ML18019B144

Provides Info Addressing Confirmatory Items Identified in Sser 3 (NUREG-1083) Section 3.10, Seismic & Dynamic Qualification of Mechanical & Electrical Equipment. Listed Programs Implemented Per Rev 1 to Srp,Section 3.10

ML18019B144
Person / Time
Site:	Harris
Issue date:	08/29/1986
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-1038 NLS-86-307, NUDOCS 8609050102
Download: ML18019B144 (9)

Text

REQU RY INFORMATION DISTRIBUT SYSTEM (R IDS)

ACCESSION NBR: 86090501 02 DOC. DATE: 86/08/29 NOTARIZED: NO DOCKET 0 FACIL: 50-400 Shearon Harris Nuclear Power Planti Unit 1 i Car olina 05000400 AUTH. NAME AUTHOR AFFILIATION ZIMMERMANiS. R. Carolina Power 5 Light Co.

RECIP. NAME RECIPIENT AFFILIATION DENTON> H. R. Office of Nuclear Reactor Regulationi Director (post 851125

SUBJECT:

Provides info addressing confirmatorg items identified in SSER 3 (NURE('-1083) Section 3. 10i "Seismic 5 Dgnamic Gualification of Mechanical 5 Electrical Equipment. " Listed DISTRIBUTION CODE: AO4BD COPIEB RECEIVED: LTR TITLE: OR/Licensing Submittal: Equipment i

programs implemented per Rev 1 to SRPi Section.3. 10.

ENCL Qualification g BIIE:

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@ME, Carolina Power & Light Company SERIAL: NLS-86-307 AUG 2 9 1986 Mr-;Harold-R-.-Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. 1 - DOCKET NO.50-000 SEISMIC QUALIFICATIONOF SAFETY-RELATED EQUIPMENT AND PUMP AND VALVE OPERABILITY REVIEW

Dear Mr. Denton:

Carolina Power R Light Company (CPRL) hereby addresses the confirmatory items identified in Shearon Harris Safety Evaluation Report, NUREG-1038, Supplement No. 3, Section 3.10. Seismic and Dynamic Qualification of Mechanical and Electrical Equi pm ent.

Carolina Power R Light Company has implemented programs at SHNPP to evaluate (1) seismic adequacy of safety-related equipment and (2) pump and valve operability. The licensing basis for these programs is Standard Review Plan (SRP), Section 3.10, Revision 1, dated April l978. This was the SRP revision in effect for the docket date of the SHNPP Operating License application (December 22, 1981). This SRP revision only addresses qualification of electrical equipment. The qualification work for electrical equipment is essentially complete. Therefore, CPRL considers that it has satisfied the licensing basis regarding seismic and operability qualification of equipment.

Carolina Power R Light Company also included safety-related mechanical equipment in the scope of the program. This added scope was not intended as a new licensing basis, but as a good engineering practice. Nevertheless, CPRL has addressed the Staff concerns in the attachments to this letter. Attachment I addresses Seismic Qualification Review Team Issues and Attachment II addresses Pump and Valve Operability Review Team Issues. With this information, the Staff should be able to complete the review and close the remaining confirmatory issues.

If you have any questions, please contact Mr. Pedro Salas at (919) 836-8015.

Yours very truly, S. R. im rman er Nuclear Licensing Section PS/crs (0051PSA)

Attachments cc: Mr. B. C. Buckley (NRC)

Mr. G. F. Maxwell (NRC-SHNPP)

Dr. 3. Nelson Grace (NRC-RII)

SbOVODOiOR 86082~

PDR ADOCK 05000400 R PDR i~

411 Fayettevilte Street ~ P. O. Box 1551 ~ Raleigh. N. C. 27602

ATTACHMENT I SEISMIC UALIFICATIONREVIEW TEAM (S RT) ISSUES The review of the seismic qualification program was conducted by the SQRT. The team reviewed information in FSAR Sections 3.9.2 and 3.10, audited selected items, and concluded (as reported in SSER 3, Section 3.10.2.3) that the program is well defined and adequately implemented. However, prior to granting final approval, the Staff requested that the issues identified in SSER Sections 3.10.2.1, 3.10.2.2, and Table 3.3 be addressed. The following information is in support of this request.

(1) Cabinet Clearance (SSER 3, Section 3.10.2.(l))

Carolina Power R Light Company informed the SQRT, during the audit, of a program to analyze and correct inadequate clearances between cabinets. SSER 3 requests that CPRL inform the Staff when the program is completed.

CPRL Position:

This program has been completed.

(2) Life S an of Non-Metallic Parts (SSER 3, Section 3.10.2.1(2))

SSER 3 requests that the life span of non-metallic parts be evaluated.

CPRL Position:

The evaluation of non-metallic parts was performed as part of the program for the environmental qualification of safety-related mechanical equipment located in harsh environmental areas. The program, described in a report submitted to NRC on September 1 1, 1985 (NLS-85-290), has been reviewed by the Staff.

The program has been completed, the life span of the non-metallic parts evaluated, and the results are being incorporated into the maintenance program.

Maintenance items necessary before the first refueling outage have in the maintenance program. The remainder items are beingbeen'ncorporated incorporated, and the work will be completed prior to the date when the maintenance activities must be performed. Carolina Power dc Light 'ompany considers this issue closed.

(3) Reevaluation of Seismic uglification of Power-0 crated Valve Assemblies SSER 3 Section 3.10.2.1 3 The Staff has requested that CPRL propose a program to reevaluate the seismic qualification of power-operated valve assemblies. Specifically, the request is for a program to ensure that valves determined to be rigid (i.e., have natural frequencies greater than 33 Hz) are not, in fact, flexible. The Staff has indicated that the request stems from a CPRL reevaluation of ITT-Grinnell air-operated diaphragm valves reported under 10 CFR 50.55(e) and 10 CFR 21.

(4051psA/pgp )

CPRL Position:

The deficiency in the analysis of the ITT-Grinnell valves was equipment-specific.

Carolina Power R Light Company evaluated and reported the concern as required by 10 CFR 50.55(e) and 10 CFR 21 in a letter dated October 25, 1980.

In addition, fundamental natural frequency evaluations for certain power-operated valve assemblies include actual resonance search testing, as illustrated in Table I. As noted in the table, some evaluations were further verified by analytical methods, thus, providing a correlation between testing and analysis.

For further discussion, see Attachment II, Paragraph (0).

Carolina Power R Light Company considers that it has fulfilled its reporting obligations and considers the corrective actions for the specific equipment item to be satisfactory. Therefore, CPRL considers this issue closed.

ualification of Control Room Cabinet Internals (SSER 3, Section 3.10.2.2)

The Staff has requested to be notified when the control room cabinet internals qualification work is completed.

CPdcL Position:

The evaluation has been completed. Therefore, CPRL considers this issue closed.

(5) Confirmation of Seismic uglification of Com onents" The Staff has requested CPRL to confirm that the seismic qualification of safety-related equipment is complete.

CPRL Position:

The seismic qualification program is essentially complete. Therefore, CPRL considers this issue closed.

(6) As-Built Anal sis of Seismic Loads~

The Staff has requested CPRL to confirm that seismic loads imposegon pumps and valves as a result of as-built analysis are within the limits of their qualif ication.

CPdcL Position:

The as-built verification of pumps and valves has been performed as part of a program to address IE Bulletin No. 79-10, Seismic Analyses for As-Built Safety-Related Piping Systems. This program has been completed, reviewed by NRC Region II, and found acceptable. The results of the Region II inspection are contained in IE Inspection Report No. 50-000/86-32, dated May 10, 1986.

Therefore, CPdcL considers this issue closed.

"New requests discussed with CPRL on August 0, 1986. They are not contained in SSER 3.

(405lPSA/vaw )

TABLE I FRE UENCY EVALUATIONOF VALVE ASSEMBLIES FREQUENCY EVALUATION MANUFACTURER R OF VALVE ASSEMBLY P.O. NUMBER TYPE OF VALVE TYPE OF ACTUATOR BY ANAL BY TEST P.O. NY - 035111 M.S. Power Op. Electro-Hydraulic Control Comp. Inc. Relief Valves P.O. NY - 035793 F.W. Isolation Electro-Hydraulic Borg Warner Valves P.O. NY - 035170 Misc. Control Electro-Hydraulic Masoneilan Valves Air-Diaphragm P.O. NY 035176 Misc. Control Electro-Hydraulic ITT/Ham mel Valves Air-Diaphragm P.O. NY - 035203 Solenoid Solenoid Target-Rock. Valve P.O. NY - 035211 Butterfly Air-Diaphragm BIF Valves (4051PSA/pgp )

ATTACHMENTII PUMP AND VALVE OPERABILITY REVIEW TEAM (PVORT) ISSUES The review of the pump and valve operability qualification was performed by the PVORT. The team concluded that (SSER 3, Section 3.10.1A) upon resolution of the issues contained in Section 3.10.1.3, the program has been properly defined and implemented.

These issues are addressed below.

(I) Revision of FSAR List of Active Valves (SSER 3, Section 3.10.1.3(2)(a))

The Staff requested that the FSAR list of active valves be updated.

CPdcL Position:

Per letter dated 3une 12, 1986 (NLS-86-220), CPRL submitted a draft revision of the list of active valves (FSAR Tables 3.9.3-13 and 10). FSAR Amendment No. 33 will update Tables 3.9.3-13 and 3.9.3-10. Carolina Power R Light Company considers this item closed.

(2) Preservice Testin (SSER 3, Section 3.10.I.3(2)(b))

The Staff requires CPRL to confirm that all preservice tests that are required before operation have been completed.

CPRL Position:

Preoperational testing at SHNPP is substantially complete. Some testing is currently in progress, the status of which is reviewed weekly with NRR and Region II Management. CPRL will complete preoperational testing as specified in FSAR Chapter 10 prior to declaring the system operable.

(3) 0 erabilit uglification of Safet -Related Active Pum s and Valves (SSER 3, Section 3.10.1.3 2 c The Staff has requested confirmation that operability qualification of safety-related active pumps and valves is corn'piete. The Staff requests that qualification consider new loads that may result from as-built condign'ons.

CPRL Position:

The qualification work is essentially complete. The as-built conditions were evaluated in the IE Bulletin No. 79-10 program (see Attachment I, Item [6]). The SHNPP program was not limited to seismic loads, but included other loads such as LOCA loads. Therefore, CPRL considers this issue closed.

(4051psA/vaw )

(0) uglification of Valves b Anal sis Alone (SSER 3 Section 3.10.1.3(2)(d))

The Staff has requested information to show that qualification by analysis alone is justified.

CPRL Position:

The seismic qualification program was developed using the acceptance criteria .

contained in Standard Review Plan, Section 3.10, Revision 1, which permits applicants to confirm operability through test or analysis. The Staff confirmed that use of either test or analysis was acceptable in letters dated November 25, 1981 (Acceptance Review Questions) and February 2, 1983 (Request for Additional Information for Seismic and Dynamic Qualification).

Following the audit of the SHNPP program, the Staff indicated that they desired testing and analysis to establish qualification. In light of this new Staff position, CPRL met with the Staff on April 11, 1986. At that meeting, the NRC Staff agreed that certain specific additional information would resolve this concern.

Carolina Power R Light Company submitted this additional information in letters dated 3une 6, 1986 (NLS-86-200) and 3une 12, '1986 (NLS-86-220). Therefore, CPRL considers this issue closed.

(4051PSA/pgp )