ML19276E843
| ML19276E843 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/28/1979 |
| From: | Baer R Office of Nuclear Reactor Regulation |
| To: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 7903210411 | |
| Download: ML19276E843 (50) | |
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%..c Docket Nos. 50-445 and 50-446 Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Towers Dallas, Texas 75201
Dear Mr. Gary:
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR CCMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 Enclosed are requests for additional information which we require to com-plete our evaluation of your application for operating licenses for Comanche Peak Steam Electric Station, Units 1 and 2.
These requests for additional information are the results of our review of the information in your FSAR through Amendment 3, and cover those areas of our review performed by the Instrumentation and Control Systems Branch and the Power Systems Branch.
Please amend your FSAR to include the information requested in the Enclosure.
Your schedule for responding to the enclosed requests for additional information should be submitted by March 23, 1979.
Based on your schedule for response and our workload, we will determine any licensing review schedule adjustments and inform you of any significant changes.
We intend to perform our review of the drawings listed in FSAR Section 1.7 concurrent with our review of your responses to the enclosed requests for additional information.
As discussed with you staff we conclude an up-dating of these electrical, instrumentation and controls drawings is 790321o$l
040. 103-Assure that a high energy line failure of the turbine by-pass (10.4.4) i system (TBS) will not have an adverse effect or preclude operation of any safety related components or systems located close to the TBS.
(SRP 10.4.4; Part III, Item 4).
040.104 Provide additional description (with the aid of drawings) of (10.4.4) the turbine by-pass valves and associated controls.
In your discussion include the principle of operations, construction, set points, and the malfunctions and/or modes of failure considered in the design of the turbine by-pass system.
(SRP 10.4.4, Part III, Item 1).
040.105 Provide the results of a failure mode and effects analysis to determine (10.4.4) the effect of malfunctions of the turbine by-pass system on the operation of the reactor and main turbine generator unit.
(SRP 10.4.4, Part III, Item 4).
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Discuss the effects of a high and moderate energy piping failure or failure of the connection from the low pressure turbine to condenser on nearby safety related equipment or systems.
Discuss what protec-tien will be provided for the turbine overspeed centrol system equipment, electrical wiring and hydraulic lines from the effects of a high or sederata energy p.ipe failure so that the turbine overspeed protection I'
system will not be damaged to preclude its safety function. '(SEP10.2, Part III, Item 8).
040. 98 Discuss the measures taken to prevent corrosion / erosion of condenser (10.4.1) tubes and components.
(SRP 10.4.1, Part III Item 1).
040. 99 Discuss the means for detecting and controlling condenser leakage.
(10.4.1 )
(SRP 10.4.1. Part III, Item 2).
040. 100 Indicate what design provisions have been made to preclude failures (10.4.1 )
of condenser tubes or cogonents from turbine by-pass blo#_cwn.
(SRP 10.4.1, Part III, Item 3).
040.101 Discuss the effect of main condenser degradation (leakage, vacuum, (10.4.1 )
loss) on reactor operation.
(SRP 10.4.1. Part III, Itam 1).
040. 102 Discuss the possible rechanisms for hydrogen production in the secondary (10.4.1) side water and provide the expected production rate of hydrogen in KFM. Discuss the effectiveness of the =eans to prevent hyd.w en buticup. (SRP 10.4.1, Pcr: III Item 1).
- 33'-
which each device begins operation to perfor:n its protective func-tion (in terms of percent of normal turbine operatino speed).
In order to evaluate the adequacy of the control and overspeed prctec-tion system provide identifying numbers to valves and mechanisms (mech-anical and electrical)~on schematics.
Describe in detail, with references to the identifying numbers, the sequence of events in a turbine trip including response times, and shc.w that the turbine stabilizes.
Provide the results of a failure mode and effects analysis for each of the overspeed protection systems.
Show that a single steam valve failure or failure of any high or moderate energy line cannot disable the turbine overspeed trip from functioning.
(SRP 102, Part III, items 1, 2, 3 and 4).
040.95 Provide a discussion on the inservice inspection program for the (10.2) turbine, turbine stop and control valves, intermediate reheat stop main and intercept valves and extraction heater non-return valves and also on the capability for periodic testing (state the frequency of tests) while operating at rated load.
(SRP 10.2, Part III, Item 5 and 6).
In section 10.2.2, Description, you indicate that the main generator 040.96 (10.2) is cooled by hydrogen at 60 psig pressure. You reference Figure 10.4-19 for the Flow Diagram Plant Gas Supply System - Hydrogen Supply.
This figure appears to be a duplicate of Figure 10.4-13.
Describe the protection ceasures considered in tne design to revent fires and explosions during c:erations such as filling and purging the generator, as well as during normal operation.
. Exhaust Gas System exposed to atmospheric conditions (ice, snow, and so forth) becomes blocked." Describe the exhaust path of the diesel engine exhaust gas to the atmosphere under the condition stated.
040.92 Experience at some operating plants has shown diesel engines have (9.5.8) failed to start due to accumulation of dust and other deleterious materials on electrical equipment associated with starting of the diesel generators (e.g. auxiliary relay contacts, control switches---
etc).
Describe the provisions made in your diesel generator electrical starting system design to preclude this condition to assure avai: ability of the diesel generator on demand.
Also describe under normal plant operation what procedure (s) will be used to minimize accumulation of dust in the diesel generator room.
In your response also consic~er the condition when unit 1 is in opera-tion and Unit 2 is under construction.
040. 93 In section 10.1 and 10.2 you state that the turbine generator is a (10.1)
(10.2) tandem-compound four-flow, 1800-rpm machine.
Also indicate the manu-facturer of the turbine generator.
040. 94 Expand your discussion of the turbine speed ccntrol and overspeed (10.1) protection system.
Provide additional explanation of the turbine and generator electrical load following capability for the turbine speed control system with the aid of system schematics (including turbine control and extraction steam valves to the heaters).
Tabulate the individual speed control protection devices (nomal, emergency and backup), the design speed (or range of speed) at 040.88 Discuss the design precautions that have been taken to prevent entry (9.5.7) of deliterious materials in the engine lubrication oil system due to operator error during recharging of lubricating oil or normal operation.
(SRP 9.5.7, Part III, Item ic).
Oa0. 89 Figures 1.1-11, 12, 13 show general arrangement plan views of the (9.5.8) diesel generator area for unit 1 at different elevations and figures 1.1-17, 18, 19 show similar views for unit 2.
Figures 9.5-58 and 59 show some details of the protective structures for the diesel generator intake and exhaust.
Provide larger and more ' etailed d
plan and elevation views of the diesel generator building with sectional views that clearly show details of the diesel aenerator arrangement.
0d0. 90 Ficure 9.5-57, Diesel Generator Combustion Air Intake and Exhaust (9.5.8)
System, schenatically shows two 6" light auace vent pipes to tne atmosphere from the diesel ergine lube oil sump tank and the crank-case.
Show the locations of these vent pipes on the drawincs requested in the previous question and indicate the seismic desian and quality class of these vents.
Ca0. 91 You state in subsection 9.5.8.2 that "a full-flow relief valve (9.5.8) located upstream frem the exhaust silencer perr.its the engihe to continue operating if the portien of the Diesel Gerarat:r C:: bus-icn 040.85 In reference to Figure 9.5-56, Flow Diagram Diesel General Lube (9.5.7)
Oil System:
- 1) Discuss the qualification of the auxiliary lube oil pump and keep warm pump (both pumps are shown to be non-seism'c) to perform in a manner to assure availability of the diesel ger.erator under all normal and accident conditions.
- 2) Show the location of instrumentation used to measure and alarm for temperature, pressure, flow and oil level.
3)
Indicate. if the filters and strainers have differer,tial pressure switches to alarm when cleaning is needed.
86 In subsection 9.5.7.2 is a statement, item 3, that "aater velocity in heat exchanger of B.S. fps maximum". Clarify the meanin,g of the value of "B.S."
040. 87 For the lube oil cooler heat exchanger provide:
(9.5.7) 1)
the design heat removal rate (btu /hr), and for both the tube and shell sides the ficw (lb/hr) and temperature differentials (*F).
2) the design margin (excess heat removal capacity) included in the design and verify tha t this is in accordance with the recomendations of the manufacturer.
040. 81 Figure 9.5-54 shows a surge tank (standpipe) in the diesel generator (9.5.5) cooling water system.
The surge tank will provide a reserve to cca-pensate for system changes in volume and any minor leaks during operation.
The surge tank will also maintain the rec,uired NPSH on the system circulating pump. Demonstrate that thE surge tank size will be adequate to maintain the required NPSH and makeup water for seven days continuous operation of the diesel generator at maximum rated load, or provide a seismic Category 1, quality group C makeup water supply to the surge tank.
040. 82 In section 9.5.6 provide information relative to the diesel generator (9.5.6) air starting on the following:
1) provide the pressure range of the air receivers for high and low acceptable pressure.
2)
Indicate the meth d of starting the diesel (air input into the cylinder or engagement of gear).
C40.83 Indicate if the filters shown on figure 9.5-55, Flow Diagram Diesel (9.5.6)
Generator Starting System, have pressure differential switches to alarm when cleaning is needed.
040. 84 You state in Section 9.5.6 that iou havc-inline air dryers to remove (9.5.6) excess moisture in the air starting system.
Describe the type of inlire air dryers, their operation and their effectiveness in rer. oval cf mois-ture in the diesel engine starting air.
. 040J9 Section 9.5.5 indicater that the diesel generator cooling water system (9.5.5) has two subsystems:
1) a closed water loop (jacket water) for tFe cylinder jackets, cylinder heads, fuel injectors, turbochargers, air intercoolers',
and lube oil cooler; 2) an external cooling water loop (service water) which cools the jacket water heat exchanger.
Provide information on the total heat removal rate (but/hr), flow (lbs/hr) and temperature differential ( F) for both the tube and shell sides of the jacket water heat exchanger.
Also provide the design margins (excess heat removal capacity) included in the design.
(SRP 9.5.5, Part III, Item 1).
0d0.80 Provide information on Figure 9.5-54, Flow Diagram Ciesel Generator (9.o.0)
Jacket Water System, on instrumentation (temperature, pressure, flow measurement and water level).
. 5)
Previde a discussion on the fuel oil level instrumentation for the 7 day storage tanks including any associated local and con-trol room alarms for warn:ng of low level.
040.76 Figure 9.5-51, Diesel Generator Fuel Oil Tanks, indicates that (9.5.4) the grade level where the tanks are buried is 810 feet.
Section 3.4 indicates the PMF is 789.7 f t.
It appears that the grade level at the bottom of the tanks is below the PMF level.
Provide a discussion on the effects of a flood at PMF level on the storage tanks. Assuming the storage tanks have a low fuel level would water seepage cause a lifting of the tanks due to bouyancy effects?
040.77 In section 9.5.4 you indicate that the fuel oil for the storage (9.5.4) tanks can be supplied by tank truck or in special circumstances by railroad tank car.
Provide a listing of cities and areas together with the distance in miles from the site from where the fuel oil can be obtained.
040.78 Discuss what precautions have been taken in the design of the fuel (9.5.4) oil system in locating the fuel oil day tank and connecting fuel oil piping with regard to possible exposure to ignition sources such as open flames and hot surfaces.
(SRP 9.5.4, Par:t III, Item 6).
components these statements refer to, describe what is your interpreation of " equivalent quality", and will these particular components be seismically qualified either by analysis or test to assure availability of the diesel generators under all normal and accident conditions.
040.75 In reference to Figure 9.5-52, sheets i and 2, Flow Diagram Diesel (9.5.4)
Generator Fuel-Oil Storage and Transfer System and Section 9.5.4:
1)
Provide information on the instrumentation for measuring the flow rate of the fuel for the emergency diesel generator fuel oil system.
2)
Figure 9.5-52, sheet 1, has roughed in outlines around groups of equipment with a triangular symbol inscribed witti a number 3.
Are these outlines to indicate a Seismic Category I, quality Class 3? Provide an updated version of this figure which clearly shows the final seismic design notation.
3)
Figure 9.5-52, sheet 2, indicates that the auxiliary fuel oil pump, drip waste return pump on the auxiliary module and parts on the engine are not designed to seismic Category I, quality class 3 classification.
Provide a discussion on the qualification of these parts to assure availability of diesel gen'erators under all normal and accident conditions.
- 4) In reference to Figure 9.5-52, sheet 2, indicate if pressure differen-tial switches will be provided for the filters and strainers to. alarm when cleaning is needed.
040.71 Table 1.3-2, sheet 18, and subsection 9.5.4.2.2 indicate that the (9.5.4) diesel generator fuel oil tank is sized for 2,160 gallons.
Branch technical position ASB 9.5-1 and Regulatory Guide 1.120 limits the total capacity of 4y tanks in the diesel generator area to not more than 1,100 gallons.
Revise your FSAR to conform to the above requirements.
040.72 Appendix 1A(N), Appendix 1A(B) and section 9.5.4 do not list Regula-(9.5.4) tory Guide 1.137.
Discuss your conformance to R.G.1.137 and also to ANSI N-195 relative to the Emergency Diesel Generator Fuel Oil Storage and Transfer System.
040.73 Discuss your conformance to regulatory guides 1.6E.,1.102 and 1.117 (9.5.4)
(9.5.5) relative to the diesel generator auxiliary systems including: 1) the
-(9.5.6)
(9.5.7) fuel oil storage and transfer system; 2) the cooling water system; (9.5.8)
- 3) starting system; 4) lubrication system and; 5) the combustion air intake and exhaust system. Also discuss the confomance to regulatory guide 1.26 for items 3 and 5 above and regulatory guide 1.29 for item 4 above.
040.74 In sections 9.5.4 and 9.5.7 you state that the components in tre (9.5.4)
(9.5.7) system are designed to the requirements of the ASME B & PV Code,Section III, Class 3.
Hcwever, when an ASME Class 3 design comconent is comercially unavailable, the cceponents is proven to be of equivalent quality.
Indicate what particular
. 040.70 Section 8.3.1.1.12 of the FSAR states that all safety-related Class (8.3.1.1.12) lE motors are designed to accelerate their driven loads with 80 percent of the motor rated voltage available at the terminals.
However, Section 8.3.1.1.11 indicates that the voltage available at the motor terminals may dip below 75 percent of nominal voltage when the diesel generator breaker closes.
From this information in the FSAR, it appears that motors designed to start their loads at a minimum 80% of rated voltage will be required to start their loads at below 75% of rated voltage.
Provide justification for using motor designed to start their loads at a minimum of 80 percent of ri2ed voltage.
e k
04067 In order to meet Branch Technical Position RSB 5-1 (see NRC ques-( 8.3.1 )
tion 212-32), it is anticipated that independent and redundant power supplies will be required to each of the four RHR valves shown on figure 5.4-6 of the FSAR (8071A, 8071B, 8072A, 80728).
If four power supplies are required, provide a description of the power supplies electrical and physical separation, provide a description of the physical separation provided the power and control cables to these valves and identify each location where the physical separation between any of the four cables (power and control) is less chan a three hour rated fire barri.r.
040. 68 Provide a description of the automatic and manual design pro-( 8. 3.1 )
visions for testing the solid state sequencer.
040.69 For each type of electric circuit that penetrates cc.ntainment; (8.3.1.2.1)
- 1) describe the fault-current-versus-time for which the primary and backup overcurrent protective systems are designed and qualified,
- 2) describe the fault-current-versus-time for which the pene-trations are designed and qualified, and 3) provide coordinated curves for items 1 and 2 above to show that the fault-current-versus-time condition to which the penetration is designed and qualified will not be exceeded.
040.64 In section 9.5.1.3.l(16) of the FSAR, i.t has been stated that "the (8.3)
(9.5.1) loss of the hot shutdown panel has no effect on safe shutdown of the plant because it is redundant to the control room and a fire is postulated in only one area of the plant at a time".
Provide a description of the control circuitry derign to the hot shutdown panel and to the centrol room that snows
- 1) that a fire at the hot shutdown panel has no affect on controls in the control roca and 2) that a fire in the cc.ntrol room, cable spreading room or any other room between the ht.t shutdown panel and the control room have no affect on the controls at the hot shutdown panel.
040.65 Class 1E cabling that leave one seismic Category I building and (8.3) enters another seismic Category I building must be routed through appropriately designed and classified ducts.
Provide a description of your design criteria for Class !E cables routed between seismic Category I buildings.
040.66 The provisions for periodic testing of diesel generator units (8. 3.1 )
should satisfy the recommendations of Regulatory Guide 1.108 (SRP' Section 8.3, Part II, items 4e and 7).
Describe how the Comanche Peak design meets the recommendations of Regulatory Guide 1.108.
In addition, identify and justify each exception taken to Regulatory Guide 1.108.
onsite power sources.
It is the staff's concern that the use of a single sequencer for both offsite and onsite power sources may com-promise the independence between the' onsite and offsite power sources.
Provide the results ofyour analysis that demonstrates that no sin-gle failure will
- 1) prevent the separation of the redundant portions of the standby power system from the preferred power system when required or 2) render both preferred power sources and bot;h redundant onsite power sources unavailable.
040. 60 It is the staff position that the diesel generator qualification (8.3.1) testing programs satisfy position 5 of Regulatory Guide 1.6, Regulatory Guide 1.9, and Branch Technical Position ICSB 2 (PSB)
(SRP revision 1 section 8.3.1, Part II, Item 4d).
a)
Describe how the reconnendations of position a of Regulatory Guide 1.9 will be demonstrated as part of the diese1 generator prototype qualifications program.
b)
Branch Technical Position ICSB 2 (PSB) reccmmends that 10 per-cent of the 300 valid start and load tests be from design hot equalibrium.
Section 8.3.1.1.11 (7b) of the FSAR implies 100 percer.t of the starts will be from design cold ambient condition.
Clarify section 8.3.1.1.11 of the FSAR.
040. 62 As indicated in Section 8.3.1.3 of the FSAR the Comanche Peak (8.3) design provides for the connecticn of both Class lE anc ncn-Class lE loads to Class lE buses.
- Identify all non-Class 1E loads connected to Class 1E buses.
a.
b.
For each non-Class 1E load connected to the Class lE buses via isolation devices provide qualification information to demonstratt that any failure in the non-Class 1E circuit will not cause unacceptable influences in the Class 1E circuits.
c.
For the security lighting systems that rely on overcurrent devices for isolation (FSAR Section 8.3.1.2.1) and for othEr non-Class 1E loads connected to the Class lE buses via unacceptable isolation devices, provide the results of an analysis ta demon-strate that any failure of non-Class lE circuits or failure of multiple non-Class lE circuits due to a design basis event, such as a fire will not degrade Class lE circuits beltw acceptable levels.
0a0.63 Tabulate, for each Class 1E system required to bring the plant to (8.3.1)
~ a safe cold shutdown, the systems essential power, control, and (9.5.1) instrumentation cable routing locations.
Identify the required systems essential cable and their' location where the separation from the cables redundant counterpart is less than a three hour rated fire barrier.
e W9 onsite power sources.
It is the staff's concern that the use of a single sequencer for both offsite and onsite power sources may com-promise the independence between the onsite and offsite power sources.
Provide the results ofyour analysis that demonstrates that no sin-gle failure will
- 1) prevent the separation of the redundant portions of the standby power system from the preferred power system when required or 2) render both preferred power sources and both redundant onsite power sources unavailable.
O40.60 It is the staff position that the diesel generator qualification (8.3.1) testing programs satisfy position 5 of Regulatory Guide 1.6, Regulatory Guide 1.9, and Branch Technical Posit' ion ~ ICSB ~2 (PSB)
(SRP revision 1 section 8.3.1, Part II, Item ad).
a)
Describe how the recomendations of position a of Regulatory Guide 1.9 will be demonstrated as part of the diesel generator prototype qua'lifications program, b)
Branch Technical Position ICSB 2 (PSB) reccmmends that 10 per-cent of the 300 valid start and load tests be from design hot equalibrium.
Section 8.3.1.1.11 (7b) of the FSAR implies 100 percent of the starts will be frca design cold ambient condition.
Clarify section 8.3.1.1.11 of the FSAR.
C40. 62 As indicated in Section 8.3.1.3 of the FSAR the Ccmanche Peak (3.3) design provides for tre c:nnecticn of both Class lE and ncn-Class lE leads to Class lE buses.
040.55 In regard to thermal overload protection for mctors of motor-operated (8.3) safety-related valves, describe how the Comanche Peak design meets the recommendations of Regulatory Guide 1.106.
Identify and justify each exception taken to the regulatory guide.
040. 56 To assure that the requirements of GDC 1 are met in the preferred (8.2.1.2)
(8.3) and onsite Class lE AC pcwer system the quality assurance program must satisfy the requirements of IEEE Standard 336 as augmented by Regulatory Guide 1.30 (SRP Section 8.2, Part II, Item 2a).
Describe and justify each exception taken to IEEE Standard 336-1971 and Regulatory Guide 1.30.
040. 57 Preoperational and initial startup tes t programs for the offsite (8.2.1.2)
(8.3) preferred and onsite Class lE AC power systems should be in accor-dance with Regulatory Guide 1.68 as augmented by Reculatory GJide 1.41 (SRP Section 8.2, Part II, Item 2b).
Describe and justify each exception taken to Regulatory Guides 1.68 and 1.41.
040. 58 With regard to the surveillance of the offsite preferred and on-(8.2.1.2)
(8.3) site Class 1E AC power system operability status, an acceptable design must satisfy the positions of Regulatory Guide 1.47, as aug-mented by Branch Techniczl Position (BTP) ICSE 21 (SRP Section 8.2 Part II, Item 2c).
Describe and justify each exception taken to Regulatory Guide 1.47 and BTP ICSB 21.
C20.59 As implied in Section S.3.1.1.5 of the FS4R, m C:manche eak design (3.3.1.1.5) includes the use of the same safety injecticn se:tencer unit for the connection of large loads ;when power is frcm ei her the offsite or t
4.
The voltage levels at the safety-related buses should be optimized for the full load and minimum load conditions that are expected throughout the anticipated range of voltage variations of the offsite power source by appropriate adjustment of the voltage tap settings of the intervening transformers. We require that the adequacy of the design in this regard be verified by a'etual measurement and if correlation of measured values with analysis results. Provide a description of the method for making this verification; before initial reactor pcwer operation, provide the documentation required to establish that this verification has been acccerplished.
040.54 The provisions for testing the automatic transfer of p:wer from (8.2.1.2) the preferred to the alternate to the standby scur:e, the pro-(8.3) visions for testing the DC power sources, rel:ys, and switches associated with the 345 and 138 KV preferred :ower scurce pro-tection system, and the provisions for testing the ensite Class IE AC and DC power systems should satisfy the recc.mendatien of Regulatory Guide 1.118 (SRP section 3.2, Part I!I, iten 3).
Des-cribe how the Cemanche Peak design meets the recornendations of Regulatory Guide 1.118.
In addition identify and justify each exceotion taken to Regulatory Guide 1.113.
g verifying that on lost of offsite power the emergency buses have teen de-energued and that the loads have been shed from the er.ergency buses in accordance with design requiremnts.
b) Verifying that on loss of offsite power the diesel generators start on the autostart signal, the emrgency buses are energi:ed with permanently connected loads, the auto-connected shutdown loads are energized through the lead sequencer, and th9 system operates for five minutes while the ganerators are leaded with the shutd:wm loads.
c) Verifying that on a safety features actuation signal (without loss of'offsite power) the diesel generators start on the autostart signal and operate on standby for five minutes.
d) Verifying that on loss of offsite power in conjunction with a safety features actuation signal the diesel generatcrs stact on the autostart signal, the e.Trgency buses are energized with per.anently connected loads, the auto-connected emergency (accident) leads are energized through the load sequencer, and the system operates for five minutes while the generators are loaded with the emergency leads.
e) Verifying that on intermptien of the onsite scurces the loads are shed free the emergency buses in accordance with design require-cants and that subsequent loading of the onsite sources h through the lead sequencer.
2.
We require that the current system designs automatically prevent load shedding of the emergency buses once the onsite sources are supplying power to all sequenced loads on the emergency buses. The design shall also include the capability of the load shedding feature to be automatically reinstated if the onsite source suoply breakers are tripped..The automatic bypass and reinstatement feature shall be verified during the periodic testing identiff eo in Position 3.
In the event an adequate easis can be provided for retaining the load shed feature when loads are energized by the onsite power system, we will require that the setpoint value in the Technical Specifications, which is currently specific as "... equal to or greater than..." be amended to specify a value having maximum and minimum limits. The licensee' bases for the setpoints and' limits selected must be documented.
3.
We require that the Technical Specifications include a test require-ment to demonstrate the full functional cperability and independence of the onsite p:wer sources at least once per 13 months during shutd:wn.
The Technical Specifications shall include a requirement for tests:
(1) simulating loss of offsite power; (2) simulating loss of offsite p:wer in conjunction with a sa'e'ty feature actuation signal; cnd (3) simulating interruption and subsequent ret:nnection of ensite ;cwer sources to their respective buses.
Proper operation shall be determined by:
c) 7.ne time delay selected shall be based on the foliceing c:ncitions:
(1) Tne allowable time delay, including c.argin, shall not exceed the maximum time delay that is assumed in the SAR accident analyses; (2) The time delay shall minimize the effect of short duration disturbances from reducing the availability of the offsite power source (s); and (3) The allowable time duration of a degrads4 voltage condition at all distributton system levels shall not result in failure of safety systems or comoonents; d) The voltage sensors sh'all automatically initiate the disconnec-tion of offsite power sources whenenver the voltage set point and time delay limits have been exceeded; e)
The voltage sensors shall be designed to satisfy,the applicatie requirements of IEEE Std. 279-1971, " Criteria for Protection Systems for Nuclear Pcwer Generating Stations"; and f) The Technical Specifications shall include limiting condition for operation, surveillance requirenvants, trip set points with minimum and maximum limits, and allowable values for the second-level voltage protection sensors and asscciated time delay devices.
Ca0.53 Recent operating experience has sh:wn that adverse effects en the (3.2) safety-related power system and safety related equipment and loads can be caused by sustained low or high grid voltage conditions. We therefore require that your design of the safety related electrical system meet the folicwing staff positions.
Supplacent the descrip-tion of your design.in the FSAR to show how it meets these positicns or provide appropriate analyses to justify non-conformance with these positions.
1.
In additior, to the undervoltage scheme provided to detect loss of offsite power at the safety ' busses, we require that an additional level of voltage protection for the onsite pcwer system be provided with a tire delay and that this additional level of voltage protecticn shall satisfy the following criteria:
a) The selecti n cf voltace and time se: ;0ints shall be determined fr:m an analysis of the voltage requiremen:s of :he safe:y-related loacs at all ensite system cistribution leveis; b)
The vcitage.pr:tection snall include c:incicence icgic cn a per bus basis t: preclude s;urious trips of the of fsite ;0wer scurce; 04051 Describe the specific design prov.sions included in the plant Class (8. 2f)
IE power systems, to assure continued operability of safety equip-ment should the off-site power system characteristics exceed the '
limits identified in Question 040.48 due to abnonnal system conditions.
The response should also specifically include the following:
(1) The design basis and criteria for identifying the off-site power system degradation and isolation of the plant' electrical power systems from the off-site power system.
(2) The design bases and criteria of systems used by the control room operator to identify the condition of all safety related buses and other safety related equipment during an off-site power system de;radation.
(3) A list identifying those mcnitors used by the control rcom operator in (2) above. This shculd also specifically include reters, indicator types, alarm setpoints, and recorders.
040.52 provide a description of the method which will be employed to verify (8.2) before reactor operation (and pericdically thereafter) the adezcacy of the plant design with regard to engineered safety features bus y ci:29e levels ar.d ; rid system scabili:y.
-12 (3) Specific design features incorporated in the plant electrical system, i.e., transformer on load / offload tap changes, voltage regulators, etc., to assure that acceptable voltage levels are maintained at the safety related buses for all modes of plant operation.
04050 Provide a description of the procedures used to maintain grid con-(8.2) figuration and operation in a condition which always satisifies the limits identified in Question 040.48.
Also, provide the following:
(1) Describe hcw the operator is made aware of the operation of the grid in regard to the limits identified in Question 040. 48.
(2) The effects of loss of the nuclear generating unit on offsite power source while operating at the limits identified in Question 040.48.
(3)
The effects of loss of the largest grid load on off-site power source while operating at the limits identified in Question 040.48.
(4)
Identify any restrictions placed on the grid operation that requires spe:ific spinning reserve (either real or reactive power) to be available within a dedicated distance from the nuclear station in order to maintain the off-site power source wichin the limits identified in Question 040 A8 during ~ grid disturbances..
040.48 State the nominal value and the maximum and minimum limits on voltage and frequency available to the station from the off-site power grid for all modes of station operations.
Discuss the relationship of these maximum and minimum limits with the predicted stable grid conditions for normal and degraded operations (e.g., ' deliberate voltage reduction to offset high power demand conditions).
040.49
'n'e require that a review be performed on the design and installation (8.2) of the station electrical systems to provide assurance that all equipment will function continuously at the c.axinum and minimum electrical characteristics during all modes of plant operation iden-tified in the Question 040. 48. Provide a list identifying each circuit and/or el_ectrical device that does not satisfy the above.
The results of such a review should also specifically include the following:
(1) The nominal and the maximum / minimum values of voltage at the safety related buses for offsite power system voltage spreads defined in Question 040. 48.
(2) The capability of all safety related leads, control and instrumentation circuits to perfom their safety functions under the offsite power system voltage spreads dcfined. in Question 040.48.
040.45 In regard to the separation and independence between the preferred (8.2.1) and alternate power source cable bus ducts shown on figure 8.2-11 of the FSAR, describe the protection provided these bus ductsthat assures.that no single event (such as a fire or one bus duct failure) can simultaneously affect both bus ducts in such a way that neither can be returned to service in time to prevent fuel design limits or design conditions of the reactor coolant pressure boundary from being exceeded.
(SRP 8.2, Part III, Items 2b, 7, and 8).
040.46 The reactor protection system must be designed to prevent any load (8.2) dispatch system action that could interfere with safety actions during periods when safety actions are required.
Provide the results of analyses of this system which a sure that no failure mode of the load dispatch system will cause an incident at the generating station or interfere with any protective action required.
(SRP Section 8.2, Part III, Item 11).
040.47 Describe the power grid frequency decay rate expected at Comanch (8.2.2)
Peak Station as a. result of disturbances occurring anywhere in the grid system.
Describe the type of disturbances considered in your study and define the maximum expected frequency decay rate. at the Comanche Peak Station.
(SRP 8.2, Part III, Item }f).
.g.
040. 44 Preferred power for unit 1 is supplied from the 345 KV switchyard (8.2.1) via transformer XST2.
If this preferred source becomes unavailable the Class lE buses are transferred automatically to the alternate offsite power source.
For unit 1 this alternate source is from the 138 KV switchard via transformer XST1, normally open breaker lA2-2, bus l A2, ' Switch 1DSW2, and normally open breaker LEA 2-2.
The description in section 8.2.1 does not address breaker coordina-tion between breakers lA2-2 and 1A2-1 or the details for shedding of loads before automatic transfer.
Provide in the FSAR a more detailed description of this automatic transfer design between the preferred and alternate power source for both Unit 1 and 2.
a)
The description should include logic and electric, schematic diagrams which show the testing provisions as well as the transfer scheme.
b)
It is not clear if the startup transformers have been sized with sufficient capacity to supply the DBA loads from the other unit as a step function versus sequencing while supplying the DBA or maximum loads for its associated unit. The description should clarify the design in this regard.
B.
Equipment Qualification plans for nuclear strainer motors 1)
On page 14 of the Reliance Electric Company summary report dated July 1,1978 it is indicated that a prototype motor was thermally aged.
Describe the extent of this thermal aging.
2)
The prototype motor after being aged to end of expected life, shoulc' have been tested at the expected extremes of the normal environment, expected extremes in power supply voltage, and expected extremes in the environmer.t assuming a loss of environmental support system.
Provide additional information that addresses these items.
3)
Describe the additional testing performed by Limotorque Corporation.
040.42 Identify each Class lE equipment that is not served by redundant (3.11 )
Class lE environmental support systems.
Define the limiting environmental conditions that are expected to occur, assuming a loss of the environmental support system.
040.43 The interrelationship between the nuclear unit and the power grid (8.1.1) have not been clearly defined in Section 8.1.1 of the FSAR.
Re-vise figure 8.1-1 and/or provide additional scaled drawings that clearly show the interrelationship between the power grid and the nuclear plant.
(SRP Secticn 8.1, Par: II).
4.
Provide the detailed description of the Functional test procedure A-302728-01 and Electrical characteristics Test procedure A-302737-01.
5.
Test procedure A-302734 implies there will be on-going quali-fication to determine qualified life.
Section 4.8 indicates that only a functional test will be performed as part of ttfis on-going qualification.
Justify the non inclusion of tests outlined in sections 6.8 through 6.11 for the on-going quali-fication program.
040.41 The following questions have been prepared based on our review of (3.11) environmental and seismic qualification plans provided by the appli-cant by letter dated December 15, 1978 to S. A. Varga from R. J. Gary.
A.
Class lE process solenoid valves - containment i' solation service.
It apoears from the test report infomation provided that valves V52600-5292-7 and V52600-5950-1 are to be cualified by tests per-formed on a different valve (V52600-5291-2).
This different valve is hemetically sealed by virtue of all welded construction as stated on sheet.10 of qualification test report on solenoid valves P/N V52600-5292-7 and V52500-5950-1.
The two valves being quali-fied for usa at Comanche Peak appear not to be hemetically sealed.
Provida qualification test infomation for the actual valves to be installed at Ccmanche Peak or provide additional infomation that shcws that valves V525C0-5929-7 and 752600-5950-1 are in fac: hemetically sealed.
7.
For each representative device located on the Solid-State Safeguards System Sequencer provide the qualification test plan. test set-up, test procedures, acceptance criteria, conclusions, and results for the monitoring of electrical safety function during seismic shaking.
B.
Solid-State Is~olation Eouioment 1.
Test procedure, seismic qualification (A-302732-01) does not Jescribe electrical monitoring during the actual seis-mic shaking.
Provide this description.
2.
Test Procedure, Qualification test plan, Number A-302734-01 does not address the following items, a) definition of service conditions to be simtslated, b) test equipment requirements including accuracies, c) performance limits or failure definition, and d) mar 3 ni Provide additional infor. nation that addresses these items.
3.
Section 5.0 of test procedure A-302734 states that the test unit will not be subjected to radiation during qualification testing.
Demonstrate that the required radiation level 3
(10 rads ganna) will produce less effect than the radiation level that wculd cause loss of the equipment's Class IE func-tion.
(IEEE Standard 323 Section 6.3.2(4)).
, 5.
In reference to Actor Environmental Testing Corporation Test report No.13601 (Appendix D to report No. 2462-1), the con-tacts af the relay being tested were not monitored during seis-mic shaking in the open position or during the actual opening and closing operation.
It is the staff position that both the normally open and normally closed contacts be monitored in tne energized and deenergized condition during seismic shaking.
It is also the staff position that the relay be operated and monitored while changing position from the energized to the deenergized position and from the deenergized to the energized position during seismic shaking.
Provide results of tests that meet the above described staff positions.
6.
From the information provided in test report No.13601 in ~ regard to the Agastat relay (type GpB), it appears that the relay was not monitored during seismic shaking.
It is the staff position that the following items be monitored during seismic shaking:
a) open and blosed contacts with the relay deenergized, b) open and closed contacts with the relay energized, c) changing posi-tion from the energized to the deenergized position, d) changing position from the deenergized to the energized position, e) the
~
ti.me delay function, and (f) the shift of the calibrated set point.
. A.
Solid-State Safeguards System Secuencer 1.
Page 3.10N-1 of FSAR states that aging and environmental effects prior to seismic qualifications will be taken into account inaccordance with 323-1974.
Seismic qualification report No. 2432-1 Solid-State Safeguards System Sequencer does not take into account aging.
It is the staffs position that equipment be aged to a qualified life before seismic shaking. Justify not aging or provide results of retest using acceptably aged equipment.
2.
Since the Solid-State Safeguards System Sequencer is being seis-mically tested on a component basis provide a listing of components that includes the following:
(a) type (functional designation or device number), (b) Manu-facturer, (c) Manufacturer's type number and model number, (d) functional description, (e) Safety function, (f) Electri-cal schematic diagram number where device appears and, (h) iden-tification of devices selected for monitoring during the seismic testing.
3.
Provide a general description of the Solid-State Safeguards System Sequencer and its safety functions.
4.
Justify, through the documentation of applicable test results, that contact chatter of 2 milliseconds will have no affect on safety systems.
3 040.36 This question number not used. 'Information requested by the (3.11)
Power Systems Branch is the same as the information requested in Question 032.32.
040.37 This question number not used.
Information requested by the (3.11)
Power Systems Branch is the same as the information requested in Question 032.32.
040.38 Table 3.118-3 and Section 3.113.4.2 of the FSAR defines the upper (3.11) environmental limit that Class lE equipment will operate.
In addi-tion to the upper limit define the normal operating envi.ronment and the lower limit operating environment that the Class lE equipment will be expected to operate.
040.39 Specific information concerning GDC's 2 and 50, Regulatory c ides u
(3.11) 1.63 and 1.131, and IEEE Standard 317 and 383 has no't beer included in section 3.11 of the FSAR.
Provide this information.
040.40 The following questions have been prepared based on our review (3.11) of BOP environmental qualification plans provided by the appli-cant by letter dated November 17, 1975 to S. A. Varga from R. J. Gary.
2 040.34 On page 3.118-6 of the FSAR, it is stated that specific information (3.11) concerning how Appendix B of 10 CFR Part 50 is met is located in Chapter 17.
It is the staff's requirement that a quality assurance program meeting the requirements of 10 CFR 50 Appendix B be established and implemented to provide issurance that all qualification test re-quirements for each safety related equipment have been satisfactorily accomplished.
Based on the statement that specific information has been provided in Chapter 17, it is not clear that the Commanche Peak qualification program is in compliance with this staff requirement.
On page 3.1-3 of the FSAR it has been stated that the design, fabrication, ccnstruction, and tasting of safety components supplied by Westinchouse conform to the requirements of 10 CFR Part 50, Appendix B.
- Describe, similarly, the ccmpliance to the requirements of 10 CFR Part 50, Appendix B for the BOP supplied safety related electrical eoui; ment or justify non-compliance.
040.35 Section 3.11B of the FSAR provides reference to Section 15.1 of the (3.11)
FSAR for results of a Steam line break versus time for the steam line break inside containment.
Provide a similar reference for steam line break outside contair. ment.
ENCLOSURE 2 REQUEST FOR ADDITIONAL INFORMATION COMANCHE PEAK UNITS 1 AND 2 POWER SYSTEMS 040.32 On page 3.118-4 of the FSAR it has been indicated that IEEE Standard (3.11) 334-1974, IEEE Standard for Type Tests of Continuous Duty Class lE Motors for Nuclear Power Generating Stations, does not. apply because the containment has no continuous duty class lE motcrs.
The 1974 version of IEEE Standard 334 coes not differentiate between motors inside and outside containment.
It is the staff,nnsition that motors outside as well as motors inside the containment be qualified to IEEE Standard 334-1974.
Provide detailed qualification program in-formation for continuous duty Class lE motors located outside con-tainment.
040.33 On page 3.118-5 of the FSAR, it is indicated that valves located in-(3.11) side of containment are listed in Table 3.118-2 and are type-tested in accordance with IEEE 382-1972.
Valves located outside containment have not been addressed.
It is the staff position that valves oustide as well as inside containment be identified and qualified in accordance with IEEE Standard 382-1972.
Revise the FSAR to clearly identify the criteria used for the qualification of valves located outside contairrnent.
32.53 On Figure 7.6-1, it is shown that both the 480V 3) AC power and
( 7. 6.1 )
the 125DC power feed each inverter.
In Section 7.6.1.2, it is stated that inverter breakers have no manual controls provided on the control board, as no manual transfers for 480 VAC to 125 VDC are necessary in the event of loss of the 480 Volt AC preferred power sourre.
Please provide detailed schematic diagrams to illustrate the operation of the inverter and its automatic transfer capability.
32.54 Your response to Q32.27 is unacceptable.
The I&C portion of the RHR (7.6.2) isolation valves should meet the single failure criterion to avoid damage by overpressurization or the potential for loss of integrity of the low pressure system and possible radioactive releases.
In conformance with the Branch Technical Position EICSB-3 of SRP Appendix 7A,
'the isolation valves between Reactor Coolant System and the Residual Heat Removal System shculd hav.s indecetident and diverse interlocks to prevent them from both being opened.
Your design has not addressed the diversity capability.
Provide the recuired information on pressure transmitters PT 205 and PT-403 to satisfy the diversity recuirement.
32.55 Your response to Q32.12 on conformance to R.G.1.75 is inadequate.
( 7.1. 2. 2.1 )
Provide information which describes the instrumentation and control ci-cuits.vnere over:urren :evices are used as isola-ion :evices.
his informa-ion snculd include -he ty:e of isc'l.ic avices Jsed 3r.c
.".e qualificati r 'nfCrTati n #:r -hese isoli-i:n de'.icss.
32.51 It is stated in Section 7.4 that there are no identifiable safe (7.4) shutdown systems per se.
The applicant should clearly identify those systems that are required for safe shutdown of the reactor.
The applicant should also provide a discussion of how the instrumentation and control portions of the safe shutdown systems conform to the following acceptance criteria stated in Part II of Section 7.4 of SRP.
(1) have the required redundancy (2) meet the single failure criterion.
(3) have the required capacity and reliability to perform intended safety functions on demand.
(4) are capable of functioning during and after certain design basis events such as earthquakes, accident, and anticipated operational occurrences.
(5) are testable during reactor operation.
35.52 The following regulatory guides related to instrumentation (lAN)
(LAB) and control system are applicable to the Ccmanche Peak station.
R.G. 1.100 (3/76), Seismic Qualifica: ion of Ziectric Equipment for Nuclear. Pcwer Plants, R.G. 1.105, Rev. 1, Instrument Setpoints, R.G. 1.118, (6/76), Periodic Testing of Electric Power and Prctection Systems.
Srcw new j:ur design ac clies wi:n :ne recommenta:icns Of a' cve RegLlatory 3uides.
Ju s.i f, iry exce0;i0ns.aken.
32.48 Describe the automatic features for switching from the injection (7.3)
(6.3) mode to the recirculation mode which are provided to assure the proper operation of safety injection system and containment
~
heat removal system.
Your response should include related logic diagrams, schematic diagrams, and the status ir.dication information available to the operator in the control room.
32.49 Provide the LOCA and the MSLB accicent environmental envelop (3.11 )
(6.2) inside the containment to verify the adequacy of the qualification of those Class lE equipment required to mitigate these events.
32.50 In Section 9.2.2.2.1, it is stated that component cooling water (CCW)
(7.3)
(9.2) is not supplied to RHR and containment spray heat exchangers during normal plant operation.
(a)
Describe your design of initiation circuitry, control room indication and/or alarm circuitries utilized for this portion of CCW system.
(b)
Provide analyses, including a failure mode and effects analysis, to demonstrate that the instrumentation and control portions relied upon to establish comconent cooling water to these safeguards systems will satisfy IEEE Std. 279-1971.
(c)
Provide a periodic test plan for these circuitries to satisfy the recommendations of R.G. 1.22.
_g.
32.45 system downstream of the MISVs, since they perform the redundant (7.3)
(10.3) isolation function in each steamline.
These analyses shall demonstrate that the initiation, control and actuation circuits for both the MSIV's and the Turbine Stop Valve and the valves downstream of the MSIV will meet the Single Failure criterion with respect to isolation of the broken main steam line.
32.46 In Section 10.4.7.2 Item 3, it is stated that the feedwater (7.3)
(10.4) isolation valves are powered from two Class lE-125 VDC power systems.
The rest of the valves and equipments in the Feedwater Isolation System are powered from non-Class lE Systems.
Provide the results of analyses to show that your design of the initiation, actuation and control portions of the Feedwater Isolation System will perform their function assuming any Single Failure in the electrical instrumentation and control system following a feedwater line break accident.
32.47 Identify all instrumentation and control circuits and components (7.3)
(3.11)
(both safety and non-safety) that may become submerged as a result of a LOCA.
For all such ccmponents and circuits that are not qualified for service in such an environment, provide the results of an analysis to determine the following:
(1) the safety significance of the failure of the components and circuits (e.g. spurious operation, loss of function, loss of accident / post accident monitoring, etc. ) as a result of flooding. (2) tne ;rcoosed' design changes, if any, resul:ing frc, your ar.alysis.
32.41.
with these valves, illustrating how the above stated staff positions (7.3)
(7.6.4) are satisfied in the design.
32.42 Provide containment isolation valve position indication information (7.3) on FSAR Table 6.2.4-1 and Figure 6.2.4-1.
32.43 Table 10.4-9 and Figure 10.4-12 do not provide sufficient information (7.3).
(10.4).
on control aspects pertaining to the auxiliary feedwater system.
Provide a description of the instrumentation and controls associated with the automatic actuation of the auxiliary feedwater system.
Provide analyses including a failure mode and effects analysis for the electrical, instrumentation and control portion of the system to demonstrate how the requirements of IEEE Std 279-1971 are satisfied.
32.44 It is stated in Section 7.3.1.1.4 that the Hydrogen Purge system (7.3) detection components are controlled from the hydrogen analyzer subpanel.
Identify the location of the subpanel.
Provide sufficient information to show that this subpanel and the instrumentation are environmentally qualified.
32.25 Provide the results of analyses to show that your design of the (7.3)
(10.3) initiation, actuation and control portions of the Main Steam Isolation Systems will perform their functions assuming any single failure in the instrumentation and control system following a steam line break at:ident.
In :nis clant, recundan: "ain S eam Isola-icn
'!a l ve s "SI'/? for eacn s ea-line are
.o provided.
.e-e'are, :nese analyses mus-include :ne ici:ia:icn, con:roi ;n: ac ua:icn systems for the Turbine Stop valves a.d any c:ner valve in -he ain s eam 32.38 Penetrating Primary Reactor Containment) or justify any exceptions (7.5) ta ken.
32.39 It is stated in Section 7.2.2.2.3 that the power range channels (7.2) are tested by superimposing a test signal on the detector signal being received by the channel at the time of testing.
Based on this'information, we are unable to conclude that the power range high neutron flux rate reactor trip circuitry shown in Figure 7.2-1 is adequately tested to verify its performance capability.
Provide a detailed discussion of how this portion of the nuclear instrumentation is periodically tested.
32.40 Des.cribe the esign basis, and separation and isolation criteria (7.2) for: (a) " Reactor trip on turbine trip" circuitry.
Also provide detailed cable routing diagrams for this trip circuitry from the sensor in the turbine building to the final actuation located in the reactor trip system.
(b) the circuitries from Reactor Trip System to the BOP devices in the Turbine / Auxiliary Building.
32.41 Identify all remotely controlled valves in the Engineered Safety (7.3)
(7.6.4)
Features Systems which require power lockout during a certain moce of operation of the system to satisfy single failure criterion.
It is the staff's position that your design should also satisfy the Branch Technical positions EICSB and EICSS-13.
orovide ce: ailed descri;; ions, wi:n scnematic ciagrams #0r the :ircuitry asscciatec 32.35 In accordance with the Standard Review Plan Section 7.1, please (7.1) cross reference in Table 7.1-1 the discussions presented in Sections 7.4, 7.5 and 7.7 describing conformance to IEEE Std. 279-1971.
32.36 a) With regard to remote shutdown panels, describe the criteria
( 7.1 ).
(7.4) for the installation and routing of instrumentation arid control circuitries between these panels and the main control room control boards.
b)
In Sec. tion 7.4.1.2.1 Item 4, it is stated that, for selected equipment having local controls outside the control room, a selector switch is provided which transfers control of the equipment from the con. trol room to a local station.
Provide a detailed description with schematics of this transfer scheme.
32.37 In Section 7.2.11.2, it is stated that the manual trip consists of (7.2) two switches with two outputs on each switch.
One output from each switch is used to actuate the train A trip breaker while, the other output actuates the train 3 trip breaker.
Please explain how this design: a) satisfies the Single Failure Criterion for redundant trains and b) satisfies the. separation requirements for redundant trains.
32.38 Describe the Reactor Coolant System Wide Range Pressure Measurement (7.5)
System including numcer of senscrs,.anufac:urer, Mcdei number, sensor location and ins: alls:"on ar Ingemen:2.
- :he senscrs are located outsice :ne con:a'nmen:, descrice icw :nis sys em design con #cres to rec:rmenda-ions of R.G. 1.11 s:nstrument Lines 32.32 Please provide a. discussion of how your design conforms to the (7.1) following Regulatory Guides identified in the standard review plan Section 7.1.
(1)
R.G. 1.12, Instrumentation for Earthquakes (2)
R.G. 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems (3)
R.G.1.67, Installation of Overpressure Protection Devices.
Also identify in FSAR Table 7.1-1 as to where the conformance discussions for Branch Technical Positions BTP EICSB-3 through BTP EICSB-16 are provided.
32.33 In Section 7.1.2.6, conformance to Regulatory Guide 1.47 is 7.1 )
discussed.
Provide justification for not including in the list, the safety-related systems, such as the Containment Recirculation and Ventilation System, the Battery Room Ventilation System, the Fuel Handling Building Ventilation System, and the Chill Water System.
32.34 In your discussion in Section 7.1.2.11 on conformance to IEEE (7.1)
Standard 338-1971, it is stated that information on response time measurements developed by Nuclear Services Corporation has been employed as part of Westinghouse's environmental qualification test programs and manufacturer's data.
Please provide more detailed information in this area, and provide reference io ECDPs for specific respcase time measurements on -he applicable ecuipment.
(d)
Technical bases should be.provided to justify the
, placement of each type of equipment in categories 2.b and 2.c listed above.
(4) Provide the qualification test plan, test setup, test procedures, and acceptance criteria for at least one of each group of equip-ment in (l.d) as appropriate 'to the category identified in (2) above.
If any method other than type testing was used for qualification (operating experience, analysis, combined qualifi-cation, or ongoing qualification), describe that method in suffic'ient detail to permit an evaluation of its adequacy.
(5)
For each category of equipment identified in (2) above, state the actual qualification envelope simulated during testing (defining the duration of the hostile environment and the margin in excess of the design requiremants).
If any method other than type testing was used for qualification, identify the method and define the equivalent " qualification envelope" so derived.
(6)
Provide summary of test results that demonstrates the adequacy of the qualification program.
If analysis is used for qualification, justify all analysis assumptions.
(7)
Identify the cualification documents that contain detailed supporting information, including test data, for items (4),
(5) and (6) above.
In addition, to meet the requirements of Appendix B of 10 CFR 50, the staff requires a statement verifying (1) that all Class lE ecuipment has been qualified to the program described above, and (2) that the detailed qualification informa-ion and test results are available for NRC audit.
O (2) Categorize the equipment identified in (1) above into one of the foll,owing groups:
(a)
Equipment that will experience the environmental conditions of design basis accidents and will be required to mitigate said accidents, and that will be qualified to function in the accident environment for the time required for accident mitigation with safety margin to failure.
(b)
Equipment that will experience environmental conditions of design basis accidents, but will not be required to mitigate said accidents, but through which it must not fail in a manner detrimental to plant safe:y or accident mitigation, and that will be cualified to withstand any accident environment for the time during which it must not fail with safety margir. to fai'.ure.
(c)
Equipment that will experience environmental conditions of design basis accidents but will not be required to mitigate said accidents, whose failure (in any mode) is considered to not be detrimental to plant safety or accident mitigation, and that will need not to be qualified for any accident environment, but will be cualified for its non-acciden: service anvironment.
(d)
Equipment that will not experience environmental conditions of design basis accidents but will be qualified to demonstrate operability under its normal or abnormal service environment.
This ecui; ment would normally be located outside of the reactor containment.
(3)
For each type of equipment in the ca egories listed in (2) above, provide separate design specificaticn requirements, including:
(a) The system safety requirements.
(b).an environmental envelope as a function of time that includes all extreme parameters, both maximut and minimum values, expected to occur during plant shutdown, normal cepraticn, abncr a] cpera:icn and any design basis event (incI.ti.g '.CC: and 'ASL3 and
- cst event anc i-i xs ).
l-)
~ ;- g. 3 g g,- c.j,;
,]J4']
' ;3 ; 3 ~ 3,
,7,';4
. gn 3
I,bjiC".aj.c arf :#.'.e i'.i :I ; f
.'a t-
- ~ d " ~. a I in'. elope specifie: 'n 3.b i:cti.
032.31 In order to ensure that your environmental qualification program (3.11 )
conforms with General Design Criteria 1, 2, 4 and 23 of Appendix A and Sections III and XI of Appendix B to 10 CFR Part 50, and to the national standards mentioned in Part II " Acceptance Criteria" (which includes IEEE Std 323) contained in Standard Review Plan Section 3.11, the following information on the qualification program is required for all Class lE equipment.
1.
Identify all Class lE Equipment, and provide the following:
a.
Type (functional designation) b.
Manufacturer c.
Manufacturer's type number and model number d.
The equipment should include the following, as applicable:
1)
Switchgear
- 2) Motor control centers 3)
Valve operators
- 4) Motors 5)
Logic equipment 6)
Cable 7)
Diesel generator control equipment 8)
Sensors (pressure, pressure differential, temperature and neutron)
- 9) Limit Switches 10)
Heaters 11)
Fans
- 12) Control Boards 13)
Instrument racks and panels la)
Connectors 15)
Electrical penetrations 16)
Splices 17)
Terminal blocks
ENCLOSURE 1 Recuest for Additional Information Comancne Peak Units 1 and 2 Instrumentation and Control Systems Q32.31 Environmental Qualification of Class lE Equipment (3.11)
The following standard question on Class lE equipment qualification was presented to the applicant at a meeting held on 7/11/78.
Sub-sequently, the Staff received the Equipment Qualification Data Packages (EQDP's) for NSSS equipment forwarded by a Westinghouse letter (NS-TMA-1987) dated 11/15/78.
We also received some " samples" of 80P equipment Environmental Qualification plans submitted by applicant's letter TXX-2907 dated 11/17/78.
Our preliminary review of the information received so far indicated that those submittals do not fully address all the qualification details specified in the question.
Therefore, we require a complete response to this standard question.
Specifically for NSSS equipment qualification, the response should include a detailed cross reference in the FSAR identifying each paragraph, Section, page number and title in the referenced material which describes the specific qualification method, qualified life, and acceptance criteria used for each individual type of ccmponent used in CPSES.
For S0P equipment qualification, the response should include acceptance criteria and qualified life for each type of class lE component used in CPSES.
The staff will commence review of the Class IE ecuipment qualification test program of Comanche Peak when ne applicant fully addresses tne folicwing standarc cuesti:n.
Texas Utilities Generating Company ccs:
Nicholas S. Reynolds, Esq.
Debevoise & Liberman 1200 Seventeenth Street Washington, D.C.
20036 Spencer C. Relyea, Esq.
Worsham, Forsyt.he & Sampels 2001 Bryan Tower Dallas, Texas 75201 Mr. Homer C. Schmidt Project Manager - Nuclear Plants Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Mr. H. R. Rock Gibbs and Hill, Inc.
393 Seventh Avenue New York, New York 10001 Mr. G. L. Hohmann Westinghouss Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230
Mr. R. J. Gary i
' 7.:
desirab'le before we start their review.
Your submittal of more recent issues of these drawings should be scheduled for a date corresponding to your response to the Enclosures.
We will resolve the details of this updating of drawings with your staff as the date approaches.
Sincerely,
' kYn hy Robert L. Baer, Chief Light Water Reactors Branch No. 2 Division of Project Management
Enclosures:
1.
Request for Additional Information - Comanche Peak Instrumentation and Control Systems 2.
Request for Additional Information - Comanche Peak Power Systems ces w/anclosures:
See next page
.