ML17298A387

Final Deficiency Rept DER 82-39 Re C-E Valve Limit Switches (Class IE) Below Max LOCA Flood Level in Containment. Initially Reported on 820730.Bechtel Review Complete. Condition Determined Not Reportable Per 10CFR50.55(e)

ML17298A387
Person / Time
Site:	Palo Verde
Issue date:	05/16/1983
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Sternberg D
References
10CFR-050.55E, 10CFR-50.55E, DER-82-39, NUDOCS 8306010375
Download: ML17298A387 (20)

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A'rizona Public Service Company P.o. SOX 21666 ~ PHOENIX. ARIZONA 85036 May 16, 1983 ANPP-2375 7.-RQT/BSK U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane Suite 210 Walnut Creek, CA 94596-5368 Attention: Mr. D. M. Sternberg, Chief Reactor Projects Branch 1

Subject:

Final Report DER 82-39 A 50.55(e) Reportable Condition Relating to CE Valve Limit Switches (Class 1E) May Be Below Maximum LOCA Flood Level In Containment File: 83-019&26; D.4.33.2

Reference:

A) Telephone Conversation between G. Hernandez and G. Duckworth on July 30, 1982 B) ANPP-21722, dated August 30, 1982 (Interim Report)

C) ANPP-22138, dated October 28, 1982 (Time Extension)

D) ANPP-22824, dated January 26, .1983 (Time Extension)

E) ANPP-23273, dated March 17, 1983 (Interim Report)

Dear Sir:

Attached is our final written report of the deficiency- referenced above, 10CFR50.55(e).

Very truly yo -s, E. E. Van Brunt, Jr.

APS Vice President Nuclear Projects Management ANPP Project Director EEVB/RQT:db Enclosure cc: See Page 2

0 Mr. D. M. Sternberg ANPP-23757-RQT/BSK May 16, 1983 Page 2 CC: Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 T. G. Woods, Jr.

G. C. Andognini J. A. Roedel D. B. Fasnacht A. C. Rogers B. S. Kaplan W. E. Ide J. Vorees J. R. Bynum P. P. Klute/D. D. Green A. C. Gehr W. J. Stubblefield W. G. Bingham R. L. Patterson R. W. Welcher R. M. Grant D. R. Hawkinson L. E. Vorderbrueggen G. A. Fiorelli

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FINAL REPORT DER 82-39 DEFICIENCY EVALUATION 50.55(e)

ARIZONA PUBLIC SERVICE COMPANY (APS)

PVNGS UNIT 1 DESCRIPTION OF DEFICIENCY The purpose of this Deficiency Evaluation Report is to review and verify accident mitigation for safety-related equipment in containment located below the maximum containment flood level (elevation 90' 6"). A survey of equipment below flood level

. inside containment developed by APS and Combustion Engineering (CE) is provided in CE letter V-CE-18011, dated 3/4/83 (Attachment A).

A Bechtel investigation has determined the survey to be complete.

Of the identified equipment, the following are safety related:

~Ta No. 1E E ui ment Associated E ui ment SIB-UV-322 Fisher P. 0. Valve SIB-UY-3 22 ASCO Solenoid Valve SIB-ZSH-322 NAMCO Limit Switch SI B-Z SL-3 22 NAMCO Limit Switch Fisher P. Valve

'IB-UV-322 O.

SIB-UY-3 32 ASCO Solenoid Valve SIB-2 SH-332 NAMCO Limit Switch SIB-Z SL-3 32 NAMCO Limit Switch SIA-UV-651 Limitorque VMO SI A-UV-682 Fisher P. 0. Valve SIA-UY-682 ASCO Solenoid Valve SIA-Z SHW 82 NAMCO Limit Switch SIA-ZSL-682 NAMCO Limit Switch CHA-UV-506 Fisher P. 0. Valve CHA-UY-506 ASCO Solenoid Valve CHA-Z SH-5 06 NAMCO Limit Switch CHA-Z SL-506 ANMCO Limit Switch CHA-HV-507 Fisher P 0 Valve CHA-HY-507 ASCO Solenoid Valve CHA-Z SH-5 07 NAMCO Limit Switch CHA-ZSL-507 DACHA-ZSH-560 NAMCO Limit Switch CHA-UV-560 Fisher P. 0. Valve CHA-UV-560 ASCO Solenoid Valve NAMCO Limit Switch CHA-Z SL-560 NAMCO Limit Switch

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~Ta No. 1E E ui ment Associated E ui ment.

SGA-UV-220 VALCOR Solenoid Valve SGB-UV-226 VALCOR Solenoid Valve lpga NCB-UV-403. - Limitorque MOV Pratt Valve.

GRA-UV&01 ROTORK MOV Dresser Valve CHN-FT-244 Rosemount Flow Trans. (~ - S~NONKNT)

CHA-PT-268 Barton Pressure Trans.

RCA-PDT-115A Barton Diff, Pres. Trans.

RCC-PDT-115C Barton Diff. Pres. Trans.

l RCD-PDT-125D Barton Diff. Pres. Trans.

RCN-PT-'181 Rosemount Pressure Trans.

RCN-PT-182 Rosemount Pressure Trans. (~ ta. Rcywmum)

RCN-PT-183 Rosemount Pressure Trans.

RCA-PT-190A Rosemount Pressure Trans.

RCB-PT-190B Rosemount Pressure Trans.

The remaining identified equipment have been determined as either not being submerged or not required to operate post-LOCA.

As part of this review, isometric'rawings, the instrument index (Drawing 13-J-ZZI-001), EE580 and the plant model were cross checked. A walkdown was also conducted.

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Page 3 II. ANALYSIS OF SAFETY IMPLICATIONS This condition is evaluated as not reportable. The post flood operability requirements of each submerged piece of safety-related equipment identified in Condition Description are given in Attachment B. In all cases, it was determined that: 1) the item had no safety-related function as part of a design basis accident; or 2) it performed'its function prior to submergence and 'subsequent submergency would not pose a health and safety hazard. Accordingly, none of the identified equipment requires qualification for sub-mergence. Therefore this condition would not adversely affect the safety of operations of the facility and is consequently evaluated as not reportable under the requirements of 10CFR50.55(e) .

III. CORRECTIVE ACTION This Deficiency Evaluation Report documents the completion of Bechtel's review and verification of the accident mitigation capability of all safety-related equipment located below the Containment Building maximum flood level. The foregoing dispositions were reviewed and concurred with by APS and CE.

0 Enclosure  !/1 Post Flood Operability Requirements for Safety Related Equipment Located Below Flood Level SIB-UV-322 SIB-UV-'322 isolates the RCS check valve leakage line from SIB-UY-322 the "safety injection system. UV-322 is normally closed, SIB-ZSH-322 fail closed, and if open it will close upon SIAS, before SIB-ZSL-322 the valve is submerged. Valve closure is assumed since SIAS is issued prior to containment spray (CSAS). SIAS is issued at 5 psig, CSAS at 10 psig. Equipment function will be coop'lete within 5 seconds after the safety injection signal (SIAS) is generated. Assuming, conser-vativel~y, that"&e .containment spray signal (CSAS) is cogenerated with SIAS (SIAS" wil1 always precede CSAS),

sprays cannot deliver water for 80 seconds. Thus, there will always be at least 75 seconds between the accomplishment of safety function and the onset of sprays.

The onset of sprays, by itself, does not mean that the equipment will be flooded. Rather, it provides an estimate of the absolute minimum time prior to to submergence.

Furthermore, as recirculation will not begin for at least 20 minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located at elevation 84 -3" and would not be expected to become submerged for 8 minutes. There is no mechanism that would allow the valve to spuriously reopen.

SIB-UV-332 Same as UV-322, concurrent failure of SIB-UV-322 is not SIB-UY-332 considered.

SIB-ZSH-332 SIB-ZSL-332

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Page 2 SIA-UV-682 SIA"UV-682 is used during normal operation to control the SIA-UY-682 level of the safety injection tanks. The safety function SIA-ZSH-682 of UV-682 is to provide containment isolation. UV-682 is SIA-ZSL-682" normally closed, fail closed, and if open it will close upon SIAS, before the valve is submerged. Valve closure is assumed since SIAS is issued prior to containment .spray (CSAS). SIAS is issued at 5 psig, CSAS at 10 psig. Equip-ment function will be complete within 5 seconds after the safety injection signal (SIAS) is generated. Assuming, conservatively, that the containment spray signal (CSAS) is cogenerated with SIAS (SIAS will always precede CSAS),

sprays cannot deliver water for 80 seconds. Thus, there will always be at least 75 seconds between the accomplish-ment of safety function and the onset of sprays. The onset of sprays; =by itself, does not mean that the equipment will be flowed: Rather, it provides an estimate of the absolute minimum time pribr. to- submergence. Furthermore, as recircu-lation will not begin for at lea'st 20-minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located at elevation 90 -3" and would not be expected to become submerged for 20 minutes. There is no mechanism that would allow the valve to spuriously reopen.

CHA-UV-506 CHA-UV-506 isolates the reactor coolant pump controlled CHA-UY-506 bleedoff from the volume control tank. The safety function CHA-ZSH-506 of UV-506 is to provide containment isolation. UV-506 is CHA-ZSL-506 normally open, fail closed, and will close upon CIAS, before the valve is submerged. Valve closure is assumed since CIAS is issued prior to containment spray (CSAS). CIAS is issued at 5 psig, CSAS at 10 psig. Equipment function will be complete within 5 seconds after the containment isolation signal (CIAS) is generated. Assuming, conserva-tively, that the containment spray signal (CSAS) is cogenerated with CIAS (CIAS will always precede CSAS),

sprays cannot deliver water for 80 seconds. Thus, there

,:,will always be at least 75 seconds between the accomplish-ment of safety function and the onset of sprays. The onset of sprays,'y itself, does not mean that the equipment will be flooded. Rather, it provides an estimate of the absolute minimum time prior to submergence. Furthermore, as recircu-lation will not begin for at least 20 minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located at elevation 90 -2" and would not be expected to become submerged for 20 minutes. There is no mechanism that would allow the valve to spuriously reopen.

CHA-HV-507 CHA-HV-507 isolates the RCP controlled bleedoff header CHA-HY-507 relief valve PSV-199. It serves no post-LOCA safety CHA-ZSH-507 function as the reactor coolant pumps are not required CHA-ZSL-507 post-LOCA. This valve is not submerged for other design basis events.

Page 3 CHA-UV-560 isolates the reactor drain tank from the reactor CHA-UY-560 drain pump. The safety function of UV-560 is to provide containment isolation. UV-560 is normally closed, fail CHA-ZSL-560'.'HA-UV-560 CHA-ZSH-560',

closed, and if open it will close upon CIAS, before the valve is submerged. Valve c1osure is assumed since CIAS is issued prior to containment spray (CSAS). CIAS is issued at 5 psig, CSAS at 10 psig. Equipment function will be comp3,etc"within 5 seconds after the containment isolation signal (CIAS) is generated. Assuming, conservatively, that the containment spray signal (CSAS) is cogenerated with CIAS (CIAS will always precede CSAS), sprays cannot deliver water for 80 seconds. Thus, there will always be at least 75 seconds between the accomplishment of safety function and the onset of- sprays. The onset of sprays, by itself, does not mean that the equipment will be flooded. Rather, it provides an est&nate. of the absolute minimum time prior to submerg'ence. There is no mechahism -that would allow the valve to spuriously reopen.

SGA-UV-220 SGA-UV-220 is the downcomer blowdown isolation valve from the number one steam generator. The safety function of the valve is to provide containment isolation, and isolate the steam generator. UV-220 is normally open, fail closed, and will close upon SIAS, MSIS or AFAS, before the valve is submerged. Valve closure is assumed since SIAS is issued prior to containment spray (CSAS). SIAS is issued at 5 psig, CSAS at 10 psig. Equipment function will be complete within 1 second after the safety infection signal (SIAS) is generated. Assuming, conservatively, that the containment spray signal (CSAS) is cogenerated with SIAS (SIAS will always precede CSAS), sprays cannot deliver water for 80 seconds. Thus, there will always be at least 79 seconds between the accomplishment of safety function and the onset of sprays. The onset of sprays, by itself, does not mean that the equipment will be flooded. Rather, it provides an estimate of the absolute minimum time prior to submergence.

Furthermore, as recirculation will not begin for at least 20 minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located .at elevation 89 and would nc" be expected to become submerged for 18 minutes. There is no mechanism that would allow the valve to spuriously reopen.

I SGB-UV-226 SGB-UV-226 is the downcomer blowdown isolation valve from the number two steam generator. The safety function of the valve is to provide containment isolation, and isolate the steam generator. UV-226 is normally open, fail closed, and will close upon SIAS, MSIS or AFAS, before the valve is submerged. Valve closure is assumed since SIAS is issued prior to containment spray (CSAS). SEAS is issued at 5 psig, CSAS at 10 psig. Equipment function will be complete within 1 second after the safety infection signal (SIAS) is generated. Assuming, conservatively, that the containment spray signal (CSAS) is cogenerated with SIAS (SIAS will always precede CSAS), sprays cannot deliver water for 80 seconds. Thus, there will always be at least 79 seconds-between the accomplishment of safety function and the onset of sprays. The onset of sprays, by itself, does not mea'n that-the. equipment will be flooded. Rather, provides an estimate of the-absolute. minimum time prior to it submergence. Furthermore, as recirculation will not begin for at least 20 minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located at elevation 89 and would not be expected to become submerged for 18 minutes. There is no mechanism that would allow the valve to spuriously reopen.

UV 40 NCB-UV-403 isolates the nuclear cooling water system return line from the RCPs. The safety function of the valve is to provide containment isolation. UV-403 is normally open and will close upon CIAS, before the valve is submerged.

Valve closure is assumed since CIAS is issued prior to containment spray (CSAS). CIAS is issued at 5 psig, CSAS at 10 psig. Equipment function will be complete within 10 seconds after the containment isolation signal (CIAS) is generated. Assuming, conservatively, that the containment spray signal (CSAS) is cogenerated with CIAS (CIAS will always precede CSAS), sprays cannot deliver water for 80 seconds. Thus, there will always be at least 70 seconds between the accomplishment of safety function and the onset of sprays. The onset of sprays, by itself, does not mean that the equipment will be flooded. Rather, it provides an estimate of the absolute minimum time prior to submergence.

Furthermore, as recirculation will not begin for at least 20 minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located at elevation 84 -0 and would not be expected to become submerged for 8 minutes; There is no mechanism that would allow the valve to spuriously reopen.

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GRA-UV-001 GRA-UV-001 isolates the containment GRS header from the GRS gas surge header. The safety function of the valve is to provide containment isolation. UV-001 is normally open and will close upon CIAS, before the valve is submerged.

Valve closure is assumed since CIAS is issued prior to containment spray (CSAS). CIAS is i.ssued at 5 psig, CSAS at 10 psig. Equipment function will be complete within 12 seconds after the containment isolation signal (CIAS) is generated. Assuming, conservatively, that the containment spray signal (CSAS) is cogenerated with CIAS (CIAS will always precede CSAS), sprays cannot deliver water for 80 seconds. Thus, there will always be at least 68 seconds between the accomplishment of safety function and the onset of sprays. The onset of sprays, by itself, does not mean that the equ'i'pment will be flooded. Rather, it provides an estimate ohe absolute minimum time prior to submergence.

Furthermore, as~ecirculation will not begin for at least 20 minutes (See Cessar 6.3.3.5), the water level in the containment will slowly rise from 80 -0" to 90 -6" at the rate of about 6" per minute. The electrical portion of the valve is located at elevation 89 -6" and would not be expected to become submerged for 19 minutes. There is no mechanism that would allow the valve to spuriously reopen.

CHN-FT-244 CHN-FT-244 is the RCP 2B seal injection flow transmitter.

serves no post-LOCA safety function as the reactor coolant It pumps are not required post-LOCA. This instrument is not submerged for other design basis events.

CHA-PT-268 CHA-PT-268 is the reactor drain tank pressure transmitter.

It serves no post-LOCA safety function as reactor drain

,tank pressure indication is not required post-LOCA. This instrument is not submerged for -other design basis events.

RCA-PDT-115A RCA-PDT-115A is the steam generator number one differential pressure transmitter. This instrument is used to detect an RCP sheared shaft event and is not required to operate post-LOCA. This instrument is not submerged for other design basis events.

RCC-PDT-115C Same as RCA-PDT-115A

'RCD-PDT-1'25D Same as RCA-PDT-115A, except it measures differential pressure on the number two steam generator.

RCN-PT-181 RCN-PT-181 is the RCP 2B seal injection pressure trans-mitter. It serves no post-LOCA safety function as the reactor coolant pumps are not required post-LOCA. This instrument is not submerged for other design basis events.

RCN-PT-182 Same as RCN-PT-181

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Page 6 RCN-PT-183 RCN-PT-183 is the RCP 2B controlled bleedoff pressure transmitter. It serves no post-LOCA safety fnction as the reactor coolant pumps are not required post-LOCA. This instrument is not submerged for other design basis events.

RCA-PT-190A RCA-PT-190A is the extended range RCS pressure transmitter, required by Regulatory Guide 1.97. This instrument is used for ATWS events. It serves no post-LOCA safety function, and.is not submerged for other design basis events.

RCB-PT-190B, Same as RCA-PT-190A The following equipment was found to be below the flood level but is not required to operate post-DBE, per V/CE-18011 dated March 4, 1983.

Tag No ~ Equipment CHE-FV-242 Fisher P'O'--Valve.

CHE-FY-242A Fisher E/P Positioner CHE-FY-242B Asco Solenoid Valve CHE-ZSH-242 Namco Limit Switch CHE-ZSL-242 Namco Limit Switch RCE-HV-403 Target Rock Solenoid Valve SIE-HV-661 Fisher P.O. Valve SIN-HY-661 Asco Solenoid Valve SIN-ZSH-661 Namco Limit Switch SIN-ZSL-661 Namco Limit Switch The following item has been -previously identified as being below the flood level per Reference (C), but is actually located above the flood level.

SSA-UV-203 Valcor Solenoid Valve The following item has been previously identified as being below the flood level, per DCP 1SM-Sl-053 the valve operator has been rotated 180 and the electrical portion of the valve is no longer below flood level.

SIA'-UV-651 Limitorque I

VMO

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