ML18045A275
| ML18045A275 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/16/1980 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-03-12, TASK-3-12, TASK-RR NUDOCS 8006250002 | |
| Download: ML18045A275 (11) | |
Text
- -* ---*
REl.~tOR~ ]~~H!f.~lt COP~ e NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket No.:
50-255 Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
Dear Mr. Hoffman:
May 16, 1980 RE:
ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT -
PALISADES PLANT You were requested to address the Environmental Qualification of Safety-Rel ated Electrical Equipment for Palisades plant by NRC letter dated December 23, 1977.
Infonnati on requested included i denti fi ca ti on of electrical equipment required to perfonn safety functions while subjected to design basis acci~ent environments, definitions of environmental service conditions at equipment locations, and status of environmental qualification documentation.
In response to this request you provided information via submittal letters dated February 24, 1978; April 6, 1978; April 12, 1978; and November 30, 1978.
During the week of January 21, 1980, a site visit to the Palisades plant
- was conducted by representatives of the NRC and our contractor, Franklin Research Center.
In this visit Class lE systems and compone.nts were inspected, plant operating procedures were discussed with plant personnel, and available qualification documentation.was reviewed.
Our letter of February 15, 1980, formally transmitted to you the two sets of NRC Guidelines referenced below, and called a meeting with the SEP plant licensees on February 21, to discuss the Guidelines.
Our letters of March 6, 1980 and March 28, 1980, provide further direction including schedules.
Although the review of equipment environmental qualification for Palisades was initiated prior to the February 21 meeting, it is our intention that the review be conducted with the same guidelines and procedures established for the other SEP plants; we stated in the February 21 meeting and the March 6 and 28 letters that
. the Palisades information would be brought to the level of the other SEP plant submittals.
sooea~o()O~
Mr. David May 16, 1980 to our March 6, 1980 letter to all SEP licensees defined five categories of infonnation that must be submitted under the SEP qualifi-cation program.
You are hereby requested to submit within 60 days for the Palisades plant the information required in these categories as follows:
- 1.
Provide the 1 ist of safety-related systems addressed in Reference
- 2.
The emergency procedures have already been provided and need not be resubmitted.
- 2.
Definition of hostile service conditions is being addressed separately*
in accordance with our March 28, 1980 letter and need not be addressed in this submittal except as needed to complete category 4.
- 3.
Provide the identification and justification of equipment considered qua 1 if i ed by experience in accordance with Reference 1, Sectfon 4.3.3, Areas Normally Maintained at Room Conditions.
- 4.
Provide the tabulation of safety-related equipment located in a hostile environment, with identification of the service conditions and qualification testing for each, in the format used for SEP Topic III-12 submittals.
- 5.
Provide the list of equipment in the tabulation of category 4. that is not qualified in accordance with the specific requirements of
.Reference 1, together with justification for the deviations from the guidelines.
As guidance in preparing the requested material, we are providing three enclosures reflecting rev.iews perfonned during the Pali sades pl ant site
- .visit during January 21-25, 1980.
Enclosures 1 and 2 list equipment considered necessary for mitigation of high energy line breaks.based on review of the Palisades emergency procedures for Main Steam Line Breaks, Feedwater Line Breaks, and Loss of Cool ant Accidents.
Service environ-ments for this equipment should be determined by postulating the broadest possible spectrum of break locations and sizes in the primary and secondary coolant systems, inside and outside containment.
Furthennore, if there are any other high energy lines... (above 285 psig or 212°F) for which a break requires mitigation, in addition to those already addressed, the systems and environments related to them should also be addressed.
e Mr. David May 16, 1980 provides specific questions concerning equipment qualification test documentation that was reviewed at the site. The questions identify deficencies in the documentation and request that you either provide additional qualification reports or justify the adequacy of the existing.
information.
Enclosures:
As stated cc:
See next page
References:
Sincerely, Jl - --/J/I 1..j-'-1~-. --x ;/
/f/J,,µ,-,.t-'-*1 ///I-l%u,f(~b-~,.t,.it/I 6~nis M. Crutchfield, C-ief Operating Reactors Bran
- 5 Divisiori of Licen~ing
- 1.
Guidelines for Evaluating En~ironmental Qualification of Class l'E Electrical Equipment in Operating Reactors ~ Enclosure 1 to NRC letter to you dated February 15, 1980.
- 2.
Guidelines for Identification of That Safety Equipment of SEP Operating Reactors for which Environmental Qualifications is to be*~.
Addressed - Enclosure 2 to NRC letter to you dated February 15, 1980.
cc
- <.~.!-';~Iler, Esquire Isha~, Lincoln & Beale S1..:ite 4200 O~e First National Plaza Chicago, Illinois 60670 Mr. ? au1 A. Perry, Secretary.
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 J~dd L. Bacon, Esauire Ccns ume rs P b1*1e r Comp any 212 ~est Michigan Avenue Jackson, Michigan 49201
- Myron M. Cherry, Esquire S~ite 4501 0:-.2 I3M Plaza Ci":icc:go, Illinois* 60611 Ms. Mary P. Si nc la i r
'Greet Lakes Energy Alliance 5711 Summerset Drive Midland, Michigan 48640 K=lcmazoo Public Library 3?5 South Rose Street Kalam~zoo, Michigan 49006
- Tcwnship Supervise~
Cov~rt Tm*mship Rou7:e 1, Box 10 V=n Buren County, Michigan 49043 Office of the Governo~ (2)
Roor;-: 1 - Capitol Building L~nsing, Michigan 48913 Director, Technical Assessment Division Off i.ce of R adi at ion Programs (fa. ~4-459)
U. s. Environmental Protection P\\gency Crystc:l
- ~all #2 A~1~ngton, Virginia 20460 r-e 16, 1980.
Agency Federal Activities &ranch Region V Office ATTN:
EIS COORDINATOR 230 South Dearborn Street Chi ca go, I 11 i noi s.
60604.
Charles Bechhoefer, Esq., Chairman
. Atomic Sa~ety and Licensing Board Panel U. S. Nuclear Regulatory Com-nission Washington, D. C.
20555 Dr.
Geo~ge c. Anderson
- Department of Oceanography University of WashiRgton Seattle, Washington 98195 Dr. M. Stanley Livingston 1005 Calle Largo Santa Fe, Ne*;1 Mexi.co 37501 Resident Inspector c/o U. S. NRC P. O. Box 87 South Haven, Michigan 49090 Pal i sades P 1 a.nt ATTN :
Mr. J
- G
- L eH i s Plant Manager Covert, Michigan 49043 William J. Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103
ENCLOSURE l PALISADES NUCLEAR PLANT SYSTEMS NEEDED FOR MITIGATION OF MAIN STEAMLINE OR FEEDWATER LINE BREAKS INSIDE AND OUTSIDE CONTAINMENT Engineered Safeguards Actuation/Reactor Protection System Containment Isolation (not needed for breaks outside containment)
Safety Injection Emergency AC and DC Power Main Steam Isolation Auxiliary Feedwater Main Feedwater Isolation Containment Cooling Chemical Volume Control Compnent Cooling Water Critical Service Water Containment Radiation Monitoring Shutdown Cooling (including MOV 3015 and MOV 3016)
Steam Dump Pressurizer Heaters and Sprays (including auxiliary spray system and CV-1057, CV-1059)
Safety Related Display Instrumentation (pressurizer level; PCS temperature and pressure; flow indication for HPSI, LPSI, auxiliary FW, CVCS, and shutdown cooling system; pump discharge pressure for CCW and SW; diesel
, generator output voltage and current; AC and DC power energized lights; valve position indicators);
Post Accident Sampling (PCS boron and hydrogen concentration)
Ve~tilation for Safety Equipment Control Room Habitability
PALISADES NUCLEAR PLANT SYSTEMS NEEDED FOR MITIGATION OF LOSS OF COOLING ACCIDENTS Engineered Safeguards Actuation/Reactor Protection System Containment Isolation Safety Injection Emergency AC and DC Power Auxiliary Feedwater Containment Cooling Chemical Volume Control Component Cooling Water Critical Service Water Containment Radiation Monitoring Shutdown Cooling (including MOV 3015 and MOV 3016)
Steam Dump Iodine Remova 1.
Hydrogen Recombiners ENCLOSURE 2 Pressurizer Heaters and Sprays (including auxiliary spray systems and CV-1057 and CV-1059)
Safety Related Display Instrumentation (source range nuclear instruments for core rod monitoring; pressurizer level; PCS temperature and pressure; flow indication for HPSI, LPSI, auxiliary FW, CVCS, and shutdown cooling system; pump discharge pressure for CCW and SW; diesel generator output voltage and current; AO.and DC power energized lights;.SIRV level; containment sump level; valve position indicators)
Post Accident Sampling (PCS boron and hydrogen concentration)
Ventilation for Safety Equipment Control Room Habitability
Q
-CLOSURE 3 SPECIFIC QUESTIONS CONCERNING EQUIPMENT QUALIFICATION DOCUMENTATION BASED bN PALISADES SITE VISIT, JANUARY 21-25, 1980 Submit the specific information requested. All component numbers and documentation references are associated with Consumers Power Company's letter of November 30, 1978 to the NRC.
- 1.
COMPONENT NUMBERS 1 AND 2, SOLENOID VALVES
- a.
Provide the date at which installation will be complete for Component 2 ASCO solenoid valves, Model Number NP 831654E,..
which are replacements for Component 1 valves.
- b.
A simple vendor Certificate of Compliance with design specifi-cations is not considered adequate or sufficient as proof of qualification. Provide for review the Test Report cited in ASCO Certification of Compliance, dated September 13, 1978,.
for Component 2.
C'.
The available documentation for Component 2 does not specify the model number of the test specimen.
The test specimen must be the same as the equipment being qualified. Provide the model number of the test specimen or provide an analysis of.
the impact of deviations between the te~t specimen's design~
materials, and production procedu~e, and those of Component 2.
- 2.
COMPONENT NUMBER 3, SOLENOID VALVES The. avail ab 1 e documentation for Component 3, cited in* Reference 7, is inadequate.
- In order to detenni ne the adequacy of the qualification of equipment, it is necessary to cite the specific service environ-ment to which the equipment is exposed during nonnal and accident conditions.. The referenced report states that air, instead of steam as required, was utilized for the test.
In addition, the test duration was not consistent with the appropriate containment temperature and pressure profile. The report was also deficient in that radiation exposure and chemical spray testing were not applied.
Provide for review a comprehensive qualification report for this component.
- 3.
COMPONENT NUMBER 4, SOLENOID VALVES Documentation reflecting qualification has not been made available for review.
Provide for review a comprehensive qualification report for this component.
- 4.
COMPONENT NUMBERS 7, 8, 9, AND 10 - MOTOR-OPERATED VALVES The documentation cited in Reference 8 indicates that the model size of the test specimen was smaller than the model size of the
,units actually installed in the plant. The test specimen must be the same as the equipment being qualified.
Provide an analysis of the impact of any deviations between the test specimen's design, materials, and production procedures, and those of the installed units; or provide for review a qualification report valid for the i n st a 11 e d uni ts.
- 5.
COMPONENT NUMBERS 11 AND 13, ELECTRICAL PENETRATIONS The available documentation cited in References 11, 20, 22 and 23 is incomplete and inadequate.
Complete and auditable records, reflecting a comprehensive qualification methodology, must be referenced and available for review for all Class lE equipment installed inside the containmeDt.
Provide for review documentation completely addressing the basis for qualification. Specific areas that must be considered are as follows:
- a.
Define the exact relationship between units installed at Palisades and those tested for Oconee.
- b.
Cite the specific service environment to which the equipment is exposed during nonnal and accident conditions, in order to permit detennination of the adequacy of the qualification of equipment. Specify the peak temperature, pressure, humidity, and radiation levels that the insulation and seals are capable of withstanding under maximum current load conditions in each conductor.
- c.
Specify the long-term temperature, humidity, and radiation levels that the insulation and seals are capable of withstanding.
- 6.
COMPONENT NUMBERS 19 THROUGH 25, AND 32 THROUGH 34, POWER AND CONTROL CABLES
- a.
The documentation cited in Reference 3 does not identify the test specimen cables with regard to manufacturer.
The test specimen must be the *same as that of the equipment being qualified.
Provide for review certification or specific documentation which correlates the exact cable tested with those installed in the plant.*
- b.
The documentation cited in Reference 3 indicates that the test duration was shorter than required by the specific service.
environment to which the equipment is exposed during normal and accident conditions.
Provide for review a comprehensive qualification report for this component, or provide analysis or justification for the test duration relative to the service environment.
- c.
The doc.urnentation cited in Reference 3 indicates that thermal aging con.siderations were not addressed.
Provide for review certification or specific documentation which addresses thermal aging degradation for these components.
- d.
The documentation cited in Reference 3 indicates that sub-mergence tests were not conducted.
Provide for revie~ a comprehensive qualification report for this component which addresses submergence.
- 7.
COMPONENT NUMBERS 26 AND 27, CONTROL CABLES
- a.
The documentation cited in Reference l indicates that a specific control cable specimen was tested (5/C 14 AWG, Number 84058-29).
The test specimen must be the same as that of the equipment being qualified.
Provide for review
. certification or specific documentation which correlates.
the exact cable tested with those installed in the plant.
- b.
Tne documentation cited in Reference l indicates that the test durati6n was shorter than required by the specifit service environment to which the equipment is exposed during normal and accident CODditions.
Provide for review*a compre-hensive qualification for this component, or provide analysis or justification for the test duration* relative to the service environment.
- c.
The documentation cited in Reference. l indicates that thennal aging considerations were not addressed.
Tests which were successful using test specimens that had not been preaged may be considered acceptable provided the component does not contain materials which are known to be susceptible to significant degradation due to thermal aging.
If the component contains such materials, a qualified life for the component mus.t be established.
Provide for revie\\'1 certification or specific documentation which addresses thermal aging degradation for these components.
- d.
The documentation cited in Reference 1 indicates that submergence tests were not conducted. Specifying saturated steam as a service condition during type testing of equipment that will become flooded in service is not an acceptable alternative for actually flooding the equipment during the test. Provide for review a comprehensive qualification test for this component which addresses submergence.
- 8.
COMPONENT NUMBERS 29 AND 30, POWER AND CONTROL CABLES Documentation reflecting cable qualification has not been made.
available for review.
Provide for review the technical report cited in Reference 4, or pro vi de for review a comp re hens i ve qua l i fi cation report for these components.
- 9.
COMPONENT NUMBER 31, INSTRUMENT CABLE The documentation cited in Reference 19 indicates that a specific instrument cable specimen was tested (3/C 16 AWG, 30 mils EPR insulation, neoprene jacket overall).
The test specimen must be the same as the equipment being qualified.
Provide for review certification or specific do~umentation which correlates the
- exact cable tested with those installed in the plant.
- 10.
COMPONENT NUMBER 35, FAN MOTOR Documentation reflecting motor qualification has not been made available for review.
Provide for review the reports cited in References 16 and 24, or provide for review a comprehensive qualification report for this component.
- 11.
COMPONENT NUMBER 36, HYDROGEN RE COMBINERS Documentation reflecting qualification has not been made available for review.
Provide for review a comprehensive qualification report for this component.
- 12.
COMPONENT NUMBERS 38, 39,-40, AND 41, PRESSURE TRANSMITTER Documentation of qualification has not been made available for review.
Documentation cited in Reference 6 is deficient with respect to duration of environmental service condictions and submergency requirements.
Specifying saturated steam as a service con*dition during type testing of equipment that will become flooded in service is not.an acceptable alternative for actually flooding the equipment during the test. Provide for review a comprehensive qualification report for these components.
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