ML13324A571
| ML13324A571 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/11/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13324A569 | List: |
| References | |
| TAC-56906, TAC-67758, NUDOCS 8503150310 | |
| Download: ML13324A571 (16) | |
Text
SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1.
DOCKET NO. 50-206 ENVIRONMENTAL 00ALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY
1.0 INTRODUCTION
Equipment which is used to perform a necessary safety function must be demonstrated to be capable of maintaining functional operability under all service conditions postulated to occur during its installed life for the time it is required to operate. This requirement, which is embodied in General Desion Criteria 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 CFR 50, is applicable to equipment located inside as well as outside containment. More detailed requirements and guidance relating to the methods and procedures for demonstrating this capability for electrical equipment have been set forth in 10 CFR 50.49, "Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," NUREG-0588, "Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" (which supplements IEEE Standard 323 and various NRC Regulatory Guides and industry standards), and "Guide lines for Evaluating Environmental Qualification of Class lE Electrical Equipment in Operating Reactors" (DOR Guidelines).
2.0 BACKGROUND
On February 8, 1979, the NRC Office of Inspection and Enforcement (IE) issued to all licensees of operating plants (except those included in the systematic evaluation program (SEP)) IE Bulletin (IEB) 79-01, "Environ mental Qualification of Class lE Equipment." This Bulletin, together with IE Circular 78-08 (issued on May 31, 1978), required the licensees to perform reviews to assess the adequacy of their environmental qualification programs.
8503150310 850311 PDR ADOCK 05000206 P
2 On January 14, 1980, NRC issued IEB 79-OB which included the DOR Guidelines and NUREG-0588 as attachments 4 and 5, respectively. Subsequently, on May 23, 1980, Commission Memorandum and Order CLI-80-21 was issued and stated that the DOR Guidelines and portions of NIJREG-0588 form the require ments that licensees must meet regarding environmental qualification of safety-related electrical equipment in order to satisfy those aspects of 10 CFR Part 50, Appendix A, General Design Criterion 4. Supplements to IEB 79-OB were issued for further clarification and definition of the staff's needs.
These supplements were issued on February 29, September 30, and October 24, 1980.
In addition, the staff issued orders dated August 29, 1980 (amended in September 1980) and October 24, 1980 to all licensees. The August order required that the licensees provide a report, by November 1, 1980, document ing the qualification of safety-related electrical equipment. The October order required the establishment of a central file location for the main tenance of all equipment qualification records. The central file was mandated to be established by December 1, 1980. The staff subsequently issued a Safety Evaluation Report (SER) on environmental qualification of safety-related electrical equipment to the licensee on June 2, 1981.
This SER directed the licensee to "either provide documentation of the missing qualification information which demonstrates that safety-related equipment meets the DOR Guidelines or NUREG-0588 requirements or commit to a corrective action requalification, replacement (etc.))." The licensee was required to respond to NRC within 90 days of receipt of the SER.
In response to the staff SER issued in 1981, the licensee submitted additional information regarding the qualification of safety-related electrical equip ment. This information was evaluated for the staff by the Franklin Research Center (FRC) in order to:
(1) identify all cases where the licensee s response did not resolve the significant qualification issues, (2) evaluate the licensee's qualification documentation in accordance with established criteria to determine which equipment had adequate documentation and which did not, and (3) evaluate the licensee's qualification documentatinn for safety-related electrical equipment located in harsh environments required for TMI Lessons Learned Implementation.
A Technical Evaluation Report (TER) was issued by FRC on June 28, 1982. An
.3 SER was subsequently issued to the Southern California Edison Company on November 30, 1982 with the FRC TER as an attachment.
A final rule on environmental qualification of electric equipment important to safety for nuclear power plants became effective on February 22, 19F3.
This rule, Section 50.49 of 10 CFR Part 50, specifies the requirements of electrical equipment important to safety located in a harsh.environment.
In accordance with this rule, equipment for San Onofre Nuclear Generating Station, Unit 1 may be qualified to the criteria specified in either the DOR Guidelines or NUREG-0588, except for replacement equipment. Replacement equipment installed subsequent to February 22, 1983 must be qualified in accordance with the provisions of 10 CFR 50.49, using the guidance of Regula tory Guide 1.89, unless there are sound reasons to the contrary.
A meeting was held with each licensee of plants for which a TER had been prepared for the staff by FRC in order to discuss all remaining open issues regarding environmental qualification, including acceptability of the environmental conditions for equipment qualification purposes, if this issue had not yet been resolved. On December 20, 1983, a meeting was held to discuss Southern California Edison Company's proposed-method to resolve the environmental qualification deficiencies identified in the November 30, 1982 SER and June 28, 1982 FRC TER. Discussions also included Southern California Edison Company's general methodology for compliance with 10 CFR 50.49, and justification for continued operation (JCO) for those equipment items for which environmental qualification is not yet completed.
A submittal on July 30, 1984 from the licensee was inadequate to resolve the environmental qualification deficiencies identified by the November 30, 1982 SER and the June 28, 1982 FRC TER, as well as the general methodology for compliance with 10 CFR 50.49. Accordingly, an audit of the environmental qualification documentation files was held on October 2, 3 and 4, 1984, with additional discussions with the licensee on October 26, 1984. This audit and discussions resulted in additional licensee submittals of November 3 and November 19, 1984.
4 3.0 EVALUATION The evaluation of the acceptability of the licensee's electrical equipment environmental OuaIification program is based on the results of an audit review performed by the staff of:
(1) the licensee's proposed resolutions of the environmental qualification deficiencies identified in the November 30, 1982.
SER and June 28, 1982 FRC TER; (2) compliance with the requirements of 10 CFR 50.49; and (3) JCOs for those equipment items for which the environmental qualification is not yet completed.
Proposed Resolutions Of Identified Deficiencies The proposed resolutions for the eouipment environmental qualification deficiencies, identified in the November 30, 1982 SER, and the June 28, 1982 FRC TER enclosed with it, are described in the licensee's November 3 and November 19, 1984 submittals.
During the December 20, 1983 meetina with the licensee, the staff discussed the proposed resolution of each deficiency for each equipment item identified in the FRC TER and found the licensee's approach for resolving the identified environmental qualification defi ciencies acceptable. The majority of deficiencies identified were documentation, similarity, aging, qualified life and replacement schedule.
All open items identified in the SER were also discussed and the resolution of these items has been found acceptable by the staff.
The approach described by the licensee for addressing and resolving the identified deficiencies includes replacing equipment, performing additional analyses, utilizing additional qualification documentation beyond that reviewed by FRC, obtaining additional qualification documentation and determining that some equipment is outside the scope of10 CFR 50.49, and therefore not required to be environmentally qualified, e.g., located in a mild environment. The staff discussed the proposed resolutions in detail on an item by item basis with the licensee during the December 20, 1983 meeting. Replacing or exemptino equipment, for an acceptable reason, are clearly acceptable methods for resolving environmental qualification deficiencies. The more lengthy discussions with the licensee concerned the use of additional analyses or documentation. Although the staff did
5 not review the additional analyses or documentation, it discussed how analysis was being used to resolve deficiencies identified -in the FRC TER, and the content of the additional documentation in order to determine the acceptability of these methods. The staff concluded that the analysis used was acceptable. In addition to the audit performed in October 1984, the licensee's equipment environmental qualification files will be audited by the staff during follow-up inspections to be performed by Region V, with assistance from IE Headquarters and NRR staff as necessary.
Since a significant amount of documentation has already been reviewed by the staff and FRC the primary objective of the file audit will.be to verify that they contain the appropriate analyses and other necessary documentation to support the licensee's conclusion that the equipment is qualified. The inspections will verify that the licensee's program for surveillance and maintenance of environmentally qualified equipment is adequate to assure that this equipment is maintained in the as analyzed or tested condition.
The method used for tracking periodic replacement parts, and implementation of the licensee's commitments and actions, e.g., regarding replacement of equipment, will also be verified.
Based on discussions with the licensee and review of its submittal, the staff finds the licensee's approach for resolving the identified environ mental qualification deficiencies acceptable.
Compliance With 10 CFR 50.49 In its November 19, 1984 submittal, the licensee has described the approach used to identify equipment within the scope of paragraph (b)(1) of 10 CFR 50.49, equipment relied upon to remain functional during and following design basis events. The licensee states that the environmental effects (including flooding) from all postulated design basis accidents (both inside and outside containment) were considered in the identification of safety related electrical equipment to be environmentally qualified. These accidents include loss-of-coolant-accidents and the High Energy Line Break (HELB) inside containment, and various HELBs outside containment.
6 The equipment that is required to operate during these design basis accidents were identified by a review of the Final Safety Analysis Report, Emergency Operating Procedures, piping and instrumentation diagrams, Technical Speci fications and other relevant sources.
The licensee's approach for identifying equipment within the scope of paragraph (b)(1) is in accordance with the requirements of.that paragraph, and therefore acceptable.
The method used by the licensee for identification of electrical equipment within the scope of paragraph (b)(2) of 10 CFR 50.49, nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions, is summarized below:
The licensee stated that the identification of this equipment was accomplished as a result of compliance with a number of other efforts.
These efforts included a preliminary review performed as part of the fire protection review, a response to IE Information Notice 79-22 and other IE Information Notices, Bulletins and Circulars, and an Emergency Core Cooling System (ECCS) single failure evaluation. This ECCS evaluation involved not only the ECCS, but also the associated systems such as the component cooling water system, the containment spray system, the standby power system and the electrical power distribution system.
These ECCS evaluations utilized failure modes and effects analysis, which would identify those nonsafety related electric equipment items whose failure could prevent satisfactory accomplishment of safety functions, therefore, the staff finds the methodology being used by the licensee is acceptable since it provides reasonable assurance that equipment within the scope of paragraph (b)(2) of 10 CFR 50.49 has been identified.
With regard to paragraph (b)(3.) of 10 CFR 50.49, the licensee states that in preparation of the main list, many devices which provided control room indication for post-accident monitoring were included on the list (10 CFR 50.49 Section b(3)). In addition, Southern California Edison Company is currently addressing the requirements of Reg. Guide 1.97.
7 Additional monitoring eouipment may be identified as part of the resolution of Supplement 1 to NUREG-0737 and will be qualified as necessary to 10 CFR 50.49.
The staff finds the licensee's approach to identifying equipment within the scope of paragraph (b)(3) of 10 CFR 50.49 acceptable since it is in accordance with the requirements of that paragraph.
Justification for Continued Operation(JCO)
The licensee has provided, in its November 3, 1984 submittal, JCOs addressing each item of equipment for which the environmental qualification is not yet completed (see enclosure for the JCO equipment list).
The staff has reviewed each JCO provided by the licensee in its November 3, 1984 submittal and finds them acceptable since they are based on essentially the same criteria that were used.by the staff and its contractor to review JCOs previously submitted by licensees. These criteria, listed below, are also essentially the same as those contained in 10 CFR 50.49(i).
- 1.
The safety function can be accomplished by some other designated equipment that is qualified, and failure of the principal equipment as a result of the harsh environment will not degrade other safety functions or mislead the operator.
- 2.
Partial test data that does not demonstrate full qualification, but provides a basis for concluding the equipment will perform its function.
If it can not be concluded from the available data that the equipment will not fail after completion of its safety function, then that failure must not result in significant degradation of any safety function or provide misleading information to the operator.
- 3.
Limited use of administrative controls.over equipment that has not been demonstrated to be fully qualified. For any equipment assumed to fail as a result of the accident environment, that failure must not result in siqnificant degradation of any safety function or provide misleading information to the operator.
8
4.0 CONCLUSION
S Based on the above evaluation, the staff concludes the following with.regard to the oualification of electric equipment important.to safety within the scope of 10 CFR 50.49.
Southern California Edison Company's electrical equipment environmental qualification program complies with the requirements of 10 CFR 50.49 since all electrical equipment important to safety will be environ mentally qualified by March 31, 1985 or an alternative date reviewed and approved by the staff and since acceptable justification for continued operation has been provided for all equipment not currently qualified.
o The proposed resolutions for each of the environmental qualification deficiencies identified in the November 30, 1982 SER and FRC TER are acceptable.
Continued operation until completion *of the licensee's environmental qualification program will not present undue risk to the public health and safety.
5.0 ACKNOWLEDGEMENT This Safety Evaluation was prepared by P. Shemanski and W. Paulson.
Dated:
March 11, 1985
'1 ENCLOSURE Justification For Continued Operation Equipment List SONGS-1.
NRC Tac Number TER Number Description C75, C76 Westinghouse Hydrogen Recombiner Model B Conax Electrical Conductor Seal Assembly Model N-11001, N-11011 MOV 18, 19 5
Limitorque Motor Operator Model SMB-00/Class B 54 Raychem Control and Instrumentation Cable Flametrol Insulation LE 2001, LE 3001 Transamerica Delaval Level LE 2002 A, B, C Transmitter LE 3002 A, B, C Model XM-54852, XM-54853 RT 1255, 1257 General Atomic Radiation Monitor Model RD-23 TE-400 A, B, C 41 Weed Instrument Company PTP TE-401A/2401A Model Numbers:
TE-401 B, C 1D6E/6120-1A-D-6-C-16.5-0-0 TF-AUA1/3402A ID6E/612-1A-D-6-C-16.5-0-0 TE-402B, C TE-410 A, B, C
2 SO0NGS -1 N PC Tag Number TER Number Description TF-41 1A/341I1A TE-411B, C
TE-A12A/2412A TE-412B, C TE-420A, B, C TE-42 1A/342 1A TE-421 B, C TE-422A/2422A TE-422 B, C VPC 23, EPC 23 44 Amphenol Penetration Model 50020353 GI0S 50 Westinghouse Pump Motor Type ABDP G27 A, G27 B, 48 Westinghouse Pump Motors Model AALG G3 A, B 49 Westinghouse Pump Motors Type CS MOV 1100 B, C, D 1, 3 Limitorque Valve Motor Operators SMB-O0/Class B MOV 720 A 7
Limitorque ValVe Motor Operator SMB-O0/Class B f-OV 866 A, B 6
Limitorque Valve Motor Operator SMB-00/Class B 80V 880 Limitorque Valve Motor Operator SMB-00/Class B
3 SONGS-1 NRC Tao Number TER Number Description CV 51'. 516, 517 17, 35, 52 Paul Monroe Hydraulic 518, 525, 526 13, 36, 51, 16 Rotary Valve Operators 527. 528, 737A, Model Number PD 89423, 737 B PD 89425, PD=89426 PE 2001, 3001 Exo-Sensor, Inc.
TE 2001, 3001 Hydrogen Monitor Assemblies AEH2 2001, 3001 Drawing 1080001.
MOV 805 A, B, C 8
Limitoroue Motor Operators Model SMA-1/Class B Revere Corp.
Thermocouple Cable.
Model Number 16, Type JX Rockbestos Coaxial Cable Model RSS-6-104 G-45 A, G-45 B 47 Chempump Pump Motors Model GPS-60L-46H-3T FT 460, 461, 462 25 Foxboro Flow Transmitters Model E 11 DM Without MCA/RRW FT 912, 913, 914 22 Foxboro Flow Transmitters Model 630-2AS PT-425 32 Foxboro Flow Transmitter Model E 11 GM
4 SONGS-1 NRC Tac Number TER Number Description HV 851 A/B, 85?
/B,
- 58.
Teledyne Solenoid Valve 853 A/B, 854 A/B Actuators Model 02112-002-5210 and 02112-003-5210 FCV 1115, D, F, F 12, 57 Valve Actuator Assemblies Honeywell Positioner ASCO Solenoid Model 8300 TE 606 38 Foxhoro Temperature Element Model DB-13V-26W SV 19, 127 (CV40, 116) 64 ASCO Solenoid Valve Model WPLB 3800 SV 28 (CV 10) 70 ASCO Solenoid Valve Model WPLB 8300 SV 29, 30 (POV 9, 10) 63 ASCO Solenoid Valve Model 8345 SV 108, 110, 112 13 ASCO Solenoid Valve (CV 102, 104, 106)
Model WPLB 8300 SV 109, 111, 123 67 ASCO Solenoid Valve (CV 103, 105, 107)
Model WPLB 8300 SV 118, 128 (CV 114, 60, 62 ASCO Solenoid Valve
- 82)
Model WPLB 8300 SV 126 (CV 115) 61 ASCO Solenoid Valve Model WPLB 8300
5 SONGS-I NPC Taq Number TER Number Description SV 410, 411 ASCO.Solenoid Valve (CV 410, 411)
Model LB 8316 SV 702 A, B, C, D 14, 15 Marotta Solenoid Valve Model 583H-AA SV 1212-6, 7 68 ASCO Solenoid Valves (CV 146, 147)
Model WPLB 8300 FY 1202, 1203, 1204 ASCO Solenoid Valves
('V 202, 203, 204)
Model WPLB 8300 HV 1287 (CV 287) 69 ASCO Solenoid Valve Model WPLB 8300 55 Anaconda-Ericsson, Inc.
Power and Control Cable Silicone Rubber Insulation RT 1256 A, P General Atomic Company RT 1258 A, B Radiation Detector Model RD-1, RD-2A PY 3545, 2546, 2530, 65 ASCO Solenoid Valves 3531 (CV 545, 546, Model 8316 530, 531) 55 Rockbestos Instrumentation Cable PVC and Teflon Insulation EPC 4, WPC 7, WPC 9, 43 Vikino Industries Inc.
EPC 1, vPC 5 Electrical Penetrations Power and Control-480VAC
6 SONGS-1 NRC Tag Number TER Number Description WPC 3, WPC 4, 43 Viking Industries Tnc.
EPC 2, EPC 3 Electrical Penetrations Power and Control-480VAC 43 Viking Industries Inc.
Electrical Penetrations Power and Control-120VAC 56 Rockbestos Control and Instrument Cable Firewall EP Insulation 56 Rockbestos Control and Instrument Cable Firewall III Insulation 59 General Electric Power and Control Cable Vulkine Insulation 53 General Electric Power and Control Cable FR-EPR Neoprene Insulation E15, W16, EPC 11, 45 Conax Electrical Penetration 12 WCP 11, 13 Assemblies Model 7895 10000-02 Z50 2530, 3531.,
37 NAMCO Limit Switches 3545, 2546 Model EA-180 7SC 2530, 3531, 3545, 2546 ZSO 2300, 2301,
- 330, 3301 ZSC 2300,
- 2301, 3300, 3301
7 SONGS-I NRC Taq Number TER Number Description Mn',V 356. 357, 358
-3,. 7 Limitorque Valve Motor
- 720B, 883 Operators SMB-00/Class RH Motor Insulation G8 A, F 46 Westinghouse Pump Motors Type CSP 39, 40 Raychem Nuclear Inline Cable Splice Assemblies Model WCSF-N SV 532 A, 533 A 10, 11 ASCO Solenoid Valves 534 A, 535 A, 536 A, Model NP 8320 537 A (CVs 532, 533, 534, 535, 536, 537)
SV 3201, 3213 SV-1212-8, SV-1212-9, 71, 67, 66 Taroet Rock Solenoid Valves SV-119, SV-120, SV-1?1 Model 81A-001, 002, 003, SV-122, SV-123, SV-124 114; 79RR-003; 8OB-001-10; SV-125 A (CV-123), SV-3302, 80 EE-001 SV-3303, SV-2004, SV-3004, SV-2401, SV-2402, SV-2403 SV-2404, SV-3A01, SV-3402 SV-3403, SV-3404 55 Simplex Wire and Cable Company Power and Control Cable Anhydrex-XX Insulation 55 Rome Cable Company Cablie Pozone A/Roprene Insulation
8 SONGS-I NRC Tag Number TER Number Description
-5.
Okonite Power and Control Cable Okonex/Okoprene Insulation E13, E14, 43 Viking Industries Inc.
WI13, W4 Electrical Penetrations Instrument Penetrations TC & Twisted Pair Cable LT 3400, A, B, C 34, 30, 31 Foxboro Transmitters LT 2400 A, B, C 32, 18 Model N-E1O PT i121 A PT 1120 A PT 430, 431, 425 X1 PT 425 X 2 FT 456, 457, 458 PT 3000 A, B, C FTH 3453, 3454, 3455 FTL 3453, 3454, 3455 PT 2010, 3010 PT 2011, 3011 PT 2001, 3001 LT 430, 431, 432 29, 30, 31 Foxboro Transmitters PT 432 23, 20, 33 Model E-10 With MCA/RRW FT 500, 501 Modification PT 501, 502, 503 FT 504