ML20100C442
| ML20100C442 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/16/1984 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| SBN-731, NUDOCS 8412050455 | |
| Download: ML20100C442 (26) | |
Text
e SEAnnooK STATION M*'% Olho.
I 1471 Worcester Rood homingham. Monochwietts 01701 (4171 172 5130 Pub 6c Service of New Hampshire Noveraber 16, 1984 SBN- 731 NEW HAMPSHIRE YANKEE DIVISION T.F. B4.2.7
' United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. J. Nelson Grace, Director Division of Quality Assurance Safeguards and Inspection Program Office of Inspection and Enforcement Refe rence s : (a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated April 2,1984, " Integrated Design Inspection 50-443/83-23", R. C. DeYoung to D. N. Merrill (c) PSNH Letter, dated May 7,1984, " Schedule for Integrated Design Inspection Response", J. DeVincentis to R. C. DeYoung (d) PSNH Letter, dated June 29,1984, " Response to Integrated Design Inspection; 50-443/83-23", W. P. Johnson to R. C. DeYoung (e) USNRC Letter, dated October 5, 1984, " Integrated Design Inspection 50-443/83-23", J. N. Grace to R. J. Harrison
Subject:
Response to Integrated Design Inspection; 50-443/83-23
Dear Sir:
Reference (e) provided the results of the NRC review of our responses
[ Reference (d)] to the Integrated Design Inspection Findings, Unresolved Items and Observations [ Reference (b)]. On November 7-9, 1984, a close-out inspection was conducted at the United Engineers & Constructors, Inc. office in Philadelphia, PA. During the inspection, we committed to provided revised / additional responses to the following IDI Findings:
Finding 2 CBS Motor Torque Finding 3 Isolation Valve Closure Finding 4 Live Loads Finding 4 Tank Farm Building Stiffners Finding 4 Structural Steel Bracing Finding 6 Qudlification Test Report Finding 6 Qualification Test Conditions
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Finding 6 EAH System Failure 8 f
Finding 6 RRR System Failure Finding 6 PCCW System Failure )
Finding 6 Temperature Control Circuit Isolation 1 Finding 6 Conduit Marking I 1
The revised / additional responses are transmitted herewith as Attachment 1.
I 1000 Elm s' . P.O Box 330. Monchester, NH O3105 . Telephone (603) 669-4000 . TWX 7102207595 )
8412050455 841116 )
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og United-States Nuclear Regulatory Commission November 13, 1984 Attention: Mr. J. Nelson Grace, Director Page 2
- Finding 4-10, Analysis of Eccentricity, was left open.pending a revision to the FSAR. Attachment 2 is FSAR Appendix 3F marked up to include the additional information requested at the reinspection. The revised Appendix will be incorporated in Amendment.54 to the FSAR.
Attachment 3 is a listing and status of FSAR changes required as a result of our responses to the IDI findings.
Very truly ours, m >
J. DeVincentis, Director Engineering and Licensing cc: Atomic Safety and Licensing Board Service L'st l
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. William S. Jordan, III
- Dians Curran .
Harmon, Weiss & Jordan 20001 S Street N.W. Brentwood Board of Selectmen Suite 430 RED Dalton Road Brentwood, New Hampshire 03833 Washington, D.C. 20009 Robert G. Perlis -
Office of the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representative of Washington, DC 20555 the Town of Rye 155 Washington Road Rcbert A. Backus, Esquire Rye, NH 03870 116 Lowell Street F.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 4
Roberta C. Pevear Town Hall Designated Representative of South Hampton, NH 03:42 the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Hampton Falls, NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Gavutis Rye, NH 03870 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
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- Jo Ann Shotwell, Esquire 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 Floor Newbury, MA 01950 Boston, MA 02108 Town Manager's Office Senator Gordon J. Humphrey Town Hall - Friend Street U.S. Senate Amesbury, Ma. 01913 Washington, DC 20510 (Attn: Tom Burack) Senator 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
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Town of Exeter 10 Front Street Exeter, NH 03833
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SB ATTACHMENT 1 FINDING 2-18: CBS PUMP MOTOR TORQUE FSAR Section 8.3.1.1.1 (page 8.3-22) states that motor suppliers are required to verify that actual test data confirms that the torque margin is equal to or greater than that of calculated data. Foreign print 51849-02-238-3 pro-vides calculated data on motor torque which are indicated as "not guaranteed".
Westinghouse provided test data on the motor, but the test was performed at no load conditions. Neither Bingham-Willamette nor United Engineers had test data in hand for loaded conditions to verify that the torque margin is equal to or greater than the calculated data.
RESPONSE
Test verification of calculated torque margins is not actually a requirement of the CBS pump specification 9763-006-238-3 nor the project generic motor speci-fication 9763-006-128-1. Test data verification was requested from Bingham-Willamette in UE&C letters SBU-7564 (6/2/76), SBU-10685 (1/4/77) and SBU-15035 (11/11/77). UE6C was unsuccessful in obtaining test data at load or certifica-tion of the existence of test data which verified the calculated torque data.
Verification of acceptable motor acceleration (torque margin) under load will be obtained during preoperational testing of the safety-related containment spray pumps.
As the verification, by test, of calculated torque margins is not a requirement, FSAR Section 8.3.1.1.1 will be changed accordingly (requirement deleted).
ADDITIONAL RESPONSE:
Test verification of calculated torque margins is not actually a requirement of the CBS Pump Specification 9763.006-258-3 nor the project generic Motor Specification 9763.006-128-1.
Specification 128-1, Section 3.2.1, requires the manufacturer to " supply written proof or curves", basically on analysis or calculation, to document acceptable torque margin. The FSAR, Section 8.3.1.1.1, will be revised (see attached page) to reflect the actual specification requirements.
We consider the calculation in F.P. 51849 to be sufficient to meet the specifi-cation requirements.
Verification of the ability of a motor / pump combination to produce sufficient system flow will be tested during preoperational system testing. The motor current during this test is verified to be less than the motor rated full ,
load current to show that the motor is not overloaded. A specific test to time motor acceleration (torque margin) is not pe rf o rmed ; system flow verifi-cation is considered sufficient to prove motor / pump acceptability.
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- s y .g ATTACllMENT 1 y .~ SR 1&2 Amendment 52 U *D .j FSAR December 1983
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[ The.= thermal overload protection for continuous duty motors located 6g, ,
inside containment is part of the the design provided to satisfy
% ! the requirements of Regulatory Guide 1.63 for containment electrical
,g g penetrations. These thermal relays will be periodically tested as 4d defined by Technical Specification 3.8.3.1.
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k.k4 h. Eauipment Grounding (g9 3 b Capper, copperveld. cable and copper bus provide low resistance ground paths wherever electrical equipment is located. All electric
<g equipment and non-electrical conductive material such as structures, 3 enclosures, tanks, and raceways are grounded in conformance with kQ *k %
IEEE Standard 142-1972 and IEEE Standard 80-1971. The building grounding system is provided with adequately sized ground cables 3 'j for peripheral connections to the station ground grid.
The method of system grounding utilized at the various voltage g- e levels is discussed in the applicable sections.
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's i. Sa fe t v-Re l a t ed Svstem Motor Selection 4 O All motors are sized for continuous operation of the running load and operate successfully at 90% of rated motor voltage. Motors
.-- e are capable of starting their rated loads with 80; voltage and 95 f
fg frequency at the motor terminals. The system design and diesel 4 generator specification assures that this voltage will be present at the motor terminals when needed. The calculated continuous Og Q M
3y brake horsepower is not greater than 95% of the horsepower rating g M*gg g of the motor. The starting torque for the motor is based on the inertia and speed-torque characteristics of the driven equipment.
Y y The motor-torque curve, at its closest approach to the load-torque curve, and at the required starting voltage, is greater than the g torque required by the load at that speed. This permits the motor s
-$ to develop a margin of torque over that required by the load to ensure successful starting and acceleration. The insulation system 4 7 for motors is NEMA Class B, as a minimum, with the actual insulation C N class selected on the basis of environment and service conditions 4 in which the motor is required to operate. The factors taken into k consideration in selection of the insulation system are resistance
$ ,g to radiation, resistance to moisture, resistance to chemicals, N
- ) ambient temperature and pressure. The motor enclosure is selected C- to protect against adverse environmental conditions. L'ind ing
- temperature detectors and bearing thermocouples are provided on b "[tc large motors to alarm high temperature conditions.
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0 % h The motor suppliers are required to verify that actual t'est data j *g g 9 w confirn that the torque margin is equal to or greater than that of 4 the _ calculated data.d A further check of motor capability is the preoperational testing conducted at the site under plant light
[. . g cn a 44 8.3-29
., ATTACllMENT 1 FINDING 3-11: ISOLATION VALVE CLOSURE Calculation Set 4.3.5.17F shows that closure of the motor operated containment isolation valves in 10 seconds during containment spray pump operation could induce water hammer peak pressures of 427 psig in lines upstream of the valves.
Review of United Engineers' drawing 9763-F-804881 showed that the maximum operating pressure in these lines during the injection and recirculation modes of operation is 376 psig. Both of these pressures exceed the 300 psi ASME Code design pressures of the tube side of the containment spray heat exchangers and pumps. The Code design pressure should be the maximum operating pressure. -
United Engineers Nuclear Group indicated that the containment building spray system description was to be modified to specify that closure of the isolation valves should not be permitted during pump operation. This is considered tech-nically significant, and assurance that valve closure will not occur during pump operation is needed.
RESPONSE
Assurance that the isolation valve will not be closed during pump operation will be provided in the operating procedures which will call for the pump to be shut of f before the valve is closed. This provides adequate protection since there is no automatic closure signal to the valve.
Drawing 9763-F-804881 - shows the maximum pressure of 300 psig which corresponds to the relief valve set pressure.
ADDITIONAL RESPONSE:
There is no normal operating condition that requires the establishment of a flow path from the containment spray pump (s) to containment via the containment isolation valves in question. Surveillance testing is performed utilizing a re-circulation flow path back to the RWST. The only time that spray will be estab-lished to containment is during an accident. In this case, the emergency pro-cedure for containment spray will be strictly adhered to. The Seabrook emer-gency procedures are based on Westinghouse Generic Emargency Response Proced-ures. The Seabrook plant specific e mergency procedure does not include any steps associated with the operation of the containment isolation valves.
Therefore, out-of-sequence performance of steps is not an issue. Flow termina-tion is accomplished solely by the shutdown of the spray pump. There is no automatic closure signal to the isolation valves.
As the closure of these valves would be a multiple step operation (reset the con-tainment spray protection signal and operate the control switch), we feel that the addition of any cautions that would address the sequential operation of these valves would not reduce the potential for closing these valves before pump trip.
[ Drawing 9763-F-804881 is a material balance tabulation and does not reflect the pre's ence of a relief valve at the containment spray heat exchanger (set pressure 300 psi) that protects the piping and components downstream of the spray pump ~
(see P&lD 9763-F-805023).
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'M' ATTACHMENT 1
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. FINDING 4-2: LIVE LOADS
'When considering load combinations which include earthquake loads, no movable live loads have been considered . for most ' Category I floors.- FSAR Se ction .
-3.8.3.3 indicates that' live loads on structures inside the containment are only present ~ during shutdown conditions.' FSAR Section 3.8.4.3 ut1112es . the normal definition of live loads'for Category I structures other than contain-ment. Per Table 4.2-1 of the Structural Design ' Criteria, SD-66, Revision 1 ,
only two floor ' areas of ' Category I structures utilizes movable live loads in
. combination with seismic loads. This situation is noted as a generic finding applying to all Category I structures at Seabrook.
RESPONSE
Movable uniform live loads were not combined with seismic loi.ds in the design of Seabrook Station.. No significant live loads were anticipated during plant operation. We concur with the IDI Team recommendation that the tech-nical- specifications ' for plant operations should place live _ load control i limitations,on the plant operators. The incorporation of this requirement ;
, into the technical specification will be completed before fuel loading. ;
ADDITIONAL RESPONSE: ,
For all Category I structures, floors will be verified for the additional l single concentrated live load of
- kips per bay anywhere on the floor in-- !
combination with seismic loads. Appropriate sections of the FSAR and SD-66 (Structural Design Crite ria) will be revised to reflect the minimum live load design condition specified above. Uniform live load which produces equivalent effects may be considered in lieu of a single concentrated live load.- Imposition of any live load greater than the specified *_ kips live load must be verified by the responsible plant engineer. The final veri-fication for this additional load will be - perf ormed after completion of the project design,' but prior to fuel load. This limitation will be inclu-ded in the technical specification and controlled by the plant operating engineer. >
- Number to be established af ter final verification of loadings.
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ATTACHMTNT 1
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) FINDING 4-6: TANK FARM BUILDING STIFFNESS The mathematical model of the tank farm described in Calculation No. SBSAG-5WB does not account for the stiffening effect of the fill concrete since the base of the seismic model utilized was erroneously designated to beat the bottom of the fill concrete.
Based on the fact that the seismic model did not incorporate the stiffening effect on 15 feet of fill concrete in the north-south direction, that only the shear stif fnesses were included in the overall computation of building stif f-ness and that the flange ef fects for bending stif fness were neglected, the team concluded that the aggr egate building stiffness was inaccurately calculated.
This has the potential of shif ting the fundnaental frequency of the structure and consequently changing the location of peak frequencies as well as the value of acceleration in the amplified responae spectra. The modeling was not consistent with the FSAR, Section 3.7(B).2.3 which states that "the elevation of the point--
of-fixity of the mathematical model is .... a lowest elevation of upper surf ace of concrete backfill which bears directly against the structure".
RESPONSE
UE&C Technical Procedure TP-17 for ARS Verification Program, Section 3.0, re-quires that structural or general arrangement drawings, masses, etc. used as or-iginal input in the seismic analyses be verified against final design parameters.
The purpose of this requirement is to show that reasonable and representative in-put data was used in the original analyses. This work for the Tank Farm area had been scheduled but n ot performed at the time of IDI audit. The completion of this program would have resolved the NRC concern.
Subsequent to NRC inspection, UE&C initiated a detailed analysis of the Tank Farm area, Unit 1, considering the stif fening ef fects of the fill concrete. The existing design will be checked against the results of the new analysis. It is estimated the whole ef fort will be completed by 9/84.
ADDITIONAL RESPONSE:
A 3-D model was constructed to better represent the behavior of this irregular structure. Mass condensation was used to maintain a manageable model. The steel and concrete portions of the model were shown to behave as decoupled dynamic sys-tems, and the analysis incorporated this for economy. The modeling and the analy-sis methods were compatible with the provisions of Standard Review Plan 3.7.2.
Construction of the new model from 'as-built' drawings pointed out other impor-tant dif ferences in structural configuration, boundary conditions and mass f rom the 1976 design of the steel portion of the structure. These include:
- 1. The 1976 design showed the roof over the steel structure as supported on the
, concrete portion of the structure along column line E.7 and on the Waste Pro-
. cessing Building along column line 5.0.
- 2. The mass of this roof is now significantly greater than in the 1976 design.
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LFINDING 4-6: (cant 'd)
-3. Changes in the framing, other than noted by the NRC, exist.
NOTE: A number of these dif ferences had been noted during the calculation close-l out effort prior to the IDI review and an in-house review was planned i
I- he . findings of .the UE&C study are described below:
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- 1. Stiffening ef fect of concrete' fill increases structural f r.:quencies by 6% to 12%.
l 2.~ Releasing the rot ational degree-of-freedom reduced the structural fre '
quencies by ~22% to 28%.
- 3. Addition of ' flange effects' increases structural f requencies by 12% to 28%.
l 9 l The af fects of items 2 and 3 are compensating, resulting in comparable natural f req uencies. Adding the ef fect of item I results in a total effect of the NRC i findings to be shifts in the lowest natural frequencies in the range of l - 11% to + 13%. 14vels of acceleration are comparable to those obtained by pre-f vious analyses. Adding the effeet of separating the steel structure's roof i from the concrete structure to the som of the ef fects of the NRC. findings re-suits an total shif ts of lowest natural f requencies of the concrete structures of - 35% to +35%. Structural accelerations of the 'as-built ' structure are generally lower than design values. Review of the structure for new forces and moments is underway. No overstress is indicated at this. time. New ARS have also been generated. Approximately 80% are enveloped by existing response spectra. The balance are not enveloped because of frequency shif ts. De impact on mechanical systems and equipment is being evaluated.
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ATTACHMENT 1 l FINDING 4-78 STRUCTURAL STEEL BRACING In calculating the stiffness of the structural steel bracing, United Engineers
! assumed that all X-bracing was composed of angles 4" x 4" x 3/4". In fact, the bracing actually consists of substantially larger members as indicated in United 4 Engineers drawings " Tank Farm and Pipe Tunnel," Drawings F-111824 and F-Ill835.
The neglect of overall bending in the development of the stif fness of the stick ,
model did not significantly simplify calculations, but did raise questions con-cerning the correct stif fnesses of the mathematical model.
RESPONSE: l As discussed in response to Finding 4-6, this concern would have been resolved during ARS Verification Program in accordance with UE&C Technical Procedure TP-17.
Subsequent to NRC inspection, UE&C initiated a detailed analysis of the Tank Farm area, Unit 1, considering X-bracing as shown on the final drawings. The existing design will be checked against the results of .the new analysis.
It is estimated that the whole ef fort will be completed by 9/84.
ADDITIONAL RESPONSE:
A 3-D model was constructed to better represent the behavior of this irregular structure. Mass consensation was .used to maintain a manageable model. The steel and concrete portions of the model were shown to behave as decoupled dynamic systems, and the analysis incorporated this for economy. The modeling and the analysis methods were compatible with the provisions of Standard Review Plan 3.7.2.
Construction of the new model from 'a s-built ' drawings pointed out other in-
.port ant differences in structural configuration, boundary conditions and mass from the 1976 design of the steel portion of the structure. These include:
- 1. The 1976 design showed the roof over the steel structure as supported on the concrete portion of the structure along column line E.7 and on the Waste Processing Building along column line 5.0.
- 2. The mass of this roof is now significantly greater than in the 1976 design.
- 3. Changes in the framing, other than noted by the NRC exist.
NOTE: A number of dif ferences had been noted during the calculation closeout ef fort prior to the IDI review and an in-house review was planned.
Changes in configuration and mass of the steel s tructure result in a seismic response (3-D model) significantly dif ferent from the 1976 model's response.
Acceleration levels are compa rable , but inertia forces are larger and distri-bution throughout the structure is dif ferent.
The' impact of this result is an apparent overstress of some anchors and brac-ing members. A remedial design ef fort is underway and a confirmatory analysis will be performed.
The assessment ef forts defined above are currently in progress and will be coupleted by 1/31/85.
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. ATTACHMENT 1 l** FINDING 6-7 QUALIFICATION TEST REPORT 1
United Engineers Specification 252-16, used to procure both Class lE and non-1 Class lE dif ferential pressure switches from ITT Barton, has been subject to considerable revision of seismic and environmental parameters during the past few years. Class 1E differential pressure switches procured by United Engineers specification 252-16 have be en delivered by ITT Barton and accepted by United Engineers Field QA without an approved qualification test report and without identification in the United Engineers non-conformance reports of the absence of an IEEE Std. 323-1974 environmental qualification test report. This violates the United Engineers vendor surveillance check plan requiring review of the environ-mental qualification test report as well as the seismic qualification test report provided with the Site Data Package or preparation of a completely descriptive non-conformance report.
RESPONSE
Vendor Surveillance Shop Ins pection Reports 9, 11, 12, 16 and 18 (SBUs-57416, 63558, 66052, 75994, and 76479, respectively) had indicated that there was no approved IEEE-323 environmental qualification test report, but failed to include it on the conditional Quality Shipment Releases (QSRs) 6962, 6721, 3605, 3614, 15802 and 15805. The remarks section of these conditional QSRs only stated that release was contingent upon ITT Barton's submittal of an approved seismic report to be included in the site data package for Class 1E items. Upon receipt at Seabrook, Field QA only issued non-conformance reports for lack of an approved seismic report. This was an error of omission.
Field QA has issued a non-conformance report (NCR 74/2722) for all the Class 1E dif ferential pressure switches and indicators included on the above QSRs.
Site Data Packages for Class lE equipment will be reviewed by Field QA to assure that the data packages contain an approved IEEE-323 qualification report or, if not, the itens were conditionally released and are identified on a nonconformance report.
In addition, personnel will be instructed on the requirements for IEEE 323 quali-fication documentation.
REVISED RESPONSE:
Our Environmental Qualification Program, described in FSAR Section 3.11, will ensure that the requirements of 10CFR50.49 are met prior to licensing.
The status of the IEEE-323 qualification of equipment located in harsh environ-ments is documented in our Environmental Qualification Report that compiles with the requirements of 10CFR50.49 and the guidance of NUREG 0588. Equipment that is locat ed in harsh environments is identified on the Class IE Equipment List by tag number, make/model and location. Environment category (harsh / mild) will be included shortly.
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FIhDING 6-7 (cent 'd )
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.g ADDITIONAL RESPONSE:
These are controlled documents that provide adequate documentation of quali-fication status to enable us to determine that the requirements of 10CFR50.49 are met prior to licensing. It is not necessary for the site QC to provide an individual status tag for each piece of IE equipment.
The UE&C Site Records Group has been directed to mark "Not Applicable (NA)"
for the Vendor Surveillance Check List requirement for IEEE-323 qualification as part of the Site Data Package. Vendor Surveillance will continue to deter-mipe the status of this qualification prior to shipment of the eq uipme n t .
This approach has been discussed with the resident Inspector (A. Cerne) and found acceptable.
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FINDING 6-83 QUALIFICATION TEST CONDITIONS For several years, ITT Barton has not agreed to meet certain environmental and
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seismic requirements of the United Engineers' specification involving both Class lE and non-Class lE devices. - A design qualification test plan proposed by ITT cBarton has been accepted by United Engineers with technical comments that still require resolution between ITT Barton and United Engineers. Issues involving inconsistencies in temperature. values (320 versus 375 degrees F).and plant specific seismic values for Class lE devices and radiation exposure (3 versue 20 megarads) for . non-Class 12 devices had not been resolved at the time of the inspection. Neve rtheless , ITT Barton advised the IDI team that an en-vironmental and seismic qualification - test report, based on this not-fully-resolved test plan, was submitted to United Engineers on 12/23/83 and United Engineers subsequently indicated that the seismic test results are indeed sa tis factory.
RESPONSE
UE&C Spec. 252-16S has been revised to reflect the Seabrook environment and to resolve information . inconsistency (Ref. SBU86057, dated March 16, 1984). There are no major seismic problems (Ref. MM202979A, March 30, 1984). Discussions-(Ref. SBU-88138, dated May 15, 1984) are under way with the vendor to resolve outstanding issues.
REVISED RESPONSE:
- 1. We have re-evaluated the applications of the Class 1E flow indicating switches (FIS) and have determined that the switches located inside containment are associated with isolation of a ruptured thermal barrier heat- exchanger.
This system has been re-designed such that this function is no longer re-quired (FSAR Section . 9.2.2). The FIS will provide high and low flow alarms, but does not require harsh environment qualification for this function.
The present qualification of the FIS envelopes the Seabrook LOCA curves.
We have reviewed the circuits that share the power supply with the . FIS to determine if they are required to perform a safety function if the FIS are exposed to conditions more severe than those cause by the LOCA.
All the circuits that share power supplies with the -FIS are associated with isolation of non-safety related component cooling water piping on low level in the head tank. We have -determined that this isolation function is not required when the FIS is exposed to conditions more severe than what they are qualified for. Therefore, the present design and environment. quali-fication is adequate.
We will revise Specification 252-16S to specify the environmental curves that are enveloped by the FIS qualification program.
- 2. Specification 252-16 stated Section 2.4.3.2 will be revised , to reflect
- vendors' radiation tolerance for non-qualified instruments.
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. . - FINDING 6-12: EAH SYSTEM FAILURE ATTACHMENT 1 Both containment enclosure emergency filter-fan trains can be rendered in-operable by the common mode failure of non-safety-related current-to-pneumatic converters EAH-PDY-5781-2 and EAH-PDY-5787-2 which modulate the fan vortex inlet dampe rs.
RESPONSE
An examination of the system performance indicates that the fan vortex inlet damper can remain in the full open pcsition, thus producing the maximum possible negative pressure within the containment enclosure and associated areas. The inlet damper control will be disconnected to ensure that the dampers are always in their " fail-open" position.
See our response to Finding 6-14 for a discussion of our review of safety-related instrumentation and controls.
ADDITIONAL RESPONSE:
The control switch on the main control board will be removed.
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SB FINDING 6-13: RHR SYSTEM FAILURE In summary, we found that _ the Emergency Core Cooling function of both Residual Heat Removal trains can be rendered inoperable due to the valves (for temperature control) not being in their proper position. Additionally, the Residual Heat Removal System can be rendered inoperable or seriously degraded during normal or emergency plant cooldown by common mode failure of non-safety-related current-to-pneumatic' converters due to environmental or seismic effects. This situation can cause the heat exchanger outlet valves to close and/or heat exchanger bypass valves to open, rather than positioning the valves to their fail-safe position, as required for accident ud tiga tion. The United Engineers control system design violates IEEE Std. 279-1971 and General Design Criteria 20, 21,22, 23 and 24.
RESPONSE
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The RRR system is a dual purpose system, as stated in FSAR Section 6.3.3.7.
The ECCS function is fully automated and single failure proof and is only required in modes 1; 2 and 3 (Technical Specification 3.3.2 and 3.5.2). Below 350 F, the stable reactivity cordition of the reactor and the limit ed core cooling requirements do not necessitate that the single failure criteria be met (Bases 3/4.5.2 and 3/4.5.3).
We will ensure that RH ..CV-606 and 607 are open and RH-FCV-618 and 619 are closed when in modes 1,2 and 3 by including these valves and their control switches (RH-CS-606, 607, 618 and 619) in the surveillance procedures that meet the system lineup surveillance requirements of Technical Specification 4.5.2.b.
Since the RHR valves and control switches are periodically verified to be in the proper position for the ECCS function, and since the control switches and solenoid valves are Class 1E, there is no single failure that will cause the valves for both trains to be repositioned to the incorrect position. IEEE Standard 279-1971 and General Design Criteria 20, 21, 22, 23 and 24 do not apply, as there is no protective action required of these valves.
The additional concerns about the RHR system being rendered inoperable during a cooldown without an accident were addressed in our response to RAI 420.52 where we showed that there is sufficient time for operator action to restore cooling with a complete loss of RHR flow. The postulated failure of the current-to-pneumatic converters (loss of heat sink) is enveloped by our response to RAI 420. "2 as the operation action (moving RH-CS-606, 607, 618, 619 to the correct position) is from the control room.
ADDITIONAL RESPONSE:
In our initial response, we committed to a Technical Specification on the con-trol switches for the RHR temperature control valves to ensure that they are in the proper position for the ECCS function when in modes 1, 2 and 3.
We will alarm the control switches when in the modulating position to assist the operators in meeting this technical specification. The alars, will be part of our bypassed and inoperable status monitoring system that follows the guid-ance of Regulatory Guide 1.47.
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t FINDING 6-14: PCCW SYSTEM FAILURE
- The design ofithe PCCW system violates position C.4 of Regulatory Guide 1.75, Revision 2, in that the loads on the associated circuits are unqua-lified and analysis has not. been conducted to address the potential de-grading effects of the unqualified components to ensure that Class IE cir-
.cuits are not degraded below acceptable levels.
RESPONSE
The Seabrook associated circuit philosophy is in compliance with require--
ments .of IEEE Std. 384-1974, Section 4.5. This. section provides three al-ternatives and requires that the design shall comply with one of these.
For Seabrook' we chose alternative (1) which states that the associated cir-cuits shall be uniquely identified as such and shall remain with or be.se-parated the same as those Class IE circuits with which they are associated."
Regulatory Guide 1. 75,' Revision 2, Section C.4, endorses this approach.
' s ,
'The finding states that " United Engineers did not conduct an analysis of the potential degrading effects of the circuits connected to non-safety re-lated -components to' ensure that safety related circuits are not degraded below acceptable levels." We like to point out that the performance of an analysis is the requirement of alternative (3) of Section 4.5 of IEEE Std. 384-1974. Since Seabro'ok ha's ' chosen alternative (1), we do not see any -
- violatien.as stated in the finding.
The finding 1 described,a scenario which appeared to show a degradation of Class;1E circuits because of ~ unqualified components. Although this is not
~
required by regulations as described above, we have performed an analysis to show that these Class IE circuits are not degraded below an acceptable level.
The finding postulated a f ailure of a non qualified current-to pneumatic
-converter provided in an instrument loop. .The IDI team postulated that this f ailure could potentially cause excessive current and consequential L hot. shorts between selector switch terminals. It was alleged that.such
. failures could cause inadvertent operation ~ of safety related components placing them in their undesirable positions.
We analyzed the f ailure mechanisms postulated in this finding. Our review indicated that the maximum output f rom the instrument loop electronics is 40 volta de,at open circuit, and 150 mil 11 amperes with a short across the electronics terminals. The GE SBM control switches are rated for 600 volts and the ' instrument cables are rated for 300 volts. The instrument cables ustd in Seabrook ~ design are~ #16 AWG which can carry up to 10 amperes.
Because of limi t ed voltage and current levels available during f aults, no degradation of cables and hence no de t rimental interaction between associated circuits'and' Class IE circuits is possible.
.. . ..s 8B t
FINDING 6-14: PCCW SYSTEM FAILURE RESPONSE: (cont'd)
In general, instrument loops whether class lE or not are powered from a transducer or a low voltage power supply. By nature of its design, this type of device limite the available fault current to a magnitude below that which can cause degradation of- the instrument cable and hence pre-vents any detrimental interaction between class lE and associated instru-mentation circuits.
In order to address possible generic implications of this finding, we intend to further review safety-related instrumentation and controls to substantiate that the Seabrook design philosophy and the design measures
. already in place prevent detrimental interactions such as the ones postulated in the finding. We like to emphasize that this review is over and above the requirement of the applicable sections of IEEE Std. 384-1974 and Regulatory Guide 1.75.
ADDITIONAL RESPONSE
! UE&C is preparing a . formal calculation (No. 9763-3-ED-00-64-F) to document the -maximum credible open circuit voltage (40V) and short cir-cuit (150 ma) f rom the instrument loop electronics (Ref. Westinghouse Pro-cess Instrumentation and Control Instruction Book - NTD Card output cir-cuitry schematic diagram). Seismic qualification of the W output circuit-ry has yet to be established.
In addition to the above calculation, generic studies are being performed in Calculation Nos. 9763-3-ED-00-F and 9763-5-ES-00-1F to preclude degradation of IE electrical, instrumentation and control systems by non-1E compo-nents. The outline of this program is attached to this response.
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, FINDING 6-14:
. ANALYSIS OF FAILURE ON NON-SAFETY-RELATED ELECTRICAL, INSTRUMENTATION AND CONTROL EQUIPMENT PURPOSE This analysis verifies that all credible f ailure modes of non-safety-related electrical, instrurentation and control equipment that is connected to_or directly affects safety-related systems do not degrade safety-related systems prior to a postulated single failure within any safety-related system.
BACKGROUND ,
Safety-related systems are designcd to perform their safety-related function assuming a postulated single failure. The single failure criterion assumes that unqualified non-safety-related equipment have failed in the worst case, credible, acde. .
METHOD
- 1. Identify the design documents for safety-related systems to be reviewed.
- 2. List the unqualified non-safety-related electrical, instrumentation and control equipment that is connected to or directly effects safety-related systems.
- 3. Identify credible failure modes.
- 4. Evaluate effects of failures.
- 5. Justify those effects that do not degrade the performance of safety-related systems.
- 6. Identify any effect that degrades the performance of safety-related systems. Refer to project management for resolution.
- 7. Revise analysis for corrective action to resolve unacceptable effects.
- 8. Document analysis in accordance with QA Program.
SB ATTACHMENT 1 FINDING 6-15: TEMPERATURE CONTROL CIRCUIT ISOLATION loop B t empe ra tu re control ins trume ntation (TYY-2271-2) circuit for the PCCW heat exchangers is lo ca t ed within cabinet CP-152B, whfch contains both Train B safety-related instrumentation card frames and one non-safety-related instrumenta-tion card frame. United Engineers Specification 174-2 requires that whenever an interface occurs between a Class IE instrument loop and a non-Class IE component, a Class IE lsolation device shall be provided to ensure that malfunction of the non-C hss IE component will not affect the proper operation of the Class IE instru-ment loop. The temperature control loop B data sheet supplied by United Engineers to Westinghouse did not specify isolation cards for the non-safety-related TTY-2271-2 temperature centrol loop circuitry. Westinghouse panel wiring diagrams do not show use of safety related isolation devices to isolate the non-safety-related circuit TTY-2271-2, or its associated card frame from the safety-related card frames within CP-152B.
United Engineers has not performed the analysis of non-sa f e ty-rela t ed circuits within cabinet CP-152B to demonstrate that safety-related circuits would not be degraded under accident conditions.
RESPONSE
We have analyzed the associated ci r cui ts external to CP-152B and have determined that failures of non-qualified components will not degrade the internal circuits.
Output isolators are provided that will prevent external faults from affecting the internal circuits. External inputs are from thermocouples or loop powered transmitters that have no failure mode that will degrade the internal ci r cui t s .
Regulatory Position C.4.5 of Regulatory Guide 1.75 is met within CP-152B as all components are identical to similar ccmponents used in Class lE circuits.
Therefore, we have determined that isolators are not required between the Class lE and associated circuits in CP-152B, and will not be provided.
See our response to Finding 6-14 for further discussion of associated circuits.
REVISED RESPONSE:
We are in the process of analyzing the non-sa f e ty related ciruits associated 7
l with CP-152B. We are listing all non-s af e ty-rela t ed inputs and outputs, and are analyzing the credible failure modes. We have determined that all inputs
! are from thermocouples or instrument sources that have low fault potential l that will not damage the internal circuits. The outputs are provided with j ,
output isola to rs or are not damaged by credible faults of the connected loads.
! This analysis is predicated on the non-safety-related components internal to CP 152B being of the same quality as safety grade components and therefore, will provide the isolation function or will not fail during a se ismic event.
This assumption and seismic qualification of the internal components has to be verified by contact with Westinghouse.
l l This analysis will be documented as required by our QA Program. We have assign-
! ed internal correspondence number MM-24272A to track this item.
l l
l l
I
.. ATTACHMENT 1-
.> 3 g
. FINDING 6-30: CONDUlf MARKING 4
The Seabrook. installed and exposed Class IE conduit is not marked distinct-ly and in a permanent manner to identify the separation group at invervals not to exceed 15 feet and at points of entry to, and exit f rom, enclosed l areas in accordance with requirements of the FSAR Appendix 8A, Section 5.1.2; IEEE Std. 384-1974, Section 5.1.2; and Regulatory Guide 1.75, Revision 2, Position C11.
I'
RESPONSE
l i
For the exposed conduits we have taken exception to the 15 foot marking as stated in FSAR Section 8.3.1.4k.
l.
We propose to amend the FSAR as shown in.the attached marked up page to in-dicate the exception to Appendix 8A. The reasons for the exception are out-lined below.
1.
l Regarding Regulatory Guide 1.75, Position Cll, we believe we meet the intent of this position in that our method of identification is simple and adequate.
More details are outlined below.
l l We don't consider this exception to have safety significance for the reasons l outlined below and, theref ore, we did not address it in the evaluation for
( compliance to IEEE 384-1974 (FSAR Section 8.1.5.2).
In the Seabrook-design, all cable trays are marked at intervals of 15 feet 'or l 1ess as given in FSAR Section 8.3.1.4k.. This is required to prevent the l
improper routing of cable since access to a cable tray can usually be made I anywhere along its length. However, access to a conduit for routing cable l is available only at the conduit ends and in-line boxes and, therefore, these I
are the minimum points we chose to identify. FSAR Section 8.3.1 4k, Cable and Raceway Identification, requires that conduits be "... identified at each end where conduit terminates and at both sides of walls, floors and in-line boxes."
The physical separation criteria at Seabrook for conduit from different separa-tion groups is a minimum of one inch. This is in agreement with IEEE Std. 384-1974, Regulatory Guide 1.75 (Revision 2) and FSAR Appendix 8A. Each conduit is installed and inspected in accordance with quality assurance procedures to in-sure that the one inch separation criteria is not violated. The results of the l of the inspection of each conduit is completely documented.
In summary, we believe that the marking of each conduit at 15 foot intervals or less is excessive and unnecessary. The markings provided at the conduit ends, both sides of walls, floors and in-line boxes is suf ficient to in-sure that cables are not pulled into a conduit of a different separation group and are adequate to allow inspection of the conduit to insure a minimum of one inch separation between separation groups.
l
.~
SB ATTACHMENT 1 REVISED RESPONSE:
FSAR Appendix 8A recommends identification every 15 feet for exposed raceways.
FSAR Section.8.3.1.4k requires that conduit be ". . . identified at each end where the conduit terminates and at both sides of walls, floors, and in-line boxes."
which was in exception to FSAR Appendix 8A but was not specifically noted as such.
We will amend the FSAR (see attached sheet) to document this exception.
We feel the intent of the identification requirements given in FSAR Appendix 8A and Reg. Guide 1.75 is to insure that cables are routed into the correct
' raceways and that the plant separation criteria can be correctly implemented.
The following describes how the Seabrook identification criteria meets this intent.
Seabrook identification criteria is documented in the Conduit Notes and Details (Drawing No. M-300228, Note E6). Const ruction Procedure FEP-502, Section 5.3 insures these criteria are implemented. For documentation of QC inspection of the identification tags, a QC inspector fills out and signs the checklist in Exhibit I of FEP-302. Item 15 on the checklist requires verification that the conduit is properly marked and identified. By pro-viding identification at the ends of the conduit where the conduit termina tes we insure the cable can be routed into the correct conduit.
Seabrook separation criteria is documented in the Conduit Notes and Details (Drawing No. M-300228, Note E2) which specifies a minimum one inch be maintained between conduits of dif f erent separation groups. This separation criteria is in accordance with FSAR Appendix BA.
Conduit is installed in accordance with construction procedure FEP-502 with Section 5.2 discussing how the separation criteria should be implemented during construction. For documentation of QC inspection and acceptance of installed conduit, the QC inspector fills out and signs the checklist in Exhibit I of FEP-502. Item 8 of the checklist requires verification that the train separation is correct. If during an inspection, an inspector finds the conduit under inspection is less than one inch to another conduit, he must trace this other conduit to an identification tag to determine its separation train. If it is of the same train, the condition is acceptable. If it is of a different train, it is a violation which is documented and must be corrected before the conduit can be accepted by QC. We feel that this shows the Seabrook identification criteria is sufficient to insure correct train separation. In addition, the tags are simple and preclude the need of reference drawings to identify a conduit which meets the intent of Reg Guide 1.75, Rev. 2.
With respect to IEEE-384 1974, we indicated in FSAR Section 8.1.5.2(a) that we reviewed it to determine if there were any requirements of safety significance that Seabrook did not meet. Since Seabrook's identification criteria insures that cables are routed into the correct conduit and that the plant's separation criteria can be correctly implemented, we did not feel that there was any safety significance to not marking conduit eve ry 15 feet. Therefore, we indicated that Seabrook meets the requirements of IEEE 384-1974.
gg ATTACHMENT 1 REVISED RESPONSE: (Continued)
As mentioned above, we feel one of the intents of raceway identification is to insure'that cable is routed-into the correct raceways. For cable tray, we do specify identification every 15 feet (see FSAR Section 8.3.1.4k) because access to trays can usually be made anywhere along its length and frequent markings are required to insure cables are installed.in the correct tray. Basically, with- respect - to cable routing, we specify the udnimum identification requirements in terms of access points to the raceway:
frequent tray marking because of continuous access to tray and at ends of conduit since these are the only points of access. Additional conduit
. markings at both sides of walls, floors and in-line boxes aid in in-plementing separation criteria.
In summary, we feel that markings provided at both ends and both sides of walls, floors, and in-line boxes are sufficient to insure that cables are pulled into the correct conduit and not one of a different separation group and are adequate to allow inspection of conduit to insure a minimum of one inch separation between conduits of dif ferent separation groups.
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ATTACHMENT 1 SB 1 & 2 Amendment S2.
k' FSAR Mgefg); /g&3, D
! BTP EICSB 27 " Design Criteria for Thermal Overload Protection for Motors of Motor-Operated Valves" i
8.1.5.5 other Standards and Documents The electric power systes is in conformance with the following documentser exGf E as nored ,
ANSI C34.2 -
1968 "Eactifiers" Practice and Requirements for Semi-Conductor "
Power ,d'80k3 ANSI C37.010 - " Application Guide for AC Bigh Voltage Breakers" 1972 ANSI C37.4 - " Definitions and Rating Structure, AC High Voltage 1953 and suppl. Circuit Breakers Rated on a Total Current Basis" of 1958 and 1970 ANSI C37.13 - "Iow Voltage AC Power Circuit Breakers Used in 1973 Enciosure" ANSI C37.20 - "Switchgear Ass'emblies Including Enclosed Bus" 1972 ANSI C37.90 - "IEEE Standard for Balays and Relay System Associated
-( 1971 with Electric Power Apparatus" ANSI C37.91 - "Cuide for Protective Balay Applications to ,
1967 Power Transformers" ANSI C57.12.00 - "Ceneral Esquirements for Distribution, Power 1973 and Regulating Transformers" ICIA No. "Eubber Insulated Wire and Cable for the Transmission l S-19 1969 and Distribution of Electrical Energy" I ICIA No. " Power Cable Ampacities" l~ P-46-426-1962 ICIA No. "Aspacities - Cable in Open-top Cable Trays" P-54-440 - 1972 ICEA No. " Cross-Linked Thermosetting Polyethylene S-66-52) .
1971 Insulation for Power Cable Rated 601-15,000 Volts" g
- NEMA MC " Motors and Cenerstors" 6 1972 Attachment "C" of AEC letter dated December 14, 1973, entitled " Physical <'M g N Independence of Electric Systems" (See FSAR Appendix 8A). For esecg6Tren To C l. 2 on c.onduir merkings nee FSAR SecAw 8 3,/.4 k . *
' Documents Applicable to Equipment Purchase Orders - The issue of the. documents g listed above in effect on the date of the purchase orders are applicable ,
(' when supplying equipment / services against the purchase order.
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, , 22 '6 8.1-9 .
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.. ATTACHMENT 2
[3]()CCEL Covjoraf'on Ss 1 s a
( "AR g 9, gny y 028
( D s 54 s , l i3 X d S V E N APPENDIX 3F VERIFICATION OF COMPUTER PROGRAMS USED POR STRUCTURAL ANALYSIS AND DESIGN Computer programs used for structural analysis and design have been verified according to the criteria described in the US NRC Standard Review Plan 3.8.1,
-Section II-4(e).
(a) The following computer programs are recognized in the public domain, and have had sufficient history 'to justify their applicability and validity without further demonstration:
Opera M ys.
Hardwar ,
Sourc V STARDYNE CDC cope 3.4 CDC
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STRU-PAK CDC S CDCf/)
System Professional CDC CDC ANSYS cpc cbc S TEUOf- t/ccEt. PS DI UEMENU UccEl _
UCCEL ywe r a h f [/) h CDC - Control Data Corporation P. O. Box 0, HQWO5H Minneapolis, Minnesota 55440
( (2) PSDI -Programs for structural Des /fn jIh C *
\ 4 19- Sky Streef Cambridse, Mass. 02/38 l
i (b) The following computer /prolgrams have been verified by solving test problems with a similar and independently-written and recognized program in the public domain:
SAG 058 (Response Spectra)
A susmary of comparison results is shown in Table 3F-1.
A X ?. rom A ve ron cde(Axl n rnenuaf syco m tn ebt c. Shel/ Proanny Ax 2 cv Y;
60mAlto, either ANSY.s o ockheed e Bo.htSon ss/a and Goace. G ~
9hd from R i
Polo Ca.) can 4s obtame .
Corp., noo Granc/ Ave.,3v.t Ne w//e Is/,f Ath furffa, yn,.
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(c) The following computer programs have been verified by-comparison with analytical results published in technical literature:
SAG 001 (WILSON 1) .
SAG 010 (WILSON 2, DYN)
Summaries of comparison resulta are shown in Tables 3F-2 and 7
3F-3,~respectively.
(d) The following computer programs have been verified by
, comparison with hand calculations for test problems which are representative of the type used in actual analyses:
SAG 008 (TAPAS) i SAG 017 (FOUREXP)
SAG 025 (SECTION)
- pff-%& (LESCAL)(srAA P) c A summary of comparison results is shown in Tables 3F-4 through 3F 8.
(
(e) The following computer programs are verified by inspection of the graphical output data.
SAG 054 (Response Envelope)
A typical verification example is presented in Table 3F-9.
9k Docu n,, tano,, sf 37pA P n gvaihd/e a, &
FSA R fsr lato/ma Power us/ bg7' 4.,
- US NRC Do&t Ms.
Sv- 31y ,i,) r8.n r ,
L.'
~11/12/84 ATTACHMENT 3 FSAR Changes Required by IDI Findings Finding FSAR Changes Status 2-9 Table 6.3-1 W to provide table update one month after completion of UE&C calculations (11/16/84).
2-18 8.3-29 Dev. 379 - To be incorporated in Amendment 54.*
2-21 App. 3A To be updated following completion of pipe break analyses (3/29/85).
UI2-2 Table 6.3-1 (See F2-9).
3-1 Table 6.2-75 Dev. 343 - To be incorporated in Amendment 54.
(Sh. I and 2) 4-1 3.8-120, 3.8-121 Dev. 364 - Incorporated by Amendment 53.
4-3 Tables 3.3-4, 3.7(B)22 4-10 App. 3F Dev. 384 -- To be incorporated in Amendment 54.*
6-30 8.1-9 Dev. 368 - To be incorporated in Amendment 54.*
4-2 3.8-100, 3.8-122 Revised IDI response commits to revising FSAR to reflect minimum live load conditions. No date established for FSAR update.
~
- Marked up FSAR page provided with SBN- 731
_. _ - _ _ , -- - - . - .