ML20100H212
| ML20100H212 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/25/1985 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| GL-84-24, IEB-79-01B, IEB-79-1B, P-85103, PL-85103, TAC-42527, NUDOCS 8504090060 | |
| Download: ML20100H212 (11) | |
Text
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P.O. Box 84o Denver, CO 80201- 0840 OSCAR R. LEE VICE PREslDENT March 25, 1985 Fort St. Vrain Unit No. 1 P-85103 Regional Administrator Region IV U. S. Nuclear Regulatory Commission M27E 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Attn: Mr. E. H. Johnson DOCKET N0: 50-267
SUBJECT:
Certification of Compliance to 10CFR50.49 (Generic Letter 84-24, G-85022)
REFERENCE:
PSC Letter dated February 4,1985 Lee to Johnson (P-85033)
Dear Mr. Johnson:
This letter is Public Service Company of Colorado's (PSC) response to the NRC's December 27, 1984 order concerning certification of compliance to 10CFR50.49 (Generic Letter 84-24).
Summary of Previous Submittals PSC has previously submitted many letters concerning environmental 3
,4g qualification of safety related equipment, either as follow up to g a.
- meetings, in response to IE Bulletin 79-01B, or in response to 10CFR50.49.
The following summarizes those previous submittals:
- s PSC Letter dated June 15, 1977 Millen to Denise (P-77137) 1.
Summarized PSC's Seismic and Environmental Qualification
/
og Program.
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2.
Summarized review on seismic qualifications of Class I (Of p ytd,p.bp\\
equipment and environmental qualifications of safe shutdown equipment, N
3 3.
Established corrective action for unqualified Class I ff equipment.
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' PSC Letter dated June 12, 1979 Fuller to Seyfrit (P-79124) 1.
Determined :the matter of environmental. qualification closed l
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. with Amendment:18 to the Facility Operating License DPR-34.
-2.
Listed Erelevant correspondence between PSC and the NRC
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during the : review of the Fort -St.
Vrain ~ Environmental Qualification' Program by NRC-NRR and NRC-I&E Region IV with PSC in 1977cand 1978.(Attachment "A" to P-79124).
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~ PSC Letter date' March 18, 1980 Swart to Seyfrit (P-80051) d
- 1..
Included -computer lists -similar to IE-79-01B Enclosure 2.
(Attachment "A" to P-80051).
'2.
Discussed' plant: equipment numbering.
(Attachment "B" to P-80051).-
i 3.
Discussed areas not applicable to a High Temperature Gas-Cooled Reactor-(HTGR),
including ) radiological details of DBA#1.
(Attachment "C" to P-80051
-4.
- Discussed steam line.. accidents ~ including report entitled
" Environmental Temperatures in the. Vicinity of the Rupture Point-of Steam Lines for Fort St. Vrain Equipment Qualification."~ (Attachment "D" to P-80051).
PSC Letter dated April 11, 1980 SwarttoSeyfrit(P-80078) 1.
Summarized items from March 18, 1980 submittal that were t'
previously accepted by NRC letter dated October 28, 1977
' Denise to Fuller;: G-77076 (Attachments "C":and "D" to P-80051).
2.
UpSated computer lists (Attachment "A"
to P-80078)'and submitted preliminary Component Evaluation Work Sheets.
j PSC Letter dated April 18, 1980 Swart to Seyfrit (P-80090)
-1.
Updated computer lists (Attachment "A"
to P-80090)and Component Evaluation Work Sheets.- -
2.
Finalized Emergency Procedures review.
i 23.
Clarification of Component Evaluation' Work Sheets.
PSCLetterdated' October 3,1980. Fuller ~toSeyfrit(P-80350) 1.
- Commitment to, completion ~ of environmental qualification
' records review, i
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Ccmnitment to completion of enviraranental testing of generic items.
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Revised emputer lists- (Attachment "A" to P-80350) and Cmponent Evaluation Work Sheets (Attachment "E" to P-80350).
4.
Discussion of areas not applicable to a If1GR, including aging.
PSC Letter dated May 17, 1983 Lee'to Collins (P-83178) 1.
Sunanarized previous subnittals.
2.
Described methods by which safety related equipnent is identified.
3.
Reviewed areas not applicable to a HIUR.
4..
Provided a schedule.for empletion of environmental qualification records audit.
5.
Provided a schedule for environmental qualification.of safe shutdown equipnent and Regulatory Guide 1.97 Category I and II equipment.
6.
Provided a Justification for Continued Operation (JOO) for operation with three items not fully qualified.
PSC Ietter dated August 15, 1983 Brey to Collins (P-83280) 1.
Updated status of environmental qualification records audit.
2.
Provided JOO for six omponents not fully qualified.
In a PSC-NRC meeting in February 1984,. PSC presented for NRC consideration its position, exception and - overall rationale for envirorsnental qualification of electrical equipnent at Fort St. Vrain.
PSC Ietter dated February 28, 1985 Warembourg to Johnson (P-85065) 1.
Subnitted PSC's report on Regulatory Guide 1.97 instrinnentation.
Fort St. Vrain Environmental Oualification (EO) Program
'Ihe Fort St. Vrain environmental qualification program was established-to ensure safe reactor shutdown.following Design' Basis Events. The specified Design Basis
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Events were a emplete offset rupture of a cold reheat line in the Reactor Building,- and a ' omplete offeet rupture of a hot reheat line in ' the Turbine Building.
In the various subnittals, -PSC made every attenpt to set forth the basis of our EQ program and to set forth differences between Fort St.
Vrain requirements and.
those being prmulgated by 10CFR50.49 -as well as provide pertinent information for NRC evaluation'in response to various bulletins and generic letters.
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R ese areas were discus'sedlin our March 18, 1980 subnittal P-80051, our October
'3, 1980 subnittal P-80350,- and our May' 17, 1983 subnittal P-83178.
For
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~-convenience, similar discussions are repeated below
.W e' FSV HIGR does not have a containment building; n 1.
Prer. Jure:
therefore,' there is no ambient pressure buildup.
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Relative, Humidity:
During an HEIB event the high energy steam
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- 2.. Lbeing released is in the high quality (dry) range.
During the qualification' testing of equipnent for.use at FSV, steam is used to provide the test environment, _thereby exposing the test sanple to'a humidity level similar to actual event conditions.
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' Chanical Spray: Chemical sprays are not utilized at FSV.
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Radiation:
Because the process fluid is not contaminated, there i
are no radiological concerns directly associated with a High l~
Ehergy Line Break (HELB) at FSV.
Our October 3,' 1980 subnittal, P-40350, concludes that the reactor building will be accessible for short term operations-following DBA#1.
It further concludes that' the acetamilated doses incurred during DBA#1 would have no operational effect on equipnent in the Reactor Building.
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Subnergence:
. Water,is not.used as.the ' primary coolant for shutdown nor is it used for emergency core spray;, in addition,
- the. voltane - of the keyway is large enough.to. a +-
A te -large quantities of water. Werefore subn%s is not a concern.
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Aging
~PSC has concluded, in our October 3, ~ 1980 subnittal, P-80350, that we have an adequate basis for taking exception to the aging requirements.^ This conclusion is based on the following-l argtanents:
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Forti St.~ Vrain does.not utilize a conventional containment L
_ building.
.Thus, harsh environmental conditions do not exist for-i
_long periods of time.
f Fort St.
Vrain' does not utilize dedicated : emergency cooling systens. - The normalL reactor cooling, systems.are also sthe j
emergency cooling systems.
The advantage here lies in the fact-i-
that the safe' shutdown cooling systems are operated in the course 1
' of normal operations..
This. eliminates the-question of--the reliability of infrequently used safety systens.. Maintenance is performed as required to ensure continued reliable operation. -
Since - the FSV HEIB is short term in ~ nature, r and yradiological' concerns minimal, access to any location in the. plant is possible shortly _ following an accident.
Redundant JForced Circulation Pooling equipnent is' physicallyn located-in idifferent' areas to preclude failures from a single'-
accident.
Additional assurance _is_ provided _by valves with e
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- manual overrides' and/or " designed failure modes" to ensure thheir proper: operation following an accident.
4 Wefavailability of access coupled with the. time available to
-restore Forced Circulation Cooling provides desirable flexibility inLterms'of manual overrides and maintenance.
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The PCRV Liner Cooling system -has redundancy.and physical separation to preclude failure frm a~ single accident.
g In the unlikely event that the mrmal power supply to the PCRV Liner Cooling. system fails,. backupower is. available_ via the
' Alternate' Cooling Methods (ACM) system. The controls and cabling for thi.s. system are physically separated-frm normal emergency 1
- equipnent.
Because of the above reasons, Fort St.
Vrain has adequate means of protecting the health and safety of the public, should " aged"
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-equipment fail during a HELB.
EQUIPMl!NP OlRLIFICATIONS
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- PSC has recently cmpleted an audit of our environmental qualifications records.
F This. audit revealed a total of nine items that were not _ fully qualified or i-Lreplaced.
All units were subsequently tested and qualified.-- As part of this
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auditfor records were placed in a'more auditable' form.
3 There-are. presently several methods -utilized to identify _ safety. related
.equipnent and their respective qualification requirements.
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-A'. general listing of Class I and Safe-Shutdown systems and equipnent is provided in the FSAR, Section 1.4.
-2.
Special syntols.cm Process and ~ Instrunentation (P&I) diagrams, Instrunent - Block (IB) diagrams, and Instrument and control (IC) i diagrams identify safety related instruments,_ process lines, and class boundaries.
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Electrical schematic diagrams highlight the exact circuitry that nust i
. function in order to provide a safe. shutdown.
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% e Safety Related Canponent List. (SR-4-2 ) _ identifies. specific l
equipnent and. instrunents that are. safety related.
SR-6-2 also.
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definest the environmental; qualification requirements 'for~
safety 2
related instruments and equipment.
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Design Directives 1are__used to provide guidance in detercining the enviru._ Ral' qualification requirements. of new equipment.
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%ese -design inputs,+ coupled with nunerous reviews of proposed ' plant design.
changes, ensure _ environmental. qualification in accordance with the FSV EQ program for all' new equipment..
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Modes of Safe' Shut'down Cooling'
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i'Ihe primary methods of core cooling used.at' Fort St. Vrain is Forced Circulation iCooling.. Forced Circulation Cooling consists of two redundant loops each with dtwo helium circulators and one steam generator.
-Each z circulator has two independent sources of motive power:
_.a steam turbine
-. drive t-which =is normally used,. and 'a backup water turbine drive.
Attachment A aidentifies six separate methods of supplying notive power to each circulator.
. Each steam gevrator. has two sections:
an +,--miver,_ evaporator, superheater (EES)' section, and.a reheater section.
There are five methods of supplying water-'to the EES,- and two methods of supplying water to'the reheater.
These methods are shown crt Attachment A.
One helitan D cir6ulat.or and either the' EES or reheater section of. the steam.
_ generator 7 in ;the same loop is capable of providing adequate heat removal following a" scram frcan full load.
Our~ recent audit of our. environmental qualification remrds has verified that all-of. the electrical:equipnent required for the proper operation of both loops of : forced circulation cooling has been qualified in accordance~with the ESV electrical equipment qualification program.
't In addition to Forced. Circulation Cooling, the core can be cooled;using the' PCRV liner. cooling system.
'Ihis method provides adequate core cooling in~.the. event of a permanent. loss of forced circulation cooling. Although' this _ accident would -
result in extensive' fuel damage, depressurization of _the PCRV and. continued PCRV
. liner cooling would protect the health and safety of the public..
Qualification of 10CFR50.49 Eqnir==nt 10CFR50.49(b)~; identifies the-electrical equipment that is required to be environmentally qualified these are:
1)
Safety related equipment.
2)- Non-safety related. equipnent whose failure could' prevent the
' satisfactory accomplishment of safety. functions.
- 3). Certain post-accident monitoring equipnent'.'
'Ihe Fort'St.,Vrain Nuclear Generating Station'is~ designed for perfomance of the~
required safety functions in ^ case of earthquakes and tornadoes.1 Equipnent which has 'a safety function under those conditions is designed and qualified to : the; requirements yapplicable~ to.' Class ILitems.as-specified: in.,the ~ ESAR. -
The-remaining.equipnent:is Class II.
Only Class.I Wir=mt is troquired' to perform a ' safety function in thel event of -
L a High Energy Line Breakr, therefore, cmly the Class I-electrical equipment itens require. consideration ~of ~ environmental = qualification? under:-the1 scope ;of
,10CFR50.49 3 'IheL applicable! environmental qualification requirements for-the 7
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electrical equipnent vary depending-on item. location and function;
'In accordance with 10CFR50.49 paragraph c(iii), Class I items 'not
. exposed : ' to - a severe environment.do not reqaire environmental qualification.
Class I litens required,for safe shutdown (Safe Shutdown equipment) that are
. exposed to a High Energy Line Break (HE[B) are required to be qualified for that i
. environment.
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'AllL Class I items required for safe shutdown exposed to a HELB have been
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qualified-in' accordance with our BQ program.
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Our. recent audit of environmental qualifications records has determined that electrical failure of Class -II equipnent due to a HELB cannot prevent Class.I electrical iequipment from performing their safety functions.
The audit also
. verified; that any u,w.nt that has an effect on a Class I function is. itself w
defined as'Clas's I.
Special designations are ' assigned to cortponents that nust j.
either maintain system pressure boundary or electrical circuit continuity.. Such u w ::nts are qualified accordingly.
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PSC~ iletter Warenbourg to Johnson dated. February 28, 1985 (P-85065) identifies o
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the 'instrunentation required' for Post Accident Monitoring (PAM).
Regulatory Guide l.97.' specifies that Category I and Category II instrunentation
-nust bec environmentally, qualified.. All of our Category I Land Category II.
b instrunentation identified in P-85065 is qualified in accordance'with our EQ program.
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-Specific Generic Letter 84-24 Concerns i
IE Bulletin ^82-04:
Research determined.that Bunker -Ramo penetrations'were-not i
used !at FSV.'
This was: attested to in PSC letter Iee ~to Collins dated j
I December 29, 1982l(P-82563).
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IE-Information Notice 11:.
A review by our _ staff has determined no Westinghouse pressure instrunents are used in' safety related systems at FSV. -
IE Information= Notice 82-52:
A staff review has determined thatonene of, the equipnent concerned is used at FSV.-
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Our staff has determined that we do not-use 4
' position 2.CR-2940 switches..
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'IE Informationi Notice 83-72:
We have determined that _none of the % equipment failures are of! concern to'FSV.
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. IE Information~ Notice 84-23: -
Research has verified that.these solenoid' valves -
are not used at FSV in any safety related application.-
IE Information Notice 84-44:' ~All cables used in HELB' areas have been qualified by our EQ r up 46..
IE Information Notice 84-47: [ Terminal blocks used at FSV. have beeniqualified in'
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.accordance'with our environmental qualification program.
' IE:Information ' Notice 84-57:-
Although,- as-a result of our envirarsnental test
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iinvestigating the possibility of inproving maintenance procedures to ensure
< protection' gainst moisture intrusion.
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- IE Inforbatidni Notice 84-68:
!Research has shown that we do not-use solenoid Kvalves with a similar design to those identified.
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' IE Information. Notice. 84-78:
The concerns'of underrated terminal -blocks in
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Limitorque operators.are similiar to those raised in Information Notice 83-
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- 72..We have determined this_ is not a problem at FSV.
Sunanary and Certifications L
Our environmental, qualification program was established to ensure safe sh'utdown j
- following postulated Design Basis' Events.
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. 'Ihis s wtan has taken into consideration and applied, as applicable, areas of concern addressed in 10CFR50.49. Among these' ares. pressure,' relative humidity, chemical spray, radiation,.sutsnergence and aging.
-Although PSC has not filed-i, any specific exemption requests, PSC's program and positions have'been set forth l
to,the NRC on several occasions, both in correspondence and in meetings in an j
attempt to reach'a mutual ~ understanding between PSC and NRC on our environmental-pt @t an.
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PSC ~ utilized..several. methods to' ensure that all new. equipment. installed is l
properly qualified as required by'our EQ program.
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The primary means,of core cooling at Fort St.
Vrain =is.. forced' circulation l
cooling.
Both.. redundant. loops are fully qualified in accordance 'with our EQ program.a
, of;'our'equignent which PSC has determined -is required.to be qualified has All I.
been qualified by;our EQ program.
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-All of-the specific action items identified in Generic Intter184-24 have been address'ed.-
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4 Based! on our positions: stated 'herein, ;we feel that we are in ffull? 'ompliance I
" with 10CFR50.49L asiit applies'to the FSV HIGR.i j -
Very;truly yours,:
4' 0.R '
Vice President
. Electric ProductionL Attachment.
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ATTACHENT A SIMRRY OF EDRCED CIRCUIATION COOLING REDUNDANCIES Number of Cooling Inops 2
Number-of Cooling Sections per Icop
-2 (EES* & Reheater)
Sources of Water to EES* '
Equipment locatial 1.- Normal Feedwater (3 EW Pumps)**
TB2 2.
Feedwater.via Bnergency Feedwater (3 EW Punps)**
TB2 Line 3.
Condensate via Emergency (4 Condensate
'IB2 Condensate Line' Pumps)
~4.-
Firewater via Emergency Feedwater
-(2. Fire Pumps)***
.Line
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- 5.. Firewater via Emergency (2 Fire Pumps)***
OPL Condensate Line Sources of Water to Reheater Equipnent Iocation 1.
Condensate via Emergency (4 Condensate TB2 Condensate Line Punps) 2.
Firewater via-Dnergency (2 Fire Pumps)***
. Condensate Line Number of Circulators Per~Icop 2
Sources'of Motive Power to-Equignent '
Incation Circulators 1.
Cold Reheat Steam main turbine steam
.. IB2 2.
Auxiliary Boiler Steam' (2 Auxiliary
. TB2 p-Boilers)-
3.
Feedwater via Emergency (3 EW Pumps)**
_ 'IB2 Feedwater Line
- 4. - Condensate via Emergency-(4 Condensate lTB2' Condensate Line Pumps) t e
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[5.: 1 Firewater. via' Bnergency (2 Fire Pumps)***
OPL Feedwater-Line
. 6. - Firewater via Emergency (2 Fire Punps)***
. Condensate Line.
- Eccmcmizer-Evaporator-Superheater
- 2. Steam Driven,~l Electric' Motor-Driven
- 1-iDiesel. Engine Driven, 1 Electric Motor-Driven OPG = Outside.of Plant.
'IB2l= Turbine Building IRB Enviturnent RX2_= Reactor Building IEB Environment
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UNITED STATES ~0F AMERICA'
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NUCLEAR REGULATORY COMISSION 4
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.In the Matter
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PublicService;CompanyofColorado Docket No. 50-267 Fort St. Vrain Unit No. 1 AFFIDAVIT 3
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.0.. R. Lee, being duly sworn..hereby deposes and says that he is-Vice' President of Public Service Company of Colorado; that -he has read the letter regarding Certification of Compliance to 10CFR50.49
- (Generic Letter 84-24) and knows the content.thereof; and that the matters set forth therein are true and correct to the best of his knowledge,.information and belief.
- 0. E. Lee Vice President 6
STATE OF' GM
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COUNTY OF h
A Subscribed:.and swornL to before me,(a Notary Public.on this1 2 F day of MA
, 1985.
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- My commission expires- (/ufM /1
,1982 -
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