ML20082E901
| ML20082E901 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/15/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 82-07, 82-7, NUDOCS 8311280362 | |
| Download: ML20082E901 (1) | |
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Vice President - Projects, Engineering and Construction General offices: 1948 West Pernali Road, Jackson, MI 49201 e (517) 788-0453 November 15, 1983 82-07 #7 Mr J G Keppler, Regional Administrator j
US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 tilDLAND NUCLEAR PLANT -
DOCKET NOS 50-329 AND 50-330 i
Q-RELATED EQUIPMENT COOLED Bf NON-Q HVAC SYSTEM i
FILE:
0.4.9.63 SERIAL: 26600
References:
J W Cook letters to J G Keppler, same subject:
(1) Serial 17529, dated June 25, 1982 (2) Serial 17578, dated August 17, 1982 (3) Serial 19096, dated November 22, 1982 (4) Serial 20696, dated February 9, 1983 (5) Serial 22187, dated May 17, 1983 (6) Serial 23767, dated August 15, 1983 The referenced letters were interim 50.55(e) reports concerning Q-related equipment cooled by non-Q HVAC systems.
This is a final report.
Bechtel Project Engineering has completed all engineering studies required to identify corrective action. Remaining activity has been scheduled and will be performed as described in the attachment.
WRB/AHB/1r
Attachment:
MCAR-59, Final Report, date October 25, 1983 CC: Document Control Desk, NRC DHood, NRC Office of NRR Washington, DC Washington, DC RJCook, NRC Resident Inspector INPO Records Center Midland Nuclear Plant 3311280362 831115 PDR ADOCK 05000329 S
NOV 181983 OC1183-0020A-MP01 g
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Serial 26600 82-07 #7 OM/0L SERVICE LIST e
Mr Frank J Kelley Atomic Safety & Licensing
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Attorney. General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission 4H Ms-Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Division Mr 0 R Stephens (3) 720 Law Building Chief, Docketing & Services Lansing, MI 48913-U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq
-Suite 3700.
Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff Midland, MI 48643 U S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555
-Dr Frederick P Cowan Hs Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3
-Boca Raton, FL 33433 Freeland, MI 48623
.Mr Fred C Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Ave, NW,-Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr-James.E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, IL 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division
.Lynchburg, VA 24505 Midland, MI 48640 Mr Steve Gadler, Esq Ms Lynne Bernebei 2120 Carter Avenue Government Accountability Project St Paul,~MN 55108 1901 Q Street, NW 2
Washington, DC 20009
'OC1183-0020A-MP01
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Attachment to Serial 26600 82-07 #7 Bechtel Associates Professional Corporation I33372 i33187
SUBJECT:
MCAR 59 (issued May 28, 1982)
FINAL REPORT DATE:
October 25, 1983 PROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Description of Deficiency Review of Q-related structures of the plant has been completed and indicates that only portions of the auxiliary building and service water intake structure have safety-related devices that are cooled by non-Q heating, ventilating, and air-conditioning (HVAC) systems. Loss of these non-Q HVAC systems following various design basis accidents (DBAs) could result in room environmental temperatures that could
.4 exceed the specified design temperature of 104F. Under these conditions, the safety-related equipment in these rooms may not operate reliably, and both trains of redundant Q-listed equipment are affected by loss of the non-Q HVAC system in many instances.
Summary of Investiaation and Historical Backaround The initial review of project drawings identified a potential for 2,000 items of Q equipment in 101 areas of the auxiliary building that are cooled by non-Q HVAC systems. Subsequent detailed reviews have reduced this quantity to 1,718 items of Q equipment, of which 646 are Seismic Category I devices with no Class 1E components.
i The detailed reviews have also identified an area in the service water pump structure with 23 items of Class IE equipment cooled by non-Q HVAC systems.
This results in a total of 1,095 items of Class 1E equipment cooled by non-Q HVAC systems in 57 areas of the auxiliary and service water buildings.
The change in the number of Class IE devices since the last report is a result of detailed reviews that have 1) identified devices previously considered Class IE as Seismic Category I devices with no Class 1E components, 2) changed listed device locations to reflect as-built conditions, and 3) changed multiple identification numbers for complex package equipment to a single identification number.
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Bechtel Associates Professional Corporation NCAR 59 i33372 Final Report October 25, 1983 lb3l3/
Page 2 Analysis of Safety Implication The predicted steady-state maximum environmental room temperatures in the existing non-Q-cooled portions of the auxiliary building and service water intake structure, assuming a DBA simultaneous with an extended loss of the non-Q NVAC systems, has been determined. The final resulting temperatures are based on two accident conditiors as follows:
i Case 1 -
A loss-of-coolant accident (LOCA) in both reactor units concurrent with a loss of offsite power - All safety-related equipment has been assumed to be operating and generating heat as well as any de or diesel-backed ac nonsafety-related equipment. The auxiliary building and ssevice water intake structure non-Q NVAC system, as well l
as non-Q heat sources (except as noted above), are assumed to be inoperative, whereas four trains of the safeguards NVAC system are assumed to be available.
(See Note, Page 3.)
No credit is taken for the non-Q NVAC systems after the offsite power is restored. The effects of heat generated by electrical cables have been considered.
- Case 2 - A LOCA in both reactor units with offsite power evallable - A total loss of non-Q NVAC systems is assumed, whereas four trains of the safeguards NVAC system are assumed to be available. Because offsite power is available, nonessential equipment could be available and generating heat as well as any de or diesel-backed ac equipment (see Note). No credit is taken for the operation of non-Q NVAC systems. The effects of heat generated by electrical cables have not been considered because only l
Case 1 results are being used to determine the need for corrective action.
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- Case 2 is not a design condition and is being used for evaluation l
only.
(See Paragraph 2 of Corrective Action Item 1 on Page 6.)
Peak temperature calculations were revised to account for electric cable heat effects. The following is a summary of the results based on these revised calculations:
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. _ _ _. _ _. _ _ _...____ _ __ _ _ _ _,___ _ _ _ _ _ _.~ _
Bechtel Associates Professional Corporation NCAR 59 i
3I87 I33372 Final Report October 25, 1983 Page 3 Case 1 Case 2 Total number of non-Q-cooled areas analyzed 171(1) 171(1)
Total number of the 171 non-Q-cooled areas 55 55 containing class 1E devices in mild environments Total number of the 55 non-Q-cooled mild 34(4) 43(4) environment areas containing Class 1E devices with peak temperature 1104F Total number of the above non-Q-cooled mild 4
4 environment areas containing Class 1E devices with peak temperature of 1104F and to which Q cooling will be added Remainder of non-Q-cooled areas containing 29(2) 39(3)
Class 1E devices with peak temperature of 1104F and not presently planned to be Q cooled Note: Although this is not a desist basis for the plant, both units were assumed to be affected by a LOCA to simplify the analysis. This assumption is conservative. Assuming one unit in LOCA and one unit in hot shutdown, the major difference would be the pipeways, where heat loads would be lower during hot shutdown because fewer engineered safety feature's (ESP) piping systems wsuld be operating.
l (1)
This number decreased for 173 to 171 because four areas (Rooms 130, 131, 328, and 329) were combined into two areas due to open floor grating between these rooms at two elevations.
(2)
Of these 29 areas, the peak temperatures are broken down as follows:
a) 104F < 14 areas s 110F l
b) 110F < 7 areas 1 120F c) 120F < 6 areas 1 130F 0193u
Bechtel Associates Professional Corporation E15. port i33187 l33372 October 25, 1983 Page 4 d) 130F < 1 area i 140 e) 140F < 1 area i 170 (3)
Of these 39 areas, the peak temperatures are broken down as follows:
a) 104F <
- areas i 110F b) 110F < 11 areas i 120F c) 120F < 6 areas i 130F d) 130F'< 5 areas 1 140F e) 140F < 2 areas i 150F f) 150F < 1 area i 160F g) 160F < 2 areas i 170F h) 170 < 2 areas i 180 i) 180T < 1 aree i 190F l
j) 200F < 1 area < 210F l
(4)
These numbers changed because due to cable heat loads, some rooms previously less than 104F are now greater than 104F, and previously some harsh environment areas were included that are now excluded.
Project engineering has reviewed the safety function of Class IE devices in the areas already identified to evaluate the safety-related implications of the equipment failure following the DBAs. The evaluations indicated that failure of certain equipment could adversely affect the capability of the plant systems to mitigate the consequences of the accident or to achieve and maintain a safe shutdown.
Probable Cause The root cause of the discrepancies is as follows. Although documentation existed on project identifying areas served by the safety-grade ventilation system, the required interdiscipline l
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Bechtel Associates Professional Corporation 133187 14337-2 1 eport October 25, 1983 Page 5 coordination was not effective because the limiting conditions defining the maximum temperature that would be experienced by safety-related devices located in areas served by non-Q HVAC systems had not been established.
Therefore, design decisions as to suitable locations for intended service were made without adequate consideration of the impact of a loss of offsite power or post-DBA conditions. This resulted in a lack of consistency in:
1.
Locating safety-grade equipment in an area served by a nonsafety-grade ventilation system 2.
Specifying and ascertaining that adequate environmental qualification survice conditions exist for the safety-grade equipment when located in an area served by nonsafety-grade ventilation systems Corrective Action 1.
Corrective actions have been implemented on a case-by-case basis as follows:
a)
Selected auxiliary building HVAC systems were upgraded to Q status to limit the effect of the peak room temperature within the current environmental qualification envelope of the equipment (see Item 3. Page 7).
b)
Class 1E devices were replaced with equipment that is l
qualified for the predicted peak room temperature (see Item 7. Page 8).
c)
Existing Class IE device were demonstrated to function as required at temperatures greater than or equal to the calculated peak room environmental temperature (see Item 8, Page 8).
l Case 1 results have been used as the basis for determining the need for corrective action. Bechtel will develop information i
based on Case 2 for Consumers Power Company's use in developing emergency operating guidance.
A list of the affected safety-related devices in the auxiliary building and service water intake structure, derived from the licensing equipment qualification data base, has been developed.
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Bechtel Associates ProfessjoN$rporation 133372 NCAR 59 i33ig7 Final Report October 25, 1983 Page 6 The list is categorized by room number and contains information on the required operability period of the safety-related device, predicted peak temperature for cases 1 and 2, and the final resolution for corrective action, if any. This list has been used as an attachment to a report documenting the results of equipment evaluation.
The basis for evaluating the acceptability of a safety-related devices' location with respect to its environmental qualification has been developed. After accounting for 1) the four areas in which Q cooling will be added, and 2) the unqualified valve position switches that are being replaced (see Item 7), all remaining devices in non-Q-cooled areas have been determined to be acceptable for the slid environment in which they are located. Approximately 180 devices are included in harsh environment qualification programs that require evaluation and updating to address a loss of non-Q-listed ventilation (see Item 3).
i 2.
Project Drawings 7220-M-560(Q), Sheets 1 through 9. Rev 0, were issued on July 26, 1982, to clarify the areas of the auxiliary building that are cooled by Q HVAC systems. Project Drawings 7220-N-560(Q), Sheets 1 through 9 were revised and additional Sheets 10 and 11 were issued for information only on l
June 24, 1983, to identify the interim calculated maximum peak temperatures that the non-Q-cooled auxiliary and service water building areas will experience. Sheet 11 tabulates temperatures calculated to date for information to project engineering.
Information Sheet 11 was revised and finalized on October 25, 1983, to account for the effects of electrical cable heat and the expected increase in the main control room post-LOCA temperature from 75 to 85F and was issued for use to project engineering. The use of these drawings provides definition for locating Q devices only in areas where a suitable environment exists.
l 3.
Based on final evaluations, safety-grade HVAC has been l
incorporated into the design for the following four areas:
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Room Ten Room Area Name Elevation Unit Coolers f
I 422, 506, corridor, chiller, and access 634'-6" 1VM-118A/B, and 646' IVM-121A/B 518 areas
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Bechtel Associates Professional Corporation NCAR 59 lbOfb[
Final Report October 25, 1983 l33372 Page 7 Room Ten Room Area Name Elevation Unit Coolers 423, 507, Corridor, chiller, and access 634'-6" 2VN-118A/B, 519 areas and 646' 2VM-121A/B 442A/B Access control, change, and 634'-6" IVM-120 storage areas 443A/B Access control, change, and 634'-6" 2VM-120 storage areas The addition of eight Class 1E unit coolers to the ESF chiller area (rooms 506, 507, 518, and 519) is required to provide correct operation of the ESF chillers and support equipment, the reactor building airborne radiation monitor local control units, and the reactor building post-loss-of-coolant accident (LOCA) hydrogen monitoring equipment. The addition of two Class IE unit coolers to the access control and change area (Rooms 442A and B and 443A and B) is required to provide correct operation of the post-LOCA reactor building area radiation monitor local control unit.
It is concluded that the safety-related devices (except as noted in Item 7 below) in the remaining mild environment areas are qualified for the environment in which they are located.
Equipment located in harsh environment areas will be evaluated j
and the results documented in the Equipment Qualification Report, Volumes 1 and 2.
4.
A purchase order has been issued to Carrier Corporation, the manufacturer of the safeguards water chillers, to replace the centrifugal compressors' impeller and the low-side float valve in the economizer section to increase the capacity of the four existing safeguards water chillers from 180 to 200 tons.
5.
Project engineering procedure (PEP) 4.25.1 was revised on May 25, 1983, to explicitly require coordination with the mechanical discipline of all future procurement and location of heat-producing or heat-sensitive equipment.
6.
Appropriate individuals have received formal documented training in the use of project Drawing 7220-N-560(Q) (Recommended Corrective Action 2) and the requirements of the revised project engineering procedure (Recommended Corrective Action 5).
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c.
Bechtel Associates Professional Corporation NCAR 59 i33187 133372 rina1 Report October 25, 1983 Page 8 7.
Position switches provided by the vendor for the cross-connection isolation valves between the main and auxilisty feedwater systems were found to be NAMCO Model EA-700-80100.
Because these switches lack seismic and environmental testing, replacement by switches qualified for the seismic and environmantal conditions has been initiated.
8.
Except as noted in Item 7 sbove, replacement, relocation, or retesting of any other equipment is not required to resolve the subject concern. Subject to favorable completion of the actions identified, documented, and monitored in Bechtel Engineering Production Schedule EPS-1019 Rev 0, all other Class 1E equipment is acceptable for the environment in which it is located.
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E Bechtel Associates ProfessionalCorporation NCAR 59 133187 l33372 rina1 Report October 25, 1983 Page 9 Reportability This deficiency was reported to the NRC on May 26, 1982, under 10 CFR 50.55(e) by Consumers Power Company.
Submitted by:
Na 1 f. /Lt b T.G. Ballweg Mechanical Group Supervisor Approved by:
5.M. Hughes Q Project Engineer l
Concurrence by:
/
l h.T. Fravel Chief Mechanical Engineer l
Concurrence by:
8 E.H. Smith ~
Engineering Manager Concurrence by:
7bh fg M.A. Dietr16h l
Project Quality l
Assurance Engineer l
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1 O. BOX 14000, JUNO BE ACH, F L 33408 FLORIDA POWER & LIGHT COMPANY NOVEMBER 8 1983 L-83-557 zo 01 s$th Mr. James P. O'Reilly C ;U
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ao Regional Administrator, Region 11 Eo U. S. Nuclear Regulatory Commission
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P. O. Box 2203 g
0 P7 Atlanta, Georgia 30301 m
y co
Dear Mr. O'Reilly:
Re: St. Lucie Unit Nos.1 & 2 Docket Nos. 50-335 & 50-389 Docketing of Safeguards information Florida Power and Light Company letter L-83-502, dated September 28, 1983, forwarded to you information regarding a temporary perimeter barrier change at the St. Lucie Plant.
That letter contained Safeguards Information, and it is our understanding that you are unable to docket the letter in accordance with your procedures.
This letter is written to allow for docketing of the above. Safeguards Information letter, as per your recommendation on this date.
We regret any inconvenience this may have caused.
Very truly yours, M
J. W. Williams, Jr.
Vice President Nuclear Energy JWW/RJS/ cab n-8311280361 831108 PDR ADOCK 05000 1
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