ML17054B361

Safety Evaluation Supporting Environ Qualification of Electric Equipment Important to Safety

ML17054B361
Person / Time
Site:	Nine Mile Point
Issue date:	01/10/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML17054B360	List: ML17054B359 ML17054B361
References
NUDOCS 8502010719
Download: ML17054B361 (30)

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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT, UNIT NO.

1 DOCKET NO. 50-220 ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY 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 Design 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 equip-ment 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 Oualification of Safety-Related Electr'.cal Equipment" (which supplements IEEE Standard 323 and various NRC Regu'atory Guide."and industry standards),

and "Guidelines for Evaluating Environmental Qualif'.cation of Class 1E Electrical Equipment in Operating Reactor's" (DOR Guidelines).

t BACKGROUND i

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,

",Environmental Qualification of Class 1E 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.

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OCR 05000220 PDR AD pDR

On January 14,

1980, NRC issued IEB 79-01B which included the DOR Guidelines and NUREG-0588 as attachments 4 and 5, respectively.

Subsequently, on tray 23,

1980, Commission Memorandum and Order CLI-80-21 was issued and stated that the DOR Guidelines and portions of NUREG-0588 form the requirements that licensees must meet regarding environmental qualification of safety-related electrical equipment in order to satisfy those aspects of 10 CFR 50, Appendix A, General Design Criterion (GDC) 4.

Supplements to IEB 79-01B 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, documenting the qualification of safety-related electrical equipment.

The October order required the establishment of a central file location for the maintenance 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 8,

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 equipment.

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 oualification 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 documentation for safety-related electrical equipment located in harsh environments required for Tl1I Lessons Learned Implementation.

A Technical Evaluation Report (TER) was issued by FRC on August 26, 1982.

A Safety Evaluation Report was subsequently issued to the

Niagara Mohawk Power Corporation on December 20, 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, 1983.

This rule, Section 50.,49 of 10 CFR 50, specifies the requirements of electrical equipment important to safety located in a harsh environment.

In.accordance with this rule, equipment for Nine Mi le Point 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,'sing the guidance of Regulatory 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 acceptabi lity of the environmental conditions for equipment qualification purposes, if this issue had not yet been resolved.

On March 15,

1984, a meeting was held to discuss Niagara Mohawk Power Corporation's proposed method to resolve the environmental qualification deficiencies identified in the December 20, 1982 SER and August 26, 1982 FRC TER.

Discussions also included Niagara Mohawk Power Corporation's general methodology for compliance with 10 CFR 50.49, and justification for continued operation for those equipment items for which environmental'ualification is not yet completed.

The proposed method of resolution for each of the environmental qualification deficiencies are documented in the May 31, 1984 submit.al from the licensee.

EVALUATION The evaluation of the acceptability of the licensee's electrical equipment environmental qualification 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 December 20, 1982 SER and August 26, 1982 FRC TER; (2) compliance with the requirements of 10

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CFR 50.49; and (3) justification for continued operation (JCO) for those equipment items for which the environmental qualification is not yet completed.

Pro osed Resolutions of Identified Deficiencies The proposed resolutions for the equipment environmental qualification deficiencies, identified in the December 20, 1982

SER, and the FRC TER enclosed with it, are-described in the licensee's May 31, 1984 submittal; During the March 15, 1984 meeting 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 deficiencies acceptable.

The majority of deficiencies identified were documentation, similarity, aging, qualified life and replacement schedule.

All'open items identified in the SER dated December 20, 1982 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 of 10 CFR 50.49, and therefore not required to be environmentally qualified, e.g.,

located in a mild environment.

!le discussed the proposed resolutions in detail on an item by item basis with the licensee during the March 15, 1984 meeting.

Replacing or exempting 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 we did not review the additional analyses or documentation, we 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 licensee's equipment environmental qualification files will be audited by the staff during follow-up inspections to be performed by Region 1, with assistance from IE Headquarters and NRR staff as necessary.

Since a

significant amount of documentation has already been reviewed by the staff and Franklin Research

Center, 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 s'urvei llance 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 our discussions with the licensee and our review of its submittal, we find the licensee's approach for resolving the identified environmental qualification deficiencies acceptable.

Com liance With 10 CFR 50.49 In its Hay 31, 1984 submittal, the licensee has described the approach used to identify equipment within the scope of'aragraph (b)(1) of 10 CFR 50.49, equipment relied upon to remain function during and following design basis events.

The licensee states that a review of plant safety analysis, technical specifications and emergency operating procedures is the basis for determining che systems required to mitigate the effects of the postulated LOCA and HELB accidents.

The LOCA and HELB accidents provide the limiting environmental conditions to which safety-related equipment would be exposed.

Electrical One Line Diagrams, Elementary Wiring Diagrams, Emergency Operating Procedures, Functional Logic Diagrams, and Piping and Instrument Diagrams (P8 ID) were reviewed concurrently to determine the role of individual electrical components in supportinq the operation of systems identified.

Application of system/component failure analysis was performed to identify the electrical equipment which requires environmental aualification.

Flooding and environ-mental effects resulting from all postulated design-basis accidents documented in the Nine t1ile Point Unit 1 Final Safety Analysis Report (FSAR), including Loss-of-Coolant and High Energy Line Break Accidents (HEI B) inside primary containment were considered.

The flooding and environmental effects resulting

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from High Energy Line Breaks (HELBs) in secondary containment, were also considered in the identification and qualification of this equipment.

Therefore, all design basis events at Nine Nile Point Unit 1 were considered within the scope of Paragraph (b)( 1) of 10 CFR 50.49.

The licensee's approach for identifying equipment within the scope of paragraph (b)(l) 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:

l.

A list was generated of safety-related electric equipment as defined in par'agraph (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 C

mitigation.

The list was based on reviews of the Plant Safety Analysis, Technical Specifications, Emergency Operating Procedures, Piping and Instrumentation Diagrams (PSIDs), Electrical One Line Diagrams, Elementary lliring Diagrams and Function Logic Diagrams.

2.

The Elementary Miring Diagrams, Function Logic Diagrams, One Line Diagrams and PSIDs o

the safety-related electric equipment identified in Step 1 were utilized for a system fai lure analysis to identifv 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 the required operation of the safety-related equipment; and

3.

The operation of the safetv-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 a system failure analysis utilizing P&IDs, Plant Safety Analysis, Emergency Operating Procedures and Function Logic Diagrams.

4.

Nonsafety-related electrical circuits i'ndirectly associated with the electrical equipment identified in Step 1 by common power supply or physical proximity were considered by system failure analysis of the original electrical design including the use of properly coordinated protective relays, circuit breaker's, and fuses for electrical fault protection.

The licensee states that the results of the above review indicated that no additional electrical equipment was identified which was not previously included on the Hay 31, 1984 Master List.

Therefore, the list of electrical equipment provided in its submittal is judged by the licensee to address all electrical equipment within the scope of paragraph (b)(2) of 10 CFR 50.49.

We find the methodology 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.

lilith regard to paragraph (b)(3) of 10 CFR 50.49, the licensee evaluated existing system arrangements and identified equipmcnt for the five types of variables defined in R.G.

1.97, Rev.

2.

A report outlining the results of the review, schedules for modifications where necessary, and justification of deviations not requiring modifications has been submitted to the iRRC for approval.

. Since the report is still under review by the staff, some of the equipment identified in the report has not been added to the 10'FR 50.49 scope.

However, some of the eouipment items jointly within the scope of HUREG-0737 and R.G.

1.97 have been included in the 10 CFR 50.49 scope.

When the R.G.

the report and equipment lists contained therein have been finalized and accepted by the staff, appropriate equipment not already in the 10 CFR 50.49 scope will be added in accordance with the R.G.

1.97 implementation schedule.

We find 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 0 eration The licensee has provided, in its tray 31, 1984 submittal, justification for continued operation addressing each item of equipment for which the environmental qualification is not yet completed (see enclosure for the JCO equipment list).

We have reviewed each JCO provided by the licensee in its Hay 31, 1984 submittal and find them acceptable since they are based on essentially the same criteria that were used by the staff and its contractor to review JCO's previously submitted by licensees.

These criteria, listed below, are also essentially the same as those contained in 10 CFR 50.49(i).

a.

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.

b.

Partial test data that does not demonstrate full qualification, but provides a basis for concluding the equipment will perform its function.

If it cannot be concluded from the avai lable data that the equipment will not fai 1 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.

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c.

L'imited 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 a significant degradation of any safety function or provide misleading information to the operator.

CONCLUSIONS Based on the above evaluation, we conclude the following with regard to the qualification of electric equipment important to safety within the scopeof 10 CFR 50.49.

.o Niagara Mohawk Power Corporation's electrical equipment.environmental qualification program complies with the requirements of 10 CFR 50.49.

o The proposed resolutions for each of the environmental qualification deficiencies identified in the December 20, 1982 SER and FRC TER are acceptable.

o Continued operation until completion of the licensee's environmental qualification program will not present undue risk to'the public health and safety.

ENCLOSURE JUSTIFICATION FOR CONTINUED OPERATION EQUIPMENT LIST Nine Mile Point Unit 1

Ta Number.

TE 1B08-26-11, 12,13, 14, 15, 21, 22, 23,

& 24 TE IG01A, B, C

D TE 70-23 SV/IV 39-05, 06; SV39-05E,

05F, 06E, 06E PT 36-07A, B, C, D

36-8A, B, C, D

FT 06A, B, C, D

FT RV-26A, 268 LT 58-05, 58-06 FT 80-49A, 56A, 71A, 76A 93-30A, 32A, 33A, 34A LT 1G06A, B

LT 60-22, 23 FT 202-92A, 49A FTRD-15 PTID-46A, 46B LT lA-12 H81-23, 24, 03, 04 H81-49, 50, 51, 52 M80-03, 04, 23, 24 NC 08A, 08B H202-33, 53 NRC TER Number 32 None 22 17 27 29 39 80 None None None None 25 38 44 42 43 None None Descri tion Hinco Nickel Temperature Elements Pall Trinity Temperature Elements Pall Trinity Temperature Elements ASCO/Va 1cor Solenoid Valves Rosemount Transmitters Rosemount Transmitters Rosemount Transmitters Rosemount Transmitters GE/MAC Transmitters GE/HAC Rosemount Transmitters GE/HAC Transmitters GE/HAC Transmitters GE/HAC Transmitters GE/HAC Transmitter GE Motors GE Motors GE Hotors GE Motors GE Motors 10

Nine Mile Point Unit 1

Ta Number N70-01, 02, 03 IV 38-01, 38-13 SV 68-08G,68-09C, 68-10C SOV 40-32B,40-32C SV/BY-202-15, 16, 31, 32, 34, 35, 36, 37, 38, 74, 75 SY/IV05 lA/B>

2R 3R ~

-4A/B, -118,

-12A POS 39-11 to 14 POS 39-05, 06 POS 01-05, 06 POS 40-32, 33, POS 68-02, 03, 04, 05, 06, 07, POS 80-15, 16, 35, 36 POS 83. 1-10, 1-12 POS 201-08, 10, 16 POS 201. 2-33, 06 POS 201-32, POS 201-32, 03 POS 201.1-09, 11 POS 201. 2-109,

110, 111, 112 POS 201. 7-08, 09, 10, 11 POS 58.1-01 POS 122-03 NR-108A,B,C,D,E,F POS 01-01,02,03,04 SOV201. 2-01, 04 SOV201. 9-91, 92 S V/IV201. 2-06, 33 SV/IV201-08, 10, 16 SV/IV201. 1-09, 11 SV/I'V201.2-03,32 SV/IV201-32 NRC TER Number 41 None 18 None None None None 50 46 None 45 47 None None 49, 100 15,16 Description GE thotors Limitorque Valve Operators ASCO Solenoid Valves ASCO Solenoid Valves ASCO Solenoid Valves ASCO So 1enoid Valves Fisher Limit Switch Namco Limit Switch Namco Limit Switch Namco Limit Switch Namco Limit Switch Namco Limit Switch Namco Limit Switch Barksdale Pressure Switch Namco Limit Switch ASCO So 1eno id Valves 11

Nine Mile Point Unit 1

Ta Number NRC TER Number Descri tion SV/IV 80-15,16,35,36 SV/IV 58.1-01 SV/IV01-03, 04 SV/IV83. 1-10, 12 SOV IV201. 7-01 SOV I.V201. 7-02 SOV 201. 7-20 SOV 201. 7-21 SOV 201. 7-23 SOV 201. 7-26 SOV 201. 7-22 SOV 201.7-24 SOV 201. 7-25 SOV '201. 7-27 SOV 201. 2-419 SOV 201. 2-420 SOV 201. 2-421 SOV 201. 2-422 SOV 201.2-429 SOV 201. 2-430 SOV 201. 2-431 SOV 201.2-432 SOY 201.7-03 SOV 201.7-04 IV40-11 IY40-30,31 IV01-01, 02 IV33-01,02 IV83. 1-09, 11 IV110-127 IV31-07,08 SOV 122-03B,03A SVIY01-05, 06 Ll, L2 12 None None Hone None Hone 75 None None Hone Numatics Solenoid Valve ASCO Solenoid Valve

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ASCO Solenoid Valve ASCO So lenoi d Valve ASCO Solenoid Valves Limitorque Motor Operator Limitorque Motor Operators Limitorque Motor Operators Limitorque Motor Operators Limitorque Motor Operator Limitorque Motor Oper'ators ASCO Solenoid Valve Numatics Solenoid Valve Beckman Hydrogen-Oxygen Monitor 12

I

Nine Mile Point Unit 1

Ta Number NRC. TER Number Description 202-76 Hone FT-19,20,21,22,23,24 SOV 39-11C, 11D, 12C, 12D, 13C, 13D, 14C, 14D SOV 60-17D, 17E, 18D, 18E None None None None None MG-162, 172, 162CP, 172CP PB-16A, 16B, 17A, 17B MCC-155, 167, 161A/8, 171A/B BB-12 Hone Hone None None PS-R0-68A,B P S-70-108, 109, 110 None None None None None 55 63 64 66 67 None 62 72 94 60 52 53 None None Honeywell Electric Heater Kerite Insulating Tape Endevco Flow Transmitter

.Valcor Solenoid Valves Valcor Solenoid Valves J-M Duxseal Electrical Sealant 3M Insulation, Tape GE Electrical Sealant Westinghouse Terminal Varnish GE Insulation Tape General Electric HG Sets General Electric Circuit Breakers

'eneral Electric Motor Control Center and Battery Board Rockbestos Control Cable AMP Ring Tongue Terminal D.G. O'rien Containment Penetrations and Connectors General Electric Terminal Blocks Mercoid Pressure Switches Mercoid Pressure Swi'tches 13

V 'P

Nine Mile Point Unit 1

Ta Number NRC TER Number Descri tion BV05-05 BV05-07 BV93-25 BY93-26 BV93-27 BV93-28 IV201-31 IV33-04 IV39-07 IV39-08 IV39-09 IV39-10 IV110-128 IV201-07 IV201-09 IV201-17 IV34-01 IV38-02 IV40-05 IV40-06 IV80-01 IV80-02 IV80-114 IV80-115 IV80-21 IV80-22 IV81-01 IV81-02 IV81-21 IV81-22 1,4,5,6,8 9,73,74,76, 77,78 Limitorque Motor Operators LT36-03 A/B/C/D

-04 A/B/C/D

-05 A/B/C/D PT 201.2-476 A/B/C/D FT201. 8-35,41,45 FT201-9-26,31, 80 IV40-01, 09, 10 PSV NR-108A,B,C,D,E,F POS NR-108A,B,C,D,E,F TS18-10A,B,C,D,E,F,G,H PT 201. 2-483,484 PT 36-23A,B LT 36-24A,B SOV 122-04,05,06,07 08,09, 10, 11 None 35 30=

None.

'. 3,7 28 82 81 83 79 59 Rosemount Level Transmitters Rosemount Pressure Transmitters Fisher Flow Transmitters Limitorque Motor Operators GE/Unimax Solenoid Actuators and Position Switches Fenwal Temperature Switches Rosemount Pressure Transmitter Rosemount Pressure Transmitters Rosemount Level Transmitters ASCO Solenoid Valves AMP Cable Splice

Nine tiile Point Unit 1

Ta Number NRC TER Number Descri tion VCS68-11A,11B,12A,12B 13A,12B SV NC-15A,B,C,D,16A,B DPT01-26A,B,C,D,E,F,G,H DPT201. 2-476, A,',C, D DPT36-06A A,B,C,D LT 36-03A,B,C,D LT 36-04A,B,C,D LT 36-05A,B,C,D PT 36-07A,B,C,D PT 36-08A,B,C,D 201.7-36A, 37A Hone FET-664 None 37 13 19 20 86 65 71 Hercoid Vacuum Switches ASCO/Valcor Solenoid Valves Rosemount Pressure Switches Rosemount Pressure Switches General Atomic Radiation Detectors General Electric Cable Foxboro Flow Switch Kerite Cable 15

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