ML20249B441
| ML20249B441 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/15/1998 |
| From: | Olivier L BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20249B442 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR BECO-2.98.045, GL-87-02, GL-87-2, NUDOCS 9806230111 | |
| Download: ML20249B441 (44) | |
Text
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G Boston Edison Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts 02360 June 15, 1998 L.J. Olivier Senior Vice President Nuclear BECo Ltr. 2.98.045 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington DC 20555 Docket No. 50-293 License No. DPR-35 Response to Reauest for Additional Information Re. Pilorim's USl A-46 Implementation This letter responds to the NRC December 16,1997 request for additional information (RAl) on the Pilgrim Station, Generic Letter 87-02 (USI A-46) Summary Report submittal of September 30,1996.
This letter describes an increase in A-46 project scope we are undertaking as a result of our review of question #2; that is, we are re-applying the Generic Implementation Procedure (GIP) Method A for evaluating equipment seismic demand in accordance with June 30, 1997, Seismic Qualification Utility Group (SQUG) guidance. This change in evaluation methodology could result in the identification of additional outliers. Our response to question
- 2 provides further details.
Should you have any questions, please contact Mr. J. D. Keyes, Regulatory Affairs Department, at (508) 830-7942.
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Regional Administrator, Region 1 Mr. Alan B. Wang U.S. Nuclear Regulatory Commission Project Manager Project Directorate 1-3 475 Allendale Road Office of Nuclear Reactor Regulation King of Prussia, PA 19406 Mail Stop: OWFN 14B2 U.S. Nuclear Regulatory Commission 1 White Flint North Senior Resident inspector 11555 Rockville Pike
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 1:
In your letter dated September 30,1996, you stated that Boston Edison Company committed to implement Generic Implementation Procedure, Revision 2 (GlP-2). You also stated that no programmatic or significant deviations from the GIP were taken while performing the walkdown and seismic adequacy evaluations at Pilgrim Station for resolution of USI A-46. List a sample of worst case deviations that are considered to be insignificant for Pilgrim and provide the basis for categorizing them as such. Also submit the definition of " safety significant" that the walkdown crew used and provide a justification of why the definition is adequate.
RESPONSE 1, PART 1:
Pilgrim's implementation of GlP-2 followed the SQUG GIP implementation guidance. Inherent in this approach is the use of engineering judgment by the Seismic Review Team (SRT) in completing various GlP-2 activities. As might be expected when performing this type of comprehensive review, deviations were identified during the walkdowns. Significant deviations were identified as A-46 Outliers. Worst-case insignificant deviations that resulted in the SRT being able to conclude the intent, if not the exact requirement, of the caveat was met were identified in the Screening Evaluation Work Sheets (SEWS) and also in the Summary Report for USl A-46 in Table 5.1. These are also addressed in RAI Question 6.
RESPONSE 1, PART 2:
" Safety significant" as a topic or definition came into play if the walkdowns identified a degraded or nonconforming condition. Under Pilgrim Station procedures, a degraded or nonconforming condition is also known as "a condition adverse to quality." The term " condition adverse to quality"is used to define conditions that negatively impact or potentially reduce quality and safety at Pilgrim Station. Walkdown crews performing inspections for USl A-46 were governed by the Pilgrim corrective action process for identification of conditions adverse to quality using Pilgrim Nuclear Power Station Procedure No.1.3.121, " Problem Report Program". The purpose of the Problem Report (PR) Program is to provide Nuclear Organization (NUORG) personnel a process to identify, assess and correct problems including degraded or nonconforming conditions, and to prevent their recurrence. The process ensures that each problem is evaluated commensurate with its significance to determine and implement appropriate corrective and preventive actions. Outlier conditions were not necessarily reported under the Pilgrim corrective action process unless they were also considered to be degraded or nonconforming as discussed in Enclosure B, Section 8 of our September 30,1996, submittal.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USl) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 2:
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 (GL) 87-02, dated May 22,1992, the following information is requested:
i
- a. Identify structure (s) which have in-structure response spectra (5% 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's (SOUG) Bounding Spectrum,
- 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 to evaluate the seismic adequacy for equipment installed on the corresponding floors in the structure (s) identified in item (a) above. If you have elected to use Method A in Table 4-1 of the GIP-2, provide a technicaljustification 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. The SSE ground motion 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 identified in the 120-day response to Supp'ement No.1 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 identified in item (a) above. Also, provide a comparison of these spectra to 1.5 times the Bounding Spectrum.
RESPONSE 2:
Pilgrim has used two different response spectra for seismic adequacy evaluations in the A-46 program. For equipment satisfying the caveats of GIP Method A, a scismic demand based on the Safe Shutdown Earthquake (SSE) horizontal ground response spectrum was used. The Method A caveats are (1) equipment is mounted below about 40 feet above the effective grade, and (2) equipment has a fundamental natural frequency (overall structural mode) greater than about 8 Hz. For equipment not satisfying these caveats, seismic demand was based on the in-structure response spectra submitted in the 120-day response to Supplement No.1 to GL 87-02.
The Method A caveat (1) above was initially applied by using the Pilgrim site ground grade, which is about plant EL 23 feet, as the effective grade for all structures housing safety related equipment. Thus, Method A was used for equipment mounted below about plar.t EL 63 feet, if caveat (2) was also satisfied (i.e., its fundamental natural frequency is greater than about 8 Hz). However, as a result of interactions between the staff and SQUG conceming the use of Page 2 of 33
l RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A Method A, a letter dated June 30,1997, was sent by Neil P. Smith, SQUG Chairman, to John F. Stolz, USNRC, Office of Reactor Regulation, on the subject " Generic issues included in NRC's Requests for AdditionalInformation on tne Use of GIP Method A". Enclosure 2 of the SQUG letter includes new recommendations to SQUG members to account for soil amplification of input motions if the plant licensing basis defines the SSE ground response spectrum below the top of the ground surface. Based on these recommendations, Pilgrim is modifying its approach to the use of Method A. This change affects our September 30,1996, submittal, and when complete, could result in the identification of additional outliers.
The original dynamic analyses performed by Bechtel for the Reactor Building, Turbine Building and Radwaste Building, applied the SSE grouna response spectrum at the respective foundation levels of these structures. This is consistent with FSAR Section 2.5.3.3.2 which defines the SSE and includes the statement " Horizontal ground acceleration at ertimated foundation depths (within the compact glacial deposits) due to the above earthquake would be about 0.15g". Since the foundations for these buildings were constructed on undisturbed glacial deposits, or on a nominallayer of select compacted fill placed over the undisturbed glacial depositt and since no lateral support of the structure was credited from the surrounding soil, these Bechtel analyses effectively treated their respective foundation levels as the free field ground surface.
Therefore, as a means to account for soil amplification as recommended by the referenced SQUG letter, we are re-defining the effective grade for each building that houses safety related equipment to be at the foundation level where the SSE ground response spectrum was applied in the original design. This modified approach means buildings will have different datums for comparisons related to the SQUG Bounding Spectrum:
Highest Floor for Effective, Grade, Effective Grade, Use of Method A, Buildina Initial Approach Modified Approach Modified Approach Reactor Building EL 23.0 feet EL (-) 17.5 feet EL 23.0 feet Turbine Building EL 23.0 feet EL 6.0 feet EL 37.0 feet Radwaste Building EL 23.0 feet EL (-) 1.0 feet EL 37.0 feet intake Structure EL 23.0 feet EL (-) 24 feet none Emerg. Diesel Bldg.
EL 23.0 feet EL 23 feet EL 49.75 feet Based on this modified approach to the application of Method A, the following responses are provided:
2 (a) Buildings having in-structure response spectra (5% critical damping) submitted in the 120-day response for e:evations within 40 feet above the effective grade that are higher in amplitude than 1.5 times the SQUG Bounding Spectrum:
Effective Grade, Highest Floor for Buildina Modified Approach Use of Method A I
Turbine Building EL 3.0 feet EL 37.0 feet Radwaste Builaing EL (-) 1.0 feet EL 37.0 feet Page 3 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION f
UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471) i ATTACHMENT A 2 (b) Method A.1 in Table 4-1 of GIP-2 was used to verify the seismic capacity for equipment installed on the floors in the structure (s) identified in item (a) if they satisfied the Method A caveats. If the equipment did not satisfy the Method A caveats, Method B was used.
The technical justification for this approach, in lieu of using Method B with the in-structure response spectra submitted in the 120-day response is as follows. Method A of GIP Table 4-1 provides a methodology to evaluate the seismic adequacy of equipment by comparing equipment capacity based on earthquake experience ground response spectra at database sites with the plant's SSE ground response spectrum (GRS). The composite earthquake experience GRS from the database sites (reference spectrum) is reduced by a factor of 1/1.5 to account for possible additional amplification of motion in nuclear plants compared to database plants and is referred to as the " Bounding Spectrum" in the GlP.
The seismic capacity of equipment defined by the Bounding Spectrum is compared to the seismic demand at the effective grade using the plant licensing basis SSE GRS. The GIP method conservatively limits the use of this approach to equipment which has natural frequencies above about 8 Hz and is located lower than about 40 feet above the effective grade for the building. These restrictions prohibit the use of GIP Method A for those equipment natural frequencies and for those higher elevations in buildings where equipment amplified responses are typically higher.
Additional details justifying the use of GIP Method A may be found in the report, "Use of Seismic Experience in Nuclear Power Plants", prepared by the Senior Seismic Review and Advisory Panel (SSRAP), February 28,1991. This report, included as Reference 5 in GIP-2, summarizes SSRAP's judgment on this subject by.et*ing on pages 102 and 103 that:
... the use of very conservative floor response spectra should be avoided when assessing the seismic ruggedness of floor mounted equipment.... Only for cases of equipment mounted more than 40 feet above grade or equipment with as-anchored-frequencies less than about 8 Hz is it necessary to use floor spectra.
Further justification for the use of GIP Method A has been fumished to the NRC in a letter dated January 26,1998, sent by Neil P. Smith, SQUG Chairman, to John F. Stolz, USNRC, Office of Reactor Regulation, on the subject "NRC Response to SQUG Letters on USl A-46 Generic RAls".
Important conclusions contained in this letter are the SQUG positions endorsed by Pilgrim as follows:
The submittal of in-structure response spectra in the 120-day response does not imply a commitment to use only these spectra exclusive of Method A.
The use of Method A is not precluded simply because calculated in-structure response spectra exceed 1.5 times the free field SSE GRS. Method A is intended for use on reinforced concrete l
frame and shear wall structures and heavily braced steel frame structures. This interpretation of i
the GIP is consistent with the previously referenced SSRAP Report (Reference 5 in GIP-2) and has been acently reaffirmed with the chairman of SSRAP, Dr. R. P. Kennedy.
2 (c) Plots of the in-structure response spectra (5% critical damping) submitted in the 120-day response, designated according to the height above the effective grade, for the Turbine and Page 4 of 33 i
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A Radwaste Building floors supporting SSEL equipment are provided as attachments (Attachment 8, Response Question 2) to this response. For equipment which did not meet the Method A caveats, these spectra were used to evaluate seismic adequacy, For equipment meeting the Method A caveats, the SSE GRS was used as the demand for capacity evaluations, and an in-structure response spectrum based on a factored SSE GRS was used as the demand for anchorage and relay evaluations. The unfactored SSE GRS, derived from FSAR Figure 2.5.6 showing the SSE GRS requirement, is plotted on the attachments. As requested,1.5 times the Bounding Spectrum is also plotted.
Attachments Pilgrim Turbine Building response spectra l
Pilgrim Radwaste Building response spectra I'
)
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 3:
On Page 4-1 of Section 4 of Enclosure B, you stated that "the SSEL contains a total of 1008 items, 1
and of this total,22 items are ' inherently rugged' or are part of the NSSS and do not require further
{
evaluation per GIP." List all equipment types that were considered ' inherently rugged'; provide information to demonstrate their seismic adequacy including their mountings.
RESPONSE 3:
Of the 22 items, the first 17 items are self-actuated check valves or manual valves which are inherently rugged and need not be evaluated for seismic adequacy including mounting per GIP-2, Section 3.3.5. The remaining 5 items are temperature elements mounted o.6 ine reactor vessel which as part of the NSSS do not require review to demonstrate saismic adequacy per GIP-2, Section 3.1.2.6. The items are listed below.
System Eauio Class EauloID Description Comment 03 N/A 305-115 CRD Charging Water Check Valve Rugged item 30 N/A 30-HO-114 RBCCW Suction Cross Tie Valve Rugged item 30 N/A 30-HO-115 RBCCW Suction Cross Tie Valve Rugged item 30 N/A 30-HO-192 RBCCW Discharge Cross Tie Valve Rugged item 30 N/A 30-HO-193 RBCCW Suction Cross Tie Valve Rugged item 54 N/A 31-CK-372A N2 Accumulator Check Valve Rugged item 54 N/A 31-CK-372B N2 Accumulator Check Valve Rugged item 54 N/A 31-CK-372C N2 Accumulator Check Valve Rugged item 54 N/A 31-CK-372D N2 Accumulator Check Valve Rugged item 54 N/A 6-CK-58A Feedwater Check Valve Rugged itera 54 N/A 6-CW.58B Feedwater Check Valve Rugged item 54 N/A 6-CK-62A Feedwater Check Valve Rugged item 54 N/A 6-CK-62B Feedwater Check Valve Rugged item 61 N/A 47-CK-101 A DG A Air Start Check Valve Rugged item 61 N/A 47-CK-101B DG B Air Start Check Valve Rugged item 61 N/A 47-CK-101C DG A Air Start Check Valve Rugged item 61 N/A 47-CK-101 D DG B Air Start Check Valve Rugged item 45 18 TE-261-40 RV Drain Line Temp NSSS item 45 18 TE-263-69-A2 RV Flange Temp NSSS item 45 18 TE-263-69-B2 RV Shell Temp NSSS item 45 18 TE-263-69-12 RV Bottom Head Drain NSSS item 45 18 TE-263-69-N1 RV Shell Temp NSSS item Page 6 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USl) A-46 i
PILGRIM NUCLEAR POWER STATION (TAC NO. M69471) i ATTACHMENT A l
l QUESTION 4:
In Section 4.1.3 of Enclosure B, you stated that " engineering judgment is an important element in the evaluation of equipment anchorage. As a general rule, all significant sized equipment was rigorously analyzed to determine anchor bolt forces. Small equipment (usually 50 lbs. or less), was accepted based on judgment if a comparison of an estimated anchor bolt force and the size and strength of the as-found anchorages indicated that sufficient anchorage strength existed." Discuss the criterion used to determine that equipment is considered as "significantly sized" and for which a rigorous analysis was performed to demonstrate its seismic adequacy.
Also, provide a sample calculation to demonstrate the seismic adequacy of small equipment anchorage.
RESPONSE 4:
Rigorous analysis generally involves the explicit calculation of anchor bolt loads using accepted computational methods, in support of a conclusion about the seismic adequacy of equipment anchorage. As an option, engineering judgment based on a review of the available facts developed from drawings, existing calculations and/ or walkdown information may be sufficient to permit the Seismic Capability Engineer's (SCE) to reach such a conclusion without further calculation. The critorion used to choose whether to perform explicit calculations or to apply engineering judgment was the GIP requirement that two independent SCE must agree on the approach selected. There was no definitive technical criterion used to determine the choice of approach. In order to reach agreement that engineering judgment is sufficient by itself as the basis for a conclusion, it is expected the conclusion be self evident based on the facts. The approach and bases for seismic adequacy conclusions are appropriately documented in cach of the Screening Evaluation Work Sheet (SEWS).
The s ze of the equipment is one of several factors the SCE considers when making a decision on f.ne level of detail required to support a conclusion on arichorage adequacy. As an example of this process for "small equipment", consider a wall mounted distribution panel in Equipment Class #14:
Distribution panels range in size from 20 to 40 inches in width and height, and 6 to 12 inches in depth, and have a weight range from 30 to 200 pounds.
They are typically anchored to a wall with four bolts, one at each comer, and thus have minimal eccentricity with respect to the center of gravity and centroid of the anchorage pattern.
Anchor bolts are generally 3/8" diameter minimum, with Unistrut fasteners and/or concrete expansion anchors. Assuming the lower strength concrete expansion anchors, the allowable capacities are 1460 pounds tension and 1420 pounds shear (GIP Table C.2-1).
Because of panel construction and minimal eccentricity in a wall mounted configuration, i
they generally have fundamental frequencies above 8 bz.
I Pilgrim SSE maximum spectral accelerations at 5% damping at about 8 hz or higher are:
Radwaste Building, Control Room @ EL 37 ft.,0.82g @ 9hz to 14hz, Turbine Building, Upper Switchgear Room @ EL 37 ft.,1.7g @ 6.9 to 8.1hz.
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l RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A Since the tension or shear capacity of a sinale 3/8" diameter concrete expansion anchor is seven times greater than the weight of a 200 pound panel, and because there are four anchors supporting a panel, it is apparent without an explicit calculation that the anchorage will be more than adequate for these typical applicable spectra accelerations. Based on these facts, SCEs may use engineering judgment to conclude that the anchorage is seismically adequate. However,if the walkdown inspections revealed defective anchors, conditions warranting multiple capacity reduction factors to be applied to the anchor allowable capacities, or other unusual circumstances, a conclusion of anchorage seismic adequacy based on judgment alone may be less obvious. In such a case the SCEs may judge that rigorous analyses are warranted to precisely determine the minimum available design margin.
1 l
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 5:
In Section 4.3, you indicated that all Seismic Capability Engineers (SCE) have been SQUG trained and certified and their resumes are provided in Appendix C. However, no SQUG training qualification was mentioned in any one of the resumes in Appendix C. Provide the evidence or certification of the SQUG training qualification for all SCEs involved in the A-46 program at Pilgrim.
RESPONSE 5:
The Seismic Capability Engineers (SCEs), whose resumes are provided in Appendix C of Enclosure B of our September 30,1996, submittal, are those individuals who performed equipment walkdowns and evaluations for the certified Screening Verification Data Sheets (SVDS) contained in Appendix D of Enclosure B. SQUG qualifications are mentioned in most of these resumes, either under the heading " Specialties / Expertise" for Pilgrim personnel, or within the description of " Professional Experience" for Stevenson & Associates personnel.
Additional SCEs participated in parts of the A-46 program other than the SVDS certifications, and their resumes were not included in Appendix C.
To provide the requested evidence of training qualification for all SCEs involved in th2. A-46 program, a memorandum is attached (Attachment 8, Response Question 5) from the SQUG Training Coordinator, dated February 13,1998, confirming the following individuals have completed the required "SQUG Walkdown Screening and Seismic Evaluation Training Course" and have been certified as Seismic Capability Engineers:
Pilorim SCEs Stevenson & Associates SCEs Charles Pitts Walter Djordjevic John G. Dyckman Thomas J. Tracy Subhash C. Chugh John J. O'Sullivan Jeffrey A. Kalb Viktor Zukauskas*
David Rydman*
William R. Kline l
- Note: Resume not included in Apoendix C of Enclosure B of our September 30,1996, submittal.
Attachment SQUG Memorandum, dated February 13,1998 I
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UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471) l l
ATTACHMtiNT A
]
QUESTION 6:
In Table 5-1 of Enclosure B regarding the comments for meeting the intent of the caveats, bounding spectra have been identified. It is unclear how individual equipment in the table did not meet the caveats described in Appendix B of the GIP-2, but was considered to meet the intent of the caveats. Provide a detailed description of how the equipment did not meet the GIP caveats, for each item in Table 5-1. As an example, provide the basis for judging that equip.aent items VAC205A-1 and VAC205D-1 have met the intent of the caveats with respect to their seismic adequacy.
RESPONSE 6:
The caveat not met, why the caveat was not met and the basis for concluding that the intent of that caveat is met is given in the table that follows.
EQUIPMENT Class Wh CaveatIntentis Description of GIP Caveat Not Met et Why Caveat is not met B10 B14, 1
MCC/BS Caveat 1 - Earthauake inclusion in the B15,B17, Experience Eauipment Class. The MCC experience database B18,B20 should be similar to and bounded by the requires bracing for MCC class of equipment described in the MCC's narrower than GIP. The description states that MCCs 18". These MCC's were narrower than 18" deep should be top seismically tested to braced or attached to the wall.
criteria which predates IEEE 344-75. The seismic test has been reviewed and found to These MCC's are 15" deep and do not have be as severe as an structural top bracing.
IEEE 344-75 test thus meeting the intent of this caveat.
1 P205,X203 5
HP/BS Caveat 2 - Driver and Pumo on Since the pump and Riaid Skid. The driver and pump should be turbine skids are 1
connected by a rigid base or common skid.
supported on a common The concem is that differential concrete pedestal, there displacement between the pump and the is no potential for driver may cause shaft misalignment.
differential movement between pump and driver. Therefore, the intent of this caveat is The pump (P205) and turbine (X203) are met.
on different skids supported on a common concrete pedestal.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A EQUIPMENT Class ID Description of GIP Caveat Not Met Why Caveat intent is Met Why Caveat is not met AO1301-12, 7
FOV/BS Caveat 7 - Actuator and Yoke not The yoke and valve AO1301-34 Independently Braced. The valve actuator body are both and yoke should not be independently supported from the braced to the structure or supported by the same structure. As a structure unless the pipe is also braced to result there is no the same structure immediately adjacent to independent bracing the valve. The concern is that if the and the intent of the operator is independently supported from caveatis met. The the valve and attached piping, then the yoke cannot act as a operator may act as a pipe support during pipe support during seismic motion and attract considerable seismic motion and load through the yoke and possibly fail the attract considerable yoke or bind the shaft.
load.
The yoke and valve body are supported and the supports may be independent.
PSV4020 7
FOV/BS Caveat 4 - Mounted on 1 Inch The pipe diameter for all PSV4563A Diameter Pipe Line or Greater. The valve of these relief valves is PSV4563B should be mounted on at least a pipe of 1 3/4" which is less than PSV4563C inch diameter. This is the lower bound pipe the minimum 1" PSV4565A size supporting FOVs in the earthquake diameter required by PSV4565B experience equipment class. The concem the caveat. All of these PSV4582A is that valves with heavy operators on small valves are lightweight PSV4582B lines may cause an overstress condition in integral units (do not PSV4582C the adjacent piping. There is no concern it have a separate PSV4582D the valve, the operator, and the line (if operator connected by RV9085A smaller than 1 inch) are well supported and a yoke). The SRT RV9085B anchored to the same support structure, judged them seismically RV9085C acceptable with a 3/4" RV9085D pipe diameter. The RV9085E PSV series valves RV9085F The pipe diameter is less than 1" weigh less than 10 lb.
RV9085G and the RV senes RV9085H weigh 2.5 lb. There is no concern for the valve or the line based on the small weight of the valves.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A EQUIPMENT Class ID Description of GIP Caveat Not Met Why Caveat Intent is Met Why Caveat is not met MO1001-8 MOV/BS Caveat 5 - Valve Operator The operator weight 36A Cantilever Lenath for Motor-Operated and operator cantilever MO1001-Valves. The distance from the centerline of length meet the intent of 36B the pipe to the top of the operator or the caveat using the MO1201-5 cylinder and the weight of the operator methodology of GlP MO1301-49 should not exceed the values given in Rev 2A, editorially Table B.8-1 corresponding to the diameter omitted from GIP Rev 2 of the pipe.
which allows the operator weight or length to exceed the Figure B.8-1 limit by up These motor operated valves exceed the to 30% provided that operator weight limit of Figure B.8-1.
the product of the weight times the length does not exceed the limits of Figure B.8-1.
As a result, the intent of the caveat is met.
MO3800 8
MOV/BS Caveat 3 - Valve Yoke Not of if the yoke stre:ts is low MO3801 Cast iron. The yoke of the motor-operated
( for example, less than MO3805 valve should not be made of cast iron. If a 20% of the specified MO3806 yoke is cast iron this caveat may be minimum ultimate MO3808 satisfied by performing a 3g stress analysis strength), then the i
MO3813 of the yoke in its weakest direction, intent of the caveat is MO4083 met. A stress analysis MO4084 of the yokes determined that the stresses all fall These motor operated valves have cast iron below 20% of the valve actuator support brackets.
minimum ultimate strength. Therefore, the intent of the caveat is met.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A EQUIPMENT Class Description of GlP Caveat Not Met Why Caveat Intent is ID Met Why Caveat is not met VAC205A-1 10 AH/BS Caveat 5 - Base Vibration Isolation The ductis so well VAG205D-1 System Checked, If the unit is mounted on supported that the SRT vibration isolators, the adequacy of the judged that the fan will vibration isolators for seismic loads should not displace. Therefore, be evaluated in accordance with Section the vibration isolators 4.4. VAC205A-1 and VAC205D-1 are are judged to meet the installed in line.
intent of the caveat.
Vibration isolators that are under the supports are unhoused and unconfined.
D16,D17 14 DP/BS Caveat 1 - Earthauake Experience D16 and D17 contain Eauipment Class. The distribution panels relays, but all of the should be similar to and bounded by the DP relays have been class of equipment described in the GIP.
evaluated as non-The Distribution Panel equipment class essential. As a result, includes the circuit breakers, fusible the relays do not have switches, metering components, to be seismically switchboard / panelboard enclosure and verified per GIP rules.
intemals and attached conduit. Relays are D16 and D17 therefore not included in this class of equipment.
meet the intent of the caveat.
i D16 and D17 contain relays.
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ATTACHMENT A EQUIPMENT Class Description of GIP Caveat Not Met Why Caveat Intent is ID Met i
Why Caveat is not met MO202-5A 8
MOV/BS Caveat 5 - Valve Operator The intent of the caveat MO202-5B Cantilever Lenoth for Motor-Operated is rnet based on vendor Valves. The distance from the centerline of qualification which the pipe to the top of the operator or demonstrates the cylinder and the weight of the operator structuralintegrity of the should not exceed the values given in valve and its parts for Table B.8-1 corresponding to the diameter the seismic plus rated of the pipe.
load condition.
i The operator weight, the distance from the centerline of the pipe to the top of the operator and the pipe diameter exceed the limits of Table B.8.1.
MO2301-4 8
MOV/BS Caveat 5 - Valve Operator The intent of the caveat Cantilever Lenoth for Motor-Operated is met based on vendor Valves. The distance from the centerline of qualification which the pipe to the top of the operator or demonstrates the cylinder and the weight of the operator structuralintegrity of the should not exceed the values given in valve and its pads for i
Table B.8-1 corresponding to the diameter th9 seismic plus rated of the pipe.
load condition.
The motor operator weight exceeds the weight limit of Figure B.8-1.
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ATTACHMENT A QUESTION 7:
In reference to Table 5-1, for Motor Operated Valves (MOV's) MO3800, MO3801, MO3805, MO3806, MO3808, MO3813, MO4083 and MO4084, the valve actuator support brackets are made of cast iron. Provide an example of a calculation, including the maximum calculated stress and the allowable stress limits to demonstrate the seismic adequacy of these MOVs.
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RESPONSE 7:
The requested example calculation is summarized below and a copy is included with the attached MO 3801 Screening Evaluation Worksheet (SEWS) (Attachment B, Response Question #7).
MO 3801 per attached SEWS: Maximum calculated bending stress in the valve yoke = 2.19 ksi, Yoke materialis ASTM A-48, Class 40 cast iron, minimum ultimate strength =40 ksi.
20% of ultimate strength = 0.2 x 40 ksi = 8.0 ksi.
20% of ultimate strength is much greater than the calculated bending stress, i.e.,8.0 ksi n 2.19 ksi.
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Therefore, the intent of GlP-2, MOV/BS Caveat 3 is satisfied and the seismic adequacy of the valve is demonstrated.
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l Attachment MO 3801 SEWS, plus calculation i
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ATTACHMENT A l
QUESTION 8:
In reference to Table 6-1, " Tanks and Heat Exchangers Evaluation Results,"it is not clear how you resolved a total of 14 outliers by " component-specific evaluation." Provide the methodology, the analysis and/or modification in detail regarding the resolution of outliers for heat exchangers E122A&B, E206A&B, E207A&B, E209A&B and E216A&B, and Tanks T126A&B and T151A&B.
RESPONSE 8:
Tanks and heat exchangers were initially screened by using the methodology contained in Section 7 f
of the GlP. It was not always possible to confirm seismic adequacy using the GIP approach. In some instances the equipment characteristics fell outside the parameters of Table 7 - 6 to which the heat exchanger screening methodology applies. In other cases the equipment could not meet the very conservative seismic demand screening provisions of that methodology. For example, if the heat exchanger dynamic response cannot be demonstrated to be rigid (i.e. > 30 Hz) in three orthogonal directions, GIP 7.4.2, Step 10 conservatively requires the seismic demand be based on the peak of the floor spectra.
For tanks and heat exchangers that are not covered by the GIP parameters or do not pass the screening guidelines, the GIP requires the components to be classified as outliers. As discussed in Section 7.2 of the GIP, component-specific evaluations are then permitted to reach a conclusion about seismic adequacy using the approach described in EPRI NP-5228-SL, Rev.1, Vol. 4, entitled,
- Guidelines for Tanks and Heat Exchangers".
Evaluations of heat exchanger outliers were performed using the applicable portions of the procedures and methodologies described in Section 7.4 of the GlP, and in Section 3 of EPRI NP-5228-SL, Rev.1, Vol. 4, as guidance. Typical evaluations considered the dynamic characteristics of the component and its support structure in each orthogonal direction. Seismic demand was based on frequency dependent spectral accelerations using the Pilgrim design basis in-structure response spectra submitted in the 120-day response to GL 87-02. The effect of nozzle loadings from attached piping was also considered. Stresses were evaluated in the load path from the heat exchanger shell, through its integral supports, to the associated anchor bolts and support structures.
The results of outlier evaluations demonstrated component seismic adequacy to GIP requirements and are considered to be resolved in all cases except two, as discussed below. A description of each component, the associated outlier condition (s) and the outcome of the outlier resolution evaluation follows:
E122A&B The Turbine Building Closed Cooling Water (TBCCW) Heat Exchangers, located in the basement of the Reactor Building Auxiliary Day at EL 3 feet, are nominally 3 foot diameter by 28 foot long vessels weighing approximately 29,000 pounds each, oriented horizontally, and mounted on steel saddles and concrete piers at each end. The outlier condition is the seismic demand, conservatively based on the spectral peak acceleration per the GIP screening methodology, exceeds l
the anchorage capacity. This outlier was addressed by performing calculations to verify seismic
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adequacy using the previously described procedures and methodologies, and in-structure response j
spectra provided in ou.- 120-day response to GL 87-02. The component specific evaluation is contained in BECo Calculation C15.0.3268, Rev. O. Based on a subsequent review, performed as a Page 16 of 33 1
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ATTACHMENT A result of collecting information to respond to this RAI question, we have concluded the evaluation did not meet UFSAR seismic damping requirements. Therefore this outlier is no longer considered to be resolved, and appropriate actions are being undertaken in accordance with the Pilgrim Station corrective action process (PR 98.9097) to resolve the outlier conditions We have also reported this condition in accordance with 10CFR50.73 (Reference LER 98-003-00, dated March 23,1998).
E206A&B The Fuel Pool Cooling Heat Exchangers, located at EL 74.25 foot in the Reactor Building, i
are nominally 1 foot diameter by 23.5 foot long vessels weighing approximately 4,400 pounds each, oriented horizontally, and mounted one above the other, on steel saddles with separate support pier structures at each end. The outlier condition is the seismic demand, conservatively based on the i
spectral peak acceleration per the GlP screening methodology, exceeds the anchorage capacity. This outlier was resolved by performing calculations to verify seismic adequacy using the previously described procedures and methodologies and in-structure response spectra provided in our 120-day response to GL 87-02. The component specific evaluation is contained in BECo Calculation C15.0.3270, Rev. O.
E207A&B The Residual Heat Removal (RHR) Heat Exchangers, located in the Reactor Building RHR quadrants at EL 10 foot, are nominally 3.75 foot diameter by 25 foot long vessels weighing approximately 40,000 pounds each, oriented vertically, and mounted on heavy steel framing. The outlier condition is the GIP screening methodology is not applicable to a vertical heat exchanger configuration. This outlier was resolved by performing calculations to verify seismic adequacy using the previously described procedures and methodologies, and in-structure response spectra provided in our 120-day response to GL 87-02. The component specific evaluation is contained in BECo Calculation C15.0.3273, Rev. O.
E209A&B The Reactor Building Closed Cooling Water (RBCCW) Heat Exchangers, located in the basement of the Reactor Building Auxiliary Bay at EL 3 feet, are nominally 4.25 foot diameter by 28 foot long vessels weighing approximately 67,000 pounds each, oriented horizontally, and mounted on steel saddles and concrete piers at each end. The outlier condition is the seismic demand, conservatively based on the spectral peak acceleration per the GIP screening methodology, exceeds the anchorage capacity. Additionally, there were baseplate anomalies determined to constitute degraded conditions which were entered into the Pilgrim corrective action process (PR 95.9027).
These outliers were addressed by performing calculations to verify seismic adequacy using the previously described procedures and methodologies and in-structure response spectra provided in our 120-day response to GL 87-02 Modifications were installed to correct the baseplate anomalies and enhance the anchorage capacity. The component specific evaluation is contained in BECo Calculation C15.0.3266, Rev.1. The anchorage modification details are contained in Field Revision Notice (FRN) design change document, FRN 95-01-60. Based on a subsequent review performed as a result of collecting information to respond to this RAI question, we have concluded the evaluation did not meet UFSAR seismic damping requirements. Therefore this outlier is no longer considered to be resolved, and appropriate actions are being undertaken in accordance with the Pilgrim Station corrective action process (PR 98.9097) to resolve the outlier conditions. We have also reported this condition in accordance with 10CFR50.73 (Reference LER 98-003-00, dated March 23,1998).
E216A&B The Non-Regenerative Heat Exchangers, located in the Reactor Building at EL 51 foot, are nominally 1 foot diameter by 27 foot long vessels weighing approximately 4,675 pounds each, Page 17 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A oriented horizontally, and mounted one above the other, on steel saddles and frame structures, on common concrete piers at each end. The outlier condition is the GIP screening methodology is not j
applicable to this heat exchanger configuration. This outlier was resolved by performing calculations
(
to verify seismic adequacy using the previously described procedures and methodologies, and in-structure response spectra provided in our 120-day response to GL 87-02. The component soecific evaluation la contained in BECo Calculation C15.0.2853, Rev. 2.
i T126A&B The Main Storage Tanks for Emergency Diesel Generator (EDG) fuel oil, located in the yard area just north of the EDG Building, are nominally 10.5 foot diameter by 38.5 foot long vessels, oriented horizontally and buried approximately 4 feet below grade to the top of the tank. The outlief
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condition is the GIP screening methodology is not applicable to buried tanks. This outlier was resolved by an evaluation of the original Bechtel design and associated calculations and by revw of the piping and conduit connection details for susceptibility to relative motions associated with support points. The component specific evaluation is described in the text of the SEWS T126A, Rev.1, and T1268, Rev.1.
T151 A&B The Diesel Generator Turbo Air Receiver Tanks, located in the Emergency Diesel Generator Building at EL 23 foot, are nominally 4 foot diameter by 10 foot long vessels weighing approximately 4,000 pounds, oriented horizontally, and mounted on steel saddles and concrete piers at each end. The outlier condition is the GIP screening methodology is not applicable to this heat exchanger configuration because of the extent of the tank overhang beyond the saddles and because of the density value associated with the air storage function which is below the minimum GIP value for I
this parameter. This outlier was resolved by performing calculations to verify seismic adequacy using the previously described procedures and methodologies, and in-structure response spectra provided in our 120-day response to GL 87-02. The component specific evaluation is contained in SEWS T151A, Rev. O, and T151B, Rev.0.
Examples of outlier resolution documentation are provided as attachments to this response as follows:
Component item Documentation i
E206A&B Fuel Pool Cooling HEs BECo Calc. C15.0.3270, Rev. 0 E207A&B RHR Heat Exchangers BECo Calc. C15.0.3273, Rev. O T151A EDG A Turbo Air Receiver Tanks BECo SEWS T151A, Rev. O BECo OSVS T151 A, Rev. O T151B EDG B Turbo Air Receiver Tanks BECo SEWS T1518, Rev.0 BECo OSVS T1518, Rev.0 l
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 9:
Section 6.2 of Enclosure C of the reference letter states that 110 relays out of a total of 622 3
essential relays are classified as " outlier relays". All outlier relays at Pilgrim Station are listed in j of the Enclosure. The safety implications arising from malfunction of outlier i
relays are provided in Attachment 3. The licensee indicated that at the time of the June 13, 1996 submittal to the NRC, there were no " Unresolved" outlier relays.
Regarding the resolution of outlier relays, very high reliance has been placed on operators' ability for recovery of many.;ismically vulnerable items within a short period of time. For i
instance, the following examples are cited.
1 For 4160V Breakers A504 and A604, I
".. operator action would be required to manually reset the lockout relay."
For4160V Breakers A509 and A609, I
".. operator action to restart the Diesel Generator is available should relays fail."
l For 480V Breakers B601, B602,102,202,310,410 in Drywell Cooling Fans VAC205A-1, l
VAC205B-1,...etc.,
" operator action to restart the dryweil cooling fans may be required should these relays fail."
Any one or a few of these operations may easily be performed; however, it is questionable whether all of the cited operator actions can be performed reliably within the short period of time available 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 information 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.
RESPONSE 9:
As a minor point of correction, the Pilgrim A-46 submittalis dated September 30,1996, not June 13,1996.
The statement in Attachment 3 of Enclosure C indicating there are no " unresolved" outlier relays at the time of the report can be confusing if not retained within the perspective of other clarifying information included before and after the statement in question. Taken together the sentences read:
..When an outlier cannot be resolved using this guidance, it is considered an
" unresolved outlier".
At the time of this report, there are no " unresolved " outlier relays. There are outliers for which the GIP resolution process has yet to be completed.
It was not intended to suggest that no further actions would be taken, only that the relays were expected to be resolved via the GIP guidance.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A I of Enclosure C of our September 30,1996, submittal describes the " concerns" associated with various categories of outlier relays and the expected resolution. It also includes the basis for why an operability concem does not exist for each category of relay and the anticipated resolution path in accordance with GIP.
It is recognized that failure of all outlier relays simultaneously would burden Operations; however, none of the relays in the safe shutdown paths are fragile and Operator action would be available. Although we did consider crew size, equipment accessibility, complexity of action, and that sufficient time was available to accomplish necessary actions, Pilgrim does not intend to rely on operators conducting multiple tasks under adverse conditions. Rather it is our intent to verify seismic adequacy of the outlier relays, and operator action is credited only while final resolution proceeds. Our goal in the A-46 issue is to use the GIP process to provide
. safe shutdown paths with no operator action required beyond normal plant shutdown activities.
The interim assumption that all outlier relays fail would result in an event previously considered; Station Blackout. PNPS procedures exist to address station blackout conditions.
No additional diagnostic / corrective operator actions are required, and although a number of breakers are identified, the logic is such that only a small number would need to be operated depending upon availability of power sources and performed sequentially, not concurrently.
The following addresses the three examples included in the RAl:
The A504, A604, A509, and A609 breakers might need their overload relay reset, they are in close proximity to the Control Room, have emergency lighting, and only one of the four breakers is needed, again not immediately but rather in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Procedures and training exist providing instructions to the operators for manually closing 4160 breakers locally.
The Drywell cooling fans would be desired within one hour to prevent complicating the scenario. This operator action is the designed / expected and previously experienced plant response to the normalload shedding feature of the EDGs. The controls are adjacent to the ground level entrance of the Reactor Building and have emergency lighting available. These actions would be performed as described in PNPS Procedure No. 2.4.44, " Loss of Drywell Area Coolers".
Breakers B310 and B410 would not be needed unless offsite power was lost and not until cold shutdown condition was achieved.
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ATTACHMENT A QUESTION 10:
The NRC staff has concems about the way the USl A-46 cable trays and conduit raceways issue is being disposed of by some USI A-46 licensees. The staff issued RAl's to several licensees on this issue. SQUG responded instead of the licensees because SQUG considered the RAl's to be generic in nature. The staff issued a subsequent RAI to SQUG as a follow-up to their response. However, the staff found that the correspondence with SQUG did not achieve the intended results in that it did not address the identified technical concems of the staff. Therefore, we are requesting your response to the items stated below.
The GIP procedure recommended performing what is called "a limited analytic evaluation" for selected cable and conduit raceway supports. The procedure further recommended that when a certain cable tray system can be judged to be ductile and the vertical load capacity of the j
anchorage can be established by a load check using three times the dead weight, no further
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evaluation is needed to demonstrate lateral resistance to vibration from earthquakes. The staff I
has concems with the manner in which these simplified GlP criteria were implemented at your plant.
The GIP procedure eliminates horizontal force evaluations by invoking ductility. However, some so-called non-ductile cable tray support systems would eventually become ductile by inelastic deformation, buckling or failure of the non-ductile cable tray supports and members.
This procedure is a basic departure from conventional methods of engineering evaluation and the GIP does not provide an adequate basis for dealing with those cable trays that are initially judged to be non-ductile but are eventually called ductile by postulating failure of the lateral supports. If this procedure was followed for eliminating cable trays from further assessment at i
your plant, then all the cable trays could conceivably be screened out from the A-46 evaluation. We request that you provide the following information to enable our assessment and safety evaluation of cable trays at your plant.
QUESTION 10A:
Define ductility in engineering terms as used at Pilgrim for the USl A-46 evaluation. Clarify how this definition is consistently applied to actual system configurations at Pilgrim Station for the purpose of analytical evaluation.
RESPONSE 10A:
Ductility as it applies to cable raceway supports is defined in the first paragraph of Section 11.8.3.3 of the GlP as follows:
"An evaluation should be conducted of the supports selected for review to characterize their response to lateral seismic motion as either ductile or potentially non-ductile. Supports suspended only from overhead may be characterized as ductile if they can respond to lateral seismic motion by swinging freely without degradation of primary vertical support connections and anchorage. Ductile, inelastic performance such as clip angle yielding or vertical support member yielding is acceptable so long as deformation does not lead to brittle or premature failure of overhead vertical support."
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A The concept of ductility is consistently applied to cable raceway supports at Pilgrim Station for the purpose of analytical evaluation by the use of the Ductility Check (GlP Section 11.8.3.3). Each of the worst case samples of raceway supports selected for the GIP Limited Analytical Review (LAR) were evaluated using this procedure to determine whether they are ductile or non-ductile. This methodology coupled with field inspection to the inclusion rules (GlP Section l1.8.2.2) and to the requirements for other seismic performance concems (GlP Section 11.8.2.3) ensure that only ductile supports are credited with ductile behavior.
QUESTION 10B:
Provide the total number of raceways that were selected for worst-case analytical calculations and were classified as ductile in your A-46 evaluation and for which you did not perform a horizontalload evaluation. Indicate the approximate percentage of such raceways as compared with the population selected for analytical review. Discuss how the ductility concept is used in your walkdown procedures.
RESPONSE 108:
11 Limited Analytical Review (LAR) raceways were classified as ductile from a total of 25 LAR raceways. The approximate percentage of ductile without lateral load evaluation LARs to the total number of LARs is 44%. The ductility concept used during the walkdowns conformed to GIP section 8.3.3, Ductility Check. This information is contained in the September 30,1996, submittal in Appendix F, Results of Cable Tray and Conduit Review.
QUESTION 10C:
Describe the typical configurations of your ductile raceways (dimension, member size, supports, etc.).
I RESPONSE 10C.
Please refer to the September 30,1996, submittal Appendix F, Results of Cable Tray and Conduit Review, Section 2.2, General Description of Pilgrim Raceways. Additionally, selected Plant Area Summary Sheets (PASS) containing detr.;ied sketches with dimensions and member sizes for LARs 6,7,8,9,12,13,15, and 23 are included in Attachment B, Response Question 10.
QUESTION 10D:
)
Justify the position that ductile raceways need not be evaluated for a horizontalload. When a reference is provided, state the page number and paragraph. The reference should be self-contained, and not refer to another reference.
RESPONSE 10D:
Since the issuance of this RAI to Pilgrim, SQUG has responded to this question on a generic basis; therefore, we refer our response to SQUG letter dated January 22,1998, from Mr. Neil P. Smith, to Mr. John F. Stolz entitled, " Suggested Responses to NRC RAls on Cable and Conduit Raceway Systems", Enclosure 1, NRC RAI Question Part 3.
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PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 10E:
In the evaluation of the cable trays and raceways, if the ductility of the attachments is assumed in one horizontal direction, does it necessarily follow that the same system is ductile in the perpendicular direction? If yes, provide the basis of this conclusion. If it is not ductile in the perpendicular direction, how was the seismic adequacy of the attachments evaluated?
RESPONSE 10E:
Pilgrim has followed the GIP in evaluation of cable raceway supports. An explanation of the GIP approach as it relates to both lateral ductility and the consideration of longitudinal loads in the evaluation of cable raceway systems is given in SQUG's generic response letter dated January 22, 1998, from Mr. Neil P. Smith, to Mr. John F. Stolz entitled, " Suggested Responses to NRC RA:s on Cable and Conduit Raceway Systems", Enclosure 1, NRC RAI Question Part 4.
QUESTION 10F:
Discuss any raceways and cable trays including supports in your plant that are outside of the experience data. Explain what criteria are used for establishing their safety adequacy and specify your plan for resolution of outliers that did not meet the acceptance criteria. Provide examples of the configurations of such raceways and cable trays including supports. Also, indicate the percentage of cable trays arJ.' raceways outside the experience data in relation to the population of raceways cod cable trays examined during the walkdowns of the safe shutdown path. Discuss how they will be evaluated and disposed.
RESPONSE 10F:
Please refer to the September 30,1996, submittal Appendix F, Results of Cable Tray and Conduit Review, Section 5.0, Conclusions, which states that with the exception of one potential seismic interaction, all power block electrical raceway are in full conformance with GIP requirements.
The raceways and cable trays review at Pilgrim Station consisted of all conduit and cable trays at all elevations of the power block buildings and was not limited to raceways and cable trays necessary to support a specific safe shutdown pathway. Area reviews were conducted in eighty specific areas cf the plant to support the effort. With the exception of one potential seismic interaction in the Machine Shop, all raceways and cable trays are within the experience data.
i The single exception in the Machine Shop area of the Radwaste Building at Elevation 23' relates to a potential seismic interaction of an unanchored water heater tank with a wall l
mounted conduit below. This outlier is not safety significant because a subsequent walkdown has determined that the conduit in question is non-safety related.
QUESTION 10G:
Submit the evaluation and analysis results for four of the representative sample raceways (one single non-ductile, one single ductile, one multiple non-ductile, and one multiple ductile raceway), including the configurations (dimension, member size, supports, etc.).
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ATTACHMENT A RESPONSE 10G:
Ductile support configuration calculations LAR 005 and LAR 017 are included (Attachment B, Response Question 10) for your review. Non-ductile support configuration calculations LAR 016 and LAR 024 are included for your review.
Attachments PASS ID AUXBAYGROUND Location: Aux Bay-Ground level El 23'-0" (with LAR 015 & 023 sketches)
PASS ID RWTBCORR Location: Radwaste/ Turbine Bldg - Corridor El 23'-0" (with LAR 012 & 013 sketches)
PASS ID MGSETCTCON Location: MG Set Room El 23'-0" (with LAR 008 & 009 sketches)
PASS ID UPSWGRCT Location: Upper Switchgear Room Cable Tray El 37'-0" (with LAR 006 & 007 sketches)
Calculation for LAR 005 Location: Turbine Bldg El 37'-0" Calculation for LAR 017 Location: Reactor Bldg El 23'-0" Calculation for LAR 016 Location: Reactor Bldg El 23'-0" Calculation for LAR 024 Location: Aux Bay Bldg El 3'-0" Page 24 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 11:
In Enclosure B of your letter, the screening verification results by equipment class, including the total number of screening items, the number of outlier items and the number of acceptable items, are provided in Table 4-1. A total of 183 outliers including one conduit and cable tray outlier were encountered. All outliers divided into 67 groups are provided in Section 8.2. The status of outliers and their safety implications are also provided. For all open outlier items, the proposed resolutions are provided in Section 9. You are requested to elaborate on your decision to defer the implementation of certain identified outliers and your evaluation in support of the conclusion that the design basis for the affected components systems will not be affected by your decision.
RESPONSE 11:
Tables 9.1 and 9.2 summarize the open equipment outliers at the time of submittal of the Seismic Evaluation Report. There are 145 outlier items contained in these tables. As of January 28,1998,40 outliers are resolved and an additional 8 involving field work are issued for construction. Of the 145 outlier items at the time of submittal of the Seismic Evaluation Report,97 items remain to be resolved.
Resolution of the remaining open outliers is scheduled for completion by RFO#12 in accordance with the Seismic Evaluation Report submittal. This schedule was chosen as a workable period of time based on Pilgrim's initial understanding of the total effort required to resolve the outliers. Pilgrim's evaluation in support of the conclusion that the design basis for the affected componenUsystem is not affected is included in Section 8.0 of the Seismic Evaluation Report.
Section 8.0 of the Seismic Evaluation Report states in part, "An outher is an item of equipment which does not comply with all of the screening guidelines provided in the GIP. The GIP guidelines are intended to be used as a generic basis for a preliminary screening evaluation of the seismic adequacy of equipment. If an item of equipment fails to pass these generic screens, it may still be shown to be adequate by additional evaluations. Most outlier conditions are minor items which were not considered to be nonconforming or degraded and did not present a concern for equipment operability.... "
"As part of the SEWS review process, Boston Edison used pertinent design basis information along with engineering judgment to determine if any outlier condition could be considered nonconforming or degraded, or otherwise warranting further review to confirm equipment operability. In a few instances, outlier conditions were identified that were nonconforming or degraded, and a corrective action process document known as a Problem Report was initiated to cause the appropriate steps to be taken to conform to regulatory requirements. Outliers O23,056 and 058 are examples of this situation.
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ATTACHMENT A The decision on why the design basis for the affected component / system will not be affected by the outlier finding was made on a case by case basis. Elaboration on example outliers follows to illustrate the approach used to conclude that the component / system design is unaffected.
i Outlier O1, from Seismic Evaluation Report, Section 8.2:
Equipment ID: T214A & T214B Outlier Finding (s): RBCCW shielded sample chambers T214A & T214B are Class 0 items.
As a result, their capacity cannot be established by the GIP. In addition they are anchored by I
friction clips which are not a recognized form of anchorage according to the elP.
Safety implications: No. The existing anchorage is substantial. Capacity will be established by additional evaluation and is expected to be adequate.
Outlier Status: Open Outlier 01 Elaboration:
These two pieces of equipment are liquid radiation process monitors for the Reactor Building Component Cooling Water (RBCCW) system. These process monitors are classified as SSEL equipment and are included to assure integrity of the RBCCW pressure boundary.
Each piece of equipment consists of a 10" diameter by 28" high cylindrical radiation shield housing a liquid well and a radiation process monitor. The radiation shie!d is mounted to a reinforced bent steel plate base which is anchored to a concrete floor with four 1/2" diameter concrete expansion anchors. Based on these facts and the walkdown, the SRT concluded that this is a very rugged piece of equipment and they did not have concem about the seismic adequacy, the anchorage, or the ability of the component or system to perform its required design function. The equipment is an outlier because the anchorage is unconventional in that it uses friction to resist load.
Outlier 06, from Seismic Evaluation Report, Section 8.2:
Equipment ID: MCC's B17, B20, D7 and D10 Outlier Finding (s): MCC's have spatialinteractions with the MCC enclosures.
Safety implications: No. The spatial interaction will not result in damage to the MCC's. The interaction will be addressed during the outlier resolution phase.
Outlier Status: Open Outlier 06 Elaboration:
The MCCs were classified as outliers because of the spatial interaction involving the possibility of relay chatter, however the spatialinteractions are minor in nature. The enclosures around Page 26 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 I
PlLGRIM NUCLEAR POWER STATION (TAC NO. M69471) i ATTACHMENT A the MCCs were constructed in the mid 1980's as part of the EQ Project to protect the MCCs from harsh environments. The enclosures are substantial steel plate and tube steel structures with entry doors that complet'ly enclose the MCCs. The conduits to the MCCs enter the enclosure through conduit entry boxes which are equipped with RTV foam seals. The conduit entry box has a bottom steel closure plate which is coped to fit around the conduits. In a limited number of instances this closure plate was observed to be in contact with the conduit.
The SRT determined that the spatial interaction did not pose a threat to the structural integrity of the MCCs or the conduit; however, the interaction was recognized as a potential cause of relay chatter. The RTV foam seals are approximately 8" deep and as a result are expected to prevent most if not all of the relative movement between the conduits and the closure plate thereby preventing a spatialinteraction from occurring. Based on these facts and the walkdown, the SRT concluded they did not have a concem about the seismic adequacy or the ability of the component or system to perform its required design function.
Outlier 011, from Seismic Evaluation Report, Section 8.2:
Equipment ID: Pumps P202A, P2028 & P202C Outlier Finding (s): RBCCW Pumps P202A, P2028 & P202C have a potentialinteraction hazard with a ventilation duct located above which has an unusual support system.
Safety implications: No. Further evaluation of the duct supports is expected to demonstrate that they are acceptable.
Outlier Status: Open Outlier 011 Elaboration:
The ductwork over Pumps P2028, P202B, and P202C was identified a potential spatial interaction. As a result, the SRT classified the ductwork as an outlier and recommended that a confirmatory evaluation be conducted. Based on the walkdown, the SRT concluded they did not have a concern about the seismic adequacy or the ability of the component or system to perform its required design function because the support system for the duct was not considered to be deficient or degraded but was considered unconventional.
Outlier 014, from Seismic Evaluation Report, Section 8.2:
Equipment ID: M01400-24A & M01400-24B Outlier Finding (s): Motor operated valves do not meet the GIP screening criteria.
Safety implications: No. Vendor qualification analysis is on file for the valves. The outlier is a GIP screening issue and is expected to be resolved by review of the vendor analysis.
Outlier Status: Open Outlier 014 Elaboration:
Page 27 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471) l ATTACHMENT A Tliese valves do not meet the requirements of MOV/BS Caveat 5, " Valve Operator Cantilever Length". The distance from the center line of the pipe to the top of the l
operator satisfies the requirements of the caveat for the 10" dia. line size; however, the I
operator weight exceeds the maximum allowable weight. The altemate method of l
qualification which involves performing a 3g stress and deflection analysis of the valve yoke was performed but was not successfulin demonstrating verification to the GIP.
In lieu of performing an additional analysis, the SRT declared the valve to be an outlier at this point in the review process. This approach was taken because at the same time that the A-46 reviews were being conducted, Pilgrim was in the process of performing detailed analyses of the subject valves in response to Generic Letter (GL) 89-10 which addresses design adequacy of these safety related MOVs. Because the GL 89-10 analysis of the subject valves would address design adequacy and the impact on the design basis of the valves, the SRT determined the GL 89-10 program would be utilized to resolve the outlier status. Thus, the seismic adequacy or the ability of the component or system to perform its required design function was not a concem.
Outlier 045, from Seismic Evaluation Report, Section 8.2:
Equipment ID: C9050utlier Finding (s): Control Panel C905 is an outlier because of anchor bolt conditions. The outlying anchor conditions are; four anchors with greater than %" gap, two anchors with slotted holes. The anchorage evaluation neglected the outlier bolts and was successful from a strength standpoint.
Safety implications: No. The anchorage is adequ.te. Tne outlying anchor bolt conditions will be addressed during the outlier resolution phase.
Outlier Status: Open Outlier 045 Elaboration:
The outlying anchor conditions identified for this panel did not preclude a successful anchorage strength evaluation. The initial concem of the SRT was that the panel contains relays and that four anchors have a gap between the panel base and the floor. Conditions of this type have the potential to allow the panel to deflect locally which has the potential to cause relay chatter. In this instance since the anchors were located in the interior of the panel, the SRT did not have a concem about chatter, the seismic adequacy, or the ability of the component or system to perform its required design function.
Outlier 060, from Seismic Evalua'. ion Report, Section 8.2:
Equipment ID: MO202-5A & MO202-5B Outlier Finding (s): Flex from the motor operator passes through the grating at Elev.23'in the drywell. There is a potential rubbing interaction between the flex and the grating.
Page 28 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A Safety implications: No. Potential interaction between the valve parts and the grating is not a i
concem based on the existing clearance and the massive size and strength of the valve assembly and will be addressed during the outlier resolution phase.
Outlier Status: Open Outlier 060 Elaboration:
The nature of the potential interactions between the flex conduit to the motor operator and the adjacent floor grating is minor. 53ased on the walkdown, the interaction will be j
limited to the flex and the surrounding grating rubbing together. The SRT determined that the spatial interaction ' id not pose a threat to the structural integrity of the valves d
or the flex conduit. As a result, the SRT concluded that there was not a significant concem about the seismic adequacy or the ability of the component or system to perform its required design function.
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l Page 29 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 12:
Indicate whether you used the SMA methodology described in the report EPRI NP-6041 for the resolution of the outlier tanks and heat exchangers. If you used the SMA methodology for the tank evaluations, you are aware that this methodology is known to yield results which are not i
as conservative as those obtained by following GlP-2 guidelines. Therefore, it is generally not acceptable for the A-46 program. Describe the extent to which the method was used in your A-46 program. For each deviation from the GIP-2 guidelines, in situations where the margin methodology is utilized, identify the nature and extent of the deviation, and provide a technical justification for its acceptance.
RESPONSE 12:
Appendix H of EPRI NP-6041-SL, Rev.1, contains. a methodology for the evaluation of flat-bottom vertical fluid storage tanks. This SMA methodology was not used. Pilgrim is following the GIP-2 guidelines for the resolution of outlier talks and heat exchangers.
Page 30 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 l
PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 13:
Indicate whether you found any anchor type (e.g., lead cinch anchor) that is not covered by the GlP-2 during the walkdown. If yes, how did you resolve the issue?
RESPONSE 13:
During walkdowns for the 20 Classes of equipment, there were instances where equipment l
anchorage differed from the five types covered by Check 2 of the Anchorage Installation l
Inspection Requirements, contained in GIP Section 4.4.1. As required by the GIP, these have been identified as outliers. Pilgrim has not completed the outlier resolution phase of the A-46, and therefore, final resolution remains open at this point in time. Nevertheless, an interim resolution was achieved for all outliers to address the question of whether a nonconforming or degraded condition existed and to assess safety implications. This process is described in I
Enclosure B, Section 8 of our September 30,1996, submittal.
^. s examples of outlier conditions where the anchor type was not one of the five covered by bie GlP, consider outliers 01,04, 025,038,050,064 reported in Enclosure B, Section 8 of our September 30,1996, submittal. The types of anchors found which were not of the five types covered by the GIP include friction clips, embedded Unistrut, expansion anchors in concrete masonry, and powder actuated fasteners. In some cases the outlier was resolved by detailed evaluations involving rigorous analysis and/or engineering judgment based on the facts. In other cases, the final resolution of the outlier may remain open, supported by an assessment of safety implications.
1
)
l Page 31 of 33 l
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A QUESTION 14:
If Thermal-Lag panels are attached to a cable tray system, discuss how the changes in weight have been incorporated in the GlP evaluation of these systems and their supports.
(
RESPONSE 14:
PNPS utilized marinite boards. Affected LAR calculations accounted for the marinite boards by incorporating their weight into the overall evaluation of the cable tray or conduit support system.
4 Page 32 of 33
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT A l
QUESTION 15:
You provided two different in-structure response spectra (IRS) in References 15.1 and 15.2, respectively, prosided below. Indicate which IRS has been used for your A-46 program. If the lRS in Reference 15.2 has never been used for resolutions of the A-46 issues, please state so.
15.1 Letter from Boston Edison Company (BECo) to NRC, "120-Day Response to Supplement 1 of Generic Letter 87-02 for PNPS," dated September 21,1992.
15.2 Letter from E. Boulette (BECo) to NRC, " Additional Response to GL 87-02, Supplement 1," dated February 9,1994, RESPONSE 15:
RefereNe 15.1 provided information concerning the procedures and criteria used for the development of in-structure spectra to be used for USl A-46. This submittalincluded a copy of BECo Specification C-114 containing Pilgrim design basis floor spectra for safety related structures and the ground response spectrum.
Reference 15.2 requested the Reference 15.1 IRS be considered as " Conservative design" for use in seismic demand screening criteria for equipment in the Reactor, Turbine, and Radwaste buildings. The NRC approved this request by letter dated June 17,1994. The characterization of the NRC approved IRS treatment in the A-46 program is represented in Enclosure B, Table 3-1 of Pilgrim's September 30,1996, submittal.
We interpret your question about "the IRS in Reference 15.2" to be asking whether the attemative IRS developed for the Reactor Building using soil structure interaction analysis is being used in the A-46 Program. These attemative IRS are discussed in paragraph two of Reference 15.2, and also in Enclosure B, Section 9.3 of the September 30,1996 submittal. We had at one time proposed to use these altemative IRS in the outlier resolution phase, but based on interactions with the staff subsequent to the September 30,1996, submittal, no longer propose to do so. Consequently, Sectic.) 9.3 is moot, and one outlier (04) previously resolved contir,96at on NRC approval of the attemative IRS, is no longer considered resolved.
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l Page 33 of 33 l
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON UNRESOLVED SAFETY ISSUE (USI) A-46.
l l
PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT B 1-ATTACHMENTS TO RAI RESPONSES l-QUESTION #2 l
QUESTION #5 QUESTION #7 QUESTION #8 QUESTION #10 l
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l i
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l RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON l
UNRESOLVED SAFETY ISSUE (USI) A-46.
PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT B l
ATTACHMENT TO RESPONSE #2 Pilgrim Turbine Building response spectra Pilgrim Radwaste Building response spectra 1
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MO MD CHECKED BY M
EdisoD colia 1EV.
DATE 3HEET op A
'ILGRIM TURBINE BUILDING g gogy)
In-Structure SSE Response Spectra @ EL 23,37 & 51 feet, compared to: ()
1.5 x SQUG Bounding Spectrum and SSE Ground Response Spectra Effective Grade is EL 6 ft. All spectra are 5% damping, horizontal direction 4, - EL SO, (p_EL GG' EFL 51' 3.0 -
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OATE HEET OF PILGRIM RADWASTE BUILDING In-Structure SSE Response Spectra @ EL 37,51,66 & 81 feet,' compared to
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8 gg gg 1.5 x SQUG Bounding Spectrum and SSE Ground Response Spectra q p Effective Grade is EL-1 ft. All spectra are 5% damping, horizontal direction EL(W 4>
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON UNRESOLVED SAFETY ISSUE (USI) A-46.
PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT B ATTACHMENT TO RESPONSE #5 SQUG Memorandum, dated February 13,1998, Confirmation of SQUG SCE Training
F4fjS Q U Gl,,y y February 13,1998 MEMORANDUM l
To:
John G. Dyckman, Boston Edison From:
David A. Frec R, Training Coordinator
Subject:
Confirmation of SQUG SCE Training This memorandum forwards the confirmation that the associated BECo and contractor personnel have successfully completed the "SQUG Walkdown Screening and Seismic Evaluation Training Course." This training qualifies them as Seismic Capability Engineers (SCEs).
Name-Company
/A 46 Cour'$e Date-Charles Pitts 9/14/92 John G. Dyckman 8/2/93 Subhash C. Chugh 8/2/93 Jeffrey A. Kalb Boston Edison 6/22/92 Viktor Zukauskas 8/2/93 David Rydman 6/2/93 William R. Kline 6/22/92 Walter Djordjevic 4/6/92 homas J. Tracy 8/2/93 g
John J. O'Sullivan 8/10/92 If you need any other information pertaining to the qualification of these individuals, please do not hesitate to contact me at 703-519-0200.
l k:\\ admin \\cfields\\freedaqug\\ memos \\dyckman.a46
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON UNRESOLVED SAFETY ISSUE (USI) A-46 PILGRIM NUCLEAR POWER STATION (TAC NO. M69471) l ATTACHMENT B t
ATTACHMENT TO RESPONSE #7 MO 3801 SEWS plus calculation l
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B cton Edixn Company - Pilgrim Nucle:r Power Stati n GIP Rsv 2, Corrected,2/14/92 SCREENING EVALUATION WORK SHEET (SEWS)
Status: Yes Sheet'1 of 3 ID : MO3801 ( Rev. 0 )
l Class : 8. Motor-Operated and Solenoid-Operated Valves Description : SSW LP A TBCCW HX OUTLET Building : AXBAY l Floor El. : 3.00 l Room, Row / Col: A COMP SEISMIC CAPACITY VS DEMAND 1.
Elevation where equipment receives seismic input 3.00 2.
Elevation of seismic input below about 40' from grade (grade = 23.00)
Yes 3.
Equipment has fundamental frequency above about 8 Hz (est. frequency = 0.00)
N/A 4.
Capacity based on:
1.00
- Bounding Spectrum 5.
Demand based on:
1.00
- Design Basis Ground Response Spectrum 0.800 f
,,......... ~
~,
G T LOG i
iil O.008 i
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i 0.10 LOG Hz 33.00 Capacity
. Demand 1
File Record Capacity H.\\ GIP \\ GIP \\ spectra. des Label l Bounding Spectrum Demand i H:\\ GIP \\PROJ002A\\ spectra. des Bu!LDINGjGROUNDl ELEVATION l23l DIRECTION l HORIZONTAL Demand 2 H.\\ GIP \\PROJ002A\\ spectra. des BulLDINGl GROUND l ELEVATION l23lDIRECTIONjHORIZONTAL Does capacity exceed demand?
YAs
BsIton Edizen Ccmpiny - Pilgrim Nucl::r Pcw:r Stati n GIP Rev 2, Corrected,2/14/92 SCREENING EVALUATION WORK SHEET (SEWS)
Status: Yes Sheet 2 of 3 ID : MO3801 ( Rev. 0 )
l Class : 8. Motor-Operated and Solenoid-Operated Valves Description : SSW LP A TBCCW HX OUTLET Building : AXBAY l Floor El. : 3.00 l Room, Row / Col: A COMP CAVEATS - BOUNDING SPECTRUM t
MOV/BS Caveat 1 - Earthquake Experience Equipment Class.
Yes MOV/BS Caveat 2 - Valve Body Not of Cast iron.
Yes MOV/BS Caveat 3 - Valve Yoke Not of Cast Iron.
Yes*
MOV/BS Caveat 4 - Mounted on 1-Inch Diameter Pipe Line or Greater.
Yes MOV/BS Caveat 5 - Valve Operator Cantilever Length for Motor-Operated Valves.
Yes MOV/BS Caveat 6 - Actuator and Yoke Not Independently Braced.
Yes l
MOV/BS Caveat 7 - Sufficient Slack and Flexibility of Attached Lines.
Yes MOV/BS Caveat 8 - No Other Concems.
Yes is the intent of all the caveats met for Bounding Spectrum?
y_es NTERACTION EFFECTS 1 Soft targets are free from impact by nearby equipment or structures.
Yes i
- 2. F the equipment contains sensitive relays, it is free from all impact by nearby equipment or N/A stuctures.
- 3. Attsched lines have adequate flexibility.
Yes
- 4. Overhead equipment or distribution systems are not likely to collapse.
Yes
- 5. No other adverse concer'es were found.
Yes is equipment free of interaction effects?
Y_e1 IS EQUIPMENT SEISMICALLY ADEQUATE?
Yet l
C. MMENTS O
SRTs are W.R. Kline, and C.T.Pitts,5/16/93.
l REF: 1. Limitorque Corporation Table of Approximate Weights, Selection Index: SEL-16,10/17/77.
- 2. MOV Table Drwg # M-MOV-6, Rev. E5.
l
- 3. MOV Table Drwg # M-MOV-5, Rev. E10.
- 4. Pratt Report " Material, Design and Dimensional Data for r ed Sutterfly Valves" dated 2/9/94.
Capacity:
Cav3: This is a Butterfly valve, manufactured by Henry Pratt. REF 4 indicates the valve actuator support bracket is cast iron. Based on a yoke analysis (attached), the stress is less than 20% of the minimum ultimate strength thus meeting the intent of the caveats.
Cav4: The pipe line diameter is 12". (REF 3) l
Bretan Ediscn Company - Pilgrim Nucitar Powar St tian GIP R V 2, Corrected,2/14/92 SCREENING EVALUATION WORK SHEET (SEWS)
Status: Yes Sheet 3 of 3
~
ID : MO3801 ( Rev. 0 )
l Class : 8. Motor-Operated and Solenoid-Operated Vanes Description : SSW LP A TBCCW HX OUTLET Building : AXBAY l Floor El. : 3.00 l Room, Row / Col: A COMP Cav5: Verified using GIP Table B8.1. The measured offset is 35" < 80" allowable for a 12" valve. The motor operator is a Limitorque SMB Size 000-2 (REF 2). The maximum weight of the operator is 175# (135# + 40# for integral cover) (REF 1) < 750# allowable for a 12" valve. The yoke dimensions are: h=7.5", w=6", t=1/2".
Evaluated by:
Date:
/
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81795 e
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4TIAGMENT TD 665 fbe.
M o 380t.
/
Valve : Mo3800, Mo3801, Mo3805, Mo3806 l
r 3
Y Approx.
Operator i
- T 6"-
D t
]
X D
C G.
d h.
IN Yoke Cross Section y
--t I
II
{
{ ( Yok Simnlified Yoke Cross Section F=3g>
F=3g s,
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Valve Body Loadin the Loadin the "x" direction "y" direction l
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F =3 xWeight Ma F XH Ma F X(H +6)
In D Xt*
la txDa 4
2 12 12 Dw FxH*
D" FxH*
24El
- 6El, g
INPUT DATA :
l Weight =
175 lbs F=
0.525 Kips H=
6.44 in -
D=
5.94 in,
t=
0.625 in -
i lyy = 0.121 in^4 Syy = 0.387 in^3 i
lxx = 10.916 in^4 Sxx = 3.675 in^3 OUTPUT DATA :
Myy/Syy =
2.19 Ksi Dyy = 0.002 in.
i Mxx/Sxx =
0.89 Ksi s Dxx = 7E-05 in.
i i
Notes:
1.
The stresses caused by the axial loads are negligible and can therefore be ignored.
1 2.
Dimensions used in the analyses are taken from Pratt Report " Material, Design and Dimensional Data for Pratt Butterfly Valves" dated 2/9/94. SRT reported field dimensions i
of H = 7.5', D = 6*, and t = 0.5*. These compare favorably within the acuracy of field measurement capabilities.
3.
The Pratt report lists the yoke (" actuator support bracket") material as Cast iron, ASTM A-48, Class 40. The ultimate strength for this material is 40,000 psi. GIP Section B.8-3, MOV/BS Caveat 3 nermits use of cast _ iron yoke stresses limited to 20% of minimum ultimate strenght, here at 20% x 40,000 = 8 Ksl.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON UNRESOLVED SAFETY ISSUE (USI) A-46.
PILGRIM NUCLEAR POWER STATION (TAC NO. M69471)
ATTACHMENT B ATTACHMENT TO RESPONSE #8 BECo Calc. C15.0.3270, Rev. O BECo Calc. C15.0.3273, Rev. O BECo SEWS T151 A, Rev. O BECo OSVS T151 A, Rev. O BECo SEWS T151B,Rev.0 BECo OSVS T151B, Rev.0 i
t i
i