ML20080Q954

Requests That Schedule for Upgrading Environ Qualification of Accident Monitoring Equipment,Per Reg Guide 1.97 & 10CFR50.49(g),be Extended to Sixth Refueling Outage,But No Later than 851130

ML20080Q954
Person / Time
Site:	Farley
Issue date:	02/22/1984
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8402270259
Download: ML20080Q954 (13)

Text

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. Memng Address.

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., North 18 h S re t Post Office Box 2641 Birmingham. Alabama 35291 1 Te?.pnone 205 783-6081 F. L Clayton, Jr.

Senior Vice President Flintridge Building AlabamaPower the southern electnc sprem February 22, 1984 Docket No. 50-348 Director, Nuclear Reactor Regulation U. S. Nucleer Regulatory Commission

. Washington,.D.C. 20555 Attention: Mr. S. A. Varga Joseph. M. Farley Nuclear Plant - Unit 1 10CFR50.49 - Environmental Qualification of Regulatory Guide 1.97 Equipment Gentlemen:

In letters dated May 20, August 24, and September 27, 1983, Alabama Power Company requested an extension to the schedule provided in

-10CFR50.49(g)[for monitoring equipment upgrading(Regulatorythe environmental Guide 1.97) for Unitsqualification 1 and 2 Theof)NRC accident granted ~an extension to March 31, 1985 for Unit 2 Regulatory Guide 1.97

(R.G. '1.97) equipment in a letter dated October 21, 1983. For Unit 1, the NRC requested that Alabama Power Company make every effort "to complete the qualifications within the goals established and approved by the Commission.

L If, in spite of your best efforts, specific deficiencies for Unit 1 will

' remain beyond April 1984, an extension can be requested." Alabama Power

- Company has expended significant resources and efforts, as described herein,

, to improve the Unit 1 degree of compliance with the 10CFR50.49(g) schedule.

( In spite of this improvement, certain equipment qualification will exceed

.the April 1984 date. Alabama Power Company, therefore, submits a revised request to extetid the schedule of.10CFR50.49(g) for specific R.G.1.97

-accident mcnitoring equipment for Farley Nuclear Plant - Unit 1.

Effective February 22,1983,10CFR50.49 establishes a goal for final 4_

environmental qualification of electrical equipment within the scope of the

,. rule "by the end of the second refueling outage after March'31,1982." The

!- Unit 1 fifth refueling outage is the second refueling outage after March 31, i1982; this outage commenced on February 10, 1984 and is scheduled to end l

-during April 1984. Attachment 1 presents the current schedule for refueling outages at Farley Nuclear Plant - Unit 1.

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. . February 22, 1984 U. ' S. Nuclear . Regulatory Connission Page 2

. Alabama Power Company stated in a letter dated November 16, 1981 that efforts to respond to R.G.1.97 [ presently addressed by 10CFR50.49 (b)(3)],

safety parameter display system, emergency operating procedures, emergency response facilities and control room design review would not commence until the NRC -finalized all applicable regulatory criteria. Finalized NRC regulatory criteria associated with emergency response capabilities was provided in Supplement 1 to NUREG-0737- dated December 17, 1982. In response to Supplement 1 to NUREG-0737, Alabama Power Company made specific commitments related to R.G.1.97 ircluding completion dates for modifications in letter dated April 15, 1983.

From the April 15, 1983 commitment date of NUREG-0737, Supplement 1, 10CFR50.49(g) allowed only ten months to evaluate the appropriate Farley Nuclear Plant Unit 1 instrumentation against the provisions of R.G.1.97 and to complete design, procure equipment, finalize design change packages and perform modifications. ,

In order to be responsive to the schedule of 10CFR50.49(g), Alabama Power Company evaluated each piece of electrical equipment requiring environmental qualification to determine the maximum feasible outage scope.

This . determination was made based on the premise that environmental qualification modifications of all R.G.1.97 instruments must be completed by the Unit 1 fifth refueling outage. The maximum feasible outage scope was

~ based on. developing engineering evaluations and conceptual design,.

identifying potential vendors and procurement lead times, reviewing

.q ualification test reports, and finalizing detailed design. These

. activities have lead to the preparation of six implementation packages for feasible modifications addressing numerous R.G.1.97 components during the Unit 1 fifth refueling-outage. -These items are identified in Attachment 2.

It should be recognized that the R.G.1.97 outage activities identified in Attachment 2 are not considered within the schedule of 10CFR50.49 and the requested extention to 10CFR50.49 -is not dependent on their completion. If 4 circinstances beyond the control of Alabama Power Company occur to prevent

.the completion of these outage activities during the Unit 1 fifth refueling outage,-then these outage activities will be completed in accordance with

-R.G. -1.97.. implementation schedule submitted in response to NUREG-0737, Supplement 1. The criteria to determine those outage activities addressed by;the schedule of-10CFR50.'49(g) was developed subsequent to the determination of the maximum feasible equipment qualification work for the Unit 1 fifth refueling outage.

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Alabama Power Company, in. consultation with the INP0 NUTAC on Emergency Response Capabilities and the NRC' Staff, determined that 10CFR50.49(g) does not necessaylly re, quire alF environmental qualification modifications to R.G.1.97. instruir.ents be completed by the Unit 1 fifth refueling outage.

~ Based on this guidance, Alabama' Power Company developed criteria to clarify thequalification requirements, schedule priorities and scope of instruments addressed; by 10CFR50.49(b)(3). These criteria ' allowed Al abama Power Company

Mr. S. A. Varga February 22, 1984 U. S. Nuclear Regulatory -Comission Page 3

- to plan, to the extent possible, a single coordinated modification concept

ad('ressing all twelve R.G.1.97 provisions for each instrument, rather than performing a series of potential modifications addressing only individual R.Gml.97 provisions (e.g. environmental qualification). These criteria, presented in Attachment 3, are consistent with 10CFR50.49 and were discussed

-with the NRC Staff during a meeting on January 11, 1984 in Bethesda, Maryland. It is Alabama Power Company's understanding that these criteria are t ceptable to the Staff.

' As a result of this revision to the R.G.1.97 implementation schedule, the specific equipnient qualification activities required to be completed for compliance with the schedule of 10CFR50.49(g) were identified. This equipment qualification activities list is provided in Attachment 4. It is emphasized that the qualification activities list of Attachment.4 could not have been completed during the present Unit i fifth refueling outage due to their design duration and procurement lead-times even considering that the clarifying criteria.of Attachment 3 were available.

Consequently, Alabama Power Company requests, pursuant to 10CFR50.49(g), that the schedule to upgrade the environmental qualification of accident monitoring equipment items identified in Attachment 4 be extended to the Unit i sixth refueling outage, but no later than November

!- 30, 1985.

It is 10CFR50.49(proposed g) be provided thatby thisApril requested 12, 1984, extension This proposed to the schedule date is of approximately two weeks prior to return to power from the Unit l' fifth

, refueling outage, which is the date for compliance to 10CFR50.49. Granting this requested extension by April 12, 1984 would prevent unnecessary loss of power generation from the extended outage required to design, procure and install equipment necessary for compliance with 10CFR50.49.

If there are any questions, please advise.

Yours very truly,

' F. L. ClaytonF Jr.

FLCJr/ MAL:1sh-D1 Attachments cc: Mr.-R. A. Thomas Mr. G. F. Trowbridge Mr. _J. P. ' 0'Reilly Mr. E.'A. Reeves

. Mr. W. H. Bradford .

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Attachment 1 Current Refueling Outage Schedule for Farley Nuc1 ear P1 ant - Unit 1 01-84 01-85

-10CFR50.49 '

effective R.G. 1.97 date Supplement- 1 Unit 1 Compliance Unit-1 01-83 02-22-83 03-83 Schedule 5th Refueling Report 6th Refueling i i 1 1 I I I I I Unit'l 4th I I '

Note 1 Note 2 Refueling Outage 04-15-83 02-84 05-84 06-84 04-85 05-85 4

Note 1: The Unit 1 fifth refueling outage is the second refueling outage after March 31, 1982.

Note 2: Completion of R.G.1.97 equipment upgrade within 10CFR50.49.

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Attachment 2 R.G. 1.97 Equipment Scheduled to be Qualified During the Unit 1 Fifth Refueling Outage It should be recognized that the R.G.1.97 outage activities identified below are not considered within the schedule of 10CFR50.49 and the requested extention to 10CFR50.49 is not dependent on their completion. If circumstances beyond the control of Alabama Power Company occur to prevent the completion of these outage activities during the Unit 1 fifth refueling outage, then these activities will be completed in accordance with R.G.1.97 implementation schedule submitted in response to NUREG-0737, Supplement 1.

A. Post-Accident Sampling System to Determine Activity Level of Reactor Coolant Outage Plant ID No. Generic Name Manufacturer Model Activity Q1P15SV3333 Solenoid Valve ASCO NP8320A184E Replace 3765 Solenoid Valve ASCO NP8320A184E Replace 3101 Solenoid Valve ASCO NP8320A184E Replace 3102 Solenoid Valve ASCO NP8320A184E Replace Q1P15ZS3333 Limit Switch NAMCO EA-170 Replace 3101 Limit Switch NAMC0 EA-170 Replace 3102 Limit Switch NAMC0 EA-170 Replace B. Containment Isolation Valve Position Indication Outage Plant ID No. Generic Name Manufacturer Model Activity NIE21ZS8961 Limit Switch NAMC0 EA-170 Replace 8880 Limit Switch NAMC0 EA-170 Replace N1831258033 Limit Switch NAMCO EA-170 Replace 8028 Limit Switch NAMCO EA-170 Replace N1G212S7136 Limit Switch NAMCO EA-170 Replace NIE21ZS8152 Limit Switch NAMC0 EA-170 Replace Q1P15ZS3331 Limit Switch NAMC0 EA-170 Replace 3332 Limit Switch NAMC0 EA-170 Replace 3333 Limit Switch NAMC0 EA-170 Rep 1 ace Q1P19ZS3611 Limit Switch NAMCO EA-170 Replace Q1E14ZS3657 Limit Switch NAMC0 EA-170 Replace 3658 Limit Switch NAMC0 EA-170 Replace Q1P13ZS3198D Limit Switch NAMC0 EA-170 Replace 3198A Limit Switch NAMC0 EA-170 Rep 1 ace Q1G212S3337 Limit Switch NAMCO EA-170 Replace Q1P17ZS3045 Limit Switch NAMC0 EA-170 Replace 3095 Limit Switch NAMCO EA-170 Replace 3067 Limit Switch NAMC0 EA-170 Rep 1 ace NIE21ZS8860 Limit Switch NAMC0 EA-170 Replace Q1P15ZS3334 Limit Switch NAMC0 EA-170 Rep 1 ace N1G21ZS7150 Limit Switch NAMC0 EA-170 Replace Q1G21ZS3380 Limit Switch NAMC0 EA-170 Replace Q1P112S3659 Limit Switch NAMC0 EA-170 Replace

~ Attachment 2 R.G.1.97 Equipment Scheduled to be Qualified During the Unit 1 Fifth Refueling Outage Page 2 B. Containment Isolation Valve Position Indication (continued)

Outage

. Plant ID No. Generic Name Manufacturer Model Activity F Q1E11MOV8701A Motor Operator Limitorque N/A Acquire.

Test" Data 8701B Motor Operator Limitorque N/A 8702B Motor Operator Limitorque N/A Q1P16MOV3019A Motor Operator Limitorque N/A 30198 Motor. Operator Limitorque N/A "

3019C . Motor Operator Limitorque N/A ,

3019D Motor Operator Limitorque N/A "

3023A Motor. 0perator Limitorque N/A 30238 Motor Operator Limitorque N/A 3023C -Motor.0perator Limitorque N/A 3023D . Motor Operator _ Limitorque N/A

- Q1P17M0V3052 Motor Operator. Limitorque N/A 3182 Motor Operator Limitorque N/A Q1P23M0V3238 Motor Operator Limitorque N/A 3239 Motor Operator Limitorque N/A Q1E21M0V8886 Motor Operator Limitorque N/A Q1P16MOV3134 Motor Operator Limitorque N/A 3135 Motor. Operator Limitorque N/A Q1E23M0V3739A Motor Operator Limitorque N/A 3739B . Motor Operator Limitorque N/A l

3745A Motor Operator Limitorque N/A l 3745B_ Motor Operator ~ Limitorque N/A

[ Q1E23M0V3740 Motor Operator Limitorque N/A F ' Q1E15M0V3361A Motor Operator Limitorque N/A l 3361B Motor 0perator Limitorque N/A 3362A Motor' Operator Limitorque N/A 13362B . Motor Operator Limitorque N/A Q1E21MOV8100' Motor Operator Limitorque N/A Delete Auxiliary Relay Modification Q1013SV3196 "

3197 Delete Auxiliary Relay l N1P13SV31988 Delete Auxiliary Relay "

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- Q1P13SV3198D Delete Auxiliary Relay "

Q1P15SV3103 Delete Auxiliary Relay Delete Auxiliary Relay "

. 3104 3765_ Delete Auxiliary Relay l_ 3766 Delete-Auxiliary Relay "

3331 Delete Auxiliary Relay 3332 Delete Auxiliary Relay "

3333 Delete Auxiliary Relay

. 3334 Delete Auxiliary Relay "

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Attachment 2 R.G.1.97 Equipment Scheduled to be

- Qualified During the Unit 1 Fifth Refueling Outage Page 3-B. Containment Isolation Valve Position Indication (continued)

. Outage Plant ID No. Generic Name Manufacturer Model Activity Q1E14SV3657 Delete Auxiliary Relay Modification 3658 Delete Auxiliary Relay Q1P17SV3045 Delete Auxiliary Relay "

3067 Delete Auxiliary Relay 3095 Delete Auxiliary Relay "

C. - Penetration Room Vent Damper Position Indication Outage Plant ID No. Generic Name Manufacturer Model Activity <

Q1E15MOV3361A Motor Operator Limitorque N/A Acquire Test Data 3361B Motor Operator Limitorque N/A 3362B Motor Operator Limitorque N/A Q1E15HV3356A Limit Switch NAMC0 EA-170 Replace q356B Limit Switch NAMC0 EA-170 Replace 3357A Limit Switch NAMC0 EA-170 Replace 3357B Limit Switch NAMC0 EA-170 Replace Q1V48HV3538A Limit Switch NAMC0 EA-170 Replace 3 38B Limit Switch NAMC0 EA-170 Replace

'D. Containment Atmosphere Temperature Indication Outage Plant ID No. Generic Name Manufacturer Model Activity N1T12TE3187E Temperature Element Conax N/A Replace 3187F Temperature Element Conax N/A Replace 3187G Temperature Element Conax N/A Replace 3187H- Temperature Element Conax N/A Replace E. Accumulator Pressure Outage Plant ID No. Generic Name Manufacturer Model Activity

'N1E21PT921 Transmitter Foxboro NE11GMIID2BF Replace 925 Transmitter Foxboro NE11GMIIO2BF Replace 929 -Transmitter Foxboro NE11GMIID2BF Replace

Attachment 2 R.G. -1.97 Equipment Scheduled to be Qualified During the Unit 1 Fifth Refueling Outage

- Page 4 F. Neutron Monitor (Scheduled for partial implementation only)

Outage Plant ID No. Generic Name Manufacturer Model Activity 5060B Cable Gamma-Metrics N/A Replace f

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j Attachment 3

- Criteria for Accident Monitoring Instrumentation Subject to Environmental Qualification

1. Schedular Criteria Alabama Power Company believes that a single coordinated modification is the intent of Supplement 1 to NUREG-0737 and 10CFR50.49. Alabama Power

' Company has therefore interpreted Supplement 1 to NUREG-0737 and 10CFR50.49 to mean that.an instrument channel would be subject to the schedule of 10CFR50.49(g) if the instrument channel satisfies all R. G.

1.97 criteria except for environmental qualification. An instrument

channel that does not satisfy one or more provisions of Regulatory Guide 1.97, other than environmental qualification, would be subject to the schedule submitted in response to Supplement 1 to NUREG-0737 for completing R.G.1.97 modifications. As an example, if an instrument

. channel is not environmentally and seismically qualified in accordance i

with R.G.1.97, then modifications to these instrument channels would be -

-implemented in accordance with the R.G.1.97 schedule of Supplement 1 to NUREG-0737. If an instrument channel satisfied all provisions of Regulatory Guide' 1.97 except environmental qualification, then qualification of the instrument channel would be subject to the schedule

. of 10CFR50.49(g).

2. .Qualification Criteria .

. Alabama Power Company interprets the phrase of 10CFR50.49(k), "are not p required to requalify electrical equipment important to safety in accordance with the provisions of this section [10CFR50.49] if the Commission has previously required ~ qualification of that equipment", to

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j. be a reference to the intended use of equipment. The intended use of equipment considered by Alabama Power Company to be within the scope of f- NUREG-0588 'and the D0R Guidelines is to monitor and/or mitigate an l accident. The minimum accident l monitoring instrumentation exposed to a harsh environment.was included in Alabama Power Company's submittal to NUREG-0588 and the D0R Guidelines.

Subsequent to these submittals,10CFR50.49(b)(3) required that "certain l post-accident monitoring equipment" (i.e., R.G.1.97 equipment) be qualified. This provision significantly increased the scope of Alabama Power Company's accident monitoring equipment previously identified in NUREG-0588 and D0R Guidelines submittals. Alabama Power Company, therefore . interprets the provision of 10CFR50.49(k) to permit qualification of the expanded scope equipment to the NUREG-0588 and 00R-Guidelines if such instrumentation is presently installed and has been or can be shown to meet those provisions. Otherwise, qualification of equipment to be~ installed to satisfy R.G.1.97 will be subject to 10CFR50.49 provisions.

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l Attachment 3 Criteria for Accident Monitoring Instrumentation Subject to Environmental Qualification Page 2

3. Criteria for Scope of 10CFR50.49(b)(3)

Alabama Power Company has interpreted the scope of 10CFR50.49(b)(3) to be those equipment items:

(a) defined as Category 1 and 2 instruments in Alabama Power Company's R.G.1.97 Compliance Report, and (b) not addressed by 10CFR50.49(b)(1) and (b)(2), and (c) located in a harsh environment.

Attachment 4 Accident Monitoring Equipment For Which an Extension to the Schedule of 10CFR50.49 is Requested Identified below are manufacturer and model numbers for presently installed equipment that is located in a harsh environment and for which environmental qualification documents have not been located. These components are scheduled to be replaced with qualified components during the Unit 1 sixth refueling outage.

A. Containment Spray Flow Plant ID No. Generic Name Manufacturer Model Location N2E13FT0958A Transmitter Foxboro E13DMISAH2 Auxiliary Building El-100' N2E13FT0958B Transmitter Foxboro E13DMISAH2 Auxiliary Building El. 100 B. Charging Line Flow Plant ID No. Generic Name Manufacturer Model Location N2E21FT0122 Transmitter Foxboro E13DHISAH2 Auxiliary Building El. 100 C. Letdown Flow Plant ID No. Generic Name Manufacturer Model Location Q2E21FT0150 Transmitter Foxboro E13DMISAH2 Auxiliary Building El. 100' D. Volume Control Tank Level Plant ID No. Generic Name Manufacturer Model Location Q2E1LT0115 Transmitter Barton 396 Auxiliary Building El. 121

Attachment 4

- Accident Monitoring Equipment for Which an Extension to the Schedule of 10CFR50.49 is Requested Page 2 E. -Reactor Coolant Pump Seal Injection Flow I Plant ID No. Generic Name Manufacturer Model Location N2E21FT0124~ . Transmitter Foxboro E13DHISAM2 Auxiliary Bldg.

El. 121' 127 Transmitter Foxboro E13DHISAM2 Auxiliary Bldg.

El. 121' 130 Transmitter Foxoboro E13DH1 SAM 2 Auxiliary Bldg.

El. 121' N2E21FIO124B Local Indicator To be- To be Auxiliary Bldg.

Determined Determined El. 121' 127B Local Indicator To be To be ' Auxiliary Bldg.

Determined Determined El. 121' 130B Local Indicator To be To be Auxiliary Bldg.

Determined Determined El. 121' F. Containment High Range Radiation Monitor-4 Plant ID No. Generic Name Manufacturer Model Location 2VAIS011F. Cable Belden 8263 Auxiliary Building k El. 139 2VAIS011H Cable Belden~ 8263 Auxiliary Building-

-El. 139 Discussion: As part of the R.G.1.97 Compliance Report preparation, Alabama Power Company has performed an evaluation of the areas Jin which these components are located and has determined that these areas would be exposed to a radiation dose from post-accident recirculating fluids. While all other components of the instruments have been determined to be either environmentally qualified or not located in an area of potential harsh environment, it has been determined that no test data is available for the above components.

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Attachment 4 Accident Monitoring Equipment for Which an Extension to the Schedule of 10CFR50.49 is Requested Page 3 Since the completion of this evaluation, Alabama Power Company has developed conceptual ~ designs to upgrade the environmental qualification of these components and Identified potential vendors and procurement lead times.

The resulting design and procurement, based on this evaluation, cannot be completed within the schedule of 10CFR50.49 for Unit 1.

The modifications to these instruments can only be completed U during scheduled refueling outages since this instrumentation is needed for power operation except for containment spray flow and the containment high range radiation monitors. The containment spray flow instruments are used in a system that is needed to satisfy the Technical Specifications and to perform safety related functions. The containment high range radiation monitors form a portion of a system that is needed to satisfy the Technical Specifications. These modifications are currently scheduled to be implemented during the Unit 1 sixth refueling outage.

Justification: Alabama Power Company emphasizes that this extension request applies only to certain post-accident monitoring equipment of 10CFR50.49(b)(3). During the time necessary to upgrade the qualification of equipment addressed by this extension request, the safe operation of Farley Nuclear Plant will not be compromised. - In letter dated May 20, 1983, Alabama Power Company indicated that equipment within 10CFR50.49, Section (b)(1), safety-related equipment relied upon to remain functional during and following design basis events, and Section (b)(2), nonsafety-related equipment whose failure could prevent satisfactory accomplishment of safety functions, have been previously qualified to the provisions of the D0R Guidelines. Additionally, as stated in letter dated April 15, 1983, Alabama Power Company interprets the provisions of Supplement 1 to NUREG-0737 to enhance the present emergency response capabilities and not to provide the sole safety function. Currently, the Farley Nuclear P1 ant computer and main control board are being utilized to monitor parameters necessary for normal and emergency conditions.

Extension The end of the Unit i sixth refueling outage but no later Request: than November 30, 1985.