ML13330A233

Environ Qualification of Safety-Related Electrical Equipment, Partial Review

ML13330A233
Person / Time
Site:	San Onofre
Issue date:	02/17/1981
From:	Office of Nuclear Reactor Regulation
To:
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ML13330A232	List: ML13330A231 ML13330A233
References
NUDOCS 8103060355
Download: ML13330A233 (20)

Text

PARTIAL REVIEW Equipment Evaluation Report By the Office of Nuclear Reactor Regulation For Southern CaEifornia dison Company Sat OnofffreNiwlear Generating Station, Unit No.

1 Docket No. 50-206 Environmental Qualification of Safety-Related Electrical Equipment Dated:

February 17, 1981 I~

86O~

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PARTIAL REVIEW EQUIPMENT EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR SOUTHERN CALIFORNIA EDISON COMPANY Sdn Onofre Nuclear Generating Station, Unit No.IL DOCKET No. 50-206 ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT 3.0 STAFF EVALUATION The staff's evaluation of the Licensee's responses was accomplished by performing an on-site inspection of selected Class IE equipment and by examining the Licensee's report for completeness and accept ability. The criteria described in the DOR Guidelines and NUREG-0588, in part, were used as a basis for the staff's evaLuation of the adequacy of the Licensee's qualification program.

During the week of JuLy 21, 1980, NRC and FRC representatives visited the San Onofre plant site, inspected safety-reLatedisystems and equipment, identi fied and tabuLated safety-related components through discussions with plant personneL, and conducted a general review of SCE's submittaL of June 18, 1980.

The inspection verified proper instaLLation of equipment, overaLL interface integrity, and manufacturers nameplate data. The manufacturer and modeL number from the nameplate data was compared to information given in the Licensee's submittaL.

The following-evaluation incorporates the SCE submittal and the FrankLin Research Center technical evaluation report (TER).

3.1 COMPLETENESS OF SAFETY-RELATED EQUIPMENT In accordance with the DOR guidelines, the Licensee was directed to estabLish a List of systems and display instrumentation needed to mitigate the consequences of a LOCA or HELB, inside or outside con tainment, and reach safe shutdown. The Lists of safety-related systems and display instrumentation were developed from a review of plant safety analyses and emergency procedures. The display instrumentation selected includes parameters to monitor overaLL plant performance as weLL as to monitor performance of the systems on the List. The systems List was estabLished on the basis of the functions that must be performed for mitigation of the consequences of a LOCA or HELB without regard to a potentially hostiLe environment. The staff has determined and verified that the systems considered by the Licensee are those required to achieve or support:

(1) emergency reactor shutdown, (2) containment isoLation, (3) reactor core cooLing, (4) containment heat removaL, (5) core residuaL heat removaL, and (6) prevention of significant release of radioactive materiaL to the environment. The staff concludes that the systems identified by the Licensee are acceptable with the exception of those items discussed in section 5.0 of this report. The systems and instrumentation List is contained in Appendix D.

The Licensee submitted an extensive List of safety-related electrical equipment.

The List was evaLuated and identicaL components within a plant area exposed to the same environment were grouped; 67 item types of equipment were identified and assessed by the staff.

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3.2 Service Conditions The Commission Memorandum and Order (CLI-80-21), dated May 23, 1980 requires that the DOR Guidelines and the "For Comment" NUREG-0588 are to be used as the criteria for estabLishing the adequacy of the safety related electrical equipment environmentaL qualification program. These documents provide the option of estabLishing a bounding pressure and temperature condition based on plant specific analysis identified in the Licensees FSAR or based on generic profiles using the methods identified in these documents.

On this basis the staff has assumed, unLess otherwise noted, that the analysis for developing the environmental envelopes for San Onofre relative to the temperature, pressure, and the containment spray caustics, have been performed in accordance with the above stated requirments.

For this review the staff reviewed the qualification documentation to ensure that the qualification specifications envelope the conditions estabLished by the Licensee. During this review the staff assumed that for plants, designed and equipped with an automatic containment spray system, which satisfies the single faiLure criterion, the main steam Line break environmentaL conditions are enveloped by the Large break LOCA environmental conditions. The staff assumed and requires that the Licensee verifies, that the containment spray system is not subjected to a disabling single component faiLure and therefore satisfies the DOR Guideline requirements of Section 4.2.1.

Equipment submergence has aLso been addressed where the possibility exists that flooding of equipment may result from high energy Line breaks (HELB).

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3.3 TEMPERATURE, PRESSURE, AND HUMIDITY CONDITIONS INSIDE CONTAINMENT The Licensee has provided the results of accident anaLyses as foLLows:

Max. Temp. ( 'F)

Max. Press. (psig)

Humidity LOCA 291 49.4 100%

MSLB Not Stated The staff has concluded that the minimum temperature profiLe for equipment qualification purposes should include a margin to account for higher than aaverage temperatures in the upper regions of the containment that can exist due to stratification especiaLLy foLLowing a postuLated MSLB. Use of the steam saturation temperature corresponding to the total building pressure (partial pressure of steam plus partial pressure of air) versus time wiLl provide an acceptable margin for either a postulated LOCA or MSLB, whichever is controLLing as to potential adverse environmental effects on equipment.

The Licensee's specified temperature (service condition) of 291*F does not satisfy the above requirement. A saturation temperature profiLe (297'F peak temperature at 49.4 psig) should be used instead. The Licensee shouLd update his equipment summary tables to reflect this change. If there is any equipment that does not meet the staff position, the Licensee must provide either justification that the equipment wiLL perform its intended function under the specified conditions or propose corrective action.

3.4 TEMPERATURE, PRESSURE AND HUMIDITY CONDITIONS OUTSIDE CONTAINMENT The Licensee has provided the temperature pressure, humidity and applicable environmetnal values associated with a HELB outside containment in the foLLowing plant area:

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1. Piping penetration building.

2. Outside containment sphere

3. Mezzanine under turbine deck

4. FueL storage building

5. Under turbine deck

6. Turbine deck extension

7. AuxiLiary building

8. Intake structure

9. ControL Administration Building

10. Condensate storage tank

11.

RefueLing water storage tank

12.

Diesel Generator Building The staff has verified that the parameters identified by the Licensee for the MSLB are acceptable.

3.5 SUBMERGENCE The maximum submergence Levels have been established and assessed by the Licensee. The staff assumed for this review, unLess otherwise noted, that the methodology employed by the Licensee is in accordance with the appropriate criteria as estabLished by the Commission Memor andum and Order (CLI-80-21), dated May 23, 1980. The Licensee's vaLue for maximum submergence is 13 feet 11 inches (eLev. 3 feet 11 inches).

The Licensee has not identified any equipment beLow this Level.

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3.6 CHEMICAL SPRAY The Licensee's FSAR value for the chemical concentration is boric acid and sodium hydroxide aqueous solution, 2500-3000 PPM boron and PH 10.5 to 9.0. The exact volume percent used by the vendors for qualification testing shouLd be verified by the Licensee. Therefore for the purpose of the review the effects of chemicaL spray wiLL be considered unresoLved.

3.7 AGING The DOR Guidelines, section 7, does not require a qualified Life to be estabLished for aLL safety reLated electrical equipment, however, the foLLowing actions are required:

1. Detailed comparison of existing equipment to the materials identifed in Appendix C of the DOR guidelines. The first supplement to IEB-79-01B requires the Licensees to utilize the table and identify any additional materiaLs as a resuLt of their effort.

2. Establish an ongoing program to review surveiLLance and maintenance records to identify potential age related degradations.

3. Establish component maintenance and repLacement scheduLes which include considerations of aging characteristics of the instaLLed components.

For this review the staff requires that the Licensee submit supplemental information to verify and identify their degree of conformance to the above requirements. The response shouLd be inclusive of aLL the equipment identified as required to maintain their functional operability in harsh environments.

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The staff wiLL review the Licensees response, when submitted, and report its evaluation in a supplemental report.

3.8 RADIATION (INSIDE AND OUTSIDE CONTAINMENT)

The Licensee has provided vaLues for radiation LeveLs postulated to exist foLLowing a LOCA event. The application and methodology employed to determine these vaLues have been presented to the Licensee as part of the NRC staff criteria contained in the DOR Guidelines, NUREG-0588 and the guidance provided in IEB-79-01B, Supplement 2. The staff's review assessed that the vaLues to which equipment was qualified, enveLoped the requirements identified by the Licensee. The vaLue estabLished 7

by the Licensee is 2 x 10 RADS for the integrated dose inside containment. The radiation service condition provided by the Licensee is Lower than provided in the DOR Guidelines for Gamma and Beta radiation.

The Licensee is requested to either provide justification for using the Lower service condition or use the service condition provided in the DOR Guide Lines for both Gamma and Beta radiation. If the former option is chosen then the anaLysis incLuding the basis assumptions, and a sample calculation shouLd be provided. A required vaLue estabLished outside containment of 6

4 x 10 RADS has been used by the Licensee to specify Limiting radiation LeveLs within the auxiLiary building. This value appears to consider the radiation Levels influenced by the source term methodology associated with Post-LOCA recirculation fluid Lines and is therefore acceptable.

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4.0 QUALIFICATION OF EQUIPMENT The foLLowing subsections are the staff's assessment, based on the Licensee's submittaL, and the Franklin TER of the qualification status of safety-related electrical equipment.

The staff has separated the safety-related equipment into three categories (1) equipment requiring immediate corrective action, (2) equipment requiring additional qualification information and/or corrective action, and (3) equip ment considered acceptable conditioned onLy on the satisfactory resoLution of the staff's concern identified in Section 3.7.

The NRC staff in its assessment of the Licensees submittaL and the TER did not review the methodology employed to determine the vaLues estab Listed by the Licensee. However, in reviewing the TER a determination was made by the staff as to the stated conditions presented by the Licensee. AdditionaLLy, the detaiLed review of supporting documentation referenced by the Licensee (e.g., test reports) has been completed by FRC.

The environmental qualification data bank to be established by the staff wiLL provide the means to cross reference each supporting docu ment to the referencing Licensee.

Where supporting documents were found to be unacceptable, the Licensee wiLL be required to take additional corrective actions to either establish qualification or replace the item(s) of concern. An appendix for each subsection is attached which provides a List of equip ment which requires additional information and/or corrective action.

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Where appropriate, a reference is provided in the appendices to identify deficiencies. It should be noted, as in the Commission Memorandum and Order, that the deficiencies identified do not necessariLy mean that equipment is unqualified. However, they are cause for concern and may require further case-by-case evaLuation.

4.1 EQUIPMENT REQUIRIING IMMEDIATE CORRECTIVE ACTION 4.2 EQUIPMENT REQUIRING ADDITIONAL INFORMATION AND/OR CORRECTIVE ACTION Appendix B identifies equipment in this category, including the tabuLation of their deficiencies. The deficiencies are noted by a Letter reLating to the Legend, identified beLow, indicating that insufficient information has been provided for the qualification parameter or condition.

R -

Radiation T - Temperature QT -

Qualification Time RT -

Required Time 9

P -

Pressure H -

Humidity CS -

Chemical Spray A -

Material Aging Evaluation, Replacement Schedule, Ongoing Equipment SurveiLLance S -

Submergence M -

Margin I -

HELB Evaluation Outside Containment Not Completed QM -

Qualification Method RPN - Equipment ReLocation or RepLacement, Adequate ScheduLe Not Provided EXN - Exempted Equipment Justification Inadequate SEN - Separate Effects Qualification Justification Inadequate QI -

Qualification Information Being Developed RPS -

Equipment ReLocation or RepLacement ScheduLe Provided.

As noted in Section 4.0, these deficiencies do not necessariLy mean that the equipment is unqualified. However, they are cause for concern and require further case-by-case evaLuations. The staff has determined that an acceptable basis to exempt equipment from qualification, in whole or part, can be estabLished provided the foLLowing can be estab Lished and verified by the Licensees:

(1) Equipment does not provide essential safety functions in the harsh environment and failure of it in the harsh environment wiLL not impact safety related functions or misLead an operator.

(2a) Equipment performs its function prior to its exposure to the harsh environment and the adequacy for the time margin provided is adequately justified, and 10

(2b) Subsequent failure of the equipment as a resuLt of the harsh environment does not degrade other safety functions or misLead the operator.

(3) The safety-related function can be accomplished by some other designated equipment that has been adequately qualified and satisfies thge single faiLure criteria.

(4) Equipment not subjected to a harsh environment as a result of the postuLated accident.

The Licensee is therefore required to supplement the information presented by providing their resolutions to the deficiencies identified which should include a description of the corrective action and scheduLes for its completion (as appLicable), etc. The staff wiLL review the Licensees response, when submitted, and report on the resolution in a supplementaL report.

It should be noted that where testing is presently being conducted, a condition may arise which results in a determination by the Licensee that the equipment does not satisfy the qualification test requirements.

For that equipment the Licensee wiLL be required to provide their proposed corrective action, on a timeLy basis, to assure that qualifi cation can be established by June 30, 1982.

4.3 EQUIPMENT CONSIDERED ACCEPTABLE OR CONDITIONALLY ACCEPTABLE Based on the staffs review of the Licensees submittaL and the TER the staff identified the equipment in Appendix C as (1) acceptable on the basis that the qualification program adequately enveloped the specific environmental plant parameters, or (2) conditionaLLy acceptable subject to the satisfactory resolution of the staff concern identified in Section 3.7.

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For the equipment identified as conditionaLLy acceptable the staff deter mined that the Licensee did not clearLy:

(1) state that a material evaLuation on their equipment was conducted to assure that no known materials susceptible to degradation due to aging have been used in their equipment.

(2) estabLish an ongoing program to review the surveiLLance and maintenance records of their plant in order to identify equipment degradation which may be age related, and/or (3) propose a maintenance program and repLacement schedule for equipment identified in item 1 or equipment that is qualified for Less than the Life of the plant.

The Licensee is therefore required to supplement the information presented for equipment in this category before fuLL acceptance of this equipment can be estabLished. The staff wiLL review the Licensees response, when submitted, and report on the resolution in a supplemental report.

5.0 DEFERRED REQUIREMENTS IE Bulletin 79-01B, Supplement 3 has reLaxed the time constraints for the submission of the information associated with coLd shutdown equipment and TMI Lessons Learned modifications. To permit a uniform program scheduLe the SEP plant reviews have been amended. The staff-required that this information be provided by February 1, 1981.

The staff wiLL provide a supplementaL 'Valuation addressing these concerns.

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APPENDIX B List of Equipment in Section 4.2, Equipment Requiring Additional Information And/Or Corrective Action NOTE: (R) Licensee has committed to replace equipment LEGEND:

DESIGNATION FOR Deficiency R -

Radiation M -

Margin T -

Temperature I -

HELB Evaluation Outside QT - Qualification Time Containment Not Completed RT -

Required Time QM -

Qualification Method P -

Pressure RPN -

Equipment ReLocation or Replacement, H -

Humidity Adequate Schedule Not Provided CS -

Chemical Spray EXN -

Exempted Equipment Justification A -

Material Aging Evaluation, Inadequate Replacement schedule, Ongoing SEN -

Separate Effects QuaLification Equipment SurveiLLance Justification Inadequate S -

Submergence QI -

Qualification Information Being Developed RPS -

Equipment ReLocation or Replacement Schedule Provided TER Equipment ModeL/

Item No.

Description Manufacturer Type Deficiency 5

Motor Byron Jackson DVMX QI 6

MOV Teledyne 02112-002-5210 QI 02112-003-5210 10 MOV Limitorque SMA-1-40 QM,A 12 MOV Limitorque SMB-000-5 QM,A 19A FLow ControLLer HoneyweLL IS HE-1 QI 19B SOV Operator ASCO 88300-B56R1 QI 21 MOV Limitorque SMB-00-25 QM,A 26 Transmitter Foxboro E13DM QM,A 27 SOV Operator ASCO WPLB QI 8300B59 B-1

APPENDIX B, Continued TER Equipment ModeL/

Item No.

Description Manufacturer Type Deficiency 28 Transmitter Foxboro E11GM QM,A 29 SOV Operator ASCO 8300861R QI 30 SOV Operator ASCO 8300B61 QI 31 SOV Operator ASCO WPLB8300B59 QI 32 SOV Operator ASCO WPLB8300B59 QI 33 SOV Operator ASCO WP831735 QI 34 SOV Operator ASCO WP831735 QI 35 SOV Operator ASCO WP8300-B61R QI 36 SOV Operator ASCO WPHTX832093 QI 37 SOV Operator ASCO WPLB-8300-B61RU QI 38 SoLenoid Moroffa valve MV-583H-4A QI 39 SoLenoid Moroffa valve MV-583H-4A QI 40 SOV Operator ASCO 8345C11 QI 41 SOV Operator ASCO WPLB-8300-B59RF QI 42 SOV Operator ASCO WPLB-8300-B59 QI 43 SOV Operator ASCO WPHTX832093 QI 44 SOV Operator ASCO WPHTX832093 QI 46 SoLenoid Atcomatic 3101 QI 48 SOV Operator ASCO WPLB8300B59 QI 49 SOV Operator ASCO WPHTX832093 QI 50 SoLenoid Atcomatic 3101 QI B-2

APPENDIX B, Continued TER Equipment Model/

Item No.

Description Manufacturer Type Deficiency 51 Transmitter Foxboro E11GM QM,A 58 SoLenoid VaLvair 5682-2 QI 66 Transmitter Foxboro NE13DM QM,A,QT 68 CabLe GE FR-EPR QM,S 79 Resistance Weed 2004 QI Temperature Instruments Detector 1

Transmitter Foxboro E11DNM QM,A,QT 3A Transmitter Foxboro NE11GM QM,A,QT 38 Transmitter Foxboro E11GM QMAQT 4

Transmitter Foxboro E13DH-QM,A,QT HFD-SAH1 9

Transmitter Foxboro 630-2AS QI 11 Motor Chempump GPS-60L QI 46H-3T 13 Transmitter Foxboro E13DM QM,A,QT 45 MOV GuLf & Western EBV-D2-2006 QI EBV-D3-15014 47 SOV Operator ASCO UNK QI 62 Temperature Foxboro DB-13V-26W QI Sensor B-3

APPENDIX C List of Equipment in Section 4.3, Equipment Considered Acceptable or ConditionaLLy Acceptable LEGEND: A -

Material Aging Evaluation TER Equipment ModeL/

Item No.

Description Manufacturer Type Deficiency 2

Transmitter Foxboro 613DM A

69 Cable FLamtroL UNK A

70 Cable Rockbestos FirewaLL A

III&SIS 72 ELectrical Conax UNK A

Penetrations 74 Cable SpLice Raychem Thermofit A

78 Limit Switch NAMCO EA-180 A

7 SOV Operator ASCO WPHT 8314 8

SOV Operator ASCO WPLB 8300B59 23 MOV Limitorque SMB-00 25 MOV Gulf & Western EBV D-6-300-7 15 MOV Limitorque SMB-10 A

18 MOV Limitorque SMB-00 A

24 MOV Limitorque SMB-00 A

60 MOV Limitorque SMB-00 A

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APPENDIX D A. Safe Shutdown Systems System Term Function Reactor Protection*

S Trips reactor when predetermined setpoints are exceeded ResiduaL Heat RemovaL+

L Long-term heat removal capability ChemicaL and Volume ControL*

L Provides reactor makeup water during cooldown/Long-term chemical controL.

Atmospheric Steam Dump Valves*

I ReLeases energy (steam) for decay heat removal and cooldown.

Component CooLing Water System L

Removes heat from the RHR heat exchangers/

transfers heat to the service heat system.

SaLt Water CooLing System L

Transfers heat from the component cooLing heat exchangers to the ocean.

AuxiLiary Feedwater System*

L Provides steam generator makeup water for decay heat removaL and plant cooldown.

ELectricaL Distribution System*

L Self-explanatory Reactor CooLant System I

Transfers heat from the reactor core to the steam generators Main Condenser System I

Transfers heat from the main steam system to the circuLating water system and the ocean.

Recirculatin System/Hot Leg L

Prevents boron precipitation during RecircuLation Long-term cooling.

+ Systems required for cold shutdown onLy.

• Systems which function both for safe shutdown and also for accident mitigating purposes.

(S) Short Term Less Than 24 Hrs.

(I) Intermediate Term Up to 30 Days (L) Long Term 30 Days PLus D-1

APPENDIX D, Continued B. Accident Mitigating Systems System Term Function Safety Injection System I

Provides cooLing water to the core post accident.

Containment Isolation System L

Isolates containment penetrations in case of accidents.

Containment Spray System I

Post-accident containment pressure and iodine controL.

ControL Room Air Conditioning L

Redundant, vitaL ventiLation system to System maintain controL room habitabiLity at aLL times.

Radiation Monitoring System L

Self-explanatory Instrument Air System I

Provides air for operating certain vaLves and other pneumatic service.

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APPENDIX D, Continued C. Accident Mitigation and Safety Shutdown Instruments RCS Temperature Steam Pressure Core Exit Thermocouples RCS Pressure Steam Generator LeveL D-3