ML20052F126

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Ro:On 760521,discrepancies Found in Seismic Certifications for Equipment,Instruments & Components & in Application of Certain Components Required to Meet Seismic Conditions. Caused by Misinterpretation of FSAR Requirements
ML20052F126
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 06/14/1976
From: Hillyard H, Swart F, Warembourg D
SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML19308A354 List:
References
FOIA-82-149 50-267-76-04, 50-267-76-4, NUDOCS 8205120139
Download: ML20052F126 (6)


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REPORT DATE: _ Jung_14. 1976 UUUSUAL EVENT 76/04 Page 1 of 5 '

OCCURRENCE DATE: (Determined) May 21, 1976 ..

FORT ST. VRAIN NUCLEAR GENERATING STATION PUBLIC SERVICE COMPANY OF COLORADO fv i A

j P. O. BOX 361 PLATTEVILLE, COLORADO 80651 REPORT No. 50-267/76/04 Final IDENTIFICATION OF

. OCCURRENCE:

Several discrepancies were found in the seismic certifications for equipment, instruments and components, and in the application of certain components re-quired to meet seismic conditions. This is identified as an unusual event per Section 7.6, Non-Routine Reports, Part C, Paragraph 3 of the Fort St. Vrain Technical Specifications.

CONDITIONS PRIOR TO OCCURRENCE:

This section is not applicable for this event.

DESCRIPTION OF OCCURRENCE:

The fundamental seismic criteria for the Fort St. Vrain plant is that Class I structures, systems and components shall be designed for the specified opera-ting basis earthquake and the safe shutdown earthquake. Further, these " Class I structures, systems and components include those items whose failure or damage could result in release of abnormal quantities of radioactivity, in interference with safe reactor shutdown, or in interference with adequate removal of decay heat".

In the process of purchasing spare and replacement parts the original require- I ments ecre reviewed to assure compliance with all applicable codes, st andard s and specifications. It was discovered in this review process that some Class I items did not have appropriate seismic certifications. These items were mainly in the category of interposing instrumentation and consisted of items such as relays, pressure switches, temperature switches, etc. In addition, items involving valves, valve operators and miscellaneous electric panels were also identified as_ potential problem areas based on the seismic data availabic.

The prime contractor, General Atomic Company (CAC), was requested to investi-gate the seismic certification documentation for Fort St. Vrain and to advise Public Service Company of Colorado of the results.

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  • l l UNUSUAL EVENT 76/04 Page 2 of 5 DESCRIPTION OF OCCURRENCE (continued):

Shortly after that. time, the cable separation and segregation problems were identified. As a part of the cable rework program, all essential equipment

, in the plant was reviewed and a new list of safety related equipment was develope? The new list was much more detailed and contained more equipment and compt..ents than originally required and defined in the Final Safety Analysis Report.

As a result of the problems originally identified and the possible require-ment for additional certification for items in the new safety related list, a complete review was made of the seismic documentation and the application of components to meet seismic conditions. In general, this review resulted in the following findings by category:

1) Interposing instrumentation and controls (i.e., relays, miscellaneous, switches or circuit components) that were not tagged equipment items and were not shown on P & I diagrams were generally not included in the seismic certification program. It was the original intent that such instrumentation was qualified because of the nature of its application (see Section 14.1.1.2 of the Final Safety Analysis Re-port) and as such, seismic documentation was not obtained.
2) Contrary to the requirements set forth by Section 14.1.1.2 of the Final Safety Analysis Report it was discovered that mercury switches had been used in thirty (30) different safety related applications.

These switches did not meet the seismic criteria set forth.

3) Several components were qualified by similarity without appropriate justification. Examples of this type of problem were the speed modules, SM-2109, SM-2110, SM-2115, SM-2116, and SM-21161 through SM-21172.
4) Several small valves, mainly safety relief valves, that were in a category requiring them to remain functional during the seismic event were qualified only by stress analysis and not on the basis of operability.
5) Several valve operators which had previously been considered as inter-posing instrumentation and controls under item 1 above were identified as having to function during the seismic event. These operators had been treated seismically on the basis of stress, but had not been appropriately analyzed and/or tested on the basis of operability.
6) Several items of equipment were not appropriately documented for seismic qualifications. Some of these equipment items were the re-sult of new items added to the plant by various plant modifications and some items were apparently overlooked in the or ginal effort to obtain seismic documentation. ,

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UNUSUAL EVENT 76/04 Page 3 of 5 DESCRIPTION OF

, OCCURRENCE (continued):

7) Several items of equipment, components, and instrumentation were added as a result of changes in philosophy and in the development of the new safety related list. These new items were not appro-

, priately documented for seismic qualification.

8) In addition to the seismic qualifications, the safe shutdown cooling equipment must also be environmentally qualified as set forth in the answer to Question 6.1, Amendment 25 of the Final Safety Analysis Report. As a result of the changes that have been made to the safety related list a potential problem of not having environmental qualifications for all safe shutdown cooling equipment has been iden-  ;

tified.

APPARENT CAUSE OF OCCURRENCE: Design Unusual Service Cond.

Including Environment Manufacture Component Failure Installation /Const. X Other (specify)

Operator See Analysis of Occurrence.

Procedure l ANALYSIS OF OCCURRENCE:

The following items are considered to be contributing factors leading to the problems outlined herein.

1) The original intent for the means in which interposing instrumenta-tion and controls were to be seismically qualified as set forth in the Final Safety Analysis Report were not clear. As a result'there were different interpretations of the requirements which were not recognized until specific problems were identified as outlined in this report.
2) Development of a new safety related list as a result of the essential cable rework program changed the original requirements with the addi-tion of new items that had not been previously identified in the various lists presented in the Final Safety Analysis Report for scismic and/or environmental qualification.
3) There was an apparent weakness in the program controlling plant changes and modifications in that seismic criteria for all changes was not consistently reviewed.
4) A sampling was made of seismic data as systems were turned over to Public Service Company for operation. Problems were identified and m _ _ __ _ _ _ _ _ _ _ _ . _ _ _

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UNUSUAL EVENT 76/04 Page 4 of 5

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ANALYSIS OF OCCURRENCE (continued):

corrected in this process based on the information available for Class I items at the time. Unfortunately, the information defining Class I items was not as detailed and complete as it should have been. Due to incomplete base information and a sampling process some item's werE app'arently overlooked in the original turn over.

CORRECTIVE ACTION:

The following items are keyed to the numbered paragraphs under Description of Occurrence.

1) Concerning the overall seismic certification program, a meeting was held with Nuclear Regulatory Commission Division of Licensing on May 24, 1976. The corrective action outlined in that meeting was that seismic qualification and the associated documentation for all Class I egri.pment, instruments, components, and structures other than those identified as interposing instrumentation'and con-trol was to be obtained prior to taking the reactor critical.

The seismic qualification and the associated documentation for the interposing instrumentation and control items is to be substantially complete prior to exceeding 40% power. In no event will there be any outstanding seismic qualification problems beyond the first refueling.

2) All of the mercury switches have been replaced by snapaction mercoid type switches acceptable for seismic conditions.
3) The speed modules were subsequently qualified by test. Other items that were identified as being qualified by similarity were reviewed for the acceptability of the seismic qualification. In some cases additional engineering evaluations were made.
4) A generic review was made for compact relief valves, and it was found that these valves will operate under the most adverse condi-tions imposed by our earthquake.
5) A review was made to identify all valve operators that required seismic qualifications. All valve operators that are required to function during a seismic event will be seismically qualified on an operational basis. Seismic documentation will be available on site for all such valve operators prior to taking the reactor critical.

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  • UNUSUAL EVENT 76/04 Page 5 of 5 CORRECTIVE ACTION (continued):
6) A review was made to identify all items of equipment for which appropriate seismic qualification and associated documentation was not availabic. Seismic qualification has been obtained or will be obtained prior to taking the reactor critical.
7) The change notice program will be reviewed and necessary changes to procedures will be made to insure that necessary consideration is given' to seismic and environmental criteria for Class I design changes and plant modifications.

Those items that represent additions added to the safety related

. list have been identified and seismic qualifications have been or will be obtained prior to taking the reactor critical.

8) The environmental qualifications at the present time meet the commitments set forth in the Final Safety Analysis Report in that all equipment and components listed in Table 6.1-1 have been environmentally qualified. For those items which have been added to the safety related list and may require environmental qualifications it is our intent to substantially complete the environmental qualifications prior to exceeding 40% power. Any items remaining open at 40% power will be subject to Nuclear Regu-latory review. All environmental qualification work will be com-plete prior to the startup after the first refueling.

FAILURE DATA /SIMILAR REPORTED OCCURRENCES:

None PROGRAMMATIC IMPACT:

Some slight delays may be experienced in bringing the reactor critical depending on the time required to complete the necessary actions outlined above.

CODE IMPACT:

None Submitted by: , M [A- ,,

Ii.' W.' 1111lya(4, Jr.

Technical Services Superv/ isor' Reviewed by: M

_D. W. Warembourg Director, Quality Assu.ance Approved by: j f o ,

,w_M FyedericE. Swart Superintendent, Nuclear Production

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