ML17298A246

Forwards Discussion of TMI & IE Equipment Qualification Items Requiring Relief from Schedular Requirements,Per 821217 meeting.NUREG-0737,Items II.D.3,I.D.1,II.F.1.3, II.B.3 & II.F.2 Discussed Per SER (NUREG-0857)

ML17298A246
Person / Time
Site:	Palo Verde
Issue date:	03/14/1983
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Knighton G Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-0857, RTR-NUREG-737, RTR-NUREG-857, TASK-1.D.1, TASK-2.B.3, TASK-2.D.3, TASK-2.F.1, TASK-2.F.2, TASK-TM ANPP-23239-ACR, NUDOCS 8303170114
Download: ML17298A246 (24)

Text

REGULATO INl-ORMATION DISTRIBUTION TEM (RIDS)

ACCESSION NBR:8303170114 DOC ~ DATE: 83/03/14 NOTARIZED:

YES FACIL;STN 50-.528 Palo Verde Nuclear Station< Unit li Ar izona Publ i STN-50-529 Palo Verde Nuclear Stationi Unit 2i Arizona Publi STN-50 530 Palo Verde Nuclear Stationi Uni,t 3i Arizona Publi AUTH ~ NAME AUTHOR AFFILIATION VAN BRUNTiE,E, Ar izona;Publ ic Service Co, REiCIP ~ NAME RECIPIENT AFFILIATION KNIGHTONp G I Licensing Branch 3

SUBJECT:

For wards discussion of TMI 8 IE equipment qualification items requiring relief from schedular requirements per 821217 meet ing, NUREG-0737 i I tems 11,0,3i I ~ 0 ~ 1i II ~ F ~ 1 ~ 3g II,B.3 L II,F ~ 2 discussed per SER (NUREG-0857) ~

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PHOENIX, ARIZONA 65036 March 14, 1983 ANPP-23239 ACR/ECS Director of Nuclear Reactor Regulation Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Mr. G. Knighton, Chief

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN-50-528/529/530 File:

83-056-026 G.1.01.10

Reference:

1) NUREG-0857, "Safety Evaluation Report" related to the Operations of Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2

& 3 dated November, 1981

2) NUREG-0857, Supplement 1,

"Safety Evaluation Report" related to the Operation of Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and 3 dated February, 1982 3)

NRC Summary of Meeting to Discuss Schedule for Completion of Palo Verde Review dated December 17, 1982

Dear Mr. Knighton:

Since the accident at TMI, there have been many changes required in nuclear plants to enhance their safety.

APS has endeavored to be responsive to these changes and to expeditiously implement them at the Palo Verde Nuclear Generating Station (PVNGS).

However, for a variety of

reasons, we may not be able to fully implement all these items prior to our presently scheduled fuel load date.

The attached identifies those TMI and IE qualification items which we believe may require relief as discussed in our previous

meeting, Reference 3 ~

We do not believe that these delays will reduce the level of safety provided for PVNGS ~

While our review identifies all items we know of as of February 15,

1983, it is also possible that other items may suffer schedule slippages due to causes beyond our control.

We will notify you of any new problems as they are discovered.

8303i70li4 8303i4 PDR ADOCK 05000528 E

PDR

J Dt Jl<gt,

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Director of Nuclear Reactor Regulation ANPP-23239 ACR/ZCS Page Two We would like to meet with you to discuss this information on March 23, 1983.

Very truly yours, E. E. Van Brunt, Jr.

APS Vice President, Nuclear Projects ANPP Project Director EEVB/ECS/wp Attachment cc:

A. C. Rogers (w/attach.)

A.

CD Gehr K. Berlin E. Licitra C. Ferguson

I I

Director of Nuclear Reactor Regulation ANPP-23239 ACR/ECS Page Three STATE OF ARIZONA

)

) st COUNTY OF MARICOPA)

I, Edwin E.

Van Brunt, Jr.,

represent that I am Vice President, Nuclear Projects of Arizona Public Service

Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its

contents, and that to the best of my knowledge and belief, the statements made therein are true.

Edwin ED Van Brunt, Jr.

Sworn to before me thdd/ day of

, 1983.

Notary Public My Commission Expires:

0 (p"

C E

'ATTACHMENT A DISCUSSION OF TMI RELIEF ITEMS Based on a

review of our current August schedule for fuel load, we have identified two TMI items that will not be completed prior to that time.

We have also identified one additional item that may fall beyond fuel load,due to'rocurement

problems, and two additional items that are clarified herein as to implementation.

Equipment qualification concerns raised in our

meeting, (reference

3) are also addressed.

1.

TMI Re uirement NUREG-0737 Item II-D.3 Pressurizer Safet Valve Position The Palo Verde SER, reference 1,Section II.D.3 (page 22-16) confirmatory item states:

"The acoustic monitoring system to provide direct pressurizer safety valve position indication is to be installed and calibrated prior to fuel loading."

This item will not be completed prior to fuel load as required.

The cause for this delay is material procurement.

The acoustic monitoring system is an integral part of the Chemical and Radiological Analysis Computer System (CRACS) which also contains the Post Accident Sampling System (PASS),

see item 4 of this attachment.

At our scheduled fuel load, we will have the acoustic sensors

mounted, cable

pulled, display instrumentation installed, and the host computer mounted.

But, the computer will not be operational due to incomplete installation and thus, the loop and system will not have been tested.

It is expected that within approximately 90 days following fuel load, depending on containment

access, this system will be tested and operational.

In the interim period, the RTDs mounted on the safety valve tailpiece and the qualified reactor drain tank pressure indication will be used to monitor safety valve status.

These two methods of indication were the original design basis means of assessing a stuck open safety valve.

During part of the period after fuel load, the Reactor Coolant System will not be at pressure, so the safety valve status will not be required.

We have reviewed these methods from a

safety standpoint and find them acceptable.

Regulatory Guide 1.97, Rev.

2 was issued

December, 1980.

We studied with our valve vendor and NSSS supplier the various methods to provide this valve position indication.

An acoustic monitoring system was decided upon as the best design for our facility, and the procurement process began mid-year, 1981.

The purchase order (PO) was placed October 8, 1981 with a required delivery date of September 30, 1982'n an effort to assure

I m

w compliance with our delivery requirements, the followin'g special provisions were incorporated as

'part of the

'purchase

'order for this equipment:

1.

Monthly management and scheduling meetings 2 ~

Bi-monthly technical meetings 3.

Agreed to expedi,tious turnaround on vendor documentation approvals 4.

Contract penaltie's for late deliveries In spite of these provisions and related efforts, this PO sustained many delays while fine points of contract interpretation of scope and definition of design were resolved.

This situation has existed throughout the life of the contract.

To minimize the impacts of this situation on the schedule, our management spent (20-30X) of every month negotiating and expediting this vendor.

Since this is state-of-the-art equipment, there were many issues that arose with regard to the definition of the scope of the work included in the contract.

By

June, 1982, the vendor integration of

software, shipments by subvendors, and vendor testing program showed signs of slippage because of inadequate preplanning.

To provide additional assurance of delivery, we instituted the following additional measures:

1.

Placed APS and Bechtel people in the vendor's shop full time to expedite the preparation of the operating procedures and testing procedures.

2 ~

Assisted vendor in expediting subvendors.

3.

Provided, on call, APS and Bechtel contacts for clarification and resolution of scope items which may arise.

In spite of these efforts, the system is currently projected to be delivered on March 31,

1983, six months later than anticipated by contract.

Several specific areas have been major contributors to this delay:

1.

Computer software development problems 2.

Subvendor's lack of timely performance 3.

Untimely factory test procedure development 4.

Shipper accidently dropped (and extens'ively damaged)

PASS equipment on the last projected ship date

We are continuing to extend every effort to expedite and improve presently scheduled shipment date and subsequent installation and testing dates.

Plant installation of devices associated with and peripheral to the system is proceeding to allow for expeditious hookup when main equipment is delivered.

2.

TMI Re uirement NUREG-0737 Item I.D.1 Control Room Desi n Review The requirement, per the reference SER Supplement No.

1, Reference 2,

Section I.D.l (page 22-1) states:

"As stated in the

SER, there were a

number of systems and items due to the incomplete state of construction of the Unit 1 Control Room and the large amount of temporary equipment in the Control Room which were unavailable for review during the site visit either in whole or in part.

Using the guidance provided in Section 6 of NUREG-0700, "Guidelines for Control Room Design Reviews,"

the staff requires that the applicant perform an evaluation of those systems and items not

reviewed, which are repeated'below in more detail, and that the applicant submit its findings,',,proposed corrective

actions, and schedule for implementing the actions.

The report of these items shall be submitted for staff review and approval no later than 120 days before issuance of the operating license."

1 1

Such a report will not be completed for Items 1 to 9 and 13 listed in the SER Section

. I.D.l 120 days, prior to the presently scheduled date for receipt of" an operating license, for, PVNGS.

The reason for this delay is that the permanent features (such as

carpet, final balanced

HVAC, emergency equipment, procedures, communications equipment, restricted

access, personal

storage, and removal of temporary test equipment) will not be located in their respective final resting places until after Power Ascension Testing is completed.

The normal operating environment is scheduled to be present only after the heavy traffic and disturbance of start-up activity is completed.

We believe that with all the test equipment and staff involved in start-up, a restoration of the normal environment prior to this time is not currently feasible nor desirable.

We propose to complete reporting on the listed items as soon as the normal environment is restored (the "schedule milestone" is "installation of the carpet").

We believe that the extensive human factors review program undertaken by APS has identified and resolved 95X of all the discrepancies.

This review was performed on the PVNGS simulator which is a replica of the finished Unit 1 Control Room; this allowed a rather complete review prior to the construction completion of the Unit 1 Control Room.

We believe we have demonstrated to the NRC staff that the control room as configured, with discrepancies

resolved, will provide an environment for error-free operation of the plant.

Based on our evaluation of the improvement implemented and the scope of the remaining work, the postponement of the review of the listed items until the normal operating environment is established will not jeopardize plant safety.

l'f

SER Section I.D.l Items 10, ll, and 12 will be reviewed and reported 120 days prior to the issuance of the operating license as required.

3.

TMI Re uirement NUREG-0737 Item II F.1.3 Containment Hi h Ran e Monitor We have determined that this item has the potential of slipping beyond the scheduled fuel load date.

The referenced 1,

SER,Section II.F.1.3 (page 22-28) states:

"The staff will verify that installation is completed prior to issuance of an operating license."

The potential availability problem of mineral-insulated (MI) cable and connector for in-containment use is the limiting item.

The current forecast delivery date is May 30, 1983; the original delivery date was November 10, 1982.

This problem exists because of the failure of the original cable and connectors to pass the IE equipment qualification program.

The cable and connector qualification problem was identified by test failure November 19, 1982.

The vendor had to redesign and start new procurement activities on the redesigned cable and connector.

The MI cable and connector/cable interface 'were first-of-a-kind design.

At the time of qualification failure, the manufacture and delivery of the original configuration was on schedule.

The monitors and the indicators are currently installed, as is the raceway system for the cable.

We are currently meeting with the vendor weekly and have been since May 11, 1982 to expedite this procurement.

This expediting was stepped up after November 19, 1982'ny further cable or connector problems will carry testing of the system beyond the fuel load date.

4 ~

TMI Re uirement NUREG-0737 Item II.B.3 Post Accident Sam lin S stem The PVNGS Post Accident Sampling System (PASS) will not be operational at fuel load as discussed in Item 1 of this attachment.

However, this system is not required to be operational prior to exceeding 5X power operation as per the SER, Reference 1,Section II.B.3 (page 22-14) which states:

"Implementation of all the requirements is not necessary prior to low power operation because only small quantities of radionuclide inventory will exist in the reactor coolant system and therefore will not affect the health and safety of the public.

Prior to exceeding 5X power operation, the applicant must demonstrate the capability to promptly obtain reactor coolant samples in the event of an accident in which there is core damage consistent with the conditions stated below...

The above stated license conditions will have to be satisfactorily addressed by the applicant prior to exceeding 5% power operation."

I l,

tg At our scheduled fuel load, this system, will be installed but not tested, and therefore, not operational.

Currently, the system is projected to be functional prior to the 5X power operation level, as required.

5.

TMI Re uirement NUREG-0737 Item II.F.2 Instrumentation for Detection of Inade uate Core Coolin (ICC)

The requirement of the

SER, Reference 1,

Section II.F.2 (page 22-28) states:

"Therefore, the staff,will require the applicant to provide documentation of, their,ICC,system for staff review and approval prior to issuance of an operating license."

The equipment, Heated, Junction

'hermocouples (HJTC) and Core Exit Thermocouples (CETs), will be installed after fuel load.

The CETs are installed on the tips of the in-core instruments, which are installed at fuel load., The HJTC,probes'ill be installed after fit-up of the CEAs and modifications are comp1eted to the CEA space housing 'the HJTC probe.

This will occur after fuel load.

At fuel load, the computer display system will be installed, but since all the attached equipment 'will not be, the system will not be tested and therefore not operational.

However, the documentation, describing the ICC system will be provided prior to OL and will provide the final implementation schedule.

6.

IE E ui ment uglification The APS equipment qualification

program, started in 1975 and based initially on IEEE 323-1974 (and subsequently on NUREG-0588), is presently in progress and nearly complete, and has as its goal, the establishment of initial environmental and seismic qualification prior to fuel load.

This

,includes the identification of qualified lifetimes on all components or subcomponents, establishment of surveillance and periodic maintenance intervals and requirements, and determination of correct seismic mounting and operability.

However, even with our best efforts, it is possible, if not likely, based on history, that certain items may not be fully qualified prior to fuel load.

The potential reasons for this are

many, including but not limited to the following:

1.

Difficulties in reaching agreement with vendors regarding interpretation of IEEE and NRC requirements.

2. 'nexpected test failures.

I'.

Interpretation of TMI. Requirements (NUREG-0737), recently quantified in 10CFR Part 50.49.

4 Retro-fits found to be required in the last stages of testing and/or analysis.

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5.

Test failures in generic programs beyond the control of the end-user.

The latter are especially troublesome, as end user efforts are generally of no avail in their resolution.

Items described in IE Information Notice 82-52 are among those being qualified in programs outside the control of APS.

As such failures'o demonstrate qua1ification for these particular items are not detrimental to the APS program inasmuch as qualification for these items is being handled on an industry-wide basis.

I For these and for all other exceptional

'cases;

however, APS commits to provide a letter to the NRC prior to exceeding 5X power on PVNGS Unit 1, describing the current status of qualification efforts.

This letter will assess the safety implications of full power 'operation without completion of qualification and will provide justification for interim full power operation if considered appropriate by APS The following table is a list of specific exceptional cases presently forecast to exist at the time of fuel load with causes of delay and estimates of completion dates:

li II

Item No.

Scope Area Identif.

No.

Type of Cause Est.

Added E oi ment Destti gualff.

~of Dele

~Com lets Notes NSSS

& BOP CE-ICE-Limitorque VMAs 5731 JM-605 Env.

IE 82-52 None A

2 ~

NSSS CE-ICE-Barton Transmitters Env.

3535 IE 82-52 None B

3 ~

NSSS CE-PE-5734 Asco Sol. Valves Enve IE 82-52 None 4 ~

NSSS CE-ICE-Target Rock S.V"s 5733 Seis.

Test Fail.

12/1/83 5 ~

s NSSS CE-ICE-Valcor Sol. Valves 5733 Env.

Test Fail.

12/1/83 6.

NSSS

,CE-ICE-

- Namco Limit Sw's 5732 Env.

Test Fail.

12/1/83 E

7 ~

NSSS CE-ICE-RdF RTDs 3535 Env.

TMI-PAM 1st Refuel 8.

BOP JM-200 Comsip Customline Control Board Components Seis.

Vendor 12/1/83 Interpretation Difficulties No Testing Done 9.

BOP NM-993 Energy Sys.

Group Env.

Hydrogen Recombiners Testing 11/1/83 Delays 10.

BOP MM-018 Cooper Energy Svcs.

Diesel Generators Enve Vendor 12/1/83 Interpretation Difficulties NOTES:

A In-Containment Replace motors when qualified and available from Out-Of-Containment

'eplace torque and limit switches before first refueling outage DC Motors Replace reliance with Peerless Motors by 12/1/83 B

Have been unable to obtain anything from Barton indicating problem resolution, despite 82-52 status shown.

J

'f, II

C Pending generic resolution, refurbish items, some before fuel load if possible, some after, some at first refueling.

D This is a generic problem not identified by IE 82-52.

Date is conditional on Target Rock resources and problem resolution.

E Some refurbishment and replacement prior to fuel load, some after.

F Non-harsh environment; not applicable to NUREG-0588.

However, vendor has differred in response to specified requirements for IEEE 323 E.g.

On specific Item 7 '

the LOCA/MSLB qualification had to be modified due to TMI-Post Accident Monitoring (PAM) requirements.

There are many other components required to be TMI-PAM environmentally qualified which were heretofore non-class IE.

Also, additional equipment has been added to the plant to meet these NUREG-0737 requirements.

All of this TMI-PAM equiment is currently being qualified to the Category I requirements of NUREG-0588'n some cases such as instrumentation to detect inadequate core cooling, future

~equipment is expected to be added.

All present and future harsh environment class IE equipment will conform to NUREG-0588 Category I requirements as modified by Generic Letter No.

82-33 dated December 17, 1982.

All present and future mild environment and seismic required equipment wi11 conform to IEEE 323 and 344, respectively.

Further information and clarification concerning implementation and integra-tion of the NUREG-0737 requirements into PVNGS will be provided in our response to NUREG-0737 Supplement 1

scheduled for submittal on April 15, 1983.

This submittal will include clarifications of the scope of the system integrated and the schedule of implementation per the supplement, plus the discussions in the scheduled regional meetings.

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