ML20012B350
| ML20012B350 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/28/1990 |
| From: | SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML13304A460 | List: |
| References | |
| M-86420, M-86420-R, M-86420-R00, NUDOCS 9003140235 | |
| Download: ML20012B350 (100) | |
Text
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., 3 Southem Callfornia Edison Conapany
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Report No. Af 8600 Revision O '
t SPURIOUS ACTUATION EVALUATION" r
Component Cooling Wsier System - Operability As:sessment n(,
San Onofre Nuclear Generating Station Units 2& 3 FEBRUARY 1990
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pSouthern Callfornin Edison Company
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Report No. M06420 Revision 0 I
I SPURIOUS ACTUATION EVALUATION i
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Component Cooling Water System - Operability Assessment
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i, San Onofre Nucient Generating Station Units 2& 3 g
FEBRUARY 1990 I
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Bechtel Power Corperstbn I
Report N:. M86420, Rev 0 M
EXECU11VE
SUMMARY
The 1988 Safety System Functional Inspection (SSFI) of the component cooling water l
(CCW) system at San Onofre Nuclear Generating Station (SONGS) Unit 2 identified a concern with the design of the CCW surge tank outlet valves. Since these valves are provided with non 1E power control circuits, there was a potential for the valves in both i
trains to close spudously if the non 1E electrical system remained energized dudng an I
earthquake. " Contrary to 10CFR50, Appendix A, GDCs 2 and 44, there was a remote possibility that this type of common mode failure could prevent the fulfillment of the CCW safety function. Such a simultaneous spurious actuation had not been considered in the original design of the CCW system.
In order to preclude a seismically induced spurious closure of the surge tank outlet valves, corrective action was implemented during the SSFI to remove power from the valves by removing the thermal overload devices at the valve hreakers. Remote valve positica indication was retained. Additionally, SCE agreed to review the e.r, tire CCW systei.", to verify compliance with GDCs 2 and 44.
Specifically, d'e review was designed to determine how other potential failures of non IE electstd components cculd impact system operability. The following actions were taken in support of this effort:
o The original CCW design was reviewed with respect to the & sign of power operated components (i.e., valves, pumos) and their control circuits.
I o
The CCW Failure Modes and Effect Analysis (FMEA) was revised to include g
passive safety related components that are powered / controlled by non 1E p
devices, and to consider spurious actuation of these components, o
Seismically induced conunon mode failure of non 1E devices was evaluated under various CCW operating modes, o
Non 1E powered devices in the CCW system whose failure could affect system performance were evaluated for vulnerability to failure under seismic conditions by review of vendor data and comparison to IE devices.
o Non 1E devices which were dissimilar to comparable IE devices were seismically evaluated through a seismic test and evaluation program, including confirmatory plant walkdmyns as appropriate.
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A systems interaction (SI) analysis, based on Unresolved Safety Issue (USI)
B A 17, was performed to ensure that other non 1E device interactions did not exist that could adversely affect CCW operability.
I These reviews and evaluations showed the following:
o Seismically induced spurious actuation of valves with non.1E power and control circuits was not part of the odginal CCW system design because non 1E power was assumed to fall as a result of a seismic event. Spurious actuation of the valves had been precluded by this assumption.
o The system is designed and constructed to withstand individual spurious actuations (a random single failure) of any single non 1E powered valve I
without loss of function. However, if multiple spurious actuatioas we.re to occur simultaneously they could impact CCW system operebility.
l~
o Of the 25 r,afety rdated valves with non 1E power and control circuits, 23 valves have circuhs that contain one or more devices that are not similar to qualified IE devices.
A limited seismic test and evaluation progren wan cor ducted by ANCO o
l Engineers to establish the fragility level of the non 1E devices. The seismic tests demonstrated that the majority of the non 1E relays have sufficient ruggedness to withstand a seismic event with an in cabinet response I
magnitude of approximately log without experiencing unacceptable contact chatter. Since this is higher than the expected response due to a design g
basis earthquake (DBE) for SONGS, the tested non 1E devices were judged acceptable for their applications, h
The surge tank outlet valves (HV 6225 and HV 6505), which had power o
removed from the valve actuators in response to the concerns identified I
during the SSFI, would not be subject to seismically induced spurious actuation and need not be electrically disabled. However, prior to restoring a remote manual capability for these valves, automatic valve closure on l
surge tank low low level must be removed.
o Of the 23 control circuits that contain one or more desices that are not I
similar to IE devices, 2 relays used in the control of 4 letdown heat I
OPM0312 11 I
1 Report Na M86420, Rev 0 y
exchanger isolation valves may lack sufficient ruggedness to withstand a DBE level seismic event. An operability assessment of the CCW system showed that spurious actuation of the relays would not result in loss of safety function.
h o
Plant walkdowns conducted to support the seismic testing verified that:
The installed non 1E devices are the same as those tested 1
Cabinet mounting of the non 1E devices is enveloped by the mounting used in the seismic test program Cabinet mounting of the ncn 1E devices is similar to that of IE devices Mounting of the non 1E cabirats is adequate to withstand a seismic 1
event of the magnitude postulated for SONGS 1
o The S1 review identified that, while thr majority of non 1E devices were accepubly located, one MCC containing devices associated with the control I
of two miniflow cross connect valves is located in a non Seismic Category l
I structure.
8 o
The MCC and its associated control devices are potentially subject to adverse interactions. liowever, an operability assessment was performed and it was concluded that the failure of th!s MCC would not result in an adverse systems interaction.
o An operability assessment of the CCW system concluded that the seismically induced actuations and systems interactions that are considered to be credible for the CCW system will not result in a loss of CCW safety function.
l The original design of the CCW system did not consider multiple seismically induced B
spurious actuation of non 1E devices, liowever, seismic testing and evaluations, plant walkdowns, and systems interactions evaluations performed as part of this review indicate that there is little potential for such actuations to occur. A thorough evaluation of non-IE devices associated with the CCW system identified only one type of non 1E relay OPM0312 111
Report N:. M86420, Rev 0 I
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(model CR120C), associated with only four letdown heat exchanger valves, that was considered to be susceptible to failure in a seismic event. An operability assessment of the CCW system showed that spurious actuations of the four valves controlled by circuits containing this type of relay is precluded by existing interlocks.
'g A detailed systems interaction assessment of the non 1E devices, was also performed to e
identify any additional mechanisms beyond seismically induced contact chatter that could impact CCW system operability. The assessment identified one MCC located in the turbine building that contained the motor starters for two miniflow isolation valves.
Because this area is not designed to Seismic Category I requirements and was not
[
I included in the plant hazards evaluations (e.g., high energy line break, fire, missile analyses), these devices could be subject to seismically induced spurious actuation and/or adverx systems interactions. An operability assessment was performed assuming both i
I energir.cd or deenergir.ed failures of these devices. 'this assessment showed that even with these postulated failures the CCW system tuuld continue to perform itr safety fu iction.
The overall review of the system established that the limited use of non 1E devices has l
only a minor effect on CCW system operr4 tion and does not adversely affect the CCW safety function. A thorough review of these non 1E devices using the methodology established in Generic Letter 87 02 and USI A 17 demonstrrted that the CCW system at I
SONGS 2&3 complies with GDCs 2 and 44. Replacing the non 1E devices with IE devices, or taking other measures to enhance the electrical power distribution and control g
systems, is therefore not considered to be warranted. Based on the conclusions above, the surge tank outlet valves (HV 6225 and HV 6505) are considered to be exempt from seismically induced actuations and need not be electrically disabled for this scenar'a.
However, prior to restoring the remote manual capability for these valves, the automatic valve closure on surge tank low low level feature must be eliminated to ensure system operability following postulated line breaks.
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Report N:. M86420, Rev 0
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l COMPONENT COOLING WATER SYSTEM l
SPURIOUS ACTUATION EVALUATION I
TABLE OF CONTENTS I
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EXECUTIVE SUMM ARY....................................
1 TABLE OF CONTENTS...................................... v DEFI NITION S........................................... ix
1.0 INTRODUCTION
..................................., 11 2.0 PU RPO SE.......................................
2 1 3.0 METHODOLOGY
..................................31 3.1 Design Review 3 4 3.2 Failure Modes and Effects Analysis
......................34 3.3 Common Mode Failure Analysis
........................35 3.4 Seismic Evaluation of Non 1E Devices....................
3 7 3.5 Seismic Testing and Evaluation.........................
3 9 l
3.6 Walkd owns......................................
3 10 3.7 Systems Interaction Evaluations
........................310
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TABLE OF CONTENTS (continued)
Page 1
4.0 RESocrS
.......................................41 4.1 Detign Review....................................
4 1 4.2 Revised Failure Modes and Effects Analysis.................
4-6 l
4.3 Common Mode Failure Analysis........................
4-8 l
4.4 Evaluation of Non.1 E Devices..........................
4 9 4.5 Seismic Testing and Evaluation.........................
413 l
4.6 Walkdowns.....................................
4 18 p
4.7 Systems Inteaction Evaluations........................
4 21 4
5.0 CONCLUSION
S AND RECOMMENDATIONS................
51 l
5.1 Seismically Induced Spurious Actuations...................
51 l
5.2 Potentitd Adverse Systems interaction 52 5.3 Summary
.......................................52 l
6.0 REFERENCES
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l APPENDICES A.
Results of Mechanical and Electrical Failure Modes and Effects Analyses B.
Results of Common Mode Failure Analyses l
C.
CCW Non 1E Devices D.
Walkdown of Non 1E Devices i
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IJST OF TABLES 11 Power Source for CCW Mechanical Components (on Critical Loop) 12 Power Source for CCW Instrumentation (on Critical Loop) 41 Resolution of Non Comparable Non 1E Devices 42 Evaluation of Non 1E Powered Devices in the Turbine Building 51 Disposition of Non 1E Devices I
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IJST OF FIGURES 11 Component Cooling Water System
.I 31 CCW Spurious Actuation Evaluation Methodology 32 Seismic Evaluation of Non 1E Devices E
33 ANCO Test Setup
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41 Original SONGS 2&3 CCW FMEA Logic 4
42 Phase II CCW Evaluation Logic
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4-3 Comparison of Test Response Spectra with Floor Response Spectra 44 Comparison of Test Response Spectra with Required Response Spectra f
f 4S Typical Relay Mounting Detail i
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F DEFINITIONS s
l Active Cepanant A component in which mechanical movement must occur to accomplish the safety function of the component.
Adverse System Intemetion (ASI)
A systems interaction that could result in specific undesirable consequences.
Common Mode Failure (CMF)
Multiple failures of structures, systems, or components as a result of a single phenomenon.
Design Basis Earthquake (DBE) The earthquake that is based upon evaluation of the maximum earthquake potential considering regional and local geology and seismology,
.j and specific characteristics oflocal subsurface material it is the earthquake that produces the maximum vibratory ground motion for which safety related structures, systems, and component are designed to perform their safety function [also called the Safe Shutdown l
Earthquake (SSE)].
Design Basis Event - The initiating event that is postulated to occur at a nuclear plant.
I The events under which nuclear safety-related structures, systems, and components are designed to perform their safety function.
Fail As is - The failure of a component, on loss of power, in the same state or position as prior to loss of power (e.g., a motorized valve that does not change position when deenergized.)
J'ailure Modes Failure types / modes can be defined as the effect by which a failure is I-manifested. A failure mode may also be defined as:
"A description of the failed condition," (e.g., motor failed to start).
A failure mode provides a descriptive characterization of the failure event in generic terms not in terms of the " failure cause" I
or in terms of the " failure effect" on the system or plant consequences. In the case of a valve which fails to close on command, the failure mode of this component is "open" or
" fails to close." Failure mcdes should consider catastrophic loss of function and/or degraded function.
Failure Modes and Effects Analysis (FMEA)
A Failure Modes and Effects Analysis (FMEA) is an analysis performed to validate a design or design change by evaluating the effects of postulated failure modes with respect maintaining the safety function of a system. The FMEA should address both active and passive failures. The FMEA should consider both time and mode dependent system operational requirements. In addition, the FMEA should consider intersystem dependencies. A FMEA should examine the process i
i OPM0312 ix
Report N:. M86420, Rev 0 W
(both mechanical and controls), electrical (power distribution and separation) and device actuation aspects of a system.
Floor Response Spectra (FRS)
A plot of the maximum response of a specific floor of a building as a function of input frequency due to a postulated DBE. The response is presented in terms of acceleration, in "g"s.
Generic Equipment Ruggedness Spectra (GERS) - A spectra representing the maximum response a given type of device can withstand without loss of function.
High Energy Line Break (HELB) A postulated failure in a piping line containing fluid l
that has: (a) a maximum operating temperature over 200F or (b) a maximum operating pressure over 275 psig, during normal system operation.
Initiating Event A single occurrence and its consequential effect that place the plant or some portion ot'the plant in an off normal condition. An initiating occurrence is not the single failure defm' ed elsewhere herein. An initiating occurrence can be an equipment failure, a human error, a nctural hazard, or a man made hazard, g
IE Device - Electrical device associated with the 1E power system and, therefore, B
designed to withstand a design basis event.
Non-Active Component A component in which no mechanical movement need occur to accomplish a safety function.
l Non-1E device Electrical device associated with the non 1E power system.
Comparable A non 1E device that is considered equivalent to a IE device in terms of l
seismic withstand capability.
Required Response Spectra (RRS)
The spectra that represents the response a given I
component or device is expected to experience during a DBE due to its location. The RRS typically exceeds the FRS due to location of the support point of the component or device relative to the floor.
Single Failure Fluid and electrical systems are considered to be designed against an assumed single failure if neither: (1) a single failure of any active component (assuming passive components function properly), nor (2) a single failure of any passive component (assuming active components function properly) results in a loss of the capability of the system to perform its nuclear safety function.
Spurious Actuation - Unexpected change in state of a mechanical component.
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System Interaction (SI)
An action or inaction (not necessarily a failure) of various systems (subsystems, divisions, trains), components, or structures resulting from a single credible failure within one system, component, or structure and propagation to other g
systems, components, or structures by inconspicuous or unanticipated interdependencies.
The major difference between an SI and a classie single failure event is in these hidden or unanticipated aspects of the initiating failure and/or its propagation.
lI Test Response Spectra (TRS)
The response spectra that are developed from the actual time history of the motion of the shake table. The TRS is chosen to envelope the RRS I
in the required frequency range.
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Repet N:. M86420, Rev 0 l
1.0 INTRODUCTION
1.1 System Description
The component cooling water (CCW) system is a safety related, redundant, Seismic I
Category I system designed to transfer heat from various plant components (e.g., shutdown heat exchangers, safety injection and containment spray pump seal coolers, emergency contaimnent air coolers) to the saltwater cooling system (ultimate I
heat sink).
I During normal operation, the CCW system functions to remove heat from both safety and nonsafety related components. Under accident conditions, that portion of the system which senices the nonsafety related loads (the non criticalloop) is automatically isolated l
on either a surge tank low low level or a containment isolation actuation signal (CIAS).
Availability of the CCW system is ensured by two redundant trains, plus an additional I
swing pump capable of being snanually aligned with either train. The swing pump is narmally aligned during operation to the train that is supplying the non critical loop.
l System operation is supported by numerous motor operated and pneumatic valves, and control devices for flow, pressure, and level indication. Figure 11 is a diagram of the CCW system.
l Components for the criticalloop portion of the CCW system are served by a combination of IE and non 1E power supplies. The essential active components (i.e., those which must change position or operate post accident), such as pumps and CCW valves which function to provide isolation between the critical and noncritical loops, are powered from 1E sources. There are, however, a number of other components, primarily non active valves, (i.e., valves which are not required to change position or operate post accident) that are provided with non 1E power. These components are designed to failin their safe position (e.g., MOVs fail as-is) on loss of non 1E power. This position is that which supports continued system function with the component deenergized.
Tables 11 and 12 show the power source (IE or non 1E) for CCW mechanical components and instrumentation.
OPM0312 11
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Y Report No. M86420, Rev 0-Table 11
~ POWER SOURCE FOR CCW MECHANICAL COMPONENTS (ON CRITICAL LOOP)
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PUMPS.Ct;W P024 X
P025 X
P026 X
VALVES Non oriticalloop isolation valves
- HV6212, x
HV6213 x
HV6218 x
HV6219 x
Non criticalloop containment HV6211 x
isolation valves HV6216 x
HV6223 x
HV6236 x
Emergency air coolers HV6366 x
containmentisolation valves HV6367 x
HV6368 x
HV6369 x
HV6370 x
HV6371 x
HV6372 x
HV6373 x
Shutdown cooling heat exchanger HV6500 x
isolation valves HV6501 x
Component cooling water pump HV6222A x
Electrically disabled P025 suction valves HV6224A x
Electrically disabled HV6222B x
HV62248 x
Component cooling water pump HV6226A x
Electrically disabled P025 discharge valves HV6228A x
Electrically disabled HV6226B x
HV6228B x
Component cooling water motor HV6227 x
Electrically disabled cooling supply valves to P025 HV6229 x
Electrically disabled Component cooling water surge HV6225 x
Electrically disabled
- 1ank outlet valves HV6505 x
Electrically disabled
- Component cooling water pump HV6220 x
mini 60w isoistion valves -
HV6551 x
HV6221 x
HV6552 x
Component cooling water supply and HV6203A x
Air operated retum valves for letdown HX HV62938 x
Alt operated HV6522A x
Air operated HV65228 x
Air operated Component cooling water miniflow HCV6537 x
Air operated block valves HCV6538 x
Air oporsted HCV6539 x
Air operated CCW supply and retum valves for radweste~
HV6217 x
components (Unit 2/3 cross connect HV6465 x
- valves)
- To prevent automatic actuation on surae tank low low level OPM0312 13
s Report No. M86420, Rev 0 Table 12 POWER SOURCE FOR CCW INSTRUMENTATION (ON CRITICAL LOOP)
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I Pressure control on CCW pump PCL 6323-1 x
1E pump controlcircuh P026 discharge l
Pressure controlon CCW pump PCL 6262 2 x
1E pump controlcircut P024 discharge Levelindicating transmitter on LIT 6490 x
Surge tanklevelin control room I
CCW surge tank LIT 6499 x
Surge tank tevelin control room levelcontrol on CCW surge tank LCL 6273 x
Opens surge tank make up LCLL 62891 x
Isolates critical /non-cthical loops i
LCL 6278 x
Opens surge tank make up LCLL 6237 2 x
Isolates critical /non-crhical loops Flow transmhter on discharge FT 6248 x
Flowinterlock with miniflow 1
side of the CCW heat exchanger FT 6243 x
Flowinterlock whh miniflow Flow alarm for CCW heat exchanger FSL 6331 x
Flow alarm in controlroom FSL 6250 x
Flow alarm in control room i
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N' Report No. M86420, Rev 0 1.2 Spurious Actuation Evaluation The 1988 Safety System Functional Inspection (SSFI) of the CCW system at San Onofre Nuclear Generating Station Units 2 and 3 (SONGS 2&3), identified a concern with the design of the CCW surge tank outlet valves. Since the valves utilized non 1E electrical and control devices powered from a non 1E electrical system there was a potential for the y
valves in both trains to close spuriously if the non 1E electrical system remained energized during an earthquake. Contrary to 10CFR50, Appendix A, GDCs 2 and 44,
~2 there was a remote possibility that this type of common mode failure could prevent the fulfillment of the CCW safety function. Such simultaneous spurious actuations had not been considered in the original design of the CCW system.
In order to preclude such a seismically induced spurious closure of the surge tank outlet f
valves, corrective action was implemented during the SSFI to remove power from the valves by removing the thermal overload devices at the valve breakers. Remote valve q
position indication was retained. Additionally, Southern California Edison (SCE) agreed 3
to review the entire CCW system to verify compliance with GDCs 2 and 44. Specifically, the review was designed to determine how other potential failures of non 1E devices
]
could impact system operability.
The review consisted of the following tasks:
A.
The original CCW design basis was reviewed with respect to the design of
}
power operated valves and their control circuits.
B.
The CCW Failure Modes and Effect Analysis (FMEA) was revised to include passive safety related components that are powered / controlled by non 1E devices, and to consider spurious actuation of these components.
C.
Seismicallyinduced common mode failure of non 1E components was evaluated under various CCW system operating modes.
D.
Non-1E devices in the CCW system were evaluated for vulnerability to failure j
under seismic conditions by review of vendor data and comparison to qualified 1
1E devices.
l E.
Non 1E devices which were dissimilar to comparable IE devices were seismically evaluated through a seismic test and evaluation program that
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Report No. M86420, Rev 0
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A System Interaction (SI). analysis, based on USI A 17, was performed to ensure that other non 1E device interactions did not exist that could adversely.
affect CCW system operability.
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g 2.0 : PURPOSE The purpose of this report is to document the CCW system operability review performed l
to address the selected use of non 1E devices in the safety related portion of the CCW
. system using methodology suggested in Generic Letter 87-02 and other documents as referenced in this report.
Specifically, this report:
i o
Identifies non 1E devices used in the safety related portions of the CCW system o
Evaluates the impact of using these non 1E devices on CCW operability by the following analyses:
L FMEA l
Common Mode Failure
'g Systems Interaction
-g Evaluates the impact of using these non 1E devices on CCW operability o
through:
l Comparison with similar IE devices Testing and evaluation of devices with no similar IE counterpart L
Confirmatory walkdowns of identified non 1E devices Identifies potential deviations in system design associated with non 1E devices o
Addresses system operability for any identified deficiencies o
l' Excluded from this review were non 1E devices associated with CCW instrumentation.
Although failure of these devices may cause a false alarm / reading in the control room, this failure will not directly impact safe operation of the CCW system since none of the -
associated instruments are part of the Post Accident Monitoring System Instrumentation m
(PAMI).
5-I OPM0312 21
Report No, M86420, Rev 0 3.0 METHODOLOGY i
The SONGS 2&3 CCW system operability assessment was performed in two phases. The first phase was an integrated assessment of the CCW system in terms of deficiencies noted during the SSFI. The results of this review were transmitted to the NRC by letter dated June 24,1988 (reference 1).
Phase II consisted of a more detailed review and evaluation of the CCW system as shown in Figure 31. This was broken into an initial and a follow-on evaluation. The results of the initial Phase II assessment were submitted to the NRC by letter dated December 16,1988 (reference 2).
Phase I
~
For the first phase of the assessment, CCW system deficiencies identified by SCE or the
. NRC as part of the SSFI inspection as potentially affecting system operability were re-evaluated collectively with respect to the four pertinent major accident scenarios (Critical Crack, Safe Shutdown Earthquake, Loss of Coolant Accident, and Main Steam Line Break Accident). Specific issues included in this review were:
Assessment of CCW system leakage criteria o
Radiation monitoring of CCW with both CCW trains in operation o
o Potential common mode failure of the CCW surge tank isolation valves inclusion of components in the Inservice Test program o
In addition to these specific issues, overall system operability was also reviewed with regard to other relevant issues, such as inclusion of single failure criteria in the Safe
/
Shutdown Earthquake analysis. A formal evaluation was. prepared to document the results of this review.
J Based on the results of this evaluation, it was concluded that the CCW system remains operable under the identified conditions. Corrective action from the Phase I CCW system review consisted of disabling the automatic operation of the surge tank outlet valves to preclude seismically induced spurious actuations that could result in a loss of both trains
- l of CCW. Remote valve position indication was retained.
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4 Report No. M86420, Rev 0
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81 87 ESTABUSH CRITERIA / BASES FOR EVALUATON 1
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CCW SPURIOUS ACTUATION EVALUATION METHODOLOGY w-
l Report No. M86420, Rev 0
~
Phase 11 m
The second phase of the program consisted of an integrated CCW system review and l
functional evaluation to revalidate the CCW system design.
Initial Phase 11 Evaluation In the initial Phase 11 CCW system review and functional evaluation, applicable design l
documentation, calculations and licensing correspondence were reviewed to compile a comprehensive design basis for the CCW system. This design basis was confirmed by c nyersations with cognizant personnel. Evaluations were then performed to address the Ey CCW system response to potential plant transients in light of broadened interpretation of regulatory criteria regarding loss of offsite power and spurious actuation of non 1E g
components. These plant transients included normal power operation and design basis events.
In order to complete the above evaluation, non 1E devices-of the CCW system critical loop were identified and their impact on system operability was assessed. Those devices whose failure did not adversely impact the system were eliminated from further review.
Follow-on Phase II Evaluation I
Additional evaluations were performed for the remaining non 1E devices to assess their susceptibility to seismically induced spurious actuation. This evaluation identified the I
need for follow-on actions including:
l o
Perform additional seismic evaluations and/or tests for the remaining non 1E devices that could impact system operability.
Review the CCW system for vulnerability to other seismic and non seismic o
adverse interactions that could cause spurious actuation.
The approach used for each portion of the Phase II evaluation is described in the subsections that follow, including:
3.1 Design Review 3.2 Failure Modes and Effects Analysis 3.3 Common Mode Failure Analysis OPM0312 3-3
(
Report No. M86420, Rev 0 s
W 3.4 Seismic Evaluation of Non-1E Devices 3.5 Seismic Testing and Evaluation 3.6 Walkdowns l
3.7 Systems Interaction Evaluations 3.1 Design Review The design of the CCW system is presented in the Updated Final Safety Analysis Report (UFSAR) in Chapters 3, 6, 7, 8, and 9. Failure mechanisms specifically evaluated in the design are shown in UFSAR Tables 7.3 26,8.3 8, and 9.2 3. Original design bases were confirmed and expanded with information obtained directly from personnel involved in the design of SONGS 2&3. Results of the design review are presented in Section 4.1.
3.2 Failure Modes and Effects Analysis A FMEA is conducted to evaluate the ability of a system to withstand the failure of major 1
or minor components and still perform its safety function. A FMEA assumes an original condition (operating mode, train lineup, etc.), an initiating event and a single failure.
Initiating events include:
o Design Basis Earthquake (DBE)
I o
High Energy Line Break (HELB) o Loss of Coolant Accident (LOCA) l o
Plant transients The criteria used in perforndng the original FSAR FMEA include the following:
A random single active failure of 1E devices was assumed in addition to the o
j initiating event (e.g., HELB, DBE).
Any initiating event that resuhed in a unit trip (e.g., DBE) was also assumed o
g 5
to occur concurrent with a loss of offsite power and therefore all non-1E power systems were assumed to be unavailable.
OPM0312 3-4
]
Report No. M86420, Rev 0 m-Safety-related components that were not required to move to perform a safety o
function (e.g., those that remain in place and act as pressure boundary only)
L were provided with non 1E power and were designed to fail in the position that would support system operation (" fait safe").
- The UFSAR mechanical and electrical FMEAs (UFSAR Tables 8.3 8 and 9.2-3) assume I
single failure to be potential failures in IE pumps and valves within the CCW critical loop. The controls system FMEA (UFSAR Table 7.3 26) assumes categorical failures (e.g.,
l loss of all non 1E power, loss of one ac load group). The controls FMEA is enveloped by the mechanical and electrical FMEAs.
The FMEAs in the UFSAR were prepared based on the assumption that only single -
failures of active components need be considered when assessing the capability of safety-I related systems to perform the required safety function and place the plant in a safe shutdown condition. Non 1E devices that are not required to change position or operate during or after a DBE were considered to lose power at the initiation of the event and l
fail in their safe positions. Accordingly, they were not addressed in the FMEAs.
In order to evaluate CCW operability in light of spurious actuation of non 1E components, the electrical FMEA (UFSAR Table 8.3-8) was revised to add the non 1E electrical power distribution system components and the mechanical FMEA (UFSAR Table 9.2 3) was revised to add non 1E process and control components.
g The original FMEA criteria were expanded for the revised FMEA tables to include the I
effects of individual spurious actuations of non 1E powered components causing one component to change position such that it results in the maximum potential adverse effect -
l on the system. Conunon mode failures were addressed separately.
The results of this expanded FMEA analysis are presented in Section 4.2.
3.3 Common Mode Failure Analysis 1
= A common mode failure is defined as multiple failures resulting from a single common cause. It is typically characterized by the potential failure of similar or identical devices.
Such multiple failures could result from such things as external events or manufacturing and installation errors that exceed a device's capabilities. Protection against common mode failures is usually accomplished either by ensuring that devices and components that can affect system operability are designed and qualified for the installed conditions (e.g.,
1 OPM0312 35
Report No. M86420, Rev 0 q.
seismic events) or by using compensating features, such as electrically disabling an MOV.
. Because the safety related portion of the CCW system has non 1E components that could impact system operability (i.e., components not designed and/or qualified for the installed l
conditions), further evaluations were required to determine if compensating features are required.
. The criteria utilized for the common mode faibre analysis are as follows:
A.
Non 1E devices in both trains of the CCW system are postulated to fail simultaneously due to a DBE and actuate valves to change position (e.g., open or close).
B.
The failure mode of the valve (s) are taken to be their worst case condition for g
the particular CCW system alignment.
C.
Offsite power is assumed to remain available post DBE and non 1E circuits are assumed to remain energized.
D.
Spurious actuation is not postulated for electrically disabled valves.
E.
-Spurious actuation of indicating devices was not evaluated since CCW operability is not impacted by failure of these devices.
F.
Assumed common mode failures are evaluated separately and are not combined I
with random single failures in order to properly assess operability impacts and develop appropriate corrective actions for the non-1E devices.
Results of the common mode failure analysis are presented in Section 4.3.
OPM0312 3-6
Report No. M86420, Rev 0 I
3.4 Seismic Evaluation of Non 1E Devices The seismic evaluation of non 1E devices was performed using the guidance provided by l.
Generic Letter 87-02, Verification of Seistaic Adequacy of Mechanical and Electrical Equipment in Operating Reactors (USI A-46), (reference 3), including the following:
'The licensee must specify all equipment items that are required to function during the period of strong shaking. The licensee must demonstrate the operability of l
these items by means other than comparison with the experience data base; otherwise, the licensee must detennine that any change of state will not compromise plant safety."
Figure 3 2 shows the logic for seismic evaluation of non 1E devices. The task consists g
of three parts:
A-Identification of non-1E devices in the CCW system that could affect I
components that serve a safety function.
B.
Comparison of each type of non 1E device with similar IE devices.
g C.
Evaluation of whether the identified differences are likely to be detrimental to l
device performance (i.e., result in seismically induced unwanted actions such as contact chatter) that could cause the CCW component to spuriously actuate.
A list of non 1E devices associated with each component was compiled from a review of design documents including the instrument index, elementary diagrams, and P& ids.
I For each device, an evaluation was performed as follows:
A.
The elementary diagram was reviewed to determine control instruments, controlling relays and interlocking contacts which could cause spurious actuations in CCW components. Only those devices that could cause spurious actuation were evaluated further.
B.
The manufacturer and model numbers of non 1E devices were identified. If these devices were identical or sufficiently similar to instruments or equipment g-used in IE control circuits, they were identified as a " Comparable" component.
This classification indicates that the same device had been procured as IE or, 8
OPM0312 3-7 I
Rgat No. M86420, Rev 0-D-
IDENTIFY NON 1E I
DEVICES 4
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. p EVALUATE FURTHER (SECTION 3.5)
Figure 3 2 SEISMIC EVALUATION OF NON 1E DEVICES OPM0312 38
l
)
Report No. M86420, Rev 0 lj l
based on engineering judgment using available vendor data, was considered J
to be sufficiently similar to a 1E device to provide a high degree of confidence that it would perform its function under seismic conditions.
t Limit switch interlocks originating from Limitorque actuators on QC-II valves were also j
considered QC-II because they are part of the QC-II boundary that has been previously 1
qualified. These limit switches were, therefore, not included in the seismic evaluation portion of the review.
I Non-1E devices that were similar to their 1E counterparts were excluded from further evaluation. The remaining non-1E devices were evaluated for their potential to impact i
CCW system operability. Those devices that (1) were not comparable to IE devices and (2) could potentially affect system operability received additional evaluation as described below.
3.5 Seismic Testing and Evaluation ANCO Engineers, Inc., Culver City, Ca., was contracted to perform seismic tests on I
samples of selected non-1E devices that did not have a demonstrated ability to perform under seismic conditions. ANCO, under contract to Electric Power Research Institute (EPRI), recently completed relay ruggedness testing in support of the Seismic Qualification Utility Group (SQUG) program for USI A-46 resolution. The instrumentation and ANCO shake table drive configuration used for the EPRI tests were thus available for use on this task.
The seismic testing was performed on three specimens of each component type using the l
guidelines of ANSI-IEEE C37.981984 (Fragility Test). Input vibration spectra were per the IEEE standard. Additional test runs were made using site / building specific UFSAR g
response spectra, with amplifications of 6 8 in the 5-10 Hz frequency range to account B
for natural frequencies in the motor control centers (MCCs) and relay cabinets. The natural frequency range of 5-10 Hz was based upon industry experience with similar MCC l
and relay cabinets.
An evaluation and device walkdown by SCE personnel had indicated that the most I
probable source of CCW spurious actuation in a seismic event would be the seal-in of a reversing contactor in a valve control circuit causing a permanent change in valve position. While in the deenergized state, this contactor seal-in could be caused by either chatter of contactor auxiliary contacts (i.e., motion of the contactor armature sufficient OPM0312 3-9 1
Report No, M86420, Rev 0 Ne I
to chatter the auxiliary contacts) or chatter of the controlling relay contacts providing power to the contactor coils. Therefore, the test was set up to monitor both chatter and seal in.
I For relay testing, all instrumentation was directly calibrated by ANCO during the set up.
The accelerometers were calibrated by direct comparison to a standard reference [ National I
Bureau of Standards (NBS) traceable) accelerometer during actual performance shaking.
Standard ANCO procedures also require that a post test calibration of all accelerometers l
be performed.
Further, all current and voltage meters used have NBS traceable calibration.
All reference voltages and contact status monitor and data acquisition functions are verified prior to test.
The ANCO test setup is shown in Figure 3 3. The results of the ANCO tests are found in reference 4 and summarized in Section 4.5.
3.6 Walkdowns Plant walkdowns were performed to verify that the tested non 1E devices were I
representative of the installed non 1E devices. In addition, installation details for IE and non 1E devices were also compared to ensure that those non 1E devices determined to be comparable to IE components would have an "as-installed" seismic withstand capability l
similar to their IE counterparts.
3.7 Systems Interaction Evaluations g
Finally, to ensure that a complete and thorough review of the CCW system had been l
performed, a detailed systems interaction assessment was performed to identify any additional mechanisms that could affect CCW operability.
For evaluation purposes, the following definition was used to determine the potential for system interactions (reference 5):
(A systems interaction (SI) is] "An action or inaction (not necessarily a failure) of various systems (subsystems, divisions, trains), components, or structures resulting from a single credible failure within one system, component, or structure and propagation to other systems, components, or structures by inconspicuous or unanticipated interdependencies. The major difference between an SI and a classic single-failure event is in those hidden or unanticipated aspects of the initiating failure and/or its propagation."
1 s
. OPM0312 3-10
w
. Report No. M86420, Rev 0 a.
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a5 Report No. M86420, Rev 0 1
I
)
B A~ fundamental requirement of this definition is that the dependency involved is-unanticipated. Thus, for example, an event involving the loss of function of Train A -
equipment, which occurs as a result of the failure of the associated Train A power supply,
.l would not be classified as a SI for this evaluation because events of this type are l
anticipated and previously evaluated. The scope of the CCW system evaluation focused on identification of the subset of sis which could result in specific undesirable I
consequences. Events resulting in' the following conditions were considered adverse systems interactions (ASIS):
.h A.
Degradation of redundant portions of a safety system, including consideration of all auxiliary support functions.
l B.
Degradation of a safety system by a system that is not safety related.
El C.
Initiation of an " accident" [e.g., LOCA, MSLB] or the initiation of a " transient" ug (including reactor trip) and (a) degradation of at least one redundant portion l 3 of any one of the safety systems required to mitigate that event or (b) degradation of critical operator information sufficient to cause the operator to g
perform unanalyzed, unassumed, or incorrect action.
D.
Initiation of an event that requires plant operators to act in areas outside the h
control room (perhaps because the control room is being evacuated or the l
plant is being shut down) and disruption of the access to these areas' (for L. g example, by disruption of the security system orisolation of an area when fire W
doors are closed or a suppression system is actuated).
.h The CCW system was reviewed against a listing of generic categories of potential ASIS to determine those categories of interactions that could be considered credible for the
,g SONGS plant. Those interactions that were considered credible were evaluated further
,E to determine their impact on the CCW system. Section 4.7 provides detailed results of this review.
LI L
I g.
~ OPM0312 3-12 Ll
. Report No. M86420, Rev O '
4.0 RESULTS 4.1 Design Review This review focused on the original design of the electrical, mechanical process, and controls / instrumentation components / devices on the CCW critical loop and their associated power supplies. Information presented in this section was obtained from 4
review of design documentation, calculations, and licensing correspondence.
This information was confirmed and expanded by conversations with cognizant licensing, mechanical, and electrical personnelinvolved in the design of SONGS 2&3.
4.1.1 Original Design of CCW System Components and Their Associated Power Sucolies Electrical, mechanical process, and controls / instrumentation components / devices which are ntial to the performance of CCW system safety functions were:
o designed, procured, installed, and tested to the appropriate quality standards
]
for ASME Section III equipment, o
designed to withstand a DBE, o
protected from and/or evaluated for seismic II/I and other potential plant
]
hazards (such as flooding, fire, etc.).
Components for the critical loop portion of the CCW system are served by a combination.
of IE and non-1E power supplies. The SONGS 2&3 design utilizes IE power supplies and control circuits for those safety related components that are required to perform an active function (change position or otherwise operate) to mitigate the consequences of an accident, limit offsite doses, or place the plant in a safe shutdown condition. This includes the CCW pumps and certain valves such as those which function to provide
)
. isolation between the critical and non critical loops. The IE powered safety related components were selected to ensure appropriate component actuation and system
]
alignment. There are also multiple, diverse alarms in the control room that function to alert the operator to off-normal system lineups or trouble in the CCW system.
.j Other components that are safety-related but non-active (such as QC-II ASME III valves that do not need to change position or operate) were classified as safety related for OPM0312 4-1
Report No. M86420, Rev 0 pressure boundary only and were provided with non 1E power. Redundant isolation valves for train separation were provided to accommodate random single failures of these non active (non 1E) valves.
1 Following a design basis event, QC II (ASME III) valves furnished with non 1E power
[
were assumed to remain functional as passive pressure boundary components. Valve I
movement was precluded because offsite power (and associated onsite non 1E power supplies) was assumed to be lost. These non. active components were designed so that l
loss of non 1E power results in the components failing in a " safe" position that supports continued operation of the CCW system.
- Further, several of the non-1E powered valves have already been electrically disabled as a result of previous system reviews for operability (e.g.,10CFR50 Appendix R fire l
induced spurious actuation evaluation).
Tables 1-1 and 12 mresent a summary of the CCW components on the criticalloop along with their assochd power supplies.
4.1.2 Original Failure Modes and Effects Analyses The CCW FMEAs are presented in UFSAR Sections 7.3.2.2, 8.3.1, and 9.2.2, Tables 7.3-l 26, 8.3 2, and 9.2 3 respectively. The following overall assumptions were made in the original FMEAs:
o Following a postulated design basis event, QC-II (ASME III) valves furnished with non 1E power were assumed to remain functional as passive pressure l
boundary components.
Valve movement was precluded because non-1E devices controlling the movement of the valves were assumed to be deenergized due to a loss of offsite-power (and associated non 1E power I
supplies).
l o
In addition to the direct consequences of a design basis event, a random failure of a single active component was assumed to occur in the system required to mitigate the effects of the accident and achieve safe shutdown.
o Non-Seismic Category I systems / components were assumed to be unavailable.
o Multiple failure of passive components and spurious actuation of non-1E devices were not~ considered in the original FMEAs.
OPM0312 4-2
Report No. M86420, - Rev 0 The FMEAs were performed assuming a single active failure as defined in 10CFR50 Appendix A (reference 6).
j "A single failure means an occurrence which results in the loss of capability of a component to perform its intended safety functions. Multiple failures e
resulting from a single occurrence are considered to be a single failure."
The following definition is taken from ANS 51.7 (reference 7):
"An active failure is a malfunction, excluding passive failures, of a component which relies on mechanical movement to complete its intended function upon 2
demand."
ANS 51.7 further broadens this definition as follows:
" Spurious action of a powered component originating within its actuation or control system shall b'e regarded as an active failure unless specific design features or operating restrictions preclude such spurious action."
In the original SONGS 2&3 design, spurious actuation of components as a result of non-IE device failures was precluded by the assumption that offsite power is lost and, as a consequence, power to all non 1E devices is lost. Since the non active components of the CCW system did not require a post seismic power supply, they were powered from non-IE power sources, f
. In a seismic event, these components were assumed to lose electrical power because the offsite portion of the non 1E power systems that provide their power was considered to be susceptible to seismically induced failure. These non 1E powered components (e.g.,
MOVs) 'were designed and installed as QC II, ASME III, and were designed to " fail safe" on loss of power.
The logic used in perfor.ning the original system FMEAs is shown in Figure 4-1. This is contrasted with Figure 4-2 which shows the logic used in the Phase II evaluation of CCW operability.
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OPM0312 4-4 ll
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OPM0312 4-5 I
a
Report No. M86420, Rev 0 4.2 Revised Failure Modes and Effects Analysis As recognized during reviews wrformed for the SSFI, for systems containing components with non 1E power sources, loss of non 1E power may not represent a conservative assumption, since this precludes spurious actuation of non-1E powered components.
Therefore, the mechanical and electrical FMEAs were revised to consider the single failure of non 1E powered components previously considered to be non. active components.
These failures are now postulated to occur as single random events because these non 1E -
devices are considered as active components for evaluation purposes.
Section 4.3 addresses the effects of multiple postulated failures.
Mechanical FMEA
~ In revising this FMEA, non-1E powered valves that are electrically disabled (e.g., selected CCW pump suction and discharge valves as shows. in Table 1-1) were not considered susceptible to spurious actuation. This left the following non 1E po yered valves whose failure had not previously been considered.
8 additional CCW pump suction and discharge valves o
o 2 CCW motor cooling supply valves s
o 2 surge tank outlet valves o
4 CCW pump miniflow cross connect isolation valves o -
3 CCW miniflow block valves 4 CCW water supply and return valves for the letdown heat exchanger o
o 4 CCW non criticalloop radwaste supply and return valves (unit cross-connect)
=
Spurious actuation of a suction or discharge valve could result in loss of cooling water to one train, if the swing pump is being used in lieu of the normal A or B train pump.
Since the other safety train is available, this does not impact CCW safety function.
Spurious actuation of a CCW motor cooling supply valve will not occur since these valves i
are power locked out, r
As a result of the concerns identified during the SSFI, spurious actuation of the CCW surge tank outlet valves was precluded by electrically disabling these valves. (Subsequent testing and evaluations concluded that these valves would not be subject to seismically induced spurious actuation and, therefore, need not be electrically disabled.)
[
OPM0312 4-6 l
Report No. M86420, Rev 0 Spurious actuation of a CCW pump miniflow isolation valve blocks the swing pump miniflow flow path. This does not affect operation of the CCW system since miniflow through either loop is not used during normal operation.
Spurious actuation of a CCW miniflow block valve to open can affect the cooling capability of one train. Since the other safety train is available, this does not impact-CCW safety function.
a
~
Spurious actuation of a CCW water supply or return valve for the letdown heat exchanger can cause loss of capability to cool the letdown flow or can affect the cooling capability of one safety train. Since the letdown heat exchanger is not required for safe shutdown and since one safety train is adequate for CCW safety functions, this does not impact CCW operability.
Spurious actuation of a radwaste supply' or return valve (may also function as unit cross connect valves) does not affect operation, since the radwaste heat loads are not required for safe shutdown and would be isolated upon closure of the non edJeal loop isolation valves.
Electrical FMEA The electrical FMEA was revised to add the following non-1E distribution system components:
J l
o Offsite power source o
Unit auxiliary transformer o
2 Reserve auxiliary transformers o
23 Circuit breakers o
3 Buses o
4 Loadcenter transformers o
3 Loadcenters
]
o 4 MCCs
=
o 1 Battery charger o
1 125 VDC panel q
J o
18 Circuit breaker / motor starters o
1 Auxiliary control relay panel
]
o 1 NSSS auxiliary relay cabinet
)
Report Ns. M86420, Rev 0
'I Failure of the above devices, except for the circuit breaker / motor starters, results m
- l partial or complete loss of non-1E power. This loss of power is enveloped by the original -
FMEA which assumed complete loss of non 1E power,
'I Failure of the circuit breaker / motor starters could result in spurious actuation of various non 1E powered valves.
The effects of these spurious actuations on CCW system I
operability are addressed in the mechanical FMEA.
' he controls / instrumentation FMEA is enveloped by the mechanical and electrical FMEAs T
and therefore was not revised.
The revised FMEAs showed that the CCW system can tolerate the spurious actuation of any single non 1E powered component without loss of safety function. Multiple spurious actuations (common mode failures) are discussed in the next section.
l Appendix A presents the detailed mechanical and electrical FMEAs.
4.3 Common Mode Failure Analysis Common mode failures (CMPs) are multiple component failures that result from the same type of failure mechanism. Seismically induced CMFs are precluded by design, in the l
case of IE devices since these devices are procured to seismic standards. Non-1E devices may or may not withstand a DBE. As a worst case, multiple components containing a I
-given type of electrical or mechanical device (e.g., motor starter, relay) might fail simultaneously. In order to evaluate the many possible combinations of component fainures, non 1E powered components were grouped based on the ability to impact j
specific CCW features (e.g., loss of pump suction, miniflow, etc).
g In order to comprehensively evaluate CCW operability, the common mode failure analysis E
' addressed the three normal system valve lineups permitted by the plant operating procedures as follows:
I-o Swing pump (PO25) in standby, aligned to either the A or B train o
Swing pump (PO25) in operation, aligned to either the A or B train o
Swing pump (PO25) isolated from both trains for maintenance.
j The results of the evaluation are presented in detail in Appendix B.
This analysis identified two major failure modes that have a potential to impact CCW operability:
i I
OPM0312 68
o i.
Report No. M86420, Rev 0 A.
Cross connect paths could occur between A and B trains at the _CCW pump suction and/or discharge cross connect isolation valves that would result in a loss of. train separation. Long term ctoss-connected operation post DBE could result in reduced system inventory and possible voiding in system high points.
B.
With the swing pump in operation, in lieu of one of the normal A or B train-pumps, a complete loss of flow could occur in the swing pump aligned train, if either a
suction or discharge cross-connect isolation. valve (HV6222B/HV6226B or HV6224B/HV6228B) were to spuriously actuate.
Since the CMF analysis showed that postulated CMPs could significantly impact plant operability, CCW non 1E devices were subjected to further evaluation as described in the.
following sections. However, because of the low probability of seismically induced spurious actuations (based on the preliminary evaluation of the non 1E components that indicated the likelihood of significant seismic withstand capability of most non-1E I
components), it was concluded that safe operation could continue while the evaluations
- were being performed.
4.4 : Evaluation of Non-1E Devices The CMF analysis showed that multiple spurious actuations of non 1E powered components could adversely impact CCW operability.
The next step in the CCW I
evaluation was to investigate whether such seismically induced multiple spurious actuations of the non-1E electrical devices were credible.
l Non 1E devices are not necessarily vulnerable to spurious actuation during a DBE. In many cases, a non 1E device is fabricated identical to a 1E device; it may lack 'only Ii procurement certifications to make it equivalent to its IE counterpart. In other cases, a 1E component is actually purchased and used in a non-1E circuit. Finally, many non 1E components differ physically only slightly from 1E components (e.g., wire insulation may be different) such that they have virtually the same seismic withstand capability. The
- purpose of this phase in the evaluation is to identify and eliminate those non 1E devices that are comparable to IE devices, in terms of seismic withstand capability, from further evaluation.
As discussed in Section 3.3, evaluation of non 1E devices was performed in three steps:
oPMo312 49
Report No. M86420, Rev 0 A.
Identification of non 1E devices in the CCW system that could affect components that serve a safety function.
B.
Comparison of each type of non 1E device with similar IE devices.
C.
Evaluation of whether the identified differences are likely to be detrimental to device performance (i.e., result in seismically induced unwanted actions such as' contact chatter) that could cause the CCW component to spuriously actuate.
The first step was to identify all non 1E electrical devices associated with CCW mechanical and electrical components. These devices are listed in Tables C 1 and C 2 of Appendix C. There are 12 device types (133 total devices) associated with mechanical components and 29 device types (95 total devices) associated with electrical power distribution components.
The 29 device types-associated with electrical power distribution components were.
~
immediately eliminated from further review, since their failure mode results in a loss of i
non 1E power. This is consistent with the assumptions used in the original design and is thus enveloped by the original design evaluations.
Next, a review of applicable engineering documents was conducted to determine how many of the 12 device types associated with mechanical components were procured as.
IE devices or were sufficiently similar to their IE counterparts to be judged " Comparable" in seismic withstand capability. Of the 12 device types,8 fit into this category (76 of the 133 total devices) and were classified as " Comparable". These 76 devices were excluded from further review.
The 4 remaining non-1E device types (57 total devices) were subjected to detailed engineering evaluation and, in selected cases, seismic' testing to assess their seismic withstand capability. These devices fall into four general categories:
]
o Relays and relay contacts (15) o Motor starters (18) o
. Control switches (12) q J
o Valve position limit switches (12)
]
Table 4-1 summarizes the disposition of these non comparable non 1E devices.
I OPM0312 4-10
~
M M
M M
M M
M M
M M
M i
O i
Tabn 41 N
e E
i oU RESOLUTION OF N NON-1E DEVICES u
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Reisys and Roley Contacts GE CR120AD 13 CCW Secton Valve Judged adeguate for sesemic l
CCW Ducheg. Vaive
- _ _ _ bened on Assoo i
testing (reference 4).
l l
}
Relays and Relay Contacts GE CR120C 2*
Leedown Heat Eschenger Valve Judged to fo5 under sesonne condmons (see text discosson, Section 4.5).
.c _t J
2.
Control Swnches Cutler Hemmer E30A8 12 CCW Secmon Volvo Judged adeguese for solemic l
j 4.
CCW Dscherge Valve w.._~_. by *.., _ i..
l CCW Meter Cooling Velve (reference 9).
CCW amamour Vaive i
3.
Motor Starters Cutler Hammer C50CN3 18 CCW Seceson Vales Judged adequese ter seenue Senes A1 CCW Dschesgo Valve
_ _. -_~._ booed on ANCO CCW Mesor Cooling Valve testing (recorence 4).
CCW nelnillow Valve i
Swge Tank Outlet Valve Redisese. Suppsy and Rosen Vasse 4
Valve Position Limit Switches letIDO EA170 12 Le ssion Host Enchanger Judpod adequece for sesemic a
c_. 2 1... by :..,_ 1..
g (reference 9).
ee E~
.O i
- There are two GE CR120C rolsys that are interlocked with as four leedown host exchanger solesion volves.
f l
,..._-,.-_..__.,_-_m.,
Report N:. M86420, Rev 0 W
NAMCO Limit Switches P
L The NAMCO valve position limit switches have very stiff springs for the small masses involved. Per engineering evaluation (reference 8), these devices can withstand seismic accelerations greater than the in cabinet DBE accelerations expected at SONGS.
~
Therefore failure of these devices is not considered credible.
Cutler Hammer Motor Starters i
The Cutler Hammer motor starters (contactors) were purchased as QC Ill for use in the g
non 1E circuits in the CCW system and have no physically similar counterparts in IE B
circuits at SONGS. The EPRI Report NP 5223, (reference 9), Generic Seismic Ruggedness of Power Plant Equipment, generated in response to Unresolved Safety Issue USI A 46, l
was initially used to assess the potential of these devices to fait during a seismic event.
The QC Ill Cutler Hammer devices used at SONGS 2&3 correspond to constituents of MCCs in the EPRI report (see Section 3.6 and Appendix D of reference 9). The following Ia quote is from that source:
I "In the energized state, motor control centers are rugged, being able to withstand 4.0 g or more. The principal failure modes at high levels are Ininor structural damage (sheet metal base tear or fatigue and relay chatter).
In the deenergized state, motor control center performance is limited by relay chatter.
The Generic Equipment Ruggedness Spectrum (GERS) for MCCs is 4.0 g with a zero period acceleration (ZPAJ of 3.0 g when energized and 1.S g with ZPA of 1.0 g when deenergized."
J The Cutler Hammer motor starters used in the CCW system are located in both the a
seismically designed auxiliary building, and the non seismic turbine building. Since no specific response spectra has been developed for the turbine building, direct comparison of the SONGS response spectra (the acceleration expected as a result of a DBE at SONGS) to the profile described above was not possible. However, a comparison of the typical response spectra for other plant locations indicates that SONGS spectra are typically higher than the GERs, indicating that the motor starters may not be able to withstand seismic accelerations of the magnitude of those expected at SONGS.
1 OPM0312 442
Report No. M86420, Rev 0 The Cutler Hammer QC III motor starters at SONGS 2&3 are normally deenergized, and hence, based on the EPRI report, would be more susceptible to spurious actuation during a seismic event than energized devices. The potential for a seismically induced common cause spurious actuation of Cutler Hammer control switches mounted in the same cabinets also existed. A spurious change in the contact state could result in energization and sealin of the circuit and a resulting change in the valve position. Since the EPRI report indicates that the motor starters could be susceptible to failure in a seismic event, they were further evaluated by seismic testing and evaluation as discussed in Sections 4.5 and 4.6.
General Electric Relays The General Electric (GE) relays were also purchased as QC III and used in non 1E applications. While the relays used at SONGS are similar to other General Electric relays and have similar model numbers to those used in IE applications, confirmation of the seismic wi*hstand capabilities was not possible. In addition, General Electric personnel confirmd that these devices are not currently covered under any GE qualification program. A review of reference 9 (Section 4.0 and Appendix D) indicated that GE industrial relays (Model CR120) were included in the EPRI test program.
The EPRI report lists the ruggedness (or fragility) of the CR120 relays at levels that are below the expected levels for SONGS, (i.e.,4.0g for the energized state and 3.0g for the deenergized state). These devices were, therefore, further evaluated by seismic testing 7
and evaluation as discussed in Sections 4.5 and 4.6.
I 4.5 Seismic Testing and Evaluation ANCO Engineers, Inc., Culver City, California, was retained to test the relays and motor
]
starters. ANCO had participated in an EPRI sponsored seismic testing program of various classes of relays in 1987, having been retained by EPRI to perform the seismic tests. The approach to testing of relays was basically that described in the IEEE relay test standard l
ANSI /IEEE C37.98 (reference 10).
]
The seismic testing performed for SONGS 2&3 relays followed the same procedures as I
those used in the EPRI program. The relays were mounted and hardwired for chatter monitoring in the same manner in both test programs. For details of the SONGS and
__l EPRI test programs, see reference 4, 1
4 OPM0312 4 13
kport N:. M86420, kr 0 i
The components tested by ANCO were a GE industrial relay, series A, model CR120AD, and a Cutler Hammer motor starter model C50CN3, series A1. The tested components were supplied from existing plant spares and were verified to be representative of the installed devices by walkdown (Section 4.6 of this report).
e The Cutler-Hammer model C50CN3, series Al motor starter tested was not the same I
series number as identified on vendor documents and engineering drawings. reviewed.
These documents listed a Cutler Hammer reversing contactor, series F.
Eaton Cutler.
i Hammer was contacted to resolve this apparent discrepancy. The supplier indicated that the series designation was used to identify component locations within an MCC bucket and that the motor starter supplied was identical to that tested. The difference in series I
number would have no impact on th:: cesting of this device.
l ANCO performed tests of the relay and contactor in the December 1988 - January 1989 time frame. Three sets of tests were conducted. However, the first two tests were
'g considered to be screcr ng tests, because the appropriate required / test response spectra i
3 had not been finalized. The results of the third set of tests were, therefore, utilized as the primary source of input.
The seismic testing (reference 4) was performed in accordance with procedures established and used for the EPRI Generic Equipment Ruggedness Spectra testing. The input motion used for the final test was an ANSI C37.98 type input spectra (reference 10). The ANCO report for SONGS (reference 4) demonstrates that the tested GE relay and Cutler Hammer contactor have sufficient ruggedness to withstand a seismic event with an in cabinet peak response (amplified by cabinet flexibility) of approximately 10g.
Testing up to this 10g level did not cause a change of state or result in contact chatter of the relays. As Figure 4 3 shows, this acceleration envelops the SONGS response spectra and means that the devices would withstand a SONGS DBE.
It should be noted that the seismic testing performed by ANCO was conducted with the test specimens mounted to a rigid panel attached to the shake table as shown in Figure 3 3. No significant chatter was noted during these tests. In the installed configuration, the seismic response spectra would be higher, reflecting cabinet flexibility and the resulting amplification. Figure 4-4 plots the required (projected in cabinet) response spectra (RRS) against the test acceleration. The floor response spectra was increased by a fcetor of six across the entire frequency range to obtain the RRS. A typical in-l cabinet amplification of three is suggested by EpRI/SQUG (reference 10). Sufficient margin is provided by amplifying the floor response spectra by a factor of six. As can be OPM0312 4 14
1 Report N: M86420, Jtre 0
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1 Figure 4 3 COMPARISON OF TEST RESPONSE SPECTRA WITH FLOOR RESPONSE SPECTRA OPM0312 4 15 I
Report Ns. M8600, Rev 0
'Ampuned Meer Respeme Speeka RESPONSE IN 9's 1.0E+02.u w.
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resonant frequencies greatu than 5 Hz.
I 1
Figure 4-4 COMPARISON OF TEST RESPONSE SPECTRA WITH REQUIRED RESPONSE SPECTRA 1
OPM0312 4 16 1
Repet No. M86420, Rev 0 seen from the figure, the test spectra envelopes the amplified required spectra in all expected frequmcy ranges for the devices. As discussed in the ANCO test report, the tested devices have resonant frequencies greater than 5 Hz. Based on this, enveloping
+
the required spectra only in frequency ranges above 3.5 Hz is consistent with the EPRI/SQUG GERS program which follows the generic testing requirements of IEEE 344 (reference 11). Since the test acceleration exceeds the RRS, the test demonstrates that C
the devices tested would withstand an earthquake of the magnitude of a DBE at SONGS.
=
An additional relay identified in Table 41, GE industrial relay model CR120C, was not available at the time of the test program and was therefore not included in the seismic testing. Subsequent to the conclusion of the test program, a sample of the CR120C relay was obtained and provided to ANCO for assessment of adequacy with respect to the SONGS DBE levels. ANCO concluded, based on manual tests, that the CR120C relay has very low ruggedness and would probably change state as the result of a seismic event.
Further evaluations of the CCW system operations were, therefore, performed to
]
determine the impact of these relays changing state during a DBE.
The GE Relay CR120C is used in the central circuits for valves HV6522A, HV6522B, HV6293A, and HV6293B. Valves HV 6293A/B are the Train A CCW isolation valves and 7
HV 6522A/B are the Train B CCW isolation valves to the letdown heat exchanger. The CCW letdown isolation valves are air operated fail close butterfly valves. Operation of the valves from the control room is only possible as tandem pairs, for example there is a single handswitch,2(3)HS6293 and 2(3)HS6522, to operate both valves. In order to open the opposite train isolation valves, such that cross train leakage could occur, then the following must occur and be available: (1) two active failures of NAMCO (EA170) close limit switches, (2) non.1E electrical power must be available, and (3) instrument air must be available. In order to open the opposite train isolation valves, the close limit switches must be closed for the train in service. Since the opposite train isolation valve close limit switches are in series it would require at least two active failures of the NAMCO limit switches, that are seismically qualified as discussed previously in this engineering evaluation. Therefore, the failure of two of these particular limit switches
]
concurrent with a relay spurious actuation is not considered credible and cross train leakage would not occur because valve position would not change.
I These evaluations show that even with the low ruggedness level of the relay, spurious e
actuation of this relay during a DBE would not adversely affect the functionality of the
]
CCW system. This conclusion is documented in NCR G928, revision 1 (reference 8).
J
Report Ns. M86420, Rev 0 m
In summary, of the 15 relays and 18 motor starters being evaluated, the ANCO seismic tests demonstrated that all but two relays were able to withstand a DBE at SONGS.
The two relays in question were associated with the letdown heat exchanger valves HV6522A/B and HV6293A/B. Failure of these two relays was evaluated and found not to impact the CCW safety function.
4.6 Walkdowns A walkdown of non.1E devices installed at SONGS was conducted to support the conclusions reached dudng the evaluation and testing of non 1E devices. The purposes of the walkdown were as follows:
Venfy that the installed relays and motor starters are the same as those tested.
o Verify that the mounting used in the plant is equivalent to that used in the o
- test, Verify that the mounting of non.1E devices is equivalent to the mounting of o
IE devices.
=
The devices that were walked down were located in three MCCs and one relay cabinet.
[
The non 1E components were observed and details documented. (Appendr D provides more detail on the walkdowns of non 1E devices.)
7 A comparison of the walkdown data sheets with the respective vendor drawings showed that the components are installed according to the drawings. No significant anomalies or discrepancies associated with the installed hardware were noted in the walkdowns.
Some documentation discrepancies were noted, however.
These are discussed and dispositioned in Appendix D. No discrepancy was found to invalidate the conclusions of l
the ANCO test results.
4.6.1 Comparison of As Built to Test Mounting The relays in the control relay cabinet were attached te mounting tracks which are bolted to a small strut channel. The small strut channel was in turn bolted to larger channels which are welded to the back of the cabinet. Figure 4 5 shows a detail sketch of the mounting of the relays in the control panels. This mounting is similar to the method of a
-n
..n 3
Jteport Ns. M86420, Rev 0
^
W s-UNISTRUT P1000(TYP)
UNISTRUT P0000(1YP) 1 8 32 SPRING NUT 0 32 x 3/4" ROUNOMEAD SCREW I
i I
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\\
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C:
CRf20 i
RELAY I
l
@1 {000' i
I GE CR120 RELAY l
Q' MOUNTING TRACKS l
10 24 x 1" ROUNOMEAD p
I 10 24 SPRING NUT s
Figure 4-5 TYPICAL RELAY MOUNTING DETAIL 4 19 OPM0312
Report N:. M86420, Rev 0 l
mounting for IE devices with the exception of the mounting track which is not used in the IE application. The mounting track as used in non 1E application provides positive attachment of the relay to the cabinet. This mounting scheme is comparable to the IE I
application.
I All of the non 1E motor starters were bolted directly to the back of the MCC bucket in the same manner as the IE motor starters.
h 4.6.2 Comoarison of Non 1E to 1E Mountine I
A walkdown was also conducted to compare the mounting of IE relay cabinets and MCCs to the non 1E relay cabinets and MCCs in the CCW system.
This walkdown was necessary to confirm that the devices that had been evaluated as comparable were l
mounted such that they would respond similarly to a seismic event. This walkdown revealed that, while there are some differences in the anchorage details of the cabinets and MCCs (e.g., amount of weld and welded vs. bolted), the anchorage of the non 1E I
cabinets and MCCs is adequate.
In comparing the mounting of IE relay cabinet to the non 1E relay cabinet, it was noted that larger weld sizes were u:ed for the 1E cabinet. This increase in weld size is due to the fact that IE cabinets are typically constructed of heavier gauge steel as a part of the overall conservative design approach. In evaluating the weld sizes used to anchor the non 1E relay cabinets, it was concluded that sufficient weld material was used to ensure l
adequate seismic withstand capability. The Generic Implementation Procedure (GIP) issued by SQUG permits the use of engineering judgement to evaluate (control) panels.
The relay cabinets have conduitt entering through the " top hat" via flexible conduits.
I These conduits provide springs at the top which will increase the frequency of the cabinets. The anchorage of the cabinets is also similar to those desirable types pictured in the GIP. Resonant frequency (in-situ) tests perfonned on the cabinets indicate that cabinet frequencies are generally above 10 Hz, which are not in the amplified region of the required response spectra. The ZPA of the floor response spectra is thus appropriate.
It is, therefore, concluded that the relay cabinets will be capable of withstanding the seismic events.
The evaluation of the 1E and non 1E MCCs included an assessment of the non 1E MCC bolt pattern to determine its capability to withstand the expected earthquake loads. The results of this evaluation concluded that the strength of this bolted connection is comparable to the welded connections used on the IE MCCs.
a OPM0312 4 20
_?
Report No. M86420, Rev 0 4.7 Systems Interaction Evaluations In support of the overall evaluation of the CCW system for common cause mechanisms that could result in spurious actuation of non.1E components, an additional systems interaction (SI) evaluation was performed. This evaluation focused on the non 1E components of the system to determine if there were mechanisms, other than seismically induced contact chatter, that could affect CCW operability.
The scope ofinitiating events to be considered for the SI evaluation was developed using NUREG 1174 (reference 5). The conclusions presented in this NUREG indicate that this SI evaluation should be limited to systems, and controls for the systems, that are required for safe shutdown and the reactor coolant pressure boundary. Furthermore, this NUREG states that the initiating events to be considered should include only those related to
=
1 seismic events, fires, and fluid.related failures such as flooding and water intnision, U
including spray from low or moderate energy piping.
]
The decision was made not to pursue a detailed review of components located in plant areas that had been evaluated for location specific initiating events (Appendix R, HELB Flooding) during the original design phase because of the minimal benefits expected.
]
This decision was based on the fact that the plant layout provides for system train f
separation without regard to IE or non 1E power supplies. Therefore, initiating events
]
in these areas that would affect both trains, and therefore, system operability, were not I
considered likely. In addition a limited review of the Appendix R spurious actuation evaluation indicated that applicable non 1E circuits had been previously addressed.
Following the above guidelines, the CCW system was reviewed to identify those components that could be subjected to previously unidentified system interactions. Based 1_
on this review, it was concluded that the few non 1E CCW components located in the turbine building would be subject to potential sis that could potentially lead to undesirable results as defined in Section 3.7 since the turbine building was not designed
]
to Seismic Category I requirements and was not included in the detailed plant hazards reviews conducted during the original design phase of the plant.
1 The following scenarios (Table 4 2) were evaluated on an individual basis to assess their impact on the CCW system operability:
1 A.
Seismically induced actuation of the fire suppression system.
B.
Seismically induced failures and Seismic Catermy II/I spatial interactions.
1 C.
Harsh eiwironments.
D.
Fire effects.
1 oPMo312 4 21
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I A review of the non 1E components of the CCW system listed in Table C 1 indicated that one MCC associated with the CCW system miniflow cross connect valves (HCV-6551 and HCV 6552) was located in the turbine building. This MCC was identified as tag number 2BM and is located at elevation 7 feet in the turbine building. In addition to being vulnerable to various postulated seismically induced interactions as a result of being I
located in a non seismic structure, this MCC was also located such that a number of postulated pipe breaks could result in ambient conditions in the vicinity of MCC 2BM that would exceed the environmental conditions for which the MCC was designed.
I An operability assessment was performed (reference 8) to determine the impact of the I
loss of power to this MCC or the potential spurious actuation of the CCW miniflow cross connect valves (HCV 6551 and HCV 6552) which are powered from this MCC. Spurious actuation of these valves is precluded by existing cross-train interlocks that will prevent l
the valves from opening. A loss of power scenado is consistent with the original design (the valves will " fail safe") and is enveloped by the spurious actuation scenado. As a result of this initial operability assessment, an additional evaluation was performed to I
determine if any single event could adversely impact all four miniflow cross-connect isolation valves. This evaluation revealed that the power cables of all four miniflow l
cross-connect valves are routed through the same fire area (2 SE-( 5) 135). Potential fires in this fire area and the resulting damage to the power cables for these four valves was previously addressed in the Fire Area Summary Document (90035BS). As indicated
- I in this document, existing procedures require that selected breakers are tripped after the l
appropriate valves are aligned to ensure CCW operability during this event.
I The remaining scenario, fire effects, was also evaluated and it was concluded that any adverse impact from this event would be enveloped by the scenanos discussed above.
This SI evaluation demonstrated that the potential ASIS that are associated with the non.
I IE devices of the CCW system that are located in the turbine building are either enveloped by existing plant hazards evaluations or are found to create no new challenges to CCW operability.
!I I
I OPM0312 4 23 I
i kport N:. M86420, Rev 0 l
5.0 CONCLUSION
S AND RECOMMENDATIONS The evaluation of the CCW system summarized in this report was performed in response I
to SCEs commitment to assess the ability of the CCW system to perfonn its safety l
3 function in light of the selected use of non 1E powered devices. Following the guidelines j
of GL 87-02, the CCW system was reviewed to identify non 1E devices. These devices
)
were then evaluated to assess their ability to affect the safety function of the CCW 4
system. Non 1E devices that could potentially impact the safety function were then evaluated further for:
o Seismically induced spurious actuations o
Potential adverse systems interactions l
5.1 Seismically Induced Spurious Actuations
!g In order to assess the potential for seismically induced spurious actuations, the identified
, W non 1E devices were evaluated for similarity to seismically qualified devices used throughout the plant. The majority of non 1E devices (63%) were determined to be
- l comparable to their IE counterparts in terms of seismic withstand capability. The remaining (37%) non 1E devices were reviewed by seismic testing and evaluation, ig including confirmatory walkdowns.
These reviews showed only two specific relays 3
(representing <1% of the non 1E devices) to be subject to seismically induced spurious actuation (i.e., contact chatter).
iI Table 51
's DISPOSITION OF NON 1E DEVICES
,l 0
g Spurious 4
3
- Comparable; ~ Acceptable ~
Actuatiori -
1 91.81 to 1E
. by test / eval; oossible f
Mechanidal Process 133' 176-
'55:
12L L and Controls Devices:
I Electrical Power
. 95 "
69; 265 0.
- Distribution Devices.
1 228 145L 81;
'2 i
tI OPM0312 51 I
Report No. M86430, Rev 0
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The relay in question (GE CR120C) was tested manually and found to have a very low niggedness threshold. However, further evaluation concluded that failure of this relay due to seismically induced contact chatter would not adversely impact system operability.
I These relays are used only in the controls of the letdown heat exchanger isolation valves.
Spmious actuation of these valves is precluded because existing interlocks between cross-train isolation valves are adequate to maintain the valves in their as-is position.
A thorough review of the non 1E devices in the CCW system using the methodology I
established in GL 87-02 demonstrated that the use of non-1E devices on the COV system will not adversely affect the ability of the system to perform its safety related function.
5.2 Potential Adverse Systems Interaction l
A detailed systems interaction assessment of the non 1E devices was also performed to identify any additional mechanisms, beyond seismically induced contact chatter, that could I
impact COV system operability. This assessment focused on potential interactions not previously analyzed in the existing plant hazards evaluations.
l The ASI review identified that only two motor starters associated with two miniflow cross-connect valves located in the non siesmic turbine building were potentially subject to ASIS. The Asis evaluated were fire effects, harsh emironment, Seismic Category 11/1 I
interactions, and flooding / water spray affects. While the actual Asis are not prevented, spurious actuation of these valves is precluded because existing interlocks between cross-l train valves are adequate to maintin the valves in their as is position.
5.3 Summary A thorough review of the non 1E devices in the CCW system using the methodology established in GL 87-02 and USI A-17 demonstrated that the CCW system at SONGS 2 and 3 complies with GDCs 2 and 44.
I I
I
~~
I
Report ND. M86420, Rev 0 I
g-
6.0 REFERENCES
1.
Letter to Mr. J. B. Martin, NRC, from Mr. C. B. McCarthy, SCE, dated June 24,1988, subject: Component Cooling Water System Review.
2.
Letter to Mr. J. B. Martin, NRC, from Mr. M. O. Medford, SCE, dated December 16,1988, subject: Component Cooling Water System Review 3.
Generic Letter 87 02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors (USI A-46), Febniary 19,1987.
4.
ANCO Test Report, Seismic Testing of a Motor Control Circuit, January 1990.
l S.
NUREG 1174, Evaluation of Systems Interactions in Nuclear Power Plants, May 1989.
6.
10CFR50, Appendix A, General Design Criteria.
7.
ANS Standard 51.7, Single Failure Criteria for PWR Fluid Systems (ANSI N6581976).
8.
SONGS NCR G928, Revision 1, January 3,1990.
9.
EPRI Report NP 5223, General Seismic Ruggedness of Power Plant Equipment, May 1987.
- 10. ANSI C37.98, Seismic Testing of Relays,1987.
I
- 11. IEEE 344 87, Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Gene.ating Stations.
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APPENDIX A RESULTS OF MECHANICAL AND ELECTRICAL FAILURE MODES AND EFFECTS ANALYSE 0
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it Component ecosing wesw valves open to anow Cbses Spunous aduseen Capsbany to coor seedo twsnian sendi supply and resum for Isedowncoonng water flow to
%w is bst. Leedown heat es.
heat enchengw(HV6293A.
leedown host changw is not mquwod br saio HV62938. HV6522A.
enchangw.
shutdown. Bothtrains HV65228) of CCW are avadable to perform ssWy fundson.
Opens Spurious adushon CooEng capabHDy of one Posmon swied I
sawy train may be knpwmd due to bar flow to components. Another i
g safety train is aveNeblo to i
4 pedorm safWy funden.
12 Component cooling water Preced pump from Cbses Loss of secumulaser None. The normelnunwnum Posihon swiidi Valves are not prowwfed minNIow controlveeves low flow condmon air pressure
%er of the system is over wish manualoperaeor i
(HCV6537.HCV6538 Spunous adushon 3000gpm. Thesevalves HCv6539) are normally closed.
Opens Spunous aduaten Coosagcapabmy of one tow now eienns sasmy train may be imponed is indivnbei due to low no.,in componeres-componmWs. Other sa8esy trainis av aabie to podorm p
sassey funden.
74 13 Componen coonng weier valves nomissy open Opens Broken valve.
None i thweis no pipe Sme5 drop in CCW smped on CCW syssem is supply and resum volves to albw cooling water loss of moeor break in the downseroom pump pressure i
_. 4-.J by fadure of h
i for radwaste-w.;;
flow to radwesse power, spunous piping. Drop in surge tardt valve wos closed non<recalvalves HV6212 system %w,;;.
aduation.
leveli there is pipe breset miholly. In addeon HV6213. HV6218. HV6219.
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HV6218.HV6219 dose en doesnseream.
j lour low surge tank savelto g
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W W W l f7 ) L, _l Tadite A-2 REVISED ELECTRICAL FtSEA (Addigen to UFSARTable 8.3 E5 (Sheet 4 of 9) 8 U
- 08 W ~ 7 NARAE NNT FUfewaves FM_LM a= =Xt
? EFFECT ON ELEUsesCAL6veits00 e s n GTOftSUnivastete 1 8C 480VI andnantar Sepplies tietsap posserto Lees of Power Laos of tsatsappowersupply to 400W Less of pessorto RdOVs 2HWW224A, 2HV6224B.2HV62204 and Transsonner 2 BIOX-B Umt2480Vloodoenter inadmnest 2B10. Assesseing See nomesf -4 The wefses failas is. 2B10 frosn Unit 3 tius 3A08 souses was psegiosely lost, ins leRuse vesult in loss of power to 480V loedogneer 2B10 80 480V I andnanter %mpuma poseer to Unit 2 Leesof Posser loss of powerto 400Vleseooneer2B16 Loss of poseerto t00Vs2HW6217 Transformer 2 B16X and1E 480Vloedoeneer 2HV6220,2HV6221,2HV6222A, 2B16 2HV622B,2HV6225,2HV6228A, 2HV62288,2HV6227,2HV6229, 2HW6485 ADO 2HV6605. The vsfses fell as-is.. 7A CwcustBresher SuppEss poseerto Unit 2 Fault loss of powerto 480VIcedcenter2811 Tenporaryloss of poseer to RdOVs 2B1101 and 1E 480Vloedcontor 2HV6651 and 2HV6552. The 2811 values leR as4s. 78 Cucust Breedser Supplies poseerto Unit 2 Fault loss of nonnsiposeersupply to 2810. Loos of posserto RADVs 2B1001 480Vloedcenter2B10 Operaeoracson een neonogpee sie 2HV6224A, 2HV62248, sa=*=neer fromInss 3AOS 2HV62284 and 2HW6228B. The velses fall as4s. 7C Ciscud Bresher Supplies tietsapposeerto Fault Lees of bet $ste powersimplyto less of poseer to RdOVs2HW6224A, 2B1013 Unit 2480Vloerbenter 480V anadnaneer2B10. Assuming fue 2HV62248,2HV62284 and 2B10 frorn Unit 3 bus 3A08 nonnel sousco was poslously lost, siis 2Hviesgue. The values toilasis. taBuse wE result in loss of posser to 480V ": _- J2B10 ^ 7D Cwcust Bresfier Supplies powerto Unit 2 Fault Lees of powerto400Vloedconter2B16 Laos of ponerto as0VB 2HV6217, 2B1801 and 1E 480Vloedoenter 2HV6220,2HV6221,2HV6222A, h 2B16 2HV6228,2HV6225,2HV6226A, L 2HV62288.2HV6227,2HV6229, 2HV6485 AND 2HW6505. The g values Isil as-is. u ,o, 8A Loadtenser 2B11 Supplies power to Unit 2 Fault Loss of poseer to Unit 2 non-1E 480V Laos of poseerto h80VB 2HW6651 (o non-1E 480V RACC 2Bhd h8CC 2004 and2HVliS52. The selves tailas is. 5 o 8B Loadoenter2B10 Supptes power to Unit 2 Fault Loss of poseerto Unit 2 non-1E 480V Loss of poseerto RADVs 2HV6224A, non-1E 480V RfCC 2BP RfCC2BP 2HV62248,2HV6228A and 2HV62288. The values fan as-is.
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L Table A-2 o REVISED ELECTRICAR. FIEA ~ j (ananmanus go UFSAR Tabte 8.38) 8 (Sheet 6 of 9) IDS COMPONENT FLARE COMPOIENT FUNCTION FAEANE MODE EFFrCT ON ELEUseauhi5miesta w tret:CiON Shusastus-10A MCC 2BM Supp'es povver to 480V Fault loss of MCC 2BM Loos of powerto MOVS 2HV6651 AC motoroperased vahes and 2HV6652.The wakes tag as-is 2HV6551 and 2HV6552 108 MCC 2BP Suppies power to 480V Fault Loss of MCC 2BP Loss of powerto MOVS 2HVRoAst, AC motoroperated vakes 2HV6228A,2HV62248 and HV62288,2HV6228A, 2HV6224A.The wakes fall as-is 2HV62248 and 2HV6224A 10C MCC 2BX SuppEss powerto 480V Fault loss of MCC 2BX toss of power to MOVS 2HV6505 AC motor operated valves 2HV6225,2HV6221,2HV6220, 2HV6505,2HV6225, 2HV6229,2HV6227,2HV622tiB, i 2HV6221,2HV6220, 2HV622tiA,2HV6222B and g 2HV6229,2HV6227, 2HV6222A.The valves fail as-is 4 2HV62268,2HV6226A, j 2HVEr/m and 2HV62221 100 MCC 2BT Suppies powerto 480V Fault loss of MCC 2BT toes of powerto MOWS 2HV6217 AC motor operated vahes and 2HV64ti5.The vehes lee as-is ' 2HV6217 and 2HV6445 10E Battery Charger Sipplies normal 125 V<le Loss of Power loss of normal power supply to 125 V<lc No altectfor90 minutes 20005 power to 125 Vile bus 2D5 bus 2DS. A bet $ cup supply of 125 V<lc is prended by battery 20011 for 90 #mnutes 11A Cwcuit Breaker Steplies normal 125 V<$c Open Lees of nonnelpowersuppy to 125 V<lc No effectfor90 minutes 2D502 power to 125 V<$c bus 2D5 bus 205. A backte sapply of 125 V< leis A pmeded by bsIIery 20011 for 90 minutes p 11B Circuit Breaker SuppEss becfiup 125 V49c Open Loos of backap power supply to 125 Vi$c No eIIsct for90 minutes IC 2D501 power to 125 V<lc bus 2D5 ~ bus 2D5. Assunung Wie normalsource R was -W,ast Weis failurewW result in aloss of 125 V<lcbus 2D5 9 12 125 V-dc Bus 2D5 Supplies Powerto 125 Fault loss of powerto Unit 2125 V<tcpenes SaoTable C-1 for aflected V-dc panel 2054P4 2DSP4. Loss of power to Unit 2 auximary conponents e contras relay panel 2L-73-4 and NSSS auxi5ary relay cabmet 2L-71 . ~, ~ _ _ _ _ m
TatWe A-2 SEVISED ELECT 54 cat. FREA (Ademon to UFSAR TatWe 8.3-8) (Sheet 7 of 9) Q 8 ' 08 COMPOENT NAnE CCMiCNi NT FUNCTION - FAILUE MODE ' EFFECT ON ELECTf98f?AL ShiEM ~ " EFFECT ON SU65WiEM ~ c D: M 13 Circuit Breaker Supphes power to 125 Open toss of power to Unit 2125VDC panel See Tabee C-1 for affected 2D506 V-dc panel 2D54P4 2DSP4. Loss of power to Unit 2 auxitary components control re41y panel 2L-73-4 and NSSS auxiliary relay cabinet 2L-71 14 125 VDC Panel Supphes 125 V-dc power to Fault loss of power to Unit 2 auxdiary control See Table C-1 for allected 2DSP4 auxiliary control relay panel relay panel 2L-73-4 and NSSS auntiary components 2L-73-4 and NSSS auxiliary cabinet 2L-71 relay cabmet 2L-71 15A Circuit Breaker Supphes 125 V<9c power to Open Loss of power to Unit 2 aux 9iary control See Table C-1 for affected 2DSP495 auxiliary control relay panel relay panet 2L-734 components 2L-734 158 Circuit Breaker Supplies 125 V-dc power to Open toss of power to Unit 2 NSSS auxiliary See Table C-1 for affected 2DSP477 NSSS auxiliary relay cabmet relay cabmet 2L-7t components 2L-71 4 16A Circuit Breaker / Supplies power to 480V Open or Closed No effect Spunous operabon of valve A 2HV6551 Starter 2BM36 MOV 2HV6551 168 Cwcuit Breaker / Supplies power to 480V Open or Closed No effect Spunous oper Wien of valve 2HV6552 Starter 2BM37 MOV 2HV6552 16C Circuit Breaker / supphes power to 480V None No effect Noimpact since the valveis power loded out Starter 2BP10 MOV 2HV6224A 16D Circuit Breaker / Supphes power to 480V Open or Closed No effect Spunous operabon of valve 3e 2HV62248 j Starter 2BP11 MOV 2HV62248 16E Circuit Breaker / Supphes power to 480V None No effect Noimpact since the valveis power loded out C Starter 2BP12 MOV 2HV6228A 16F Circuit Breaker / Supphes power to 480V Open or Closed No effect Spunous operaton of valve 2HV6228B R Starter 2BP13 MOV 2HV62288 16G Circuit Breaker / Supplies power to 480V Open or Closed No effect Spunous opera 90:1 c' vth 2HV6465 Starter 20T44 MOV 2HV6465 o 16H Circuit Breaker / Supphes power to 480V Open or Closed No effect Spunous opcT'oW.wwe 2HV6217 Starter 2BT45 MOV 2HV6217
s. Table A-2 o REVISED ELECTRICAL FRIEA 2 (Ad@ Hon to UFSAR Table 8.3-8) S (Sheet s of 9) g IDS COMPOIENT NAME COMPONENT FUNCTION FAILURE MODE EFFECT ON ELECTRICAL SYSTEM _ ' El-FECT ON SUBSYSTEM - 1 61 Circuit Breaker / Supplies power to 480V Open or Closed No e6ect Spunous operalen of valve 2HV6220 Starter 2BX42 MOV 2HV6220 16J Circuit Breaker / Suppres power to 480V Open or Closed No eMect Spunous operaAn of vahe 2HV6221 Starter 2BX43 MOV 2HV6221 16K Circuit Breaker / Supplies power to 480V Open or Closed No eGect Spurious operaton of valve 2HV6225 Starter 2BX46 MOV 2HV6225 16L Circuit Breaker / Supphes power to 480V Open or Closed No e#ect Spunousoperaton of valve 2HV6505 Starter 2BX47 MOV 2HV6505 16M Circuit Breaker / Supplies power to 480V None NoeMect Noimpact since the valveis power loded out h Starter 2BX49 MOV 2HV6222A k 16N Circuit Breaker / Supplies power to 480V None No eMect Noimpact since the valveis power locked out Starter 2BX50 MOV 2HV6226A 160 Cwcuit Breder/ Supplies power to 480V None No e6ect Noimpactsince the valveis power locked out Starter 2BX51 MOV 2HVr?27 16P CircuitBreaker/ Supplies power to 480V - Open or Closed No eMect Spunous operaton of vahe 2HV622?B Starter 2BX53 MOV 2HV62229 De 160 Circuit Breaker / Supplies powerto 480V Open or Closed No e6ect Spunous operaton of valve j 2HV62268 g. Starter 2BX54 MOV 2HV-62268 16R Circuit Breaker / Supplies powerto 480V None No eNect Noimpactsince #ie vaheis power locked out g Starter 2BX55 MOV 2HV6229 16S Auxiliary Control Supplies 125 V-dc power Faulted Loss of breaker Loss of power to 2HV6293A, 2HV62938,2HV6552A, y Relay Panel 2L-734 to solenced vahes 2HV65520,2HCV6537. 2Hv6293A,2HV62938, 2HCV6538.and 2HCV6539 The - 3U 2HV6552A,2HV65528, vahes fait closed 2HCV6537.2HCV6538, e and 2HCV6539
+ Report No. M86430, Rev 0 ) 1 L ai j I a Pli o!! i I e I { l 11 i i 11 i g ! 1 I.$11 lj l I!Il I i i [ c1 gig !! 3 i f I fl I ! It!,lI i a m i 1 !i i 911 1iI, I ur ii i ei s.,s
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- UE8 C000000N GOODE FAtttNIE Ap04 LYSIS F001 900N-1E POWERED C000PONENTS ON THE CCW SYSTERE N
W 2 Of N I;GBETHOO OFM a 3 i EVAllJATION " COftHECTWE ; '*ggw - aiv J A' > 4 x;N. ~j'm DETECTIOII' . FAILINIE RAECHAfGSal e m DESCRS' TION OFes; pp"y*F AILURE Is00E 9:w, ':J"
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6 Safety trains A and B cross-Ols&arge aoss-connect Spurious adusekst Water mer be trans8 erred High4ms surge tek tevel No ellect onsystem Ofone connecsed on disserge valves HV6226A/B er of MOVdue to sersmic from train e tain alarms irt 9telong term - operabRey. Spunous accumeon gescluded ty side. HV6229A/B oport hadvertendy event seiende adeguacy of non 1E devices. Addleonsey,vesnes HVS226A and HV6226A are electicasy *= Mad for Appendhr R purposes, enedvereene c==._ a. of A and 8 trains is presented 7 Safety tahs A arpf 8 are naniBour valves HV6220 and Spurious actuation of Water rney be transfoned Surge tanklevelhipV No efIect on systern oper-94ano crossennected ort 9te HV6551.or HV6221 and MOVs due to seismic from tain to tain. sour alarms M 9telong abeer. Tfue angnment h this <hscharge side via Wie pig HV6552 biadvertendy open. event term. senario only occurs vehen P025is doum tar g minrmow ene. P-025 is MiniSow controlvalve HCV4537 mameenance. va8ves HV h.~,ca esscticapy or HCV-6539 inadverten9y 6220.HV6551.HV6221 opens. and HV6552 spelbegin to open but emanng innertoess on vafue postian wel kn-mettimely stop vafve w mort. Thh weemitDie cour transiemng from tabt is tain. 8 Loss of minlAowIIcar pati PM fnhlRow isotaden vsfves Spurtois act*intieriof None. AanlBourisnot N/A NoefAset on system. None for swing pump PM HV6220 and HV6551 or HV6552 MOVs due to sersmic utikred at gut to'v operatrIIey. henillowconsol v*e ts normany clesed at and Hv6229 inadverteney close. event. sus sour. Mrunaw contetvasve 'A ncv453s seas h ciosed posason h. = k 9 Safety trains A and B are Vdves HV6522A/B er Spurious acsuselon of Water mer be transferred Serge tanklevet too eseect on system None 4 crossannected via ese HV6293A/D ;. A_Oi relay due to seestmc event. Irorn tran to tain. mdlcagon and alarms m._,. Spurtoes S actummonis precaused by setdown heat ermanger open. emsung cross-trah wasve .M, warogen remains avadabee intertocks This analysis ordy addresses the potential for seismicaEy induced common morte tallures kmi non-1E devices. It does not indude a randorn single fisilure. NOTE:
v. Report No. M86420, - Rev 0 ~ ) $8 I I I I I I I .is m.l)..I. l.i 'ii.!.i,ill l i {i Il ,I.I1 t' j It:sli2,!li 1 !!:ii!t!t [ lh}Ijjk; 1 i i'l i I 1 d I li lii
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p I I I I il I I APPENDIX C CCW NON 1E DEVICES jI -I l; -I
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e. i m a P{11 i 11 8 11 11 s Iss Iss l <.1 Iss Iss 8 !R I!!ii I!!ii !!!!si!!!ii !!!ii a i qa.iiiini insin iiini iniin iniin khh khh khh khh (hg'RJ, 19988 'llill lisil ailli lilli l n l ) glan $$na $$nn Egan $$nn l 0 s 3 m y. y!!! lill! l kj illl illl illl li I !!$ lie lllie lllie lllie llIvell s. I @! liie!liiel 111! liie! liie! flk 11 1 Iri 11 11 le1 8 e iurli iurli slill ilill suill l l l l I _m c.,
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s p e d*j t 4 G e y s l o e b e b t e u s m s 1 a e w 8 R s a R G l B e s s e ?M ~ s e e s s s s s Mm. t t e es SM s i h O D 0 E Dt t 1 i d d 00 n n r O n 3 bfT' o 3 n 00 e a a G 77 33C 33C 22C E 22C 7 aP e e O 84 9 5 00 88 48 88 M 3 33 33n 33s 43s S 33e 3 n n n SS 44n 44t 34a D 44t 0 geIM 8 a e e g.pd2 8 l 8 8 A, 9, l 4 4 A, B. 4 4 A. 6 4 A, 3 E. E, 00 g{mM: O0 00 00 0 S 5 8, e, 598
- 838, 559 559 S59 N50 4,
388 776 03 0 E. 0 8S9 33 9 8 1 2 8 20 228 ~ 7 86e 3 3 3 s Oe 8 09 3 0 e30 0O 0 00 O0 s g 3 33o 3 3ss SS S9 S8 a SS e ee PPe doe t PPS ppm PPO mnSs s s s o s n ee e VVE BGfa EeEDs WVE VVE VVG f p T'aP tS eMTW C L GLLLL GLLLLGLLLLL 3LLLL e 8EEEE VRC vRECC eEEEE eEEEEWEEEEE I WNfMM ecc LCC sNN Ncc8 WNpfN ee LCNCC N AH VfAAs P AAMMPMAMMM P AA Vff P AAAA I I RR Cs R I P PPPPP PPPPPPPPPPP PPPPP 8a I 7$4E> 0, SE C q$d+& 4 RXK I 4 4 808 - 0 B9B X44 Xx 4 mRY V e80 8 e0889008 8 3Bs 555 55555555353 55535 222 EL eM7 E 111. n 5 1111A111717OO LLLOL sSS 1 1117 Pi 2 2a 1 f S e0uM 9P sOOSs o-LL1lL LLLLtL1.LLLL L uLLUU 222a2 22222222s2A 222A 2 uUU L AA BBB O Ps sRRBe t e R R R E^ iN T N 9j* ?- O T; A FIM C B E e-EIO J sssss ss s ssess ssssssosss s N se soe eesee eeeeeeoeee0 eeeeo eee g _1 ( W ee0 e YY9Ns YYYYY YYYYYYYYYY9 YYYYV YYf J0s 1W Z S X$OC.P S - R e EC le O t 1 t t C A pmMi c A B .s C P 2 q JR e s 2 o s t L K s e R R R R H Nh o e t o EOE S H .d b s A Al A8 e e AR - R f4D d 4 9 S 1RC a d - 8 ERC I s S T 8 S s T V ;;- f 8 - f ElCR El D t E 9. C C R f e t 5 ( 4 08w 33SA 2 0VOl 20VOU cNE r h a
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8 eOE e A 3 0VOt 0 3 3SA+1 4 8 A A 3S+L33S+M2 l 3 C f f1 11Ef PPO B60 C 2AC f 1 4 - 1 1-PPO p-s61 0e El PPO El E ppt 4AAAR 1 a.%fM d 0 &AAAA t 5 5 s0 R35 AAAA AAAA q S1 CEC H2222 N 2 2 2 2 +s 2222C 8 2222 S9C a0 r r r o 5 E w$g ee ss 1 L wn s EOE! se s f e nn e s 0 s u 1RCa u ae 0 ss r r s r r s r s r r r r r ooooo p M g He eoooo ooeoooeoeo r s s r s a I 8TDp 0 0 8 n r4 eoooo oooooooeoe oooeo s r 9 00Ea o ee s u e r dice s ttttt tt tt tttmbtt ttbtt s s p s s p s s m nusn uSu W 00C eC es masnu nuunnuuuusE f wNk% s C (s S E u a eeeoo ooooeooooo oeoee Dd C eC AtGCC FFFFF FFFFFFFFFFG FFFFF I C A r$4L - L E EOEL A 9D A 30 A 0D A 30 0 8D 3334 3 7C 4 B 8084 3333 24A 444 1RCa n C 808 24 T2c 044 24444 0tVO 22C e 444 24 Il e6 22262 32242222420 22242 22 466N8 24c 0 0 TYYH4444H82 468 - 1 22O c 664H4 00E G 44D o TYYCY - CYTYYCY TYYCY 4So 80D .C T wS AS2 FFFFF FFFFf-FFFFt R FFFFF VH2 A 6 sHLC4 22222 2222222222C 22222 H24 e 3) r r r ru e e a e nr s e c s c a e re a b v t t EE m x n u r E E E E 1CEeT e T# ^m r r t r l et et nt et 6IP rt oi re od reot rt od a 0V es on er on os on os on u^ 0E1 ivRos s~ s e n e s e ivRanseivRee s e ivRaa 0 D h. s 0 s b mnoCe pga$ mnoCs mneCs mneCl b A e r l nCent oi ra e r s o u e s os nm o os nmy o s os nn e1 y e e aa nCa namCe nSi a e smem nCa u nb v n n u uqlae a qlaM a l u u La _teoe a a TWSABTWSABR TWSAB v :S a ql g aNql I r r l r a r l g g v::RCS TI SAB g 5o 6 5 4 5 4)f ) 2g 0 E ) 2 2 t 7 LTN 2m ) ) ) 0e 4ib 7 t 0 6k W 4d 3 - c 8 - c 3 ela A89Mg Po 5 Pa 3 Po 5 Pl 2 CEI PV o 5 B 2 g 2 l l 4 yE 4 po 4 eNPg Pe 2 pB 4 pB nr V mC gAOI PRg mg 4 mw V mw V u o C ur o V e n u HsC a u a V uo C uo CaSg Pt H P8o H Peo H PBe H Peh H v oa (2 r d v 2 li l 2 WeV Wt e Inb EoE We m 2 Wia 2 l l ( g Wi r a a ( t n ( ( e ECD d N CD CRV CRV CAV C C C C C C c s o e a '). ts" p e 7 8 9 t re c s OoK8 9 ll IliIIlf'f[lilI 'I!/[-l [jl.tf(lllifliflf flf[l[lI\\}(lftIli
_m ... E E E_ E. lE ~ E Ei E' ' E E ' E :E E E b Oy-TatAeC t ^ O$ CCW NON1E N PROCESS AfD CONm0L REVICES tJ (Shoot 3 of Sl - fTERS itIECHAgeCAL3 p g5000HE g g pNON1Ee e NON-1E c.i ~ u NOIHE; .-- T-r 8 ." m gwy W[Nrhpggn qpe ?y gge 3 M> CONm0L ~ c'iTO1E ?S s ' POWEft. ^ MG, ! ? ",b a 80D. 4 COtrOBENT4 +~Mp DEVICEQ4fC +CosmIOL ' CONm0L- ,m DIMCE., C0er000ENT SUPPLY.l LOCATIOtt ~ Odh fEbbaftKSfF~ '* 7 >ha.p..g QT;Q" WsTTPEp M 9DEVEEin 9 DEVICE E Q...A 2.D,ESCRFTION-
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'M" "-M' F ms e i 11 CCW Pump PE Valve M HV4229 Umhonque SedB-00f10H29C Yes Bus 2BX VLV O D 30705 Geotor CocEng ^ 2HS4229 - 00SC 10N - Yes BUS 29X 30CR OD 30734 Vaso. Sinner 42 OCCC Coeur-Hanener C50CN3 Sodes At No GUS29X B8CC Noems 6,8. 80 35734 (2W4229) l i t 12 CCW Pung P-025 valve Accessor W4228A Unusongue SedB40f15-H3BC Yes Bus 29P VLV OD 30710 i tector CooEng Hanthushch HS6228 eBSC 10N - Yes 08LO734 BACR peste 3. 9030885 Value Retsy (BDO C GE CR120AD Mo RALO734 PANEL-OD 30885 CongotSutch CS Cuper4tanener E30A9 No BUS 29P BSCC 80otes 6. 8. OD 30710 (2HV4228A) Starter 42 OCCC Coeur-Hammer C50CN3 Sedes At No BUS 29P RfCC Notes 6,8. 80 30710 9 13 CCW Pung P-025 Valve Acesseor W-62289 Urrutongue SMB00f15 H39C Yes Bus 29P VLV OD 30711 l 4 Discharge Vahe Haruismech MS4228 GASC 10N Yes teLO734 RACR Note 3. 90 30885 [ Retsy LASOC GE CR120AD No RALO734 PANEL 0D 30885 (2HV $22W) ConhetSutch CS Coeur-Hammer E30A9 No BUS 29P OfCC ' 9estes 6,8. 80 30711 Starter 42 OCCC Cueer44ansner C50CN3 Sedes At No 90529P 90CC Destes 6. 8. DD 30711 14 CCW Pung P424 Valve Actuser HV4220 Umhongue STAB 400f2-HOBC Yes Bus 29X VLV OD 30711 BAirdRour Valve Hanetsweth 2HS4220 efSC 10N Yes MLO734 MCR Note 3. DD 30886 l Roemy tAROC CR120AD Me RfLO734 PANEL Notes 6. 8. 80 30886. OD 30735 (2HV4220) Starter 42 OCCC Coeur 44mmmer C50CN3 Ledes A1 feo BUS 2BX BACC Notes 6. 8. 80 30735 ConselSudeth CS Cueer-Hammer E30A9 No BUS 29X BSCC fesses 6. 8. 80 30735 N 15 CCW Pung P-024 Valve Actentor HV4551 Undsongue SMB400f2-HOBC Yes Bus 2EB8 VLV OD30711 tenso.v.he H.na th 2HS4220 MSC 10N Yes Mt0 m MCR Note 3. OD 3 Ns. OD s.882 a Reimy LAROC GE CR120AD No MLO734 PMcEL Notes 6,8. 00 30886. DD 30002 M i (2HV4551) Secreer 42 OCCC Cueer44emmer C50CN3 Sedes At No BUS 2004 teCC secess 6,8. 9030882 0 ContralSelech CS Cueer-Hammer E30A9 No BUS 29R8 GACC festes 6. 8. 00 3D882 + 1 oo %Au5 ,D e t ~ . - +.. ,...n< ~.w.
g m m a f 3 A. W 1- ..I'~ O Totde C-1 ' 'tp E ccW es0N-1E aneceeAseCAL PROCESS Afm CONmOL DEVOCES g s*. M (Sheet 4 et8) w yme w gygy^ggg.yp p, HERS q MEC-^ l- = g e p1Eg a n 98000-1E & a 800se 1Es e pe0001E -;,
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00 0, fCOtrDfENTj l SEVICE 4 CONTROL ICostTROL- !&C0887ROL -iTD1E 68 -PUWER,' 'O NW ) ~ ~ L W;NCMS fMg DEVICE F DEvtCE S COIIPUBEE08t ' SUPPLYi L00419000 gW' BRIAAfsts ?g< EDESCfurn00s, Y
- TTPE M DEVICEd #7 RK+y J
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TAG CH LR 16 CCW Pump P 026 Valve Actunger HV4221 Umhangue SR88400f2-HOBC Yes - Bus 2BX ' VLV E/D 30736 ReinlBour Value Hondumede 2HS4221 98SC 10N Yes 88LO734 00CR Note 3.E/D30908 E/D30736 Roley LBR0fC GE CR120AD , 90s 98LO734 PANEL 80oees 6.8.OD 30896 (29W4221) Starter 42 OCJCC Cuest-Hammer C50CN3 Series At feo BUS 2BX 90CC 88 pees 6. 9. E/D 30738 Coveret m** CS Cueer-Hanener E30AB 9eo BUS 2BX tsCC Neeos 6. 9. E/D 30736 17 CCW Pipoge P426 value Actuator HV4iS52 thnhangue SA88400v2-HOBC Yes 2Bh8 VLV. E/D 30709 heinieper Value Hendeelldt 2HS4221 88SC 10N Yes teLO734 RfCR Note 3. E/D 30088. E/D 30083 Rotay LBR0rc GE CRf20AD too 04LO734 PAfEL 8epass 6.8 (2HV-tiSS2) Starter 42OCJCC Cueur44mmness C50CN3 Series At See BUS 2000 00CC Notes 6. 8. E/D 35893 CareetSmach CS Cueer-Hervener E30AB Peo BUS 20h8 tsCC feoses 6,8. E/D 30883 18 Leedoesn Huet _ _ _ ~ ^- StS6293 a8SC 10N Yes 98LO734 00CR OD 30798 i Enfienger(E082) Retny HSIX GE CR120C feo 08t0734 PANEL Note 6.9. E/D 30798 q Valve UmitSeedt ZSL6522C 80A8800 EAf70 98o 08LO734 RV E/0 30798 Lindt Smach ZSL65220 90A88C0 eat 70 No 08LO734 RV 00 30798 (2HV4293A) Umit Sutch 2SL/H6293A SIAASCO EA170 No R8LO734 VLV Noess 2. 7. E/D 30798 19 toedoesn Host Handschde HS4293 00SC 10N Yes 88t0734 RSCR E/D 30798 En9umger(EOS2) Reiny HSfY GE CRf20C No R8LO734 PA80EL Nota 6.9. E/D 30799 Vafve Unit Smach ZSL6522C DeAA8CO EA170 fee 94LO734 RV E/D 30790 Undt Seech ZSL65220 NAA8CO EAf70 peo 88LO734 VLV E/D 30798 (2HV42938) Umit Seede ZSUH62938 90488C0 EA170 90s 98LO734 RV Notos 2. 7. E/0 30798 Se 20 Leedown Heat Hantbumlech MS 6522 00SC 10N ' Yes 98LO734 00CR OD 30790 Enhanger(E082) Relay HSfY GE CR1200 f6e A8LO734 PANEL Nose 6.9. E/D 30798 q' Vasv. umn Sanch zSLs29sc seAn8CO EA170 fee 98LO734 VLV OD 30798 h, Umm Seech 2SL62930 NAAOCO EAf70 peo 88LO734 RV E/D 30798 (2HV4522A) Umst Smach 2St./H6522A NAh4CO EA170 fee 88LO734 VLV penses 2.7.E/D 30798 0e 21 Leedown Heat Handseech H!HI522 88SC 10N Yes 98L0734 SfCR E/D 30798 g Enchanger(E082)Retsy HStY GE CR120C fee 88L0734 PANEL Note 6. 9. E/D 30798 y Vasve Umn Smach zSt6293C sema4CO EAf70 fee 98LO734 VLV OD 30798 ,9 UnetSench zSL6293D feAmeCO EA170 See 98LO734 VLV OD 30798 (2HV45229) Umit Salsch 2SUH6522B NAA8CO EA170 No 80LO734 VLV Notes 2. 7. E/D 30798 $U e
Report No, M86420, Rev 0 y' y$l
- 1 i
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Report No. M86420, Rev 0 'l u I l. 1{1 $l 8 it i 1 i , j ! } 1r ]l k ll!!,I1ll{l
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1 mum; - aus aus n -- asum sua sus aus aus amm L J. sum aun sum n uma i l l: L Tat:4e C-2 n: 50DN-1EELECTRICAL POWER DISTRIBUTION DEVICES w (Sheet 1 of 7) 91900N-1E ELEC% C000PA"?'"" 8: CORE 3ONENT $. $9Ert;ntig#4 MMON 1EELECys#$p% DEVICE @M M%DEVICEi$9; gjeTO.1Esfi ELECTR8 CAL g%('4NON-1E EM5% MygesswxWmwp**4yggomn W 'ELECTRfCAL CORE 80fENT OESCIWNIOfd' geeMgesg$neprpsesg@gmg~ea##rtM TAG 900BWER **N?YPEN MANUFACTUftGR sannsJ:ammases:R WDEVICE70 incoming BKR for2A09 from 2XR1 2A0807 1200A AC8 ITE SHK-350 Yes ControlCKT BKR 2A0007 TS Test Switch GE SB1 Yes ControlCKT BKR 2A0007 2HS-1683A Handswech MSC 10-H Yes ControlCKT BKR 2A0007 2HS-1684A Handswitch MSC 10-H Yes ControlCKT BKR 2A0807 SR,SH Auximary Relay STRUTHERS DUN 21988XP Yes 4 ControlCKT BKR 2A0007 Vanous (HGA) Auxiliary Relay GE Various HGAs Yes n ControlCKT BKR 2A0807 Vanous(HFA) Auxiliary Relay GE HFA51 Senes Yes(1) ControlCKT BKR 2A0807 Various (AGA) AuxiEary Relay AGASTAT 7000 Series Yes ControlCKT BKR 2A0007 SX Aurdiary Relay STRUTHERS DUN 106X6X107 Yes ControlCKT BKR 2A0807 Vanous ControlPower BKR WA WA Yes k ControlCKT BKR 2A0007 Vanous Fuses MA WA Yes A ControlCKT BKR 2A0007 12SR1 SYC Check Relay GE 121JSSIA1A Yes [ ControlCKT BKR 2A0007 127RX ResidualVolt Relay GE HFA51 Senes Yes kn' Control CKT BKR 2A0007 Not Available Potential XFMR Not Available Not Avadable WA 9 { Control CKT BKR 2A0807 Various Svid-un;zina Varir=M Vanous No(3) + l
m e1 .Fl...I 1 J Table C-2 ocK NON1E ELECTRICAL POWER DISTRIBUDON DEVICES - 80 (Sheet 2 of 7). W^ d#^" e siFNON 1E ELECsg $NON4EELEC; COREPA*JLe s ft Ew, g;gn!We.pW?!GaMa#rsags ELECTRICAL $g$g$fMON-1Ej M*NiDEVICEss@f fi%DEVICEie94% 5l$1 TOTEMS
- .ELECTRICALCOREPONENTDESC5MBON 39g$y CORFONENT y pp-pgappgupagagssaggan!;eanMM TAGtm W J WDEVICETYPE -.
REANUFACTURER RBODELNURABER MDEVICEfRI Control CKT BKR 2A0005 2A0005 1200A ACB ITE SHK-350 Yes ControlCKT BKR 2A0005 TS Test Sunsch GE Set Yes ControlCKT BKR 2A0005 2HS-1684 Handst.::di MSC 10-H Yes ControlCKT BKR 2A0005 Vanous(HFA) Auxiliary Relays GE HFA51 Series Yes Control CKT BKR 2A0005 Vanous (HGA) Auxiliary Relays GE Various HGAs Yes O Control Scheme 2A0810 186HFA Auxiliary Relay GE - 12HFA5142H Yes ControlScheme 2A0009 Not Available ControlBKR . Not Avaikham Not Available Yes ControlScheme 2A0009 Not Available ControlFuse . Not Avh Not Available Yes ControlScheme 2A0009 TS Test Swilch ITE TypeC77 Yes Control Scheme 2A0009 2HS-1682 Handswech MSC 10-H Yes-ControlScheme 2A0809 Vanous(HGA) Auxiliary Relay GE Vanous HGAs Yes A ControlScheme 2A0009 186HFA Auxiliary relay GE 12HFA5142H Yes Load Center XFMR 2B11X Dry ITE Not Available Yes(2) g Load Center XFMR 2B16X Dry ITE Not Available Yes(2) g. 9 Load Center XFMR 2B10X Dry ITE Not Available .Yes (2)
- n, Load Center 2011 Indoor ITE Not Available Yes(2) o
u n4 ru Table C-2 I NON4E ELECTRICAL POWER DISTRIBUTION DEVICES S (Shen 30f 7)
- NON4EELEC5 COe58"E*" 8 ayswgggg49ppwl:ptaggN5fpqggg ELECTRICAL apsp%;ygg gNDOME ELEC?J ;inEDEVICEtenM F4?JO;1ER CORFOMENT $*jiMNON4Ed g MFDEVICEWi#
t w
- ELECTRICAL.;C0er0fEENTDESCIW8 TION bh % @ W!"#FM993&s#jf$wi^ W SM **#@)3 TAG N'Z_ _ = _=i SMwaue ivree '""*" 5 Asnematu inf0EI 900esBE3t TNDEVICEt31 2B16 Indoor iTE -
Not Avaih8da Yes(2) Load Center 2B10 indoor ITE Not Avadsbis Yes(2) Load Center FeedierBKRlor2BM from 2B11 2B1106 600A ITE K-Don 600S Yes 86-HFA Aoix5iary Relay GE 12WA51A42H Yes(1) ControlScheme 2B1106 Feeder BKR for2BP freen2810 2B1002 600A ITE K-Don 600S Yes 06HFA AuxiEar, Relay GE 12HFA51A42H Yes(1) Q ControlScheme 2B1002 2B1602. 400A ITE K-Don 600S .Yes FeederBKR for20X from2B16 ControlScheme 2B1602 86HFA Auxiliary Relay GE 12HFA51A42H Yes(1) FeederBKR for2BTfreen2B16 2B1602 600A ITE K-Don 600S Yes 86 FHA Auxiliary Relay GE 12HFA51A42H Yes(1) ControlSchems 2B16 to. Load Center 2B11 MainBKR 2B1101 ACB ITE K-2000S Yes j A Load Center 2B10 MainBKR 2B1001 ACB ITE K-2000S Yes D k Load Center 2B16 Main BKR 2B1601 ACB ITE K-2000S Yes w 2BTF 600A,3P Cueler-Hammer 412H133 Yes(4) E u ManuaiTransfer Swhch ,9 2BM NfA Cuger-Hammer NfA No g Motor ControlCenter 2BP N/A Cuder-Hammer NrA No Motor Control Center
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w mmmr .-3 F L_J t j t. r O Table C-2 E8 NON1EELECTRICAL POWER DISTRIBUTION DEVICES 'O (Sheet 5 of 7) ._ ___ ;y_ans a $@800164Esa sa*gRDEWBCEM6 %f8701EWR W M A M r% m $fM e m m n@ M s p pig ELECTRICAL gggwem;r _ ~ $800N 1EELECs !ELECTRMCOBr0NENTDESC5WTIOff CORFOfENT %97N098;1Ea! MfDEVICE%W J 9WWV@%MMMMMMSM@M2nh o TAG Pm_ R @ DiEvniTYPE ? 08A80UFACTURER nannsa ? M WhEVICEW l MCC 2BP BKR for HVfDPAA 2BP12 SA MagneemonIr Weelinghouse HFB Yes i MCC 2BP BKR for HVsopnR 2BP13 5AMagneem only Wesemghouse HFB Yes MCC 2BX BKR forHV6220 2BX42 3A Magnetconly Weelinghouse HFB Yes I i MCC 2BX BKR forHV6221 2BX43 ' 3A Magnete only Wesinghouse HFB Yes. MCC 2BX BKR for HV6222A 2BX49 SA Magnetc only Washnghouse HFB Yes n A. MCC 2BX BKR for HVfp??R 2BX53 5A Magneteonly Washnghouse HFB Yes MCC 2BX BKR forHV6225 2BX46 3AMagneteonly Weshnghouse HFB Yes MCC 2BX BKR for HV6226A 2BX50 SA Magnetconly Wesanghouse HFB Yes MCC 2BX BKR forHV62268 2BX54 5A Magnehc only Washnghouse HFB Yes MCC 2BX BKR forHV6227 2BX51 10AMagnehconly Wesanghouse HFB .Yes 3 MCC 2BXBKRlor HV6229 2BX55 10A Mag %-only Weshnghouse HFB Yes a MCC 2BX BKR for HV6505 2BX47 3A Magnete only Washnghouse HFB Yes 3: MCC 2BT BKR forHV6217 2BT45 3A Magnete only Weshnghouse HFB Yes g MCC 2BT BKR for HV6465 2BT44 3A Magnetc only Weshnghouse HFB Yes MCC 28M Starter for HV6551 2BM36 Size 1 Culler-Harnmer C50CN3A1 No e MCC 28M Starter for HV6552 2BM37 Size 1 Cuger-Hammer C50CN3A1 No
Oo 6 TatAo C 2 P.! NOl61EELECTRICAL POWER DISTRIBUTION DEVICES (Sheet 6 of 7) %N0061E EL.ECW DNON1EELEA COIFA*" 5 pg W9gp$ @@$DEVICEQUA !!MDEVICE9fAi *%TO1EM? ER.ECTRICAL l asiMAps%e42/i$9EWgga s w$rmn; M 1EFAs $$ COIWOMENT 'a W yn,iiTYPEEN RBANUFACTURER manOEL980BNBER ?$9EVICEt8i ELECTRICALCOIWpMENT. a Al WweniMMstenMPH195tFAN;PP7M6MW TAG pm_11 -- MCC 2BP Starterfor HV6224A 2BP10 Sire 1 Cuder-Hammer C50CNSA1 No MCC 2BP Starterfor HV62248 2BP11 Size 1 Cueer-Hammer C50CN3A1 No MCC 2BP Starter for HM 2BP12 She1 Cuper-Hammer C50CN3A1 No MCC 2BP Starter for HV62288 2BP13 Size 1 Cuper-Hammer C50CN3A1 No MCC 2BX StarterforHV6220 2BX42 Size 1 Cuder-Hammer C50CN3A1 No MCC 2BX Starter for HV6221 2BX43 Size 1 Cueer-Hammer C50CN3A1 No MCC 2BX Starter for HVFMA 2BX49 Size 1 Cuder-Hammer C50CNEA1 No i MCC 2BX Starter for HVFMR 2BX53 Size 1 Cuter 44ammer C50CN3A1 No MCC 2BX Starter for HV6225 2BX46 Size 1 Cuder-Hammer C50CN3At No se MCC 2BX Starter for HV6226A 2BX50 Size 1 Cuper-Hammer C50CN3A1 No MCC.x ete,e,,o,HVm6B .x54 m, cm, ,,o 7 MCC 2BX Starter for HV6227 2BX51 Size 1 Cueer-Hammer C50CN3A1 No g={ MCC 2BX Starter for HV6229 2BX55 Size 1 CW 4"...a 650GGA1 No O
4 OoK Table C-2 80 NON-1EELECTRICAL POWER DISTRIBUTION DEMCES (Sheet 7 of 7) gNON-1E ELEC rN COR58 ARABLE evW@wMgf9hC/WWS@!AWr3M9mgg ELECTINCAL gggigsvMgggg$g&l$MDEMCE@g#!$@ON1EELECp @TOi11EEGi ~ fDEMCEngis pptiNON1E% @.LECTRICALCCRW80NENTOEScismON sis 9s CORAPONENT (s@iue:vescTYPEW# "*^*"X L M ' gg6rwieggggelEl huevsDEias l vneude#atr@NT@s@MMfSMMPPtWAP TAG 9'E T_4 l 2BX47 Sire 1 Cuder-Hammer C50CN3At No MCC 2BXStarterfor HV6505 2BT45 Size 1 Cader-Hammer C50CN3At No MCC 2BT StarterforHV6217 2BT44 Sire 1 Culler-Hammer C50CN3At No MCC 2BT Starter for HV6465 O t; The OC I and OC lit devices are the same except for tesemg, OA pecedure, 1. and modelrumbers. 2. Elecincal swilchgear, load certers, and load center translormers do not have model numbers. The 1E and non-1E swilchgear, loadegs, and loadceeder transfomiers areidentical. se Class 1E synchronizeg is made up of cornponents provided with the 4 KV 9 3. Class 1E switchgear. Part of the non-1E synchronmng is made up ciidenecal 5 components provided with the 4 KV non-1E swechgear and part of the non-1E synchronizing is provided by cabmet L224 which is OC 111. g The dsconnect switch size is such Wiat a seismec event is not Ikely to induce chaltenng. R' 4. h .o. GENERAL. D = N/A = Not applicable 0 NOT AVAILABLE = Not avadable without impacting plant operahon y., ................. -,.,,. = _.. -...
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g I I APPENDIX D WALKDOWN OF NON-1E DEVICES B lI I
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.oJ. I I Report No. M86420, Rev 0 l APPENDIX D CCW SPURIOUS ACTUATION .g COMPLETION ACTIVITIES - gj WALKDOWN OF NON 1E DEVICES I INTRODUCTION The Component Cooling Water system is required for safe shutdown of the plant. A-number of controlling devices in the circuitry were identified as non-1E devices, i.e., these devices _were not seismically qualified. _ A plan was developed to demonstrate that these non 1E devices were sufficiently similar to IE devices (seismically qualified) to take .k credit for their operation post DBE. As a part of this plan, a walkdown was initiated to inspect and document the devices installed in the plant. This documentation is required. to support the seismic testing that was conducted on the selected CCW components. The purpose of the walkdown was to verify that the installed devices are the same as those listed 'on the elementary diagrams and procurement documentation. Furthermore, this _ h. walkdown was conducted to verify that component mounting in the cabinets was enveloped by the mounting used during the seismic text progmm. - A second walkdown was performed to inspect " comparable" IE MCCs and relay cabinets. The purpose of this second walkdown was to provide information that could be used to f. make a comparative evaluation of the IE and non 1E component mounting and cabinet -anchorages. .WALKDOWN PROCEDURES l . The'walkdown procedures followed were simple. Each of the devices identified (in Table D 1, attached) as not qualified or not qualifiable was listed on a walkdown-data sheet. A walkdown team, consisting of a Bechtel seismic engineer, a Bechtel electrical physical I layout designer, two SCE engineers, and a station maintenance person, conducted the walkdown on July 25,1989, and observed each of the devices identified. Each MCC cubicle-was opened and the device was located. The model, manufacturer, SCE tag number and, if possible, the manufacturer's date code were recorded. Anomalies, I if found, were noted. Anomalies included the possibility of " adders" attached to the contactors or relays. The mounting of each device, as well as the MCC and relay panel
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Report No. M86420, Bev 0 l
- anchorages, were recorded. Photographs were taken of each cubicle, except that identical cubicles'in a single line up may not have been photographed.
EVALUATION OF WALKDOWN DATA The walkdown revealed several anomalies or discrepancies in documentation. The discrepancies found were: model numbers and tag numbers differed from the data sheets, g component description on data sheet was not the same as that type installed, and some .3 additional tag number information was found. More specifically, the differences are: ~ A. Starter model numbers on the data sheets were Cutler Hammer F Series, whereas the model number on the installed starters were Cutler-Hammer Series A1; B. Starter 420C/CC was incorrectly identified on the walkdown data sheet as 420C/RC due to a typographical error in the walkdown data base; I C. Component description for control switch listed on data sheet as "handswitch", Cutler-Hammer catalog indicated a push button operator; D.- In addition to the tag numbers stated in the walkdown program data base and _l_ on the elementary diagrams,.the following relays had additional identifiers attached: Relay LBDC -- 2R LBRO -- 2N HSLX -- 2L LBRC -- 2M HSIY -- 2K The terms "handswitch" and " control switch" are sometimes synonymous, as in this case. 'I The interchangeability of the terms will not affect operability of the device; therefore, this should not be considered a discrepancy. I The discrepancy of Item 2 above is not significant as this is believed to be a typographical error in the walkdown program data base (the elementary diagram, drawing 30735, indicates OC and CC). All the starter contactors are identical and only this one is labeled as "RC," which would indicate a typographical error. I OPM0312 D-2 -I. _ _ _ - -____m.__-._.__m
Report No. M86420, Rev 0 The additionalidentification tags attached to the relays as described in Item 4 above are - used for wiring purposes. Rather than list the entire tag number for the devices in a circuit, an abbreviated identifier such as "2R" is used to aid in routing and terminating wires. The major discrepancy found was the Cutler Hammer starter, which was labeled Series Al on the starter and listed as Series F in the walkdown data base. It appears that the electrical designer who originally developed the elementary diagrams and the electrical engineer who developed the walkdown program data base used the designation series F81 from the vendor drawings. A telephone call was placed to Eaton Cutler Hammer to ascertain the difference between the Al designation on the device and the F81 = designation used on the vendor drawings (and included in the walkdown data base). There is no difference, the F81 designation is a code that the manufacturer puts on the drawing to identify a specific component in a specific MCC bucket. Since the two series designations Al and F81 are essentially the same device, there would not be any adverse affect on the operability of the CCW system. During the walkdown and inspection of the identified devices, particular attention was given to the possibility that " adders" may have been installed in the MCC cubicles and relay panels, particularly on the relays and contactors themselves. The significance of the presence of adders is that they would have a direct bearing on the seismic testing + ) that was done. No adders were observed, either on the relays or contactors, or anywhere within the MCC cubicles or relay panels. There are similarities between the mountings and anchorages of the IE and non 1E devices and MCCs and cabinets. The 1E rotary relays were found to be mounted to the relay cabinet by bolting (1/4 inch) directly to P6000 strut channels that were in turn welded to the back of the relay cabinet. The non-1E relays were mounted in a mounting ] track, bolted to strut channel that is bolted to another strut channel welded to the back panel of the cabinet. Although the non-1E relays are mounted in tracks, the similarity of the overall mounting is comparable. The anchorage of the non 1E cabinet is similar to the anchorage of the 1E cabinet; however, the anchorage is not as extensive. The non-1E cabinet has three plug welds located along its 72 inch length in the back with 3 inch long, flair-bevel fillet welds at the front corners, whereas the 1E cabinet is anchored with 6 inch long,1/4-inch fillet ) welds at 12 inch centers along the front and back faces. This difference is consistent with the conservative design approach used for IE devices. The relays found in the 1E MCCs I e-m m y
Report No. M86430, Rev 0 are not the same as those found in the non-1E MCCs; however, the mounting of the relays is the same, that is, small bolts are used to mount the relays. It should be noted here that the IE relays are larger than the non 1E relays. - The anchorage of the MCC to the building is significantly different for the IE MCC than for the non 1E MCC. Welds 2-1/2 inches long, at 8 inch centers are used to anchor the IE MCCs and the non 1E MCCs are bolted. The mounting details of the non 1E MCCs were evaluated and determined to be capable of withstanding DBE loads. COUCLUSIONS The devices identified as not qualified or not qualifiable were inspected to verify the as. built condition as indicated by the walkdown program data base and elementary drawings. Several discrepancies were noted during the walkdown, such as labeling for = identification purposes. None of the discrepancies found have a significant bearing on the ability of the devices to perform their intended functions and thus will not have an s adverse affect on the operation of the CCW system. Similarities in mounting and anchorages exist between the non 1E and IE devices and -l MCCs and cabinets. The mounting of the relays in both the MCCs and cabinets are E similar for the 1E and non 1E devices, although the non 1E relays in the relay cabinets ] are mounted in mounting tracks, whereas the 1E relays are not. Since the mounting J tracks provide a positive locking mechanism to hold the relays, this difference in mounting can be considered minor The anchorages of the MCCs and cabinets differ ] between the IE and non-1E; however, there are similarities that do exist. Both classes of relay cabinets are welded to the building floor steel. The Class IE cabinets are welded q with substantially more welding than the non 1E cabinets, although the amount of I welding for the non 1E cabinets is still substantial. The welding of the IE cabinets supports the conservative design of the cabinet anchorages and also assists in providing } additional stiffness to the cabinet. The non 1E cabinets do not require the same stiffness, thus the welding is not as extensive as for the IE cabinets. The same arguments apply to the MCCs, even though the non 1E MCC is anchored with bolts rather than weld material. J I i _m m y
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