-101A, B and C) that require operator actions for use in the SQUG safe shutdown. Clarify how these operator actions could be performed within the allowable time frame and in a hazardous or unfamiliar environment.

6. Section 8 of the reference report states that "the unresolved outliers will be prioritized as to their safety significance and scope. If modifications are required, the implementation of modification and replacements will be scheduled during one of the next three BVPS-1 refueling outages." Discuss how the unresolved outliers will be ranked considering their safety significance and scope. Provide the results of the prioritization analysis, an actual schedule for completion of the outlier resolution and an assessment of the impact on plant safety in consideration of the proposed schedule for resolution.

7. In reference to Sections 2.2.1.5 and 2.3 of Attachment 2 to the reference report, the essential relays in the fire protection systems that are neither seismically qualified, nor included in the Seismic Qualification Utility Group (SQUG) database are listed in Table 2.1-1, as " FIRE PROT. - NO QTR." The report mentioned that these relays /contactors may be qualified by using a database other than the SQUG database. If so, identify the database, and the nature and the extent of the deviation from the GIP-2 and provide justification that the. database is acceptable for such applications.

8. In Section 2.2, the bad actor relays Westinghouse COM-5, and SG relays and General Electric HGA relays used at BVPS-1 are identified as outliers because of low seismic ruggedness chatter (in accordance with GIP-2 guidance). The section indicated that these relays are used as normally open contacts and, therefore, their seismic capacities exceed the demand level of relays used in that configuration. Provide the seismic qualification data for these relays to demonstrate that these relays have seismic capacity exceeding the seismic demand.

9. Referring to the in-structure response spectra provided in your 120-day response to the NRC's request in Supplement No. 1 to Generic letter 87-02, dated May 22, 1992, provide the following information:

a. Identify structure (s) that have in-structure response spectra (5 percent critical damping) for elevations within 40 feet above the effective grade, which are higher in amplitude than 1.5 times the SQUG bounding spectrum.

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b. With respect to the comparison of equipment seismic capacity and seismic demand, indicate which method in Table 4-1 of GIP-2 was used i

to evaluate the seismic adequacy for equipment installed on the i

corresponding floors in the structure (s) identified in Item (a) above. If you have elected to use method A in Table 4-1 of GIP-2, provide a technical justification for not using the in-structure response spectra provided in your 120-day response. It appears that

some USI 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. The SSE ground motion a

response spectrum for most nuclear power plants is defined at the plant foundation level. The SQUG bounding spectrum is defined at the free-field ground surface. For plants located at deep soil or rock sites, there may not be a significant difference between the ground motion amplitudes at the foundation level and those at the ground surface. However, for 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

above the effective grade. If the in-structure response spectra l 3

identified in the 120-day response to Supplement No. I to Generic '

Letter 87-02 were not used, provide the response spectra that were i actually used to verify the seismic adequacy of equipment within the i structures identified in Item (a) above. Also, provide a comparison of these spectra to 1.5 times the bounding spectrum.

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Page 2 December 20, 1996 U.S. Nuclear Regulatory Commission y j47g I

Element & Isotope: .See Attached Schedule

! Mode of Shipment: Truck, Closed Van, Exclusive Use Routing: US 23 to US 1181 Estimated Time and Date of Departure and Arrival:

See Attached Schedule A total of sixteen shipments are necessary to complete this project. The attached schedule identifies the first seven shipments currently scheduled. The remaining shipments and dates will be identified at a later date when scheduling arrangements have been determined. l I

Please contact me at (423) 743-9141, Ext. 1154 if you have questions or comments.

Sincerely, NUCLEAR FUEL SERVICES, INC. 1

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\

oseph Pugh Transportation & Waste Manager

/ka Enclosure I

I invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas this 26th day of December 1996 l

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