ML17254A933

Forwards Resolution of Environ Qualification Issues Noted in Franklin Research Ctr 820528 Technical Evaluation Rept TER C5257-454 & NRC 821213 Ser.Discussion of Conformance w/10CFR50.49 Encl

ML17254A933
Person / Time
Site:	Ginna
Issue date:	08/30/1984
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Paulson W Office of Nuclear Reactor Regulation
References
NUDOCS 8409060321
Download: ML17254A933 (36)

Text

REGULATORY %FORMATI044 DISTRIBUTION SAM (RIBS)

ACCESSION! NBR; 8409060321=

DOC e DATE > 84/08/30 NOTARIZED e NO DOCKET A'ACIL:50~244 Robert Emmet Ginna Nuclear Planti Unit ii Rochester G

05000244 AUTHBYNAME'UTHOR AFFILIATION KOBERiR,I'I, Rochester Gas 8 Electric Corp.

RECIP ~ NAME RECIPIENT AFFILIATION PAULSON<H.

Operating Reactors Branch 5

SUBJECT:

Forwards resolution of environ qualification, issues",noted in Franklin Research Ctr 820528 Technical Evaluation Rept'ER C5257 454 8,

NRC 821213 SER,Discussion of conformance w/10CFR50.49 encl'ISTRIBUTION CODE:

A048D COPIES RECEIVED:LTR ENCL g

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TITLE: OR/Licensing Submittal!

Equipment Qualification NOTESiNRR/DL/SEP 1cy.

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~rzutz i uiVZlN izrIIII ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649-0001 ROGER W. KOBER VICE PRESIDENT ELECTRIC &STEAM PROOIICTION TfICPHONE AREA COOK Tld 546-2700 August 30, 1984 Director of Nuclear Reactor Regulation Attention:

Mr. Walter Paulson Operating Reactors Branch No.

5 U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

Environmental Qualification of Electrical Equipment R. E. Ginna Nuclear Power Plant, Docket No. 50-244

Dear Mr. Paulson:

This letter concerns the resolution of environmental quali-

.fication issues noted in the Franklin Research Center Technical Evaluation Report, FRC TER C5257-454, dated May 28,

1982, and transmitted with the NRC's Safety Evaluation Report by letter dated December 13, 1982.

This resolution of issues is provided in Enclosure l.

Also provided, as Enclosure 2, is a discussion of RG&E conformance with the Environmental Qualification Regulation, 10CFR50.49, in particular paragraphs (b)(1), (b)(2),

and (b)(3).

Since RG&E has installed all equipment required to be environmen-tally qualified at this time, there are no Justification for Continued Operation included in this submittal.

This information had previously been -discussed in a meeting between RG&E and the NRC on April 17, 1984.

y truly yours, Enclosures ger W. Kober

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Enclosure 1:

Resolution of Xssues Defined in FRC TER C5257-454

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION Solenoid Valves (SOV's) for PM I.b Control Valves documentation, Similarity, Aging, Life/Replacement, Aging Program, Environmental Envelope Replacement with Qualified ASCO Solenoid Valves SOV's for Feedwater Bypass Valves I.b Documentation, Similarity, Aging, Life/Replacement, Aging Program, Environmental Envelope Replacement with Qualified ASCO Solenoid Valves SOV's for Nash Valves III.b Not in Scope SOV's for Main Steam Isolation Valves - Supply I.b Documentation, Similarity, Aging, Life/Replacement, Aging Program, Environmental Envelope Replacement with Qualified Valcor Solenoid Valves SOV's for Main Steam Isolation Valves - Vent SOV's for Containment Recirculation Dampers I.b I.b Documentation, Similarity, Aging, Life/Replacement, Aging Program, Environmental Envelope Documentation, Similarity, Aging, Life/Replacement, Aging Program, Environmental Envelope Replacement with Qualified Valcor Solenoid Valves Replacement with Qualified ASCO Solenoid Valves SOV's for SI Recirculation Valves Not in Scope SOV's for Containment Purge Valves I;b Documentation, Aging, Life/

Replacement, Environmental Envelope, Radiation Replacement with Qualified ASCO Solenoid Valves SOV's for Containment Depressurization Valves I.b Documentation, Aging, Life/

Replacement, Environmental Envelope, Radiation Replacement with Qualified ASCO Solenoid Valves 10 SOV's for Pressurizer PORV's II.a Similarity not Established Similarity Analysis Provided By Ref.

77 SOV's for Control Room Dampers Not in Scope 12 Limitorque MVA's SMB-2 for MOV 841, 865 III.a Exempt

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13 14 DESCRIPTION Iimitorque MVA's SMB-00 for MOV's 826A-D; 896 A,B Limitorque MVA's SMB-00 for MOV's 825 A,B NRC CATEGORY II.c II.c DEFICIENCIES Qualified Life Qualified Life PROPOSED RESOLUTION WCAP 7410-L, Ref.

18, Specifies 40 Yr. Life WCAP 7410-L, Ref.

18, Specifies 40 Yr. Life 15 16 17 Limitorque MVA's SMB-00 for MOV's, 4007,

4008, 4027, 4028; 4000 A>B Limitorque MVA's SMB-00 for MOV's 850 A,B; 857 A>B>C; 856; 860 A-D> 704 A,B Limitorque MVA's SMB-00 for MOV s 851 A>Bj 878 B>D> 878 A>C III.a Exempt II.c Qualified Iife III.a Exempt - 851 A,B; 878,B,D Conditional - 878 A,C Note 1 on page 4b of the Franklin TER has been resolved by submittal of RGB letter of December 15, 1983, from Maier to Crutchfield, "Environmental Qualification". ~

WCAP 7410-L,.Ref.

18, Specifies 40 Yr. Iife 878 A,C are locked-closed.

This has 'been found acceptable by the NRC.

See RGSE letter of February 1, 1983 from Maier to Crutchfield, "Environment'al Qualification".

18 Limitorque MVA's SMB-1 for MOV's 852 A,B II.c Qualified Life WCAP 7410, Reference 18, Specifies 40 Yr. Life 20 21 Limitorque MVA's SMB-00 for III.b MOV's 9703 A,B; 9704 A,B; 9710 A,B Auxiliary Feedwater Pump Motors III.b Containment Spray Pump Motors III.b Not in Scope Not in Scope Not i.n Scope These motors can see a

harsh radiation environment

'from Post-LOCA recirculation.

Reference 69 provides radiation qualification to 1 x 10

Rads, which is greater

)han the worst-case 2.8 x 10 Rads calculated for this location.

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION 22 Component Cooling Water Pump Motors III.b Not in Scope 23 Residual Heat Removal Pump Motors III.b Not in Scope These motors could see a

harsh radiation environment from Post-LOCA recirculation.

Ref.

69 provides qualification data to 1 x 10

Rads, which is substantially higher than the worst-case rgdiation dose of 2.8 x 10 Rads.

24 Auxiliary Feedwater Pump Motors III.a Exempt Note 1 on page 46 of the Franklin TER has been resolved by RGB letter of December 15,

1980, from Maier to Crutchfield, "Environmental Qualification"..

25 Safety Injection Pump Motors III.b Not in Scope These motors could see a

harsh radiation environment from Post-IOCA recirculation.

Ref.

69 provides qualification data to 1 x 10

Rads, which is substantially higher than the worst-case rgdiation dose of 2.8 x 10 Rads.

26 27 Service Water Pump Motors Hydrogen Recombiner Blower Motors III.b II.c Not in Scope Qualified I,ife WCAP 7410-L notes motor was qualified.7-year continuous duty operation at 150 C.

Since motor is used only.for periodic operability tests, and is located in an ambient environment of about 50~C, it is judged that a 40-year qualified life is assured.

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"DESCRIPTION NRC CATEGORY DFZICIENCIES PROPOSED RESOLUTION Note:

The.motor-to-lead splice has been replaced with a qualified Raychem splice sleeve.

28 29 Charging Pump Motors RHR Cooling Fan Motors III.b Not in Scope II.a Documentation Similarity RG&E has reviewed the referenced qualification

document, Ref. 69, Westinghouse Report 71-,1C2-RADMC-R1, and concluded that all materials which could have been used in the motors are qualified for at. least 1 x 10

Rads, which is greater thgn the worst-case 2.8 x 10 Rads.

Qualified Life Per Ref; 69, an expected operating life of 20 years is noted.

Since these motors are not used continuously, and are operated at their maximum rating, a

life of 40 years can be

expected, considering the routine maintenance program in place at Ginna Station.

30 Cooling Pans for Charging, Containment Spray, and Safety Injection Pump Motors II.a Documentation Similarity RG&E has reviewed the referenced qualification

document, Ref. 69, Westinghouse Report 71-1C2-RADMC-Rl, and concluded that all materials which could have been used in the motors are qualified for at least 1 x 10

Rads, which is greater thgn the worst-case 2.8 x 10 Rads.

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION Qualified Life Per Ref. 69, an expected operat'kg life of 20 years is noted.

Since these motors are not used continuously, and are operated at their maximum rating, a

life of 40 years can be

expected, considering the-routine maintenance program in place at Ginna Station.

31 Grouse-Hinds Electrical Containment.Penetrations I.a Qualified 32 Westinghouse Electrical Containment Penetrations I.a Qualified Westinghouse Terminal Blocks I.b Aging Degradation Qualified Life/Replacement

Spray, Submergence, Radiation These terminal blocks have been replaced by fully-qualified Raychem sleeves.

34 Xerite Power Cable in Containment II.a Similarity, Radiation Reference 78 provides the results of qualification testing of Kerite cable, includigg radiation dose of 2 x 10

Rads, as well as a materials/sizing similarity evaluati'on.

Based on this information, the Kerite cable is considered fully environmentally qualified~

Note that the Beta Radiation issue is addressed by RG&E's qualification level of 2 x 10 Rads.

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DESCRIPTION NRC CATEGORY'EFICIENCIES PROPOSED RESOLUTION 35 Kerite Control Cable Inside Containment II.a Similarity Radiation Reference 78 provides the results of qualification testing of Kerite cable, includigg radiation dose of 2 x 10

Rads, as well as a materials/sizing similarity evaluation.

Based on this information, the Kerite cable is considered fully environmentally qualified.

Note that, the Beta Radiation issue is addressed by RG&E's qualific on

.level of 2 x 10 Rads.

36 Kerite Cable Outside Containment I.a Qualified 37 Coleman Instrument Cable Inside Containment II.a Qualified Life, Radiation Reference 51 states aging performed equivalent to 40 yr.

Radiation qualification per Ref.

51 and 9/7/81 letter>

documents minimum of 4.1 x 10

Rads, which is greater t)an DOR guidelines of 2 x 10 Rads.

Coleman Cable Outside Containment II.a Qualified Life IPCEA S-61-402 (Ref.

10) provides aging requirements for this cable.

Since this cable is outside'ontainment, and the only harsh environment is gamm~

radiation, aging is not a major concern.

Radiation Ref.

76 provides confirmation that the PVC cable is adequate for a radiation dose of 7 x 10

Rads, which is greater than the maximum expected radiation level at )he cable location of 3 -x 10 Rads.

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION 39 Rome Cable Outside Containment II.a Qualified Iife IPCEA S-61-402 (Ref.

10) provides aging requirements for this cable.

Since this cable is outside containment, and the only harsh environment is gamma radiation, aging is not a major concern.

Radiation Ref.

76 provides confirmation that the PVC cable.is adequate6 for a radiation dose of 7 x 10

Rads, which is greater than the~

maximum expected-radiation level at (he cable location of 3 x 10 Rads.

40 General Cable Outside Containment II.a Qualified Life IPCEA S-61-402 (Ref.

10) provides aging requirements.for this cable.

Since this cable is outside containment, and the only harsh environment is gamma radiation, aging is not a major concern.

Radiation Ref.

76 provides confirmation that the PVC cable is ad'equate6 for a radiation dose of 7 x 10

Rads, which is greater than the maximum expected radiation level at )he cable location of 3 x 10 Rads.

41 RUST Ievel Transmitter Aging Qualified Life/Replacement Aging Program This transmitter has been replaced with a fully-qualified NE-10 series Foxboro transmitter.

EST Level Switch III.b Not in Scope The level switch has been replaced with a fully-qualified NE-10 series Foxboro transmitter.

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION 43 Steam Line Flow Transmitter II.a Documentation Similarity These transmitters have been replaced with fully-qualified NE-10 series Foxboro transmitters.

44 Containment Pressure Transmitters III.b Not in Scope These transmitters have been replaced with fully-qualified NE-10 series Foxboro transmitters.

45 Pressurizer Pressure Transmitters I.b Aging, Qualified Life/

Replacement, Aging Program,

Spray, Submergence, Radiation, Test Sequence These transmitters have been replaced with fully-qualified NE-10 series Foxboro transmitters.

46 Steam Line Pressure Transmitters I.b

Aging, Qualified life/Replacement, Aging Program These transmitters have been replaced with fully-qualified NE-10 series Foxboro transmitters.

47 Pressurizer Level Transmitters I.b Aging, Qualified I.ife/

Replacement, Aging Program

Spray, Submergence, Radiation, Test Sequence These transmitters have been replaced with fully-qualified NE-10 series Foxboro transmitters.

48 Boric Acid Storage Tank Transmitters II.c Qualified Life These transmitters perform their function prior to Post-LOCA sump recirculation.

Further, they are located in an area which would not be subject to a harsh-environment.

Thus, these transmitters should be considered outside the scope of this review.

49 Steam Generator Level Transmitters I.b Documentation These transmitters have been

.replaced with fully-qualified NE-10 series Foxboro'transmitters.

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TER ITEM NO.'ESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION 50 Resistance Temperature Detectors II.a Inside Containment Documentation, Aging, Qualified Life/Replacement, Aging Program, Environmental Envelope, Radiation, Test Sequence The Hot Leg RTD's which supply input to the saturation meter have been re'placed with fully-qualified Conax RTD's (see reference 79).

The Cold Ieg RTD's are not at this time used by RGB as a primary safety-related input following an accident which would result, in a harsh environment (it would not be considered a category 1 or 2 instrument per RG 1.97). If this situation changes-during the RG 1.97 review, the Cold Leg RTD's will be treated appropriately (see 3/30/84 letter).

51 52 Batteries Diesel Generator Engine and Controls III.b Not in Scope III.b Not in Scope 53 54 55 Generator and Controls III.b Reactor Containment Fan Cooler Motors II.a DG Fuel Oil Transfer Pump Motor III.b Not in Scope Not in.Scope Similarity The lead-to-cable splice has been replaced with fully-qualified Raychem splice sleeves.

The Rotanium grease is no longer used.

Chevron NRRG grease, with a radiationgresistance of greater than 5 x 10 Rads, is used (see Ref. 80).

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED RESOLUTION Note that the motor-to-lead splice is an int'egral part of the motor, and was qualified with the motor.

Qualified Iife/Replacement WCAP 7410-L, Reference 18, specifies a;40-Year life for RCFC motor components, including insulation materials and lubricants.

Radiation The motor was qualified for a total radiation dose of 2 x 10

Rads, and is considered qualified for both gamma and beta radiation (see RGB's letter of 2/1/83, item 55b).

Another FRC concern related to dose rate.

Since that time, Regulatory Guide 1.89 and NUREG/CR-2089 have concluded that standard gamma simulators can adequately, duplicate damage from both ambient and accident radiation environments.

Since these standard simulators were used in the qualification of the Ginna RCFC motors, the radiati~

qualification is considered fully acceptable.

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56 DESCRIPTION Reactor Trip Breakers NRC CATEGORY II.a DEFICIENCIES Documentation PROPOSED RESOIUTION WCAP-7706-L, submitted to NRC by letter of Nov. 6, 1981, provides a qualitative evaluation of the effects of adverse temperature and. humidity conditions (p. 3-22) on the trip breakers.

Since the postulated accident conditions are relatively mild (215~F, 0.8 psig, 100$ RH), the trip breakers perform. their function

.- within seconds,-they are physically located two floors away from th~

postulated accident condition (pipe crack),

and subsequent long-term failure of the trip breakers could not cause the control rods to be withdrawn from the core, RG&E considers the trip breakers-environmentally qualified to perform their safety function.-

57 Reactor Coolant Pump Breakers II.a Documentation These breakers are not subject to a harsh environment when the safety function is required (small break cold leg IOCA inside containment).

These breakers are located in the Turbine Building.

Further, FRC has st~

that "from a strictly determin~ic viewpoint, there is no objection to the licensee's response".

RG&E considers this item to be not in the scope of the "harsh" environment qualification review.

58 59 60 I&C Cabinets/Controls Relay Racks Control Room HVAC III.b Not in Scope III.b Not in Scope III.b Not in Scope

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DESCRIPTION NRC CATEGORY DEFICIENCIES PROPOSED JZSOLUTION 61 62 Cable Splices Inside Containment I.a Containment Sump "B" I,evel Transmitters Qualified Documentation These transmitters have been replaced with fully-qualified t'ransmitters (see Ref. 81).

63 Hydrogen Recombiner Igniter Exciter Units I.b Documentation One parallel path for these pressure switches for each recombiner have been replaced with fully-qualified NE-10 series Foxboro transmitters.

64 65 NAMCO Limit Switches LVDT for Pressurizer Safety Valves Position Indication I.b Similarity Radiation Similarity was established in RG&E's 2/1/83 letter, where the installed switches were identified as model EA180-11302, identical to those tested and fully environmentally qualified.

The new units, model no.

500XS-ZTR, have been installed.

These are fully environmentally qualified, as noted in the Franklin TER.

66 Head Vent Valcor Solenoid Valves II.a Similarity The installed valves are V52600-6042, which are qualified as noted. by Reference 73.

67 Containment Pressure Transmitters I.b Documentation, Similarity, These transmitters have been Aging, Qualified Life/Replacement, replaced with fully-qualified Aging Program NE-10 series Foxboro transmitters.

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Enclosure 2:

RGEE Com liance with 50.49 1.

Paragraph (b)(1) of 10CFR50.49 requires that safety-related electrical equipment remain functional during and following design basis events, which are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena.

During the April 17 meeting between RG&E and the NRC, RG6E was requested to "...confirm by an auditable documentation trail that the post-accident harsh environment assumed for the purposes of the equipment qualification program envelopes the worst-case conditions, and those environmental profiles and assumptions have been approved by the NRC".

A series of evaluations were performed for Ginna Station during the Systematic Evaluation Program, of all high and moderate energy line breaks and cracks, and equipment failures, which could result in a harsh environment inside and outside containment including the effects of flooding.Reference documents used to generate the list of required equipment included the FSAR, Technical Specifications, Emergency Procedures, PAID's, and electrical distribution diagrams.

The results of all these

analyses, were evaluated in the designation of appropriate design. basis conditions for RGGE's environmental qualification,program.

The complete list of safety-,related electrical equipment considered by RG&E to require environmental qualification for a harsh environment is included 'in the Franklin TER C5257-454, except as supplemented by TMI items in RGGE's March 30, 1984 submittal.

The design basis environmental qualification envelope was provided to FRC, and reviewed and found accept-able in Appendix A of the TER.

For information and documentation

purposes, the specific SEP topic Safety Evaluation Reports applicable to this review are:

ao b.

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SEP Topic III-5.A, "Effects of Pipe Break On Structures,

Systems, and Components Inside Containment".

SEP Topic III-5.B, "Pipe Break Outside Containment".

SEP Topic VI-2.D, "Mass and Energy Release for Possible Pipe Break Inside Containment".

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SEP Topic IX-3, "Station Service and Cooling Water S ys tems".

SEP Topics XV-1, XV-2, XV-3, XV-4, XV-5, XV-6, XV-7 g XV-8, XV-10, XV-12, XV-14, XV-15, XV-17, "Design Basis Events Accidents and Transients",

September 4, 1981.

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September 24, 1981 and March 3, 1982.

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SEP Topic XV-19, Loss of Coolant Accidents (Radiological)

September 29,

1981, and Loss of Coolant Accidents (System),

October 2, 1981.

Paragraph (b)(2) of 10CFR50.49 requires assurance that non-safety-related electrical equipment will not fail under postulated environmental conditions'uch that it could prevent satisfactory accomplishments of the required safety functions by safety-related equipment.

RGGE has performed, through the Systematic Evaluation Program and other reviews, numerous evaluations of the possible effects of non-safety-related equipment on safety-related functions, as defined in 50.49.

These evaluations, which have been reviewed and approved by the

NRC, show that no adverse effect on the required safety functions will occur as a result of such interactions.

During the course of these evaluations, auxiliary equipment connected electrically and/or mechanically to the required safety-related equipment was reviewed to determine if failures due to the postulated environmental conditions could adversely affect the required safety functions.

Also, associated circuits were reviewed to assure that failure would not prevent the required safety functions, because of the existence of properly coordinated protective relays, circuit breakers, and fuses for electrical fault protection.

The following Safety Evaluation Reports or RG6E correspondence are among these considered applicable to the review:

a ~

b.

SEP Topic III-12, "Environmental Qualification of Electrical Equipment",

dated December 15, 1980 (considered acceptable in Franklin TER C5257-454, item 15 and 24).

SEP Topic III-10.A, "Thermal Overload Protection for Motor Operated Valves",

SER dated August 3, 1981.

c.

SEP Topic,IV-2,'Reactivity Control System",

SER dated May 26, 1981.

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SEP.Topics VI-10.A and VI-7.A.3, "Testing of Reactor Trip System 'and ESF's Including Response Time Testing",

and,"ECCS 'Actuation'System'!,,,SER dated November 27, 1981.

e.

SEP Topic VI-7.C.1, "Appendix K Electrical Instrumentation and Control Reviews",

SER dated November 27, 1981, updated September 28, 1983.

SEP Topic VI-7.F, "Accumulator Isolation Valves Power and Control System Design",

SER dated June 24, 1981.

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SEP Topic VII-1.A, "Isolation of Reactor Protection System from Non-Safety Systems, Including Qualifiction of Isolation Devices",

SER's dated December 20, 1980 and July 30, 1981.

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SEP Topic VII-2, "Engineered Safety Features System Control Logic and Design",

SER dated December 28, 1981.

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SEP Topic VII-7, "Acceptability of Swing Bus Design",

RG&E letter of February 13, 1979.

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SEP Topic VII-4, "Electrical Penetrations of Reactor Containment",

SER dated October 8, 1981.

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10CFR50 Appendix R Alternative Shutdown System, RG&E letter and report dated January 16, 1984.

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Post-accident flooding effects on ECCS Valve Controlsg RG&E letters dated May 20, 1975 and May 30, 1975.

Based on these

analyses, RGGE concludes that. no additional equipment falls within the scope of 10CFR50.49(b)(2).

Paragraph (b)(3) requires that certain post-accident moni-toring equipment (referenced to a footnote specifying RG1.97) be included in the environmental qualification review.

The RG&E evaluation of Regulatory Guide 1.97 is being conducted separate from the Environmental Qualification Program, as part of the review of Supplement 1 to NUREG-'737.

A letter concerning RGSE's position relative to Regulatory Guide 1.97 was sent to the NRC on January 31, 1984.

Post;accident monitoring equipment which RG&E presently uses to provide necessary operator information (such as required Emergency Procedure indications) has previously been incor-porated into the list of instrumentation within the scope of the environmental qualification review, and meets RGSE's requirements.

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