ML20136F583
| ML20136F583 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point, Saint Lucie  |
| Issue date: | 01/20/1995 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20136C539 | List:
|
| References | |
| FOIA-96-485 NUDOCS 9703170008 | |
| Download: ML20136F583 (13) | |
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i ATTACMENT 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR pmJLATION EVALUATION OF THE FLORIDA PONER AE LIGHT COMPANY'S RESPONSE T0 GENERIC LETTER 87-02 FOR ST. LUCIE UNIT 1 A E TURKEY POINT UNITS 3 AE 4 DOCKET NOS.: 50-335/250/251
1.0 INTRODUCTION
In December of 1980, the NRC designated " Seismic Qualification of Equipment in Operating Plants" as an unresolved safety issue (USI A-46). The safety issue of concern was that equipment in nuclear plants for which construction permit applications had been docketed before about 1972 had ndt been reviewed according to the 1980-81 licensing criteria for seismic qualification of equipment (i.e. Regulatory Guide 1.100; IEEE Standard 344-1975, and Section 3.10 of the Standard Review Plan (NUREG 0800, July 1981)).
Generic Letter (GL) 87-02 was issued in February of 1987 to implement the resolution to USI A-46 which concluded that the seismic adequacy of certain equipment in i
operating nuclear power plarts should be reviewed against seismic criteria not in use when these plants were licensed.
On June 2, 1988, the licensee made a presentation to the staff, and concluded that, in light of the relatively low seismicity of their plant sites, the existing design basis ensured sufficient seismic margin, and there was no significant safety benefit to be gained by addressing the requirements in GL j
87-02.
The licensee supported its position with a plant-specific value-impact 3
analysis, and requested that it be totally exempted from GL 87-02. The staff did not accept the licensee's position, but determined that their argument offered sufficient rationale to justify a scaled-back program to demonstrate that the FPL plants meet the original seismic licensing bases. Since that time, the staff and the licensee have had numerous dialogues, including meetings, conference calls, and written correspondence, but have not reached full agreement on the extent to which the program should be scaled-back.
Although the staff never fully accepted the licensee's program, the licensee proceeded with the implementation of its proposed scaled-back program at St.
Lucie Unit I and Turkey Point Units 3 and 4.
References 5 through 17 contain the significant' written correspondence between the staff and the licensee.
In a letter dated February 24, 1994 criteria which an implementation prog (Reference 1), the staff described general ram should include to satisfy the intent of USI A-46 for facilities located in low seismic regions, and identified specific areas where the licensee's current program appeared deficient when evaluated against the criteria. The primary areas of concern involved the adequacy of the licensee's safe shutdcwn path, the extensive use of engineering judgement for verifying equipment seismic adequacy, and the lack of an adequate relay evaluation. By letter dated May 24, 1994 (Reference 2),
the licensee provided information on the above areas of concern. The licensee also referred to recently published information relating to the seismic hazard of their plant sites to further support its position that its current scaled-back program is adequate. Essentially, the new information involved the resolution of differences between two sets of seismic hazard curves; one developed by EPRI and endorsed by the nuclear utilities, and the other 9703170008 970301 PDR FOIA BINDER 96-485 PDR n
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2 developed by LLNL and endorsed by the NRC.
Earlier LLNL curves reflected a higher seismic hazard for the FPL plants, whereas recently revised LLNL curves are in closer agreement with the EPRI hazard estimates.
The following evaluation is primarily based on the information presented in the licensee's September 8, 1992 (Reference 3), July 15, 1993 (Reference 4),
-and May 5,1994 submittals, but also considered the supporting / clarifying information provided during several meetings and conference calls with the licensee, and the information provided in References 5 through 17.
Specifically, this evaluation discusses each of the major program elements identified in GL 97-02, and assesses the effectiveness of the licensee's proposed scaled-back program for addressing each of the elements. GL 87-02 essentially requested that the affected licensees develop a seismic adequacy verification program which includes the following major elements (1) a safe j
shutdown path 2nsuring that the plant can be brought to and maintained in a j
hot shutdown condition for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, (2) the mechanical and i
electrical equipment associated with the path, (3) the tanks and heat exchangers associated with the path, (4) the cable tray and conduit raceway 4
systems associated with the path, and (5) the essential relays associated with the path.
2.0 DISCUSSION AND EVALUATION The September 8, 1992, and July 15, 1993, submittals provided the USI A-46 implementation program summary reports for St. Lucie and Turkey Point respectively, and described the following: (1) the scope of the licensee's scaled-back program, (2) the walkdown procedures and evaluation criteria which the licensee used in its USI A-46 program, and (3) a summary of the implementation results. The May 5,1994, submittal included the following information: (1) where applicable, a discussion as to how the implementation program satisfied the general criteria for plants located in areas with low i
seismic hazard, as described in the staff's letter dated February 24, 1994, l
(2) where applicable, a discussion as to why there was no safety concern ir.
not fully meeting certain criteria, (3) a description of proposed changes to the program in order to address specific areas of concern identified by the staff, and (4) responses to the staff's Request for Additional Information (RAI) of June 23, 1993.
2.1 Adeauacy of Safe Shutdown Path In the September 8, 1992, and July 15, 1993, submittals, the licensee provided descriptions of how plant safe shutdown would be achieved and maintained at each site, and which plant systems would be needed.
In addition, the licensee provided its safe shutdown equipment lists (SSEL) which identified the associated mechanical and electrical equipment. The licensee stated that the safe shutdown paths chosen will ensure that hot shutdown is achieved and maintained for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> rather than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as requested in GL 87-02.
This issue was one of the major points of contention between the staff and the licensee,.and its resolution is discussed below.
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In the May 5,1994, submittal, the licensee described additional non-seismic 4
water sources and also use of the primary bleed and feed approach which can be used to maintain a hot' shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> at each site.
the licensee indicated that the additional equipment associated with the non,
However seismic water sources would not be included in the SSEL and would not b 3
i seismically evaluated.
equipment was that, because of the diversity of the available wate j
i for ensuring that hot shutdown can be maintained for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the low probability of an SSE, it can be assumed that at least one of the sources will be available following an SSE even if none are seismically verified.
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addition, even if all of these sources are unavailable, the feed and bleed In
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approach can be used which consists of equipment which has either been seismically qualified per the original plant design or else included in the i
.USI A-46 verification program.
The licensee has identified a primary path and an alternate path to achieve hot' shutdown.
Both paths account for the following plant safety functions:
reactivity control, inventory control, and residual heat removal.'
For both sites, decay beat removal is accomplished with the auxiliary feedwater system taking suction from the condensate storage tank, the steam generators and atmospheric steam dump valves.
The steam generator code safety valves provide a back-up heat removal path should the atmospheric steam dump valves fail to function.
The licensee has provided various diverse water sources to remove reactor core decay heat at these plants.
the Auxiliary feedwater system (AFW) taking suction from the condensate storage tank.
will last for(CST). The CST has a capacity of about 240,000 gallons which 3/4 and 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> for the St. Lucie plant.the first 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of core decay heat This period of time is sufficient to conduct post trip surveys and cnnduct contingency planning if required.
Other operational cooling configurations available via this procedure are reestablishing main feed water flow, establish feed flow using the standby steam generator feed pumps and establishing feed flow from the other unit assuming it has not lost power.
can provide indefinite decay heat removal.There are the long term cooling sources that If these cooling sources are unavailable, the operator will move to line up the numerous other non-seismic water sources located at the sites.
These are:
Turkey Point 3/4 Raw water storage tank #1 500,000 gallons Raw water storage tank #2 750,000 gallons Demineralized water storage tank 500,000 gallons St. Lucie Unit 1 City water tank #1 500,000 gallons City water tank #2 500,000 gallons Treated Water tank 500,000 gallons
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4 Following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of cooling for Turkey Point Units 3 and 4 from t la hours of cooling for St. Lucie Unit 1 from the CST, an additional
, and gallons of cooling water is needed fcr St. Lucie 190 000 j
4-core decay heat removal for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
I, cooling sources are unavailable, the operator would implemen
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bleed and feed mode of cooling which uses the refueling water sto the safety injection pumps.
I indefinite decay heat removal.This emergency mode of cooling can provide and Components and equipment within this cooling path are either seismically qualified per original plant design or they walked down by the GL-87-02 seismic review team and determined to be j.
seismically adequate.
The numerous water sources, flow paths and time available for ac I.
operational alignments provides reasonable assurance that adequate d Ii removal capability is available in the event of a seismic event.
t based normal and emergency operating procedures for lining up co Symptom j'
are available at these sites.
Therefore, the staff concludes that the licensee's approach to achieve and maintain hot shutdown for 7 seismic event is acceptable.
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2.2 I
Adeadacy of In-structure Response Spectra 1
the floor response spectra for all equipment whose j
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less than 8 Hz above grade wer,e compared against 1.5 times the bound
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capacities of the equipment were found to be acceptable.
discuss 'how the floor response spectra were generated. The licensee did not 3
parameters affecting the floor response spectra are ground response spectru The pertinent i
structural damping, parameters used in soil structure interaction analysis
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equipment damping, etc.
response spectra during. The staff will review the adequacy of the floor j _
the planned site inspection.
i 2.3 Seismic Adeauacy of Mechanical and Elearical Eouionent i
mechanical and electrical equipment, and associate i
similar to that approved for the generic resolution of USI A-46.
i used a Seismic Review Team (SRT) to conduct a wa The licensee SSE.
in seismic design, seismic analysis and test qualification practices for i
nuclear power plants.
The program was based on a combination of experience data and plant walkdowns to demonstrate seismic adequacy, and referenc of the same documents that are referenced in GIP-2 insofar a 1
used to verify the equipment adequacy.
seismic adequacy of the equipment, its anchorage, and a check for seism interaction concerns..
a GIP-2 program, however, was the extensive reliance on th of the SRT rather than adequacy.,In addition, performing explicit calculations, te demonstrate the' licensee's program produced minimal documentation as to what specific equipment and anchorage attributes were evaluated du
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the walkdown process.
Also, the licensee stated that it s.onsidered safe rugged, and therefore, did not include them in the seismi 4
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valves for safe shutdown an important part of the USI A-46 process.
will. review the licensee's basis for determining the ruggedness of selected The staff i
safe shutdown valves during the site inspections, j
i The licensee's application of the experience database is a good example of the j
extent to which the licensee employed SRT judgement.
In order to use the demonstrated that the equipment item is similar to a genera i
i equipment-included in the database.
physical attributes (e.g., size, weight, general configuration, etc.), and
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also applying specific caveats, which describe equipment-specific seismic
- a vulnerabilities.
The licensee stated that it had used the Senior Seismic
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Review and Advisory Panel (SSRAP) Report, Revision 4, to verify the applic-i ability of the experience database. However, the staff's previous review of this report determined that it did not provide a complete description for each equipment category.
This concern was communicated to the licensee in the June 23, 1993 RAI.
The licensee responded that the SRT consisted of individuals L
intimately involved in the development of the criteria and caveats in GIP-2 for applying the database, and, as such, it was confident that the equipment j.
and caveat descriptions in Rev. 4 of the SSRAP report, augmented by the SRT knowledge provide sufficient bases for assessing equipment construction adequacy o,r equipment categories and/or anomolies addressed in the spe 1-
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' caveats (referred to in Rev. 2 of the GIP).
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.that it perfomed a subsequent review of its walkdown data sheets andIn addition, th confirmed this conclusion. Because of the lack of documentation to demonstrate that the appropriate criteria are satisfied, the staff will I,
confirm the adequacy of this part of the program during the site inspection.
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For verifying the adequacy of the equipment anchorage, the licensee committed i
to the criteria in EPRI NP-5228-SL, Revision 1, which is the same criteria utilized in GIP-2.
Seismic verification of e accomplished through two screening reviews. ~quipment anchorage was i
I both screens in order to be considered adequate without performing a seismic a)i capacity calculation.
The first level screen was a " design basis" screen; the i
equipment anchorage was reviewed to determine if it was in conformance with-i design basis drawings.
The licensee stated that, regardless of whether the existing equipment anchorage could be shown to meet the EPRI NP-5228-SL, Revision I criteria, the anchorage was restored to the "as designed" configuration.
The second level screen involved a determination by the SRT as to whether the anchorage was "obviously rugged" based on the EPRI criteria.
calculation demonstrating conformance with the EPRI criteria was performed for A
any equipment anchorage not judged to be "obviously rugged." Lccause of the lack of supporting documentation, the staff is not able to evaluate the technical adequacy of the SRT's judgements.
the adequacy of the SRT's judgements by performing detailed anchorageTher inspections of a sample of SSE items during the aforementioned site inspection.
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The licensee's program also did not include a check for adequate anchor bolt i
torque tightness, which is considered one of the most important attributes for ensuring the integrity of bolted expansion anchors.
This issue was raised in the staff's RAI of June 23, 1993.
based on utilizing a non-intrusive walkdown, and that it was not a i
data comparing the capacity of bolts failing this test to bolts passing the test.
Therefore, the licensee concluded that there was no justification to augment its program to include anchor bolt torque tightness testing.
i staff maintains that torque tightness testing is an important part of the The anchorage inspection criteria to which the licensee committed (EPRI NP-5228-SL), and will assess anchor bolt torque tightness of selected safe shutdown equipment items during the site inspection.
The licensee indicated that its programs included a review of potential i
seismic interactions primarily based on the procedures and criteria in EPRI
!1 NP-6041, "A Methodology for Assessment of Nuclear Power Plant Seismic Margin The licensee's program addressed _ potential interactions due to seismic II over i
I concerns, proximity of equipment, and flexibility of attached lines.
i-unresolved interaction which could possibly prevent an equipment item fromAny t-performing it., safe shutdown function resulted in the equipment being identified as an outlier.
assessing seismic' interactions is consistent with the methodology the generic resolution of USI A-46' and is therefore acceptable.
i the submittal for St. Lucie Unit 1, the licensee indicated that the SRT found However, in many examples of poor seismic housekeeping such as unanchored temporary lj ceilings, etc., which were noted by the SP.T on the data sheets{
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licensee's report did not discuss the resolution of these concerns.
The adequacy of the licensee's implementation of this part of its program will be The i
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verified'during the site inspection.
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1 2.4 Seismic Adeouacy of Tanks and Heat Exchanaers i
t 2.4.1 Turkey Points Unit 3 and 4 4
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The licensee has evaluated a number of safety-related vertical steel tanks.
The staff's review of the procedures and calculations indicate that the calculations are focussed on demonstrating seismic margins (to be used for IPEEE program) and not on the design buis calculations required for 1
resolution of USI A-46.
Even after the implementation of the upgrades recommended by its consultants, the level of seismic margin earthquake that 3
the tanks (Refueling Water Storage. Tank and Condensate Storage tank) can withstand without exceeding the corresponding acceptance criteria has been calculated to be 0.119 This is less than the SSE at the plant of 0.15g peak ground acceleration.
Also, the Component Cooling Water Surge Tank and the Boric Acid Storage Tank have not been screened by the SRT. Resolution of concerns relating to tank capacities below demand level need to be addressed by the licensee, using alternatives acceptable to the staff, to satisfy the minimum requirements for stability of these tanks and safety functions of the attached piping. The staff will review the methods of resolving these outliers during the site inspection.
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2.4.2 St. Lucie Unit 1 The licensee's procedure for evaluating safe shutdown tanks and heat and determining whether the anchorage satisfied the ap requirements.
Tt.a specific methodology and criteria for performing the assessment was not provided in the procedure.
majority of the items were determined to be acceptable based on conservat i
anchurage calculations which were reviewed and accepted by the SRT.
j Component Cooling Water Tank Platform was found unacceptable, and was The subsequently modified to include several additional bracing members.
addition, the SRT raised concerns with rusting on the anchor bolts of both In Diesel Oil Storage Tanks.
degraded bolts were adequate to carry SSE loads. Subsequent calculations dem t
To prevent further bolt degradation, the licensee implemented a repair modification which included i
removing all corrosion products from the anchor bolts, application of i
protective coatings, installation of cover plates to enclose each anchor bolt bolts from future corrosion. pocket, and the application of a filler material which The licensee indicated that its scaled-back USI A-46 resolution program for A-40, " Seismic Design Basis," as it applies to tanks and However, the resolution of USI A-40 required more than an assessment of the 1
anchorage. This issue was raised in the staff's June 23, 1993 RAI, which i
requested that the licensee provide an assessment of the buckling mode of failure of tank shells, and also provide an assessment of anchor bolt and tank shell shear stresses considering the vertical component of the SSE.
licensee's May 5, 1994, response essentially stated that the conservative The methodology used to evaluate the anchorage ensured that buckling of the tank shell would not occur.
The licensee also stated tr it has perfomed calculations to demonstrate the adequacy of the tanks with respect to bolt and shell shear stresses due to the vertical component of the SSE.
Based on the staff's review of the program summary report, it is not clear that the licensee's calculations are sufficient to demonstrate the overall i
adequacy of the tanks and heat exchangers for USI A-46 and USI A-40.
i Therefore, the staff will verify the adequacy of the licensee's program for t
assessing the overall adequacy of the safe shutdown tanks a found condition of the tanks, during the site inspection.
2.5 Seismic Adeauacy of Raceway Systems The licensee stated that, based on the low seismicity of the plant sites, and the inherent ruggedness of raceway systems as evidenced by experience data, it did not include a specific evaluation of raceway systems in its programs.
licensee further stated that raceways were reviewed for inclusion in the The i
scaled-back program, but were determined to be low contributors to seismic risk; as such, there was no apparent cost-benefit to including raceways in the seismic verification program for either Turkey Point Units 3 and 4, or St.
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Lucie Unit 1.
The staff acknowledges that raceway systems have performed well
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s in past earthquakes, but maintains that some limited review should be T
1 performed to ensure that there are no gross plant-specific design or 3
installation problems. Therefore, the St. Lucie Unit I and Turkey Point Units l
l' 3 and'4 raceway systems will be inspected and evaluated on a sampling basis i
during the site inspections. The staff will also ensure that the licensee has j
properly considered the weights of the fire barriers (attached to raceways) in 4-establishing the seismic adequacy of the supports and anchorages of the 4
raceway systems.
i i-2.6 Evaluation of Essential Relays The licensee's program for evaluating relays at each plant site included a screening process to determine if the plant utilized any of the low seismic i
ruggedness, or " Bad Actor" relays as listed in Appendix E of EPRI NP-7148-SL, in its safe shutdown path. The licensee indicated that of the 23 relay types
. 1 identified in the EPRI document, only 13 were used in any application at St.
!1 Lucie or Turkey Point.
Two additional relay types were eliminated from the
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list because it was determined that they could not possibly be used in safe shutdown equipment. 0f the remaining 11 relay types, the licensee determined.
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that 7 had been fully seismically qualified to IEEE 344-1975 either at St.
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Lucie Unit 2 or else at the Turkey Point facility.
4 The licensee indicated that it would perform further reviews to determine if i
its USI A-46 safe shutdown paths utilized any of the remaining 4 types of relays.. If any are found, the licensee would determine if potential relay 3
- i chatter could be addressed by plant operator action to reset the relay. procedural changes or through the use of If this is unsuccessful, the licensee i-indicated that the relay would be replaced with a seismically qualified relay.
The staff finds this procedure acceptable for addressing " Bad Actor" relays.
i During the site inspection, the staff will review the specific seismic t
qualification documents (i.e., test results demonstrating conformance to IEEE c
344-1975) for the 7 relay types discussed above which were determined to be
- A fully qualified, and the staff will also review the adequacy of procedural changes and/or operator actions for resetting relays.
L j4 With regard to essential relays other than " Bad Actors," the licensee indicated that, based on the low probability of a seismic event occurring at either the St. Lucie or Turkey Point site, and the lack of evidence to suggest 2
that there has been or may be a problem with the anchorage of any relays installed in the plants, it does not feel that there will be any benefit i
gained by using its resources to verify the proper mounting of essential L
relays. The staff maintains that the evaluation of potential relay chatter is a major issse in the resolution of USI A-46.
Further, even considering the i
loe seismicity of the FPL sites, it is possible that in-cabinet amplification of SSE'loede could be sufficient to cause relay chatter, especially if the relay is not properly mounted. Chatter in essential relays could potentially cause problems with the operability of safe shutdown equipment. Therefore, it i
is important that the relays be properly mounted to ensure that chatter would not likely occur. Consequently, the staff will verify, through sampling during the inspection effort, that relays in safe shutdown equipment are properly mounted per design / installation drawings and/or the manufacturer's recommendations.
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2.7 Resolution of Outliers 2.7.1 Turkey Point Units 3 and 4 The licensee stated that every equipment item for which a concern or recommendation to improve the seismic capacity was made by the SRT was j
identified as an outlier.
i identified at Turkey Point Units 3 and 4.As a result, thirty-five equipment outliers w Each outlier was tracked until final resolution.
In general, the outliers consisted of the following i
(1) degraded / deficient equipment anchorage issues, (2) a potential seismic interaction concern, and (3) identification of seismically vulnerable details on specific equipment.
implemented hardware modifications, which were documented in Plan i
Change / Modification (PC/M) Packages, to increase the seismic resistance of the equipment.
In addition, the as-found condition of each outlier was immediately evaluated for o plant operability concerns.perability and none were determined to be potential In its May 5, 1994, submittal, the licensee stated that all but two of the 4
outliers at Turkey Point Units 3 and 4 had been completely resolved, and that the remaining two would be resolved by September 30, 1994. The staff finds that, if adequately implemented, the licensee's actions should be sufficient to resolve each of the outliers identified during the program implementation.
During the site inspection, the staff will verify, on a sample basis, that the outliers have been adequately resolved.
4 2.7.2 St. Lucie Unit 1 1
The licensee reported that three equipment outliers were identified and evaluated during the walkdowns at St. Lucie Unit 1, and that none were determined to be potential plant operability concerns.
The three outliers l
included the platform for the Component Cooling Water (CCW) Surge Tank, a 480V Motor Control Center (MCC), and a 480V toad Center for the Pressurizer Heater.
The concern with the tank platform involved the strength of the platform support structure as well as potential seismic interactions. The MCC and the load center were identified as outliers because of potential anchorage implementing hardware modifications.The licensee indicated that all three outliers concerns.
The licensee also indicated that, because of some concerns identified during the walkdowns, it felt it was prudent to implement modifications for three other items identified as non-ccnformances even though the items had passed the screening reviews and were judged adequate by the SRT.
These three items included the anchor bolts for the Diesel 011 Storage (DOS) Tanks, a battery charger, and a 125V DC Bus.
For the DOS tanks, the licensee implemented a modification to remove corrosion from the anchor bolts, and provide for the application of protective coatings, cover plates, and filler material to protect the bolts from future corrosion. For the battery charger, the licensee stated that it upgraded the anchorage even though the existing i
1 anchorage capacity wa:: determined to be acceptable for the seismic demand.
For the 125V DC Bus, the the welds which attach this cabinet to its base angle iron were found to have burned through the cabinet wall.
The licensee stated i
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i 10 that this item was not considered an outlier because it determined anchorage would be acceptable if the welds were re resolution was to provide supplemental anchorage. paired. The licensee's the modifications for all of the outliers and non-conformances we implemented during a subsequent outage in accordance with FPL Minor Engineering Package (MEP) PCM 152-190M.
The staff finds thati the licensee has taken adequate actions to resolve outliers and non-conformances identified during the program implementation.
However, it is not clear why the 125V DC Bus was not identified as an outlier in its USI A-46 program.
modification was implemented to resolve any anchorage concerns w
,j anchorage for this equipment item, the staff considers it resolved.
3.0 Sul94ARY OF MAJOR STAFF CONCERNS i
Based on the discussion above, the staff has identified several concerns which must be further evaluated in order to confirm the adequacy of the licensee's program implementation.
These issues will be the primary focus of future staff inspections at St. Lucie Unit I and Turkey Point Units 3 and 4, and are described below:
1 The staff will review the methods used to develop the in-structure response spectra for performing equipment evaluations.
2.
The staff will verify, by sampling, that the safe shutdown equipment is similar to equipment in the experience database.
3.
The staff will review selected safe shutdown equipment items (e.g.,
valves, raceway systems, etc.) which were excluded from the seismic verification process based on the licensee's position that these items are inherently rugged.
4.
Because of the extensive use of SRT judgement for screening out equipment anchorage, and the lack of documentation to support the judgements, the staff will verify, by sampling, that the criteria in EPRI NP-5288-SL, Revision I has been adequately addressed.
5.
The staff will verify, during the site inspection, the adequacy of the licensee's implementation of the methodology for assessing seismic interactions.
6.
The staff will review the capacity versus demand evaluations for seier ed equipment items to confirm the appropriateness of the lice..see's method of comparing capacity and demand at the plant level rather than for each individual equipment item.
7.
The staff will review the licensee's evaluation of tanks and heat exchangers to verify the adequacy of the licensee's calculations, and to ensure that the program adequately resolves the outliers and concerns
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tank issues for USI A-40 and USI A-46.This will resolve the seismic adequacy of 1
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During the site inspection, the staff will review the specific seismic qualification documents for the " Bad Actor" relays and the adequacy of procedural changes and/or operator actions for resetting relays.
9.
The staff will verify, by sampling, the installation adequacy of relays in safe shutdown equipment.
10.
The staff will review the licensee's motheds for resolving outliers, including any needed revisions to plant procedures to address the j
several issues involving poor housekeeping.
4.0 CONCLUSION
S Based on'the information provided in the licensee's submittals dated September
'8, 1992, July 15,-1993, and May 5,1994, and the supporting and clarifying information provided in References 5 through 17 and during several meetings and conference calls, the staff finds that pending staff verification of the appropriateness of the licensee's many prog, ram assumptions and adequacy of the implementation activities, the licensee's scaled-back program is, in general, adequate to resolve the primary concern of USI A-46.
However, as discussed in Section 3.0 of this evaluation, the staff has identified ~several areas of concern which must be further evaluated before a final determination can be reached regarding the overall program adequacy.. Consequently, the staff intends to conduct site inspections in order to fully evaluate the licensee's USI A-46 program implementation, with special emphasis on each of the concerns noted in Section 3.0 of this report.
It is noted that the site inspections will not be limited to the areas described-in Section 3.0; but will be used to verify the adequacy of the entire program. The closure of USI A-46 for each FPL plant will be documented in separate supplements to this safety evaluation following the resolution of all of the above concerns, and any additional issues which may be identified during the site inspections.
'~j 5.0 REFERE EEft 1.
Letter from J. Norris and L. Raghavan, USNRC, to J.H. Goldberg FPL, dated February 24, 1994.
2.
Letter from W. H. Bolke, FPL, to USNRC, dated May 5, 1994.
3.
Letter from W. H. Bolke, FPL, to USNRC, dated September 8, 1992.
4.
Letter from W. H. Bolke, FPL, to USNRC, dated July 15, 1993.
5.
"Sununary of Meeting Held With Florida Power and Light Company (FPL) on June 2, 1988, Regarding Seismic Qualification of Equipment (USI A-46 Generic Letter 87-02)," June 16, 1988.
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6.
Letter from W. F. Conway, FPL, to USNRC, dated August 4, 1988.
7.
Letter from'J. A. Norris and G. E. Edison, USNRC, to C. O. Woody, FPL, dated August 4, 1989.
8.
Letter from J. H. Goldberg, FPL, to USNRC, dated October 2, 1989.
9.
Letter from J. H. Goldberg, FPL, to USNRC, dated December 13, 1989.
l 10.
Letter from USNRC, to J. H. Goldberg, FPL, dated January 23, 1991.
11.
Letter from W. H. Bolke, FPL, to USNRC, dated February 27, 1991.
12.
" Summary of Meeting Between FPL and NRC Staff," dated March 18, 1992.
I 13.
Letter from W. H. Bolke, FPL, to USNRC, dated May 15, 1992.
14.
Letter from J. A. Norris and L. Raghavan, USNRC, to J. H. Goldberg, FPL, dated July 28, 1992.
1 15.
Letter from USNRC, to FPL, dated June 23, 1993.
16.
" Seismic Qualification of Mechanical and Electrical Equipment - USI A-46 (summary of July 20, 1993, meeting)," dated July 28, 1993, o
17.
Letter from W. H. Bolke, FPL, to USNRC, dated September 15, 1993.
I
_ _ _ _ _. ~
o
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l 4
i ATTACHMENT 2 SALP INPUT L
l Facility N-- : St. Lucie Unit 1, Turkey Point Units 3 and 4 S"-- ry of Review Activity USI A-46, ' Verification of Seismic Adequacy of j
Equipment in Operating Reactors."
completing the review of the Itcensee's original submittals, and a 3
response to an outstanding RAI and another sta i
several sigrificant unresolved issues with the licensee's USI A-46 implementation programs.
j engineering support activities.This SALP pertains to the adequacy of the licensee's Narrative Discussion of Licensee Performance address the staff's RAI.The licensee's response generally Icrked s 5
As a result, the staff has not been able to reach final closure on the USI A-46 issu review of the licensee's programs,e at the FPL plants. Throughout the staff's the licensee has continually relied on the staff to identify programwh i
I
. weaknesses, and has taken the attitude of providing minimal information in respondim; to the staff's comments. Additionally t
provide clear or reasonable justification for seve,ral apparent programmatict shortcomings.
upcoming site inspection at one of the licensee's facilities.Thes Oriainator: Michael McBrearty, NRR/04EB Date: 1/12/95 I
,