ML20097A794
| ML20097A794 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/07/1984 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20097A780 | List: |
| References | |
| NUDOCS 8409130385 | |
| Download: ML20097A794 (9) | |
Text
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SEmOOK STATION IPUBLIC SERVICE sne n ans Osc.:
r Companyof New Hampshre 1671 Worcester Road Framingham, Massachuatts 01701 (617) - 872-8100 September 7, 1984 S BN-710 T.F. B7.1.2 United States Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated May 7, 1984, " Request for Additional Information on Environmental Qualification of Electrical Equipment Important to Safety", G. W. Knighton to R. J. Harrison (c) PSNH Letter, SBN-549, dated August 12, 1983, " Response to Safety Evaluation Report Outstanding Issue #6 (SER 3.11; Equipment Qualification Branch)", J. DeVincentis to G. W. Knighton
Subject:
Response to Safety Evaluation Report Outstanding Issue #6 (SER 3.11; Equipment Qualification Branch) and Request f or Additional Information 270.4 Through 270.12
Dear Sir:
In response to your Request for Additional Information (RAI) included in Reference (b), we have enclosed responses to RAI 270.4 through 270.12.
Section 3.11 of the FSAR and our report entitled " Environmental Qualification of Electrical Equipment Important to Safety" (EQR) which was submitted in Reference (b) will be revised as indicated in the enclosed RAI responses.
Very truly yours, YANKEE AIDMIC ELECTRIC COMPANY M
(
John DeVincentis, Director Engineering and Licensing cc: Atomic Safety and Licensing Board Service List 8409130385 840911 PDR ADOCK 05000443 E
F
,Cilliam S. Jordan, III Diann Curran Harmon, W;ies & Jordan 20001 S Street N.W.
Brentwood Board of Selectmen Suite 430 RED Dalton Road Washington, D.C.
20009 Brentwood, New Hampshire 03833 Roy P. Lessy, Jr., Esquire Office of the Executive Legal Director Fdward F. Meany U.S. Nuclear Regulatory Commission Designated Representative of Washington, DC 20555 the Town of Rye 155 Washington Road Robert A. Backus Fsquire Rye, NH 03870 116 Lowell Street P.O. Box 516 Calvin A. Canney
'Mancehster, NH 03105-City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Department of the Attorney General Augusta,'ME 04333 Dana Bisbee, Esquire Assistant Attorney General Mr. John B. Tanzer Office of the Attorney General Designated Representative of 208 State House Annex the Town of Hampton Concord, NH 03301 5 Morningside Drive Hampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Fevear Town Hall
-Designated Representative of South Hampton, NH 03C42 the Town of Hampton Falls 1Drinkwater Road Patrick J. McKeon Hampton Ts11s, NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Cavutis Rye, NH 03b70 Designated Representative of the Town of Kensington Carole F. Kagan, Esq.
RFD 1 Atomic Safety and Licensing Board Panel East Kingston, NH 03827 U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Est,uire Assistant Attorney General Mr. Angie Machiros Environmental Protection Bureau Chairman of the Board of Selectmen Department of the Attorney General Town of Newbury One'Ashburton Place, 19th F.loor Newbury, MA 01950 Boston, MA 02108 Town Manager's office Senator Cordon J. Humphrey Town Hall - Friend Street U.S. Senate Amesbury, Ma.
01913 Washington, DC 20510
"(Attn: Tom Burack)
Senato-Gordon J. Humphrey 1 Pillsbury Street Diana P. Randall Concord, NH 03301 70 Collins Street (Attn: Herb Boynton)
SEabrook, NH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 Town of Exeter 10 Front Street Exeter, NH 03833
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t f hI
h g RAI RESPONSES
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JRAI 270.4 (3.11)
'A single failure'has apparently not been assumed when calculating the
- maximum pH for chemical spray qualification purposes..This is required by
' -10CFR50.49(e)(3).
Response
- , w -
1The Seabrook containment spray system design provides a limited amount of NaOH y-M
-available for ECCS injection and spray purposes.
In the calculation of
" maximum spray pH for long-teria cooling, the entire volume of caustic was
! assumed to be added to the sump water. Postulated single failures would not increase' recirculation spray _pH.
RAI 270.5'(3.11)
! Thd difference between the incontainment temperatura and pressure profiles published.in the Equipment. Qualification Report (Figure 3-1) and the profile
. published -in the FSAR '(Figure 3.11 (B)-1) should be explained, along with a
- detailed-explanation of the methodology used to establish these curves _beyond
,the 10 seconds curves published in the FSAR.
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. Response:
~
The differences between the incontainment profiles in the FSAR (Figure 73.11(B)-1) and the Environmental Qualification of Electrical' Equipment Important to Safety Report (EQR) (Figure 3-1) is that these two-figures reflect different revisions of the same UE&C document,~namely Drawing No.
-9763-F2300219. The document is being revised and will appear both in the FSAR
-and'the EQR. These environmental env11 opes incorporated the results obtained in the.long-term containment temperature response analysis (Calc.' Set No.
- 4.3.23-25F).
Page 1 of 7
The method.used to extend the' curves on Drawing Number 9763-F-300219 (Figure 3-1 of the EQR) beyond.10 seconds was an extrapolation of the LOCA profiles back to steady-state conditions. This method is very conservative cince it does not account for the precipitous drop in temperature and pressure that calculations have shown occurring at the initiation of hot leg injection.
- These calculations show that with a switchover to hot leg injection at 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, the containment temperature returns to 120 F more rapidly (approximately 4 days after LOCA) than that indicated by the pressure and temperature profiles shown on Drawing Number 9763-F-300219 curve. The calculations also demonstrate that with worst case heat loads and no spray the containment' temperature can rise above 120 F and the intermittent use of the spray beyond the 30-day post-accident period will maintain the 120 F.
RAI 270.6 (3.11)
Section 4.1.4E is contradictory. The flood levels for the containment and the RHR, CS, and SI equipment vaults should be supplied. These levels should be compared to the equipment e'.evations, and a walkdown executed to ensure that these elevations are correct. Also, if credit is taken for floor drains, this system must be qualified.
Response
Section 4.1.4E will be changed to more clearly state the intent of this
-paragraph, i.e., any Class 1E equipment needed to operate post-accident which could be submerged will be qualified for submergence. This does not include Class 1E equipment in the RHR, SI, or CS equipment vaults because of redundant equipment located in separate vaults. Only one of these redundant vaults could be flooded for any particular break, consequently the loss of equipment in any one vault 1due to submergence would not effect accident mitigation.
The flood level of the containment is (-)20' - 8" and any Class 1E equipment in the containment which is needed to operate post-accident will have a i
walkdown executed to confirm its elevation.
.No credit is taken for floor drains.
page 2 of 7
pg4 R&I 270.7 (3.11)-
. C' i'
IIt is unclear if^the seals mentioned in Section 4.1.6 are qualified. Also to "be considered are cable splices and other electrical interface equipment.
.Rgsoonse:
"The seals mentioned in 4.1.6 are qualified and the next revision of the EQR will clarify this.- Also to be addressed in this revision will be the qualification of cable splices and other electrical interface equipment.
Qualification documentation and evaluations of all electrical interface equipment will-be provided as part of.the EQ package.
1RAI 270.8 (3.11)
Define "appropeiste m;rgins" as used in the context of Section 4.1.5 of the Environmental Qualification'(EQ) report.
Response
By. " Appropriate' Margins" in Section 4.1.5, it is meant that the reconsnended margins stated in IEEE Std. 323-1974 are met.
If theJe requirements in any
.particular case are not met, then the. application of that device and its particular location are analyzed and a justification is written.
RAI 270.9 The' Qualification Evaluation'Worksheets (QEW) are incomplete. Missing are t
notations to explain:
's.
Outstanding items' b.
Qualified life l
Tc.
Maintenance and surveillance requirements ld.
Qualification methods i
(e.
Qualification environment does not always envelope accident environment, l
L.
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Page 3 of 7 j
s
In addition, some equipment listings in the BOP section of Appendix A have no QEW and no corresponding listing in Appendix 3H of the FSAR. There are also
'some new QEW sheets with no equipment listings.
Response
The Seabrook Program documents equipment qualification in a file or package format. Within this format, the Assessment Report (Environmental Qualification Report (EQR), Section 4.2.2] provides a review of vendor docunentation. The QEW is part of the Assessment Report and is provided in the EQR to supplement other information contained therein.
Concerning the specific items noted by the NRC as missing from the QEW, these are provided within the Seabrook EQ Program as follows:
a.
Outstanding Items The qualification status, including the identification of outstanding items is found for each Purchase Order and equipment type as part of the Index at the front of Appendix B of the EQR.
.b.
Qualified Life The Qualified Life is on the Qualification Evaluation Worksheet (QEW)
-under the " Qualified" column. Changes will be made in the next version of the EQR to clarify the format for qualified life data in this column.
c.
Maintenance and Surveillanco Requirements This information is specifically found in each Assessment Report (see EQR, Figure 4.4, Page 3),
m d.
Qualification Methods The method of qualification is fully described in the test report included with the vendor documentation package, s.
Qualification Environment Does Not Always Envelope Accident Environment Figure 1 of the Assessment Report details a comparison of test and l
postulated accident profiles. Any exceptions and justificaticn for I
. acceptability are provided in the Assecament Report.
Pago 4 of 7
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- The FSAR is presently being revised to delete Appendix 3H and in its place, a
. reference is made'to the Equipment List in the EQR. Appendix 3H is an early revision of the Class 1E equipment located in " harsh" and " mild" environments.
. Appendix A of the EQR listed only Class 1E equipment in a " harsh" environment.
The EQR will be revised to eliminate any discrepancies between the Equipment List in Appendix A and the QEW sheets in Appendix B.
RAI 270.10'(3.11f
- No qualification evaluation worksheets have been prepared for the NSSS scope of supply. Therefore, it is not possible to determine from available data:
a.
The applicable reference being used to establish qualification.
b.
The qualification status of each equipment item.
c.
The items mentioned in Statement 6.
Response
QEW sheets for the NSSS. scope have been initiated but are not complete at this
' time. Items a and'c will be addressed in the applicable QEWs.
Item b will ec
.added to the EQR similar to the status information now listed for BOP p
equipment at the beginning of Appendix B.
I a:
RAI 270.11 Verify that the Seabrook EQ Program includes all equipment in Categories 1 and j~
O of Regulatory Guide 1.97, Revision 2, which is currently installed or that
- .l will be installed prior to fuel load. Justification must be provided for all Category 1 and 2 items that are not included in the EQ program.
Response
. We are.4a the process of. selecting our accident monitoring instrumentation following the guidance in Regulatory Guide 1.97, Revision 3.
Any exceptions to. the recommendations of the Regulatory Guide will be indicated and justified.
l i
page 5 of 7 m.
,..:e Our EQ program will include those items that we list as -Category 1 and 2 items.
RAI 270.12 (3.11)
A review of the Seabrook Station FSAR Section 3.11 indicated the following' areas of concern.
a.
There is a lack of correlation between some values in Tables 3.11(N)-2
.and 3.11(N)-3 and those found in the Service Environment Chart (Figure 3.11(B)-1].
b.
The normal dose for one area in Note 9 of the Service Environment Chart is still listed as "Later".
'c.
Appendix 3H does not contain all the qualification information indicated in Section 3.ll(B).1.
d.
The summary provided in Section 3.11(B).2 is incomplete.
Is the EQ report a supplement to the summary or a replacement for the summary?
Please clarify.
Responne:
a.
These discrepancies will be reviewed and appropriate revisions made to the FSAR.
b.
The final dose calculations for this area have been completed and will be included in the next revision of the Service Environment Chart.
c.
The FSAR is presently being revised and Appendix 3H is being deleted.
In its place, a reference will be made to the Environmental Qualification of Electrical Equipment Important to Safety Report (EQR). All Equipment Qualification Information referred to in Section 3.11(B)-1 of the FSAR, will be included in the EQR, Assessment Reports, and/or vendor documentation.
Page 6 of 7
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'. ' 'f d.
Section 3.11(B).2 is presently being revised. Changes which are pertinent to this RAI^are summarized as follows:
4 1.
Section 3.11(B).2.1 the present summary is being deleted and replaced by a reference to the EQR report. The summary sheets in Figure 3.11(B)-2 are also belas deleted. The EQR discusses the equipment qualification methodology in greater detail.
2.
Section 3.11(B).2.2 - the present summary is to be deleted and replaced by a summary that expands on conformance to general design criteria of Appendix A and B to 10CFR50 and conformance to specific IEEE standards.
In the sections of the FSAR where the EQR is referenced, the EQR is a replacement for_the FSAR summary.
Page 7 of 7 m