ML20039F087
| ML20039F087 | |
| Person / Time | |
|---|---|
| Site: | 05000561 |
| Issue date: | 07/05/1977 |
| From: | Taylor J BABCOCK & WILCOX CO. |
| To: | Cox T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111090060 | List:
|
| References | |
| FOIA-80-515, FOIA-80-555, RTR-REGGD-01.089, RTR-REGGD-1.089 NUDOCS 8201110839 | |
| Download: ML20039F087 (11) | |
Text
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adr. Roger S. Boyd FROM: Babcock & Wilcox CAra cP cccuutNT 08/31/77 Lynchburg, Va.
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JUL 91977 ~ 8' Mr. Thomas R. Cox Light Water Reactors Branch 93 5
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Dear Mr. Cox:
In the review of B-SAR-205, some NRC questions have involved the qualification methodology for safety-related Control and Instrumer;tation (C6I) equipment.
The purpose of this letter is to inform you of the status of the B6W C6I qualification program in order to clarify the B-SAR-205 commitment with respect tc Regulatory Guide 1.89 (" Qualification of Class 1E Equipment for Nuclear Power Plants").
In early 1976, B6W completed the submittal of a 3-part Topical Report (BAW-10082) to define its CSI qualification program.
NRC evaluation letters on this Report were issued in December of 1975 and July of 1970.
Since that time, B6W has been working to complete a revised report which would document the B6W qualification program to address Regulatory Guide 1.89 and the NRC concerns expressed in the evaluation letters.
Our current schedule is to have this revision available for NRC review in the fourth quarter of this year.
We believe that the NRC evaluation comments will be addressed in a manner satis-factory to the NRC Staff.
To facilitate the Staff evaluation of B-SAR-205 on the issue of safety-related C6I equipment qualification, we are providing a brief response to each of your evaluation comments on Parts 2 and 3 of BAW-10082 in the attached enclosure.
Our purpose is to show that the revised BAW-10082, when submitted, should be acceptable for PDA and CP licensing needs.
Specifi-cally for B-SAR-205, we believe that you have sufficient information in hand (or committed for fourth-quarter 1977) to judge that the documentation of our C6I equipment qualifi-cation program will be acceptable, j
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N&Wilcox Mr. Thomas R. Cox Page 2 July 1, 1977 Should there be any questions on this matter, please-contact Mr. C. S. Banwarth of my staff.
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James H. Taylor /
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NRC EVALUATION COMMENTS AND B6W RESPONSES ON PART 2 OF BAW-10082 1.
Acceptance criteria and methods for combining the results of separate qualification tests are not included in the Test Sequence Equipment Aging Section of the report but will be documented in Part 3 of BAW-10082.
This approach to documenting how B6W intends to comply with IEEE Std 323-1974 has resulted in a segmented document that does not stand by itself.
RESPONSE
The revision to BAW-10082 will be provided in one document which will cover the complete qualification program for B6W C6I equipment.
The contents of this report are currently planned to include:
List of equipments (type, function, location)
Seismic qualification methods Normal-and accident-environment qualification methods (e.g., power supply, temperature, RFI/EMI, pressure, humidity, chemical spray, radiation),
including margin Preliminary accident, seismic, and test profiles Life-qualification methods Test sequence Combination of individual qualification program results Use of qualification program results to validate Safety Analysis assumptions Interface criteria 2.
Because this document has been referenced ~in other topical reports and applications, it is assumed that the subject report is to represent a generic qualification of CSI equipment in B6W's scope of supply.
It is not clear how this can be accomplished when the subject report references the prospective applicant's SAR for such basic information as location, environment definition, required cperating times, and definitions of test margins.
For the subject report to be generic in nature, this information will have to be included in the body of the report.
RESPONSE
BAW-10082 is a generic report, intended for numerous appli-cants, and thus locations or environments of CGI equipment will not be exactly specified.
The revised report will indicate general equipment location (e.g., "inside contain-l ment," " main control room") which have boundaries effectively i
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delineated by their typical environment.
For example, if a module is qualified to operate under conditions of atmospheric pressure, 10-80% humidity, and 40-110*F, it is qualified for locations enveloped by these values (such as the control room).
The substantive facts are the environmental parameter ranges and the interface requirements which evolve; the o
" location" is given primarily for convenience to the user to indicate the expected application location.
Appropriate interface responsibilities will be identified in BAW-10082.
Required operating times and test margin factors, to the i
extent required by the Standard Review Plans for Construc-4 tion Permit applications, will be provided in the revised topical report.
3.
In Section 3.0, " Normal and Accident Conditions", it is proposed the adjustment or recalibration of devices be allowed when the devices have been subjected to " Worst-Case Conditions", and are going to be restored to normal operation when the device is returned to the reference operating conditions.
This procedure is not acceptable for any Class 1E equipment that is required to operate during and after the accident period.
This procedure must be revised accordingly.
RESPONSE
Certain accidents (e.g., LOCA) produce environments which may lead to instrumentation errors greater than those predicted under " normal conditions".
The B6W Safety Analyses account for these " worst-case" errors during and after the accident.
The accidents which produce " worst-case conditions" are those which will result in a plant shutdown, cooldown, and repair.
Due to the extreme environmental conditions, some error types (e.g.,
zero shif t) may be retained by the instrument.
Therefore, during the plant repair period following such accidents, any instrumentation subjected to the accident environment will be checked and adjusted as necessary to remove any error influences retained from the harsh environ-ment in order to assure that " normal condition" error predictions are still valid.
4.
In Section 6.4.1.3, the method for determining the midpoint of the plateau (which is used for setting the high voltage),
should be established.
RESPONSE :
The source-range neutron detectors are not part of a safety-related system.
The re fore, the revision to BAW-10082 will delete mention of the source-range proportional counter. _
5.
In Section 6.4.2.2, Temperature Element, there is no mention of whether the TE's have to be operable during or after the worst case conditions.
If the TE's are required to be operable during and after the accident an operability test should be included that demonstrat
- his.
A RESPONSE :
The qualification program for RPS, ESFAS, and SRCI temperature elements will demonstrate operability under appropriate worst-case conditions and for the required period of operability.
BAW-10082 will describe tests which demonstrate operability of the element under normal conditions and the extremes of accident conditions.
6.
Figure 2, " Typical Pressure / Temperature V.S. Time Profile (For Worst Case Containment Conditions) is not representative of the simulated service condition test profile documented as Figure 1 in IEEE Std 323-1974 and is therefore unacceptable without additional justification.
RESPONSE
Safety-related I6C equipment required to function under worst-case containment conditions will be subjected to two pressure / temperature transients to meet section 6.3.1.5(7) of IEEE 323-74.
Thus, the Simulated Service Condition Test Profiles (to be documented in.the revision to BAW-10082) will be similar to Figure 1 of IEEE 323-74.
NRC EVALUATION COMMILNTS, WITH B6W RESPONSES, ON PART 3 0F BAW-10082 1.
It is the staff's understanding that the subject report is generic in nature and is already referenced in the SAR's of Pebble Springs, Greene County, WNP 1 and 4, and B-SAR-205.
Since this is the case, all the information outlined in Section 6.0 of IEEE Std 323-1974 must be provided.
This is the same basic problem encountered and commented on during our review of Part 2 of this report.
Until this information is included in the subject report, it is not clear how an acceptable qualification test plan for B4W Class IE equipment can be documented for use in a generic manner.
RFSPONSE:
The revision to BAW-10082 will respond to each part of Section 6.0 of IEEE 323-1974.
(See also the response to first comment on Part 2.)
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General Comments 1
a.
It was the staff's impression from reviewing Part 2 of this report that one of the primary objectives of the report was to demonstrate that the acceptance criteria of IEEE Std 323-1974 was met.
In Part 3 of this report the scope has been expanded to include equipment to be l
qualified that is " Pre-Regulatory Guide 1.8S", and therefore pre-IEEE Std 3.23-1974.
If generic qualifica-tion is the objective of this report,it is recommended, for the purpose of clarity, that equipments in the " Pre-Regulatory Guide 1.89" category be handled by a separate topical or the plant applicability, and by definition, the generic applicability of this topical redefined.
b.
It is recommended that the environment qualification information presently documented in Parts 2 and 3 of this report be combined into one document, with the information discussed in item 1 above incorporated in it.
(IEEE Std 323-1974, Section 6.0 - requirements)
RNSPONSE:
2a. The revision to BAW-10082 will address only those equipments which will be generically qualified to Regulatory Guide 1.89, and therefore IEEE Std 323-1974.
2b. The revision to BAW-10082 will be a one-piece, combined report presenting the B6W CGI seismic and environmental qualification program for compliance with Regulatory Guide 1.89.
3.
In conjunction with item 1 above and item 6 of the Regulatory Evaluation of Part 2, the " worst-case generic" environmental factors mentioned in Appendix A of Part 3 of this report must be defined and quantitative values documented in this report.
RESPONSE
The " worst-case generic" factors mentioned in Appendix A of Part 3 (chemical, radiation, temperature, pressure, humidity-environment and power quality) will be quantitatively defined in the revision to BAW-10082.
The values will be generic (with margin) to envelope all plants for which BAW-10082 is applicable.
However, since final design parameters need not be firmly established until FSAR stage, these factors will be preliminary..
j 4.
Qualification of Class IE equipment to ensure operability when subjected to long-term in situ vibration as outlined in IEEE Std 323-1974 has not been addressed in this report.
It is the staff's position that this environmental factor be incorporated into the equipment qualification program as outlined in IEEE Std 323-1974 or the justification be provided for not demonstrating the capability of the Class IE equipment to satisfactorily withstand long-term vibration.
RESPONSE
The revision to BAW-10082 will address long-term in-situ vibration.
The majority of the CSI equipment will not be located or positioned where it will experience any long-term vibration, and the qualification interface requirements will incorporate appropriate mounting restrictions.
Those C6I equipments which will be allowed to be subjected to in-situ, long-term vibration will have this environmental factor considered in the equipment's qualification program.
5.
Section 2.1 references Figure 3 for the qualification test sequence.
It is noted that in this figure, and the other figures attached to Part 3 of this report, the temperature, pressure, humidity, and chemical environmental factors have not been quantified.
These values must be established as outlined in IEEE Std 323-1974.
RESPONSE
Standard Review Plans 3.10 and 3.11 provide that specific accident and test factors of temperature, pressure, humidity, radiation, and chemical spray need not be established until submittal of an FSAR.
BAW-10082 will define the intended magnitude of margin for each factor, and will provide pre-dicted accident profiles as well as currently planned test profiles.
Preliminary quantified values will be provided, but final test values cannot be established until a test laboratory is contracted and the test facility capabilities are firmly known.
Some uncertainty is also present because design and accident conditions have not been finali ed; for example, calculations predicting the effects of steam line break environments are still being reviewed.
6.
Define and justify the bases for not performing worst-case accident and post-accident qualification tests on equipments located outside the containment.
(Reference Section 2.1, page 3)
RESPONSE :
This statement from section 2.1 was to indicate that equipment outside containment would not be qualified to the worst-case and post-accident containment environments.
This equipment outside containment will be qualified to worst-case and post-accident environments predicted for the local environment in which the equipment is intended to be located...
7.
In Section 2.1 and 4.0, it is stated that equipments in controlled environments need not be subjected to the equipment aging portion of the qualification testing sequence, but that the significance of aging effects in mild environments still has to be determined.
Since aging effects for B6W equipment located in mild environments has not been determined, provide the justification for " waiving" the aging of this equipment.
In addition, provide an expanded discussion which supports the conclusion, in Section 4.0, that there should not be a common mode failure due to aging for equipment located outside the reactor building in a controlled environment.
RESPONSE
The revision to BAW-10082 will provide an expanded discussion for aging-qualification of equipment located outside contain-ment.
In summary, it will be shown that this equipment will only be subjected to one type of stress which has the potential of influencing redundant equipments - i.e., a seismic event -
and that the ex-containment equipment aging program will appropriately account for it.
8.
In Section 2.2, page 5, it is stated that " type test levels are increased by some margin if required by the general guidelines of IEEE Std 323-1974, Saction 6.3.1.5."
This section of IEEE Std 323-1974 specifically requires testing to verify that adequate margin exists.
Define what is meant by, "if required," identify and justify any exceptions to the margin requirement, and quantify all margins used.
RESPONSE
All type-test levels will include some margin, to conform to the guidelines of IEEE 323-1974.
The revision to BAW-10082 will include (preliminary) quantified margins for all type tests.
9.
In Section 3.0, " Methods for Combining Test Results", the philosophy described for combining errors due to environmental effects on individual devices and for combining errors on instrument strings is not based on equipment performance specifications.
It is not clear how a particular method for error combination can be selected based on environmental ~
or operational effects alone.
The staff cannot evaluate these error combination methods until the Equipment Performance Specifications are established.
When that is done, the acceptability of the error combination methods can be established because the device, instrument string and system accuracy requirements will have been defined, and the other factors (such as environmental) affecting this accuracy will be defined.
RESPONSE
A qualification-test error combination method based on environmental and operational effects will be justified for i
CSI equipment, considering the intended function.
The resultant error will be shown to be less than that required by product i
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specificaticas.
In turn, the requirements of the product specification will be compared to Safety Analysis assumptions to demonstrate that equipment will be manufactured to design requirements which assure that Safety Analysis assumptions regarding instrumentation imprecision will not be exceeded.
10.
Section 4.0 (page 14) stated that aging effects for equipments outside containment will be considered through analysis and that advanced life conditioning during type testing is not considered necessary for equipments subject to periodic testing and maintenance in accessible locations or in controlled environments.
The staff requires that aging be included in the qualifica-tion program for equipment outside the containment.
There-fore, modify the topical report to include this requirement or provide a detailed description of the periodic test requirements and procedures to detect any degradation due to environmental factors or failures of equipment. Also include an interface requirement in the topical report that will ensure that the proper systems are provided to maintain a controlled environment where required.
RESPONSE
The revision to BAW-10082 will detail the aging consideration for ex-containment equipment included in the CGI qualification program.
The revision will also include a definition of the interface responsibilities incumbent upon the user of the equipment.
11.
Section 4.0 (page 15) states that until appropriate aging methods are developed, B4W will continue to " burn-in" modules and/or critical components to significantly decrease infant mortality.
Clarify whether or not this is the only pre-aging performed on equipment to be installed insido containment.
RESPONSE
" Burn-in" of modules will not be the only aging procedure for in-containment equipment.
Details of the CSI aging program will be provided in the revision to BAW-10082.
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