ML13324A498
| ML13324A498 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/19/1984 |
| From: | Medford M Southern California Edison Co |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| References | |
| TAC-42516, TAC-67758 NUDOCS 8411210258 | |
| Download: ML13324A498 (29) | |
Text
Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 M.O.MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING November 19, 1984 (818) 5721749 Director, Office of Nuclear Reactor Regulation Attention: 3. L. Zwolinski, Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Environmental Qualification of Electrical Equipment San Onofre Nuclear Generating Station Unit 1 The purpose of this letter is to document the results of a meeting with the NRC staff held on December 20, 1983 in Bethesda, Maryland to discuss the environmental qualification of safety related electrical equipment at San Onofre Unit 1. The intent of the meeting was to (1) reach agreement on resolution of qualification deficiencies identified in the Franklin Research Center Technical Evaluation Report (TER), (2) address compliance with 10 CFR 50.49, and (3) address equipment "Justifications for Continued Operation" (JCO).
Each of these items is discussed in this letter. This letter also documents our understanding of additional information which the NRC staff indicated should be considered regarding the resolution of the qualification deficiencies. Finally, this letter has been delayed to coordinate the response with information requested by the NRC's May 9, 1984 letter regarding the environmental qualification program.
The material which was presented during the December 20 meeting regarding the resolution of TER qualification deficiencies is provided as. Our understanding of additional information which the NRC staff indicated should be considered during the qualification program is provided as. Also provided in Enclosure 3 are additional details on the resolution of the qualification deficiencies identified in Enclosure 1.
000 Following the discussion of the Franklin TER deficiencies at the December 20 meeting, the NRC staff asked if the equipment list had been o
changed and if JCO's had been provided for the equipment identified. Since the NRC staff's issuance of their Safety Evaluation Report (SER) dated November 30, 1982 which included the Franklin TER dated June 28, 1982 there Nu have been no additions to the list of safety-related equipment for San Onofre ra Unit 1. The equipment list was provided in our submittal dated October 31, 1t 1980 and supplemented by letter dated November 4, 1981.
By letter dated
-4 February 24, 1982 JCO's were provided for all safety-related equipment a.a.
identified in the October 31, 1980 submittal.
This included the equipment addressed by the Franklin TER with the exception of the charging pumps and th valve positioners for the safety injection valves. The components added by A
- g.L 14r.
- 3.
November 19, 1984 the November 4, 1981 submittal did not have JCO's included in the February 24, 1982 submittal. The JCO's for all equipment in the environmental qualification program including the charging pumps, valve positioners and the items from the November 4, 1981 submittal, were provided by letter dated November 3, 1984.
The NRC staff requested that we provide the method for identifying safety related (10 CFR 50.49b(l)) equipment, non-safety related (b(2))
equipment and post-accident monitoring (b(3)) equipment and confirm that the equipment identified addresses all design basis accidents including flooding outside containment. The equipment identified in the October 31, 1980 submittal and supplemented by letter dated November 4, 1981 is that safety related equipment identified by a review of the final safety analysis, emergency operating procedures and other relevant sources.
The design basis accidents for which this equipment is required to operate include the LOCA and HELB inside containment and HELB outside containment. The flooding of safety related equipment outside containment resulting from a HELB was addressed as part of the effects of the non-Category A equipment failure issue which was submitted to the NRC by letter dated March 21, 1975. The results of that investigation showed that (1) safety related equipment is not affected, or (2) safety related components, systems, etc. are sufficiently monitored to allow corrective action to be taken, or (3) redundant and separate safety related equipment exists to preclude common mode failure.
With regard to the identification of non-safety related equipment, our May 20, 1983 letter in response to 10 CFR 50.49(g), indicated that compliance with 10 CFR 50.49b(2) was accomplished as a result of compliance with a number of NRC issues.
This is exhibited in our efforts on SEP, Fire Protection, I and E action and our response to the NRC's April 8, 1976 letter on the single failure evaluation of the ECCS as discussed below.
The May 20, 1983 letter indicated that a preliminary review of non-safety related equipment failures was performed as part of the Fire Protection review at San Onofre Unit 1. During the review, no equipment was identified that would affect safe shutdown.
In addition to the May 20, 1983 response, the failure of non-safety related equipment has been addressed as part of requests made by various IE Bulletins, Circulars and Information Notices, including Information Notice 79-22, Interaction Between Non-Safety Grade and Safety Grade Systems. The effort on this particular notice involved the evaluation of the Steam Generator PORV Control System, the Main Feedwater Control System, the Pressurizer PORV Control System and the Rod Control System for failure of non-safety grade equipment which could affect the performance of safety functions during the accident. The results of the evaluation, which were transmitted to the NRC by letter dated October 5, 1979, were procedural changes to improve operator response to specific events.
Equipment modifications or replacements were not necessary. It was determined that failure of non-safety grade equipment in the identified systems would not prevent the performance of a safety function.
Mr. 3.
November 19, 1984 As part of the ECCS single failure evaluation, the failure of ECCS equipment and its auxiliaries was addressed. This work involved a review of the equipment required to shutdown and mitigate the consequences of an accident for possible failures which would prevent the performance of a safety function. The results of this effort were provided to the NRC by letters dated December 21, 1976 and December 20, 1977.
This work included a failure evaluation of safety related equipment, a flooding evaluation of equipment inside containment and a separation evaluation of the safety related equipment. Specific recommendations included installing power interrupt devices on various safety-related and non-safety related pump motors, valve operators and instrumentation inside containment and rerouting control and power cable for certain redundant safety-related equipment. The recommendations from the reports are being addressed as part of the SEP Integrated Assessment currently in progress at San Onofre Unit 1. As indicated in our May 20, 1983 letter, in the event non-safety related equipment which affects safety related equipment is identified in future reviews or modifications, they will be qualified in accordance with 10 CFR 50.49 or replaced. Based on efforts to date, additional work in this area to identify non-safety related equipment failures is not necessary.
With regard to the identification of post-accident monitoring instrumentation (i.e., 10 CFR 50.49b(3)), the response in our May 20, 1983 letter is still applicable. Post-accident monitoring equipment was identified in the October 31, 1980 submittal. Additional equipment installed as part of TMI modifications was identified in our July 2, 1982 submittal.
Additional monitoring equipment may be identified as part of NUREG-0737, Supplement 1 work and will be qualified as necessary to 10 CFR 50.49.
By letter dated May 9, 1984, the NRC staff requested additional information regarding the environmental qualification program. The responses to the specific items in that request are included with this letter as.
For your information, we plan to complete all activities described herein by March 31, 1985, including the identification of any equipment which will require replacement. To date, fifteen components have been identified which require replacement. Since we will be unable to replace these items with qualified components by March 31, 1985, we have submitted a request for extension to November 30, 1985. The request was transmitted to the NRC by letter dated July 30, 1984.
If you have any comments regarding this letter or its enclosures, please let me know.
Very truly yours, Enclosures
ENCLOSURE 1 Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 1 Component Type:
Motorized Valve Actuators SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 10(8)
MOV-850AB,C Limitorque m/n SMA-1-40 IIA Similarity; Aging; Qualifiable based on valve oper mw/Reliance m/n 400524-FQ Qualified Life/Replacement ating requirements. Additional Schedule; Aging Program evaluation to address aging, qua]lified life/replacement schedule will be performed.
15(1)
MOV/LCV lOOB',C Limitorque m/n SMB-00-10 IIA Similarity; Aging; Additional evaluation to addr*
w/Reliance m/n 400524-FQ Qualified Life/Replacement deficiencies based on vendor type Schedule testing is being performed.
Also evaluating qualifiability based on valve operating requirements.
15(2)
MOV/LCV llOOD Limitorque rn/n SM1B-00-10 IA Similarity; Aging; Additional evaluation to address w/Peerless rn/n KS45153 Qualified Life/Replacement deficiencies based on vendor type Schedule testing is being performed. Also evaluating qualifiability based on valve operating requirements.
18(5)
MOV-18,190 Limitorque m/n SMB-00 IIA Similarity; Aging; Additional evaluation to address w/Peerless Qualified Life/Replacement deficiencies based on vendor type Schedule; Aging Program testing is being performed. Also evaluating qualifiability base on valve operating requirementW 59(7)
MOV-720A,B Limitorque m/n SMB-00 IIA Similarity; Aging; Additional evaluation to address Qualified Life/Replacement deficiencies based on vendor type Schedule; Aging Program testing is being performed. Also evaluating qualifiability based on valve operating requirements.
12(6)
MOV-866A,B Limitorque m/n SMB-00 IIA Similarity; Aging; Additional evaluation to address w/Peerless rn/n P11766 Qualified Life/Replacement deficiencies based on vendor type Schedule; Aging Program testing is being performed.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 2 Component Type:
Motorized Valve Actuators (Cont'd.)
SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 20(3)
MOV-356,357,358 Limitorque m/n SMB-00-25 IIA Similarity; Aging; Additional evaluation to address w/Reliance m/n 709571-JY Qualified Life/Replacement deficiencies based on vendor type Schedule; Aging Program testing is being performed.
23(4)
MOV-880 Limitorque m/n SMB-00 IIIA NA Exempt from qualification. Valve w/Peerless not required to operate.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 3 Component Type:
Solenoid Valves SCE SONGS-1 Equipment NRC/TER Item # ID Number.
Description Category Deficiencies Response/Resolution 19(12)
FCV-11150,E,F ASCO m/n 88300 B56R1 IV Documentation not provided Valve internals rebuilt [see SCE letters 4/4/81 and 4/18/81].
Maintenance to be performed at 5-year intervals.
26(60)
CV-82(SV-128)
ASCO m/n WPLB8300 B61RV IIA Documentation not adequate Evaluating similarity of valves*
to other tested valves. Quali fication evaluation will also consider valve operating requirements.
(62)
CV-114(SV-118)
ASCO m/n U8302 C26R IIA Documentation not adequate Evaluating similarity of valves to other tested valves. Quali fication evaluation will also consider vakve operating requirements.
28(13)
CV-102,104,106 ASCO m/n WPLB8300 861R IIA Documentation not adequate Evaluating similarity of valves (SV-108,110,112) to other tested valves. Quali fication evaluation will also consider valve operating requirements.
29(67)
CV-103,105,107 ASCO m/n 8300 B61 IIA Documentation not adequate Evaluating similarity of valves (SV-109,111,113) to other tested valves. Quali fication evaluation will also consider valve operating requirements.
30(68)
CV-146,147 ASCO m/n WPLB8300 B59 IIA Documentation not adequate Evaluating similarity of valves (SV-1212-6, to other tested valves. Quali 1212-7) fication evaluation will also consider valve operating requirements.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 4 Component Type:
Solenoid Valves (Cont'd.)
SCE SONGS-1 Equipment NRC/TER Item #
- 11) Number Description Category Deficiencies Response/Resolution 31(66)
SV-1212-8, ASCO m/n HTX821027 IIA Documentation not adequate Replaced with qualified Target 1212-9 Rock valves.
32(71)
CV-117,118,119 ASCO m/n WP831735 IIA Documentation not adequate Replaced with qualified Target (SV-119,120,121)
Rock valves.
33(71)
CV-120,121,122 ASCO m/n WP831735 IIA Documentation not adequate Replaced with qualified Target (SV-122,123,124)
Rock valves.
34(67)
CV-123 ASCO m/n WP8300 B61R IIA Documentation not adequate Replaced with qualified Target (SV-125)
Rock valves.
35(10)
CV-537 ASCO m/n WP HTX832093 IIA Documentation not adequate Evaluating similarity of valves to other tested valves. Quali fication evaluation will also consider valve operating requirements.
36(61)
CV-115 ASCO m/n WPLB8300 864RU IIA Documentation not adequate Evaluating similarity of valves (SV-126) to other tested valves. Quali fication evaluation will also consider valve operating requirements.
39(63)
POV-9,10 ASCO m/n 8345C11 IIA Documentation not adequate Evaluating similarity of valves (SV-29,30) to other tested valves. Quali fication evaluation will also consider valve operating requirements.
40(64)
CV-40,116 ASCO m/n WPLB8300 B59RF IIA Documentation not adequate Evaluating similarity of valves (SV-19,127) to other tested valves. Quali fication evaluation will also consider valve operating requirements.
Southern California' Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 5 Component Type:
Solenoid Valves (Cont'd.)
SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 41(70)
CV-10 (SV-28)
ASCO m/n WPLB8300 B59 IIA Documentation not adequate Evaluating similarity of valves to other tested valves. Quali fication evaluation will also consider valve operating requirements.
42(10)
CV-533,536 ASCO m/n WPHTX832093 IIA Documentation not adequate Evaluating similarity of valves to other tested valves. Quali fication evaluation will also consider valve operating requirements.
43(11)
CV-534,535 ASCO m/n WPHT832093 IIA Documentation not adequate Evaluating similarity of valves to other tested valves. Quali fication evaluation will also consider valve operating requirements.
46(69)
CV-287 ASCO IIA Documentation not adequate Evaluating similarity of valves to other tested valves. Quali fication evaluation will also consider valve operating requirements.
47(68)
CV-202,203,204 ASCO m/n WPLB8300 B59 IIA Documentation not adequate Evaluating similarity of valves (SV-126) to other tested valves. Quali fication evaluation will also consider valve operating requirements.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 6 Component Type:
Solenoid Valves (Cont'd.)
SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 48(11)
CV-532 ASCO mm WPHTX832093 hA Documentation not adequate Evaluating similarity of valves to other tested valves.
Quali fication evaluation will also
- consider valve operating requirements.
76(65)
CV-530,531 ASCO 8316 hA Documentation not adequate Evaluating similarity of valves to other tested valves.
Quali fication evaluation will also consider valve operating requirements.
77(65)
CV-545,546 ASCO 8316 IIA Documentation not adequate Evaluating similarity of valves to other t
'ested valves.
Quali fication evaluation will also consider valve operating requirements.
44(17)
CV-525,527 Atkomatic m/n 3101 IIA Documentation not adequate Will be replaced as part of Efcomatic valve modification.
45(19)
CV-526,528 Atkomatic m/n 3101 IIA Documentation not adequate Will be replaced as part of Efcomatic valve modification.
49(16)
CV-515,516 Atkomatic m/n 3101 IIA Documentation not adequate Will be replaced as part of Efcomatic Valve modification.
37(14)
SV-702BD Morotta m/n MV583H-4A IA Documentation not adequate Exempt from qualification. Valves not required to operate.
38(15)
SV-702AC Morotta m/ MV583H-4A fA Documentation not adequate Exempt from qualification. Valves not required to operate.
57(9)
CV-76,77,78,79 Valvair m/ 5682-2 fA Documentation not adequate Additional evaluation to address (SV-85,86,87,88) radiation-only environment is being performed.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 7 Component Type:
Transmitters: Flow/Level/Pressure/Temperature SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 63(21)
FT-2002-A,B,C Controlatron m/n 240N3CS40 IIA Documentation not adequate Replaced with fully qualified equipment (N-ElO series). Docu mentation is being prepared as part of TMI modification program.
3(30)
PT-430,431 Foxboro m/n N-EllGM IIA Documentation not adequate; Qualified based on type testing Similarity; Aging; Qualified completed in May 1983.
Life/Replacement Schedule; Aging Program; Duration; Profile Envelope; Test Sequence 50(34)
PT-1120A,B,C Foxboro m/n N-EllGM HA Documentation not adequate; Qualified based on type testing PT-1121A,B,C Similarity; Aging; Qualified completed in May 1983.
Life/Replacement Schedule; Aging Program 64(28)
LT-450X,451X, Foxboro m/n N-El3DM IIA Documentation not adequate; Qualified based on type testing 452X Similarity; Aging; Qualified completed in May 1983.
Life/Replacement Schedule; Aging Program; Duration; Profile Envelope; Test Sequence 4(29)
LT-430,431,432 Foxboro m/n E13DH IIA Documentation not adequate; Qualifiable. Documentation based Similarity; Aging; Qualified on vendor type testing will be Life/Replacement Schedule; performed.
Aging Program; Duration; Profile Envelope; Test Sequence 2(18)
FT-456,457,458 Foxboro m/n 613DM IIA Documentation not adequate; Replaced with fully qualified Aging; Qualified Life/
equipment (N-ElO series).
Replacement Schedule; Aging Program 9(22)
FT-912,913,914 Foxboro m/n 630-2AS IIA Documentation not adequate To be replaced with qualified transmitters.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 8 Component Type:
Transmitters: Flow/Level/Pressure/Temperature (Cont'd.)
SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 3(30)
PT-432 Foxboro m/n E11GM IIA Documentation not adequate; Qualifiable for all parameters Similarity; Aging; Qualified except radiation. Radiation Life/Replacement Schedule; qualification is being evaluated.
Aging Program; Duration; Profile Envelope; Test Sequence 1(25)
FT-460,461,462 Foxboro m/n E110M IIA Documentation not adequate; Additional evaluation to address Similarity; Aging; Qualified deficiencies based on vendor type Life/Replacement Schedule; testing is being performed.
Aging Program; Duration; Profile Envelope; Test Sequence 13(23)
FT-500,501 Foxboro m/n E13DM HA Documentation not adequate; Additional evaluation to address Similarity; Aging; Qualified deficiencies based on vendor type Life/Replacement Schedule; testing is being performed.
Aging Program; Duration; Profile Envelope; Test Sequence 25(20)
FT-504 Foxboro m/n E130M IIA Documentation not adequate; Additional evaluation to address Similarity; Aging; Qualified deficiencies based on vendor type Life/Replacement Schedule; testing is being performed.
Aging Program 27(33)
PT-501,502,503 Foxboro m/n E11GM IIA Documentation not adequate; Additional evaluation to address Similarity; Aging; Qualified deficiencies based on vendor type Life/Replacement Schedule; testing is being performed.
Aging Program 80(32)
PT-425 Foxboro m/n E13GM HA Documentation not adequate; Additional evaluation to address Similarity; Aging; Qualified deficiencies based on vendor type Life/Replacement Schedule; testing is being performed.
Aging Program; Duration; Profile Envelope; Test Sequence 91(24)
FT-602 Foxboro m/n E13DM IIIB NA Not in Scope (cold shutdown equipment).
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 9 Component Type:
Transmitters: Flow/Level/Pressure/Temperature (Cont'd.)
SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Categor Deficiencies Response/Resolution 14(27)
LC-951 Gems Corp. m/n LS800 IB Qualification Pending New sump level monitoring equip Modification ment has been istalled. Documen tation is being prepared as part of TMI modification program.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit I Page 10 Component Type:
Level Switches SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Categor Deficiencies Response/Resolution 17(26)
LS-73 Magnetrol IB Qualification Pending New sump level monitoring equip m/n A153FVPKTDM Modification ment has been installed. Documen tation is being prepared as part of TMI modification program.
S
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 11 Component Type:
Electrical Penetrations SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 72(44)
Penetrations Amphenol IIA Documentation not adequate; Qualifiable. Documentation based Aging; Qualified Life/
on vendor type testing will be Replacement :Schedule; performed.
Profile Envelope; Spray 71(45)
Penetrations Conax IA NA Qualified.
70(43)
Penetrations Viking IIA Documentation not adequate; Additional evaluation to assess Profile Envelope; Steam; material capability and circuit Spray; Radiation applications will be performed.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 12 Component Type:
Electric Motors SCE SONGS-]
Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 44(52)
CV-525,527 Boston Gear m/n ADR IIA Documentation not adequate Will be replaced as part of Efcomatic valve modification.
45(51)
CV-526,528 Boston Gear m/n ADR IIA Documentation not adequate Will be replaced as part of 49(51)
CV-515,516 Efcomatic valve modification.
11(47)
G-45A,B Chempump IIA Documentation, not adequate Qualified by analysis for interim m/n GPS-60L-46H-3T operation. Additional evaluation to assess long-term qualification will be performed.
21(48)
G-27A,B Westinghouse m/n AALG HC Aging; Qualif'ied Life/
Qualified. Documentation is in Replacement Schedule; progress.
Aging Program 5(49)
G-3A,B Westinghouse Type CS IIA Documentation not adequate Preliminary evaluation indicates steam is the only outstanding item. Additional evaluation to resolve this concern will be performed.
16(46)
G-8A,B Westinghouse CSP motor IV Documentation not provided Preliminary evaluation indicates m/n 65F15619 steam is the only outstanding item. Additional evaluation to resolve this concern will be performed.
62(50)
G-10 Westinghouse IIA Documentation not adequate Preliminary evaluation indicates steam is the only outstanding item. Additional evaluation to resolve this concern will be performed.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 13 Component Type:
Electrical Cables/Splices SCE SONGS-1 Equipment NRC/TER Item # ID Number Description Category Deficiencies Response/Resolution 65(59)
Cable General Electric IIA Documentation not adequate; Qualifiable. Documentation based m/n Vulkene Similarity; Qualified Life/
on vendor type testing is being Replacement Schedule performed.
66(53)
Cable General Electric IIA Documentationinot adequate; Qualifiable. Documentation based m/n FP-EPR Neoprene Similarity; Aging; Qualified on vendor type testing is being Life/Replacement Schedule; performed.
Aging Program; Submergence 67(54)
Cable Raychem IA NA Qualified.
m/n Flamtrol 68(56)
Cable Rockbestos IA NA Qualified.
m/n Firewall III & SIS 69(55)
Cable Various IV Documentation not provided Previous qualification evaluation is being reviewed against new environmental profiles. Cables previously qualified for contain ment use are still qualified. For other cables, the materials of construction and circuit require ments are being evaluated to establish qualification.
73(39)
Cable Splices Raychem m/n Thermofit IA NA Qualified.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 14 Component Type:
Position Switch SCE SONGS-1 Equipment NRC/TER Item # ID Number Description Category Deficiencies Response/Resolution 44(35)
CV-525,527 Trombetta IIA Documentation not adequate Will be replaced as part of m/n SOL NA 702E1 Efcomatic valve modification.
45(36)
CV-526,528 Trombetta IIA Documentation not adequate Will be replaced as part of 49 36)
CV-515,516 m/n SOL NA 702E1 Efcomatic valve modification.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 15 Component Type:
Limit Switches SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 78(37)
PORV & Block NAMCo IIC Qualified Life/Replacement Qualified. Additional evaluation Valve m/n EA180-11302 & -12302 Schedule of qualified life/replacement schedule will be performed.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 16 Component Type:
Terminal Blocks SCE SONGS-1 Equipment NRC/TER Item #
ID Number Description Category Deficiencies Response/Resolution 75(40)
Terminal Block Various IA NA Replaced with qualified Raychem Thermofit Splices [see SCE let ters dated 4/28/81 and 5/18/81].
Southern California Edison Southrn Cliforia EisonEnvironmental Equipment Quali fi'cation San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 17 Component Type: RTD SCE SONGS-1 Equipment Item #
ID Number DescriptionNC/E Category Deficiencies Response/Resolution 61(38)
TE-606 Foxboro m/ DB-13V-26W IIA Documentation not adequate Evaluating'modification of lead wires to establish qualification.
Also evaluating safety function of this component to see if required.
79(41)
TE-400 thr u Weed m/ 2004 lB Qualification pending Replaced with new qualified Weed
-422 A,B,C modification RTDs. Documentation is being pre pared as part of TMI modification program.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 18 Component Type: Radiation Detector SCE SONGS-1 Equipment NRC/TER Item # ID Number Description Category Deficiencies Response/Resolution 87(42)
R-1232 TracerLab m/n AX-22 IB Qualification Pending Qualified General Atomic radia Modification tion monitors have been installed. Documentation is being prepared as part of TMI modification program.
Southern California Edison Environmental Equipment Qualification San Onofre Nuclear Generating Station TER Resolution Status Unit 1 Page 19 Component Type:
Valve Positioner SCE SONGS-1 Equipment NRC/TER Item # ID Number Description Category Deficiencies Response/Resolution 19(57)
FCV-1115D,E,F Honeywell m/n IS HE-1 IB Qualification pending Replaced with qualified equip modification ment. Documentation and develop ment of maintenance intervals has been prepared.
6(58)
HV-851 thru Teledyne IV Documentation not provided Previous qualification is being
-854 A,B m/n 02112-002-5210 and reviewed to incorporate new
-003-5210 environmental profiles.
ADDITIONAL INFORMATION REQUESTED BY NRC GENERIC The qualification documentation should reflect the similarity between the tested component and the installed component.
An adequate time for margin should be justified in the qualification documentation.
The effect of failed equipment following completion of the safety function should be addressed in the qualification documentation.
Adequate justification should be provided for those components considered exempt. This should include the effect of failure of the component in the harsh-environment.
Analysis alone will not be accepted for a steam environment.
As part of the qualification of components, the effects of failure of component local controls should be addressed.
Motorized Valve Actuators In the event that it is necessary the check valve in series with MOV 850A, B and C should be included in the JCO.
The Franklin TER dated June 28, 1982 for MOV 18 and 19 (TER Item No. 5) indicates the valves are actuated upon safety injection initiation. This information is based on SCE's February 24, 1982 submittal.
This is to clarify that MOV 18 and 19 are not automatically actuated upon safety injection. The operator remote manually opens the valves to begin long-term recirculation.
The response for MOV 18 and 19 should be the same as that for MOV 356, 357 and 358 (TER Item No. 3).
A basis for the exemption of MOV 880 from qualification should be provided.
The discussion will include the effect of valve failure in the harsh environment and if necessary, the check valve in series in the JCO.
Solenoid Valves The qualification of solenoids should include consideration of normally energized solenoids for valve life.
A basis for the exemption of SV 702 A, B, C and D from qualification should be provided. The discussion will include the effect of valve failure in the harsh environment.
The Atkomatic solenoid valves will be replaced with qualified valves as part of the Efcomatic valve replacement.
-2 Transmitters As part of the qualification documentation for Foxboro transmitters, the electrical interface should be addressed.
Electric Motors The Boston Gear Motors will be replaced with qualified components as part of the Efcomatic valve replacement.
The analysis for 6-45 A and B should not only include a materials analysis but also the mechanical aspects of the material should also be addressed following exposure to the harsh environment. The operability of the motor should also be addressed. The Franklin TER identifies items to be specifically addressed.
Cable Consideration should be given to developing a surveillance program for cable.
Terminal Blocks Terminal blocks in safety related circuits inside containment have been replaced with qualified Raychem splices. The NRC was informed of the replacement by letter dated May 18, 1981.
This information is included in the Franklin TER dated June 28, 1982 under TER No. 40.
Franklin TER Components required to operate following submergence should be qualified for those conditions.
AL:0794F ADDITIONAL INFORMATION ON RESOLUTION OF EQ DEFICIENCIES
- 1. Motorized Valve Actuators The field data regarding these actuators has been obtained.
Limitorque will be contacted to identify the applicable test data for each actuator. A qualification evaluation based on the field and test data will be performed. The evaluation will address similarity, aging, qualified life and replacement schedule for each actuator.
- 2. Solenoid Valves ASCO solenoid valves will be evaluated for qualification based on operation time. This will be done utilizing available engineering reports and test data. The evaluation will address the similarity, aging, qualified life and replacement schedule for each solenoid valve if qualification is possible. The Valvair solenoid valves have been determined to be part of cold shutdown equipment and are therefore not part of this equipment qualification effort.
- 3. Transmitters The field data regarding these transmitters has been obtained. Foxboro will be contacted to determine the internal modification of the ElO series transmitters.
Based on this information, the transmitters will be evaluated for qualification. The evaluation will include similarity, aging, qualified life and replacement schedule.
- 4. Electrical Penetrations Qualification testing documentation for the Amphenol penetrations is available. Additional evaluation will be performed to address aging, qualified life, chemical spray and the profile envelope to complete the existing documentation. The qualfilcation of the Viking penetrations will be addressed based on testing of other Viking penetrations and analysis.
- 5. Electric Motors Field data on Westinghouse motors has been obtained. Available test data will be reviewed and Westinghouse will be contacted if necessary to determine the applicable test data. A qualification evaluation based on this information will be performed to address similarity, aging, qualified life and replacement schedule. The evaluation will also include motor lead splices, motor bearing and lubrication.
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- 6.
Electrical Cable Qualification documentation for General Electric and Vulkene cable exists. The documentation will be utilized to address similarity, aging, qualified life and replacement schedule. For the cable identified as various, the cable manufacturers have been identified and available test data will be determined.
ACL:2483F RESPONSE TO NRC Letter dated May 9, 1984 By letter dated May 9, 1984, the NRC staff requested additional information regarding the environmental qualification program at San Onofre Unit 1. This responds to that request.
- 1.
Submit all applicable JCO's that are currently being relied upon and certify the following for each JCO associated with equipment that is assumed to fail:
No significant degradation of any safety function or misleading information to the operator as a result of failure of equipment under the accident environment resulting from a design basis event will occur.
Response
JCO's for all equipment items in the San Onofre Unit 1 environmental qualification program have been developed. They incorporate a reference to the specific 10 CFR 50.49(1) section which provides acceptable criteria for JCO's.
- 2. The licensee should certify that in performing its review of the methodology to identify equipment within the scope of 10 CFR 50.49(b)(2) that the following steps have been addressed:
- a. A list was generated of safety-related electric equipment as defined in paragraph (b)(1) of 10 CFR 50.49 required to remain functional during or following design-basis Loss of Coolant Accident (LOCA) or High Energy Line Break (HELB) Accidents. The LOCA/HELB accidents are the only design-basis accidents which result in significantly adverse environments to electrical equipment which is required for safe shutdown or accident mitigation. The list was based on reviews of the Final Safety Analysis Report (FSAR), Technical Specifications, Emergency Operating Procedures, Piping and Instrumentation Diagrams (P&IDs), and electrical distribution diagrams;
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Response
As indicated on page 2 in paragraph 1 of the letter the method for identifying safety related electrical equipment is described. The list of equipment was provided to the NRC by letters dated October 31, 1980 and November 4, 1981.
The list was determined by review of the FSAR, emergency operating procedures and other relevant sources which include P&IDs, Tech. Specs.
- b. The elementary wiring diagrams of the safety-related electrical equipment identified in Step 1 were reviewed to identify any auxiliary devices electrically connected directly into the control or power circuitry of the safety-related equipment (e.g., automatic trips) whose failure due to postulated environmental conditions could prevent required operation of the safety-related equipment and;
Response
As part of the ECCS single failure evaluation, which resulted in two submittals to the NRC dated December 21, 1976 and December 20, 1977, the wiring diagrams were reviewed. The results of that review were documented in the report Separation and LOCA Environment Assessment of San Onofre Unit 1 ECCS dated December, 1977.
The recommendations made in the report are being addressed and resolved as part of the Systematic Evaluation Program. Specific recommendations included installing power interrupt devices on various safety-related and non-safety related pump motors, valve operators and instrumentation inside containment and rerouting control and power cable for certain redundant safety-related equipment.
- c.
The operation of the safety-related systems and equipment were reviewed to identify any directly mechanically connected auxiliary systems with electrical components which are necessary for the required operation of the safety-related equipment (e.g., cooling water or lubricating systems).
This involved the review of P&IDs, component technical manuals, and/or systems descriptions in the FSAR.
Response
The review of auxiliary systems was included as part of the development of the list of safety-related electrical equipment.
- d.
Nonsafety-related electrical circuits indirectly associated with the electrical equipment identified in Step 1 by common power supply or physical proximity were considered by a review of the electrical design including the use of applicable industry standards (e.g.,
IEEE, NEMA, ANSI, UL, and NEC) and the use of properly coordinated protective relays, circuit breakers, and fuses for electrical fault protection.
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Response
As discussed on pages 2 and 3 of the letter a review of nonsafety-related circuits affecting safety-related circuits was not included as part of the environmental qualification review. However, the letter does indicate that a specific review of nonsafety-related equipment is not necessary since other efforts are in effect doing this. The other efforts include IE Bulletins, Circulars and Information Notices, Fire Protection Program and the Systematic Evaluation Program.
- 3.
Provide certification that all design basis events which could potentially result in a harsh environment, including flooding outside containment, were addressed in identifying safety-related electrical equipment within the scope of 10 CFR 50.49(b)(1).
Response
As discussed on page 2 in paragraph 1 of the letter the design basis events include LOCA and HELB. Flooding outside containment was also addressed as part of the effects of non-Category A equipment failure.
ACLlorens:2337F