ML19338F491
| ML19338F491 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/10/1980 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8010200425 | |
| Download: ML19338F491 (12) | |
Text
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..p, Al:bama Power Company 600 Nortn 18th Street P%t Offica Box 2641 Birmingham. Alabama 35291 Tetennone 205 250-1000 m
F. L.'CLAYTON, JR.
L Senior Vice President Alabama Power the southem electrcsystem l
October 10, 1980 i
Docket
'o. 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission i
Washington, D. C.
20555 Attention: Mr. A. Schwencer Gentlemen:
l JOSEPH M. FARLEY NUCLEAR PLANT - U'.;T 2 ENVIRONMENTAL QUALIFICATION REVIEW Enclosed is the additional Class lE Electrical Equipment environ-mental qualification information requested at the NUREG-0588 Audit exit meeting on September 24, 1980.
Silould any additional-information be required, please advise.
Yours truly, k,
- j; W. L. Clayton, Jr.
TLC:de Enclosure cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. W. H. Bradford Mr. L. L. Kintner w/ encl.
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QUESTION 1:
Were temperature and pressure conditions.used for the environmental qualification of equipment established in accordance with the methodology as outlined in NUREG-0588?
RESPONSE
NUREG 0588 states that the plant-specific profiles for temperature and pressure reviewed and found acceptable by the staff may be used for environmental qualification of equipment. The Bechtel standard computer program COPATTA was used to establish the time dependent temperature and pressure envelopes used for the environmental qualification of equipment inside containment. COPATTA and its associated topical report, BNTOP3 Rev. 4, have been reviewed by the NRC staff and have been accepted for use in the Farley containment design analysis. To determine qualiff-c-
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cation envelopes for breaks outside of containment the Bechtel standard computer program COPDA was used. This code and its associated, topical report, BNTOP4 Rev.1, have been reviewed and approved by the NRC. staff.
Both codes have been utilized to establish the containment and sub-compartment pressure and temperature profiles reported in the Farley FSAR for HELBs. Therefore, the method used to ' calculate the time-dependent temperature and pressure conditions is in accordance with the -
NUREG-0588 procedures.
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QUESTION 2:
What are the corrective action commitments for the replacement of ' the equipment identified as being deficient in qualification documentation in the Environmental Qualification Submittal?
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RESPONSE
As a result of the NUREG-0588 Qualification review, two generic i
types of components were determined to be deficient in qualification documen-tation. These generic types are solenoid valves, both inside and outside the containment, and limit switches outside the containment. These deficiencies, together with corrective action commitments and justification for interim operation, are given below:
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1.
Solenoid Valves - Inside Containment A total of 18 solenoid valves inside the containment were determined not to have adequate qualification documentation. These solenoid valves are used on containment isolation valves and perform their safety function prior to the effects due to the accident environment. Should failure occur, the isolation function of these valves would be main-l tained and such failure would not adversely affect other safety-related i
equipment.
Furthermore, these solenoid valves have high temperature coils and contain no Buna-N or plastic parts. Although complete quali-i fication testing or analyses have not been performed on the specific assemblies, separate qualification tests have been performed on individual I
constituent components of the valve assembly. Based on the fact that no material which has- -deleterious effects due to the harsh environments is included in these valves, and that previous limited testing has successfully verified qualification, interim use of these valves is
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- acceptable until they can be replaced. Replacement with qualified
, valves having adequate documentation will be completed by the end of the'first refueling outage.
If any problems arise beyond the control of Alabama Power Company which may impact this schedule, the NRC will be notified. A replacement program to fully support
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this schedule has been implemented and appropriate design changes and purchase orders already have been issued.
2.
Solenoid Valves - Outside Containment A total of 43 solenoid valves outside the containment were determined not to have adequate qualification documentation. Although a few of these valves do contain plastic seals, interim operation can be justi-i fied on the basis that the accident temperature excursion for a main steam line break lasts less than two seconds, and there is sufficient thermal lag within the valve body to preclude any damage to the valve j
internals.- In addition, the valves have high temperature coils, which would resist damage due to temperature excursions of short duration.
The pressure excursion is so low and so short as to be negligible.
Based on the fact that the short duration of the harsh environment would l~
have no deleterious effect on these solenoid valves, interim use of these valves is. acceptable until they can be replaced. Replacement l
with qualified valves having adequate documentation will be completed by the end of the first refueling outage.
If any problems arise beyond the control of Alabama Power Company which may impact this schedule, the NRC will be notified. ~ A replacement program to fully support this schedule has been implemented and appropriate design changes and purchase order have already been issued.
rag:; 3 3.
Limit Switches - Outside Containment A total of 37 limit switches outside the containment were determined not to have qualification documentation.
Interim operation is justified on the basis that the accident temperature excursion to which these switches are exposed is less than two seconds in duration, and the thermal lag of the switch enclosure precludes damage to the internals.
Should subsequent failure occur, other safety related components would not be affected. Based on the facts of short duration of the harsh environment and that potential subsequent failure will not adversely affect other safety-related equipment, interim ute of these switches is acceptable until they can be replaced. Replacement with qualified switches having adequate documentation will be completed by the end of the first refueling outage.
If any problems arise beyond the control of Alabama Power Company which may impact this schedule, the NRC will be notified. A replacement program to fully support this schedule has been implemented and appropriate design changes and purchase orders have already been issued.
QUESTION 3 Provide typical Certificates of Conformances and verify that Certificates of Conforaances are available for all open equipment qualification items as-identified in the Farley NUREG 0588 Submittal.
RESPONSE
l The equipment identified in the Evironmental Qualification Submittal as lacking environmental qualification documentation is listed in Tables 1 and 2.
Certificates of Conformances are available for all items listed in the tables except Asco Solenoid Valve Model No. HT8300B58RU. With regard-to "his item, the vendor has been asked to furnish a copy of the Certificate ot' Compliance. Verification of receipt of this information will be forwarded to the NRC along with the response to Questions 4 and 5 when they are available. Attachments 1 and 2 provide typical Certificates of Confordance as requested. The Certificates of Conformances along with copies of the applicable specifications for all -"tstanding items listed 1
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in the tables will be added to the NUREG 0588 qualification Documentation l.
File located at the plant and will be available for staff ri.v'- :.
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TABLE 1 EQUIPMENT INSIDE CONTAINMENT LACKING ENVIRONMENTAL QUALIFICATION 1
Environmental
'Equipmen' Model Number of Quali fication Description Number Function Physical _ Items Status Information SV JV214411 Actuate-1 Certificate of Conformance Air-0perated SV HTX8316C15E Valve for 2
Isolation 1
12, SV-HTX8320A22V TOTAL SV 18 e
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TABLE 2 EQUIPMENT OUTSIDE CONTAINMENT LACKING ENVIRONMENTAL QUALIFICATION 1
Environmental i
Equipment Model Number of
- Qualification Description Number Function Physical Items Status Information l
SV HT8300858RU Actuate 6
See Note Below Air-0perated SV 8002-HV-202-Valve for 6
Certificate of Conformance 301-3U Isolation SV HT8211B35 6
SV HT8211854 6
SV HT8321A6 8
SV HT8320A108 2
SV HT8300A108 6
l SV HTX8316C45V 3
l TOTAL SV 43 LS EA-170 Valve 23 a
position LS EA-700 indicator 3
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LS EA-710 3
n LS OPD-AR
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l TOTAL LS 37 i
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NOTE: flone available. Vendor has been requested to furnish a copy of the Certificate of Conformance.
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QUESTION 4:
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For the available documentation of the Limitorque operator, three areas of concern were noted:
a) No information documented concerning aging of the actuator (motor stator excluded).
b) It appears that separate effects testing was used to environmentally qualify the Reliance Motors.
c) Complete environmental qualification information was not documented concerning the Peerless Motors.
RESPONSE
The vendor has been contacted on the above items. When this infor-mation is received from the vendor, it will be forwarded to the NRC. We will keep you informeo of our progress in this effort.
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QUESTION 5:
For the Gems Level ~ Transmitters, final test results are needed to verify
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that these items are adequately environmentally qualified.
RESPONSE
The vendor has been contacted on the above item. When this infor-mation is received from the vendor, it will be fonvarded to the NRC. We will keep you informed of our progressin this effort.
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QUESTI0ft 6:
Of three. items checked through the procurement cycle, two showed no problem. The third item raised some concern because no evidence was available within the allotted audit time to show that hardware found l
to be unacceptable during " bench testing" (and perhaps during pre-fuel load tests) is entered into the nonconformance control system.
RESPONSE
A copy of the Nonconformance Report (NCR) documenting the particular equipment problem found was provided to tir. Frank. Ashe of EQB on Wednesday, September 24, 1980.
Specific procedures are in existence for Construction, Startup, and Production to ensure that equipment nonconformances are properly reported, documented, and closed out.
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QUESTION 7:
On the basis of a TPNS number, a procurement cycle was traced. Later it was found that the item being. traced had been sent to the supplier, repaired, returned to Alabama Power Company and stored as a spare.
A different serial numbered part was given the same TPNS number and installed without QA knowing that a change had been made. Both parts had the same model number and were interchangeable.
RESPONSE
The TPNS (Total Plant Numbering System) is a system to identify a functional entity anywhere in the plant.
For exampie, Q2N11SV3369AA is the number assigned to a solenoid valve associated with a MSIV. The number identifies the valve as safety related (Q), in Unit 2 (2), in
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the main steam system (Nil), a solenoid valve (SV), and a va1ve function number'of 3369AA. The model number plus the serial number identify the specific component, not the TDNS number.
The. existing plant filing system for construction and operation contain all data related to a particular. TPNS. item, including procurement
-records and component replacement records (purchase orders, york requests,
. design change requests, etc.). As long as plant procedures are followed, replacement of a' component and a resulting change in serial number will be documented in the files. Periodic audits are conducted by QA during construction to insure that the correct equipment is installed.
o This TPNS. identification system is a part of the Operations QA i
Program described in the FSAR Section 17.2 and the Operations Quality Assurance. Policy Manual which has been reviewed.and accepted by the NRC.
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