ML20024D155

Board Notification 83-100:forwards Info Re Environ Qualification of safety-related Electrical Equipment & Mixed Oxide Fuel

ML20024D155
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/21/1983
From:	Miraglia F Office of Nuclear Reactor Regulation
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP), Atomic Safety and Licensing Board Panel
References
TASK-AS, TASK-BN83-100 BN-83-100, NUDOCS 8308030223
Download: ML20024D155 (5)

Text

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July 21, 1983 Docket ?!o. 50-155 MEMORAtIDUM FOR: Atomic Safety and Licensing Board for Big Rock Point Atonic Safety and Licensing Appeal Board for Big Rock Point FROM:

Frank J. Miraglia, Assistant Director for Safety Assessment Division of Licensing

SUBJECT:

-EQUIPi!ENT QUALIFICATION AND MIXED OXIDE FUEL (B0ARD fl0TIFICATION N0.83-100)

Consumers Power Company's (CPC) proposal to expand the storage capacity of the Big Rock Point spent fuel pool is presently under litigation before the Atomic Safety and Licensing Board (ASLB).

In early June 1982, the first ASLB hearings on the expansion were held in Boyne Falls, Michigan.

Genuine issue of fact number three under Christa-ifaria Contention 8 (C-MS) and 0'ileill Contention II.E-2 (0'ileill II.E-2) involves the qualification of the containment spray valves for high temperature and high humidity.

The combined contention C-f tB/0'Neill II.E-2 was referred to as the TitI contention because the contention questioned the safety of the pool after a LOCA when the containment would be inaccessible for an extended time (pool is inside containment). During the June 1982 hearing the staff presented tcstimony showing that the valves are qualified for high temperature and humidity. The staff's testimony was based on information presented by the licensee in several submittals including one dated April 30, 1982.

On flay 31, 1983 CPC submitted information as part of the continuing assessnent of the environmental qualification of_ safety-related electrical equipment. This submittal provided new information on the containment spray valves. In the April 30, 1982 submittal CPC indicated that the valves only had to be operable early in an accident to initiate containment spray. The fiay 31, 1983 submittal amends the earlier submittal by indicating that the valves must remain operable for up to 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> following a break because the containment spray valves must be closed when core spray is manually switched to the recirculation mode. Containment

-spray valve closure is required to ensure adequate water to the core spray during recirculation since containment and core spray are fed by the same header piping. Before the recirculation mode, the fire water system provides enough water for both systems.

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' July 21, 1983 This infornation is being provided to the Board because it is relevant to the hearing issue as discussed above. This information does not alter the staff's testimony because the high temperature and humidity tests which provided the basis for qualification ran well past 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />. Therefore, the valves are still judged to be qualified for high temperature and huaidity as stated in the staff's testimony.

Another contention related to maintaining the pool in a subcritical condition was addressed in the June 1982 hearing. The ASLB issued an initial decision on the contention and CPC appealed that decision. The appeal was heard by the Atomic Safety and Licensing Appeal Board on llarch 24, 1983.

In response to a question by the ASLAB, staff stated that Big Rock Point no longer has mixed oxide fuel in the reactor. That statenent was correct at that time.

In late June 1983, CPC informed the staff by telephone that two mixed oxide fuel assemblies which were stored in the pool after a previous cycle will be placed back into the reactor during the cycle which is scheduled to begin in August 1983. This information is being provided to the Board because it relates to a statement the staff made to the ASLAB. The information has no significance in the criticality contention or any of the other contentions before the ASLB or the ASLAB.

[Ori'ginni signed by Trank J. Miraglia Frank J. Miraglia, Assistant Director for Safety Assessment Division of Licensing

Enclosure:

Consumers Power Company letter dated May 31, 1983 cc w/ enclosure:

See next page C0!4 TACT:

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i l i for up to 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> following a break because the containment spray valves must be closed when core spray is manually switched to the recirculation mode. Containment spray valve closure is required to ensure adequate water to the core spray during recirculation since containment and core spray are fed by the same header piping. Before the recirculation mode, the fire water system provides enough water for both systems.

This information is being recommended for board notification only because it is relevant to the hearing issue as discussed above.

This information does not alter the staff's testimony because the high temperature and humidity tests which provided the basis for qualification ran well past 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />. Therefore, the valves are still judged to be qualified for high temperature and humidity as stated in the staff's testimony.

j Another contention related to maintaining the pool in a sub-critical condition was addressed in the June 1882 hearing. The ASLB issued an initial decision on the contention and CPC appealed l

that decision. The appeal was heard by the Atomic Safety and Licensing Appeal Board on March 24, 1983.

In response to a question by the ASLAB, staff stated that Big Rock Point no longer has mixed oxide fuel in the reactor. That statement was correct at that time.

In late, June 1983, CPC informed the staff by telephone that two l

mixed oxide fuel assemblies which were stored in the pool after a l

previous cycle will be placed back into the reactor during the cycle which is scheduled to begin in August 1983. This information is being recommended for. board notification only because it relates to a statement the staff made to the ASLAB. The information has no significance in the criticality contention or any of the other contentions before the ASLB or the ASLAB.

(Original oigned by Frank J. Miraglia Frank J. Miraglia, Assistant Director for Safety Assessment Division of Licensing l

Enclosure:

Consumers Power Company letter dated May 31, 1983 cc w/ enclosure:

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NRC FORM 318 (10-80) NRCM 0240 OFFiClAL RECORD COPY use.,o:= m-en.=

Mr. Paul A. Perry, Secretary U. S. Environmental Protection Consumers Power Company Agency 212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office ATTN:

Regional Radiation Representative Judd L. Bacon, Esquire -

230 South Dearborn Street Consumers Power Company Chicago, Illinois 60604 212 West Michigan Avenue Jackson, Michigan 49201 Peter B. Bloch, Chairman Atomic Safety and Licensing Board Joseph Gallo, Esquire U. S. Nuclear Regulatory Commission Isham, Linccin & Beale Washington, D. C.

20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris Wasnington, D. C.

20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Peter W. Steketee, Esquire Washington, D. C.

20555 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic Safety and Licensing Board Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Board Washington, D. C.

20555 U. S. Nuclear Regulatory Commission Washington, D. C. _ 20555 Big Rock Point Nuclear Power Plant ATTN:

Mr. Dave Hoffman Mr. John O'Neill, II Plant Superintendent Route 2, Box 44 Charlevoix, Michigan 49720 Maple City, Michigan 49664 Christa-Mari a Mr. Jim E. Mills Route 2, Box 108C Rouie 2,' ' Box 108C Charlevoix, Michigan 49720

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Charlevoix, Michigan 49720 William J. 'Scanlon, Esquire Chai rman 2034 Pauline Boulevard County Board of Supervisors Ann Arbor, Michigan 48103 Charlevoix County Charlevoix, Michigan 49720 Resident Inspector Big Rock Point Plant Office of the Governor (2) c/o U.S. NRC Room 1 - Capitol Building RR f3, Box 600 Lansing, Michigan 48913 Charlevoix, Michigan 49720 l

l Christine N. Kohl Hurst & Hanson Atomic Safety & Licensing Appeal Board 311 1/2 E. Mitchell L

U. S. Nuclear Regulatory Commission-Petoskey,- Michigan 49770 l

Washington, D. C.

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CC Dr. John H. Buck Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

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Ms. JoAnn Bier 204 Clinton Street Charlevoix, Michigan 49720 Thomas S. Moore Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 James G. Keppler, Regional Administrator Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Lee E. Jager, P.E., Chief Environmental and Occupational Health Services Administration Michigan Department of Public. Health 3500 N. Logan Street Post Office Box 30035 Lansing, Michigan 48909 i

Mr. David J. VandeWalle Nuclear Licensing Administrator Consumers Power Company

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..y Generet offices: 1945 West ParnaH Road, Jackson, Mi 49201 1517) 788-oS50 May 31, 1953 Dcnnis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Cocsission Washington, DC 20555 DOCKIT 50-155 - LICENSE DPR BIG ROCK POINT PLANT - ENVIRONMFNTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPHENT - RESPONSE TO THIRTY (30) DAY REQUEST The NRC in a letter dated April _26, 19.83, sub=itted the Safety Evaluation Report (SER) and the Technical Evaluation Report (TER) f or the Environ = ental Quclification cf Safety-Related Electrical Equipment for the Big Rock Point Plant.

The staf f requested in the SER that Consumers, Power Company reaffirm the justification for continued operation (JCO) and within thirty (30) days of

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receipt of the SER, submit information for items in NRC Categories I.B. II.A and IV for which JC0 was not previously submitted to the NRC.

This letter responds to this request.

Consumers Power Company has determined that additional JC0 is not required since no new equipment has been'added to the Big Rock Point Plant.

Therefore, with thE exceptions noted below, the JC0 provided in our April 30, 1982 submittal is still valid.

It should be noted that a compreh'ensive review program is being conducted for items in' NRC Categories I.B and II. A and will be scheduled as part of our integrated assessment program which will be described in our upcoming June 1,1983 submittal. (Please note that items in NRC Category IV are precluded from the scope of our review program since the TER did not identify any open items.)

As a result of our review of the JC0 provided in Consumers Power Company letter dated April 30, 1982 for motor-operated valves: -MO-7051, MO-7061, MO-7070, MO-7071, MO-7064 and MO-7068, an error was found concerning the operability times of t,hese valves.

Specifically, Consumers Power Company failed to address the need for these valves to close when entering the recirculation mode following core spray actuation. Big Rock Point Plant emergency procedures require the operator to isolate containment sprays (MO-7064, MO-7068) and one core spray line to ensure adequate core spray flow to the core spray train in-service.

This transfer to the recirculation mode can occur between four and 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> following the break event. Accordingly, please replace the applicable JC0 statements documented in our April 30, 1982

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submittal with the following statements. We plan to update the Big Rock' Point EEQ Book and submit-it to the NRC.

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eJv606v127-830531 OC0583-0029A-NLO2 DR ADOCK'05000355 I. h PDR

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DM; utchfielc, Chief 2

Eig Ecci. ?cin Plant EEC - 30 DAY EESPOSSE May 31, 1983 MO-7051 and MO-7061

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The unqualified equipment will have performed its safety function prior to d

failure.

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As outlined in the su==ary section of the discussion on Containment Atmos-l pheric Conditions, core sprny actuatien occurs within 2.5 minutes folleving a large or intermediate break event. 'For small breaks, core spray occurs

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1 i= mediately following Reactor Depressurization' System (RDS) actuation.

Conditions prior to depressurization are significantly less than design

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paraneters due to limited exposure to the harsh contain=ent environment.

E Upon entering the recirculation mode, four to twenty-one hours following a y

break, closure of MO-7051 or M0-7061 may be necessary if the break occurs in g

the high energy side of the primary core spray line.

Closing one out of two y

valves (MO-7051 or MO-7061) would be necessary to ensure long term adequate E

core spray flow, e

5 An actuator of the sa=e type used on an MO-7051 and MO-7061 cuccessfully co=pleted a 1.0CA si=ulation. Testing for radiation or ther=al aging qualifi-cation for this type of actuator has not been done; however, most component materials used in the actuator and =oter can withstand a threshold da= age of at least 4.0 x 106 RADS.

Since the valves (MO-7051 and MO-7061) are not required to operate beycnd a twenty-one he.ur time period, the safety functien perfor=ed by these valves vculd have been executed before prolonged exposure to the harsh environnent could conceivably result in their failure.

MO-7064 The unqualified equipment vill have per'for=ed its safety function prior to failure.

g As outlined in the sur: mary section of,the discussion on Contain=ent Atmos-pheric Conditionc (ie, for stea= line breaks requiring containment spray) i-actuation occurs shortly following the event when contain=ent environ =ent has g

not degraded significantly.

MO-7064 is not located in the steam drum cavity; i.

the area which experiences the te=perature rise during the stea= line break.

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Upon entering the recirculation mode, four to twenty-one hours following a

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g break, closure of MO-7064 is necessary to ensure adequate core spray flow. An actuator of the same type used on MO-7064 has successfelly completed a LOCA m

I cimulation.

A test for radiation and thermal aging was conducted on actuator units similar to the. type used on MO-7064. Based on the results of these tests, we conclude that the environmental conditions are less than design due to successful actuation of containment spray.. Since MO-7064 is riot required it-to operate beyond a twenty-one hour time period, the safety function of E

MO-7064 would have been performed before prolonged exposure to the harsh mF environment could conceivably result in its failure, u

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DMCrutchfield, Chief 3

Eig Eock ?cin Flant EEQ - 30 DAY RESPONSE May 31, 1983 MO-7070 and MO-7071 The unqualified equipment will have performed its safety function prior to.

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failure.

As outlined in the summary section of the discussion on Containment Atmos-pheric Conditions, core spray actuation occurs within 2.5 cinutes following a large or intermediate break event.

For s=all breaks, core spray occurs immediately following RDS actuation. Conditio'ns prior to depressurization are significantly less than design parameters due to li=ited exposure to the harsh containment environment.

When entering the recirculation mode, four to twenty-one hours f ollowing a break, the Emergency Operating Procedure (EMP 3.3) instructs the operator to close the backup core spray line valves (MO-7070 and MO-7071).

However, if the break has occurred in the high energy side of the primary core spray line, the backup core spray line is utilized to provide core cooling and the primary core spray valves are closed. MO-7070 and MO-7071 would remain open to ensure long term adequate core spray flow.

The cotor operators for MO-7070 and-MD-7071 are to be replaced in the 1983 refueling outage with Rotork actuators, Model Nunber 14NA1.

Since these actuators are qualified via type testing, the safety function of these valves (MO-7070 and MO-7071) would be perfor=ed..

MO-7068 The unqualified equipment will have performed its safety function prior to failure.

As discussed in the su= mary paragraph on Containment Atmospheric Conditions, actuation of' Primary Containment Spray (MO-7064) would occur shortly'following a steam line break, and before contairi en3_ environment has significantly m

degraded.

Should the unlikely failure of MO-7064 occur at this time, secondary containment spray (MO-7068) would be manually actuated inmediately.

When entering the recirculation mode, four to twenty-one hours following a break, closure of the secondary containment spray valve (MO-7068) is necessary to ensure adequate core spray flow.

An actuator of the same type us*d Qn MO-7068 has successfully completed a LOCA l simulation. Testing for. radiation or thermal aging qualification for this type of actuator has not been done; however, most component materials used in the actuator and motor can withstand a threshold damage of at least 4.0 x 106 RADS.

Since the environmental conditions are less than design due i.

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OC05E3-00293-NLO2

a DMCrutchfield, Chief Eig Rock ?cint Plant EEQ - 3C 2..Y RESPONSE May 31, i9E3 to successful actuation of containment spray and the valve is not required to operate beyond a twenty-one hour time period, the safety function of MO-7068 would have been performed before exposure to the harsh environment could conceivably result in its failure.

It should be noted that the secondary containment spray is a redundant system.

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.r CAC' N Kerry A Toner Senior Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point 6

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.OC0583-0029C-NLO2

BOARD NOTIFICATION BN-83-100

• w/enclosurc Docket (50-155)

OPE NRC PDR SECY Local PDR OGC ORB!5 Reading F. Miraglia H. Denton*

L. Berry' E. Case

• EQBranch (V. Noonan)

D. Eisenhut*

ORAB (G. Holahan)

R. Purple

• SEPB (W. Russell) 4 M. Williams G. Lainas D. Crutchfield R. Emch H. Smith M. Jambor J. Hard, EW 450 A. Bennette (1)

ACRS (10)

R. Hartfield OIE PPAS AEOD J. Thoma*

H. Ornstein E. Blackwood J. Gray J. Scinto, OELD E. Christenbury, OELD ASLB Licensee ORBf5 Service List (attached)

S. Varga D. Vassallo R. Clark J. Stolz C. Thomas R. Vollmer S. Hanauer Attorney, OELD E. L. Jordan

~ J. M. Taylor Regional Administrator Resident Inspector.

W.LJ. Dircks,.EDO (4)

R. Wessman*

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