LD-94-072, Provides Justification for Tier 2 Seismic & Valve Testing Expirations

Provides Justification for Tier 2 Seismic & Valve Testing Expirations

ML20078S492
Person / Time
Site:	05200002
Issue date:	12/16/1994
From:	Brinkman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LD-94-072, LD-94-72, NUDOCS 9412280327
Download: ML20078S492 (3)

Text

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ABB December 16, 1994 LD-94-072 Docket No.52-002 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

System 80+ Tier 2* Expiration

Reference:

ABB-CE Letter LD-94-073, dated December 16, 1994

Dear Sirs:

The enclosure to this letter provides justification for having an expiration date of "first full power" for the Tier 2* items on seismic qualification and motor-operated valve testing which were identified in the Introduction of the Design Control Document (Reference). ABB-CE expects that the expriation dates for these items and for Human Factors Engineering will be agreed upon and incorporated into the DCD when other staff review comments are addressed in January 1995.

If you have any questions, please call me or Mr. Stanley Ritterbusch at (203) 285-5206.

Very truly yours, COMBUSTION ENGINEERING, INC.

C. B. Brinkman Director Nuclear Systems Licensing ser/lw

Enclosure:

As Stated cc: S. Magruder (NRC)

P. Lang (DOE)

O ABB Combustion Engineering Nuclear Power QV$

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gggg K Combustran Ergnnenng Inc. P O. Box 500 Telephone (203) 6881911 9412280327 941216 PDR ADOCK 05200002 Ne7cN Y A PDR

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, ATTACHMENT TIER 2* SEISMIC AND VALVE TESTING EXPIRATIONS 4

seismic Qualification GDC 1 of Appendix A and paragraph XVII of Appendix B to 10 CFR 50 establish requirements for records concerning the qualification of equipment. In addition, for System 80+, there is a COL Action requiring the licensee to make the specific details of the plant-specific seismic and dynamic qualification program available for NRC evaluation at the time of COL application (see COL No. 3-7 in Table 1.10-1 and Section 3.10 of the DCD). This includes a description of administrative control procedures; equipment qualification reports and records; results of in-plant tests; and, if used, documentation on qualification by experience. Thus, it is not expected that an applicant would modify the seismic qualification program described in CESSAR-DC without NRC prior knowledge and approval, as that would be in violation of an established program submitted at the time of COL. Any concerns about such violations are most properly addressed through the normal inspection and enforcement program.

A principal cost related to design and supply of safety related components is associated with the initial qualification program.

Once qualification of System 80+ equipment has been performed for the first unit, there woeld be little or no cost benefit for that licensee to provide replacement components, or initial components for follow-on plants, that are qualified to lesser standards.

Also, in the general provisions to the Certified Design Material (CDM), there is a requirement for type tests, analyses, or a combination of type tests and analyses, of the Seismic category I mechanical and electrical equipment (including connected instrumentation and controls) identified in the Design Description, to demonstrate that the as-built equipment including associated anchorage, is qualified to withstand design basis dynamic loads without loss of its safety function. A licensee is expected to follow the approval qualification program when either providing initial components or when purchasing replacement equipment to meet this CDM commitment.

Lastly, once any System 80+ unit is in operation, there does not appear to be any regulatory basis for distinct and separate enforcement procedures regarding replacement components for that unit from those which are in place for other operating units. In fact, considering advanced design features and improved safety implemented in Advanced Light Water Reactor designs, any concerns related to requiring " prior NRC approval" have less associated safety risk. In other words, there is less safety risk, and, l therefore, there is less need for " prior approval."

. a 1

Motor Operated valve Testing 4

The COL applicant referencing the System 80+ Standard Design is )

required to develop and/or provide site and plant specific I information on mechanical systems and components design. This  !

information includes qualification and preoperational testing of I safety related pumps and valves and a detailed pump and valve j inservice testing program (see COL No. 3-6 in Table 1.10-1 and Section 3.9.6 of the DCD). Thus, it is not expected that an I applicant would implement a change to the critical elements of the MOV test program without NRC prior knowledge and approval, as that would be a direct violation of an established program submitted at the time of COL. Any concerns about such violations are most properly addressed through the normal inspection and enforcement l program.  ;

1 A principal cost related with the design and supply of motor j operated valves is associated with the initial qualification ,

program. Once qualification of System 80+ motor operated valves has been performed for the first unit,. there would be little or no cost benefit for that licensee to provide replacement valves, or initial valves for follow-on units, that are qualified to a lesser standard. Also, in the general provisions to the Certified Design ,

Material (CDM), there is a requirement for tests or type tests of I active safety-related Motor-Operated Valves (MOVs) identified in l the Design Description to demonstrate that the MOVs are qualified l

to perform their safety functions under design basis differential pressure, system pressure, fluid temperature, ambient temperature,  ;

minimum voltage, and/or maximum stroke times. A licensee is i

expected to follow the approved qualification and preoperational testing program for MOVs when either providing initial components  ;

or when purchasing replacement equipment to meet this CDM j commitment. The cost efficiency of Standard Plant design, will encourage System 80+ licensees to make maximum use of the MOV test program and results developed for the first unit. In addition, with the maintenance rule in place, the issue of safety valve testing will have high exposure, thus deterring a licensee from I inadvertent negligent actions. I Lastly, once a System 80+ unit is in operation, there does not appear to be any regulatory basis for distinct and separate enforcement procedures regarding replacement components for that unit from those which are in place for other operating units. In fact, considering advanced design features and improved safety I implemented in Advanced Light Water Reactor designs, any concerns related to requiring " prior NRC approval" have less associated safety risk. In other words, there is less safety risk, and, therefore, there is less need for " prior approval."

,